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<br /> <br />DETAILED CON~MENTS BY THE <br />U.S. ENVIRONMENTAL PROTECTION AGENCY <br />DRAFT ENVIRONMENTAL IMPACT STATEMENT <br />WOLF RIDGE CORPORATION MINE PLAN <br />FOR A NAHCOHLITE SOLUTION MINE <br />General Comments on thE: EIS Process and EPA's UIC permit authority <br />The following comments 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 appreciates that BLM was able to include <br />in the EIS the analysis of the proposed action and the UIC program <br />(Appendix F). The issues identified by EPA in that brief analysis have yet to <br />be resolved by the agency and the applicant. We expect that the process of <br />information exchange and discussion of alternative means of well completion, <br />abondonment and monitoring will continue between our agencies and the <br />applicant and that the result of these deliberations can be summarized in the <br />EIS. <br />According to the applicant, EPA will receive the application for the <br />Underground Injection Control (UIC) Permit for the proposed action by the end <br />of October, 1986. EPA anticipates it will take approximately six months from <br />receipt of a complete application until EPA issues a draft Class III UIC <br />Permit. This means that the current EPA schedule for issuance of a draft UIC <br />permit would be April, 1987. According to discussions with BLM staff, your <br />office now plans to issue the final EIS by March, 1987. We request that our <br />respective staff meet and discuss the following concerns at your earliest <br />convenience. During this session we can address a joint Final EIS and draft <br />UIC permit process to help resolve any informational gaps and any possible <br />conflicting regulatory aspects of the proposed action. <br />EPA strongly sugge:>ts that several cross sections be developed to show <br />the details of the applicant's well construction and abandonment of production <br />and injection wells. In addition, similar cross sections are needed to depict <br />the alternative mitigat~~ion methods for completion and abandonment and <br />alternative means and locations of monitoring the proposed solution mining. <br />Development of these cross sections will aid greatly in the upcoming <br />discussions between our agencies and the applicant. <br />Specific Comments on the: draft EIS <br />p. 1-1 The purpose and need for the proposed action is limited to a <br />description of the production of the sodium bicarbonate product. A <br />brief discript:ion of the product use and its alternative use, as <br />suggested by the applicant, as a flue gas desulfurization agent <br />could be included in the final EIS. <br />p. 2-3 The applicant proposes to use a chemical gel-type mud between the <br />8 5/8 inch casing and the drill hole and later for sealing the drill <br />hole. What evidence can be provided from the pilot project or other <br />sources that this mud will stay in placel <br />