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<br />unmined rock remaining above the mining zone as the primary confining unit below the base of <br />the Lower Aquifer. Fluids will not be injected directly into any aquifer system, whether it is a <br />USDW or not. <br />As mentioned above, EPA has determined that the construction and monitoring <br />requirements required by the Area Permit are adequate to assure protection of USDWs and has <br />determined that the Draft Permit can be issued, with appropriate modifications. Ii should be <br />noted that even when the Area Permit becomes effective, only the initia126 cavities specifically <br />mentioned in the Permit may be constructed under the initial authorization. This number does not <br />include the existing test cavities which are also covered by this Permit. Prior to construction of <br />any additional new cavities, the operator must submit a request for approval of these new wells <br />and provide information on their location and their proposed completion plan under the provisions <br />of 40 CFR 144.33. The EPA will review the proposed construction details, the information <br />obtained from the drilling of the other nearby wells and the results of the on-going monitoring <br />results before issuing authority to construct. As the project expands, the monitoring plan will also <br />be reviewed and the monitoring requirements will be modified as warranted. <br />After reviewing all comments, EPA believes that the construction and monitoring <br />requirements laid out in the Permit are adequate to assure protection of USDWs as <br />mandated by the SDWA and the UIC regulations. Therefore, EPA is proceeding with the <br />action and no changes were made to the Permit in response to these comments. <br />Comment 4: The around-water data submitted by the applicant are not valid. <br />The following three (3) paraphrased comments discussed the issues relating to the validity <br />of the ground-water quality data submitted by the applicant. <br />1. There was a letter from American Soda to Rio Blanco County (3/8/99). In this letter American <br />Soda addresses concerns over ground water quality in the Piceance Creek Basin. EPA must <br />investigate the validity of claims made in the letter before it can issue the Permit. <br />2. These baseline data are defective, inadequate, anomalous, and inappropriate, and continue to <br />appear in official documents in reviewing this project. <br />3. (Page 6 SOB) The Draft document states: "Data indicates there are most hkely no USDW's <br />below the base of the Uinta (approximately 675 feet from the surface) at the site of this lease." I <br />believe that inaccurate or misleading information may have been provided to the EPA regarding <br />water quality in the Lower Aquifer. As I have learned over the past several months of monitoring <br />this project, water quality in the Lower Aquifer varies substantially at the project location, and the <br />Lower Aquifer should really be considered as two aquifers (A-Groove and B-Groove), not a <br />single aquifer. <br />11 <br />