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

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31
Permit pg. 11
Section E - 3.b
2nd Paragraph
(d e)
Correct alphabetical sequence, see d) and e) and language to be
consistent with Appendix D and the SOB.
The Alphabetical sequence should be corrected as follows:
a) following completion of the well to establish baseline for the infection well associated
with the first cavity. b) after 50% of planned nahcolite recovery of the first cavity; c) after
75% of planned nahcolite recovery of the first cavity; di following cessation of the first and
second mining cavities; and 1 after 3 years of cessation of mining of the second cavity.
32
Permit pg. 12
Section E - 4
1st Paragraph
2nd sentence
The UIC Permit calls for Surface Subsidence monuments (SSM) to be
monitored biannually. This is not consistent with provisions set forth in
the SOB on page 17 which calls for SSM to be monitored at least once
every two years.
EPA should revise permit language such that Surface Subsidence Monuments are monitored
at least once every two years as stated in the SOB.
33
Permit pg. 13
(SOB pg. 18)
Section F - 4
1st Paragraph
1st sentence
Submittal of reports is now required within 30 days following completion
of a P&A, previously 60 days was allowed. Conflicting wording is found in
the SOB (page 18) still allowing the previous 60 day time period.
EPA should revise permit to allow 60 days for P&A report submittal as indicated by the SOB
(page 18).
34
Permit pg. 13
(SOB pg. 18)
Section F - 4
1st Paragraph
1st sentence
Plug and abandon reports shall be submitted using EPA form 7520-14
according to the permit, or using EPA form 7520-13 according to the SOB.
It is not clear which form should be used.
EPA should clarify whether EPA form 7520-13 or 7520-14 should be used and revise wording
to indicate he proper form in both the SOB and permit.
Appendix A
35
Pg. A-1
Appendix A
1st Paragraph
2nd Sentence
2nd bullet point
Missing period at the end of the sentence.
If cementing to surface is not accomplished with initial cementing attempt, remedial
cementing techniques shall be employed to get cement to surface,
Daub & Associates, Inc.
Page 4 of 6 UIC Draft Comments - November 2015