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13 13 <br /> 1" <br />A <br /> ~ <br />~-/~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> ' <br />~ ..c REGION VIII <br /> ONE DENVER PUCE -989 tBTN STREET -SUrtE Ia00 <br /> DENVER. COLORADO OWDARAq <br /> Ref: 9PM-EA <br /> Willy Frank, Project Coordinator <br /> Bureau of land Mawgement $EP 2U 148E <br /> White River Resource Area <br /> P.0. Box 918 <br /> Meeker, Colorado B16a1 <br /> Ocar Flr. Frank: <br /> In accordance vith our responsibilities under the National <br /> Envtronmen[al Policy Ac[ (NEPA), Section 309 of the Clean Air Act, end <br />_ Par[ C of the Safe Dn nking Water Ac[, the Region V111 Uttue o[ the <br /> Environmen Cal Prot ectlon Agency (EPA) has revieved [he Draft En vSronmenta] <br /> Impact Statement for the Wolf Aidge Corporation Nine Plan far a Nahcolite <br /> Solution Fline. Our detailed comments are attached for your consideration <br /> on this unique mining operation. <br />N EPA's principal concerns ere Chet the analysis of impacts to [he <br />tM ground end surface voters needs to be improved, specific canstrucclon end <br />O operational fea cures o[ [he proposal require further refinement especfelly <br /> regarding infection .ell abandonment, and chat BIlP s final EIS anelysas <br /> regarding gro un duster protection should be coordinated with EPA's proposed <br /> issuance of a Class III underground injection veil perml[ for the proposed <br /> activity. We believe ve can eccompllsh these goals ]clot ly vith [he <br /> cooperac ive approach displayed by your office and look forverd to e <br /> mutually beneficial process eventually leading [o regulatory compliance for <br /> the proposed action or en eLt ernative to the proposed action tonal scent <br /> with Bl2f and CPA statutory mandates. <br /> According to [he procedures EPA uses to rate the adequacy of a draft <br /> E19, the Draft ETS far [he Wol[ Ridge Corporation Mine Plen for s Nahcol ice <br /> Solution Mine viii be listed in the Fedora] Repis[ur in Category EC-2 <br /> meaning ve have environmental concerns with the proposed ectlon regard mg <br /> ground and surface voter protection and that additional information is <br /> recommended regarding [he spa ciflc items noted In the detailed comments. <br /> Please contort Mr. West nn Wilson ec 703/297-17(17 or Mr. Marc Herman at <br /> 707/297-1447 regarding chc pr eperat wn of EPA's f,]ass III per ml[ and [he <br /> BIN Fl nel CI ti. <br /> Sincerely, <br /> <br /> <br /> ~Dal[hn al, Ch <br /> Envlronmea[al Assessment Branch <br /> Enclosure <br /> cc: William D1cRereon, EPA, Washington, D.C. <br /> Dob Btcw r[, Department of the Interior, Denver <br /> Ed kosar, Industrial Resources, Inc. <br />DETAILED LOhJSE NTS BY THE <br />U. S. ENV[NOiJigE11TAL PROTECTION AGEVLT <br />GRAFT ENVIROIlidENTAL IMPACT STATEMENT <br />WOLF RIDGE CORPORATION MINE PLAN <br />FORA 1lAHLOHLITE SOLUTI011 IaI KE <br />General Lonrnents on the EIS Process and EPA's UIL Dermi[ authority <br />The following comment; reflect EPA's concerns with the analysis of the <br />possible impacts of the proposed action on the Piceance Basins aquifers and <br />their associated surface waters. EPA aDDrec Totes that BLM was a61e to include <br />in the EIS the analysis of the proposed ac tlon and the UIC program <br />(Appendix Fl. The Issues identified by EPA in that hrlef analysis have yet to <br />be resolved by the agency and the aDPllcant. We expect that the process of <br />information exchange and tli scussion of alternative means of well cmpletlon. <br />abandonment and moni [ors ng will contt nue between our a9encles and cne <br />applicant and that the result of these deliberations can be summarizetl in [he <br />EIS. <br />According to [he applicant, EPA will receive the application for the <br />Underground Inj ettion Control (UIL) Permit for the pro DOSed action by the end <br />of IXtober, 1996. EPA an Cl clpates it will take apDroAlma tely six months from <br />receipt of a complete application until EPA issues a draft Class IIL UlC <br />Permit. This means that the current EPA schedule far issuance of a draft UIC <br />permit would be April, 1997. Accortlin9 to discussions with BLM staff, your <br />office now plans [o Issue the final EIS by Flarch, 1997. 4e request that our <br />respective staff meet and discuss the following concerns at your earliest <br />convenience. During this session we can atltlress a joint Final EIS and draft <br />UIL permit process to help resolve any informational gaps and any possible <br />conflicting regulatory aspects of the proposed action. <br />EPA strongly suggests that several cross sections be developed to show <br />the details of the applicant's well construction and abandonment of Droduc Cio~ <br />antl injectf on wells. In addition, similar cross sections are needed to depict <br />the alternative ml ti gati on me[liods for comDletlon and abandonment and <br />al ternattve means and loca[i ons of monitoring the proposed solution mining. <br />Development of these cross sections will aid greatly in the upcami ng <br />tllscussions between our agencies and the apDl scant. <br />Specific Lomnents on the draft EIS <br />p. 1-1 The purpose and need for the proposed action 15 liml tad to a <br />descrip[ton of [he production of the sodium bicarbonate Droduc t. A 20, <br />brief discription of the product use and its al terns [i ve use, as 49 <br />suggested by the aDDllcant, as a flue gas desulfuri zatfan agent <br />coultl be included in the final EIS. <br />p. 2-7 The applicant proposes to use a chemical gel-type mud between the <br />8 B/B inch casing and the tlrill hole antl later for sealing the drill 83, <br />hole. Nhat evidence can 6e yrovltled from the pilot Drojact or other Bfi <br />sources that this mud will stay in pl ace7 <br />