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: June 15, 1999
To: Allen Sorenson
From: Harry H. Posey
• •
STATE OF COLORAD
ts o01
Subject: Review: Ameralia, Inc., Ro c k Sc
Lease Experimental Nahcolite Mine
Project; M -99 -051
Following are general and specific comments on the captioned operation.
D I V I S I O N O F
MINERALS
GEOLOGY
RECLAMATION
MINING•SAFETY
Bill Owens
Governor
GENERAL COMMENTS:
1. Because nahcolite and associated oil shale contain numerous trace metals and bittern salts
that formed during evaporation of the original saline lakes, dissolution of nahcolite is likely
to produce a brine with high concentrations of numerous elements and compounds in
excess of surface water, agriculture and drinking water standards. Such processing waters
would be considered toxic under the definition of "Acid or Toxic Producing Materials" in
the Mined Land Reclamation Act (the Act) at 34 -32- 103(1).
2. Based on the potential for generation of what would be considered "toxic" materials under
the Act at 34 -32- 103(1), and based on the potential for contamination of shallow aquifers
and surface water from production and processing facilities, and based on the volume of
processing fluid that is likely to be present in each well production unit, it is recommended
that this facility be classed as a "Designated Mining Operation" as defined in the Act at 34-
32- 103(3.5) and as described at 34 -32- 112.5.
3. On the assumption that the facility is deemed to be a DMO, and based on our recent
conversations with the Operator, Ameralia should collect and submit at least 5 quarters of
baseline water quality monitoring for surface and groundwater downgradient of the
proposed test facilities.
4. On the assumption that the facility is deemed to be a DMO, the Operator should prepare
and submit plans for ground and surface water monitoring. Groundwater monitoring
should include verification of the direction of groundwater gradient.
5. All process solution lines should be provided with dual containment such as pipes in lined
ditches, dual - walled pipes, or rupture containment berms. Double walled piping should be
avoided in traffic areas, or areas where accidental breakage is likely to be due to contact
with heavy equipment such that both pipe walls are breached. The permit should describe
the holding and carrying capacity of each storage or conveyance system, and account for
the containment of accidental spillage according to the volume of the likely spill plus
whatever storm capacity may be necessary to provide sufficient freeboard.
Greg E. Watcher
Executive Director
Michael B. Long
Division Director
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