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. ~, JUN-19-1959 ST 09 ROTHGERSER JOHNSON°LYONS _i07 53(3 5252 F.23 • • As we have already observed, it is impossible for as indeprndent evaluator to presently prepare a more thorough critique. For example, while the EPA is prepazed to allow the reiajectian of 'boiler blow down,' the hazardous tnaterials to be used in the boiler (as described on DLIS Table 2-5) are identified merely as "corrosion inhibitor." scale inhibitor," and "oxygen scavenger." One would have to guess not only at what the substances aze, but also how they would interact with the other substances that may be employed in the injection fluid wader various temperattues. Similarly, the water quality information which appeazs on Table 2-4 of the DEIS lists only four select sodium compounds, without disclosing measurements of the specific components of the wmpounds, ar arty other elements or substances that are mobilized by American Soda's solution mining process. (The utility of Table 2-~ is further limited by the f'aa that the information is presented in an aggregated summary) American Soda is employing a process designed to leach sodium compounds out of rock, and such a proves: will ttnavaidably mobilize other substances along with the sodium compounds. Further, there is no dispute that changing trmperanrre and pressure pazameters will affect both the effectiveness of sodium recovery, sad the range of substances that are mobilized. Table 2-4 of the DEIS discloses neither the details of subsiaarrs mobilized by cturent pilot project operdtioas, nor the range of substances that tray be mobilized by the full scale Facility if it is operated at difFerent tetrtperatures and pressures. However, under the draft UIC permit, almost any solutiom which comes out of the ground or is used in processing may be reinjected- 'Ibis is a subject which deserves more thoughtful treatment than the dismissal offered ro the DMG by American Soda. Nor is it persuasive to claim that some other agenry will take rtre of the problem. Consider the EPA. The central premise of the Statement of Basis for the draft UIC permit ~ that the Amuicaa Soda injection wells will be drilled through the Lower sad Upper Aquifers into a stratum which is not itself an aquifer, so that iF the integrity of the injection wells can he assured, there can be ao risk of harm to the aquifers. The DMG'e Second Adequacy Letter gives General Chemical considerable comfort that the DMG already appreciates some of the ways in which this approach may be catastrophically flawed. The key point here is that if the EPA is wrong, the proposed parfanrtance band is a mere 568,400, i.e., EPA's estimate of the cost to plug and abandon each solution mining well. Drawing the larger picture together, then, American Soda would ]rave DMG ignore the risks to aquifers for which there is adtuittedly inadequate baseline data, on the throry that a bond of $68,400 is a sufficient fallback in the event that the EPA's regulatory approach fails. Note that actual failure may be for reasons such as subsidence or fracturing which cony be unrelated to the adequacy of the EPA's own regulatory wnstraints, and that the authorized injections can make it impossible to ever know what the baseline was. General Chemical submits that this result should be unacceptable to the DMG. Each state and federal agency has its own role to play, and no agenry 6hould he persruded to refrain from asserting its authority oa the premise that informal reliance on another agenry will assure an undefined yet acceptable regulatory climate. President Harry Truman had a sign on his desk which read, "The buck stops here." Americas Sada is both uplicitly sad implicitly urging the DMG to accept the notion that the environmental buck stops somewhere else. Neither the draft Environmental Impact Statement