1999-12-15_GENERAL DOCUMENTS - M1999051

• Permit No: M1999051
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 12/15/1999
• Doc Name: Memos and Letters
• From: DRMS
• To: Various
• Media Type: D
• Archive: No

DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
Date: December 15, 1999
To: Allen Sorenson
From: Harry Posey
•
STATE OF COLORADO
Subject: Review: Reclamation Permit Application Adequacy Response; Ameralia Rock
School Lease Experimental Nahcolite Mine Project; M -99 -051
This memo covers the captioned adequacy response dated November 1999, and received by the
Division on November 24, 1999.
In permit review letters and meeting discussions with the Operator, we have laid out logical and
regulatory premises relaying the Division's interpretation that the captioned facility should be
classified a designated mining operation (DMO), as described in the Act. The Operator has
disagreed with that interpretation, and the Permit Application Adequacy Response describes
grounds for the Operator's interpretation. I have mined those grounds, sifted and sorted the
premises, and have segregated the constituent particles of evidence from the residues of opinion
and provide herein the results of my assay.
D I V I S I O N O F
MINERALS
GEOLOGY
RECLAMATION
MINING•SAFETY
Bill Owens
Governor
1. In Attachment 3, Environmental Protection Plan, page 2, the operator states that nahcolite,
sodium bicarbonate, is a designated chemical. This is the Operator's interpretation, and I
would not concur with it.
2. In the absence of analyses to the contrary, it is still maintained that nahcolite process
solutions likely will be deemed designated chemicals due to high concentrations not of
sodium bicarbonate but rather to the presence of several metals that are regulated in drinking
water. The operator has committed to provide proper analyses of the process solution upon
initiation of the solution mining and the Division would be obligated to consider that
information and reconsider whether the operation would qualify as a DMO or not.
3. Other issues of DMO status still remain. These include but are not limited to the potential for
high TDS process solutions to invade USDW's above the mining zone.
4. The introductory section indicates in several places that the facility will not have an
evaporation pond. Section E -5.4, first paragraph, indicates otherwise.
5. Attachment 4, Surface and Groundwater Monitoring Plan, p. 1, 2 par. The Operator is
advised that numeric protection levels (NPL's) for groundwater must be based on at least 8
analyses from each groundwater well or collection of well samples. These analyses must be
of high quality. The analyses should cover 5 quarters (minimum of 13 months) unless it can
Greg E. Walcher
Executive Director
Michael B. Long
Division Director
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