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pumping the hot water approximately 2,000 to 3,000 feet underground where the hot water dissolves <br />the nahcolite. The hot water which is now saturated with dissolved nahcolite is pumped to the surface <br />and back to the plant where the sodium bicarbonate is precipitated out of solution (recrystallized) <br />through a cooling process. NSI's in situ, solution mining operation has a minimal footprint and does not <br />strip away overburden materials thereby retaining maximum acreage for wildlife. <br />Section 3.10 of NSI's Mine Plan (2010) describes wildlife species to be expected and those species found <br />on and in the area of NSI operations. Discussions of the potential for the occurrence of threatened or <br />endangered species, seasonal usage, the general effects on wildlife as well as mitigation measures to <br />prevent the loss of habitat are presented. Aqueous process fluids are contained within pipelines and /or <br />fenced pond areas. Cabling strung across the ponds, with iridescent streamers, coyote decoys and a <br />propane cannon are used to keep birds out of the pond area. Sodium bicarbonate product is packaged <br />and stored inside or contained within enclosed silos or the storage dome. <br />It is noted that most of the sodium bicarbonate will precipitate out of solution on or very near the <br />ground surface in the event of a spill of NSI's aqueous process fluid. This rapid precipitation and <br />crystallization of sodium bicarbonate will occur as the process water cools and becomes incapable of <br />retaining higher quantities of sodium bicarbonate in solution. The crystalline sodium bicarbonate would <br />then be raked or scraped up and properly disposed. It is further noted that a significant amount of NSI's <br />sodium bicarbonate (baking soda) product is in demand and sold as an animal feed additive. Any <br />detrimental effects to wildlife resulting from any potential spill of NSI's process water are anticipated to <br />be minimal to non - existent. <br />A Colorado Parks and Wildlife comment letter is attached as Appendix E. <br />(19) Disposal of Tailings and Sludges in Mine Workings <br />NSI does not use any designated chemicals or cause acid mine drainage, NSI is not a uranium mining <br />operation. NSI solution mines in situ, nahcolite (naturally occurring sodium bicarbonate which is <br />commonly called baking soda). NSI's in -situ solution mining operation does not generate tailings or <br />sludges. NSI's aqueous process fluids will remain in the mined interval as solution mining progresses <br />and at the conclusion of mining operations. These aqueous fluids will reach a saturation equilibrium <br />with respect to in situ sodium bicarbonate and similar to existing aquifer fluids which are near and <br />overlie the mining interval. Aqueous fluids from blowdown events for the boilers and cooling towers are <br />contained in the waste pond and will be disposed of in an approved manned and in accordance with all <br />applicable rules and regulations upon plant closure. <br />Daub & Associates, Inc. NSI 2012 EPP <br />Page 14 <br />