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Proposed Action <br />Surface and Groundwater puality <br />In our original Biological Assessment we did not address the potential for groundwater or <br />surface water contamination in any detail. These issues have received a hil;h level of public <br />and governmental scrutiny throughout the NEPA process, and although we feel that pollution <br />control mechanisms installed within the Agency Preferred Alternative aze as thorough and <br />efficacious as the situation warrants, we feel it is appropriate to give this isstre increased <br />attention in this document. <br />The following discussions outline the pertinent issues involving the potential for project- <br />related contamination to local water sources, as well as designs for protecting the quality of <br />ground and surface waters (pages 4-9 through 4-18 of the Draft EIS provide details). <br />Surface Wager <br />With the exception of storm water runoff, both facility sites have been designed to eliminate <br />any accidental dischazge to off-site surface water. Storage and evaporatio~t ponds have been <br />designed to accommodate all process water with a required safety factor a~td freeboard safety <br />mazgin (in accordance with Bureau of Reclamation Small Dam Design criteria). All <br />evaporation ponds will be constructed with a double liner and leak detection and collection <br />system in accordance with CDMG requirements. Storm water runoff will be captured at both <br />facilities in 1-acre retention ponds, suspended solids allowed to settle, the water tested and, if <br />meeting appropriate dischazge permit limits and water quality standards, dt;canted into an <br />adjacent ephemeral drainage (Piceance site) or Pazachute Creek (Pazachute site) under a <br />Colorado Pollution Dischazge System (CPDS) permit administered by the Colorado <br />Department of Public Health and Environment. Ponds designed to control facility runoff have <br />been designed to withstand a 24-hour, 100-year flood conditions in addition to a volume <br />equal to the lazgest capacity storage tank on-site plus a 50% safety capacity margin. <br />American Soda has prepazed a Preliminary Response Plan that addresses various safety, spill <br />prevention and materials management issues, and includes BLM and OSH.~ requirements for <br />spill detection, confinement and cleanup. This plan requires that hazardous materials be stored <br />in durable containers and located such that any accidental spillage would riot drain into waters <br />courses or groundwater. Larger quantities of hazazdous materials (>500 g;rllons) must be <br />surrounded by impermeable containment structures designed to contain 150% of the total <br />storage volume of storage tanks plus all possible precipitation and runoff that might be <br />simultaneously impounded. <br />A °Pipeline Plan of Development" has been developed and contains information on detection <br />and response to an accidental release of product through a leak or a catastrophic pipeline <br />failure. <br />Pipeline construction and design specifications exceed applicable DOT staitdazds and would <br />provide greater resistance to catastrophic damage than the region's natural gas pipelines. The <br />44-mile line would be divided into 3 segments with manually operated gate valves placed in 2 <br />readily accessible locations, 1 in the upper Parachute valley (TSS R95W section 30); the other <br />