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Letter to Kurt Nielsen 3 April 18, 1999 during that year was appropriately cased and cemented to prevent comingling of aquifers and transmission of process solutions outside the casing. Each well should be tested prior to operation. Please provide a detailed description of the mechanical integrity testing methods that will be employed. The certification of the wells should include an installation report with reference to American Petroleum Institute (API) standards or other standards as applicable. Similarly, the DMG will require submittal in the annual report of a certification and abandonment report for each well that is abandoned and plugged during the project year. c) DMG is concerned with the potential for loss of containment do to leaks in the surface piping system and the potential for adverse impacts to soil, vegetation, and habitat that may result. Please provide a description of piping system monitoring that will be conducted to prevent or minimize these impacts. What will be the frequency for visual inspection? How will these inspections be documented? Can pressure fluctuations that may be indicative of leaks be monitored and alarm or automated shut-off systems be triggered? Provide a description of the systems that will be used. In each annual reclamation report the DMG will require certification of the proper installation of all well field piping for the report year. The certification should be signed by a professional engineer or other qualified person (e.g., a journeyman stream fitter) and should reference API or other appropriate standards for pipe and valve installation. The report should also include certification that all piping salvaged for reuse was tested and found to be sound and should describe the testing and acceptability criteria applied to salvaged pipe. d) It is the DMG's understanding that any spills and runoff from the Piceance Site processing facilities area will be directed to the evaporation pond or, alternatively, to a lined storm water pond, the design for which a submittal to the application is forthcoming. DMG further understands that topsoil will be completely stripped from the facilities area and stockpiled in a location where it will be isolated from the potential adverse effects of any spill within the processing plant. Please affirm that these design strategies will be employed and provide a description of the structures that will be in place (e.g., curbing, drains, and sumps within buildings and berms, ditches, culverts outside buildings) to route spills and runoff to the pond or ponds. 3. Provide a ground water monitoring plan as a technical revision to the application (Rule 1.8). The DMG has determined that the ambient ground water characterization plan detailed in the draft Ground Water and Surface Water Monitoring Plan dated April 1999 is generally acceptable under the requirements of Rule 3.1.7 if the changes specified in the DMG letter to Paul Daggett dated April 12, 1999 and in the attached DMG internal memo by Harry Posey are incorporated. However, it is emphasized that this plan is considered by DMG to be an ambient ground and surface water characterization plan and not a final monitoring plan. The information obtained through implementation of the l3 month characterization plan will be used to formulate the ongoing monitoring plan and to establish numeric protection levels and points of compliance as appropriate. The ongoing monitoring plan will incorporate actionable levels and will specify actions to be taken if those levels are detected by monitoring. The basis for ground and surface water protection under American Soda's proposed mine plan is to put in place EPFs (practice-based permit conditions -Rule 3.1.7(2)) that will p~eve~u water quality impacts. Hence, changes in water quality at a monitoring point indicative of an