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<br /> <br />that may be int7uenced by the high temperature mining cavity, mechanical integrity testing, <br />cement logging, and certification that the wells were properly installed. <br />All facilities used to convey or contain process solution are considered Environmental <br />Protection Facilities, and must be designed, constructed, tested, and certified to assure <br />containment. <br />• Mining injection solution pressures and other parameters will be monitored continuously to <br />provide early warning of potential containment loss from mining cavities, production wells, <br />or well field piping. <br />• Surface and ground water will be monitored to detect the influence of potential leakage of <br />process solution [o the aquifer systems. <br />A resource conservation issue related to the high temperature process solution is the potential to <br />damage to future mining potential for the co-located resources of oil shale and Dawsonite. <br />American Soda will monitor process solutions for indications of the distillation of oil shale, and <br />will take mitigating measures, including decreasing the temperature of mining solution, if <br />distillation is indicated. DMG would not take issue with the co-recovery of Dawsonite during <br />solution mining, but since this may be an item of concem with BLM, the two agencies have <br />conferred on this issue. It is BLM's position that dissolution of Dawsonite would not occurae <br />the mining temperatures proposed by American Soda. The only potential contaminant of <br />concem that may dissolve from Dawsonite is aluminum, and aluminum has been included as a <br />parameter in the required surface and ground water monitoring. <br />Comment #5: 'The application does not address the impact on the future mineability of oil shale. <br />Db1G Response: As discussed in the DMG response to comment #4, American Soda will <br />monitor the process solution to detect if distillation of oil shale is occurring in the mining <br />interval, and will take mitigating measures if distillation occurs. American Soda will also <br />monitor the Mahogany zone, which is the richest oil shale interval and is located several hundred <br />feeC above the solution cavities, and will take corrective measures if subsidence that may damage <br />the future mineability of this resource is detected. <br />Comment #6: Why is no bond required for reclamation of the Parachute Site? <br />DMG Response: The Pazachute Site is an off-site refining facility (Rule 1.1(31)) and is not <br />included in American Soda's reclamation permit. <br />Comment #7: Perched aquifers may be present in the area of the Yankee Gulch Project and may <br />contain drinking quality water worthy of protection. <br />DMG response: American Soda has committed [o a systematic characterization of the ground <br />water resources at and around the mine site. Based on the results of the characterization study <br />points of compliance, practice based permit conditions, and numeric protection levels will be <br />established in accordance with Rule 3.1.7. The characterization of the ground water will be <br />completed in advance of injection of fluid for commercial scale solution mining. <br />Comment #8: What type of remedial actions will be used if erosion problems develop? <br />