Final 

FEASIBILITY AND COST ANALYSIS
 

FINDINGS AND RECOMMENDATION REPORT
 

PARADOX VALLEY UNIT BYPRODUCTS DISPOSAL STUDY
 

Submitted to:
 

Wastren Advantage, Inc.
 

1571 Shyville Road
 

Piketon, Ohio 45661
 

Submitted by:
 

Amec Foster Wheeler Environment & Infrastructure, Inc.
 

San Diego, California
 

January 2017
 

Amec Foster Wheeler Project No. 1655500023
 

©2016 Amec Foster Wheeler. All Rights Reserved. 

 

 

 

 

January 2017 

Dave Sablosky 

Wastren Advantage, Inc. 

1571 Shyville Road 

Piketon, Ohio 45661 

Re:	 Final Feasibility, Cost Analysis, Findings, and Recommendation Report for Paradox 

Valley Unit Byproducts Disposal Study 

Dear Dave: 

The report included here satisfies the deliverable for the Paradox Valley Unit Evaporation Ponds 

Study 3: Final Feasibility, Cost Analysis, Findings, and Recommendations for Byproducts 

Disposal Report. As agreed with you and with Reclamation, this is a single combined report for 

the Byproducts Disposal Study that includes all elements anticipated from the Feasibility and Cost 

Analysis study, and the Findings and Recommendations report. This is a final version including 

all the information collected for Study 3 combined into a single report. It also includes the 

responses to the final comment matrix submitted by Reclamation. 

If you have any questions or concerns regarding this report, please contact Carla Scheidlinger at 

858-300-4311 or by email at carla.scheidlinger@amecfw.com. 

Respectfully submitted, 

Amec Foster Wheeler Environment & Infrastructure, Inc. 

Carla Scheidlinger 

Project Manager 

Amec Foster Wheeler Environment & Infrastructure, Inc. 

9210 Sky Park Court, Suite 200 

San Diego, California 

Tel: (858) 300-4300 

Fax: (858) 300-4301 www.amecfw.com 
Wastren Advantage, Inc. 

Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

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Final Combined Findings and Recommendation Report
 

Paradox Valley Unit Byproducts Disposal Study
 

Amec Foster Wheeler Project No. 1655500023
 

January 2017
 

TABLE OF CONTENTS 

Page 

ACRONYMS AND ABBREVIATIONS...........................................................................................v
 

1.0 BACKGROUND AND INTRODUCTION ........................................................................1-1
 

1.1 Statement of Problem.........................................................................................1-1
 

1.2 Location..............................................................................................................1-1
 

1.3 Organization of Report .......................................................................................1-2
 

2.0 POND SERIES CONCEPT ............................................................................................2-1
 

3.0 ASSUMPTIONS .............................................................................................................3-1
 

3.1 Inputs and Pond Sizes .......................................................................................3-1
 

4.0 BYPRODUCTS ..............................................................................................................4-1
 

4.1 Evaporation Tests ..............................................................................................4-1
 

4.1.1 Procedure...............................................................................................4-1
 

4.1.2 Brine Results ..........................................................................................4-2
 

4.1.3 Laboratory Salt Results ..........................................................................4-3
 

4.2 Potential End Products.......................................................................................4-4
 

4.2.1 Food Grade Salt .....................................................................................4-4
 

4.2.2 Processed Salt .......................................................................................4-4
 

4.2.3 Chlor-alkali Salt ......................................................................................4-5
 

4.2.4 Deicing Salt ............................................................................................4-5
 

4.3 Bitterns ...............................................................................................................4-6
 

5.0 DETERMINATION OF PRODUCT QUANTITIES AND QUALITIES..............................5-1
 

6.0 QUANTITY OF END PRODUCTS .................................................................................6-1
 

6.1 Solid Halite Salt ..................................................................................................6-1
 

6.2 Bittern .................................................................................................................6-1
 

7.0 MARKETABILITY...........................................................................................................7-1
 

7.1 Food Grade, Processed, and Chlor-alkali Salt ...................................................7-1
 

7.2 De-icing Salt .......................................................................................................7-1
 

7.3 Bittern .................................................................................................................7-1
 

7.3.1 Metal production.....................................................................................7-1
 

7.3.2 Road Dust Control and De-icing.............................................................7-1
 

8.0 END USERS ..................................................................................................................8-1
 

9.0 POTENTIAL DIRECT BUYERS .....................................................................................9-1
 

10.0 TRANSPORT OF SALT PRODUCTS..........................................................................10-1
 

10.1 Harvesting and Loading Considerations for Solid Salt .....................................10-1
 

10.2 Harvesting and Loading Considerations for Bittern (MgCl2 Liquid) ..................10-2
 

11.0 PRICE OF SALT PRODUCTS .....................................................................................11-1
 

11.1 Solid Salt for Road Deicing ..............................................................................11-1
 

11.2 Liquid Bittern Salt .............................................................................................11-1
 

11.3 Sale and Disposal Options ...............................................................................11-2
 

12.0 STORAGE OF SOLID SALT........................................................................................12-1
 

12.1 Type of Waste ..................................................................................................12-1
 

12.1.1 Evaporation Ponds ...............................................................................12-1
 

12.1.2 Naturally Occurring Radioactive Material (NORM) in Solid Salt
 

Products ...........................................................................................................12-1
 

12.2	 Methods and Issues for Handling.....................................................................12-1
 

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Final Combined Findings and Recommendation Report
 

Paradox Valley Unit Byproducts Disposal Study
 

Amec Foster Wheeler Project No. 1655500023
 

January 2017
 

TABLE OF CONTENTS (CONTINUED) 

Page 

12.3 Disposal Sites...................................................................................................12-2
 

12.3.1 Broad Canyon Landfill ..........................................................................12-2
 

12.3.2 Reams Construction 80 Ponds Landfill ................................................12-3
 

12.4 Independent Salt Storage Facility Associated with the Ponds .........................12-3
 

12.4.1 Permitting Issues ..................................................................................12-3
 

12.4.2 Application Submission Process ..........................................................12-5
 

12.4.3 Application Content ..............................................................................12-6
 

12.4.4 Financial Assurance .............................................................................12-7
 

12.4.5 Siting Approval .....................................................................................12-7
 

12.4.6 Application Fees ...................................................................................12-7
 

12.4.7 Additional Fees.....................................................................................12-7
 

12.4.8 Post-Closure fees .................................................................................12-8
 

12.5 Storage of Bittern Salts ....................................................................................12-8
 

12.5.1 Construction Cost Estimates ................................................................12-9
 

12.5.2 Management of Disposal Facility..........................................................12-9
 

13.0 RECOMMENDATIONS................................................................................................13-1
 

13.1 Salt products anticipated ..................................................................................13-1
 

13.1.1 Finding..................................................................................................13-1
 

13.1.2 Recommendation .................................................................................13-1
 

13.2 Marketability .....................................................................................................13-1
 

13.2.1 Finding..................................................................................................13-1
 

13.2.2 Recommendation .................................................................................13-2
 

13.3 Storage.............................................................................................................13-2
 

13.3.1 Findings................................................................................................13-2
 

13.3.2 Recommendations................................................................................13-2
 

14.0 REFERENCES.............................................................................................................14-1
 

LIST OF TABLES 

Table 1. Salt Products Produced in Laboratory Evaporation Tests..................................4-4
 

Table 2. Salt Type Specifications for Deicing Use............................................................4-5
 

Table 3. Salt Crystal Size Specifications for Deicing Use ................................................4-6
 

Table 4. Specifications for Products Approved by PNS for Road Use .............................4-7
 

Table 5. Trace Element Limits for Road De-Icing Bittern Products (PNS) .......................4-8
 

Table 6. Usage of Road De-Icing Materials in Colorado in 2013 .....................................8-6
 

Table 7. Specifications for MgCl2 used in Envirotech’s Products .....................................8-7
 

Table 8. Direct Buyers and Producers Contacted by Amec Foster Wheeler....................9-1
 

Table 9. Transport and Disposal Costs for Salt from Three Locations...........................10-2
 

Table 10. Transport Costs for Bittern (MgCl2 Liquid)........................................................10-3
 

Table 11. Regulation of Salt Storage for PVU Project......................................................12-4
 

Table 12. Fees Applicable to Solid Waste Disposal Permitting........................................12-8
 

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Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

LIST OF FIGURES 

Figure 1. Overall Map ........................................................................................................1-3 

Figure 2. Paradox Pond Schematic...................................................................................2-3 

Figure 3. Major Salt Deposits and Dry Production Sites in North America........................8-3 

Figure 4. Flowchart for the Completion of a Certificate of Designation ...........................12-6 

LIST OF APPENDICES
 

APPENDIX A SALT COMPOSITION TABLES 

APPENDIX B SALT CRYSTAL PHOTOGRAPHS 

APPENDIX C BULK DE-ICING SPECIFICATION 

APPENDIX D USE OF SALT PRODUCTION MODEL 

APPENDIX E ESTIMATION OF EVAPORATION AND PRECIPITATION 

APPENDIX F ION MASS DELIVERED TO BITTERN STAGE 

APPENDIX G RADIONUCLIDE TESTING REPORT 

APPENDIX H BRINE SOLIDS TESTING FOR LANDFILL DISPOSAL 

W:\2017\Projects\16-555-00023 Paradox Valley Unit Evap Ponds\R0117-0006\R0117-0006_FINALCombined byproducts report Jan 2017.docx 

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ACRONYMS AND ABBREVIATIONS 

Amec Foster Wheeler Amec Foster Wheeler Environment & Infrastructure, Inc. 

Ca Calcium 

Ca SO4 Calcium sulfate 

CD Certificate of Designation 

CDPHE Colorado Department of Public Health and Environment 

DOT Department of Transportation 

EDOP Engineering Design and Operations Plan 

F Fahrenheit 

gpm Gallons per minute 

h-P hoh-Pak 

K potassium 

M million 

Mg Magnesium 

Mg SO4 Magnesium sulfate 

MgCl Magnesium chloride 

Na Sodium 

NaCl Sodium chloride 

NORM Naturally Occurring Radioactive Material 

ppm Parts per million 

PVU Paradox Valley Unit 

Reclamation Bureau of Reclamation 

SG Specific gravity 

SO4 Sulfate 

USGS United States Geological Survey 

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Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

1.0 BACKGROUND AND INTRODUCTION 

1.1 Statement of Problem 

The Bureau of Reclamation’s Paradox Valley Unit (PVU) is a component of the Colorado River 

Basin Salinity Control Program, a multi-works program to control the salinity of Colorado River 

water delivered to users in the United States and Mexico. The PVU currently intercepts 200 

gallons per minute (gpm) of 260,000 mg/l brine and diverts it to a 16,000’ deep injection well for 

disposal. The injection rate has been curtailed during the 20 year life of the well due mainly to 

induced seismic activity associated with the injection process. At the current rate, Reclamation 

prevents approximately 100,000 tons per year from entering the Colorado River system. The 

current collection well field is capable of producing 400 gpm. However salinity control benefits 

may decrease when pumping in excess of 300 gpm. Therefore, for purposes of this study, the 

goal is to control up to 170,000 tons per year, or 300 gpm. Due to current and future limitations of 

the injection well, and long term salinity control considerations at Paradox, Reclamation is 

currently evaluating alternative methods of brine disposal of this produced brine. One of the longterm strategies being considered for brine disposal is diverting the brine to an evaporation pond 

or series of ponds. The Byproducts Disposal Study investigates the nature of the solid salts that 

would be produced in such an evaporation pond complex, the nature of the liquid magnesium 

chloride rich brine that remains, and evaluates preferred methods for their disposal or sale. This 

report presents and discusses the Feasibility and Cost Analysis for such disposal, and presents 

Findings and Recommendations regarding byproducts and their disposal or sale. 

Amec Foster Wheeler is conducting studies for three other aspects of the evaporation ponds. 

These studies include the management of hydrogen sulfide (H2S), the siting, design, and 

operation of the ponds, and the ecological risk associated with the development and operation of 

the ponds. The results of these studies are integrated as appropriate with the byproduct disposal 

study. 

This report is to present the cost and feasibility analyses of potential byproducts produced by the 

PVU brines in evaporation ponds. These analyses lead to findings and recommendations that 

address the ultimate disposal or sale of the salt products. The nature of the salts that will be 

produced is described, the various issues associated with both sale and storage of those products 

are discussed, and recommendations based on these findings are made. 

This evaluation was conducted without the benefit of a pilot-scale project in the field. Absent such 

a project, these conclusions must be taken as preliminary. They are the result of the best available 

data from initial brine analyses and laboratory evaporation studies, and of responsible peerreviewed models. In the experience of the industry professionals involved in this work, however, 

any final conclusions would require the development of an on-site field pilot project. 

1.2 Location 

The PVU is located near Bedrock, Colorado in the Paradox Valley of Montrose County, about 10 

miles east of the Colorado-Utah state line (Figure 1). The well sites are located adjacent to the 

Dolores River, which flows from south to north through the valley. The elevation of the well sites 

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is about 5000 feet. The Broad Canyon and Reams 80 Pond Landfills, which are discussed in the 

disposal section of this report (Section 11.3), are located approximately 25 miles from the 

production well sites, to the south of the town of Naturita. 

1.3 Organization of Report 

This report will first describe the nature of the evaporation ponds that will produce salt products, 

and will touch on the operational parameters that contribute to the production of salt products. 

Details of the nature of the brine itself are discussed, along with the nature of the products that 

are predicted to be produced from evaporation under different environmental conditions. The 

quality and quantity of the potential products will then be described, and the harvesting strategies 

required to collect those products from the ponds will be discussed briefly. Detailed operational 

strategies will be the subject of a separate report (Amec Foster Wheeler 2016a). The report then 

evaluates the potential disposition of those products, evaluating the potential markets, prices 

which suppliers have paid for the products in the past, and our professional judgement about the 

viability of entering these markets with PVU-generated products. The report also evaluates the 

disposal options for products that may not reach a market, and recommends which disposition 

option(s) should be considered. The costs for implementing these disposition options are 

discussed. Overall recommendations are made for how decisions may be made regarding the 

sale or disposition of the salt products in the future. 

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January 2017 

2.0 POND SERIES CONCEPT 

The pond series (Figure 2) is designed to accommodate a continual flow rate of 300 gpm, and 

for optimizing evaporation during the periods of time when evaporation exceeds precipitation. It 

includes an initial surge pond to accommodate flows during periods of low evaporation; 39 acres 

acting as a concentrator to bring the brine to a state of saturation, and a total of 290 acres of 

ponds serving as crystallizers where solid salts will be deposited. A bittern concentration pond 

of 24 acres allows for bittern liquids to attain the concentration required for road deicing use, 

and a final bittern storage pond accommodating up to 10 AF of fluid confines the final liquid 

product prior to sale or disposal. Ponds were determined using a model that is described in the 

Pond Design Strategy Report (Amec Foster Wheeler 2016b) and which is also considered in 

Appendix D. 

The pond series can be operated with some flexibility depending on climate and weather 

parameters, or on what byproducts are desired. Details of the operational strategies that 

produce the salt products discussed here are in the Operational Strategies report (Amec Foster 

Wheeler 2016a). In this report, the ponds are identified as in Figure 2, and their operation is 

assumed to have the potential to produce the products described here. The points at which a 

freshwater feed is needed for brine transfers are shown in Figure 2 as FW. 

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Amec Foster Wheeler Project No. 1655500023 

January 2017 

3.0 ASSUMPTIONS 

There are several assumptions that were used to determine the size and footprint of the ponds, 

and these assumptions are detailed in the Pond Design Strategy Report (Amec Foster Wheeler 

2016b). A summary of important parameters of pond design that affect operation are shown here. 

3.1 Inputs and Pond Sizes 

Amec Foster Wheeler has made the following assumptions about the inputs to the system, which 

are based on the chemistry analyses of the brine and of the operational goals of the project. 

•	 The rate of flow into the system will be relatively constant at 300 gpm of brine. 

•	 The input brine has specific gravity (SG) of 1.1725 as reported from the hoh-PAK 

laboratory analysis. 

•	 Evaporation rates were calculated based on local climate data analyzed from 1993-2015, 

and on pan evaporation data produced by Reclamation at the PVU facility. Pertinent 

parameters are: 

o	 A pan to pond coefficient of 0.73. 

o	 Well brine evaporation discount factor of 0.72. 

o	 Saturated brine evaporation discount factor of 0.76. 

Based on the data, the pond series is designed for a surge pond to accommodate flows during 

periods of low evaporation; 39 acres acting as a concentrator, and of a total of 290 acres of ponds 

serving as crystallizers. Refinements for the evaporation rates included assumptions that across 

the concentrator an average discount factor (the factor by which evaporation is different from that 

of pure water) of 0.74 is appropriate, and across the crystallizers, which are fed in parallel, an 

average discount factor of 0.66 is appropriate. 

Assumptions are also made for bittern production. These assumptions are: 

•	 The bittern point is set at SG = 1.2610 in order to produce a product with the required 

maximum concentration of magnesium (Mg) for deicing salt as described in Section 4.3. 

The SG point was arrived at by interpolation of the laboratory results. 

