1999-11-24_PERMIT FILE - M1999051

Home Browse Search

Waste streams are limited for the Project. The mining method is containment and re- circulation of solution between the process plant and the mining interval located in a non- water bearing zone below the lower aquifers. During the process of attempting to avoid the DMO classification,AmerAlia revised the recovery process, including replacing the 7-acre waste water evaporation pond with an evaporator. After evaporating and recycling the water from the waste stream,the remaining solids will be delivered to an approved landfill. Rio Blanco County is currently determining what fees, if any,to charge to accept this material for landfilling. The majority of this solution consists of natural groundwater and common water treatment constituents concentrated from reverse osmosis and water softening processes used to purify water(used in many homes and industrial facilities) and cooling tower blowdown(similar to material found in home evaporative coolers). Any chemicals added to reduce scaling or to make the processes more efficient will not be hazardous. Considering the current laws regulating hazardous chemical disposal, chemical manufacturers are very careful that chemicals used in these types of industrial processes are not of a hazardous nature. An analysis of the anticipated make-up of the solids is included as Attachment 5. The pregnant liquor filter backwash represents debris from the mining formation, and the solids will be landfilled with the evaporator solids. Hazardous chemicals or elements are not anticipated in this product. 3.a)The 7-acre evaporation pond is no longer part of the Project. As described above, the 7-acre pond will be replaced with an evaporator. The 3-acre process pond has been replaced with a combination of a holding tank and the curbed concrete plant floor. The holding tank is connected by sumps to the curbed plant floor. The holding tank and the curbed plant floor are each sized so that either would contain the volume of solution in the largest vessel in the plant. Should a vessel rupture, solution would be pumped from the curbed plant floor to the holding tank. The double impervious synthetic lined well field drainage pond will be constructed in the second quarter of 2000. This pond may be replaced by a tank. A Technical Revision to the Application containing the plans, specifications,volumes,operating parameters,and a quality assurance construction protocol for this drainage pond, or tank, will be submitted to the DMG at least 60 days before planned construction. Construction of the drainage pond, or tank, according to the plans and specifications will be certified by a qualified individual, and this certification submitted to the DMG. This pond, or tank, will be used for temporary storage of solution from the well field pipelines should a pipeline need to be drained for any reason. Solutions would be in the pond, or tank, for a short period of time before being pumped back into the system using fresh water for dilution as necessary. The pond will not be used for evaporation and waste storage. 3.b)AmerAlia will include with each annual report certification by a qualified individual following protocol of the American Petroleum Institute, or other similar applicable standards,that each well installed during that year was appropriately cased and cemented to prevent transmission of process solutions outside of the casing. The mechanical integrity testing methods and well logging to be used will be those required by the US Environmental Protection Agency. Those requirements are found in 40 CFR 146.8. The 3 DMG 11-23-99 Response AmeriAlia,Inc.