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~ Die: ~ -/~_ g~ ~ ~~~ IIIIIIIIIIIIIIII <br />BEFORE THE MINED LAND RECLAMATION BOARD <br />STATE OF COLORADO <br />PREHEARING BRIEF OF GENERAL CHEMICAL <br />IN THE MATTER OF AMERICAN SODA, L.L.P., YANKEE GULCH MINERALS <br />PROTECT, FILE NO. M-99-002, APPROVAL OF A 112 PERMIT AMENDMENT <br />APPLICATION <br />The principal legal issue presented by this application is whether the proposed <br />Groundwater and Surface Water Monitoring Program, whlch does not itself establish turmeric <br />protection levels, but is rasher intended to generate data which can be used to establish numeric <br />protection leNeLr, cmr satisfy the requirements of statute and Rule. <br />This issue corresponds to the DMG's discussion of Comment Number 20 in its Issues <br />Raised in Public Comments on the Application. It is a legal issue because the main fad is not in <br />dispute. Valid pre-mining ambient goundwater data do not exist. The Groundwater and Surface <br />Water Monitoring Program addresses this fact. The DMG recommends approval of a thirteen <br />month data collection pogam which will be conduced prior to injection of solution mining <br />fluids, but simultaneously with other development activities. <br />General Chemical's Prior Comments <br />Comment Number 20 does not fairly summarize Genera! Chemical's prior comments. <br />General Chemical has consistently objected that American Soda's Monitoring Program proposal <br />is illegal. General Chemical has many years of environmental regulatory experience, and is <br />