•	 With the bittern at SG = 1.2610, the evaporation discount factor is 0.55. 

•	 A total of about 63 gallons (gal) of every 1,000 gal of brine fed from the concentrators to 

the crystallizers will result in the initial bittern. After bittern concentration, about 4 gal of 

concentrated bittern would remain. 

•	 The size of the bittern concentrator pond is 24 acres. 

These assumptions are derived from calculations that result in all the solid salt being made 

conforming to salt deicing quality standards, as described in Section 4.2.4. These assumptions 

do not maximize the quantity of salt made in the crystallizers, nor do they minimize the amount of 

bittern solids generated. 

Finally, it is assumed that the H2S in the brine will be removed such that operators can work in 

the area without any undue risk to health or to being exposed to noxious odors. 

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Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

4.0 BYPRODUCTS 

The byproducts that will be possible to produce from the evaporation ponds are a function of the 

nature of the produced brine, and of the manner in which the pond series is operated. In order 

to determine what the brine could produce, this project began with a series of evaporation tests. 

4.1 Evaporation Tests 

A sample of well brine from Paradox Valley was sent to hoh-PAK (h-P) Labs in Louisiana for 

testing. This laboratory is highly experienced in testing saline brines and related salts. h-P is 

audited yearly by the salt industry to certify its results, and has been utilized several times to do 

the type of testing discussed below. 

The intent of the testing was to determine the phase chemistry of the brine as it evaporates. The 

testing follows both the brine and the precipitated salts as brine concentration increases. Testing 

was done for evaporation under both warm and cold season conditions. The results allows 

prediction of the quality of salts produced. Using evaporation and precipitation data from the area, 

this information also allows modeling a series of ponds that will produce these salts in the area of 

the Paradox Valley and predict the quantities produced. 

Refer to Appendix A for the associated Excel Spreadsheet describing the test results and analysis 

of the h-P data. Appendix B shows pictures of the salt formed during the evaporation tests. 

4.1.1 Procedure 

Well brine was placed in a shallow evaporation dish and placed in a climate-controlled box. The 

box was kept at 120oF. A fan maintained air movement above the surface of the brine, and 

provided for exchange of outside air. The temperature was set to speed the progress of laboratory 

work, and was not meant to duplicate atmospheric conditions in the field at the PVU site. Note 

that the phase chemistry of saline brines of these concentrations is not temperature dependent in 

this temperature range. A similar test was done at 12oF to determine if the phase chemistry was 

different at that temperature. 

Brine in the evaporation dish and precipitated salts were gathered and both brine and solid salts 

were tested at intervals during the procedure. The intervals varied and depended on when enough 

salt was made for testing. The test procedure followed the ASTM E-534 protocol used worldwide 

by salt producers and users. 

The brine was tested for calcium (Ca), magnesium (Mg), sulfate (S04), potassium (K), specific 

gravity (SG) and pH. Direct sodium (Na) measurement was attempted in several samples. 

However, since the required dilution to measure the Na was 20,000:1, any small error was greatly 

magnified. This led to unreliable results and the measurement was discontinued. Trace chemicals 

such as barium and zinc were not measured. 

Specific gravity and potassium were measured as a way to track the concentration path of the 

brine. Specific gravity is easy to measure in the lab and in the field; however, great accuracy is 

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Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

needed to use this metric to detect small changes in concentration, and specific gravity data are 

therefore more difficult to interpret. Potassium will not precipitate at the concentrations 

investigated, and is therefore a good way to measure percent evaporation. As concentration of K 

in the brine increases as a direct result of evaporation, that concentration allows for an accurate 

calculation of the amount of water evaporated from the brine. 

Testing of the precipitated crystals was done to measure water insolubles (dirt), Ca, Mg, and SO4. 

Calculations were then made to determine the solid phase mineral makeup of the crystals. Again, 

trace chemicals were not measured. 

The salt crystals were sent to the lab at TestAmerica for the detection of radionuclides. This was 

done to determine if the salts would constitute hazardous waste if they are permanently disposed 

of in a landfill facility. The results are in Section 12.4.1. 

4.1.2 Brine Results 

The initial brine analysis is shown at a K concentration of 4846 parts per million (ppm) (SG = 

1.1725). Sodium chloride (NaCl) saturation was reached at a K level of 5523 ppm (SG=1.1986). 

At that point, 12% of the original brine had evaporated. 

Thereafter, precipitated crystals were removed from the brine when there was an amount 

sufficient for testing. When the crystals were removed, a sample of the brine was also taken for 

analysis. The percent evaporation, based on K concentration, is shown for each sampling. A final 

brine sample was taken at 91% evaporation. The amount of solid salt at this brine point was too 

small to test. These results are shown in Table A-1 in Appendix A. 

The brine did evaporate to dryness under laboratory conditions at 120oF. A further test was made 

by h-P to simulate ambient temperatures in the upper 80's F (day simulation) and in the 50's F 

and 60's F (night simulation). This sample also evaporated to dryness under the laboratory 

conditions. 

The graphs in Appendix A illustrate the results of the testing. The “Summer Brine Phase 

Chemistry-K” graph shows K as a tracer for concentration, and the “Summer Brine Phase 

Chemistry-SG” graph shows SG used for the same purpose. (Note that K is a much more 

definitive measure of concentration for doing this kind of analysis.) Data in black are laboratory 

results. Data in green are calculated from the laboratory results. Calcium is depicted on the graphs 

as ten times the lab value in order for the line to be more easily visible. Any line or part of a line 

shown on the graphs that slopes downward from left to right shows definitive precipitation of that 

element. 

An upward sloping line may or may not indicate precipitation. Sulfate is precipitating with Ca, but 

as there is stoichiometrically more SO4 than Ca, the SO4 line does not show a downward trend. 

The percent evaporation based upon SO4 was also computed. Note that the SO4 numbers are 

much lower than the K numbers. This indicates that SO4 is precipitating. 

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Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

4.1.3 Laboratory Salt Results 

Knowledge of saline brine chemistry and the use of stoichiometric relationships allow for 

calculations of the type of minerals precipitating from the brine. Given the lab measurement of 

Ca, Mg and SO4 in the collected salts, a calculation of the minerals precipitated was made. These 

results are shown in cells describing the crystals in Appendix A, Tables A-1 through A-3 and in 

Table 1 below for the tests done at 120oF. 

The first crystals that formed in an amount large enough to test were formed between K=5523 

ppm and K=7573 ppm. This range is from the point where NaCl (halite) first started to precipitate 

at 12% of initial brine evaporation, to 36% of initial brine evaporation. Note again that, due to 

testing methods explained above, the percentage of NaCl was calculated by subtracting the 

amounts of Ca and Mg salts, and the insolubles, from 100 per ASTM E-534. So these first crystals 

were 97.60% NaCl, 2.2% CaSO4, 0.14% magnesium chloride (MgCl2) and 0.07% magnesium 

sulfate (Mg SO4). 

Four samples of crystals were gathered for testing. The results for salt crystal composition are 

shown in Appendix A Table A3; photos of the crystals collected are in Appendix B (Figure B2 and 

B2). The average NaCl composition across all samples was 98.63%. This does not mean that the 

statistical average NaCl content was 98.63%, as the sample sizes were different, and lab 

conditions don’t really allow for weighted averages. However, note that the NaCl content of each 

sample doesn’t vary substantially. Therefore the statistical average would actually be close to 

98.63%. 

As the CaSO4 (gypsum) precipitates during the evaporation process, the amount of gypsum 

decreases. This is entirely in keeping with the known progress of other similar saline brines. 

The amount of MgSO4 and MgCl2 shown in the results generally increases as the percent of the 

brine that is evaporated increases. The precipitation of gypsum and the precipitation of Mg salts 

are fundamentally different. Gypsum is co-precipitating with NaCl before the solid sample is 

collected from the brine. Mg salts only precipitate after the crystals are removed from the brine. 

These evaporated brines exhibit a high surface tension and stick tenaciously to the surface of the 

precipitated crystals. No matter how well the collected crystals are drained before testing, a small 

amount of brine will remain on the crystals. If the brine on the crystal surface dries before testing, 

the magnesium minerals will precipitate on the surface of the NaCl crystals. Although they appear 

in the analysis as constituents of the halite, they are not actually part of the halite crystal but rather 

a film of a different material adhering to those crystals. If the brine does not dry before testing, the 

mineral ions are in the brine and show up in the testing. In either event, the Mg minerals are 

calculated. In a commercial salt production facility, the brine adhering to the salt crystals is washed 

off before going to a stockpile, resulting in a salt that is very low in Mg. 

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January 2017 

Table 1. 

Salt Products Produced in Laboratory Evaporation Tests 

1st 

Crystals 

2nd 

Crystals 3rd Crystals 4th Crystals 

% % % % 

CaSO4 2.20 0.71 0.54 0.57 

MgSO4 0.07 0.00 0.13 0.37 

MgCl2 0.14 0.13 0.19 0.41 

Insolubles 0.004 0.001 0.001 0.001 

NaCl (by diff) 97.59 99.16 99.15 98.65 

Under laboratory conditions, these brines, then, produce a preponderance of halite, with only 

trace amounts of gypsum and Mg salts under laboratory conditions. MgCl2 can be produced in 

greater quantity in the ponds under the climatic conditions of Paradox Valley than can be 

produced under laboratory conditions. 

The tests performed at 12oF give essentially the same results as shown above (See Appendix A, 

Winter Brine Analysis). As the overwhelming preponderance of salt will be made at warmer 

temperatures, Table 1 indicates in generally accurate terms the nature of the product that will be 

formed year round. 

4.2 Potential End Products 

The solid salt byproducts described above can be treated in a variety of ways to produce final 

products. These potential products, how they are produced, and the potential for their market 

disposition, are described in the following sections. 

4.2.1 Food Grade Salt 

Strictly speaking, the quality requirements for food grade salt revolve more around good 

manufacturing process than around product purity. In order to produce food grade salt, the 

production facility must have a documented and inspected process to eliminate metal particles 

from the salt, a documented and inspected process to keep contaminants such as rodent 

droppings out of the salt, and other management requirements. However, in effect, the American 

consumer has associated food grade with high purity as well. In addition, there are also a number 

of granule size screening ranges to be considered in a food grade product. Therefore, a food 

grade product from PVU would have to meet all of the criteria for purity, granule size range and 

contamination. Food grade salt is packaged in a variety of ways and some products require 

additives such as iodine. Production of food grade salt would involve a high level of capital 

expenditure, business development and organization, and cost. Based on the professional 

experience of the team, production of this material is not recommended. 

4.2.2 Processed Salt 

A second category of products uses salt from a stockpile that has been washed a second time, 

dried to near zero moisture, screened to meet granule size requirements, and packaged in a 

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variety of ways – bulk, bulk bags, bags, etc. Some deicing locations that have very low 

temperatures want a bagged, dried salt. Furthermore, some of these processed products require 

additives prior to being used for purposes such as seafood processing salt. Water softening salt 

is a big user of processed salt. This kind of production would also involve a high level of capital 

expenditure, business organization, and cost. Based on the professional experience of the team, 

production of this material is not recommended. 

4.2.3 Chlor-alkali Salt 

A third category of products is salt sold in bulk directly from a stockpile. The salt in the stockpile 

has typically been harvested from a crystallizer pond, washed and drained. One use for this salt 

is feedstock for chlor-alkali facilities. The chlor-alkali process is an industrial process for the 

electrolysis of NaCl. It is the technology used to produce chlorine and sodium hydroxide (caustic 

soda), which are commodity chemicals required by industry. The chemical industry is the largest 

consumer of salt worldwide, using about 60% of the total production. This industry converts the 

salt mainly into chlorine, caustic soda and soda ash (Sedivy 2008). 

The production process for chlor-alkali facilities has been changing over the last couple of 

decades. The newer processes require high quality salt. Salt made from PVU brine for this use 

would have to be washed, and otherwise treated to assure adequate purity. The general purity of 

NaCl from solar salt production anticipated by the chlor-alkali is 99.8%. Laboratory testing would 

have to be done at the outset, however, to determine whether washing, which is an expensive 

process, would even produce a product of the necessary quality. Based on the professional 

experience of the team, production of this material is not recommended. 

4.2.4 Deicing Salt 

Salt used for deicing is applied to road surfaces to melt snow and ice and to improve the safety of 

the roads for vehicle passage. This is the most feasible product for production at the PVU facility. 

In the United States, deicing salt must meet both a quality and granule size range specification. 

Those specifications can vary from jurisdiction to jurisdiction, and the minimums are set in ASTM 

D-632. Typical specifications are shown in Tables 2 and 3. 

Table 2.
 

Salt Type Specifications for Deicing Use
 

Component Specification 

(%) 

Lab Results 

(%) 

NaCl db* (min) 97.9 98.6 

Ca+Mg (max) 0.7 0.4 

SO4 (max) 0.5 0.8** 

Insolubles (max) 0.05 0.002 

Moisture (max) 2.0 Not known 

Notes:
 

*db denotes “dry basis”. The NaCl content is stated without moisture
 

** Actual percent of SO4 can only be determined with a pilot pond test.
 

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Table 3. 

Salt Crystal Size Specifications for Deicing Use 

USS Mesh % Passing 

3/8 90-100 

4 20-90 

8 10-60 

30 0-15 

Some suppliers report providing a product with a lower percentage of SO4 and a higher allowance 

for Ca and Mg (Central Salt 2012), so the final product would have to be evaluated by the entity 

marketing it. Some shipping destinations will require a Yellow Prussiate of Soda (YPS) additive. 

This is inexpensive and easily applied at the time of shipment. YPS keeps salt stockpiles from 

freezing in very cold situations, and could be added at the PVU production site. 

Based on lab testing, salt produced from PVU brine can meet the quality requirements for this 

kind of use. It is not possible to know much about meeting the size requirements until salt can be 

made in a pilot size pond. As salt crystal size is climate dependent, it is expected, based on salt 

produced in similar climates, that the produced PVU salt would also meet crystal size 

specifications. Some minimal screening to remove lumps and fine particles would probably be 

necessary to produce a marketable quality of salt. Although most producers subject harvested 

solar salt to processes of washing, drying and screening (Compass Minerals 2014), these 

processes would not be needed if road deicing salt is to be the only use. This process does not 

require much capital or operating costs. Normal stockpile stack drainage should take care of the 

moisture specification. A sample deicing salt specification that would be applicable to salt is in 

Appendix C. 

4.3 Bitterns 

The point at which a brine is considered to be “bittern” can be designated in different ways and 

for different purposes. The bittern point in the salt industry is determined by quality considerations 

for the main product, which is generally NaCl. If a process focuses on producing a marketable 

bittern product without regard to the salt product, then a different bittern point could be designated 

to achieve that result. Leaving the brine in a crystallizer for longer than would be done for the 

production of NaCl, for example, could lead to a more valuable bitten product, as less desirable 

compounds would precipitate out and remain in the crystallizer. 

Bittern is generally thought of as a liquid product that is high in Mg content. Such products can be 

sold to Mg metal producers as a raw material feed, used in some formulations for road deicing, 

and applied to dirt roads as a dust suppressant to satisfy government mandated particulate matter 

regulations. 

Although h-P was able to take the PVU brine to complete dryness in the lab, this result was 

obtained in dishes that had a very shallow level of brine in them. In field conditions, especially if 

bittern production was a goal, bittern would be produced. The bittern would consist of both bittern 

fluids and bittern solids (Section 5.2). 

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Magnesium chloride (MgCl2) is a common component of a variety of commercial preparations of 

road deicers. Per personal correspondence with Tyler Weldon (Colorado DOT Staff Maintenance 

Engineer, July 14, 2016), Colorado uses the Pacific Northwest Snowfighters (PNS) specifications 

as their standards. Other surrounding states also use these specifications. Table 4 below shows 

the Mg content specification for a variety of Mg-based products used on roads. Colorado uses 

FreezeGard 0®, Ice Ban®, and Caliber M1000®. The required percent MgCl2 for the list and for 

Colorado products ranges between 26 and 30%. Other specifications, however, may have trace 

mineral maximums, which are shown in Table 5. In addition, corrosion inhibition requires 

additives. 

Table 4.
 

