GENERAL49859

• Permit No: M1983194
• IBM Index Class Name: General Documents
• Doc Date: 3/15/1995
• Doc Name: ANNUAL REPORT & GROUND WATER MONITORING PLAN NAHCOLITE PROJECT FN M-83-194
• From: DMG
• To: WHITE RIVER NAHCOLITE MINERALS L L CO
• Media Type: D
• Archive: No

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999
STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depanmenl of Natural Resources
1 J 13 Sherman SI.. Room 215

Denver, Colorado 80203 II~~~
Phone: [phone]h-3567
FAX: [phone]
DEPARTMENT OF
NATURAL
March 15, 1995 RESOUIZCES
Roy Romer
Mr. Ed Baker cnverrror

White River Nahcolite Minerals, L. L. Co. lames 5. Lochhead
E.ecoave D,rmnr
P.O. Drawer 72, 3200 Co. Rd. 31 Michael B. Long
Rlfle, CO 1650 Division Dirttlor g~
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RE: Annual Report and Ground Water Monitoring Plan, NahcoGte Project, ,}
File No. M-83-194 V° ,/
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Dear Mr. Baker: N
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The Division has reviewed your annual report for 1994, received on Febn3ary 2, 1995.
Overall the report is well organized and meets all of our requirements. Of particular i nterest
was your deport on reclamation activities and the detailed hydrologic reports. It appears that
despite the dry growing season, your revegetation efforts continue to be successful.
We do have two items of concern. First, on page 31 you discuss a possible lease
modification with the U.S. ESLM concerning acreage adjustments for the BLM lease. Will
this affect the Division's permit boundaries?
Secondly, the data on pages 92 and 93 -Section 6.1.6 and Table 6-16 indicate that leakage
from the waste and process ponds is increasing. Do you plan to attempt to eliminate the
leakage? If not, could you demonstrate that it is not a problem? Please notify the Division
in the next 30 days if the trend of increased leakage continues.
Because of the possibility of an adverse impact on groundwater quality due to leakage from
the waste or process water ponds, or other leakage from the production wells or the
production complex, the Division is requesting that White River Nahcolite Minerals L. L.
Co. submit to the Division a groundwater monitoring program which complies with
Rule 3.1.7(7). The plan should include points of compliance as described under
Rule 3.1.7(6) and should establish permit conditions, including numeric protection levels,
protective unclassified groundwater uses as described under Rule 3.1.7(1), (2), (3), and (4).
As stated in Rule 3.1.7(5), the submittal will be considered a Technical Revision. The
Division realizes that the majority of this requested information has been submitted either in
the original application, in P.mendment No. 2, or in the "Comprehensive Monitoring Plan for
Commercial -Scale Solution Mining of Nahcolite", but believes that a single comprehensive
document as described in Rule 3.1.7(7) is needed, which includes permit conditions and