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<br />2. a) Plans and specifications for the 13-acre evaporation pond at the Piceance <br />Site will be incorporated into the permit prior to initiation of pond construction. <br />Specifications for this pond will be submitted as a technical revision to the 112 <br />Permit Application under DMG Rule 1.9. American Soda will advise the DMG <br />of the basic schedule for pond construction and liner installation in order to <br />facilitate DMG inspections of the work. Design changes to plans and <br />specifications for pond construction will be submitted to the DMG for its review <br />and approval. An installation certification would be provided in accordance <br />with DMG requirements. <br />b) Mechanical Integrity Testing (MIT) will be performed on each well prior <br />to operation in accordance with EPA Underground Injection Control Permit <br />requirements. Mechanical integrity will be demonstrated by a combination of <br />methods, including cementing records, pressure testing, well bore logs, and <br />cement bond logs. Guidelines for MIT, as established in 40 CFR 146.8, have been <br />included with the Summary Reference Document. An installation certification <br />would be provided in accordance with DMG requirements. American Soda will <br />also submit a certification and abandonment report for each well that has been <br />abandoned and plugged during the project year. <br />c) Monitoring of the well field piping will be conducted in accordance with <br />the Well Field Spill Plan (Appendix G) of the Preliminary Response Plan. This <br />plan was submitted to the DMG as a technical revision to the 112 Permit <br />Application by letter dated April 23, 1999. Monitoring, as described in this plan, <br />includes an emergency alarm system programmed to activate when a substantial <br />decrease in pressure has been identified in the well field piping. Visual checks of <br />the well field will be performed twice daily (once every 12-hour shift). A visual <br />inspection of valves and flanges in the well field piping will be conducted once <br />per week by maintenance staff, and acheck-off sheet will be used to document <br />the inspection results. <br />Information on piping; specifications is provided in Attachment 6 of Appendix A <br />(Summary Reference Document). Each annual reclamation report to the DMG <br />will include certification of the proper installation of all well field piping for the <br />report year in accordance with DMG requirements. <br />d) Spills that cannot be contained in the immediate processing area and <br />runoff from the Piceance Site processing facilities will be directed to a 1-acre <br />stormwater retention pond. Specifications for this pond have been submitted as <br />a technical revision to the 112 Permit Application by letter dated April 16, 1999. <br />The Preliminary Response Plan establishes procedures to capture spills prior to <br />their entering the stormwater system. However, it is possible that a large, <br />sudden release of liquid in the processing area could enter the stormwater pond. <br />'~: APplu~~n AyyW[Y Pno..~ 2 <br />~nM t.YM Stlnm Muw~Y ITTn <br />ArTV, YdL LLP. <br />