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<br />the temperature at which Ute distillation ofoil shale occurs. Since vse do not know this temperature, <br />how is i[ possible to enforce lltis COA. The BLM is either establishing a selling which will result <br />in damage to the environment, perhaps conflicting with existing sodium (case restrictions (or <br />protection of oil shale or the potential to damage the environment through distillation of the oil <br />shale. In particular, long-term or continuous exposure to temperatures above 300 degrees F should <br />be considered. Regarding the "Hydrology, Geology Minerals" conditions 1~, please provide <br />verification that high temperature cements were used in constructing wells; please provide the carbon <br />monoxide and methane monitoring data; please provide the dissolved organic carbon and <br />concentrations of oil and grease; and any information regarding the destructive distillation of any <br />oil shale. <br />Please provide tltc data on the BTX concentrations and, if any waste disposal involving petroleum <br />products was necessary, provide the analysis of Ilte contaminated Iuid (hopefully it was not <br />discharged to the pond), the volume of the fluid, and the location where it has been or is proposed <br />to be disposed. <br />Item 14: How many production wells artd mining cavities have been constructed to date? At public meetings, <br />American Soda Itas touted tltc success of their Test Mine Plan. One of the criteria of success was <br />to construe a full sized nursing cavgty and detemtine how much sodium product it could extract Gom <br />the cavity. Based on the data provided, with over hvo years of effort, the American Soda's Test <br />Mining Plan effons have not demonstrated the economic viability of their proprietary mining <br />program. Production of 7,655 Ions of sodium does not provide a high degree of confidence that <br />American Soda's process is economically viable, and it would be a travesty for BLM to authorize a <br />commercial scale operation withow a demonstration of viability for the mining method. <br />llem 15: Please provide the data submitted by Antericmt Soda that verify no leakage has occurred from the <br />ponds. <br />hem 16: Wcrc the aquifers monitored dov~•n dip from the test mining cavities? If so, please reference the data <br />from the monitoring wells, and if not please indicate why such data were not required. <br />Working with my geohydrological experts, we prepared the attached graph that compares the sodium <br />bicarbonate data for wells 21-2 (alluvium), 20-8 (Uinta) and 20-5 (Uinta). These data were obtained <br />during monitoring ofthe Test Mining Project currently being carried out by American Soda and the <br />data is abstracted from the monitoring reports submitted to the BLM. Please note the following <br />conclusions regarding these data: <br />• Well 20-5 shows a rise in bicarb level from about 1,600 ppm on 11-2-97 to over 6,000 ppm <br />on 4-29-98. It then drops to around 2,500 ppm on 8-29-98 and then back up to 4,000 ppm <br />on 11-22-98. <br />• Well 20-8 shows a rise in bicarb levels from 10-02-97 to 9-21-98. After 9-21-98 the bicarb <br />value jumps to over 3,000 ppm <br />• The above two wells are in the lower part of the Uinta Formation which is a U. S. Drinking <br />Water Aquifer. <br />• Well 20-8 is a water supply well. <br />• The alluvial well, 21-2, tracks the other two wells. <br />