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~ ~ c for EPA to require American Soda to identify all potential chemical constituents that could enter each fluid stream and provide EPA with Material Safety Data Sheets for each chemical that has any hazardous characteristics. EPA can then require appropriate testing where fluids may contain hazardous wastes and such fluids are incorporated into the injection fluid, or it can eliminate a fluid stream that it believes poses too much of a potential hazard. Wholesale authorization to use the ten fluid streams without sufficient data might lead to unacceptable injection of hazardous wastes into the ground beneath the site and this should not be permitted to occur. Page 22: EPA is currently requiring monthly water level monitoring of groundwater monitoring wells. I believe this creates a major management problem for the Agency, for the water resources, and for American :Soda. The key issue of concern that it might be a month before potential drilling or mining impacts could be detected. The water level data appears to be the most sensitive parameter available for determining whether drilling and mining operations may have an adverse impact on G~otential USDW sources. This is the fundamental purpose of the UIC permit, but in this instance, one of the most sensitive parameters is n~~t being given sufficient attention. A continuous water level monitoring s~~stem is not an unreasonable expense for the value gained in this instance, and I strongly suggest that EPA consider requiring such a monitoring system on all monitoring wells. I am attaching a copy of an analysis of sodium bicarbonate concentrations in three different monitoring wells (monitoring data submitted by American Soda to BLM and obtained under a FOIA). It shows that during well drilling and test operations, sodium bicarbonate concentrations in the three wells (in USDW quality aquifers, see attached water quality data) varied in general conjunction with one another. Please note the following conclusions regarding these dz~ta: • Well 20-5 shows a rise in bicarb level from about: 1,600 ppm on i1-2-97 to over 6,000 ppm on 4-29-98. It then drops to around 2,500 ppm on 8-29-98 and then back up to 4,000 ppm on 11-22- 98. \ Well 20-8 shows a rise in bicarb levels from 10-02-97 to 9-21-98. After 9-21-98 the bicarb value jumps to over 3,000 ppm ' The above two wells are in the lower part of the lJinta Formation which is a U. S. Drinking Water Aquifer. • Well 20-8 is a water supply well. • The alluvial well, 21-2, tracks the other two wells. Based on the data in the attached graph, it appears that something is occurring in these aquifers, and a reasonable presumption is that this "something" in the test mining operations cause these impacts since no 4