Specifications for Products Approved by PNS for Road Use
 

Pacific Northwest Snow Fighters (PNS) Qualified Product List – PRODUCTS
 

Date of Listing: April 4, 2016
 

Category 1 – Corrosion Inhibited Liquid Magnesium Chloride
 

Product Name Manufacturer Corrosion Rate 

% Effectiveness 

% MgCl2 

Concentration 

Date 

Approved 

Iceban 200 Earth Friendly Chem. 8.4 26% 8/15/2002 

Caliber M1000 AP Envirotech Services Inc. 20.8 28% 8/2/2004 

Meltdown with Shield 

AP 

Envirotech Services Inc. 25.9 30% 8/2/2004 

Hydro-Melt Green Cargill 24.3 28.5% 8/1/2005 

Meltdown APEX with 

Shield AP 

Envirotech Services Inc. 25.1 30% 1/25/2006 

FreezGard Cl Plus Compass Minerals 12.2 30% 8/28/2006 

Ice B’Gone II HF Sears Ecological Appl. 28.6 25% 8/9/2007 

FreezGard LITE Cl Plus Compass 12.3 27% 6/13/2001 

HydroMelt Liquid Deicer Cargill 28.0 28.6% 8/15/2011 

FreezGard Cl Plus Sub 

zero 

Compass 14.1 27.5% 10/11/2011 

Ice Ban 305 GMCO Corporation 25.3 26.6% 1/10/2013 

FreezGard 0 CCl GMCO Corporation 21.2 30.0% 1/10/2013 

Meltdown Apex Envirotech Services Inc. 22.4 30.0% 4/16/2014 

Meltdown Inhibited Envirotech Services Inc. 24.1 30.0% 4/29/2014 

ProMelt MAG 20 INH Innovative Surface 

Solutions 

25.2 30.0% 7/13/2015 

ProMelt Ultra 1000 INH Innovative Surface 

Solutions 

28.2 27.0% 7/31/2015 

NexGen Torch GMCO Corporation 25.0 30.0% 12/17/2015 

Note: Iceban 200 was formerly Iceban Performance Plus M 

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Table 5. 

Trace Element Limits for Road De-Icing Bittern Products (PNS) 

Element Concentration limit (ppm)* 

Arsenic 5 

Barium 10 

Cadmium 0.2 

Chromium 0.5 

Copper 0.2 

Lead 1 

Mercury 0.05 

Selenium 5 

Zinc 10 

Total cyanide 0.2 

Total phosphorus (1% solution) 25 

pH (1:4 solution) 6 to 9 

Sulfate (% by weight) 2 

*Unless otherwise indicated 

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5.0 DETERMINATION OF PRODUCT QUANTITIES AND QUALITIES 

Amec Foster Wheeler used a non-proprietary model to determine the quantity and quality of salts 

that could be produced on an annual basis at the PVU site. This model was also informed by the 

professional judgement and experience of the Amec Foster Wheeler consultant team. Appendix 

D is a summary of the results of that model using one of several assumptions or scenarios that 

was selected to optimize the quality of solid salt produced that would be suitable for sale for road 

deicing use. A discussion of the evaporation data and how it informs the model is in Appendix E. 

The Excel spreadsheet that produced the tables shown in Appendix C is also provided as a 

separate file to allow the user to manipulate the assumptions to produce different scenarios for 

consideration. This report uses the assumptions shown in the tables and discussion of Appendix 

D. Pond sizing was also done using these assumptions (Amec Foster Wheeler 2016 b). Amec 

Foster Wheeler emphasizes that the quantities and qualities of products discussed here cannot 

be known definitively unless a pilot pond series is designed and operated for at least a year. The 

team also stresses there are multiple operational parameters and assumptions which would affect 

ultimate pond design and operation. For this project, the team selected the scenario shown in 

Appendix D. 

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6.0 QUANTITY OF END PRODUCTS 

6.1 Solid Halite Salt 

Calculation of the total quantity of marketable halite that would be expected to be produced by 

the PVU project each year is based on the assumption of a constant production rate of 300 gpm 

of brine at a constant chemical composition, and on the operation of the ponds to discharge brine 

from the concentrator and crystallizers at a defined SG. The current quantity assumed at this time 

is 137,000 tons of solid halite. This total does not include the mass of the bitterns, which include 

both liquids and solids, and which are described separately in Section 5.2. 

6.2 Bittern 

The salt model that was produced to arrive at the pond design (Amec Foster Wheeler 2016b) 

predicts that after 94% of the well brine produced annually evaporates in the concentrator and 

crystallizers, about 30.7 AF would remain as a “dilute” bittern with an MgCl2 concentration of 

about 2.7%. This would need to evaporate to a concentration of 30% MgCl2 to be marketable. 

The model cannot make especially accurate predictions about the quantity of marketable MgCl2 

that could be recovered from the ponds, as much of the ultimate results depend on operational 

parameters and on a field knowledge of the nature of the solid salts that will precipitate from the 

bittern fluid as bittern salts. A pilot pond test would be required to make accurate volume and 

mass determinations. The brine solution at the point of discharge from the crystallizer ponds is 

saturated in halite and mixed Na, Ca and K-SO4 compounds. It is also highly saturated in 

polyhalite -- K2MgCa2-4(SO4): 2H20 (per a PHREEQC analysis). It is not, however, close to 

saturation in any other Mg compound. Therefore, the discharged brine will continue to 

precipitate halite and other salts. These bittern salts have little or no value, and they must be 

removed from the bittern as it continues to concentrate. This process is discussed in the 

Operational Strategy Report (Amec Foster Wheeler 2016a). This continued precipitation will 

entrain some of the remaining bittern brine in the voids of the crystal mass. 

The residual brine will be enriched in Mg by the relative loss of other compounds including the 

K, but the recoverable volume could be small. To determine the volume of final MgCl2 that could 

be recovered, as well as the exact nature of the bittern solids, it will be necessary to construct 

and operate pilot ponds as discussed above. 

Based on the models presented, the best prediction that can be made at this time is for about 

3,456 tons (643,254 gal) of concentrated MgCl2 would be produced per year. The inventory of 

salts present in the bittern is shown in the table in Appendix F. 

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7.0 MARKETABILITY 

The principal goal of the PVU project is for the on-going and continual removal of salt from the 

groundwater system. In evaporation ponds, the products produced from this brine are halite salt, 

and MgCl2 bittern liquid. Both the produced halite salt and MgCl2 bittern liquid would require 

some level of processing to meet market requirements. Marketability of each kind of product is 

discussed below. 

7.1 Food Grade, Processed, and Chlor-alkali Salt 

To make the salt products suitable for the various end users, the application of advanced 

technologies in salt production and processing are necessary to facilitate profitable production 

of high quality solar salt for human consumption, exports, and the chlor-alkali industry (Sedivy 

2008). In the professional opinion of the team, the development of an operation for the 

production, storage, transport, and marketing of food grade, processed, or chlor-alkali salt 

should not be considered. 

7.2 De-icing Salt 

For deicing salt, the PVU brine can produce an acceptable product. The issue of whether a 

remotely located producer such as the PVU, or a more local distributor/applicator would be able 

to enter the existing market given the transportation hurdle is an important consideration, and it 

is addressed below in Section 9.0. Cost and pricing data for this product is also addressed in 

this report, in Section 10.0. 

7.3 Bittern 

7.3.1 Metal production 

It is unlikely that bittern produced by the PVU project could be sold to Mg metal producers, 

given transportation costs and market supply factors. The Mg metal producer closest to the PVU 

is in the Salt Lake City area. They have a captive system and produce all their own brine at a 

low cost, and do not require any inputs from other sources. The only time on record when they 

purchased brine from an outside source was in 1983 when the Great Salt Lake flooded and the 

facility’s in-house brine system was inundated. Once they reactivated their system, they stopped 

buying the product from other sources. 

7.3.2 Road Dust Control and De-icing 

The other two uses for bitterns are for road de-icing and dust suppression products. The nature 

of the bitterns needed to supply this market is discussed in Section 4.3. Bitterns produced from 

PVU brine could be marketed for these purposes. 

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8.0 END USERS 

Road salt products and MgCl2 preparations are by far the most widely used chemical methods of 

deicing roadways because of their ease of use, effectiveness, and relatively low cost compared 

to alternative de-icing methods. Driven by an increased public expectation for safe and clear 

roads, and fueled by relatively low costs, many states have steadily increased their use of road 

salt and MgCl2over the last 30 years. 

Figure 3 is a map showing the salt producing locations in North America. It can be seen that the 

main producers are in Utah, Kansas, Oklahoma and New Mexico. Kansas is the top salt producing 

state in the US, and its salt is derived from mines. The closest producer to PVU is located in 

Moab, UT. A major source of solar salt is at the Great Salt Lake, production facilities along the 

shore of the lake. 

Per the United States Geological Survey (USGS) Mineral Commodity Summary for Salt, in 2015 

47.2 million tons of salt was produced and used in the United States (USGS 2015). A total of 23.2 

million additional tons were imported, and 0.8 million tons produced domestically were exported. 

The amount imported tends to vary with the needs for winter deicing. Of the 69.5 million tons used 

in the United States in 2015, 46% or 32.4 million tons was used for road deicing. Compass 

Minerals (2014) estimates that 37 million tons per year are used in North America, based on 

average winter weather conditions. Most of the deicing salt sold in the Midwest and East is 

produced from underground mines. In the West, however, deicing salt is produced in solar ponds. 

The 137,000 tons of solid salt produced by the PVU project, then, is a very small fraction (0.45%) 

of the salt used annually in the United States for deicing, and would be unlikely to dramatically 

affect the competitive climate for solid salt in this country. The salt could, however, prove to be a 

valuable resource for deicing salt providers who sell such a product in the region. Reclamation 

could consider offering the products to suppliers who would pay more than the disposal costs. 

Potential purchasers of deicing salt produced by PVU are most likely to be State Departments of 

Transportation (DOT), counties, larger cities, other producers that can more cheaply serve their 

customers from PVU products, and independent distributors and spreaders. Compass Minerals 

(2014) reports that their principal customers are states, provinces, counties, and maintenance 

contractors that purchase material in bulk, untreated, for ice control on public roadways. Compass 

Minerals (2014) also reports that highway deicing salt in North America is sold primarily through 

an annual tendered bid contract process with governmental entities, as well as through some 

longer-term contracts, with price, product quality and delivery capabilities as the primary 

competitive based market factors. 

The solid salt can be used in different ways for deicing. The salt can be spread as is, mixed with 

sand, used with wetting agents or anticorrosion additives, or as an ingredient in a liquid product. 

Much of the deicing salt is purchased and transported during the summer to be stockpiled at the 

point of use prior to the onset of winter. If the upcoming winter has many snowfalls and all the 

stockpiled salt is used, spot deliveries would be made from a supplier during the winter. As noted 

above, tonnages of salt purchased vary significantly from year to year due to differences in the 

frequency and intensity of winter storms. 

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The use of deicing salt varies somewhat from state to state. Also, states change their salt policies 

from time to time. Following is an overview of current salt usage policies by state. The states 

analyzed are those within a reasonable transportation distance from Paradox. 

Colorado 

Given competition from Utah, Kansas and New Mexico, Colorado is likely to be the major market – 

at least initially – for PVU byproducts. Although there are no salt producers in Colorado, Colorado 

Department of Transportation (CDOT) uses a variety of salt-related products to treat Colorado 

highways during winter storms. All of the products contain salt with added corrosion inhibitors 

used to prevent or remove the build-up of ice and snow on roads and minimize the impact on 

vehicles. The two major types currently used are salt complexes and sand mixtures. An example 

of a salt complex is Ice Slicer®, a proprietary product of Redmond Minerals. It is a mined product 

that Redmond describes as a blend of complex chlorides (Na, Mg, Ca, K) with an anticaking 

additive and a red color. The other type is a sand or sand/salt mixture, which is mainly used in 

the high elevations and the eastern plains where more extreme cold temperatures exist and more 

traction is needed. Sand Slicer®, for example, is sand with some MgCl2 or other similar chemicals 

mixed in. Table 6 lists the actual usage in the State of Colorado for the winter of 2013/14. Some 

of the listed products are proprietary, and others are mixed by the State from ingredients acquired 

separately. Although there is some use of unblended solid salt (as road salt and the salt 

component of the salt-sand mix), salt does not form a large part of the deicing materials used in 

Colorado. 

A more important constituent of Colorado’s road deicing arsenal is MgCl2. This product is used 

alone (liquid de-icers, salt brine) and as an ingredient in a number of mixtures. With few 

exceptions, these products are manufactured or pre-mixed materials that incorporate proprietary 

additions for corrosion control or for other performance enhancements. Many of these are 

produced by Redmond Minerals from their salt mine located in central Utah, or by Envirotech with 

offices in Colorado. 

In Colorado, an important avenue for selling byproduct material is the MgCl2 market. The product 

required as a raw material is a 30% MgCl2 liquid. Envirotech is one of the major suppliers of MgCl2 

products in the region. They have expressed interest in purchasing MgCl2 from the PVU project 

as long as it meets their specifications (Jonathon Nelson, pers. comm. August 9, 2016). A sample 

MgCl2 specification for the products they sell is in Table 7. As the laboratory data from h-P did not 

include concentration of the initial bittern fluids, it is not possible to evaluate the characteristics of 

the final bittern. It will be possible to attain the target 30% concentration of MgCl2, but the amount 

of sulfates and other constituents is not known. Information in Section 6.2 shows that 3,456 tons 

(643,254 gal) of concentrated MgCl2 could be produced per year. Depending on the price offered 

in any year, sale in Colorado might be possible. 

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Table 6. 

Usage of Road De-Icing Materials in Colorado in 2013 

Description Quantity UOM Total Cost 

cost/unit 

delivered 

Producer 

(if known) 

Calcium Chloride 1.025 TON $415.54 $405.40 

Calcium Chloride 9.18875 TON $6,116.63 $665.67 

SALT, ROAD 162.98 TON $25,490.39 $156.41 

Abrasive Non-Sanding 7,749.11 TON $64,066.83 $8.27 

Abrasive Non-Mixed for 

Sanding 

2,808.50 TON $44,667.83 $15.90 

SALT-SAND MIX 18,306.94 TON $550,970.86 $30.10 

Liquid Deicer 254,308.10 GLL $165,553.71 $0.65 

ICE SLICER RS 40,345.34 TON $3,974,021.61 $98.50 Redmond 

Minerals 

LIQUID DEICER 

SPECIAL (Liquid+SaltSand) 

5,144.50 TON $98,044.40 $19.06 

Caliber 1000 14,400.00 GLL $11,784.00 $0.82 Envirotech 

APEX, LIQUID DEICER 8,822,724.70 GLL $7,323,932.29 $0.83 Envirotech 

SAND/SLICER 163,606.12 TON $4,555,557.25 $27.84 

ICE SLICER SB 8 TON $861.46 $107.68 Redmond 

Minerals 

RAPID THAW 23.25 TON $2,495.21 $107.32 GMCO 

CALIBER M-2000 15,726.00 GLL $15,557.06 $0.99 Envirotech 

ICE BAN 305 2,654,557.00 GLL $2,075,344.02 $0.78 Earth 

Friendly 

Chemicals 

LIQUID DEICER 

SPECIAL (PRE-MIX) 

3,774.03 TON $63,006.97 $16.69 

Salt Brine, Gallon 600,264.60 GLL $326,849.50 $0.54 

Solar Qwicksalt 1,167.25 TON $100,058.24 $85.72 

Ice-Melt, Snow, Ice, 

Sidewalk, -25F 

4.875 TON $3,892.00 $798.36 

SOS-TM, LIQUID 

DEICER, MAG 

CHLORIDE 26% 

24,156.00 GLL $29,112.58 $1.21 Envirotech 

$19,492,798.38 

Source: CDOT 2014. This information is for CODOT only and does not include cities, counties or municipalities. 

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Table 7.
 

Specifications for MgCl2 used in Envirotech’s Products
 

Utah 

There are 73 road maintenance stations in Utah, and all of them have on-site salt storage (Report 

UT-14.02). Salt is used as-is for deicing, or is made into a liquid product by mixing it with water. 

Salt from the PVU ponds could be used in this way. In 2014, UDOT reported use of 194,000 cubic 

yards of solid salt (183,330 tons), as well as 1.8 million gallons of liquid brine (Deseret 2014). 

Utah also used Quiksalt®, which is a proprietary product of Compass Minerals. We note that the 

PVU project would be pumping 158,000,000 gallons/year. It is over 99% NaCl salt with added 

MgCl2 and anticaking agents. The major salt producers in Utah include Compass Minerals, 

Redmond Minerals, Cargill and Morton. Most of the produced salt comes from the evaporation 

facilities at the Great Salt Lake. In addition, there is a mine in Redmond and a solar operation in 

Moab. 

Wyoming 

The state’s main product used for deicing is a salt/sand mixture. Data from 2014 shows that 

Wyoming used 4,860 tons of salt at $73.98/ton; 1209 gallons of salt brine at $.21/gallon, and 

225,583 gallons of MgCl2 at $.84/gallon (Clear Roads 2015). There are no salt producers in 

Wyoming, although there are salt storage facilities throughout the state. 

Idaho 

Idaho uses salt on its roads for deicing, but does not produce any salt in the state. In 2014, Idaho 

used 104,000 tons of solid salt at $58/ton, 4,409,000 gallons of salt brine at $.07-$.11/gallon, and 

7,798 tons of MgCl2 at $152/ton (1,450,000 gallons at $0.82/gallon)(Clear Roads 2015). 

Nebraska 

Nebraska uses both salt and sand for road deicing. There are no salt producers in Nebraska. The 

only area that is a potential customer for PVU salt is the western part of the state, due to the 

proximity of large amounts of salt available from neighboring Kansas. 

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Kansas 

Kansas is the largest salt producing state in the United States. Kansas is therefore not a likely 

market for PVU salt. Kansas salt has a large presence in Eastern Colorado. 

New Mexico 

There are significant salt producers in the southeast part of the state. In 2012, the State contracted 

for 15,960 tons of salt to be delivered to 86 sites. 

