2004-09-08_REVISION - M1999002

• Permit No: M1999002
• IBM Index Class Name: Revision
• Doc Date: 9/8/2004
• Doc Name: Mod.- Ground Water Monitoring Plan
• From: American Soda LLP
• To: DMG
• Type & Sequence: TR4
• Media Type: D
• Archive: No

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AMERICAN
SODA, L.L.P.'
Ed Cooley
Health, Environment, and Safety Manager
2717 County Road 215
Parachute, CO 81635
Tuesday, September 7, 2004
Ms. Erica Crosby
Colorado Division of Minerals and Geology
1313 Sherman Street, room 215
Denver. CO 80203
Dear Erica:
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SEP 0 8 2004
Telephone [phone]
Facsimile [phone]
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ENV192.04
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Enclosed is Technical Revision;~o DMG Permit Number M-99-002. This technical revision provides
the basis for modification of the Ground Water Monitoring Plan associated with the Yankee Gulch
Sodium Minerals Project.
As you are already aware, we are currently transitioning to a period of temporary suspension of
production operations at our Piceance Creek site. The enclosed revision provides monitoring criteria
for both the interim status (temporary suspension of production operations) period and for
commercial production once operations resume. Included is data regarding the parameters
proposed for continued monitoring, Permit Condition Values (Numeric Protective Levels and Early
Warning Indicators), and a graphical summary of all of the constituents which are not recommended
for retention on the water quality parameter list.
In a recent phone conversation you asked about including volatile organic constituents such as
benzene, ethylbenzene, and total xylenes (BTEX) in the ground water quality list. Originally during the
permitting phase of the project there was discussion among the regulatory entities and American Soda
regarding monitoring organics in association with the mining activity. As a result of those discussions,
the sample collection and analysis of BTEX was included in the process analytical list and this data is
provided quarterly to the various regulatory agencies.
Bringing water up from depth in the ground water wells results in a pressure change that releases the
carbon dioxide and methane formerly in solution in the ground water. In most cases, the water is
saturated with bubbles at the surface. It is difficult to obtain a representative sample of the volatile
organics under such conditions. Also, at this point, we do not have background data to compare with
operational data.
American Soda has been collecting monthly BTEX samples in the production lines as required in the
original plan since the first month of solution mining operations. The process stream lines are closed
systems due to the temperatures and pressures of operation. Tedlar bags are used to collect the
volatile organics samples in the production lines so that any gaseous constituents are trapped in the
bag and not volatilized. To minimize any sampling error as a result of transferring, the sample is
collected directly into dedicated one time use tedlar bags from the process pipe sample port. Samples
are hand delivered to the EPA certified laboratory for analysis within 24 hours.
Natural Sodium Products For A Cleaner Environment