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• (4a)h) A detailed description of the methods and means to protect and monitor all aquifers <br />AMSO's plan is to avoid aquifer impacts rather than to remediate contaminated aquifers. The <br />targeted Illite Mining Interval lies below the aquifers and is isolated from the aquifers by a <br />protective cap of nahcolitic oil shale. AMSO believes it can develop and commercialize shale oil <br />recovery from the Illite Mining Interval in a manner that avoids significant impact to the <br />overhead nahcolitic oil shale, to the higher oil shale resource, and to the aquifer resources. <br />AMSO has determined the critical aquifer characteristics above, within, and below the R-1 Test <br />Retort interval. Based on these results, AMSO will design, construct, and operate retort tests <br />within the mining interval in a manner that protects all aquifers that may constitute an <br />underground source of drinking water (USDW). Such aquifers are known only to exist well <br />above the mining interval. An aquifer within the mining interval is unexpected. Aquifers are <br />known to exist below the mining interval in some locations in the basin but not in other <br />locations. It is important to note that the water quality in aquifers below the Dissolution Surface <br />generally precludes those aquifers from being classified as a USDW. <br />A Ground and Surface Water Monitoring and Response Plan has been prepared using site <br />characterization results (see Appendix 4-10). Down-gradient Wasatch, L3, and B-Groove <br />monitoring wells will be constructed and used to establish baseline, confirm the success of <br />AMSO's ground water protection effort, and to discover unexpected results. <br />Early detection of unexpected results is accomplished using nearly continuous measurement and <br />• recording of piezometric pressure in the monitored aquifers. Pressure changes transmit nearly <br />instantly and are proven as an early detection method for similar applications in the basin. Long <br />term trends are established by quarterly sampling and water quality evaluation. Pre-operational <br />water quality sampling and evaluation will establish a statistically consistent baseline. Monitor <br />well sampling and evaluation will be performed quarterly during operation, quarterly for a one <br />year period following operation, and annually thereafter for an additional two year period. <br />One pre-existing well has been completed in the L-3 on well pad MWP 1 up-gradient from the <br />Test Pad area where retorting is to take place. The L-3 aquifer will also be monitored up <br />gradient on well pad MWP 1 and down gradient on well pad MWP 2. The L-3 is the aquifer <br />immediately above the Dissolution Surface and thus nearest the test retort. The L-3 water quality <br />is very poor, but the L-3 will be monitored in both the baseline and operational periods to <br />confirm no aquifer impact has resulted from the test retort. <br />Although water is not anticipated in the Wasatch Formation, a monitoring well has been installed <br />in this formation on well pad MWP 2 pad down-gradient from the Test Pad. <br />The lowest portion of the previous USDW aquifer overhead of the Test Retort is the B-Groove, <br />which will be monitored downgradient from the Test Retort during the baseline, operational, and <br />post-operational periods. <br />C? <br />43