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• s <br />development, the BLM, EPA and DMG permits only cover (in detail) the first <br />phase of planned development. Therefore, if WRN does obtain the lease <br />modification, this would only change the long term mining plan which the BLM, <br />EPA and DMG have not been ask to approve. The overall sodium lease area of <br />8222.6 acres would not change significantly. In the next two-three years, WRN <br />will have to apply for a commercial Mine Plan with the BLM and EPA. At that <br />time, WRN will also submit long term plans to the DMG and modify permitted <br />disturbance acreage. In summary, the lease modification would not affect the <br />Division's permit boundaries for the current WRN project. <br />2. Second, leachate rages from the waste and process ponds have increased and <br />WRN hereby submits notification within the 30 day limit stated in your letter of <br />Mazch 1S, 1995. The following are most recent leachate rates for the WRN site: <br />p.~tg Waste Pond Pr ocess Pond <br /> >~ >~ ~ >~ <br />Jan.199S 68.8 9.4 241.9 80.6 <br />Feb.199S 318 45.4 215.6 71.9 <br />Mar.199S 242.•4 34.6 235 78.3 <br />-Apr. 11,1995 57.1 8.2 103.0 34.3 <br />Please use the latest leachate rates to compare to Table 6-16, page 93 of the <br />1994 Annual Report. 1Vote leachate rates are in gallons per day and gallons per <br />acre per day. Leachate rates are quantities collected and pumped back to ponds, <br />and it_ should lze road that leachate rates are not leakage_ from the ponds. The <br />difference is leachate moves through the first liner and is collected and pumped <br />back to the ponds, where leakage or seepage is that which moves into the <br />ground and could effect groundwater. <br />On March 18, 1993 W:IZN submitted to the Colorado Department of Health, <br />Water Quality Control Division (WQCD) a request for waiver of the <br />requirement to obtain a. Ground Water Discharge Permit (no reply has been <br />received to date). The letter to WQCD is attached for your information which <br />may address some of your concerns. The design of the waste and process ponds <br />was very conservative and met EPA design criteria for hazardous waste sites. <br />The water in the ponds is not a hazardous waste, but a salt brine. The <br />installation of the liner was by Gundle Lining Systems Inc. The top liner is a <br />60 mil. high density polyethylene (HDPE) material and the bottom liner is 40 <br />mil. HDPE. <br />