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• <br />Letter to Roger Day 8 June 18, 1999 <br />end of the life of mine, and if adequate vegetation has been established the 2:1 slope may be <br />permitted to remain. <br />13. It is stated in section G -3.1 of the application that monitoring features of facilities designed to store <br />or convey process solutions will be inspected and their conditions recorded on a regular basis. Please <br />list and fully describe all monitoring systems, provide a schedule for monitoring of all systems, e.g., <br />continuous, daily, quarterly, etc., and list the criteria for the data generated that will trigger corrective <br />actions. The critical components subject to on -going monitoring would include, at a minimum, process <br />pipeline pressure and integrity, process solution volumes and mining cavity material balance, ground <br />and surface water, surface and subsurface subsidence, pond freeboard, and pond liner leak collection. <br />14. Reference is made to the enclosed memo prepared by Harry Posey. Most of the issues raised in the <br />memo will be addressed through responding to the above listed items. However, the following items <br />from the memo should be specifically addressed by AmerAlia in the adequacy letter response package: <br />General Comment no. 6, and Specific Comments numbered 4, 5, 6, and 7. In further discussion of <br />General Comment no. 6, AmerAlia should also describe measures to be taken to prevent aquifer <br />contamination if adverse structural geology is encountered during the drilling of production wells. In <br />addressing Specific Comment no. 4, AmerAlia should provide an on -going monitoring proposal for the <br />pregnant soda liquor that will demonstrate that distillation of oil shale is not taking place. <br />15. Please provide a description and specification for the heat and sulfate resistant casing cement <br />discussed in section D -3.3 of the application. <br />16. It is stated in section D -3.5 of the application that cavern stability evaluations included the <br />assumption that fluid pressures within the cavern exert a boundary pressure provided by the weight of a <br />column of water to the surface. Please provide a discussion of the basis for this, assumption. <br />17. Figure C -1 provided with the application has a scale of approximately 1" =900'. Rule 6.2.1(e) <br />requires that this map be provided at a scale not smaller than 1"=660'. <br />18. On figure C -1 it appears that approximately the first 400 feet of the access road is located outside <br />the proposed permitted area. If this road is new construction or a significant upgrade to an existing <br />road, this road segment must be included in the permit (Rule 1.1(4)) and legal right to enter <br />demonstrated in Exhibit N to the application. <br />19. In the lease agreement provided in Exhibit N to the application, the lessee is listed as E.E. Kinder <br />Company. Documentation must be provided showing that the rights have been granted to AmerAlia. <br />20. Please note that Rule 8.1 requires operators to report within 24 hours any failure or imminent failure <br />of environmental protection facilities designed to contain or control process solutions. Under this <br />regulation, AmerAlia must report spills or leaks from well field piping or any other problems with <br />environmental protection facilities to the DMG within 24 hours. Undesirable event reports required by <br />