Laserfiche WebLink
EXHIBIT L - Reclamation Costs (Rule 6.4.12): The current estimated reclamation <br />cost only accounts for a total disturbance of 62.52 acres. The proposed total <br />affected acreage is 260 acres; please provide all information necessary to <br />calculate the costs of reclamation. The information must be submitted and broken <br />down into the various major phases of reclamation. You must provide sufficient <br />information to calculate the cost of reclamation that would be incurred by the state. <br />It is unclear what the differences are concerning the calculation of reclamation <br />costs, between NSI's previous Amendment 02 (1991) when the affected acreage <br />was increased to 73 acres and the current proposed Amendment 03 increasing the <br />affected acreage to 260 acres. Under Amendment 02 the reclamation costs have <br />been calculated when NSI proposed a new well. Additional bonding would then be <br />put in place, keeping the bonding current with the disturbed acreage. As was <br />pointed out, NSI's current estimated reclamation costs (and bonding) accounts for <br />a total disturbance of 62.52 acres, yet Amendment 02 still allows for 73 affected <br />acres. The proximal nature of resource variation within the mined intervals and <br />technological developments tend to preclude long range well field plans in favor of <br />a staged development approach. A good example of this is the fact that the 112 <br />amendment 02 (1991) projected that the permit acreage increase to 73 acres <br />would last for 5-6 years. In fact, the Amendment 02 permitted acreage has been <br />adequate to provide for 19 years of sodium bicarbonate mining. Calculating <br />reclamation costs as development proceeds would seem to be the most accurate <br />and efficient method of establishing the reclamation costs. NSI currently provides <br />the DRMS with sufficient information to calculate the cost of reclamation prior to <br />new well construction. <br />EXHIBIT U - Designated Mining Operation Environmental Protection Plan (Rule <br />6.4.21): You must provide information sufficient to demonstrate that an <br />Environmental Protection Plan is not required to address proposed or permitted <br />activities that do not involve, affect, or influence the storage, handling or disposal <br />of the designated chemicals and do not disturb toxic or acid-forming materials, and <br />that do not cause, or have the potential to cause, generation of acid mine drainage. <br />In order to demonstrate that Exhibit U is not applicable to permit M-1983-194 <br />please sample the recovered "pregnant" nacholite solution that is recovered during <br />the mining process. The list of parameters to be sampled for is enclosed with this <br />document. A sample of the pregnant liquor has been submitted for testing of the <br />requested analytes. <br />Your application will not be considered submitted until the information listed above is <br />received and found sufficient to begin our review. A decision date will be established 90 <br />days from the date of receipt of all of the requested information. Additionally, if you have <br />already published notice you will need to republish notice, after the Division considers the <br />