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Letter to Roger Day 3 June 18, 1999 <br />documents. The certification of the wells should include an installation report with reference to <br />American Petroleum Institute (API) standards or other standards as applicable and <br />documentation on the testing and logging that was conducted. Similarly, the DMG will require <br />submittal in the annual report of a certification and abandonment report for each well that is <br />abandoned and plugged during the project year. <br />c) DMG is concerned with the potential for loss of containment do to leaks in the surface piping <br />system and the potential for adverse impacts to soil, vegetation, and habitat that may result. A <br />description of piping system monitoring is provided in section D -3.5 of the application that <br />includes visual inspections and pressure sensing transducers connected to an alarm system. <br />What will be the frequency for visual inspection? How will these inspections be documented? <br />What magnitude of pressure fluctuation will trigger the alarm system? In each annual <br />reclamation report the DMG will require certification of the proper installation of all well field <br />piping for the report year. The certification should be signed by a professional engineer or other <br />qualified person (e.g., a journeyman stream fitter) and should reference API or other appropriate <br />standards for pipe and valve installation. The report should also include certification that any <br />piping salvaged for reuse was tested and found to be sound and should describe the testing and <br />acceptability criteria applied to salvaged pipe. <br />d) Please affirm that topsoil will be completely stripped from the facilities area and stockpiled in a <br />location where it will be isolated from the potential adverse effects of any spill within the <br />processing plant or in the well field or process piping corridors. Provide a description of the <br />structures that will be in place (e.g., curbing, drains, and sumps within buildings and berms, <br />ditches, culverts outside buildings) to route spills and runoff from the facilities areas to the <br />ponds. <br />4. As a component of the pond plans discussed in item 3.a. above, AmerAlia must provide analysis of <br />the water balance for each pond and provide sizing calculations and operating and minimum residual <br />freeboard criteria. For example, if a pond is constructed to receive various waste water inputs from the <br />processing plant, the volumes for the inputs should be estimated and a demonstration provided that <br />evaporation will keep pace and prevent net water accumulation in the pond. The minimum operating <br />freeboard should be specified based on these estimates where if the minimum operating freeboard is <br />reached, discharges to the pond would have to be curtailed until additional pond capacity can be <br />installed. The minimum operating freeboard should be established to provide capacity for the one <br />percent annual chance flood inflow plus the volume of the largest storage tank or vessel located <br />upgradient of the pond plus adequate residual freeboard to prevent overtopping by wave action on the <br />pond surface. If any berms or ditches are proposed to route runoff around the ponds or around the <br />facilities area, these structures should be designed for the 100 -year storm and the runoff and structure <br />sizing calculations provided. For the fresh water pond only, a spillway should be provided that will <br />pass the 50 -year flood inflow. <br />5. The process water ponds described in the permit application incorporate a geonet leak collection <br />system to be located between the two layer geomembrane liners. Please provide a plan for monitoring <br />the amount of fluid collected by the leak collection layer, specify an allowable leakage rate, and list the <br />