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(c) Water samples collected from NSI monitoring wells are sent to ACZ Laboratories, Inc. (ACZ) in Steamboat Springs, CO for laboratory analytical analysis. ACZ is a qualified analytical laboratory with equipment sensitivities that meet industry standards for analyte detection limits. NSI's well construction and monitoring program ensures that groundwater contained within the 4 aquifers is protected from potential cross - contamination and potential contamination associated with solution mining operations. (10) Surface Water Control and Containment Facilities Information (a) In 2010 the DRMS determined that NSI's sodium bicarbonate (baking soda), in situ, solution mining operation should be classified as a Designated Mining Operation (DMO). For more than 20 years NSI's sodium bicarbonate, solution mining operation was not considered to be a DMO by the DRMS and as such the plant facilities, while properly designed, engineered and constructed, were not anticipated, expected or required to conform to the more onerous, phased approach of construction certification or the QA /QC program of an Environmental Protection Facility. Nevertheless, as displayed in the Stormwater Management Plan (SWMP) below, the NSI plant facility and existing infrastructure does comply with EPP requirements. (b) Storm Water Management Plan NSI's Storm Water Management Plan is attached as Appendix B. (11) Surface Water Quality Data (a) There are no perennial sources of surface water within 2 miles down - gradient of NSI's area of operations. The drainage distance, through normally dry drainages, from NSI's area of operations to Yellow Creek is 3.6 miles. It is noted that most of the sodium bicarbonate will precipitate out of solution on or very near the ground surface in the event of a spill of NSI's aqueous process fluid, therefore, the potential for any adverse impact to surface waters minimal to non - existent. This rapid precipitation and crystallization of sodium bicarbonate will occur as the process fluid cools and becomes incapable of retaining higher quantities of sodium bicarbonate in solution. The crystalline sodium bicarbonate would then be raked or scraped up and properly disposed. The USGS has consistently monitored these streams at sampling points near and downstream of the NSI leases. Section 5.2.5 of the previously submitted and approved Mine Plan (July, 2010 and earlier versions) displays a record of water quality data taken from the Piceance Creek and Yellow Creek USGS sampling points near the NSI leases between the years 1980 and 2010. This data establishes both a baseline for water quality of the respective streams, as well as showing that ongoing NSI solution mining operations have not adversely affected the quality of these water courses. (b) Due to the lack of perennial waters on the NSI leases, surface water quality and flow data cannot be adequately gathered to establish a baseline. However, the aforementioned Piceance Creek and Yellow Creek data from Section 5.2.5 of the previously submitted in the Mine Plan (July, 2010 and earlier versions) are considered to be adequate to address surface water quality concerns. (c) Surface water quality samples, in the vicinity of the NSI lease areas, are collected and analyzed under the oversight of the USGS. The USGS intends to continue sampling from these sampling points indefinitely. Due to the lack of perennial water courses on the leases, the distance to Piceance Creek and Yellow Creek, and the distance from the nearest location where the surface water is collected as drinking water ("40 miles at Rangely, CO), it is highly unlikely to impossible that a surficial spill of pregnant liquor in NSI's area of operations will result in any detrimental surface water quality. Daub & Associates, Inc. NSI 2012 EPP Page 11