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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43
Pg. D-2
(Permit Pg.
12)
Appendix D
Subsurface
Subsidence Table
Permit Condition
Subsurface Subsidence Monitoring now requires any subsidence indicated
by TDR or a log of 6 inches or more shall be reported to the EPA. Six
inches of subsidence is not currently detectable, using current technology
for detection. Two (2.0) feet is the minimum detectable level of
subsidence, requiring a reportable value greater than 2.0 feet.
EPA should update the permit to allow 2.0 feet of subsidence, 6 inches is not detectable with
current technology for detection.
44
Pg. D-2
(Permit Pg.
12)
Appendix D
Subsurface
Subsidence Table
Permit Condition
The language related to Gamma Ray logging should be consistent with
Permit Section E.3 and the SOB (SOB pg. 16).
EPA should revise wording as follows:
1) following completion of the well to establish baseline for the infection well associated
with the first cavity; 2) after 50% of planned nahcolite recovery of the first cavity; 3) after
75% of planned nahcolite recovery of the first cavityi 4) following cessation of the first and
second mining cavities; and 5) after 3 years of cessation of mining of the second cavity.
45
Pg. D-2
(Permit Pg.
12)
Appendix D
Subsurface
Subsidence Table
Reporting
The word order in the following sentence should be corrected.
The annual report will provide the quarterly analysis of TDR data and all of the gamma ray
logs that were conducted within 60 days.
46
Pg. D-2
Appendix D
Surface
Subsidence Table
Record Frequency
The EPA should correct the table from biannually to at least once every
two years (biennially) per language in the SOB on page 17.
Biennially - At least once every two years.
Appendix E
47
Pg. E-1
Appendix E
1st bullet point
Appendix E now requires that an MIT part I test be conducted prior to
plugging and abandoning a well. Any casing leaks will need to be repaired
prior to completion of P&A operations. This is an unnecessary step, any
casing leak will be plugged by cement.
This step is unnecessary and should be omitted from the permit.
Daub & Associates, Inc.
Page 6 of 6 UIC Draft Comments - November 2015