PERMFILE129206 - Laserfiche WebLink

Home Browse Search

iii riiiiiiiiiiii iii • STATE OF COLORADO ~~ ~~Ft: DIV1510N OF h11NERALS AND GEOLOGY Dr;.u II1111N ill N.IIULI N,PSUUlCCS i I ; Sherman SI .Room 215 prm~rr. G>loradir AU!U3 I'honr: 1 (1151 RbG-ISbi rnx 1x,aat~-~lloa April 18, 1999 DIVISION OF MINERALS GEOLOGY 0. E C L A M A T I O N MIN ING•5.4FETY Mr. Kurt Nielsen e~llowen, fib; American Soda LLC Gmernnr E w,l~n,•r c~e .O. BOX 2070 s Esecuuve Oireuor Glenwood Springs, CO 81602 r.hchael B. Lonp ~mL. Nr-n--L Divn~on Dbecro~ RE: Adequacy of the Application, Yankee Gulch Project, File No. NI-99-002 Dear Mr. Nielsen: The following issues remain to be addressed for the Yankee Gulch Project reclamation permit application to meet the minimum requirements of the Colorado Mined Land Reclamation Act for permit issuance. Please respond to each of the listed items prior to the established decision date of May 3, 1999 or provide a written request for extension of the decision date. 1. The Division of Minerals and Geology (DMG) has determined that the Yankee Gulch Project is a Designated Mining Operation (DMO) as defined in Rule 1.1(14) of the Hard Rock/Metal Mining Rules and Regulations of the Mined Land Reclamation Board (Rules). The basis for this determination is found in Rule 1.1(l4)(b), which states mining operations will be designated if "toxic or acid-forming materials will be exposed or disturbed as a result of mining operations." The proposed mine plan may expose or disturb toxic materials in the following two ways. a) Drill holes used to inject processing solution and extract dissolved nahcolite from the tazget mining zone will be drilled through the lower aquifer. Some zones within the lower aquifer are known to exhibit concentrations of certain toxic constituents that exceed human health andfor agricultural standards for ground water. The lower aquifer is further known to exhibit upward gradients in the northern part of the Piceance Basin. This leads to the potential for comingling of poorer quality lower aquifer water with the ground water of the upper aquifer if leakage were to occur along the cased and cemented production wells. b) The heated and pressurized solutions injected into the saline zone for recovery of nahcolite are intended to dissolve only sodium bicarbonate. During this process the heated solution may dissolve other minerals containing toxic elements such as fluoride and possibly barium. Other elements of concern that have been dissolved by ground water in contact with the rocks of the Parachute Creek member of the Green River formation include boron and lithium. It reasonable to assume that toxic constituents documented to be dissolved in ground water in the lower aquifer may also be dissolved by the solution mining injection fluid. As a DMO, an Environmental Protection Plan (EPP) will be required for the Yankee Gulch Project. The required elements of an EPP are listed in Rule 6.4.20. DMG has completed a review of the current