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groundwater contamination. This contamination would then become the baseline data for future consideration and therefore inaccurately depicts the true characteristic of groundwater quality. During the drilling process, the zones between the different aqueous zones would be exposed to each other. Without previous study, it would be difficult to assess whether contamination within these zones has occurred. The only method available to protect communication between zones is to case each aqueous zone so that it is isolated and cemented back to the surface thereby preventing communication between woes. Because cementing to isolate an aqueous zone is difficult, it should be carried out and certified by professional, qualified outfits. Failure to properly case a well transitioning through an aqueous woe would allow for communication between the aqueous layers. Case in point, the Applicant is planning on converting holes drilled for core sampling to sampling wells (Groundwater and Surface Monitoring Plan: -Appendix A; Completion detail American Soda -20-10). Once the potential for communication between the aquifers has been minimized the potential for contamination during well development must then be considered. If the Applicant develops the well without a nitrogen blanket, the opportunity for liquid to dissolve a path up toward the aquifers exist. Even if a nitrogen blanket is used, the potential still exists for aquifer contamination. In this instance, as the cavern develops out vertically, ledges of shale could black nitrogen allowing water to dissolve down and around the ledge. Once this occurs, solution is free to dissolve up along the vertical path of any sodium deposit until it makes it way to the aquifer layer. Regardless, since so little is known about solution mining under the conditions proposed by the Applicant, baseline data must be accurate to protect the aquifers and water quality as defined in the statutory requirements of the Colorado Mined Land Reclamation Act. OTHER TECIINICAL GROUNDS FOR OBJECTION Beyond the issues surrounding concurrent development of wells and proper well completion practices, other concerns exist which jeopardize an accurate baseline characterization. We stress once again, a purpose of the reclamation permit is to protect hydrogeological resources. In order to due so, an accurate characterization of that resource must be developed first, using proper well completion techniques and free of influences from the proposed future mining activities. Our concerns are as follows: 1. [Disposal Well Influence On Baseline Data] There has been no mention of the Applicant's operational disposal well in the AAI Groundwater and Surface Water Monitoring Plan or in the original DMG 112 Application. There has been no discussion or response from the DMG related to the fact that the Applicant is injecting highly concentrated saline solutions via a disposal well into the Lower Aquifer without any concern for the potential adverse effects from this practice. Since baseline data has not been developed, this practice is already influencing the baseline against which the Applicant would be judged. Furthermore, the impact on water quality and aquifer pressure gradients is not understood. This practice should not be allowed given that the baseline water quality data is not yet developed.