Laserfiche WebLink
<br /> <br />may not be in the direction that the Monitoring Program study design has assumed. And, changes <br />in the wncemrations to be monitored have followed General Chemical's expression of concern <br />about the reporting levels initially contained in the Monitoring Program. <br />As important, American Soda continues to conduct pilot plan operations. These <br />operations themselves may affect goundwazer quality. This should not be a possibility under the <br />plain language of the Colorado Mined Land Reclamation Act, which both requires a permit in <br />advance of mining operations, and which specifically defines mining operazions to include <br />developmental activities such as a pilot plant. The continued existing operation of the American <br />Sode pilot plant is a po'urt that was explicitly raised and ignored in General Chemical's letter of <br />May 28, 1999. <br />Further, while the DMG has characterized the Monitoring Program as °rigorous° in <br />response to Comment I I, the third party validation by USGS appears to be limited to handling <br />and testing of samples, not to proper completion of wells, or to an evaluation of other potential <br />defects in the Monitoring Program. If bad data is caused by errors in the completion of the <br />monitoring wells, for example, these errors cannot be cured simply by rigorous handling and <br />testing of samples. They can only be cured by proper completion of the monitoring wells, which <br />in turn may require mare than satisfying the performance-based standards for well construction <br />which ase designed to prevent commingling of aquifers. <br />The potential for errors unrelated to USGS handl'mg and testing is enhanced by the Fact <br />that American Soda benefits from testing which establishes poor ambient quality. As the DMG <br />