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6-21 -1999 7 ~ C~3Ptd ~ GiHON -EFFERT rr. A SECS AT LAu FROt 1CG I HON ASSOCIATES 303 436 93 P. 8 Mr. Chuck Williams Page 7 June 21,1999 EPA requested a statistically sound number of samples addressing; background data on ground water, geology, surface water and riparian areas. The DEIS (at pages 3-12 to 3-21 and Table 3.5,1) relies on insufficient U.S.G.~~. surface water data from one year for the project area within the Piceance Creels Basin ("Piceance") and U.S. Corps of Engineers information for the project area near Parachute, Colorado. The ground water data for the Piceance area is taken from twenty-year-old literature, There is no ground water quality date for the Parachute Site. Page 4-17 suggests only general outlines of ground water baseline monitoring to be conducted in the future after the project is approved, but does not include details. ii. EPA requested maps identifying water sampling points/wells. The DEIS provides little such information. Instead, Figure 2-10 shows the location of 10 proposed monitoring wells to be drilled after the project is approved, The DEIS says at page 4.17 that more wells and a baseline data gathering effort are needed, but no such plan is specificapy proposed. Furthermore, there is no map included of these baseline monitoring wells. iii. EPA requested that BLM consider a sufficient number of wells attd locations to monitor the effects of the project on ground water in all relevant aquifers, as well as an analysis of the existing data to identify data gaps and anomalies that will . require additional data to resolve. At page 4-17, the current platy indicates 10 monitoring wells. Mote wells are needed in order to address EPf'~ s concern. iv. EPA indicated that the analytical detection limits used in collecting data should be compared to water quality standards and criteria to assure that detection limits are low enough to fully evaluate standards compliance and biological effects. EPA also asked for adequate levels of precision and accuracy (QA/QC:). There is no information in the DEIS on [hese subjects, v. EPA asked that $LM analyze water hardness (mg/I, CaC03) and the seasonal range of these water quality values, especially for aquatic lifc..Tb~ere is no _ information addressing this because there is no recent baseline monitoring data present in the DEIS. The monitoring program (page 2-21) covers ground water only, and does not mcnrion hardness and seasonality as parameters. Furthermore, the DEIS (at page 4-17) concludes that the current monitoring plan u insufficient and must be augmented before operations can begin.