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Section 2.0 Stormwater Management Controls <br />2.1 SWMP Administrator <br />As of April of 2011, Eric Simms of NSI has been deemed the current SWMP Administrator, and <br />is the point of contact for all SWMP - related matters. The SWMP Administrator is responsible <br />for conducting bi- annual inspections of structural control measures and monthly inspections of <br />the potential pollution areas on the NSI Lease. The SWMP Administrator will correct <br />insufficient or damaged existing structural control measures and will implement necessary <br />additional structural control measures and best management practices (BMPs). <br />NSI's process fluids include pregnant and barren liquors, and makeup water pumped from the A- <br />Groove Aquifer. The pregnant liquor is the sodium bicarbonate saturated fluid pumped from the <br />ground after injection and nahcolite dissolution. This fluid is very high in TDS, sodium, and <br />some chloride. The barren liquor is the process fluid after it exits the sodium bicarbonate <br />crystallizers. This fluid has a slightly elevated TDS content. The makeup water is pumped from <br />the A- Groove Aquifer, considered an underground source of drinking water (USDW) by the <br />Environmental Protection Agency (EPA), but is not a potable water source. <br />2.2 Identification of Pollutant Sources and Best Management Practices (BMPs) <br />Potential pollutant sources for NSI's industrial and solution mining operations can be <br />differentiated into two categories, based upon the location of the activities. These include <br />potential sources in and around the plant and potential sources associated with the well field. <br />The corresponding BMP for a potential pollutant source and a schedule for the implementation <br />of the BMP will be addressed with the identification of the pollutant source. <br />2.2.1 Potential Plant Pollutants <br />The NSI processing plant has a prismodal stormwater drainage control infrastructure consisting <br />of 8 stormwater control zones (Figure 2). Stormwater that falls in the vicinity of the plant and <br />from the roof of the plant is filtered into one of these 8 zones, which contain 6 stormwater <br />catchments, thereby containing all potential pollutants from the NSI plant that could be <br />incorporated into stormwater discharge. <br />2.2.1.1 Process Line <br />Within the processing plant, abundant piping exists which contains and transfers both pregnant <br />and barren liquors to and from the plant. Additionally, the process line within the plant consists <br />of crystallizers and dryers which extract the sodium bicarbonate product. Though the piping and <br />extraction machinery exist within the plant itself and are not influenced by stormwater, it is <br />important to note that the plant has a built -in drainage system in the event of a breach of the <br />piping that drains directly from the plant to the evaporation pond. <br />Daub & Associates, Inc. NSI 2011 SWMP <br />Page 4 <br />