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Letter to Roger Day 6 June 18, 1999 <br />is mined upward, the material balance will not be able to characterize cavity shape if irregular cavity <br />walls develop. DMG suggests that the following procedure be employed to establish cavity size <br />controls as enforceable components of the reclamation permit: <br />a) AmerAlia should commit to developing individual cavities during the initial undercut no larger than <br />125 feet in diameter, measured by material balance, without first conferring with the DMG. <br />b) AmerAlia should commit to evaluating technologies that may be available to characterize the size <br />and shape of solution mining cavities and to evaluating the effectiveness of the material balance <br />approach. The results of these evaluations would be provided to DMG for review and acceptance <br />prior to raising the gas cap to mine the second resource interval. <br />c) Provide DMG a copy of the report by Prats (1977) referenced in the permit application. <br />d) Due to the criticality of characterizing cavity size and shape to assure that material damage from <br />subsidence will not result, AmerAlia may be required to drill the test cavities if no functional <br />remote sensing method is found to be suitable. <br />10. In the permit application it is stated that residues in the evaporation pond will be tested at the time <br />of final reclamation, and based on the results of that testing the pond liner and pond residues will either <br />be buried and reclaimed in place, or will be removed from the site and disposed of in a landfill. For the <br />purpose of estimating reclamation costs and establishing the amount of reclamation bond to be required, <br />DMG will assume the more expensive reclamation alternative, which is off site disposal. In order to <br />facilitate the estimation of this cost, please provide DNICI with an estimated volume of liner and residue <br />to be removed, a description of methods and equipment needed to remove the contaminated material <br />and transport it to a landfill, the location of a landfill that would accept the contaminated material and <br />the tipping fee that would apply. <br />11. Wildlife issues to be addressed are listed here. <br />a) The plant site and process solution ponds should be fenced. Eight foot high chain link or <br />equivalent will be required to exclude mule deer. Please provide a description of the fence to be <br />installed. Include a description of installation measures to be employed to assure that wildlife <br />will be prevented from crawling under the fence. <br />b) The process solution ponds should be netted to exclude birds. See the attached memo from <br />Harry Posey for further discussion of items 1 1.a and b. <br />c) Reestablishment of wildlife habitat on disturbed land will be largely a function of the successful <br />reestablishment of woody stem plant species. The reclamation plan included in the permit <br />application proposes a seed mixture that includes both herbaceous and shrub species. Both <br />DMG and the Colorado Division of Wildlife (DOW) are concerned with the potential for <br />grasses to out compete shrubs for available moisture and thus hinder shrub establishment on the <br />reclaimed landscape. In order to better assure that shrubs and the wildlife habitat that they <br />provide are efficiently reestablished, DMG suggests that reclamation of larger disturbed areas <br />should incorporate strips of land, located along contour, where no grass seed is planted. These <br />contour strips would be approximately 20 feet wide and spaced every 100 to 300 feet. Within <br />