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The Colorado Department of Public Health and Environment areas of oversight include the issuance of <br />Construction (Emission) and Stormwater permits. Construction permits mandate the periodic <br />submission of Air Pollution Emission Notices (APENs) and monitor and control emissions by regulating <br />production levels and fuel usage. NSI's Stormwater permit is issued subsequent to the development of <br />a Stormwater Management Plan which seeks to understand and control stormwater runoff. <br />The Colorado State Office of the Engineer regulates the permitting and construction of water and <br />monitoring wells. <br />(4) Other Permits and Licenses <br />This EPP requirement relates to designated chemicals and acid mine drainage. NSI does not use any <br />designated chemicals or produce any acid mine drainage forming materials. NSI does not hold, nor is <br />NSI seeking to apply for any permits relating to any designated chemicals or acid mine drainage forming <br />materials. <br />(5) Designated Chemical(s) Evaluation <br />NSI does not engage in metallurgical extractive processes and therefore uses no designated chemicals, <br />nor does NSI produce any acid mine drainage. NSI is not a uranium mining (in -situ leach mining) <br />operation. <br />(6) Designated Chemical(s) and Material(s) Handling <br />NSI does not engage in metallurgical extractive processing and therefore uses no designated chemicals, <br />nor does NSI produce any acid mine drainage. NSI is not a uranium mining (in -situ leach mining) <br />operation. <br />(a) NSI's mining operation involves the in -situ, aqueous dissolution and recovery of nahcolite (sodium <br />bicarbonate, also known as baking soda). Heated water (process fluid) is conveyed by pipeline <br />underground where the hot water dissolves nahcolite. This fluid becomes saturated with sodium <br />bicarbonate and is pumped back to the plant where the sodium bicarbonate is crystallized, dried and <br />sold commercially. The process water is reheated and recirculated with additional well water <br />augmenting the process fluid as necessary. NSI's aqueous process fluid was evaluated for the presence <br />and quantities of 48 constituents and /or parameters. The constituent /parameter list was provided by <br />the DRMS. The DRMS determined that elevated levels of total dissolved solids (sodium bicarb) and trace <br />amounts of five constituents of NSI's process water exceeded Colorado drinking water and /or <br />agricultural use standards. <br />(b) Elevated levels of total dissolved solids (TDS) were identified as a toxic constituent by the DRMS; <br />however, NSI does not share this viewpoint. The elevated levels of TDS are due to the presence of <br />sodium bicarbonate, which, once crystalized and dried, becomes NSI's commercial product (baking <br />soda). The sodium bicarbonate product is bagged and contained within an onsite, enclosed warehouse <br />or within a storage dome prior to truck transport load -out. All product conveyors are covered and /or <br />contained within the process plant. <br />Trace amounts of boron were identified as a toxic constituent of NSI's process fluid. Boron is not listed <br />as a constituent of concern in Colorado or EPA drinking water standards; however, elevated levels of <br />boron are believed to affect plant growth. Trace amounts of chloride, fluoride, uranium and benzene <br />were also noted in NSI's aqueous process fluid. Concurrent with the occurrence of these 5 trace <br />constituents of NSI's process water is a degree of dilution as fresh well water is continually added to the <br />aqueous process fluid. Process fluid and trace constituents remain in the mined interval and replace the <br />volume of mined material (nahcolite). Closure of the process and waste ponds will result in a quantity of <br />material, primarily sodium bicarbonate and sodium chloride (salt) that, in addition to the pond liners, <br />Daub & Associates, Inc. NSI 2012 EPP <br />Page 6 <br />