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08/09/2000 16:24 9706259137 AMERALIA,INC PAGE 04 2- PURGE VOLUME Was the 3-displacement purge goal being achievedT AmerAlia is now verifying the 3-well bore displacement purge volume goal for the Uinta and A~iraove monitoring wells. The next sampling of the B-Cnoove well will verify the 3-well bore displacement purging for the B-groove well. As always, the BLM is irrvited and encouragod to attend and participate in our water sampling activities. 3- DISCHARGE RESTRICTION Purge water disposal plan revision This is the main concern of this letter. The purge water from the Dissolution Surface Aquifer monitoring well is of such poor quality, the BLM required AmerAlia to stop releasing it to the on-site pit. The 3-well bore displacement purge volume sampling method was extensively discussed with the BLM during the monitoring plan development and approval activity. Monthly sampling commenced in January 2000. Until the May 2000 sampling, MWD-1 and MWD-2 purge water was directed to the drilling pit The EPA staff was helpful by providing a April 199tS low purge volume sampling protocol paper by Puls and Barcelona, The authors explain this sampling method is viable for specific well construction and site hydrology. Specific concern is expressed related to the conditions present in the sampling interval of MWD-1 and MWD-2. Given the results of the exploration and monitoring activity, AmerAlia Ends no cause to continue sampling the Dissolution Aquifer. The Dissolution Surface Aquifer is not a resource and sampling is not necessary to protect the drinking water resources. This is true regionally and is consistent with cwrem and historical BLM, EPA and DMG resotuce nuuragement actions. As explained in greater detail in our July 10, 20001etter, AmerAlia feels it is unwise and unnecessary to continue sampling, with or without discharging water from the sampling activities. AmerAlia also believes it is unreasonable for the BLM to expect AmerAlia to continue sampling the Dissolution Surface Aquifer for consistency with other Piceance Basin projects. AmerAlia's project is not the same as other operations in the Piceance Basin. AmerAlia's mine plan does not propose nor does it allow commingling mining solutions with the Dissolution Surface Aquifer. AmerAlia's mitre plan does not inject disposal fluids into the Dissolution Surface Aquifer. The result of the ground water exploration program did not yield troubling results requiring explanation as the potential adverse impacts of pilot solution mining or shaft sinking activity by others. The quality of our monitoring program and analytical results of our ground water exploration provide a sound foundation upon which the agencies can act with confidence.