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• • <br />4. Pg. D -16. The Operator proposes to inject water of up to 350° Fahrenheit. It is presumed <br />that this temperature limit is based on some at -hand information about mineral solubility, <br />production characteristics or other feature. The Division would consider it necessary to <br />protect the oil shale resource, yet there appears to be no data in the permit proposal <br />showing the limits above which oil shale may deteriorate. The Operator should furnish data <br />showing that water temperatures of 350° Fahrenheit will not release of otherwise degrade <br />the oil shale. <br />5. Figure C -3.8. The centrifugation step of the crystallization and dewatering phase appears <br />not to account for removal or recycling of the nahcolite -free decant. Please explain. <br />6. Page D -37, and elsewhere. Wastewater and evaporation ponds. The plan should include <br />means for disposing of unevaporated wastewater from the waste water and evaporation <br />ponds. <br />7. Page D -46, section D -5.2. The permit should have some provision for storing biocides in <br />only limited quantities. Secondary containment will be required, and instructions for use <br />and disposal should be available to the Division, in the even of operational failure such as <br />abandonment or bankruptcy. The permit should specify the maximum quantities of each <br />chemical that will be stored on site. <br />8. Page D -52, D -53, section D- 6.3.2, and Page T -1, section T -2. In light of this review, the <br />Operator should revise the text related to DMO status. The Division believes that water <br />from the dissolution zone, and possibly the process solutions would be classified as toxic <br />for several constituents and have the potential to harm water supplies in the shallow <br />aquifers, surface streams, and holding ponds if not properly controlled. <br />9. Page E -8. Section E -5.4, fourth paragraph. The Operator indicated in earlier parts of the <br />narrative (page D -53, third paragraph) that evaporation pond solids remaining after <br />operations or developed during operations would be tested via TCLP and disposed of <br />properly, but this section indicates the solids may be buried with the liners. Please clarify <br />the discrepancy between these two statements. <br />10. Page G -16. G -5.3. Aberrant or non - compliant data should be reported immediately. <br />cc: Carl Mount <br />Jim Pendleton <br />3 <br />