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<br />data appeaz to be anomalous and will advise them that care should be exercised in <br />reviewing these data. The notice sheet will specifically indicate that interpretation of <br />data from well 20-1 is problematic and that the assessment of Lower Aquifer water <br />qualih~ based on these data should be done ~~ith caution. The draft monitoring plan <br />and the notice sheet will be provided to the EPA and the Colorado Division of Minerals <br />and Geology (CDMG) prior to issuance of their respective commercial permits, and <br />documentation of these actions will be provided to RBC. <br />American Soda is committed to working with RBC and the other agencies to <br />cooperatively address their concerns in the ~~roundwater monitoring program <br />American Soda has retained the services of Bishop-Brogden Associates, [nc., a water <br />resources consultant specializing in groundwater, to assist in the development of the <br />final monitoring plan. :~merican Suda will include monitoring provisions for the <br />Piceance Creek Alluvial Aquifer and local springs, as determined through consultation <br />with the various agencies. Specific locations, numbers, and sampling frequencies of <br />these svstems will be determined as part of the final monitoring plan. American Soda <br />intends that the final monitoring program will be a dynamic and flexible plan that may <br />be altered based on the results of future data collection and in cooperation with the <br />permitting agencies. :'lfter the monitoring program is implemented, American Soda <br />will produce annual data reports and provide the reports to the agencies. American <br />Soda will periodically provide analytical results to RBC and other agencies on a timely <br />basis throughout the year or upon request. <br />American Suda is committed to protecting groundwater quality in the Piceance Creek <br />Basin. As we have discussed with RBC end other agencies, American Suda will take <br />appropriate and effective measures to protect groundwater quality including the <br />following. <br />• [ffective well completions to isolate aquifer tivstems, including the use of tubing <br />inside properly cemented casing, lugging to evaluate the adequacy of well completions, <br />and mechanical integrity testing of wells prtor to operation. <br />• Operational monitoring of the pressure and flow in and out of wells to evaluate <br />potential leakage and detect well faiiur~•s. Isolatiuii of the solution minim; cavity is <br />required for the mining process to work. If pressure cannot be maintained on a well, <br />the well cannot be mined. <br />• Establishment of a roof zone above each cavtty to further isolate the mining <br />horizon from the aquifer svstems. TIZe roof zone will be approximately 150 feet thick. <br />• Completion ut a final ;;roundwater monitoring plan that is both economically <br />feasible and technically viable. T11e inonituring plan well include the proper collection <br />Water t>ual,ty 1-Z <br />R,o Blanco l.,unnr Add~mrol INOnninOn Raqu~a~ <br />Piceance Mimnq Upemm~ <br />Amencan Soda. I.LP. <br />