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<br /> <br /> <br />in published literature show that parts of the lower aquifer has natural concentrations of <br />several elements [ha[ would exceed drinking water standards. (The published <br />information includes mostly USGS publications on oil shale from the 1970s, some of <br />which are referenced in the Permit Application.) The lower aquifer in the target area may <br />be under higher hydrostatic pressure than the upper aquifer, if so the tendency for water <br />movement is upwards, from the lower aquifer to the upper aquifer. Unless the lower <br />aquifer remains isolated from the upper aquifer, there is a potential for the upper USDW <br />aquifer to be cross-contaminated by toxic substances from [he lower aquifer, due to <br />mining-related activities. This leads to the determination that the operation should be <br />classified a DMO. <br />b. Based on general geological and geochemical principles, meteoric water in <br />equilibrium with the rocks in the nahcolite zone should develop water quality similar [o <br />water in the dissolution zone. Contact with high temperature water such as proposed for <br />the American Soda operation will hasten dissolution and water:rock equilibration. Thus <br />it is likely that the composition of the process solutions will contain concentrations of <br />elements that will exceed drinking water standards. This implies [ha[ there is a need [o <br />protect both the upper aquifer, the alluvial aquifer, and surface waters from <br />contamination by the process solutions. If the process solutions indeed prove to be high <br />in potentially toxic chemicals, this would lead to a determination that the operation <br />should be classified a DMO. <br />Based on item b, above, the operator should submit information on the trace element <br />composition of the process solutions to help determine how the non-saline waters may need <br />to be protected. <br />3. Analytical detection levels. In various places in the application and supporting documents <br />the operator lists sampling and analytical parameters without indicating relevant detection <br />levels. The operator is advised that for the proposed surface or groundwater sampling and <br />analyses, the analyze list and the associated detection levels should consider the current and <br />potential future beneficial uses of the water. For groundwater, the current and potential <br />future beneficial uses include drinking water and agriculture. The surface waters in the region <br />are classified for aquatic life, recreation, and agriculture uses. The operator should consult <br />the most recent versions of WQCC's "Basic Standards and Methodologies for Surface <br />Water" and "Basic Standards and Methodologies for Ground Water" for a complete <br />parameters list and determine the appropriate detection levels. We understand that American <br />Soda is in the process of submitting this information to the Division, and we will review it <br />immediately upon receipt. <br />SPECIFIC COMMENTS. <br />DOCUMENT TITLE: CMLRB Permit Application <br />1. The upper aquifer occurs in the basal Uinta Formation and in the upper part of the underlying <br />Green River Formation, above the A-Groove marker. The application refers to the federal <br />2 <br />