In summary, Colorado and possibly parts of Utah and Wyoming remain the most likely end users 

for PVU salt. The salt would most likely be marketed not directly to the state DOTs, but to one or 

more of the companies or suppliers listed above. Magnesium chloride is probably the most 

valuable product; it is not known at this time, however, how much of a suitable product the PVU 

ponds could produce. 

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9.0 POTENTIAL DIRECT BUYERS 

The salt producers map shown in Figure 2 indicates the locations of production sites. It was 

noted in Section 6 that there are large salt producers in Utah, Kansas and New Mexico. These 

producers typically have satellite distribution facilities strategically located near the places of use 

of their customers. In addition, local distribution companies buy salt from the major producers. If 

PVU salt would provide a lower delivered cost to certain deicing locations, sales could be made 

to these companies. If they can expand market share by utilizing PVU salt, they would likely 

look at that opportunity. 

Amec Foster Wheeler has contacted several direct buyers or producers that have indicated 

interest in obtaining further information about the PVU salt if it is produced. These buyers are 

shown in Table 8. 

Table 8.
 

Direct Buyers and Producers Contacted by Amec Foster Wheeler
 

Company Name Person Contacted Phone Email 

A1 Salt Mark C. Chick 314-428-4804 mark@markchick.com 

Envirotech Jonathan Nelson 720-641-8415 jnelson@envirotechservices.com 

Morton www.emaks.com 312-807-2000 NA 

Nutrecycle LLC Ken McKay 563-370-2970 KEN@nutrecycle.com 

Custom Pool LLC Jack Anderson 618-538-9985 Jack@customizedpools.com 

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10.0 TRANSPORT OF SALT PRODUCTS 

Due to salt’s relatively low production cost, transportation and handling costs tend to be a 

significant component of the total delivered cost making logistics management and customer 

service key competitive factors in the industry. The high relative cost associated with 

transportation tends to favor the supply of salt by producers located nearest to the customers. 

This section addresses those costs, and draws some conclusions about the potential for 

overcoming them based on the ability to provide the product at essentially no production cost to 

the acquiring entity. 

10.1 Harvesting and Loading Considerations for Solid Salt 

Compass Minerals (2014) notes that prices for salt used in highway deicing and consumer and 

industrial products in the U.S. have increased at an historical average of approximately 3% per 

year, although there have been recent fluctuations which have been above and below this 

average. As the crystallizer ponds are expected to be managed in parallel, there will always be 

one of the four ponds that has a sufficient depth of deposited salt to be readily harvested during 

the winter months of each year. Transportation of the salt from the evaporation pond site to any 

point of distribution or storage will involve the use of trucks. Even though the Landfill site is 

adjacent to the Broad Canyon Landfill, the seasonality of harvest makes a conveyor belt system 

less cost-effective than trucking. 

A total of about 137,000 tons of solid salt will be produced each year. When a crystallizer is ready 

for harvest, the salt crop will be between 11 and 12 inches thick. In its undisturbed state, the salt 

bulk density is about 90 lb/ft3. Once disturbed, the bulk density is reduced to about 70 lb/ft3. The 

disturbed bulk density was used when soliciting quotes from trucking companies for the cost of 

moving the salt. 

Bids for road salt are made on an “as delivered” basis. The information obtainable for costs 

therefore includes the delivery charges. From a single supplier to a single client the prices vary 

based on point of delivery. In order to determine in generalities the cost of loading and shipping 

the salt, some assumptions were made. 

Without a special permit, the maximum load for trucks operating on paved roads in Montrose 

County is 85,000 lbs. Use of a truck and pup (a standard dump truck pulling a dump trailer) gives 

the best load hauling potential, with the lightest truck weight. A truck and pup can carry about 25 

tons. Given the proposed salt production rate, approximately 5,480 truck loads per year would be 

required. With a special permit, the maximum gross weight of a load could be increased to about 

110,000 lbs, allowing for a net load of about 35 tons.. This would reduce the number of truck loads 

required to approximately 3,914 trucks per year. 

For local hauls, the assumption is the cost for such hauling would be approximately $0.14 per 

ton-mile (USDA 2014). Table 9 shows the cost per ton to transport the salt from each of the 

proposed pond sites (Amec Foster Wheeler 2016) to the Broad Canyon Landfill or to Reams 80 

Ponds. It also shows the total cost to dispose of 137,000 tons of salt per year at the Broad Canyon 

Landfill or to Reams 80 Ponds, including the transport cost and the receiving cost of $10 per ton 

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(pers. comm. J. E. Stover of Broad Canyon Landfill to Carla Scheidlinger, March 24, 2016; pers. 

comm. Reams July 6, 2016). Other transport costs shown in Table 9 include for delivery to a rail 

siding at Grand Junction, CO using the interstate highway system through Moab, UT, which is a 

distance of approximately 170 miles; and to Glenwood Springs, CO along the same route, a 

distance of about 256 miles. 

Trucking may not be the preferable method of delivery once the material has left the local region. 

Salt can shipped over a greater distance by train, or barges on the major river systems. Barges 

can be eliminated for the purpose of this discussion. There is a cost to transferring salt from a 

truck to a train, however. Salt must be first stockpiled near a train siding, then loaded into cars. 

For the purposes of presenting conceptual costs, this report assumes that these costs would be 

the same on a per ton basis as the cost assumed for loading to the trucks. 

Finally, the cost to harvest the salt, transport it by truck to Grand Junction, load it onto a rail car, 

and ship it to Denver (a rail distance of 273 miles) is also shown in Table 9. 

Table 9.
 

Transport and Disposal Costs for Salt from Three Locations
 

Paradox NW BLM Landfill 

Transport Cost (per ton) to 

Broad Canyon Landfill or 

Reams 80 Ponds 

$5.04 $3.50 $0.28 

Annual Cost to Dispose at 

Broad Canyon Landfill or 

Reams 80 Ponds 

$2,060,480 $1,849,500 $1,408,360 

Transport Cost (per ton) to 

Grand Junction, CO $24.80 $25.92 $29.00 

Annual Transport Cost to 

Grand Junction $3,397,600 $3,551,040 $3,973,000 

Transport Cost (per ton) to 

Glenwood Springs, CO $35.84 $36.96 $40.04 

Annual Transport Cost to 

Glenwood Springs, CO $ 4,910,080 $5,063,520 $5,485,480 

Transport Cost (per ton) to 

Denver, CO $34 $35 $38 

Annual Transport Cost to 

Denver, CO $4,656,630 $4,810,070 $5,232,030 

10.2 Harvesting and Loading Considerations for Bittern (MgCl2 Liquid) 

The bittern is produced from the bittern concentrator by pumping the concentrated liquid from 

the sump that is designed into the bottom of the pond, where it has settled. The fluid is then 

shipped by road, most likely to a facility such as Envirotech that would use it as a raw ingredient 

for their proprietary de-icing products. 

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The trucking costs are assumed to be the same as for solid salts, by the ton. The point of 

delivery, however, would most likely be at Glenwood Springs, CO. Table 10 shows the cost per 

ton, and per gallon, for delivery from each of the potential pond sites, shipped over the same 

route through Moab, UT as was assumed for the solid salt. 

Table 10.
 

Transport Costs for Bittern (MgCl2 Liquid)
 

Location Miles to Glenwood 

Springs, CO Cost/ton ($) Cost/gal ($) Annual Transport Cost 

Landfill 286 $40.04 $0.22 $138,378 

BLM 264 $36.96 $0.20 $127,734 

Paradox NW 256 $35.84 $0.19 $123,863 

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11.0 PRICE OF SALT PRODUCTS 

11.1 Solid Salt for Road Deicing 

State and local governments spend over $2.3 billion to control snow and ice annually. The market 

minimum volume is relatively stable during any given year, as salt contracts often involve an 80% 

delivery acceptance rate, guaranteeing demand from state and local agencies (Balakrishnan 

2015). Spot prices for road de-icing salt are extremely variable from year to year, however, as 

supply and demand are difficult to predict. From the demand side, the timing, intensity, and 

distribution of snowstorm events plays heavily into the need for repeated application of salt to 

roads. Although salt producers can store some amount of salt at their own facilities, they typically 

produce only what they expect to be able to sell. When unexpectedly severe weather is 

widespread, salt prices may increase dramatically in response to underproduction from mines 

and evaporation facilities. As the price of salt is usually presented “as delivered”, the cost of fuel 

can also drive up the delivered price of salt, although the price to the producer would presumably 

remain stable, with the transportation costs driving up the delivered price. 

In 2015, for example, Michigan’s MDOT (MDOT 2015) reported that the winter season average 

cost of road salt for the state and local road agencies was $65.81 per ton delivered, an increase 

of about 46 percent over the 2013-2014 average of $44.99 per ton. This was the result of 

legitimate market conditions caused by that winter’s harsh weather. Road salt suppliers and 

government agencies depleted existing inventories at the end of the previous winter, which was 

one of the harshest on record. Suppliers consequently had less road salt to supply for this season 

while agencies were simultaneously purchasing above-average amounts in order to restock. In 

addition, due to heavy market demand, fewer road-salt suppliers were willing to bid for supply 

contracts. New Mexico contracted for salt in August 2015 for delivery to various points in the state 

through August 2017 for a price per ton ranging from $62 to $132 delivered, underscoring the 

importance of the point of delivery in the determination of price (New Mexico 2015). 

Given that solid salt can be delivered to Denver by truck and rail for under $40/ton, it could be 

that the salt can at least be offered to suppliers for no cost and have that transaction be an 

economical disposal solution for Reclamation. Also given that the cost to transport it for deposit 

at Broad Canyon or Reams 80 Ponds is at least $1 per ton, and possibly as much as $6 per ton 

(plus the $10/cu yd, or $10.58/ton, disposal fee), it could even be in Reclamation’s interest to pay 

a small amount to a supplier to remove and transport the salt. 

11.2 Liquid Bittern Salt 

The liquid bittern, when evaporated to a concentration of 30% MgCl2, could be among the valuable 

products that the project could produce. As discussed in Section 5.2, the amount of concentrated 

MgCl2 that the project would be able to produce is difficult to calculate from the knowledge 

available at this time. The model predicts approximately 643,000 gallons of this material each 

year, which translates to approximately 3,456 tons per year. Envirotech Services sells 250,000­

300,000 tons of MgCl2 each year, much of it in Colorado (pers. comm. with Jonathan Nelson, 

August 8, 2016). The PVU project could therefore supply a small portion of Envirotech’s market. 

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Given the price that Colorado pays for this product as shown in Table 6, the revenue to 

Reclamation could be up to $466,000 per year, taking into account the cost of transport from the 

PVU area to Envirotech at Redmond, UT and assuming that Envirotech would pay PVU 75 

percent the market price shown in Table 6. 

11.3 Sale and Disposal Options 

In order to remove any perception that government funding for this project was allowing for unfair 

competition in the market for salt products, the salt products would be made equally available to 

all interested suppliers for bidding. There are several scenarios in which salt could be disposed 

to suppliers. 

A solid salt or MgCl2 product supplier could offer to purchase raw, unprocessed salt products from 

Reclamation for a price that would be greater than or equal to the cost of transport and storage 

of the salt in the Broad Canyon or Reams 80 Ponds Landfill, or to the cost of handling and longterm storage at on on-site facility. Such a scenario would allow Reclamation to realize annual 

project costs that would be below the projected costs of operation and maintenance by putting 

salt disposal costs into the income column of a balance sheet. 

If there is no opportunity for the sale of salt during any given year, Reclamation could offer the 

salt products to interested suppliers at no cost, thus reducing the need to store or transport the 

salt. This option would also reduce annual operation and maintenance costs by removing 

transport and storage costs from the annual budget. 

A final option would be to offer to pay interested suppliers to remove the salt. If what a supplier 

bid for this service was equal to or lower than the costs to Reclamation for transport, handling, 

and disposal of the salt, Reclamation would also reduce annual operation and maintenance costs. 

As discussed in Section 11.1, the prices and demands for salt products are variable and 

unpredictable. Given the value of the MgCl2 products, some cost recovery from that product is 

likely on a regular basis. For the solid salts, sale and disposal options as discussed here should 

be evaluated on a year-by-year basis. 

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12.0 STORAGE OF SOLID SALT 

If sale of the solid salt is not considered a viable option, or if sales in any year are less than the 

total production volume of salt due to market factors beyond the control of the project, there will 

need to be provision for the storage, either long-term or short-term, of the salt. The salt could 

either be disposed of at an existing landfill site, or it could be stored at an independent facility 

developed in association with the evaporation ponds. If both the landfill and evaporation pond 

facility are operated by Reclamation, it may be possible to operate the landfill as both a landfill 

and temporary storage facility. This stockpile of salt could be available to meet peak salt 

demands. 

12.1 Type of Waste 

12.1.1 Evaporation Ponds 

The evaporation ponds themselves will not be regulated as impoundments. The ponds will be 

regulated by Colorado Department of Public Health and Environment (CDPHE), who 

determined that the salts contained in the ponds would be considered "environmental media”, 

not solid waste. 

The Ponds will require a single liner (compacted clay or synthetic liner) with a percolation rate 

equal to or less than 10-6 cm/s, so no discharge permit would be necessary. 

For pond closure, the liner would need to be removed and disposed of in a landfill; and 

subgrade soils would need to be demonstrated to be clean. 

Finally, the ponds would need to be fenced, for security purposes. 

12.1.2 Naturally Occurring Radioactive Material (NORM) in Solid Salt Products 

In order to get information on radionuclide content of the material, solid salt samples were shipped 

from h-P where the crystals had been created to TestAmerica for analysis. The results 

(TestAmerica 2016; provided as Appendix G) showed that the concentrations in the salt crystals 

are far below average background concentrations found in Colorado for both Uranium and 

Thorium, and that the solid salt would be considered non-hazardous solid waste (Jim Grice, 

Radioactive Materials Unit, CDPHE, pers. comm. via email, August 19, 2016)). This means that 

the material could be disposed of in a permitted landfill. It could also potentially be stored in a 

dedicated storage facility developed associated with the pond site. 

The salt was also tested for Radium by laboratories contracted by Reclamation. Results for 

Radium 226 and Radium 228 were at or below the detection limits for the analysis (United States 

Bureau of Reclamation 2016; also as Appendix H). 

12.2 Methods and Issues for Handling 

The solid halite salt would be harvested from the crystallizers using a loader as described in the 

Pond Operational Strategy report (Amec Foster Wheeler 2016a). It would be stockpiled close to 

the crystallizer pond complex and any remaining brine allowed to drain back into the crystallizers. 

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Any precipitation falling on the stored salt would percolate through it and create a salt brine that 

would be collected to be similarly delivered back to the pond complex. When the salt had been 

sufficiently drained, it would be loaded onto trucks either for sale or for delivery to a disposal area. 

During the time it is stacked, the salt would not produce any fugitive dust. In the extensive 

experience of the consultant, there are no salt evaporation storage sites where fugitive dust is an 

issue. A salt stack quickly forms a crust that wind cannot disturb. If fugitive dust were to be a 

problem, spraying the surface of any new salt with a single application of water would create a 

crust. However, the salt comes to the stack with a moisture content. Evaporation of that moisture 

naturally forms a crust. Once delivered to a storage facility and compacted or distributed, the salt 

can be trafficked over with trucks. A soil cap would not be necessary, either during the time the 

stack awaits loading at the pond or when it is placed in an active on-site storage facility. When 

the storage facility is retired, closure requirements would include re-grading the salt to a condition 

of stable slopes, then capping with an engineered cover of composite liner system with a leak 

detection systems. Leachate would be managed thorough monitoring, collection, and pumping 

back into the ponds. 

As part of the expert panel discussions (CRB 2015), capping and closing a full bittern pond, and 

creating a new bittern pond from time to time was considered. If bittern solids were removed from 

time to time and stored in a contained landfill, a single bittern storage pond could be operated on 

a more continual basis. However, if only a portion of the bittern liquid can be sold, bittern liquid 

will also build up over time and would eventually require long-term management. 

The costs associated with the construction of a dedicated salt disposal facility at the pond site 

location are presented in The Design Strategy report (Amec Foster Wheeler 2016b). The 

economic viability of storing salts on location vs. transporting and disposing of them at a landfill 

would need to be evaluated when the final site selection for a pond series is made. 

12.3 Disposal Sites 

12.3.1 Broad Canyon Landfill 

The most readily available existing option for solid salt storage is in the existing landfill at Broad 

Canyon, in southern Montrose County, CO. This Montrose County landfill is fully permitted, and 

includes a permitted expansion area. CDPHE has indicated that this disposal option has the 

fewest concerns of the disposal options presented (pers. comm. August 24, 2016). Broad Canyon 

Landfill is located approximately 25 miles from the PVU facilities at the Dolores River, and is 

operated by J.E. Stover & Associates. The landfill management has tentatively agreed to receive 

all of the salt waste produced over the proposed 50-year life of the evaporation pond project (J.E. 

