HYDRO21989

• Permit No: M1999002
• IBM Index Class Name: Hydrology
• Doc Date: 6/26/1999
• Doc Name: VIC INFO
• From: TOM DODSON & ASSOCIATES
• To: US ENVIRONMENTAL PROTECTION AGENCY
• Media Type: D
• Archive: No

.-• ~OM DODSON & ASSOCIATES
' 2] 50 N. ARROWHEAD AVENUE
~' ~ SAN BERNARDINO, CA 92405
• TEL [phone] FAX [phone]
E-MAIL [e-mail]
June 26, 1999
Mr. Chuck Williams (8P-W-GW)
U. S. Environmental Protection Agency
999 18`h Street, Suite 500
Denver, Colorado 80202-2466
Dear Mr. Williams:
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The following comments are submitted for your consideration regarding the "Draft
Area Permit Class III Solution Mining Wells Yankee Gulch Project, EPA Area Permit No.
C03858-00000", prepared in May 1999. The basis for submitting these comments is
a concern that inaccurate data is being used by the U. S. Environmental Protection
Agency (EPA) in preparing the permit and that additional monitoring should be
required to ensure that degradation of an underground source of drinking water
(USDW) is not caused by issuance of the Draft permit as proposed. Please consider
the following comments prior to issuing the Draft permit and I would like to be
informed of the resolution of comments and issues raised below.
Draft Statement of Basis and Draft Area Permit
Page 2: I have been reviewing most of the American Soda Yankee Gulch
permitting efforts and several documents have discussed the
"temperature below that which the destructive distillation of oil shale may
occur." Yet, not a single document provides any evidence that defines
the point at which destructive distillation of oil shale (kerogen) begins to
occur when it is exposed to "rubblization" due to the proposed mining
technique and continuous temperatures greater than 300° F for extended
periods of time. In particular, American Soda's proposed mining
technique envisions leaving about 70% of the cavity volume mined as
rubblized oil shale waste in the cavities created by solution mining.
Volatile organic compounds (benzene, toluene, xylene and other VOC)
may be capable of being stripped from the rubblized oil shale at the
proposed mining temperatures.
Please make a complete evaluation of whether partial distillation of the
oil shale can occur as a result of this process and incorporate the findings
in the final permit, if the permit can still be issued without causing this
type of distillation. In addition, the potential for inclusion of VOC in the
production Fluid should cause the EPA to require monitoring of both fluid
and vapor concentrations of such chemicals (organics) as part of the