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l~ <br />Mr. Dan Jackson <br />.tune 24, 1999 <br />Page 2 <br />~' ~ <br />2. P. 3, Par. 4, P. 20, last Paz.The volume of saline minerals removed can be calculated with <br />reasonable accuracy, but the method of identifying the shave of the cavity, which is critical <br />to structural integrity, is not described. Some method of monitoring the migration of the <br />solution front into pillars via the saline beds is needed. <br />PP. 5-7 Hydrogeology. Water quality in the Parachute Creek Aquifer. The high <br />concentrations of salt noted aze anomalous compared to past results of cazeful <br />drilling/testing by the USGS at the US Bureau of Mines' Horse Draw site and <br />at Fault Draw, and at the White River Nahcolite site (then aMulti-Mineral <br />Corp. operation) (see reference, attached letter). These USGS results <br />indicated TDS concentrations of a few 1,000 mg/L in the Lo~Ner Aquifer orily <br />a few ]0's of feet above the dissolution surface. A common practice during <br />drilling is to sample drill return water as a hole is deepened, as a way to <br />estimate aquifer water quality. However, isolated Nahcolite nodules <br />commonly occur in the oil shale section, where the near-impermeable rock <br />has protected Nahcolite from solution by groundwater. When the drill <br />penetrates such nodules, the resulting return water is charged with dissolved <br />Nahcolite until the nodule is completely dissolved, thus leading to mis- <br />interpreting this water as characteristic of the aquifer. The USGS evidence <br />clearly indicates that the Pazachute Creek aquifer meets criteria for a US DW. <br />4. Monitoring Leakage of injection fluid, caving, subsidence, and wide excursions of the <br />solution front (cavity shape) can best be detected early on by monitoring <br />wells. Cavity leakage can readily be detected by Piezometers with ] 0-30' of <br />perforations bottomed at the dissolution surface. Measurement of water level <br />changes aze inexpensive, very sensitive, and may well be the first indication <br />of leakage. Monitoring wells in pillazs would detect major solution <br />extrusions laterally. <br />P. 16. Injection Interval. A minor point, there are several aquifers below the Green River <br />Fm (none likely to be affected). <br />6. P. 17, Par. 102 Because oil shale is not a strong rock, injection fracturing pressures can be <br />significantly less than the normal 1 psi/ft. rule of thumb. See Item 2, P. ] of <br />my 3-8-99 attached letter. Such hydrofracturing will result in small, probably <br />insignificant earthquakes at the locus of fluid movement. The high pressures <br />within cavities will promote brine flow along any fractures into the overlying <br />aquifers. <br />