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<br />Project and a summary statement detailing how each issue was resolved, or in cases where the <br />parties remain unsatisfied, a summary of the DMG's position on the issue. This section shall <br />serve, in part, to satisfy the requirement of Rule 1.4.5(5)(b) for DMG to set forth a written <br />explanation of the grounds for a recommendation to approve an application over an objection. <br />Comment #1: Rio Blanco County raised a concern with the usefulness of ground water quality <br />data provided in the reclamation permit application. <br />Resolution: The County provided input for, and endorses, the "Ground Water and Surface Water <br />Monitoring Plan" that has been incorporated into the application. <br />Comment #2: The DOW provided comprehensive comments on wildlife and wildlife habitat <br />protection, restoration and mitigation measures. <br />Resolution: DOW was integrally involved in the preparation of the "Wildlife Mitigation Plan" <br />that has been incorporated into the permit, and is satisfied with the content of the plan. <br />The remaining comntettts in the list were submitted jointly by General Chemical Corporation <br />and Church and Dwight Company, lnc. <br />Comment #3: The Yankee Gulch Project should be a Designated Mining Operation. <br />DMG Position: The Yankee Gulch Project has been designated as discussed under "DMG Issue <br />#1" above. <br />Comment #4: Solution mining extraction temperatures proposed in the reclamation permit <br />exceed federal sodium lease limitations. How can the permit be approved to operate at 420 <br />degrees when the impact and consequences of such activities have not yet been characterized? <br />DMG Position: The federal government is responsible for enforcing the provisions of the <br />sodium leases at the Yankee Gulch Project, and neither the DMG nor the Board would require an <br />applicant coordinate lease requirements with the requirements of the reclamation permit. The <br />documents would be autonomously enforceable, so in effect the most restrictive requirement <br />between the two documents would apply. However, DMG cannot take an enforcement action <br />against an operator for violation of lease terms. The environmental protection issues related to <br />the injection of high temperature solution mining fluid are: <br />• Deterioration of cemented casing that may lead to leakage of process solutions into aquifer <br />systems. <br />• Dissolution of potentially toxic elements and compounds present in the rock that may be <br />carried with the pregnant process solution. <br />These issues are addressed in the application by: <br />• The cased and cemented solution mining wells are Environmental Protection Facilities as <br />defined in Rule 1.1(15). They must be installed and tested in accordance with the terms <br />listed in the permit including well logging, use of high temperature casing cement in the zone <br />