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<br />b) The cooling ponds at the Experimental Test Mine site have been <br />constructed with a geonet layer between two geomembranes. <br />Monitoring of the cooling ponds consists of a leak detection system between the <br />upper and lower pond liners. All leakage through the upper liner will drain to a <br />sump, and this drainage is facilitated by installation of the geonet. For <br />continuous monitoring, the sump will be checked daily whenever the ponds <br />contain fluids. Should leakage occur, the fluids would be removed with the <br />sump pump. The sump pump will be calibrated, and the duration of pump <br />operation will be recorded to document the volume of fluid pumped. Volumes <br />derived by this method will be used to determine whether leakage rates equal or <br />exceed an action leakage rate (ALR) of 250 gallons per acre-day (gpad) and a <br />response action plan (RAP) leakage level of 500 gpad. Both BLM and DMG Have <br />previcusly approved these leakage rates. IE the ALR is exceeded, American Soda <br />will notify the BLM the next business day and monitoring will be increased. [f <br />the RAP leakage rate is exceeded, a response action plan will be implemented to <br />address the specific details of the leakage (rate, which pond, time of year, etc,), as <br />determined in consultation with the DMG and BLM. <br />Minimum freeboard for the cooling ponds at the Experimental Test Mine Facility <br />is 2 feet. <br />c) The ponds at the Experimental Test Mine Facility have a maximum storage <br />capacity of 11.7 acre-feet of solution. American Soda intends to recover, to the <br />extent possible, existing product material in the ponds. For the purpose of <br />estimating the amount of material removed at the time of reclamation, it is <br />assumed that up to 20 percent of the pond capacity may be non-recoverable <br />material. Therefore, 2.34 acre-feet or 3,775 cubic yards of material may require <br />removal at the time of final reclamation. The estimated volume of pond liner <br />that would require removal at the time of final reclamation would be 250 cubic <br />yards. <br />14. American Soda understands that, in accordance with Rule 4.2.1(8), the amount of <br />bond held by the Mined Land Reclamation Board may be reduced by subtracting <br />the amount of reclamation bond held by the BLM from the estimated cost to <br />reclaim the site. <br />15. The need to conduct apre-operational inspection is noted. <br />~:.w~..,.., way w..P.- 11 <br />l.nY.1 (:u4f~Y.lmm M.wW Pn~'1 <br />•.wrn sJa LL1' <br />