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AmerAlia Inc. <br />818 Taughenbaugh Blvd. <br />Rifle, Co. 81650 <br />July 10, 2000 <br />Mr. James Cagney <br />Bureau of Land Management <br />73544 Hwy 64 <br />Meeker CO 81641 <br />Mr. D. Edwin Hogle <br />Director, Groundwater Program <br />UIC hnplementation Program <br />U.S. EPA <br />999 18a' Street, Suite 500 <br />Denver CO 80202 <br />/Mr. Allen C. Sorenson <br />Reclamation Specialist <br />Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver CO 80203 <br />RECEIVED <br />dUL 14 Pa00 <br />Division of Minerals & Geobgy <br />Subject: AmerAlia Rock School Project <br />Ground Water Monitoring Plan <br />Modification Request <br />MWD-1 and MWD-2 Monitoring Wells <br />Dear Sirs: <br />55S <br />AmerAlia has collected sufficient data for the Dissolution Surface Aquifer monitor wells MWD-1 <br />and MWD-2 to prove the Dissolution Surface Aquifer is not a resource to be protected <br />(underground source of drvilring water or USD W) beneath the Rock School Sodium Lease. <br />Instead the poor quality water of the Dissolution Surface Aquifer poses a risk to the overlying <br />USDW aquifers if the protective ground water pressure gradient were reversed by AmerAlia's <br />solution mining activity and water from the Dissolution Surface Aquifer were forced into these <br />overlying aquifers. In order to assure protection of USDWs, AmerAlia proposes to monitor and <br />protect the natural pressure gradient instead of conducting redundant water quality testing of the <br />MWD-1 and MWD-2 Monitoring Wells. <br />AmerAlia completed individual monitoring wells for our groundwater monitoring program in a <br />manner which isolated the specific aquifer to be monitored by an individual well and prevented <br />the commingling of aquifer waters. Wells were initially drilled short of the top of each ground <br />water monitoring interval, and the wells were cased and cemented sealing off a~ overlying <br />aquifer waters before subsequent drilling and exposure of the target monitoring interval. <br />Without exception, in my experience in the Piceance Basin, when wells are drilled through <br />overlying aquifers to reach lower aquifers, the waters from the overlying aquifers are proven to <br />flow downward in the open borehole. Cross flowing ground waters have corrupted much of the <br />deeper aquifer hydrologic data collected by the USGS and industry in the Piceance Basin over the <br />