Thanks for posting that link
It does appear that these permits are for more than just operation. They are also required for construction but, as you say, not all construction. There is a fairly extensive list of pollutants and thresholds. If it is likely the thing you are constructing will exceed one of these thresholds then you do need the permit. I suspect they could drill the freeze wells. These are 4 inch wells. Wells like this get drilled all the time all over Nebraska without permits. I don't see how these wells would produce significant pollutants. The next step would be chillers and piping it all together. That really should not produce significant pollutants. I think the big question is what drives the chillers. If it is electric motors and they can get enough electricity to the site then they should be able to start freezing. If it is big diesel engines that might be a different story. I suspect shaft sinking (and hauling all the material removed) and the surface processing facilities will go way over those thresholds.If (and a big IF) they could get freezing stared that sure wold help the schedule. I also suspect Scot Honan has considered all of this, knows the answer to all these questions, and has a big schedule up on the wall of his office detailing each step.
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