2015-11-30_HYDROLOGY - M1983194

• Permit No: M1983194
• IBM Index Class Name: HYDROLOGY
• Doc Date: 11/30/2015
• Doc Name: Comments
• From: Daub & Associates / Natural Soda
• To: DRMS
• Email Name: THM
• Media Type: D
• Archive: No

Natural Soda LLC/Daub ft hte. — Uit PPlrmlt cootie*, November 2015— Draft UIC Permit #0030358-00000
Item*
UK Perm Location
ws/G&A comment
Requested Revision
Pym *
SectionParafraPhl
Sentence
Statement of Basis (SOB)
1
SOB Page 3
Background
2nd Paragraph
3rd Sentence
NS has replaced the American Institute of Baking Certification with
NSF/ANSI 60 and the Foundation for Food Safety FSSC 22000 certification.
The EPA should revise as shown.
NS currently holds a Food and Drug Administration (FDA) approval, NSF/ANSI 60. and FSSC
22000 Certification to produce food grade sodium bicarbonate from their operation.
2
SOB Page 3
Background
6th Paragraph
2nd Sentence
To more accurately represent the geology, the EPA should revise as
shown.
As this barren fluid passes through a nahcolite bearing horizon it dissolves and becomes
saturated with sodium bicarbonate, leaving in place insoluble rock.
3
SOB Page 4
Hydrogeologic
Setting
3rd Paragraph
1st Sentence
To more accurately represent the hydrogeologic and geologic setting, the
EPA should revise as shown.
In discharge areas, water moves upward from the Dissolution Surface Aquifer through the R-6
and Mahogany Zones to the B -Groove and A -Groove Aquifer.
4
SOB Page 4
Geologic Setting
1st Paragraph
4th sentence
To more accurately represent the hydrogeologic and geologic setting, the
EPA should revise as shown.
The Basin contains reserves of coal, natural gas, oil shale, sodium chloride, sodium
bicarbonate and Dawsonite.
5
SOB Page 4
Geologic Setting
2nd Paragraph
2nd Sentence
EPA should revise as shown.
The Uinta Formation is characterized by low porosity sandstone and siltstone with
intertongues of Green River Formation marlstone and oil shale up to approximately 1,200
feet thick.
6
SOB Page 5
Geologic Setting
1st Paragraph
2nd Sentence
To more accurately represent the hydrogeologic and geologic setting, the
EPA should revise as shown.
NS has targeted the Boies Bed within the lower L-5 zone in the Parachute Creek member for
solution mining.
7
SOB Page 5
Leached Zone
2nd Paragraph
EPA should revise the Paragraph as shown.
The basal 50 to 100 feet of the Leached Zone is intensely leached and rubblized, but does not
produce Targe amounts of groundwater. Discharge is generally greater in the B -Groove.
Overall in the Lease area, the Leached Zone has a thickness ranging from 650 to 700 feet.
8
SOB Page 6
A -Groove
2nd Paragraph
9th Sentence
EPA should revise as shown.
The lower interval may contain numerous horizons of vugs dissolution features and rubble.
9
SOB Page 6
L-5 Zone
1st Paragraph
6th Sentence
EPA should revise as shown.
Near the base of the L-5 zone, just above the Dissolution Surface, are a series of dissolution
rubble intervals ranging in thickness from less than one foot to more than 25 feet.
10
SOB Page 10
Table 2.4
4th entry
Green River - L-5 TDS level, Replace "25,000" with ">25,000"
TDS (mg/I) 2,400 - >25.000
11
SOB Page 10
Part 111
2nd Paragraph
2nd Sentence
The SOB states a max temperature of 300 deg. F which may be to low for
future NS operations.
The temperature of the barren fluids injected through the wellbore may reach a maximum of
350 dea F.
12
SOB Page 11
Area of Review
1st Paragraph
Sentence
EPA should revise as shown.
The AOR for this area permit is defined to be a quarter mile outside of
the lone -half mile outside the BLM lease boundary).
UIC NSpermit boundary,
13
SOB Page 11
Area of Review
4th Paragraph
1st Sentence
EPA should revise as shown.
A search of the Colorado Division of Water Resources database indicates that there are no
active drinking water wells (domestic or public) within 6 miles from the recently added
Federal Sodium Lease area COC -0119986 proposed for aquifer exemption.
14
SOB Pa a 12
g
Approved
Injection Fluid
(b) (d)
The EPA should revise as shown per comments listed for Permit Section
C.5
EPA should add a statement allowing NS the following:
(b) fresh water pumped from the A -Groove Aquifer or other fresh water source, used as
make-up water;
(c) make-up water from the process pond.
(d) iniection of recovered insoluble material from formation to aid in the stability of a
cavi .
Daub & Associates, Inc.
Page 1 of 6
UIC Draft Comments - November 2015