Facility construction no longer goes directly from design to building permit. There is often an environmental permit that needs to be obtained or an environmental assessment that needs to be performed along the way. EarthFax has assisted several clients with these permitting and assessment needs. This experience has included:
PLANNING AND PERMITTING SERVICES FOR A SHALE MINE. EarthFax provided mine planning and permitting services for a shale mine located in central Utah. Tasks included drafting a plan for development of the mine, and revising the Notice of Intent to allow expansion of mine boundaries so that shale reserves can be extracted and/or overburden stored. Mine development plans included methods to dewater the mine ahead of shale extraction, plans to maximize overall extraction of shale from the mine, projections of how the mine will look at the end of each 50,000-ton phase of shale extraction, and identification of areas where overburden can be removed and stockpiled in anticipation of final reclamation. Permitting services included preparation of a revised Notice of Intent to allow expansion of existing mine boundaries that will allow for additional shale extraction and storage of overburden.
COAL MINE PERMITTING. Permit documents have been prepared by EarthFax personnel for several coal mines in Colorado, Utah, Washington, and Wyoming. Baseline inventories of hydrology, soils, and geology have been conducted, and information regarding biological resources, air quality, land use, legal issues, financial issues, and compliance issues has been gathered. Major engineering aspects of the mining and reclamation operations have been designed, including roads, pads, runoff- and sediment-control facilities, grading plans, etc. Design information developed by others has been gathered and reviewed and subsidence-control plans have been developed. Impacts of mining activities on these resources have also been predicted and mitigation measures have been designed. In addition, reclamation plans have been developed, including programs for identifying, handling, storing, and redistributing topsoil and for revegetating the reclaimed areas. Detailed reclamation bond estimates have also been developed. EarthFax professionals have also managed multi-disciplinary teams when required to gather additional information. All information has been prepared in formats acceptable to the regulatory agencies and submitted, following client review, to the agencies for approval. EarthFax has then continued to provide follow-up services to the mining companies to resolve permitting issues with the agencies.
PREPARATION OF LEASE-BY-APPLICATION DOCUMENTATION. EarthFax has prepared documentation necessary for coal mining companies to expand their Federal lease holdings through the Lease-By-Application process. Information regarding existing environmental resources (soils, land use, air quality, hydrology, geology, etc.) has been gathered from published data and supplemented with field data as required. The appropriate information has then been prepared for submittal to the appropriate agencies.
PREPARATION OF DATA ADEQUACY DOCUMENTATION. In support of future coal leases on U.S. Forest Service property, EarthFax has prepared Data Adequacy reports, presenting all environmental data available for the property of concern. These reports are necessary for the Forest Service to determine if sufficient environmental information is available for the agency to make a decision regarding potential leasing of land under their control. Where needed, additional information has been gathered to meet the needs of the agency.
EVALUATION OF ALTERNATIVES TO REDUCE, CONTROL, AND RECYCLE WASTES AT A MINE IN RUSSIA. EarthFax received an EcoLinks Challenge Grant through the United States Agency for International Development to study alternatives for reducing, controlling, and recycling waste rock at a coal mine located in the Sakhalin region of the Russian Federation. The coal mine, operating since1913, has been generating but not controlling various waste streams related to coal mine operations. Specific tasks associated with this project include evaluating alternatives for minimizing environmental pollution resulting from existing mine waste dumps and increasing opportunities to recycle this waste, selecting alternatives and developing a model program to control and beneficially reuse solid wastes generated by the mine, and preparing a project report which outlines the feasibility of solid-waste control and recycling at the facility. In addition to these objectives, EarthFax evaluated alternative underground mining methods to minimize the production of waste rock and evaluated the coal burning efficiency of the town boiler to minimize ash production.
MINERAL MINE PERMITTING. Documentation has been prepared for gold, silver, and uranium mines in the western United States to obtain the necessary permits to operate. Baseline studies were performed as necessary to support permitting activities, including identification of soil, surface water, groundwater, and general geologic conditions. Input was provided in the siting and design of tailings/waste containment facilities. An Environmental Assessment of one of the sites was prepared and used as the basis for development of the reclamation plan. Reclamation plans were incorporated into the mine plans and the documents and necessary forms were submitted to local, state, and federal agencies for approval. Liaison was provided between the clients and the regulatory agencies.
PREPARATION OF SPCC PLANS AND FACILITY SPECIFIC RESPONSE PLANS FOR A PETROLEUM REFINERY. Both a Spill Prevention, Control, and Countermeasures ("SPCC") plan and a Facility Specific Response Plan under the Oil Pollution Act of 1990 ("OPA-90") were prepared for a petroleum refinery in Utah in accordance with the requirements of the U.S. Environmental Protection Agency. Work involved calculation of all tank quantities and release volumes for use in developing worst-case discharge response scenarios. Both secondary containment plans and contingency plans to protect federal navigable waters and wetlands in the event of a worst-case discharge were developed. Both the SPCC Plan and the OPA-90 Plan included development of procedures for tankage and conveyance features, refueling facilities, evacuation plans, emergency response plans, and all other aspects of the Oil Pollution Prevention regulations. Both plans were revised or updated as practices within the facility changed with respect to the handling or storage of oil or oil products . Work included revision to the "significant and substantial harm" ratings of the facility.
