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Mr. Travis Marshall <br />August 18, 2008 <br />Page 3 of 5 <br />open (pending downhole activities) by either installing casing or a packer seal. If a packer seal <br />is installed, potentiometric measurements will be used to confirm the integrity of the seal. <br />The well-completion plans seem to indicate that monitoring wells will be left as open holes in <br />the monitored intervals, rather than equipped with screened intervals. If so, what types of tests <br />will be performed; and what methods of sample extraction is proposed? <br />AMSO Response: <br />Open-hole well completions are commonly used for monitoring wells within the Piceance <br />Creek Basin, particularly for wells completed within the Parachute Creek Member. AMSO <br />assumes that the tests referred to in the comment refer to the types of hydrologic test that will <br />be performed in the completed well. Several factors will be used to select the specific tests to <br />be performed on the wells, including our experience testing similar water-bearing units within <br />the basin, depth to the monitoring interval, evidence of entrapped gas in water within the <br />interval, the range of permeabilities expected within the interval, and expected quality of water <br />within the interval. Pumping tests may be conducted which will provide the opportunity to <br />collect samples for groundwater analysis during the test If pump testing is not considered <br />desirable because of the depth to the interval, excessive gas, anticipated low permeability, or <br />poor water quality impacting water management and disposal, alternative methods will be <br />considered, such as using water, air, or nitrogen to pressure the test interval. <br />The same criteria used to select the proper testing methods will also be used to select the <br />proper sampling methods for the wells. Methods will be evaluated on a per well basis and will <br />include such sampling methods as submersible pumping, nitrogen lifting, and micro-purging. <br />4. For water quality sampling; please submit the proposed sampling and analysis plan, a list of <br />proposed analytes, and a plan for establishing and characterizing pre-operational background <br />water quality. <br />AMSO Response: <br />Please see enclosed AMSO Sampling and Analysis Plan for Surface-Water and Groundwater <br />Monitoring. <br />5. The NOI states that water generated during drilling and hydrologic testing will be handled in <br />the same manner as drilling waste. Does this mean that water that does not evaporate is to be <br />transported off site? <br />AMSO Response: <br />Yes, AMSO is prepared to dispose of all water generated during the Phase I effort that does not <br />evaporate by transporting the water off site for disposal at a facility authorized to receive such <br />waste. Water generated during Phase I would be disposed of on site by discharging to an <br />unlined pit or the ground surface and allowing it to infiltrate only if it is demonstrated that the <br />water meets the quality requirements for land disposal and such disposal has been approved by <br />110 East 3 Street, Suite 201 P.O. Box 1470; Rifle, CO 81650 Phone: 970-6254324 Facsimile: 970-625-4318