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<br />3 ~~ <br />p. 2-17 An illustration would be helpful showing how the project will <br />develop including plan and cross sectional views of the solution <br />cavities. A plan view of the cavities and well fields as they <br />relate to the location and flow patterns of groundwater resources <br />would also be useful. <br />p. 2-24 The mitigation proposed by BLM in section 2.4 does not adequately <br />address the potential for brine movement into the annular space. <br />EPA may require the applicant to modify its plan for mechanical <br />integrity to hold sufficient air pressure at the surface to maintain <br />the liquid/air interface in the annular space below the dissolution <br />surface. EPA now is of the opinion that the surface pressure <br />criteria for :shutting a well in needs to be established such that <br />the liquid/air interface does not extend above the base of the R-6 <br />zone. <br />p. 2-25 It is noted that considerable additional air quality controls may be <br />necessary for the 500,000 TPY alternative. Presumably such measures <br />would be needed by the applicant to assure compliance with the <br />Class II air quality increments under the Clean Air Act. Additional <br />air quality control measures may also become necessary for the <br />proposed action if EPA concluded from its current western states <br />acid deposition investigations that additional sulfur and nitrogen <br />oxide controls; are necessary to assure protection of the air quality <br />related value<,~ of PSD Class I areas. A brief mention of EPA's <br />current acid deposition investigation should be included in the <br />final EIS and deference to the State of Colorado and EPA in <br />implementing possible further controls on sulfur and nitrogen oxides <br />noted accordingly. (Note: The Colorado Department of Health, Air <br />Quality Control Division, received partial delegation from EPA for <br />the PSD program on September 9, 1986.) <br />p. 2-35 The EIS concludes that under the proposed action groundwater quality <br />could not be significantly impacted by direct contamination partly <br />because the area of the base of the groundwater system in contact <br />with the mine represents only one percent of the total area of the <br />aquifer system in the Piceance Basin. It is possible that active <br />dissolution of nacholite is occurring over a smaller portion of the <br />basin rather than, as suggested, the entire basin. If so, then the <br />increased dissolution as a result of this action could produce an <br />impact on groundwater quality different from the areal proportional <br />relationship. <br />p. 3-12 Based upon a report by Wright Water Engineers, the EIS indicates <br />that the hydraulic head difference in the well field area is from <br />1 to 10 feet. It needs to be established that the well completions <br />showing this difference in head were such that the upper and lower <br />zones were completely isolated when the head differences were <br />measured. <br />