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<br />Based on the data in the attached graph, it appears that something is occurring in these aquifers, and <br />a reasonable presumption is that this "something" is the test mining operations are the cause of the <br />adverse water quality impacts since no outer activities occur in the area of the monitoring wells. The <br />data seem to indicate that the activity is impacting all three wells, almost concurrently, which would <br />imply communication between the aquifers underlying American Soda's Test Mine Plan area. <br />Another way of looking at the BLM monitoring data submitted by American Soda reveals the same <br />pattern of consistent effect, including a degradation of water quality in all aquifers. The water quality <br />tables provided above and the table which follows, show a time dependent change in several <br />parameters (note that some data are missing due to either poor data gathering or quality assurance <br />problems). <br />Well 20-28 (water supply well) <br />With a BLM limit of 2,000 mg/I. <br />Date Bicarb Total Dissolted Solids Chloride <br /> <br />12-22-98 1,277 1,784 44 <br />11-22-98 2,906 2,135 108.2 <br />09-21-98 2,055 2,055 116.4 <br />06-29A8 2,184 1,870 28 <br />03-04-98 2,OlG M/D 28 <br />12-12-97 2,310 1,180 57.4 <br />10-02-97 I,G80 M/D 36 <br />OI-28-97 793 1,2G0 20 <br />Through the analysis of data provided in response to my FOIA, I believe the Test Mine Plan is already <br />creating adverse water quality impacts. I have attached several tables that compare water quality <br />based on American Soda's monitoring data and regional water quality data. These tables and <br />discussion follow: <br />Water Quality Comparison for Piceance Basin Data <br />Alluvial <br />Bicarbonate <br />Am Soda 21-2 <br />USGS (I) <br />Gb (2) <br />C-a (3) <br />TDS <br />Chloride <br />Max Min A1can Ma: Min Mcan Max Min Mean <br />2806 929 1791 2292 1500 1900 102 14 38.6 <br />3560 336 1220 6720 469 <br />826 250 509 993 69G <br />- - 636 - - <br />1750 270 5.2 42 <br />1600 67 I 15 <br />1423 - - 18 <br />No significant conclusion can be made between American Soda data and other referenced data as concentration generally <br />increases downstream toward American Soda and many of the wells referenced by the USGS. However, anal}'sis ofjust the <br />American Soda data indicates a significant trend toward poorer water quality and raises the question of what is the source of <br />8 <br />