HYDRO30213 - Laserfiche WebLink

Home Browse Search

solution mining of sodium minerals at the project site ("Evaluation of Impacts to Oil Shale Due to Solution Mining of Sodium Minerals, Yankee Gulch Sodium Minerals Project", Agapito Associates, Inc., September, 1999). Further, the BLM ROD indicated that the document is a summary of a literature search on low temperature effects on oil shale and of the process data collected during the Yankee Gulch pilot plant. The information from the pilot plant shows organic compounds are found in the recovery production fluids. The project quantified the potential volatile organic hydrocarbon (VOC) emissions from the well head gas sepazators, stripper system, and the combustion sources. These data collected show that it does not appear that the organic compounds detected in the production streams aze indicative of distillation of the oil shale. Although the information in the September report was not considered directly relevant to EPA's Class III Permit decision, a copy of the report has been placed in the Administrative Record for the Permit. In any event, it is EPA's understanding that BLM is requiring the operator to conduct their commercial operations in conformance with the lease terms, including the protection of oil shale resources, as authorized by the BLM. As a result of the review of these comments and the associated information, EPA has determined that no changes to the Permit are needed in response to this specific concern. Comment 22: What verification has American Soda submitted re as rding "assumed production per well" (See Page 4 SOB). Response: EPA considers this concern to be more of resource recovery issue than a concern relating to the protection of USDWs. The resource recovery and verification of nahcolite production comes under BLM jurisdiction. As explained elsewhere in the Permit, the applicant has provided EPA with information relating to the proposed injection and production stream pressures and volumes. These target values were based on the review and evaluation of data from the test cavities. EPA has no reason to dispute the proposed injection parameters. As a result of the review of this comment and the associated information, EPA has determined that no changes to the Permit are needed in response to this specific concern. Comment 23: There has been a fundamental depravation of the public's rieht to comment on thines before they are approved. Response: EPA does not agree with this comment as all the material not determined to be confidential business information, under the provisions of 40 CFR Part 2, was made part of the administrative record. For instance, the Ground-water and Surface Water Monitoring Plan and the Subsidence Monitoring plan were available for public review along with the Draft Statement of Basis and the Draft Class III UIC Area Permit when the Draft Permit was issued on May 19, 1999, which was the commencement of the public comment period. Although the wtial rough draft of the water monitoring plan, submitted on April 11, 1999, was marked confidential, this was done to allow the various regulatory agencies an opportunity to requ've changes before issuance of a public document. The Water Monitoring Plan and the Subsidence Plan (both dated 38