Stover, pers. comm.). Their disposal fees are $10/cu yd. The volume of salt to be landfilled is 

approximately 159,000 cu yd. per year. The cost estimate for disposing of all the salt at this facility, 

therefore, is approximately $1.6 million per year in 2016 dollars. This amount includes a solid 

waste user fee payable to the State of Colorado. Disposal of salt into a landfill would also require 

paying for the cost of transportation to the landfill, as shown in Table 8. Since this landfill is in use, 

no road upgrades will be necessary for its use by the PVU project. 

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12.3.2 Reams Construction 80 Ponds Landfill 

The 80 Ponds Landfill is owned by Reams Construction. This facility is located on Hwy. 141, 4.5 

miles southeast of Naturita, Colorado. It is approximately 23 miles from the PVU facilities at the 

Dolores River. The cells that are currently being used are permitted to receive non-hazardous 

oil and gas production and extraction waste consisting of soil and water only. The permitted 

ponds have an HDPE liner. 

Dianna Reams, the owner of Reams Construction, indicates that they have the room to expand, 

and are willing to open an additional cell to receive PVU salt (pers. comm. July 6, 2016). They 

have reviewed the lab results from the salt, and state that $10/cu. yd. would be the cost for 

deposition at their facility. This location would present comparable costs to those at the Broad 

Canyon landfill. Since this landfill is in use, no road upgrades will be necessary for its use by the 

PVU project. 

12.4 Independent Salt Storage Facility Associated with the Ponds 

The nature of the solid salt produced by this project would qualify it as a non-hazardous solid 

waste. A storage facility for the salt would therefore be characterized as a solid waste disposal 

site, with the associated permitting issues. Each of the three sites under consideration for the 

PVU evaporation ponds has the area available for the construction of a storage facility. The issues 

associated with the development of such a facility are reviewed here. 

12.4.1 Permitting Issues 

Anyone operating a facility for solid waste disposal where processing, treatment, or final disposal 

of solid waste is performed must obtain a Certificate of Designation (CD).1,2 In effect, the CD is 

the permit.3 “The Solid Wastes Disposal Sites and Facilities Act (solid waste act) (C.R.S. § 30­

20-100, et seq.) defines a dual-jurisdictional relationship between the department and the local 

governing authority for siting, permitting, and regulating a solid waste site and facility. Roles and 

responsibilities in the solid waste act provide for the department to regulate the design, 

operations, monitoring, closure and post-closure of a solid waste site and facility. Land use 

decisions are left to the local governing authority. The Colorado Department of Public Health and 

Environment (CDPHE) works with the local governing authority to evaluate the proposed solid 

waste site and facility. While the statute does not prohibit a local governing authority from 

conducting its own technical review of the engineering design and operations plan for permitting 

1 Section 9 Waste Impoundments: Permitting, Operation, Monitoring, Closure and Post-Closure Care According to 

the Regulations Pertaining to Solid Waste Sites and Facilities, 6, C.C. R. 1007-2, Part 1 Final Guidance, November 

2014. https://www.colorado.gov/pacific/sites/default/files/HM_sw-sect-9-waste-impoundment-guide.pdf 2 “Certificate of Designation” as used in the regulations means a document issued by the local governing body having 

jurisdiction to a person authorizing the use of land for a solid wastes disposal site and facility pursuant to the Solid 

Wastes Disposal Sites and Facilities Act, Colorado Revised Statutes (C.R.S.) Title 30, Article 20, Parts 1 and 10 

(solid waste act). The “Certificate of Designation,” which incorporates all information as may be required by the 

Colorado Department of Public Health and Environment (CDPHE) and the local governing body having jurisdiction, is 

then issued by the local governing body having jurisdiction if the department’s Hazardous Materials and Waste 

Management Division has determined that the minimum standards have been met. 

https://www.colorado.gov/pacific/sites/default/files/HM_sw-sect-9-waste-impoundment-guide.pdf 3 Section 9 Waste Impoundments, p 8. 

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a solid waste site and facility, most local jurisdictions defer to the department’s expertise for this 

review and determination.”4 

For the purposes of this project, facilities potentially requiring a permit include the evaporation 

ponds, temporary or interim salt storage locations, and ultimate landfill or disposal locations. Table 

11 summarizes the permitting requirements, and indicates which agency is responsible for the 

permits. 

Table 11.
 

Regulation of Salt Storage for PVU Project
 

Phase Regulatory Agency Determination and/or Permitting 

Requirement 

Evaporation Ponds CDPHE Solid Waste Ponds have been determined to be 

“environmental media.” Permit is not 

required. 

CDPHE Water Quality Permit is not required as long as 

there is no expectation that surface 

water will be impacted. Liner design 

is prescriptive: double liner system. 

CDPHE Hazardous Waste Not hazardous 

CDPHE Air Quality TBD 

Temporary or Interim Salt Storage 

Locations 

CDPHE Water Quality Permit is not required as long as 

there is no expectation that surface 

water will be impacted. Liner design 

is prescriptive: double liner system. 

CDPHE Hazardous Waste Not hazardous 

CDPHE Air Quality Could petition for a daily cover 

waiver. Depends on the fugitive dust 

permit. An emissions permit may be 

necessary. Based on salt 

composition, unlikely to be 

necessary. 

Ultimate Landfill or Salt Disposal 

Location 

CDPHE Solid Waste Permit is required 

CDPHE Hazardous Waste Not hazardous 

Given the information in Table 11, permits for the operation of the ponds and of a temporary 

storage facility would not be required, as the material is not hazardous. The presence of Naturally 

Occurring Radioactive Material (NORM) in the salt has been determined to be below the threshold 

of concern (TestAmerica 2016). Temporary storage would be for stockpiling salt for delivery to a 

sale point rather than for holding it for any extended period of time; no permits would be required 

for this storage either. If the project elects to use an existing landfill such as Broad Canyon or 

Reams 80 Ponds, those locations would be permitted separately from the PVU project. 

4 Section 9 Waste Impoundments. 

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Permits would only be required to develop a new landfill or storage facility for ultimate salt disposal 

at the evaporation ponds site. The permitting process is summarized here. 

12.4.2 Application Submission Process 

Prior to beginning the CD/ Engineering Design and Operations Plan (EDOP) application process, 

an organizational meeting should be scheduled with the interested parties and CDPHE. There is 

no charge from CDPHE for this meeting. 

Figure 3 illustrates the sequence of events required for the CD application process for an 

independently developed and operated ultimate disposal facility. The CD application (which is a 

standard form) and EDOP should be completed in accordance with Montrose County Special Use 

Permitting and/or County Engineer. There may be a fee from Montrose County for reviewing the 

application, which will be determined at that time; in the context of the entire project, it would be 

nominal. 

The CD application review and approval process begins with the submittal of an EDOP with a 

minimum of two (2) hard copies and one (1) electronic copy. Montrose County must forward one 

(1) hard copy and one (1) electronic copy of the CD application and EDOP to the CDHPE for 

review along with a request for recommendation of approval or disapproval. 

Submittal of the application by Montrose County to CDPHE begins a Completeness Review which 

may take up to 30 days. At the end of this period they will notify Montrose County in writing of the 

completeness status. Incomplete applications and EDOPs will be returned. Complete CD 

applications and EDOP notifications will be accompanied by a “30 Hour Billable Time Notification 

Waiver/Cease Work Notice” to be signed and returned by the applicant to CDPHE. This finalizes 

this phase of the application and begins a 150-day Technical Review, also conducted by CDPHE. 

At some point toward the end of the Technical Review, Montrose County must provide at least 30 

days for public review and comment of the CD application. A public hearing must be held prior to 

the issuing of the CD. A public notice must be published in local newspapers at least 10 days, but 

no more than 30 days, prior to the hearing. The public notice must also be posted in at least one 

conspicuous location at the offices of Montrose County and in at least one location at the proposed 

site. Notices must be posted at least 30 days prior to the public hearing and continue through the 

day of the hearing. 

If CDPHE is unable to complete the technical review in this timeframe, they may refer it to a 

consultant, which will extend the response time. Montrose County would have the right to decline 

up to two recommended consultants, at which point CDPHE will complete the review as time 

allows. 

It should be anticipated that the permitting process will take at least 6 months (pers. comm. 

CDPHE August 24, 2016). 

Figure 4 below illustrates the process. 

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Figure 4. Flowchart for the Completion of a Certificate of Designation 

Source: Section 9 Waste Impoundments: Permitting, Operation, Monitoring, Closure and Post-Closure Care According to the 

Regulations Pertaining to Solid Waste Sites and Facilities, 6, C.C. R. 1007-2, Part 1 Final Guidance, November 2014. 

https://www.colorado.gov/pacific/sites/default/files/HM_sw-sect-9-waste-impoundment-guide.pdf 

12.4.3 Application Content 

The application consists of eight sections and supporting appendices, tables, and figures. 

Additional content may be submitted. 

• Introduction 

• Location Restrictions 

• Geologic and Hydrogeologic Conditions 

• Design Requirements 

• Operations 

• Closure Plan Requirements 

• Post-Closure Plan Requirements 

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• Final Engineering and Hydrogeologic Approvals 

12.4.4 Financial Assurance 

Owners must provide proof of sufficiency of financial assurance to CDPHE for payment to a third 

party to close the facility and conduct post-closure care, until such time that CDPHE determines 

that proof is no longer necessary.5 Methods for establishing financial assurance are numerous 

and include instruments such as a surety bond, establishment of a trust, letter of credit, insurance, 

and others. An extensive list of options is provided in 6 CCR 1007-2 Part 1, Section 1.8. 

12.4.5 Siting Approval 

In addition to a CD or EDOP, an applicant for a solid waste site and facility will need to go through 

the local land use process to get siting approval. The local land use approval process is 

independent of the Hazardous Materials and Waste Management Division’s review process. The 

local land use process may come prior to, during, or after the Hazardous Materials and Waste 

Management Division’s review.6 It is necessary to determine if more information about this 

process exists. 

12.4.6 Application Fees 

All facilities and solid waste disposal sites are subject to document review fees and activity fees. 

The CD Application and EDOP Review fees are listed in Table 12 below. Additional fees are 

documented in 6 CCR 1007-2 Part 1, Section 1.7.2. 

Fees due at the time of the application submittal include: 

• CD/EDOP application fees 

• Montrose County document review fees (may be applicable) 

12.4.7 Additional Fees 

Additional CDPHE fees that are likely to apply later: 

• Financial Assurance review fees 

• Financial Assurance 5-year review fees 

• Monitoring Reports 

• Closure plan modification fees 

• Post-closure plan modification fees 

5 6 CCR 1007-2, p. 44.
 6 Section 9 Waste Impoundments, p.9.
 

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Table 12. 

Fees Applicable to Solid Waste Disposal Permitting 

Applicable Document Review and Activity Fees Schedule 

Task Fee Ceiling Description 

Certificate of Designation Application $35,000 Accrues at $125/hour. 

Financial Assurance – Annual $3,000 

Fee to review the 

documents. Not submitted 

in with initial application. 

Required annually, and 

adjusted for inflation. 

Financial Assurance – 5 yr $5,000 Paid every 5 years when 

the estimate is revised. 

Monitoring Reports (e.g., groundwater 

landfill gas, remediation) $3,000 Annual monitoring report, $3,000 max 

General Correspondence $500 Usually captured in some 

other category 

Special Requests $10,000 Ad hoc 

Corrective Actions $10,000 If required 

Closure Plan modifications $5,000 If submitted 

Post-closure plan modification fees $5,000 If submitted 

Post-closure fees $1,000 Paid annually for 30 years 

12.4.8 Post-Closure fees 

The facilities would be subject to an unattended surface impoundment post-closure fee of $1,000 

per year, to be paid annually as regulated under Part 9 (Surface Impoundment Facilities) for a 

minimum of thirty (30) years..7 These fees are due to the Treasurer of the State of Colorado for 

the duration of the post-closure care period to reimburse CDPHE for costs incurred in tracking, 

compliance monitoring, compliance assistance, plan review, enforcement, and other recurring 

activities that are reasonable and necessary to ensure compliance with these regulations.8 

12.5 Storage of Bittern Salts 

The storage of bittern salts (mixed salts resulting from the concentration of bittern liquid) would 

be done only if no market was deemed feasible. Bittern solids, as discussed in Section 5.2, would 

be stored either in an existing landfill or in a separately permitted facility, as these mixed salts 

would have no commercial value. The mass of the bittern salts, which are solid salts that 

precipitate out of the bittern as it is concentrating to 30% MgCl, is predicted to be approximately 

8,200 tons per year. This is just the mass of the solid material, however; with entrained fluids, if 

such fluids are not extracted for sale as bitterns, the annual mass would be 11,600 tons (including 

MgCl2 and other bittern solids). The cost of transport and disposal of such salts can be found in 

Table 9. 

7 6 CCR 1007-2 Part 1, Section 3.6.3, p. 88. 8 6 CCR 1007-2, p. 39. 

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12.5.1 Construction Cost Estimates 

Construction costs associated with the development of a dedicated storage facility for salt 

products is considered in the Design Strategy Report (Amec Foster Wheeler 2016b). 

12.5.2 Management of Disposal Facility 

A dedicated storage facility would be managed by a third party, such as a landfill operator who 

would be retained by the project for this purpose. Costs associated with such management are 

beyond the scope of this report. 

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13.0 RECOMMENDATIONS 

Based on the information presented herein, the findings and present recommendations for the 

disposal of the PVU salt are summarized. It is important to recognize that the exact quantity and 

quality of solid salt and bittern products resulting from operation of the evaporation ponds cannot 

be known exactly without the construction and operation of a series of pilot ponds. In addition, 

operational strategies can differ depending on the quality and quantity of any specific salt product 

that is preferred. The calculations summarized in this report represent the best effort of the 

modelers and the authors to present a likely scenario for pond operation and for salt production. 

13.1 Salt products anticipated 

13.1.1 Finding 

The only practical marketable solid salt product that our studies indicate could be produced by 

the proposed PVU evaporation ponds is road de-icing salt. This is because of the high costs for 

producing and handling food grade salt, processed salt, or chlor-alkali salt. There is also the 

potential for the production of bittern MgCl2 as a liquid product. The quantity of marketable bittern 

would be rather low if the solid salt road deicing quality specification is met. If the goal is to produce 

high quality road salt, the brine is moved earlier into the bittern pond. In that case, more salts are 

left in the bittern that will then precipitate in the bittern pond and reduce its value. 

13.1.2 Recommendation 

Amec Foster Wheeler recommends that the evaporation ponds be sized, designed, and operated 

for the production of solid salt of a suitable quality for de-icing use, and of bittern MgCl2 in a 

concentration suitable for road deicing use. The design and operation reports follow this 

recommendation. 

13.2 Marketability 

13.2.1 Finding 

The market for road deicing salt would need to be relatively local, as the cost of transportation is 

the largest factor in determining a price. The states most likely to utilize road salt are Colorado, 

Wyoming, and parts of Utah, as these states and regions use the product, are relatively close to 

the Paradox Valley, and do not have major supplies of salt produced closer in distance than the 

PVU. DOTs purchase salt from suppliers that may or may not be the entities that produce the salt. 

Multiple contracts are awarded each year for salt supply, and bidding is highly competitive. 

Although suppliers will be eager to protect their own markets, there may be markets that can be 

exploited by suppliers using PVU salt, especially during years of unusually high or unpredictable 

demand, since PVU salt will be produced continuously and not in response to market forces. 

Suppliers that we have contacted for both solid salt and liquid bittern products have indicated 

interest, as long as the product produced meets their quality specification. 

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13.2.2 Recommendation 

Reclamation should develop relationships with several road salt suppliers, including those such 

as Cargill, Morton, and Compass that produce salt themselves. Marketing to the producers of 

brand-name de-icing products such as Envirotech could be done as well. Marketing directly to 

state DOTs is not recommended. If the solid salt produced at the PVU can be transported at a 

competitive cost, it could be an attractive commodity. It is not recommended that Reclamation 

charge for the salt, at least initially, but rather make it available to suppliers who can bid for 

removing it at no cost. If markets in the future indicate that the salt could be more valuable than 

anticipated at this time, Reclamation could attempt to partially recoup costs of production by 

marketing the salt to the suppliers at a competitive cost. The same strategy should pertain for 

bittern fluids. If the produced fluids are of sufficient quality and quantity to attract the interest of 

supplier and of the manufacturers of proprietary mixtures, sales could be reasonably anticipated. 

13.3 Storage 

13.3.1 Findings 

As the PVU project will produce salt at a continuous rate, and without regard to market forces or 

prices, it is highly likely that in some years, there will be a need to remove the salt from the 

crystallizer ponds to a storage facility for disposal. That facility could either be an existing site, 

such as the Broad Canyon or Reams 80 Ponds Landfill, or a newly developed solid waste facility 

developed by Reclamation specifically for this project. 

The calculated cost for transportation and payment of fees to the Broad Canyon Landfill or to the 

Reams 80 Ponds facility is shown in Table 9. From all sites except for Landfill, the annual 

projected cost is over $2M per year. Therefore, development and operation of an independent 

storage facility is preferred. The permitting process for such a facility is neither extremely difficult, 

time-consuming, nor relatively expensive. The costs of the construction of a near-site storage 

facility are presented in the Design Strategy report (Amec Foster Wheeler 2016b). Operational 

costs have not been developed for such a facility, but the operation should be done by a third 

party with the appropriate skills and licenses (if applicable). 

