2015-11-30_HYDROLOGY - M1983194 - Laserfiche WebLink

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Natural Soda 11C/Daub & Asso -ine. tNC Perthit bar 2015— Draft UC Permit f1C030350-10000 Reind INC Permit location , + NS/INIACannnrt - M*rotted Revision Pep R Section PeratirePAI 24 Permit pg. 8 Section C - 6 2nd Paragraph 2nd Sentence 3rd Sentence NS requires prompt response for approval from the Director to allow for timely completion of necessary work. Early in the development of a cavity, the potential exists to cool off and plug the flow path through the cavity rendering the well pair permanently inoperable. EPA should add a statement as follows: If the Permittee is unable to complete work within the specified time period, the Permittee may provide an alternative schedule and shall obtain Director's approval. Infection operations shall not resume until the well has successfully demonstrated mechanical integrity and the Director has provided verbal and written approval to recommence infection. The Director will respond to the permittee within twenty four (24) hours of receiving notification followed by written approval. If no response is received from the director within twenty four (24) hours of notification (phone/e-mail/fax/mail/overnight carrier). the permittee has authorization to proceed with proposed operations. 25 Permit pg. 9 Section D - 1 (b) 1st Sentence The proposed sentence more clearly defines the approval timeline when conducting Part II MIT tests. EPA should revise as follows: Within 90 days of receiving authorization to inject and periodically as specified in APPENDIX B, the Permittee shall demonstrate external Part II MI. 26 Permit pg. 9 Section D 3 1st Paragraph 1st sentence A 30 day notice prior to conducting any MIT is now required, the previous MIT notice was 10 days prior to an MIT. This may lead to potential conflict for timely completion of planned and unplanned MIT's. EPA should revise the MIT notice period to 10 days, as required in the previous NS UIC permit. 27 Permit pg. 10 Section D - 4 2nd Paragraph 1st sentence NS requires prompt response for approval from the director to better allow NS to plan and conduct necessary work. Injection operations shall not resume until after the MI loss has been resolved, the well has demonstrated mechanical integrity pursuant to 40 CFR §146.8, and the Director has provided approval to resume infection. The Director will respond to the permittee within twenty four 124) hours of receiving notification followed by written approval. If no response is received from the director within twenty four (24) hours of notification (phone/e- mail/fax/mail/ovemight carrier), the permittee has authorization to resume iniection. 28 Permit pg. 10 Section E - 2 1st Paragraph 4th sentence Any revision to NS EMP/SAP documents now requires EPA written approval to be accepted as a condition of the UIC permit. To prevent delays with other governing agencies a response period should assigned with this condition. NS will notify EPA of any modification to the EMP/SAP. Within 30 days of this notification the EPA can respond. if no response is received the modification will be deemed accepted. 29 Permit pg. 11 (SOB pg. 16) Section E - 3 1st Paragraph 1st sentence A subsurface subsidence well shall be required for every two cavities mined and will be installed prior to the development of the first cavity and proximally located near the intersection of the injection and recovery well. Clarification is needed as to the timing of the surface subsidence well installation, which needs to occur after the completion of the well pair. EPA should clarify permit language as follows: A subsurface subsidence well should be required for every two cavities mined and will be constructed upon completion of the injection and recovery wells. EPA should also include: NS will install a subsurface subsidence well proximal to the Intersection of the 1514 Infection and Recovery wells upon obtaining all necessary permits. which may occur within 9 months of this UIC permit issuance. 30 Permit pg. 11 Section E 3 2nd Paragraph 1st sentence It may not be possible to place Subsurface Subsidence wells proximally located at the intersection of all injection and recovery wells due to restrictions related to the land surface. These restrictions would be archeological sites, paleontological sites, topographic limitations (streams/drainages/cliff bands), etc. The EPA should add a provision allowing alternate SSMW locations with approval and consider the following wording: For recovery well configurations that include a horizontally drilled injection and recovery well, the subsurface subsidence wells shall be sited directly over the cavity, proximally located at the intersection of the injection and recovery wells. Subsurface subsidence wells may be sited at alternate locations adiacent to or between the infection and recovery wells when the land surface or BLM regulations/requirements do not allow well construction at preferable sites. Daub & Associates, Inc. Page 3 of 6 UIC Draft Comments - November 2015