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<br />the Per-mittee will be required to plug and abandon we1120-1 (identified as a possible source of <br />inter-aquifer communication) prior to commercial operations. Work is currently being done, and <br />will continue to be done, by the applicant to address this issue. Under the provisions ofthe <br />permit, all new Bound-water and surface water data collected as outlined in the Water <br />Monitoring Plan will be submitted to EPA on a quarterly basis. These data will be reviewed, and <br />a comprehensive review by Regional staff will also be performed on a priority basis before <br />commencement of commercial operation. These data (Bound water and surface water) will also <br />be available for public review in thr Regional Office, If the new baseline data show that the <br />previous data were not valid, EPA has the authority to modify or revoke this Permit as necessary <br />to protect USDWs. <br />With regards to the concerns relating to the location of USDWs at the site, EPA believes <br />that the data submitted aze representative of site conditions near the monitoring wells in question. <br />Additionally, EPA has adopted the standard hydrologic terminology of the area that includes the <br />Uinta and A-Groove in the Upper aquifer and the B-Groove and Dissolution Surface in the Lower <br />aquifer. The Upper and the Lower aquifer systems are sepazated by the Mahogany Zone. It <br />should be noted that the Water Monitoring Plan establishes monitoring points in the Unita (CJpper <br />Aquifer), the A-Groove (Upper Aquifer), the B-Groove (Lower Aquifer) and the Dissolution <br />Surface (Lower Aquifer). <br />After a review of all comments and the information in the Permit application, EPA <br />has determined that these data are adequate for the purpose of establishing conditions for <br />the Permit. As mentioned previously, EPA's permit action does not imply that the water <br />quality of the initial area to be mined is representative of the water quality elsewhere in the <br />basin. Additionally the construction, operating and monitoring requirements are designed <br />to prevent migration of fluids out of the injection zone into any aquifers regardless of their <br />quality. They are also designed to detect any migration that may occur. <br />Comment 5: Ground-water baseline data are required for EPA to issue a Permit. <br />The following nine (9) pazaphrased comments discussed the issue relating to the need for a <br />ground-water baseline prior to issuance of the Permit: <br />1. Without Bound water baseline data, it is simply impossible for EPA to comply with it's <br />obligations under the SDWA or NEPA. The monitoring plan calls for monitoring to determine <br />baseline data; the data will not be available until a year after all public comment has closed. <br />2. (Page 6 SOB) The Statement of Basis and Draft Permit require only two seasons of <br />monitoring to establish a baseline for the two springs near the project area. This is not sufficient <br />to chazacterize the full range of flow regimes for the two springs. At least one baseline sampling <br />should be conducted in each season, winter, spring, summer and fall. Operations will be year- <br />round and the baseline and future sampling should be conducted at ]east quarterly at these springs <br />to ensure that degradation or alterations in spring activity will be discernable at first occurrence. <br />13 <br />