Regardless of the ability to sell the marketable salt products, there will be a need to dispose of 

some bittern solids that do not have market value. 

13.3.2 Recommendations 

Unless the pond complex is sited quite close to the existing Broad Canyon Landfill, it is 

recommended that the PVU pursue the development of an independent storage facility adjacent 

to the ponds, and operated for the exclusive use of the brine evaporation project. Costs are being 

developed for the construction and operation of such a facility. Costs are unlikely to exceed the 

$100M+ cost of transporting the solid salt over a 50 year period to the Broad Canyon or Reams 

80 Ponds Landfill. 

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14.0 REFERENCES 

Amec Foster Wheeler. 2016a. Operational Strategies Report. Pond Optimization Study 2. 

Paradox Valley Unit. Report submitted to United States Bureau of Reclamation. 

September 2016. 

Amec Foster Wheeler. 2016b. Pond Design Strategy Report. Pond Optimization Study 2. Paradox 

Valley Unit. Report submitted to United States Bureau of Reclamation. September 2016. 

ASTM D-632. Standard Specification for Sodium Chloride. Copyright © ASTM International, 100 

Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States. 

www.astm.org 

Balakrishnan, A. 2015. “Road salt: Winter's $2.3 billion game changer,” Cary Institute of 

Ecosystem Studies, 20-Feb-2015. [Online]. Available at: 

http://www.caryinstitute.org/newsroom/road-saltwinters-23-billion-game-changer. 

CDOT. 2014. CDOT’s Winter Maintenance Strategy. PowerPoint Presentation prepared by 

Colorado Department of Transportation. January 2014. 

Clear Roads. 2015. Clear Roads 2015 Technical Advisory Committee Spring Meeting: Minutes. 

March 17-19, 2015. Coeur d’Alene, ID 

Consultant Review Board (CRB). 2015. Report from the Consultant Review Board on Paradox 

Valley Unit—Colorado Salinity. March 17-19, 2015. Grand Junction, Colorado. Report 

Submitted to Bureau of Reclamation. July 2015. 

Deseret News. 2014. http://www.deseretnews.com/article/865616406/UDOT-uses-salt-andbrine-solution-to-clear-roads-more-efficiently.html?pg=all 

Michigan Department of Transportation (MDOT). 2015. Road Salt 2014-2015 Winter Season 

Pricing Report. State of Michigan Department of Attorney General. 

NCHRP 25-25(04). 2005. Final Report Environmental Stewardship Practices, Procedures, and 

Policies for Highway Construction and Maintenance v1.0. Updated November 2005. 

Chapter 8. 

New Mexico, State of, General Services Department. 2015. Price Agreement Number 60-805-15­

13305. 

RTI. 2014. Measuring North Carolina Railroad Company’s Impact on North Carolina. A report 

prepared for the North Carolina Railroad Company. September 25, 2014. 

Salt Institute. 2014. Alexandria, VA. Map and Information on website at www.saltinstitute.org 

Sedivy. 2008. Economy of Salt in Chloralkali Manufacture. National Salt Conference 2008, 

Gandhidham 

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TestAmerica. 2016. Analytical Report. TestAmerica Job ID: 160-18103-1. Client Project/Site: PVU 

- Radionuclide Testing. Performed for Amec Foster Wheeler. July 31, 2016. 

United States Bureau of Reclamation. 2016. Paradox Valley Unit Brine Solids Testing for Landfill 

Disposal. Report dated November 22, 2016. 

USDA United States Department of Agriculture Cooperative Extension. Feb 2014. Cost Factors 

in Harvesting and Transporting Woody Biomass. 

http://articles.extension.org/pages/70339/cost-factors-in-harvesting-and-transportingwoody-biomass 

United States Geological Survey (USGS). 2016. Mineral Commodity Summary for Salt. Prepared 

by: Wallace P. Bolen [(703) 648–7727, wbolen@usgs.gov] 

Utah Department of Transportation Project. 2014. Deicer Usage on Concrete and Asphalt 

Pavements in Utah. Report UT-14.02. Prepared for Utah Department of Transportation. 

Prepared by Brigham Young University, Department of Civil and Environmental 

Engineering. 

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APPENDIX A
 

SALT COMPOSITION TABLES
 
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Table A1. 

conditions. 

Analysis of brine after sequential crystal deposition at summer temperature 

Summer Brine Analysis (120oF) 

Spl. No. Identification Ca Ca Mg SO4 K** Na* SG pH % Evap % Evap 

ppm X10 ppm ppm ppm ppm K SO4 

0930316 Initial Brine 1,780 17,800 1,652 6,378 4,846 95,340 1.1725 7.20 

0400416 Brine At Initial NaCl Cryst 1,520 15,200 1,993 6,419 5,523 ---­ 1.1986 7.22 0.12 0.01 

0950316 Brine After 1st Crystals 1,160 11,600 2,855 7,119 7,573 119,020 1.2105 7.21 0.36 0.10 

1060316 Brine After 2nd Crystals 860 8,600 3,852 7,983 10,388 ---­ 1.2131 7.31 0.53 0.20 

1210316 Brine After 3rd Crystals 720 7,200 5,710 10,370 14,188 ---­ 1.2230 7.31 0.66 0.38 

0060416 Brine After 4th Crystals 480 4,800 16,040 26,336 40,810 ---­ 1.2436 7.20 0.88 0.76 

0410416 Final Brine 280 2,800 35,310 52,096 55,850 ---­ 1.2745 6.72 0.91 0.88 

Table A2. Evaluation of crystals produced under summer temperature conditions. 

Summer Salt Analysis (120oF) 

Water Calc Calc 

Spl. No. Identification Insoluble Ca Mg SO4 Na NaCl 

% % % % % % 

0940316 1st Crystals 0.004 0.648 0.049 1.610 38.35 97.59 

1050316 2nd Crystals 0.001 0.210 0.033 0.486 38.97 99.16 

1200316 3rd Crystals 0.001 0.158 0.074 0.481 38.96 99.15 

0050416 4th Crystals < 0.001 0.168 0.180 0.701 38.77 98.65 

0.002 0.296 0.084 0.820 

Table A3. Composition of crystals produced under summer temperature conditions. 

1st Crystals 2nd Crystals 3rd Crystals 4th Crystals 

% % % % 

CaSO4 2.20 0.71 0.54 0.57

 residual SO4 0.06 -0.02 0.10 0.30 

MgSO4 0.07 0.00 0.13 0.37

 residual Mg 0.03 0.05 0.10 

MgCl2 0.14 0.13 0.19 0.41

 Total 2.41 0.84 0.85 1.35 Avg NaCl 

NaCl 97.59 99.16 99.15 98.65 98.63

 Na 38.35 38.97 38.96 38.77 

Tables A4 and A5. Specifications for salt used for deicing compared to laboratory results. 

Deicing chemical specs vs results 

Deicing Salt Size Specs 

Spec Lab Results 

NaCl USS Mesh % Passing db (min) 97.9 98.6 

Ca+Mg (max) 0.7 0.4 3/8 90-100 

SO 4 20-90 4 (max) 0.5 0.8 

Insolubles (max) 0.05 0.002 8 10-60 

Moisture (max) 2.0 ? 30 0-15 

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Paradox Valley Brine Laboratory Data 

NOTE: Data in black are laboratory results. Data in green are calculated from the laboratory results. 

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0 

10,000 

20,000 

30,000 

40,000 

50,000 

60,000 

4,000 14,000 24,000 34,000 44,000 54,000 64,000 

ppm of Ion 

ppm K 

Summer Brine Phase Chemistry-K 

SO4 

Mg 

Ca x 10 

Figure A1. Phase chemistry of PVU brine based on analysis of K during the summer 

evaporation sequence. 

0 

10,000 

20,000 

30,000 

40,000 

50,000 

60,000 

1.1600 1.1800 1.2000 1.2200 1.2400 1.2600 1.2800 

ppm Ion 

SG 

Summer 

Brine Phase Chemistry-SG 

SO4 

Mg 

Ca x 10 

Figure A2. Phase chemistry of PVU brine based on analysis of SG during the summer 

evaporation sequence. 

Page A-2 
 

Table A6. Analysis of brine after sequential crystal deposition at winter temperature 

conditions. 

Winter Brine Analysis (12oF) 

Spl. No. Identification Ca Ca Mg SO4 K** SG pH % Evap 

ppm X10 ppm ppm ppm K 

Initial Brine 1,780 17,800 1,652 6,378 4,846 1.1725 7.20 

0040516 Brine After 1st Crystals 1,120 11200 2,673 6,666 7,333 1.2105 7.16 0.34 

0350516 Brine After 2nd Crystals 840 8400 4,447 9,176 11,898 1.2142 7.26 0.59 

0120616 Brine After 3rd Crystals 520 5200 8,967 15,514 23,960 1.2255 7.35 0.80 

0220616 Brine After 4th Crystals 120 1200 21,311 31,356 53,125 1.2545 7.09 0.91 

 

Winter Salt Analysis (12oF) 

Water Calc 

Spl. No. Identification Insoluble Ca Mg SO4 Na 

% % % % % 

0030516 1st Crystals 0.022 0.720 0.034 1.778 38.27 

0340516 2nd Crystals 0.006 0.320 0.015 0.691 38.85 

0110616 3rd Crystals < 0.001 0.184 0.088 0.568 38.91 

0210616 4th Crystals < 0.001 0.188 0.194 1.144 38.68 

0.014 0.353 0.083 1.045 

Table A8. Composition of crystals produced under winter temperature conditions. 

1st Crystals 2nd Crystals 3rd Crystals 4th Crystals 

% % % % 

CaSO4 2.45 1.09 0.63 0.64

 residual SO4 0.05 0.00 0.13 0.69 

MgSO4 0.06 0.00 0.16 0.87

 residual Mg 0.02 0.02 0.06 0.02 

MgCl2 0.08 0.06 0.22 0.07

 Total 2.62 1.15 1.00 1.58 Avg NaCl 

NaCl 97.38 98.85 99.00 98.42 98.41

 Na 38.27 38.85 38.91 38.68 

Table A9. Specifications for salt used for deicing compared to laboratory results. 

Deicing chemical specs vs results 

Spec Lab Results 

NaCldb (min) 97.9 98.4 

Ca+Mg (max) 0.7 0.4 

SO4 (max) 0.5 1.0 

Insolubles (max) 0.05 0.014 

Moisture (max) 2.0 ? 

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Table A7. Evaluation of crystals produced under winter temperature conditions. 

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0 

5,000 

10,000 

15,000 

20,000 

25,000 

30,000 

35,000 

4,000 24,000 44,000 64,000 

ppm of Ion 

ppm K 

Winter Brine Phase Chemistry-K 

SO4 

Mg 

Ca x 10 

Figure A3. Phase chemistry of PVU brine based on analysis of K during the winter 

evaporation sequence. 

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APPENDIX B
 

SALT CRYSTAL PHOTOGRAPHS
 
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Figure B-1 

First Crystals 

Figure B-2 

Second Crystals 

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Figure B-3 

Winter Crystals 

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APPENDIX C
 

BULK DE-ICING SPECIFICATION
 
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PARADOX VALLEY
 

BUREAU OF RECLAMATION
 

DRAFT SPECIFICATION
 

Bulk Deicing Salt 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DESCRIPTION:
 

Bulk Deicing Salt is a coarse screened, 

white crystalline sodium chloride, produced 

by solar evaporation of brine. The salt crystals 

are drained of excess moisture and screened 

to size. 

Component Typical 

Sodium Chloride (dry basis)1 97.9% 

Calcium & Magnesium (as Ca) 0.7% 

Sulfate (as SO4) 0.5% 

Water Insolubles .05% 

Surface Moisture 0.2.0% 

Yellow Prussiate of Soda2 As needed 

COMPLIANCE: 

Bulk Deicing Salt is not approved for human or 

animal consumption. It is intended for use only as 

a chemical deicer on roadways and 

thoroughfares. This salt complies fully with ASTM 

specifications. 

ADDITIVES: 

Bulk Deicing Salt may contain yellow prussiate 

of soda, which is added to improve caking 

resistance. 

APPLICATIONS: 

Bulk Deicing Salt is intended for use as an ice 

and snow removal agent on highways and other 

roadways. 

PACKAGING AND SHIPPING: 

Bulk Deicing Salt is available only in bulk form. 

METHODS OF ANALYSIS: 

EXPECTED CHEMICAL ANALYSIS: 1

By difference of impurities 

2

Sodium ferrocyanide decahydrate 

EXPECTED SIEVE ANALYSIS: 

USS 

Mesh 

Opening 

Inches 

Typical 

% 

Specification 

3/8” 0.375 93 90-100 

4 0.187 67 20-90 

8 0.0937 30 10-60 

30 0.0232 0.5 0-15 

BULK DENSITY:
 

Parameter Typical Specification 

Pounds per cubic 

foot 

75 71-79 

Methods of analysis and product performance evaluation are taken from the ASTM 

designations D 632 and E 534. 

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APPENDIX D
 

USE OF SALT PRODUCTION MODEL
 
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Appendix D to Byproducts Report
 

Use of the Salt Model
 

I. Introduction 

This information is presented to assist in the use and interpretation of the salt model that was 

developed by John Chesnut of Amec Foster Wheeler for the PVU Evaporation Pond Optimization 

project. The model itself is provided as a spreadsheet in an Excel file (MinVerse Model PVU) that 

can be used to explore various options regarding the design and operation of the evaporation 

ponds. The parameters of the model are described here, with instructions on how user-controlled 

parameters can be varied to produce different results depending on the desired salt outcome. 

The discussion is aimed at the relatively sophisticated user of Excel. Minimal effort has been 

made to simplify the discussion; it should be used by individuals familiar with Excel functions. 

A screenshot view of the first tab of the spreadsheet, “Model”, is shown in Figure D1. Selected 

portions of that page are referred to in the discussion below. 

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Figure D1. Salt model running the “Cl at Pyles” scenario. 

(Green Cells are user adjustable) Yellow Cells are calculated and should not be touched 

Scenario lookup 

Scenario CL at Pyles conversion to PPT 3 

Flow 300 GPM > 596,884 Cubic Meter/year 2 

Sp gr 1.1725 Units > 699,846 Metric Tons 

K 0.004846 g/L > 0.004133049 ppT 

Mg 0.001652 g/L > 0.001408955 ppT 

Cl 0.13970381 g/L > 0.119150371 ppT 

Reference ET 63.0 inch per annum 

Rain 16.0 inch per annum Concentration factor 

Sp Gr at Sat 1.1986 Units > 0.132839004 CL 

K at Sat 0.005523 g/L > 0.004607876 ppT 1.114885357 K -

Sp GR at Bit 1.261 Units 

Intermediate 1168.15 mm Concentrator ppm Total Evap Mass 

Tons Conc Evap Salt Cramer Rule Solution Hectare Acres 

Concentrator Mass 699,846 1 0.45803 1 627,729 Metric Mass 

Evap Factor 0.74 K 2,892 0.0046 0 0 157,451 Sq Meters 15.75 38.89 72,117 

Evap in mm 458 mm Cl 83,387 0.1328 0 0.6067 - Metric Ton 

Evap in Inches 18.0326 inch Mg 986.05 - Entrain 

Main Stage 

Main Stage Tons Conc Evap Salt Cramer Rule Solution 

Evap factor 0.66 Mass 627,729 1 0.36458 1 78,835 Metric Mass 

Evap in mm 365 mm K 2,892.50 0.0367 0 0 1,164,571 Sq Meters 116.46 287.65 424,575 

Cl 83,386.9 0.1010 0 0.6067 124,319 Metric Ton 

31,079.86 Entrain Mass 

-

Residual check 

Bittern Tons Conc Evap Salt Cramer Rule Solution 

Evap Factor 0.55 Mass 47,755 1 0.23608 1 29,698 Metric Mass 

Evap in mm 236 mm K 1,752.16 0.05900 0 0 59,406 Sq Meters 5.94 14.67 

Cl 4,823.27 0.08003 0 0.6067 4,033 Metric Ton 

1,008.20 Entrain 

Bittern by Mass 

Sg At Main 1.261 

Bittern mass 47,755.15 

Bittern Volume 37,884.21 

bittern Evap 0.2360803 160,471.70 Sq Meters 16.05 39.64 

Acrefeet bittern 30.71 

Summary Concentrator 39 Acre 

Crystallizer 288 Acre 

Footprint 327 Acre 

Halite Metric Ton 124,319 Halite Metric Ton 

US TON 1.10231 137,039 Halite Tons 

Halite Efficiency 432 Tons/Area 

Bittern Wet Mass 47,755.15 Metric ton 

Area at Steady state Evap 39.64 acres 

Restore default 

Run selected 

scenario 

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January 2017 

II. Design of the model. 

The concentrator and crystallizer stages are solved by a system of three simultaneous equations 

in the form: 

Mass = Brine Mass – (Evaporation Mass + Salt Mass) 

The three equations solve for total mass, chloride (Cl) mass and Potassium (K) mass 

simultaneously. No provision is made for leakage, as it was assumed that ponds will be 

competently lined. 

