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CHAPTERFOUR Responses to Pu611c and AgiencY Comments <br />Letter and <br />Comment No. Response <br />F-2.11 It is not necessary to monitor for in situ temperature because the injection <br />and extraction water temperatures from the solution mining well would be <br />monitored by American Soda, which allows the evaluation of cavity <br />temperature. (Refer to Section 5.0 of the Groundwater ands Surface Water <br />Monitoring Plan in Appendix G.) <br />F-2.12 As described in Sections 2.2.1.2 and 2.2.3.2 of the Draft E.IS, the <br />evaporation ponds at both the Piceance and Pazachute site, and the <br />mechanical vapor recompressor (MVR) pond at the Parachute Site would <br />be designed with adequate freeboazd to: <br />• accommodate the normal maximum operating level plus the 100-yeaz <br />(24-hour) precipitation event <br />• accommodate wave action on the pond level without overtopping <br />• provide at least 1 foot of freeboard above the pond level that <br />accommodates wave action <br />The process ponds do not intercept surface runoff, and are not expected to <br />occasionally discharge. Therefore, no surface water dischazge permit is <br />needed. If any overflow did occur, the proponent would notify the <br />Colorado Department of Public Health and Environment (CDPHE), in <br />addition to the BLM. Section 2.2.5.4 of the Draft EIS, Evaporation Pond <br />Monitoring, (page 2-22) has been revised to reflect the notification to <br />CDPHE. <br />American Soda intends to obtain an industrial stormwater permit from <br />CDPHE for the Piceance and Parachute sites. The project would be <br />permitted under Colorado's Sand and Gravel General Permit for potash, <br />soda, and borate mines (Permit No. COG-500000). <br />F-2.13 Bonds aze required to protect the environment, to ensure downhole <br />plugging and surface reclamation following drilling and development; and <br />to cover unpaid federal royalty obligations. There are several agencies that <br />would require bonding for the proposed project. EPA requires a bond for <br />inhole closure of all production wells through the UIC permit program. <br />The BLM requires bonds for closure of all monitoring well and core holes; <br />all surface reclamation on federal land; and federal royalty obligations. . <br />The Colorado Division of Minerals and Geology (CDMG;i requires a bond <br />for the Piceance Site based on surface disturbance. The amount of the <br />bond depends on CDMG's concurrence with the adequacy of the <br />requirements imposed by BLM's and EPA's bonds. Rio Blanco and <br />Gafield counties also anticipate requiring bonds for potential road damage <br />during the construction phase. <br />4-6 <br />