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07j11/2000 13:57 9706259137 AMERALIA,INC PAGE 03 <br />last 40 years. It is nearly impossible to correct acrd account for the cross flow contmrin~auon firm <br />the sampling intervals by praging large volrmes of borehole fluids. In a similar open bolo ceae in <br />the Piceance Basin, hundreds of gallons per mimtte was measured entering the Disaotutiat <br />Surface Aquifer flour the overlying A and B Groove Aquifers, <br />As a result of casing acrd eementing the overlying aquifers before penetrating the Dissolution <br />Surface Aquifer, AmerAlia gained nearly vugm water quality samples as the sio-only dulling <br />method penetrated the sampling interval vvhoreby lining Sash cuttings and fonoation water to the <br />surface. 13us, high quality ssrnpling mtesval confirmation and water sampling was achieved <br />during both the drilling and completion of each of those wells along with the following moruhly <br />sampling event. <br />these Dissolution Surface Aquifer waters are not frt for human, agriculhual or animal <br />consumption. 7]tis water kills plains and poisons the soil if released to the ground 'Ihe nearest <br />approved disposal site for this water is 90 miles away. User of a disposal site for redrmdant <br />groundwater sampling is both costly and contrary to responsible managemerrt. Beat management <br />practices would be those practices which avoid the environmental camsegaences and liability of <br />exposure of unnecessazy waste prodoaioa, nnnsportation, end disposal of such fluids. <br />A single well bore purge avem for either of these wills produces approximately 2,300 gallons of <br />fluid Without factoring in the high TDS and elevated specific gravity, water produced during a <br />single purge event for both wells exceeds the cxQaairy of a water truck. <br />AmerAlia does not endorse the low volume aquifer monitoring well sampling technique. 1'he <br />historical and ongoing sampling problems and miss-information generated by low volmne well <br />sampling techniques ate well doatmented in the Piceance Basis <br />AmerAlia believes s high quality monitoring well drilling and completion technique followed by <br />high volume sampling supercedes hrmdrods of micro Purged sampling events of poorly or <br />questionably ooastructed momtaring walls. <br />AmerAlia Hoots that WRNM's mine plan cotttmirrglcs mining solutions with aquifer waters near <br />the Dissolution Stufece. The in-situ pressore of the commingled wares is measured by recording <br />water levels and is controlled to provide pressam grsdiem protection of the overlying USDW <br />aquifers. Aquifer protection compliance is documented with a oominuous in-situ pressws record <br />soil monthly aquifer water quality sampling of the USD W aquifers. Monthly wmer quality <br />sampling of t6o Dissolution Surface Aquifer merely documents the commingling ei~ and does <br />not pmtect err dowment protection of the overiying aquifers. <br />AmetAlia notes that American Soda used the Iowa aquifer about the Dissolution Surface for <br />inaction and diaposai of mining solution. Disposal of injecrod ruining solution both ptessutizea <br />and commingles Dissolution Surface Aquifer waters with mining solutions. AmerAlia does not <br />know if the aquifers e< the American Soda sin are protected by afavorable in-situ pressure <br />gradi®; if the gradient has been maintained, or if in-situ pressures ate oominuously reoartded to <br />determine the impacts of the disposal injection activity. <br />Unlike W RNM end American Soda, AmerAlia has not asked w permit a mine plan whieh <br />included eoanningled rnirtutg solutions with Dissolution Surface Aquifer warms. Instead <br />AmerAlia intends to avoid contaminating the Dissolution Surface Agaifer waters with mining <br />solutions and monroor waver pressures or lords as assurance. <br />