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'. <br />Letter to Kurt Nielsen 2 Agri) 18. 1999 <br />permit application in relation to the requirements of Rule 6.4.20, and has determined that most of the <br />elements required for an EPP have already been included in the application. Submittal of a ground <br />water monitoring plan and a subsidence monitoring plan, as discussed in subsequent sections of this <br />letter, will till the most significant gaps in the current application relative to the EPP requirements. In <br />addition, the DMG will require that American Soda provide a summary reference document detailing <br />each of the 19 required elements of an EPP as listed in Rule b.4.20 and specifying the location in the <br />original permit application or subsequent application submittals where each of the 19 required elements <br />is addressed. For those elements of an EPP that are not applicable to the Yankee Gulch Project, a <br />statement to that effect in the summary reference document is appropriate. Submittal of this summary <br />reference document will be considered additional information provided for the purpose of "detailing, <br />clarifying or explaining" the application (Rule 1.8(4)). <br />DMG will require that American Soda provide chemical analysis of the process solution to be <br />recovered from the mining cavities. It is DMG's understanding that such a sample could be collected <br />from the test mining facility. Analysis should be completed for parameters in Table 3 of the draft <br />Ground Water and Surface Water Monitoring Plan dated April 1999 and for dissolved organic carbon, <br />BTX, oil and grease, and methane. These analyses will provide information relative to the DMO <br />determination under item l.b. listed above. If trace elements or contaminants are present in the process <br />water stream, DMG will require a description of the management of these elements or contaminants. In <br />particular, will any trace elements or contaminants be refined out of the process solution at the Piceance <br />Site? And if so, how will the waste stream be disposed of or otherwise managed? <br />2. Structural elements at DMOs designed [o contain or control process solutions are defined in the <br />Rules as Environmental Protection Facilities (EPF). EPFs at the Yankee Gulch Project would include <br />the cased solution mining wells, the surface piping network, the double lined evaporation pond, and the <br />processing plant itself. Rule 7.3 lists design and construction requirements for EPFs. The application <br />of these requirements to the Yankee Gulch Project are discussed in the following subsections. <br />a) Plans and specifications for the evaporation pond must be incorporated into the permit prior to <br />initiation of pond construction. The permit may be issued prior to the submittal and approval of <br />these plans and specifications. However, submittal of the pond information after permit <br />issuance would be considered a technical revision to the permit (Rules 1.5.2 and l.9). The pond <br />specifications should include a statement that American Soda will advise the DMG of the basic <br />schedule for pond construction and liner installation in order to facilitate DMG inspections of <br />the work. A statement must also be included that any changes to the plans and specifications <br />are subject to review and approval by the D[vIG. Upon completion of pond construction, Rule <br />7.3.2 requires certification of the installation by a professional engineer or other qualified <br />individual that the facility was constructed in accordance with the approved plan. The <br />certification should include a construction report and drawings illustrating the as-built <br />configuration of the pond and the geomembrane panels. <br />b) The DMG will require [hat American Soda include with each annual report a certification by a <br />professional engineer or other qualified individual that each solution mining well installed <br />