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.; <br />lI <br />Letter to Kurt Nielsen 4 Mav ~3 1999 <br />surface of solution in a mining cavity as discussed under [he heading "Distillation Process Concerns" in the <br />General Chemical letter. <br />14. It is stated in section I.0 of the Ground Water and Surface Water Monitoring Plan that water quality <br />trends will be developed over a 13-month period prior to start up of commercial operations (emplrnsis <br />ndderl). It is DMG's position that the reclamation permit application as it is written prohibits injection of <br />solution mining fluids into new production wells until the 13-month water quality characterization period is <br />completed. <br />15. Please note that Rule 8.1 of the Hard Rock Metal Mining Rules and Regulations of the Mined Land <br />Reclamation Board requires operators to report within 24 hours any failure or imminent failure of <br />environmental protection facilities designed to contain or control process solutions. Under this regulation, <br />American Soda must report spills or leaks from well field piping to [he DMG within 24 hours. Other <br />environmental facilities at the site are discussed in the DIvIG's first adequacy letter dated April 18, 1999 and <br />in American Soda's adequacy response received May 13, 1999. Undesirable event reports required by the <br />BLM may suffice for DMG's reporting requirements regarding any loss of containment of production fluid. <br />16. American Soda is required to submit proof of Fling with the Rio Blanco County Clerk of the <br />foitov: tng documents: <br />a. A , opy of the technical revision to the application dated April 23, 1999 (letter no. 124-627). <br />b. The adequacy response package dated May 13, 1999 (letter no. 124-660). <br />c. American Soda's forthcoming responses to this letter. <br />Please review Rule 1.8.1(2) and understand that a permit may not be issued without provision of the <br />required proofs of filing. For continuity and understanding by any person reviewing [he application <br />materials on file with [he County Clerk, copies of this letter and the DMG's first adequacy letter should also <br />be filed. <br />17. Please address the following issues discussed in the internal DMG memo dated April 16, 1999 from <br />Harry Posey to Allen Sorenson. A copy of this memo was previously provided to American Soda. <br />a. Is healing of fractures by temperature-controlled precipitation of solids considered a means to <br />prevent adverse impacts that may be caused by subsurface loss of containment of process solution? <br />If so, provide experimental or other evidence to demonstrate the efficacy of this effect. <br />b. Describe measures to be employed to avoid drilling of production wells into fractured or faulted <br />strata. Provide any stntctural geology information available for the lease area and surrounding <br />areas, and describe plans to develop an adequate structural geology database prior to commercial <br />operations. <br />c. Provide a tabulation with reference to appropriate standards (e.g., American Petroleum Institute) for <br />the well logging to be conducted at the Yankee Gulch Project. The logging must be adequate to <br />assure [hat the cerocuicd casing will prevent communication between aquifers and will prevent the <br />introduction of injection or production Fluid into zones above the dissolution surface. <br />