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• •6-2i-1999 7:06PM FROf,~IHON ASSOCIATES 303 436 93~ p_ I3 <br />GIHON <br />EFFERT <br />rr. <br />~a ~tiEYS AT LAIS <br />Mr. Chuck Williams <br />Page 12 <br />June 21, 1999 <br />The Subsidence Monitoring Plan submitted by American Soda in April 1999, after <br />the close of the comment period on the DEIS, does little, if anything to ~conect the inadequacies <br />of the initial Subsidence Plan. The Subsidence Monitoring Plan proposes monitoring surface <br />subsidence in roughly the same manner as the Subsidence Plan did, i.e., annually checking the <br />elevation of monuments. Again, if measurable subsidence may not be evident for 30 to 100 <br />years, a significant amount of subsidence could occur before being detected. The Subsidence <br />Monitoring Plan also proposes subsurface monitoring using time domain reflectometry ("TDR") <br />and borehole geophysics. American Soda, however, acknowledges that TDR may not be an <br />adequate means of monitoring subsurface movement. See Subsidence Monitoring Plan at 3 {Apr, <br />l5, 1999) {'elf TDR does not prove to be an adequate means of monitoring subsurface movement, <br />other instrumentation techniques will be evaluated."). Furthermore, it is unclear whether <br />borehole geophysics or TDR will provide sufficient information regarding cavity integrity to <br />ensure no subsidence occurs. <br />D. Water Monitoring Plans. <br />The DEIS contains so little baseline data that any new data is per se significant. The <br />more extensive ground water monitoring plan proposed by American Soda will yield much mote <br />accurate information about the baseline ground water conditions than did its review of stale <br />literature and its samples from three wells for the DEIS. The proposed plan is the minimum <br />necessary to determine whether there arc underground sources of drinking water in the area of <br />review and whether they may be degraded by the injection activities. These are questions EPA <br />must answer before it can fulfils its permitting obligations under the Safe Drinking Water Act <br />(see discussion below). <br />E. The Well Failure Rcsoonse Plan and the Pinelint Soill Plan. <br />The DEIS indicated that American Soda must complete a Well Failure Response Plan <br />and a Pipeline Spill Plan in order to attempt to mitigate potential environmental impacts from <br />the project. See DEIS at 4-16, 4-112. To date, these plans have not been made available to the <br />public. Any mitigation requirements are likely to affect significantly the environmental impacts <br />of the proposed project. The public should be given an opportunity to evaluate and comment on <br />any mitigation efforts proposed by American Soda. <br />Finally, it is nor acceptable to wait to make a decision about supplementing the E1S <br />until the results of the monitoring plan are known. By then, American Soda will have invested <br />millions of dollars in the project; it is unfair both to American Soda and to the public, and illegal <br />under NEPA, to allow this investment bcforr the environmental itnpacts of the project can be <br />assessed. The investment will create almost irresistible pressure to allow the project to go forward <br />and forego further environmental analyses. <br />12 <br />