GENERAL32022

• Permit No: M1983194
• IBM Index Class Name: General Documents
• Doc Name: COVER SHEET-2 PUBLIC COMMENTS ON DRAFT EIS & RESPONSES TO COMMENTS
• Media Type: D
• Archive: No

2. RESPONSES TO PUBLIC COMMENTS
that the company keep all brines or increased levels of saline
minerals contained within [he boundaries of the lease and
that remedial action be taken i( monitoring wells detect
increases in dissolved solids migrating from the production
well field. For further details and clarification of monitoring
requirements, see monitoring summary in the TEXT
CHANGES section (Water Resources, Environmental
Consequences). In addition, please refer to Appendix C.
Response No. 18. Dedicated hydrologic monitoring
wells are those wells located outside of [he production weB
field and outside of the zone of influences of subsidence
for the purpose of gathering baseline values both up and
down gradient of the field. These may either be newly
completed we!!s, existing in-place wells, or a combination
of both. [o addition, if monitoring in the weB field indicates
increased dissolved solid concentrations, the dedicated
monitoring wells would be used to pick up or tract any
potential plume migrating from the fields. Therefore, BLM
feels that it is necessary to maintain a reliable monitoring
system surrounding the well field.
Response No. 29. The "General Development Compo-
vents" section in [he draft describes the project only as
proposed by WRC in their mine plan and only to the level
of detail contained in the mine plan.
BLM is in complete agreement with EPA's proposal and
will support same when the detailed monitoring plan is
submitted.
Response No. 30. In addition to monitoring the lowest
part of the lower aquifer, BLM believes that monitoring
of the B-Groove is essential in detecting any leaks that may
occur in well strings above the base of the lower aquifer.
Monitoring of the B-Groove would also provide a backup
system to the lower sampling interval and would aid in
detecting any potential increase in dissolved solid movement
and gradient Flow changes from the dissolution surface
upward into the lower aquifer.
Oil Shale
Response No. 31. The best interest of the United States
Government is the conscientious preservation, development,
and use of its resources, as appropriate. The multintineral
resource should be developed in such a manner that the
highest recovery of all resources will be attained. One
resource should not be foregone for the other. The Boles
Bed would not be recoverable by conventional mining
methods and no impacts to the oil shale resources are
predicted; therefore, the recovery of this nahcolite by solution
mining is a plus in the overall recovery of minerals in the
Piceance Basin.
Response No. 31. Modified In Situ (MIS) methods are
not conducive to heavily fractured ground as exists in the
sodium lease tract area. M[S retorts are subjected to high
negative pressure. Leakage of air from one retort to another,
or from mine air to the retort, can be very detrimental
to the process as well as create safety hazards. MIS has
not been sufficiently demonstrated in the basin to announce
it as a viable mining method in the basin.
Response No. 33. As stated in the referenced paragraph,
the poor rock quality has rendered the recovery of minerals
from the R-6 Zone within the sodium lease area unfeasible
by existing recovery methods, and the Mahogany Zone will
not be affected by the proposed nahcolite recovery of the
Boles Bed. Although the quantity figures for oil shale and
sodium resources are not in a table format, they are in
the narrative section you refer to.
Response No. 34, No change. The total thickness of
the identified minable zone is as much as 60 feet, of which
at least a 40-foot thickness would be extractable. The mining
of this zone would, by definitiam, include the dewatering
zone needed to mine this interval.
OB Shale/NahcoGte
Response No. 35. Because of the proximity of the Boles
Bed to the dissolution surface, that bed could not be recovered
by methods other than solution mining. A lowering of the
dissolution surface would take place over a very long period
of time and would not render the underlying oil shale beds
less minable. The distance from [he dissolution surface down
to the minable oil shale is sufficient so that necessary crown
pillars can be left without loss of resource.
Oil Shale/Wafer Resources
Response No. 36. The premise of the environmental
impact statement is the conservation of resources, both
mineral and environmental. The solution mining of the
nahcolite 8oies Bed presents virtually no risk to the detriment
of the future minability of the oil shale. The minable oil
shale would remain virtually intact, as it is today, and any
additional commingling of the aquifers, than exists today,
would not be inherent. The monitoring and mitigation
developed in this document will accomplish this goal.
Reclamation
Response No. 37. Considering [he potential limitations
on reclamation success (page 3-17 of the draft) and prescribed
reclamation goals (page 4-15 of the draft), monitoring
revegetation attempts over one growing season is not
considered adequate. Since reclamation bond release criteria
are predicated on relative production and crown cover of
perennial species, including seeded shrubs, it is highly
unlikely that the operator would be able to successfully
satisfy the performance criteria within 1 year. A minimum
2-46