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• • <br />Letter to Roger Day 2 June 18, 1999 <br />aquifer may also be dissolved by the solution mining injection fluid. For further discussion on <br />this topic, see the attached memo prepared by Harry Posey <br />As a DMO, an Environmental Protection Plan (EPP) will be required for the Rock School Lease <br />Project. The required elements of an EPP are listed in Rule 6.4.20. <br />2. To evaluate the nature of any impurities that may be collected by the mining solution, DMG will <br />require that AmerAlia provide chemical analysis of the pregnant soda liquor to be recovered from the <br />mining cavities. This analysis should be conducted as soon as possible once operations commence. <br />Analysis should be completed for a full suite of inorganic parameters as discussed in item 7 below, and <br />for dissolved organic carbon, BTX, oil and grease, and methane. The analyses should be for the <br />dissolved form of the constituents. These analyses will provide information relative to the DMO <br />determination under item 1.b. listed above. If trace elements or contaminants are present in the process <br />water stream, DMG will require a description of the management of these elements or contaminants. In <br />particular, will any trace elements or contaminants be refined out of the process solution at the on -site <br />processing facility? And if so, how will the waste stream be disposed of or otherwise managed? This <br />waste stream may include any solids filtered from the pregnant soda liquor as discussed in sections D- <br />3.2 and D -3.6 of the application. <br />3. Structural elements at DMOs designed to contain or control process solutions are defined in the <br />Rules as Environmental Protection Facilities (EPF). EPFs at the Rock School Lease Project would <br />induce the cased solution mining wells, the surface piping network, the process solution ponds, and the <br />processing plant itself. Rule 7.3 lists design and construction requirements for EPFs. The application <br />of these requirements to the Rock School Lease Project is discussed in the following subsections. . <br />a) Plans, specifications, and a quality assurance protocol for the ponds must be incorporated into <br />the application. Specifications are required for both the embankment earthwork and the <br />geosynthetics installation. Quality assurance requirements should list the types of tests to be <br />conducted with reference to appropriate standards and should specify the frequency at which the <br />testing will be conducted. The pond specifications should include a statement that AmerAlia <br />will advise the DMG of the basic schedule for pond construction and liner installation in order <br />to facilitate DMG inspections of the work. A statement must also be included that any changes <br />to the plans and specifications are subject to review and approval by the DMG. Upon <br />completion of pond construction, Rule 7.3.2 requires certification of the installation by a <br />professional engineer or other qualified individual that the facility was constructed in <br />accordance with the approved plan. The certification should include a construction report and <br />drawings illustrating the as -built configuration of the pond and the geomembrane panels. <br />b) The DMG will require that AmerAlia include with each annual report a certification by a <br />professional engineer or other qualified individual that each solution mining well installed <br />during that year was appropriately cased and cemented to prevent comingling of aquifers and <br />transmission of process solutions outside the casing. Each well should be tested prior to <br />operation. Please provide a detailed description of the mechanical integrity testing methods and <br />well logging that will be employed with reference to appropriate standards or guidance <br />