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HYDRO31424
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HYDRO31424
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Entry Properties
Last modified
8/24/2016 8:55:07 PM
Creation date
11/21/2007 1:44:57 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1999051
IBM Index Class Name
Hydrology
Doc Date
2/1/2001
Doc Name
Underground Injection Control
From
EPA
To
DMG
Permit Index Doc Type
Correspondence
Media Type
D
Archive
No
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<br />and during the period after injection commences (weekly for water level, temperature, and <br />conductivity). Because the Dissolution surface is the interface between the Saline Zone and the <br />first overlying aquifer that could be impacted by a cavity failure, EPA believes that weekly <br />monitoring of the three indicator parameters is needed to provide a means of early detection of <br />problems. The requirement for actual sampling of the Dissolution Surface aquifer on a monthly <br />or quarterly basis have been dropped in favor of this indicator monitoring. It should be noted <br />that these requirements are consistent with the monitoring required by the recently issued Yankee <br />Gulch Area Permit. In addition, the Permit has been modified to give the Director authority to <br />add additional monitoring parameters if deemed necessary after baseline monitoring. <br />Should the operator request an expansion of the wellfield, an expanded ground-water <br />monitoring network with appropriate baseline will be required as indicated in the Statement of <br />Basis. The Final Permit language has been amended to clearly require submittal of an expanded <br />monitoring plan with any request for expansion of the wellfield. Depending on the scope of any <br />expansion, the increased monitoring could include new wells that would assess up-gradient, <br />down-gradient, and cross-gradient flow paths. <br />The injection well monitoring program called for in the Rock School Lease Draft Permit is <br />similar but not identical to other commercial in-situ nacholite mining facilities in the basin. <br />Although the list of sample constituents is not as comprehensive as that provided for in the <br />Yankee Gulch Permit, the number of constituents could be increased as needed when the facility <br />requests expansion. To facilitate this process, the Draft Permit has been modified to require <br />monthly monitoring for all major anions and cations for the first six months of operation. This <br />will provide adequate data on which to establish a monitoring baseline for the constituents in the <br />production and injection fluid streams. <br />Based on a review of all comments, EPA does not believe that there are grounds for <br />denial of the Permit. EPA believes that the Final Permit conditions as amended are <br />adequate to address the potential for contamination of USDWs as result of this project. <br />Therefore, EPA has decided to proceed with issuance of the Permit. <br />Comment 2: Commentors believe that the technology has been proven by other previously <br />permitted facilities and that this Permit should be issued to allow the Company to demonstrate the <br />viability of their project. <br />Response: EPA agrees with the comments. During the application process, EPA determined <br />that the technology for in-situ mining of nahcolite contained in oil shale deposits had been proven <br />to be viable based on work done at the nearby Yankee Gulch Lease. Any new facility, however, <br />will have differences in geologic conditions that may require slight differences in the production <br />techniques than those utilized at other facilities. EPA and commentors concurred that the <br />operator of the Rock School Lease was justified in starting with a pilot phase to develop a better <br />understanding of the specific operating conditions needed for this facility. For this reason, the <br />permit allows a startup using three (3) initial cavities. Based on the results ofthis phase of the <br />project, the Area Permit will be modified to allow additional cavities. <br />4 <br />
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