PREPARATION OF AN SPCC PLAN FOR A DEFENSE DEPOT. A Spill Prevention, Control, and Countermeasures ("SPCC") plan was prepared for a principal Defense Distribution Depot in Utah that is maintained by the U.S. Defense Logistics Agency. The depot not only serves as a central location for receipt, inspection, storage, and shipment of inventory, but also serves as a maintenance facility for equipment, vehicles, etc. Plans were prepared to describe facility drainage, secondary containment, inspection procedures, security requirements, personnel training, and spill response. Individual areas of concern were addressed.
SUPPORT OF ENVIRONMENTAL IMPACT STATEMENTS RELATED TO CONTROL OF GREAT SALT LAKE FLOODING. Sections of two Environmental Impact Statements have been prepared for a lake-level control project associated with flooding of the Great Salt Lake. The lake level had risen significantly during a period of above-normal precipitation, flooding several facilities near the lake and threatening others. One EIS examined the impacts of pumping of the excess Great Salt Lake water to the desert west of the lake, while the other EIS examined in the impacts of operating a salt-production facility using water that had been pumped to the desert. For each project, detailed field investigations were conducted and published literature was reviewed to document the baseline soil, geologic, and groundwater conditions. Testing and analyses were conducted and numerical models were constructed to further predict the potential environmental impacts. In the first project, special concerns included the impacts of impounding the water in the desert on the adjacent Bonneville Salt Flats Speedway, a popular area for establishing land speed records. In the second project, particular care was taken to identify impacts of solar pond operation on a nearby hazardous-waste landfill. In each case, document sections were prepared and public meetings were held. The appropriate comments were incorporated into the reports and the final documents were published.
EIS SUPPORT FOR A MAJOR NATURAL GAS PIPELINE. Sections of an Environmental Impact Statement were prepared for a project involving the construction of a natural-gas pipeline from Wyoming to southern California. The purpose of this pipeline was to provide natural gas to customers in southern Utah and southern Nevada as well as for injection into a major oil field in southern California to assist in secondary recovery of oil. Detailed field investigations were performed and published literature was reviewed to determine soil, surface water, and groundwater conditions along the pipeline route. Particular concerns examined in the project included slope stability issues, as the pipeline crossed several landslides and other naturally-unstable areas, and the impacts to surface water created at stream crossings. Document sections were prepared and public meetings were held. The appropriate comments were incorporated into the reports and the final documents were published.
ENVIRONMENTAL ANALYSIS OF A PROPOSED SUBDIVISION. EarthFax conducted an environmental analysis of a proposed residential development to be constructed near a major resort area in Utah. Hydrologic, geologic, soil, biologic, and socioeconomic information was gathered and analyzed to determine the impact of the project on the environment. Public meetings were attended and the documents were revised as necessary to address public concerns regarding the project.
SUPPORT OF PART B PERMIT APPLICATIONS. EarthFax has provided support to the client preparation of Part B permit applications for hazardous-waste treatment, storage, and disposal facilities at a major rocket-motor manufacturing facility and a hazardous-waste incinerator, both located in northern Utah. In both cases, EarthFax evaluated the regulatory siting criteria with respect to flood plains and seismic zones. For the flood-plain evaluations, channel cross sections were surveyed and flood flows were estimated using rainfall-runoff models and regional flood-flow models. Water-surface profile models were then used to calculate flood elevations in the vicinity of the treatment, storage, or disposal facilities. For the seismic evaluations, published literature was reviewed to determine the potential for faults showing Holocene displacement to be present in the vicinity of the facilities. Aerial photographs and the results of fault-trenching investigations were then used to provide site-specific data concerning the potential presence of Holocene-age faults. Appropriate sections of the permit applications were then prepared and submitted to the client for incorporation into the larger document.
INPUT TO GUIDANCE MANUAL FOR PERMITTING OF OPEN BURNING/OPEN DETONATION FACILITIES. EarthFax prepared sections of a permit writer's guidance manual for open burning/open detonation facilities used by explosives manufacturing operations. The manual was intended to assist those who were attempting to comply with regulations promulgated by the U.S. Environmental Protection Agency under 40 CFR 264, Subpart X. The work was performed in support of efforts being made by the Institute of Makers of Explosives and the Aerospace Industries Association of America to develop a guidance manual that would be acceptable to EPA. EarthFax prepared sections dealing with groundwater and subsurface evaluations, discussing preliminary evaluations, detailed evaluations, and monitoring considerations that would be necessary to satisfy the needs of 40 CFR 264.601.
PREPARATION OF SUBPART X PERMIT INFORMATION. Documentation was prepared in support of a Subpart X permit for an open burning/open detonation site at an explosives manufacturing facility in northern Utah. EarthFax evaluated the potential for activities at the site to cause migration of wastes to groundwater and the subsurface environment, surface water, wetlands, and soil. Available data were evaluated to determine the rate and direction of groundwater flow. A water balance was then prepared to determine the potential for waste constituents to migrate to the soil and underlying groundwater. Surface runoff conditions were also assessed with respect to the potential for erosion of contaminated materials. Potential exposure to contaminated soil via inhalation and ingestion was also examined. Waste movement was evaluated with respect to metals, nitrates, and organics.