HYDRO27655 - Laserfiche WebLink

Home Browse Search

~- PURGE VOLUME Was the 3-displacement purge goal being achieved? AmerAlia is now verifying the 3-well bore displacement purge volume goal for the Uinta and A-Groove monitoring wells. The next sampling of the B-Groove well will verify the 3-well bore displacement purging for the B-groove well. As always, the BLM is invited and encouraged 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 releasingatto 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-l and MWD-2 purge water was directed to the drilling pit. The EPA staff was helpful by providing a April 19961ow 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. Criven the results of the exploration and monitoring activity, AmerAlia finds 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 current and historical BLM, EPA and DMG resource management actions. As explained in greater detail in our July . __ _ _ 10,.2000.1etter,_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 mine 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,