2000-08-04_REVISION - M1999002

• Permit No: M1999002
• IBM Index Class Name: Revision
• Doc Date: 8/4/2000
• Doc Name: GEOCHEMISTRY INTERNAL MEMO ON ADEQUACY OF TR3
• From: Harry Posey
• To: ALLEN SORENSON
• Type & Sequence: TR3
• Media Type: D
• Archive: No

• 1 STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman 6L, Room 215
Denver
Colorado N0203

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RECLAMATION
MINING•SAFETY
August 4, 2000 /
Bil l Owen
Governor
To: Allen Sorenso~%~"'" v cre~e.wal~ner
From: Harry Posey E`e`°~"e o "'`~°`
Sub~ect: American Soda• Baseline W r Monitorin Re ort and Pro osed Anal e Li ''~6,e1 B. tons
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Under the captioned document, American Soda has provided
1. a list of proposed monitoring parameters,
2. a proposed sampling schedule, /~ / , f ~ Q
3. analysis of process solutions, and - F^'v~ ~ ~ ~ ~ t [Ot+~'ut t'"~
r~,~proposed numeric protection levels based on the Dixon statistical method as required
by the Division,
I have reviewed items l through 3 but not item 4, above.
This review presumes that the purpose of the groundwater monitoring is to detect potential leaks
of process fluids from the productive formation; that during production, the process fluids will
have higher than ambient formation pressures; that the process fluids will have higher TDS and
higher temperature, at a minimum, than overlying potable water zones; and the potential for loss
of fluid to shallower formations is to be monitored. It is presumed further that groundwaters are
also to be monitored for evidence ofcross-formational fluid movement, particularly from non-
potabledissolution zone waters into shallower, potable water zones of the B-Groove, A-Groove,
and Uinta Formations. These presumptions account for the observations that all potable waters
in the shallow zones are of relatively poor quality compared with most other potable
groundwater in the state.
Based on a review of the groundwater and process solution analyses, the list of parameters
appears to be adequate for the intended monitoring purposes to detect leaks from the mining
formation and to detect cross-formational movement of fluids that are naturally high in
constituents to the more potable waters in other zones. The parameters list is conservative in that
several of the potential contaminant elements would behave similarly in a cooler, post-mining
environment. A smaller list of indicator parameters would be sufficient, particularly after a
longer shake-down phase during which sampling and analytical procedures are perfected and
made routine.
The proposal calls for monitoring various chemical and physical parameters in the Alluvial
aquifer, the Upper Uinta aquifer, A-Groove, B-Groove, and dissolution zone. The proposal
requires sampling, analysis and reporting in all cases, and NPL's are proposed for all but the
dissolution zone. I again would caution the Division not to require analysis of chemical