HYDRO22446 - Laserfiche WebLink

Home Browse Search

1. t,; ~. c~/q ~u a ySy~~ . Moog Y•'J ~S~„ t'• (~Sb.Xnt ~ri5 Mr r~~~ `C Nl~l~ti+++s •• MICHAEL C. IRELAND, P.C. •• Attorney at law 225 North Mill Street, Suite2Qf 2~3 Aspen, Colorado 8161 I ! ~ r Telephone: 7B3 925.5358 ~ ~ !~ Facsimile: 381925-9220 { ~ (? 990 tl!i June 7, 1999 Mr. Dan Jackson III IIIIIIIIIIIIIIII 999 r. I I ~ 199 ~~ ~ ~.' Er'A itEGIGN VII1. Mr. Chuck Williams (SP_W_GW) I (J~ /~ ~ US Environmental Protection Agency ~~/c liL1NL~ • ,li (~ ,l /t- ~ 999 18a' Street, Suite 500 Denver CO 80202-2466 Re: Draft UIC Permit and Statement of Basis, Yankee Gulch Project Dear Messrs. Williams and Jackson: I am in receipt of the above referenced Drafi UIC Permit documents and am writing to express concern about both the procedures utilized in issuing them and their substantive content. First and foremost, I am disappointed that the defects in the water quality data discussed by myself and Mr. Jackson in April appear to have been glossed over in issuing the draft permit and statement of basis. It appears that the EPA has accepted without further review the applicant's representation that the Lower Aquifer does not meet USDW standards in spite of some rather anomalous data points offered by the applicant and in spite of contrary evidence brought to my attention. I am also disappointed that I was not sent a copy of the Statement of Basis and Draft UIC Permit as promised during my discussion with Mr. Jackson. I ordered a copy though the BLM but would have appreciated receiving the documents as promised without the time and expense of requesting them. Of much greater concern is the selective, unsupported embrace of anomalous data points as characteristic of the llpper and Lower Aquifer. The Statement of Basis and Draft Permit describe the Upper Aquifer as follows: oThe data indicates that USDWs are probably confined to the Uinta portion of the Upper Aquifer. TDS concentrations indicate that TDS increases dramatically with the depth of the Green River Formation (Parachute Creek Member) portion of the Upper Aquifer, with the water sample from 811 feet, immediately above the Mahogany Zone, yielding a concentration of 15,900 mg/I. Lower Aquifer. TDS concentrations ranging from 38,000 mg/I to 60,000 mg/1 have been reported in the Lower Aquifer. A water sample taken from the Lower part of the Lower Aquifer at the American Soda monitoring well 20-I in June 1997 exhibited a TDS concentration of 61,6000 mg/I at a depth of approximately 1,400 ft near the dissolution surface **** There have been some questions regarding the construction of this well and