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AmerAlia, Inc. May 21, 1999 <br /> P.O. Box 1330 <br /> Rifle, CO 81650 <br /> (970) 625-9134 Fax: (970) 625-9137 <br /> Mr. D. Edwin Hogle <br /> Environmental Protection Agency <br /> Region VIII, Ground Water Program, 8P-W-GW <br /> Suite 500 <br /> 999 18"Street <br /> Denver, CO 80202-2466 <br /> RE: Class V UIC Permit Application for the AmerAlia Rock School Lease Experimental <br /> Nahcolite Project <br /> Dear Mr. Hogle: <br /> Enclosed for your review are 3 copies of the AmerAlia, Inc. Class V Underground Injection Control <br /> Permit Application for the AmerAlia Rock School Lease Experimental Nahcolite Project. The <br /> Application was developed pursuant to 40 CFR Parts 124-147. AmerAlia requests that you consider <br /> this project an experimental pilot operation and accordingly the application as a Class V area well <br /> permit application. Furthermore AmerAlia, Inc. requests EPA to approve this application via the <br /> authorization by rule process. <br /> AmerAlia, Inc. considers this operation to be experimental in nature with the initial phase to include <br /> up to six solution reining cavities over a 5-year period of time. AmerAlia has completed the resource <br /> exploration phase of the Rock School project and is working on a commercial mine plan. <br /> Proven solution mining technology is not available to AmerAlia. A competitor,White River Nahcolite <br /> Minerals (WRNM), owns the only proven technology. Not only is WRNM's technology ownership an <br /> issue, their patented technology is only applicable to thick bedded nahcolite which does not exist <br /> within the Rock School Lease. <br /> Commercial solution mining of the Rock School Lease nahcolite must focus on the disseminated <br /> nahcolite in an oil shale matrix. The potential to do so was demonstrated and patented by Shell Oil. <br /> The patent has expired. The 300°F (range) solution mining demonstration project phase only added a <br /> few feet to the drilled borehole radius. They then enlarged the cavity by combining oil shale retorting <br /> and nahcolite solution mining. The Rock School Lease forbids oil shale retorting. <br /> American Soda is conducting experimental pilot mining to develop disseminated nahcolite solution <br /> mining methods from a resource similar to AmerAlia's. Their activity is proprietary and confidential. <br /> Their results are unavailable to AmerAlia. Public observation of their activity indicates they, like <br /> Shell Oil, have only added a few feet to the drilled wellbore. <br /> White River Nahcolite spent years developing a successful process producing commercial sodium <br /> bicarbonate from solution mined nahcolite. Shell's solution project did nothing to develop such a <br /> process. From public observation,American Soda's experimental pilot plant disposes of the solution <br /> mined nahcolite. <br /> ? Commercial nahcolite solution mining and sodium bicarbonate production is as much an art as science. <br /> Commercial sodium bicarbonate must achieve a specific particle size distribution as well as high <br /> purity. Experience teaches that both of these factors are difficult to control and strongly influenced by <br /> natural solution mining impurities. These impurities can be organic or inorganic. <br />