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1~ N N Mr. 4l)ly Frank September 23, I9B6 Sanm comments specific to the E15 Lollar: Page 1-3, Dera. 3. In of ew of the less controllable method of solution mining, mining to rlthln 50 Teet of a lease boundary seems much too lenient ~ 22 If the o11 shill! aM nshcolite On ad3olning Federal lanOS 1s tmpet rcd, are there any provisions for lndemnl/f cation for loss of oil shale, nahcolite, end ground water resources on these lands by the lessee? Page 2-8, pare. 2.2.12.3. If substantial subsidence occurs, Mat steps wu~ De taken by BLM to correct the prbblemi provisions for Daymm~t by the lessee 45 far damage Lo oil shale am the sodium leases that might be caused by solution mining of nahcolite should be included 1n this EIS. Pa 9e }6, Dara. 3.2.3. The EIS states that the oi) shale fn the leached zone is too incompetent t0 mine by conrentlenal Beans. Nhat about MI5 methods? Most o! the oil shale on the C-a and C-b tracts has been leached of nahcolite anO can be considered Dart of the leached zone, On the C-b tract, mining plans Include retorting ail shale by an MIS method in parts of the Mahogany Zone, B-groove, aiM R-6 oil-shale zones. On the C-a tract, the MI5 retort No.l, Mich vas sucessfully burned, extends rerticelly from the middle oT the 3~ R-5 through the R-6 to nearly the top of the Mahogany Zone. These o71 shales contain ruDbll zones and solution breccias. 4lthout a comparison o! the rock properties of the leached oil shale on the C-b and C-a tracts with the properties of the oil shale 1n the leached zone on the sodium lease lands, the conclusion that the leached zone on the sodium lands cannot De mined fs untenable. The oil shale to the leached zone on the sodium leases should De considered as recoreraDie resources that could be ferioutly impaired or lost by solution ml ni ng of the Bales bed. Page 3-7, fig. 3-111. The serattgraphy Ls too generals xed to clearly see the relationships between oil shale, nahcolite, antl darsanlte. Profiles of Fischer assays, nahcolite, and dewsonlte for one of the Intlustrlal Resouces core holes on the sodium lease lands should De shorn to gl re the reader some Idea of the vertical disLrf butlon and abundances of these resources on the 43 sodium lease lands, Slmllar to that published by Cale, Oeub, and Yelchnan (1982, Ceolo9y of the Norse Draw nahcolite end oil-shale mine, Ptceance Creek Basin, Colorado Iln] ]5th 011 Shale Symposium Proceedings: Colo. Sch, Nines, p, 15-28). Mr. tally crank 3 Septer~er 23, 1986 Page }e, pare. 3.3.2. The trcetmenL of oil shale resources 1n this section fs not adequate. Estimates oT the total tonnages of o11 shale--principal ly fn the R-6 and Mahogany zones--that could Oe adversely affected by solution mining should be included In a table. Tne total amount of nahcolite that would be recovered Dy the proposed solution mining plan should also be included. 33 The amount of 1n-piece shale-o11 resources far the Mahogany and R-6 zones on the 219-acre .ell-field area under the Proposed Actfon is estimated at 140 million barrels that could be adversely affected Dy solution mining as opposed to production o/ an estimated 4 mf llfon tons of nah<olite (330 cavities a 12,000 tons of nahcolite per cavity), Sincerely yours, ~..G..A.&~;, John R. Oynt, Geologist ono i / >~.-...aJ'r~a el- I.. ~] Thomas Gooch, BrenrJr Cfilef7