Laserfiche WebLink
1 <br />1 <br /> <br /> <br />1 <br /> <br /> <br />1 <br /> <br /> <br /> <br /> <br /> <br /> <br />1 <br />1 <br /> <br /> <br /> <br />December 13, 1999 • • Pnge 11 <br />Monitoring systems will be in place at the solution mining well trunk line (upstream of the <br />steam stripper) prior to raising average cavity temperatures above 300°F. Baseline data will be <br />collected for carbon dioxide, dissolved organic carbon, BTEX (benzene, toluene, ethyl benzene, <br />and xylenes), oil and grease, and methane from the process stream. These parameters will be <br />monitored on a monthly basis for the remainder of test mining operations and during commercial <br />mining operations. <br />Potential leakage from a solution cavity will be monitored by comparative evaluation of <br />injection and production fluid (and/or mass) flow rates and nitrogen consumption, which will be <br />automatically reported to a master control system. The nitrogen gas cap will be monitored daily by <br />measuring nitrogen consumption and production fluid pressure. <br />4.2 Hazardous Waste Determination <br />Once commercial operations begin, American Soda will evaluate each of the Class III UIC <br />permitted injection fluids (injection fluids) separately to ensure that they are not hazardous wastes <br />(as defined by 40 CFR Part 261.3). American Soda will refer to 40 CFR Part 262.11 in making <br />this determination. Due to the fact that the hazardous waste "lists" have already been examined, <br />and none of the injection fluids are "listed," the review will be limited to an evaluation of <br />"hazazdous characteristics." The hazardous waste characteristics, which are ignitability, <br />corrosivity, reactivity, and toxicity, are defined in 40 CFR Part 261 Subpart C. <br />None of the injection fluids in test mining operations exhibited hazardous "characteristics." <br />Therefore, since comparable fluids will be used for injection during commercial operations, <br />American Soda expects that commercial injection fluids will also not be considered hazardous <br />wastes. Nonetheless, each characteristic will be evaluated. The characteristics of ignitability and <br />reactivity will be evaluated by performing a technical review of the processes and raw materials <br />used in the operations that generate the injection fluids. If necessary, a "flash point" test will be <br />performed for the ignitability characteristic. The "corrosivity" characteristic will be evaluated by <br />use of a pH meter to measure the pH of the fluid. The "toxicity" characteristic will be evaluated <br />by having a sample of the injection fluid analyzed by an off-site, certified laboratory. The <br />parameters that will be measured in the injection fluid will be those that are contained on the <br />"TCLP list" (40 CFR Pari 262 Subpart C). Because the injection medium is a liquid, the total <br />concentration of each parameter will be measured rather than the "leached" concentration. If the <br />Agapito Associates, Inc. <br />