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