The segment solutions are provided using the Excel Formula 

=INDEX(MMULT(MINVERSE(Variable Matrix), Mass Matrix),"index number") 

The formula calculates the inverse matrix of a variables array (3x3) using the MINVERSE function. 

The inverse matrix is solved using the MMULT – matrix product function. The solution is stored in 

a 1x3 array. The two inputs are the Mass Matrix and the inverse of the Variable matrix. The index 

function (1,2,3) calls the individual solution values of the each element of the MMULT solution 

array. 

The solution appears in the following form (Figure D2) on the spreadsheet. 

Figure D2. Solution for salt produced from PVU brine 

Tons Conc Evap Salt Cramer Rule Solution 

Mass 47,755 1 0.23608 1 29,698 Metric Mass 

K 1,752.16 0.05900 0 0 59,406 Sq Meters 

Cl 4,823.27 0.08003 0 0.6067 4,033 Metric Ton 

Mass is calculated in metric tons, and can be converted to US tons using the conversion tables 

provided in the Constants tab of the spreadsheet. The variable array uses % values for 

ConcentrationMeter values (or % of a cubic meter) for evaporation, and % values for the 

constituent parts of the salt mass. The solution is presented in Metric tons, sq meters of surface 

area, and metric tons of salt formed. 

Entrainment Mass is factored from a default 25% mass of the salt mass formed. The Entrainment 

mass factor is found on the "Constants" tab, and could be adjusted. 

The solution is provided as input to the next matrix element, and entrainment mass is subtracted. 

III. Use of the model 

Only green cells in the model are user adjustable. All other cells are dependents on the green cell 

parameters --- DO NOT TOUCH OR MODIFY yellow cells. These are not protected in the design 

of the model. Entering values in yellow cells will BREAK THE MODEL, and the spreadsheet must 

be restored from a saved copy. For this reason, it is recommended that an unmodified version of 

the model be saved and that any versions that may be modified be saved with a new name. 

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Figure D3. Scenario selection tabs in the salt model 

Restore default 

Run selected 

scenario 

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Final Combined Findings and Recommendation Report 

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The Cramer rule solutions are live formulas, and any change in the green cells will update all 

solution values. Several "canned" alternative parameters are provided in the control form list (box 

on the right of Figure D3 below). These alternatives must be loaded by pressing the "Run Selected 

scenario" button. The button overwrites any user changes to green cells. The "Restore default" 

simply rewrites the default scenario, and restores the model to the default solution. 

The model does not make a "sense" check on altered parameters. Therefore, entering values that 

are out of scale (such as bittern Specific Gravity (SG) showing as less than crystallizer SG) will 

cause irrational answers. Restoring the default parameters will bring the model back to "sense". 

The Scenario tab stores the "canned solutions" accessed through the control form. “Spare” 

columns are provided for users to edit and save their own adjustments, and may be named so 

that they can be identified in the future. 

The Chemistry tab provides the model with SG (Sp Gr) and bittern concentration through a simple 

linear trend calculation of the K and Sp Gr data. The tab stores data from the hoPak results (and 

other analysis), but is only accessed for the SG and concentration of K data. 

The Constants tab is accessed for the Entrainment Fraction parameter, default value is 25% by 

mass. The evaporation factor for Class A Pan to open pond conversion, default value 0.73 is also 

stored on this page. Other values are presented for reference. 

The Rain tab stores a sequence of ET and Rain data for Co Ag Met stations, and the synthetic 22 

year series that was created by combining Olathe and YellowJacket station data. A button on the 

Rain tab calls a macro that steps through the ET and Rain values and writes the results to the 

"Results Tab" 

The Results tab writes the acreage solutions for concentrators, crystallizers, and bittern ponds 

from the Macro called on the Rain tab. It writes results based on the scenario (or user 

adjustments) made on the Model. If unedited adjustments are left on the Model, the results of 

calling the Rain macro will vary. 

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IV. Parameters of the PVU salt pond model 

Parameters used for the model developed specifically for the PVU project are described below. 

The parameter list as it appears in the spreadsheet model is shown as Figure D4. 

Flow: Average flow is shown in gallons per minute (GPM), and is used to calculate volume and 

mass delivered on a 24 hours per day/7 days per week/365 days per year basis. No provision 

was made for downtime, but a modified flow rate would change the total volume delivered in line 

with expected downtime. 

Specific Gravity (Sp Gr) of well brine. This parameter is used to calculate the total mass of 

solids from volume, and the ion concentration in parts per thousand (ppt) from concentrations 

reported in mg/L of K, Mg, Cl – (Potassium, Magnesium, Chloride). These concentrations are 

those that were reported by brine chemical analysis which were assumed to be in mg/L units. 

Chloride, which was not present in the 2016 hohPak analysis, is calculated separately from a 

forced cation-anion molar balance, and added back in. 

ET and Rain. These parameters are expressed in inches per year (as per Colorado Agricultural 

Meteorology - Co Ag Met data). Default values represent the 1st quartile measure of a synthetic 

22 data series based on Olathe and Yellow Jacket weather stations. A more thorough discussion 

of ET, Rain, and the synthetic model is described in a separate memo which is included as 

Appendix E. The PVU model has a macro that steps through the available annual data to provide 

a range of annual solutions. 

Saturation Sp. Gr. This parameter is used to calculate ppt concentration of the tracer Potassium 

(K) at saturation based on its reported value in g/L. This in turn determines the default 

concentration factor, which is the relative volume change of the saturated brine as it evaporates. 

Since the concentration factor is the product of two variables with some uncertainty, the error in 

the factor is the product of the variable errors. The default value (1.1986) is from the hohPak 

summer series. Alternatively, a PHREEQC simulation reports a higher value (1.207) when halite 

saturation index reaches 0. 

K at Saturation. This parameter is the K concentration (g/L) reported at halite saturation. The 

default value (0.004846) is the concentration reported by the summer hohPak series. 

Alternatively, a PHREEQC simulation reports a higher value (0.006013496) when halite saturation 

index reaches 0. 

Sp Gr at Bittern. Bittern point was selected for production of maximum halite purity as determined 

from consultant John Pyles’s professional experience. Bittern point is used to provide a K 

concentration based on a simple linear regression of Sp Gr to K in the hohPak data series. 

Page D-5 
 

 

Figure D4. Parameter list, with default values, in the salt model 

Scenario 

Flow 

Sp gr 

K 

Mg 

Cl 

Reference ET 

Rain 

Sp Gr at Sat 

K at Sat 

Sp GR at Bit 

CL at Pyles conversion to PPT 

300 GPM > 596,884 Cubic Meter/year 

1.1725 Units > 699,846 Metric Tons 

0.004846 g/L > 0.004133049 ppT 

0.001652 g/L > 0.001408955 ppT 

0.13970381 g/L > 0.119150371 ppT 

63.0 inch per annum 

16.0 inch per annum 

1.1986 Units 

0.005523 g/L > 0.004607876 ppT 

1.261 Units 

 

 

 

 

 

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Evaporation factors relative to fresh water 

The model provides three evaporation factors for brine (Figure D5). Evaporation follows the 

formula 

Inches = [(ET*Pan-to-Pond Factor*Concentration Factor) – Rain] 

For this reason, the effect of rain, especially on higher gravity brines, is very important. Rainfall is 

highly variable annually, and this factor may require adjustment in order to manage brines 

effectively for the desired product. 

The Pan-to-Pond factor default value is 0.73 and is taken from reference for western Colorado. 

(NOAA technical report TR33, Farnsworth, R.K., E.S. Thompson, and E.L. Peck (1982). 

"Evaporation Atlas for the Contiguous 48 United States," NOAA Technical Report NWS 33, 

Washington, D.C.) This value is affected by site elevation (due to the effect of partial pressure) 

and ambient humidity. 

The default concentrator factor is the midpoint of the Well Brine (0.72) and the Saturated Brine 

(0.76) factors recorded in the continuing pan tests undertaken at Bedrock. It is assumed that a 

serpentine concentrator pathway produced by a concentrator pond constructed with a baffle will 

perform, on average, at the mean value. 

The crystallizer evaporation value reflects the same logic: use of a midpoint performance value 

(0.66) of Saturated and Bittern brines. 

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January 2017 

Bittern evaporation is calculated with a 0.55 factor relative to fresh water. High magnesium bittern 

are hydroscopic and absorb water from the atmosphere. It is not anticipated that the pond bitterns 

are at magnesium saturation when released from the crystallizer, or drained from stockpiled salt. 

Figure D5. Evaporation rates used at different stages of the pond sequence 

Concentrator 

Evap Factor 0.74 

Evap in mm 458 mm 

Evap in Inches 18.0326 inch 

Main Stage 

Evap factor 0.66 

Evap in mm 365 mm 

Bittern 

Evap Factor 0.55 

Evap in mm 236 mm 

Concentration factor for ions 

Three factors of concentration are user adjustable (Figure D6). 

1) Chloride concentration on exit of the crystallizers. 

2) Residual potassium 

3) Residual chloride 

The residual mass check are values that check for “sense” in the bittern point, which is set to 

maximize purity of the halite stage, and avoid halite contamination in the magnesium bittern. The 

values are based on concentration breakpoints set by John Pyles, converted to ppt values, as no 

laboratory produced check analysis is available in the hoh-Pak data, and no data on chloride has 

been developed. 

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Figure D6. Concentration factors in the salt model 

Main Stage 

Tons Conc 

Mass 627,729 1 

K 2,892.50 0.0367 

Cl 83,386.9 0.1010 

Residual check 

Tons Conc 

Mass 47,755 1 

K 1,752.16 0.05900 

Cl 4,823.27 0.08003 

V. Changing parameters and changing results 

As the user alters any of the parameters described, the final results will change. This can be 

useful if the final end products are to be modified. For example, if the production of Mg bittern is 

desired, changing the Sp Gr for bittern as in Figure 3 will produce different solutions for 

management of the crystallizers. If a colder, warmer, wetter, or drier year is predicted, modifying 

the climate data as in Figure D4 will produce different results for management of the brine to 

obtain the desired result. 

Page D-8 
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APPENDIX E
 

ESTIMATION OF EVAPORATION AND PRECIPITATION
 
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Appendix E
 

Estimation of Evaporation and Precipitation 

Design area of a solar pond series is dependent on rate of evaporation and precipitation falling 

on the operating ponds. Evaporation and especially precipitation are variable year-over-year. A 

pond system should be designed to accommodate this uncertainty and variability. Other sources 

of uncertain estimates include the interaction of evaporation rate and brine density, small changes 

in input brine density, and arbitrary bittern points. 

Evaporation, precipitation and weather data has been collected at the Paradox site beginning in 

May 2015. A CoAgMet weather station has been in operation at Bedrock (site brk01) since late 

2013. A network of CoAgMet stations with long-term weather data operates regionally, with online 

databank beginning in 1993. The information is available at: http://ccc.atmos.colostate.edu/cgibin/stationsum_form.pl 

The data series can be cross-correlated to extend the expected evaporation performance of the 

PVU solar ponds, and estimate inter-annual variation in rates. The local PVU evaporation pan 

and precipitation data series are virtually equivalent to the CoAgMet Bedrock data series (Figures 

E1 and E2). The ET calculated using the 1982 Kimberly-Penman equation matches the PVU 

Class A pan series more precisely in the 2016 season than the alternative ASCE Standardized 

reference evapotranspiration (also reported) for unanalyzed reasons. This close agreement 

between these two independent data series give strong confidence that the larger CoAgMet data 

set can be used to describe PVU evaporation and precipitation performance. 

Weather data collected at nearby network sites since 1993 can be used to estimate the climatic 

variance at the Paradox site. The nearby "Olathe 1" site shows strong resemblance to the 2014­

16 CoAgMet Bedrock series for evaporation (Table E1). Mean annual Reference ET at Olathe 1 

over the 22 years of data collection (some data missing, and values interpolated) is 61.28 inches 

(St Dev = 2.19 inches). Equivalent 2014-2015 values for Bedrock station are 61.18 and 60.34. 

Linear correlation (using the 2 available data points indicate that RFET at Bedrock = 1.044* 

Olathe. The Olathe site is semi-irrigated and the Bedrock station is dryland, so the overage at 

Bedrock in respect to Olathe can be anticipated. In summary, a synthetic Bedrock data series can 

be developed by taking using 104% of the Olathe measure. 

Table E1. Olathe and Bedrock ET Data 

Reference ET Total Inches 

Olathe Bedrock 

2014 60.03 61.18 

2015 55.73 60.34 

22 year Mean 61.28 (est) 63.7 

The low standard deviation in the Olathe dataset indicates that on an inter-annual basis the 

variation in Reference ET is minor. ET is inversely correlated with precipitation; wet, rainy years 

have lower evaporation. 

Precipitation data has much higher variance. Precipitation accumulation is highly idiosyncratic to 

sites; that is, correlation between yearly and monthly data among the nearby CoAgMet network 

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sites is relatively low. Variation between yearly cumulative totals across the long-term data 

collection sequence is also high. 

The effective pond evaporation is determined by 

[ReferenceET * Pan-to-Pond factor * Brine Concentration factor] – Precipitation 

Consequently, high variation in precipitation (and season of the precipitation) affects the pond 

performance strongly. Additionally, as the brine concentration factor falls from an anticipated 0.75 

to 0.55 across the pond series, the relative impact of precipitation variance increases dramatically. 

Comparison of 2014-6 Bedrock precipitation data to long-term medians and same year 

comparisons of other CoAgMet sites shows Bedrock has higher base precipitation in the 2014-15 

sequence. Empirically, in 2014-5, Bedrock cumulative precipitation was 110% of the same-year 

YellowJacket data. 

Rescaling the long-term median at Yellow Jacket to this empirical correction yields a model 

Bedrock median cumulative precipitation of 13.2 inches. Inter-annual standard deviation in the 

YellowJacket data is 2.8 inches. 

A synthetic data series based on the simple linear corrections to Olathe ET and Yellow Jacket 

precipitation was constructed and tested against default conditions in the design spreadsheet 

(Figure E5). The results show that the default design based on 2015 empirical data is highly 

conservative – 2015 Reference ET was slightly reduced, and precipitation was likely significantly 

higher than normal. 

Scaled 22 year median values for ET are 63.5 inches with 12.7 inches of rain. Sizing design 

elements against the 22-year median values reduces crystallizer acreage from 345 to 240 acres 

using the spreadsheet's otherwise default parameters. Using the 1st quartile values (63.2 inches, 

15.8 inches) generates a 327 acre crystallizer, and 62 acre concentrator. 

Several factors buffer design requirements: 1) Wet years are typically followed by normal or dry 

years, allowing a pond system to catch up with evaporation. 2) A surge pond design provides 

extra concentrator area that can be used to bring a slowly evaporating brine to saturation. 3) The 

bittern point is chosen to maximize quality over quantity of the halite deposit, so extra brine can 

be released to the bittern pond to form a low quality halite-bittern mixed deposit. 

Page E-2 
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Amec Foster Wheeler Project No. 1655500023 

January 2017 

Figure E1: 2015 Precipitation Data for PVU and Bedrock CoAgMet 

CoAgMet vs. BOR Rain data 

0 

2 

4 

6 

8 

10 

12 

14 

16 

18 

5/1/15 6/1/15 7/1/15 8/1/15 9/1/15 

10/1/1511/1/15 12/1/15 

1/1/16 2/1/16 3/1/16 4/1/16 5/1/16 6/1/16 

Date 

B O R Gu a ge 

C o AgM e t Gu a ge 

Figure E2: 2014-6 Reference ET and PVU Class A evaporation data series 

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Figure E3: Cumulative precipitation Bedrock and long-term (22 year) median values 

Cumulative Precipitation: long term median 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Month 

Bedrock 2015 

Othlanthe 

Dove 

YellowJacket 

Figure E4: Model Cumulative precipitation (based on 1.10 correction of Yellow Jacket
 

CoAgMet median).
 

Scaled Model Precipitation 

0 

200 

400 

600 

800 

1000 

1200 

1400 

1600 

1800 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Month 

Bedrock 2014 

Bedrock 2015 

Model Correction 

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January 2017 

Figure E5: Design element sizing for a "model" annual ET and Precipitation. Note Net ET 

is defined as Reference ET – Precipitation (used only to scale axis). 

Design vs. Ag Met Weather data 

0 

50 

100 

150 

200 

250 

300 

350 

400 

450 

40.0 42.0 44.0 46.0 48.0 50.0 52.0 54.0 56.0 58.0 60.0 

Net Annual ET (inches) 

Crystalizer Design 

Concentrator Design 

Model Concentrator 

Model crystalizer 

Bedrock CoAgMet 

Bedrock CoAgMet Conc 

Median 

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Page E-6 
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APPENDIX F
 

ION MASS DELIVERED TO BITTERN STAGE
 
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APPENDIX G
 

RADIONUCLIDE TESTING REPORT
 
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January 2017 

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ANALYTICAL REPORT 

TestAmerica Laboratories, Inc. 

