HYDRO26949

• Permit No: M1999051
• IBM Index Class Name: Hydrology
• Doc Date: 7/17/2000
• Doc Name: Certified Mail Letter from BLM
• From: BLM
• To: DMG
• Permit Index Doc Type: Correspondence
• Media Type: D
• Archive: No

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C-0119985
United States Department of the Interior 55~
BUREAU OF LAND MANAGEMENT Fr .
White River Resource Area
73544 Highway 64
Meeker, Colorado 81641 RECEIVED
CERTIFIED MAIL NO. Z 416 132 332
RETURN RECEIPT REQUESTED
AmerAlia, Inc.
Attention: ~Mr. Roger Day
818 Taughenbaugh Blvd.
Post Office Box 1330
Rifle, Colorado 81650
Dear Mr. Day:
July 13, 2000 dU~ 17 Z(jQII
Division ofMinerals b Geology
We have received your July 10,2000 letter concerning MWD-1 an MWD-2. Our
staff does not agree that AmerAlia has collected sufficient data for the
Dissolution Surface Aquifer. We have concerns on the sampling procedures;
please refer to our May 16, 2000 letter. TDS value in the MWD-1 have varied
from an initial January 18, 2000 sample of 58,900 to a March 27, 2000 sample
of 38,500. It is not known if this is the result of improper purging of the
well bore prior to sampling or if the TDS decline is due to well development.
AmerAlia was aware~of the large volumes necessary to properly purge the well
bores. On page A-1 of the November 23, 1999 Surface and Groundwater
Monitoring Plan; for AmerAlia, Inc: Experimental Pilot F1ant~Nahcolite Project
under Well Puraina it states: "Monitor wells must be purged prior to sampling
to ensure that a representative sample of the groundwater is collected and not
a sample of the stagnant water in the well casing. Three casing volumes
should be removed before sample collection." As stated in the May 16, 2000
letter the well bores volumes MWD-1 and MWD-2 are calculated to be 1,045
gallons and 1,062 gallons respectively. Three volumes would be 3,135 gallons
and 3,166 gallons, which is significantly larger than the stock tanks that
were set on site for collection of the dissolution surface water during
sampling. It has been suggested by the BLM to AmerAlia to use a micro purge
sampling procedure to eliminate the necessary large volumes of well bore
water.
In the May 16, 2000 letter we asked you to change or modify the current
sampling methodology to address the sampling concerns. Instead~of a using a
sampling procedure that would require significantly less water to be~remove
from the dissolution surface aquifer, AmerAlia's response was to simply stop
sampling these wells.
Sampling frequency in Table la of the approved November 23, 1999 Surface and
Groundwater Monitoring Plan, for AmerAlia, Inc. Experimental Pilot Plant
Nahcolite Project show MWD-1 and MWD-2 are to be sampled monthly for the short
list and quartly for the long list. This plan was developed and submitted by
AmerAlia as part of the Environmental Assessment for the Experimental Pilot
Plant Nahcolite Project. Adherence to the plan is necessary for AmerAlia to
be in compliance with the approved project. The BLM has not approved a change
in the monitoring plan to relax the baseline monitoring of the dissolution
surface aquifer. A decision on the part of AmerAlia to cease sampling~of the
dissolution surface aquifer does not meet the re quirement s~of the approved
plan. According to 43 CFR 3592.1 (a)"No operations shall be conducted except
as provided in an `approved plan." According to 43 CFR 3598.4 (a) the
authorized officer shall serve a notice of noncompliance to the operator for
failure to compl y'with any of the established requirements.
Therefore, AmerAlia is in noncompliance with the approved Surface and