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Date: July 15, 1999 <br />To: Allen Sorenson <br />From: Harry Posey <br />Subject: Ameralia meeting <br />I met today with Roger Day (Ameralia) & Jack Clark (consultant), as planned, to discuss DMO <br />status and perceptions for Ameralia's proposed nahcolite operation. <br />Mr. Day presented reasons and justifications to classify Ameralia as a non -DMO. We discussed <br />some of the regulatory mechanisms that might back their proposal, should they decide to oppose <br />the Division's decision. These included: <br />(a) prove that process solutions contain no toxic materials, or <br />(b) show the Division /Board that they are a small generator. <br />Ameralia presented several of their avenues of pursuit, including: <br />(1) a worst case spill calculation for a risk assessment, <br />(2) comparison of production rates for the three local operations, <br />(3) water quality data for Yellow Creek showing current state of degradation, and <br />(4) analysis of White River Nahcolite's process solution. <br />(1) The spill calculation purports that a spill would have minimal consequences. It considered <br />the following: <br />a. maximum amount of process solution ever in transit or in storage, <br />b. maximum number of wells that will be in production, and <br />c. pumping rate <br />d. estimated response time. <br />With those considerations, it was calculated that a spill lasting 15 minutes could release about <br />one water truck's worth of solution. <br />(2) The volume comparison for yearly production from the various adjacent operations indicates <br />that Ameralia's production volumes are 1/10 that of the highest volume producer: <br />American Soda = 1.5 mtpy <br />White River = 0.125 mtpy <br />Ameralia + 0.150 mtpy (at max production). <br />The water quality analysis from Yellow Creek indicates that the creek is degraded beyond its <br />agricultural classification for several parameters. Hence, its uses are limited and the stream <br />is use protected. Moreover, it is about 20 miles to higher water quality classification waters <br />on White River. <br />(3) <br />(4) The White River Nahcolite process solution analysis shows mostly non - detects for metals. <br />Discussion. <br />We discussed adequacy of the 15- minute duration assumption. (The mining plan apparently calls <br />for 24 -hour oversight and monitoring and manual shutoff for emergencies. Automatic shut -offs <br />will not be employed.) <br />Ameralia was cautioned to be aware that assumptions factored into spill prediction calculations <br />might become permit conditions. <br />