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last 40 years. It is nearly impossible to correct and account for the cross flow contamination from <br />the sampling intervals by purging large volumes of borehole fluids. In a similar open hole case in <br />the Piceance Basin, hundreds of gallons per minute were measured entering the Dissolution <br />Surface Aquifer from the overlying A and B Groove Aquifers. <br />As a result of casing and cementing the overlying aquifers before penetrating the Dissolution <br />Surface Aquifer, AmerAlia gained nearly virgin water quality samples as the av-only drilling <br />method penetrated the sampling interval whereby filling fresh cuttings and formation water to the <br />surface. Thus, high quality sampling interval confirmation and water sampling was achieved <br />during both the drilling and completion of each of these wells along with the following montlily <br />sampling event. <br />These Dissolution Surface Aquifer waters aze not fit for human, agricultural or animal <br />consumption. This water kills plants and poisons the soil if released to the ground. The nearest <br />approved disposal site far this water is 90 miles away. Use of a disposal site for redundant <br />ground water sampling is both costly and wntrary to responsible management. Best management <br />practices would be those practices which avoid the environmental consequences and liability of <br />exposure of unnecessary waste production, transportation, and disposal of such fluids. <br />A single well bore purge event for either of these wells produces approximately 2,300 gallons of <br />fluid. Without factoring in the high TDS and elevated specific gravity, water produced during a <br />single purge event for both wells exceeds the capacity of a water truck. <br />AmerAlia does not endorse the low volume aquifer monitoring well sampling technique. The <br />historical and ongoing sampling problems and miss-information generated by low volume well <br />sampling technignes aze well documented in the Piceance Basin. <br />AmerAlia believes a high quality monitoring well drilling and completion technique followed by <br />high volume sampling supersedes hundreds of micro purged sampling events of poorly or <br />questionably constructed monitoring wells. <br />AmerAlia notes that WRNM's mine plan commingles mining solutions with aquifer waters near <br />the Dissolution Surface. The in-situ pressure of the commingled waters is measured by recording <br />water levels and is controlled to provide pressure gradient protection of the overlying USDW <br />aquifers. Aquifer protection wmpliance is documented with a continuous in-situ pressure record <br />and monthly aquifer water quality sampling of the USDW aquifers. Monthly water quality <br />sampling of the Dissolution Surface Aquifer merely documents the commingling effects and does <br />not protect or document protection of the overlying aquifers. <br />AmerAlia notes that American Soda used the lower aquifer above the Dissolution Surface for <br />injection and disposal of mining solution. Disposal of injected mining solution both pressurizes <br />and commingles Dissolution Surface Aquifer waters with mining solutions. AmerAlia does not <br />know if the aquifers at the American Soda site are protected by a favorable in-situ pressure <br />gradient, if the gradient has been maintained, or if in-situ pressures aze continuously recorded to <br />detemrirre the impacts of the disposal injection activity. <br />Unlike WRNM and American Soda, AmerAlia has not asked to permit a mine plan which <br />included commingled mining solutions with Dissolution Surface Aquifer waters. Instead <br />AmerAlia intends to avoid contaminating the Dissolution Surface Aquifer waters with mining <br />solutions and monitor water pressures or levels as assurance. <br />