PERMFILE67880 - Laserfiche WebLink

Home Browse Search

Comment 21 The Reclamation Permit Application Should Contain A Mitigating Plan In The Event Of A Worst-Case Subsidence Scenario (Section U.2.2 Solution Mining Cavity Stability, Pg. U-3) Why was Agapito's initial worst~ase scenario rejected for a more conservative worst- case scenario? What were the predicted effects on the surface, groundwater and oil shale from Agapito's initial worst case scenario? What was the basis for Agapito's conclusion on Subsidence? Based on 80 years of solution mining experience and the lack of site-specific studies relating to Yankee Gulch, the incomplete disclosure of the Agapito study, and the substantially different geology's between the Yankee Gulch Site and the Windsor Site (referenced by Agapito in the DEIS), we believe that subsidence scenario contained in this permit application does not accurately reflect the potential for greater subsidence scenarios. American Soda should provide site-specific studies that support the subsidence scenario contained in the Reclamation Permit Application and the studies should be made available for public comment before a Reclamation Permit is considered. Comment 22 The Reclamation Permit Application TS Incomplete In That It Fails To Address A Number Of Key Concerns Regarding The Stability Of American Soda's Solution Mining Plan (Section U.2.2 Solution Mining Cavity Stability, Pg. U-4) Why does American Soda and Agapito fail to recognize the fact that there are many individual shale resource intervals that contain oil shale with grades equal to or in excess of 25 G.P.T. that must be protected pursuant to the American Soda Federal lease stipulations? There are numerous rich oil shale horizons in the solution mining intervals, directly above the proposed solution mining horizons, within the leached zone (600+ feet) and above the Mahogany Zone that have been overlooked, left out and not considered by American Soda, why? Why is only the Upper Aquifer of concern to American Soda and Agapito when the entire hydro-stratigraphic interval should be of concern and consideration? Since the previous conclusions of water quality provided by American Soda aze in contention, On the Division Of Mineral And Geology should not approve a Reclamation Permit which has only accounted for a portion of the total potential effected Aquifer's. The terse statement "Therefore, there is no anticipated significant impacts to the future mineability of oil shale..." is not supported or substantiated by any fact, data, information or research in this document, why? How can the public provide comments on such nebulous and limited amount of scientific input? Page 7