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.- IUN-21-1999 11 06 ~NERRL CHEMICRL 201 515 1985 P.05i09 N 1. The following is a direct excerpt from the draft statement of basis: "The test phase began in July 1997 as a class V experimental test cavern with the purpose of determining whether it was economically and technologically feasible to extract the mineral nacholite by the use of a solution mining process with elevated temperature and pressure." Our notes on the American Soda test mine facility suggest that American Soda has not proven that this project is economically or technologically feasible. Fur instance: al There are four caverns that have been developed by American Soda. One cavern lost circulation during attempts of initial production. In another cavern the well casing dropped down hole in the well bore. One of the caverns had a blowout during drilling and high pH completion fluids were released to the environment. We do not feel comfortable that American Soda has proven the process to be technologically feasible. h) !n the April 12, 1999 Rio Blanco County Commissioners Minutes, Kun Nielsen stated: "The diameter of one (cavity) is projected at 34 feet wide and 450 feet in height, but no technology exists to view the cavity. The size is inferred by the volume removed." In the test mine plan, American Soda starts that the cavern sizes are expected to be 200 feet wide and 600 feet in height (roughly cylindrical in shape). This means the test mine cavity described above, which is the largest of the four cavities, is only 2°~ of the volume of the cavity as described in the Test Mine Plan. Since the ability to control horizontal growth does not exist, American Soda has not shown [his project is technologically or economically feasible or has grossly misstated the number of solution mining wells that will be operational in order to achieve the desired 1.4 million tons of nacholite production per yeaz. c) As of 3/1/99, two years after the Test Mine Plan was approved, only a total of 7655 tons of nacholite had been removed from the American Soda test caverns. It would also appear that American Soda has failed to complete one full size test cavity which is the purpose of the Test Mine Plan. Based on this information American Soda has not provided a case for commercial viability. Before the EPA considers the Class 111 Area Permit. American Soda should be required to explain to the public and the EPA how they have met the requirements of validating technological and economic feasibility according to the Class V U1C Rule Authorization. in the event proof of economic and technological feasibility has not been met, it would be premature and inappropriate for the EPA to issue a Class Ill Area Permit.