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<br />• Subsidence monitoring plan. <br />• Adequacy of the Designated Operation Environmental Protection Plan. <br />• Mineability of oil shale. <br />These issues were listed in the pre-hearing order. <br />7. At the Pre-hearing Conference, lists of possible witnesses and exhibits For the <br />Final Hearing were submitted by American Soda, L.L.P., and General Chemical Corp. The lists <br />were attached to the pre-hearing order. <br />8. The pre-hearing order was mailed to the parties on June 16, 1999. <br />9. The Board held the Final Hearing in this matter on June 23, 1999, in Denver, <br />Colorado. The Division attended as staff to the Board. <br />10. At the Final Hearing, the Board's attorney presented the pre-hearing order to the <br />Board on behalf of Ms. Kraeger-Rovey, who was unable to attend the hearing. After considering <br />the pre-heazing order, the Board adopted the pre-heazing order as submitted with the following <br />two changes: 1) delete the word "Amendment" from the description of the matter in the caption, <br />and 2) delete "Church & Dwight Co., Inc." from the listing of General Chemical Corp. on page <br />1. Section II. <br />11. In consideration of the presentations made at the hearing, the Board finds that: <br />A. The M-99-002 permit application Designated Operation Environmental <br />Protection Plan meets the requirements of the Act, and the Hard Rock/Metal Mining <br />Rules and Regulations, 2 C.C.R. 407-1 ("Rules"). <br />B. The M-99-002 permit application and reclamation plan adequately protect <br />the future mineability of oil shale pursuant to the Act and Rules. <br />C. The M-99-002 permit application subsidence monitoring plan adequately <br />addresses subsidence of the surface terrain over the mining operation, with the exception <br />that the plan should include subsidence monitoring monuments on the production well <br />casings across the site. <br />l2. The Board heazd detailed and substantive presentations related to the protection of <br />water quality and quantity at the site. After considering the presentations of the parties, the <br />Board finds the following: <br />A. The collection of baseline ground water quality data during the 13 month period <br />prior to the commencement of injection of solution mining fluids, subject to the permit <br />conditions outlined below, satisfies the water quality protection mandate of the Act and <br />the Rules. <br />B. The final ground water quality parameters for the permit must be incorporated <br />through a technical revision process in order to ensure that the baseline data collected <br />