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<br />Item 10: <br />Well 20-5 (Upper Aquifer, Uinta) <br />Monitoring well <br />Date Bicarb Total Dissolved Solids Chloride Fluoride <br />I1-22-98 3,948 3,040 138 8.7 <br />10-29-98 3,402 2,045 112 7.5 <br />06-29-98 2,990 29,400? 16,361? 7 <br />03-04-98 4,158 M/D 159 8.3 <br />12-11-97 2,520 M/D 73.8 5.0 <br />06-10-97 774 1,210 15 2 <br />A rcwiety of the water quality data for Wcll 20-9 (see below) does not reveal any discernable trend. <br />However, note lltat the I~igli Bicarb reading on 02-02-99 is inconsistent with the TDS value, and <br />again it could reflect a possible release of drilling fluid from the extraction sells. <br />Well 20-9 (Loe•er Aquifer, B-Groove) <br />Monitoring well <br />Date Bicarb Total Dissolved Solids Chloride Fluoride <br />02-02-99 14,322 9,390 210 M/D <br />O1-21-99 0? 2,991 4,070 4.9 <br />12-22-98 7,392 9,GIG 2,156.6 23:8 <br />However, there is a subtle issue that arises by examination of the data summarized above. Since the <br />TDS values all fall bclo~v 10,000 mg/I, this aquifer should be considered as an EPA Drinking Water <br />Aquifer which contradicts the data submitted to the EPA in order to obtain the UIC permit for <br />injection in Wcll 206. These data should have prompted BLM to communicate with EPA in Demer <br />to reevaluate the acceptability of using the aquifer for discharge of fluids in the ponds which began <br />on Februan' 6, 1999. The discharges may be in violation of American Soda's UIC permit. <br />Item 11: Maximum and minimum values, such as volumes oC ^uid injected and recovered, would not appear <br />to Itavc any proprietary value, since Otese numbers represent a simple mass balance for the operation. <br />Please identify the parameters included in the monthly report, and indicate the reasons why such <br />parattteters are considered proprietary. Tltis is not a commercial production operation and the <br />quantitative results of the Test Mine Plan implementation should be available for review to allow <br />independent pecrreview ofthc data. <br />Item 12: Scc comments under Item 2 about. <br />Item 13: This is another instance where BLM has changed a COA apparently without having any real data <br />to evaluate the effects of authorizing the change Specifically, the BLM's May 8, 1998 letter to Mr. <br />Nielson specifically states "We could not find, either through practical experience or research, where <br />Piceance Basin Oil shales lead been subjected to temperatures oC400 degrees for extended periods <br />of time." Yct, the BLM agreed to the proposed change in the solution mining cavity temperature of <br />up to 400 degrees F. <br />A vrl~ole new set of conditions resulted, the first being a COA regarding the "Solution Mining <br />Tetnpemture". The tentpemlure of the solution used for solution mining must be maintained below <br />