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provided in the April 29 letter. At the time the initial letter was written, B]LM did not <br />discount any water use attributable to the potential for American Soda to use air-cooled <br />technology versus the cooling towers (water-cooled) identified for product processing in the <br />draft EIS, nor did we consider the elimination of any evaporation ponds. The last pazagraph of <br />the listed fish discussion on page 10 of the April 29 letter was meant only to inform of <br />possible process modifications which would result in reduced water consumption. <br />In American Soda's most current design, as will be presented in the fmal IiIS, the cooling <br />towers would be eliminated from the Pazachute processing facilities, theretry reducing water <br />consumption by approximately 4 gpm. Therefore, the fmal annual consumptive water use <br />envisioned for the entire mining operation would be about 1158 acre-feet. Although <br />American Soda has added a 1-acre stormwater retention pond to the Piceat~ce processing site <br />(intercepting precipitation from the facility site), evaporative losses associated with this feature <br />had akeady been factored into the overall depletion figure. <br />Water Oualitv Effects <br />Although a somewhat lengthy inclusion, the "Surface and Groundwater Quality" portions of <br />the Proposed Action section aze meant to document BLM's consideration of these issues in <br />the context of endangered fish and their habitat. We aze satisfied that the various plans aze <br />adequate in assuring that any effects on groundwater or surface water expression would be <br />quickly detected and that contingencies emplaced to minimize the effects of accidents or <br />abnormal incidents aze sufficient. We feel that project-induced water contamination cannot be <br />foreseen as having an adverse influence on endangered fish cottservation. <br />Dtrect Involvement of 100-veaz Floodolain <br />The river intake system is an existing structure that consists of the concrete crib in the middle <br />of the Colorado River channel (see Proposed Action) and a pair of pipes t~uried beneath the <br />river bed. The pumping station is housed within a 3000 square-foot concrete structure on a <br />terrace about 90-feet lateral and 20-feet above the normal base flow mazgin of the channel. <br />The water is delivered from the pumphouse sump to an adjacent 5.5 acre ;settling pond which <br />sits on another bench about 5 vertical feet above the pumphouse facility. These terraces <br />support a greasewood-sagebrush community and do not appear to be active: components of the <br />current river channel. American Soda intends on replacing the pumps and electrical hardware <br />at the pumping facility and performing general maintenance activities on dt<is site. Inspection <br />and maintenance of the crib will be performed with boat access. Maintenance is expected to <br />involve handwork; no heavy equipment construction in the channel or on the banks is <br />anticipated. <br />We do not believe that this facility or minor construction and maintenance activities on <br />previously disturbed portions of these terraces would have an adverse influence on bank <br />stability or floodplain function along this reach of the Colorado River, and. would therefore, <br />have no adverse impact on the 100-yeaz floodplain as designated critical habitat. <br /> <br />