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6_~t_~ggg ~:rjap~•1 FR01 GIHON ASSOCIATES 3D3 436 93~ P;g '~ ,~IHON -EFFERT ~,,:. A \F.ti~S AT L.it4' Mr. Chuck Williams Page 8 June 21, 1999 vi. EPA requested that BLM identify pollutants of concern. The DEIS does not provide this information. There are no specifics in the DEIS regarding chemicals to be used or characteristics of mining solution to be injected, piped, and stored in ponds. vii. EPA indicated that a Corrective Action and Monitoring Plan should he developed for the project and summarized in the DEIS. Instead, the DE1S indicates that a well failure response plan is currently under development (page 4-16) artd that a pipeline spill plan will be developed before operations (page 4-I i2). Furthermore, the DEIS indicates that spills of hazardous materials would be cleaned up, but neither provides a specific plan nor identifies hazardous materials to be used or handled. Page 2-23 refers to "site protection plans" for emergency situations, indicating they are yet to be developed. . viii. EPA reyuested a description of how the site will be reclaimed during and after mining, including the differences between initial and post mining conditions. 7'he DEIS includes some discussion of reclamation at pages 2-24 to 2-29, and Appendix A is a very brief executive summary of the Reclamation Plan, apparently from the Commercial Mine Plan. However, the DE]S says simply that American Soda will reclaim based on BLM's mitigation measures and Conditions of Approval for the Project. This device precludes public consideration and comment. We understand that the Colorado Department of Mines and Geology is responsible for issuing a Reclamation Permit. We also recognize that BLM has its own reclamation requirements. Regardless of federal and state jurisdiction, reclamation is very much within the scope of issues that must be addressed by EPA in an EIS for a federal mining project. ix. EPA asked that BLM focus on ground water protection and UlC permits, linking the effects of the proposed process to the discharge limits, mixing zones, wel[ rcqu'vetttcnts, etc., required through various state and federal permits. The DEIS does not respond to this request. The DEIS includes no data from test wells, no analysis of potential impacts on ground water from injection wells (except a cursory discussion at page 4.14), no detailed discussion of the impacts of injecting hot water under pressure into the ground, no detailed discussion of the likelihood and effects of subsidence, and no well failure response plan. x. EPA requested that the effects of water withdrawals from streams during mining be evaluated and disclosed. The DEIS says (page 4.12) that removal of water could contribute to depletion in the river system, but contradicts itself'on the next 8