TestAmerica St. Louis 

13715 Rider Trail North 

Earth City, MO 63045 

Tel: (314)298-8566 

TestAmerica Job ID: 160-18103-1 

Client Project/Site: PVU - Radionuclide Testing 

For: 

AMEC Foster Wheeler E & I, Inc 

9210 Sky Park Court 

Suite 100 

San Diego, California 92123 

Attn: Carla Scheidlinger 

Authorized for release by: 

7/31/2016 6:16:21 PM 

Elizabeth Hoerchler, Project Mgmt. Assistant 

(314)298-8566 

elizabeth.hoerchler@testamericainc.com 

is report has been electronically signed and authorized by the signatory. Electronic signature is 

ended to be the legally binding equivalent of a traditionally handwritten signature. 

esults relate only to the items tested and the sample(s) as received by the laboratory. 
Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1 

Project/Site: PVU - Radionuclide Testing 

Table of Contents
 

Cover Page . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
 

Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
 2
 

Case Narrative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
 3
 

Chain of Custody . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
 

Receipt Checklists . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
 

Definitions/Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
 7
 

Method Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
 

Sample Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
 

Client Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
 

QC Sample Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
 

QC Association Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
 

Tracer Carrier Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
 

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TestAmerica St. Louis 

Page 2 of 13 7/31/2016 
Case Narrative

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Job ID: 160-18103-1

Laboratory: TestAmerica St. Louis

Narrative

CASE NARRATIVE

Client: AMEC Foster Wheeler E & I, Inc

Project: PVU - Radionuclide Testing

Report Number: 160-18103-1

With the exceptions noted as flags or footnotes, standard analytical protocols were followed in the analysis of the samples and no 

problems were encountered or anomalies observed. In addition all laboratory quality control samples were within established control 

limits, with any exceptions noted below. Each sample was analyzed to achieve the lowest possible reporting limit within the constraints of 

the method. In some cases, due to interference or analytes present at high concentrations, samples were diluted. For diluted samples, 

the reporting limits are adjusted relative to the dilution required.

TestAmerica St. Louis attests to the validity of the laboratory data generated by TestAmerica facilities reported herein. All analyses 

performed by TestAmerica facilities were done using established laboratory SOPs that incorporate QA/QC procedures described in the 

application methods. TestAmerica’s operations groups have reviewed the data for compliance with the laboratory QA/QC plan, and data 

have been found to be compliant with laboratory protocols unless otherwise noted below.

The test results in this report meet all NELAP requirements for parameters for which accreditation is required or available. Any exceptions 

to NELAP requirements are noted in this report. Pursuant to NELAP, this report may not be reproduced, except in full, without the written 

approval of the laboratory.

Calculations are performed before rounding to avoid round-off errors in calculated results.

All holding times were met and proper preservation noted for the methods performed on these samples, unless otherwise detailed in the 

individual sections below.

All solid sample results for Chemistry analyses are reported on an "as received" basis unless otherwise indicated by the presence of a % 

solids value in the method header. All soil/sediment sample results for radiochemistry analyses are based upon sample as dried and 

disaggregated with the exception of tritium, carbon-14, and iodine-129 by gamma spectroscopy unless requested as wet weight by the 

client.

This laboratory report is confidential and is intended for the sole use of TestAmerica and its client.

RECEIPT

The samples were received on 07/08/2016; the samples arrived in good condition, properly preserved. The temperature of the coolers at 

receipt was 21.0° C.

ISOTOPIC THORIUM (ALPHA SPECTROMETRY)

Sample PVU-SALT-20160701 (160-18103-1) was analyzed for Isotopic Thorium (Alpha Spectrometry) in accordance with DOE. The 

samples were prepared on 07/19/2016 and analyzed on 07/28/2016. 

The following sample in batch 160-261169 consists of a salt matrix and is non homogeneous: PVU-SALT-20160701 (160-18103-1).

No additional analytical or quality issues were noted, other than those described above or in the Definitions/Glossary page.

ISOTOPIC URANIUM (ALPHA SPECTROMETRY)

Sample PVU-SALT-20160701 (160-18103-1) was analyzed for Isotopic Uranium (Alpha Spectrometry) in accordance with DOE A01R_U. 

The samples were prepared on 07/19/2016 and analyzed on 07/27/2016.

TestAmerica St. Louis

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Page 3 of 13 7/31/2016 
Case Narrative

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Job ID: 160-18103-1 (Continued)

Laboratory: TestAmerica St. Louis (Continued)

The following sample in batch 160-261171 consists of a salt matrix and is non homogeneous: PVU-SALT-20160701 (160-18103-1).

No analytical or quality issues were noted, other than those described above or in the Definitions/Glossary page. Page 4 of 13 TestAmerica St. Louis 7/31/2016 

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Page 5 of 13 7/31/2016 
Login Sample Receipt Checklist

Client: AMEC Foster Wheeler E & I, Inc Job Number: 160-18103-1

Login Number: 18103

Question Answer Comment

Creator: Clarke, Jill C

List Source: TestAmerica St. Louis

List Number: 1

Radioactivity wasn't checked or is </= background as measured by a survey True

meter.

The cooler's custody seal, if present, is intact. N/A

Sample custody seals, if present, are intact. N/A

The cooler or samples do not appear to have been compromised or True

tampered with.

Samples were received on ice. True

Cooler Temperature is acceptable. True

Cooler Temperature is recorded. True

COC is present. True

COC is filled out in ink and legible. True

COC is filled out with all pertinent information. True

Is the Field Sampler's name present on COC? True

There are no discrepancies between the containers received and the COC. True

Samples are received within Holding Time (excluding tests with immediate True

HTs)

Sample containers have legible labels. True

Containers are not broken or leaking. True

Sample collection date/times are provided. True

Appropriate sample containers are used. True

Sample bottles are completely filled. True

Sample Preservation Verified. True

There is sufficient vol. for all requested analyses, incl. any requested True

MS/MSDs

Containers requiring zero headspace have no headspace or bubble is N/A

<6mm (1/4").

Multiphasic samples are not present. True

Samples do not require splitting or compositing. True

Residual Chlorine Checked. N/A

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Page 6 of 13 7/31/2016 
Definitions/Glossary

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Qualifiers

Rad

Qualifier Description

U Result is less than the sample detection limit.

Qualifier

Glossary

These commonly used abbreviations may or may not be present in this report.

¤ Listed under the "D" column to designate that the result is reported on a dry weight basis

Abbreviation

%R Percent Recovery

CFL Contains Free Liquid

CNF Contains no Free Liquid

DER Duplicate error ratio (normalized absolute difference)

Dil Fac Dilution Factor

DL, RA, RE, IN Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample

DLC Decision level concentration

MDA Minimum detectable activity

EDL Estimated Detection Limit

MDC Minimum detectable concentration

MDL Method Detection Limit

ML Minimum Level (Dioxin)

NC Not Calculated

ND Not detected at the reporting limit (or MDL or EDL if shown)

PQL Practical Quantitation Limit

QC Quality Control

RER Relative error ratio

RL Reporting Limit or Requested Limit (Radiochemistry)

RPD Relative Percent Difference, a measure of the relative difference between two points

TEF Toxicity Equivalent Factor (Dioxin)

TEQ Toxicity Equivalent Quotient (Dioxin)

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Method Summary

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Method Method Description Protocol Laboratory

A-01-R Isotopic Thorium (Alpha Spectrometry) DOE TAL SL

A-01-R Isotopic Uranium (Alpha Spectrometry) DOE TAL SL

Protocol References:

DOE = U.S. Department of Energy

Laboratory References:

TAL SL = TestAmerica St. Louis, 13715 Rider Trail North, Earth City, MO 63045, TEL (314)298-8566

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Sample Summary

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Lab Sample ID Client Sample ID Matrix Collected Received

160-18103-1 PVU-SALT-20160701 Solid 07/01/16 12:00 07/08/16 13:00

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Client Sample Results

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Client Sample ID: PVU-SALT-20160701 Lab Sample ID: 160-18103-1

Date Collected: 07/01/16 12:00 Matrix: Solid

Date Received: 07/08/16 13:00

Method: A-01-R - Isotopic Thorium (Alpha Spectrometry)

Analyte

Thorium-228 0.0561 U

(2σ+/-)

0.0603

(2σ+/-)

1.00 0.0932 pCi/g 07/19/16 13:35 07/28/16 10:17 1

RL MDC

0.0601

Result Qualifier Unit Prepared Analyzed Dil Fac

Count Total

Uncert. Uncert.

Thorium-230 0.0653 0.0494 0.0497 1.00 0.0483 pCi/g 07/19/16 13:35 07/28/16 10:17 1

Thorium-232 U0.0150 0.0247 0.0247 1.00 0.0416 pCi/g 07/19/16 13:35 07/28/16 10:17 1

Thorium-229 30 - 110

Tracer

07/19/16 13:35 07/28/16 10:17 1

%Yield Qualifier Limits Prepared Analyzed Dil Fac

83.2

Method: A-01-R - Isotopic Uranium (Alpha Spectrometry)

Analyte

Uranium-233/234 0.738

(2σ+/-)

0.234

(2σ+/-)

1.00 0.0967 pCi/g 07/19/16 13:35 07/27/16 13:57 1

RL MDC

0.226

Result Qualifier Unit Prepared Analyzed Dil Fac

Count Total

Uncert. Uncert.

Uranium-235/236 U0.0211 0.0423 0.0423 1.00 0.0634 pCi/g 07/19/16 13:35 07/27/16 13:57 1

Uranium-238 0.217 0.122 0.124 1.00 0.0772 pCi/g 07/19/16 13:35 07/27/16 13:57 1

Uranium-232 30 - 110

Tracer

07/19/16 13:35 07/27/16 13:57 1

%Yield Qualifier Limits Prepared Analyzed Dil Fac

57.4

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Page 10 of 13 7/31/2016 
QC Sample Results

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Method: A-01-R - Isotopic Thorium (Alpha Spectrometry)

Lab Sample ID: MB 160-261169/1-A Client Sample ID: Method Blank

Matrix: Solid Prep Type: Total/NA

Analysis Batch: 262493 Prep Batch: 261169

Thorium-228

Analyte

U 0.110 pCi/g 07/19/16 13:35 07/28/16 10:171

MDC

1.00

RL

0.0803 0.0808

(2σ+/-) (2

σ+/-)

MB

0.1019

MB

Result Qualifier Unit Prepared Analyzed Dil Fac

Uncert.

Count

Uncert.

Total

Thorium-230 0.1489 0.0781 0.0790 1.00 0.0485 pCi/g 07/19/16 13:35 07/28/16 10:171

Thorium-232 0.02989U 0.0345 0.0346 1.00 0.0299 pCi/g 07/19/16 13:35 07/28/16 10:171

Tracer

Thorium-229 30

- 110 07/19/16 13:35 07/28/16 10:17 1

%Yield Qualifier Limits Prepared Analyzed Dil Fac

76.6

MB MB

Lab Sample ID: LCS 160-261169/2-A Client Sample ID: Lab Control Sample

Matrix: Solid Prep Type: Total/NA

Analysis Batch: 262494 Prep Batch: 261169

Thorium-230

Analyte

24.5 26.88 2.62 1.00 0.0797 81110

- 118

(2σ+/-) RL MDC

LCS LCS

pCi/g

Added Result Qual Unit %Rec

Spike

Limits

Uncert. %Rec.

Total

Thorium-229

Tracer

30

- 110

LCS

%Yield Qualifier Limits

85.7

LCS

Method: A-01-R - Isotopic Uranium (Alpha Spectrometry)

Lab Sample ID: MB 160-261171/1-A Client Sample ID: Method Blank

Matrix: Solid Prep Type: Total/NA

Analysis Batch: 262304 Prep Batch: 261171

Uranium-233/234

Analyte

U 0.112 pCi/g 07/19/16 13:35 07/27/16 13:571

MDC

1.00

RL

0.0391 0.0391

(2σ+/-) (2σ+/-)

MB

0.004573

MB

Result Qualifier Unit Prepared Analyzed Dil Fac

Uncert.

Count

Uncert.

Total

Uranium-235/236 -0.004268U 0.00854 0.00854 1.00 0.104 pCi/g 07/19/16 13:35 07/27/16 13:571

Uranium-238 0.06959U 0.0733 0.0736 1.00 0.0831 pCi/g 07/19/16 13:35 07/27/16 13:571

Tracer

Uranium-232 30

- 110 07/19/16 13:35 07/27/16 13:57 1

%Yield Qualifier Limits Prepared Analyzed Dil Fac

55.5

MB MB

Lab Sample ID: LCS 160-261171/2-A Client Sample ID: Lab Control Sample

Matrix: Solid Prep Type: Total/NA

Analysis Batch: 262305 Prep Batch: 261171

Uranium-233/23 4

Analyte

6.37 5.934 0.738 1.00 0.0710 8493

- 120

(2σ+/-) RL MDC

LCS LCS

pCi/g

Added Result Qual Unit %Rec

Spike

Limits

Uncert. %Rec.

Total

Uranium-238 6.51 6.188 0.761 1.00 0.0567 pCi/g 95 82

- 122

Uranium-232

Tracer

30

- 110

LCS

%Yield Qualifier Limits

82.2

LCS

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QC Association Summary

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Rad

Prep Batch: 261169

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batc

160-18103-1 PVU-SALT-20160701 Total/NA Solid ExtChrom

MB 160-261169/1-A Method Blank Total/NA Solid ExtChrom

LCS 160-261169/2-A Lab Control Sample Total/NA Solid ExtChrom

Prep Batch: 261171

Lab Sample ID Client Sample ID Prep Type Matrix Method Prep Batc

160-18103-1 PVU-SALT-20160701 Total/NA Solid ExtChrom

MB 160-261171/1-A Method Blank Total/NA Solid ExtChrom

LCS 160-261171/2-A Lab Control Sample Total/NA Solid ExtChrom

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Page 12 of 13 7/31/2016 
Tracer/Carrier Summary

Client: AMEC Foster Wheeler E & I, Inc TestAmerica Job ID: 160-18103-1

Project/Site: PVU - Radionuclide Testing

Method: A-01-R - Isotopic Thorium (Alpha Spectrometry)

Matrix: Solid Prep Type: Total/NA

Lab Sample ID Client Sample ID (30-110)

Th-229

160-18103-1 83.2

Percent Yield (Acceptance Limits)

PVU-SALT-20160701

LCS 160-261169/2-A Lab Control Sample 85.7

MB 160-261169/1-A Method Blank 76.6

Tracer/Carrier Legend

Th-229 = Thorium-229

Method: A-01-R - Isotopic Uranium (Alpha Spectrometry)

Matrix: Solid Prep Type: Total/NA

Lab Sample ID Client Sample ID (30-110)

U-232

160-18103-1 57.4

Percent Yield (Acceptance Limits)

PVU-SALT-20160701

LCS 160-261171/2-A Lab Control Sample 82.2

MB 160-261171/1-A Method Blank 55.5

Tracer/Carrier Legend

U-232 = Uranium-232

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Wastren Advantage, Inc. 

Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

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Wastren Advantage, Inc. 

Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

APPENDIX H
 

BRINE SOLIDS TESTING FOR LANDFILL DISPOSAL
 
Wastren Advantage, Inc. 

Final Combined Findings and Recommendation Report 

Paradox Valley Unit Byproducts Disposal Study 

Amec Foster Wheeler Project No. 1655500023 

January 2017 

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U.S. Department of the Interior 

Bureau of Reclamation 

 

Paradox Valley Unit 

Brine Solids Testing for Landfill Disposal 

November 22, 2016 

In May 2016 brine from the U.S. Bureau of Reclamation’s (Reclamation) Paradox Valley Unit 

was tested in a small-scale crystallizer by Saltworks in Vancouver, BC. A sample of the solids 

(11% moisture content) was sent to the Reclamation Technical Service Center in June 2016. At 

the request of Reclamation’s Western Colorado Area Office, samples were sent to Huffman 

Laboratories, Inc. in Golden, CO, for analysis in September 2016. Solids samples were analyzed 

by Huffman Laboratories, Inc. for thorium and uranium. Solids samples were analyzed by Hazen 

Research, Inc. for radium. Results are shown below. 

Thorium and Uranium (Huffman Lab No. 171216) 

Lab 

Huffman Labs 

4630 Indiana St 

Golden CO 80403 

303-278-4455 

chemistry@huffmanlabs.com 

Instrumentation 

Perkin Elmer NexIon 300D ICP-MS. Th232 and U235 as U238 masses. Detection limits were 

0.01 ug/L for both Th and U in clean sample matrices. Terbium was utilized as the internal 

standard. 

Standard Operating Procedures 

HHL SOP ICPMS-01 Rev#2, HHL QA-01 Rev#2 

Sample Preparation 

Samples were digested in triplicate at nominal 100, 200, and 300 mg sample to a final weight of 

200 g after a nitric, perchloric, hydrofluoric, and boric acid digestion (propriety digestion 

method). 

Results 

Thorium Uranium
 

(μg/g) (μg/g)
 

<0.1 <0.1 
U.S. Depart

Bureau of R

ment of the Interior 

eclamation 

Radium (Hazen Project No. 12081)