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<br /> <br />3. )n light of the lack of baseline data on water quality and the existence of USDWS, it is in the <br />public interest upon inadequate assessment of the environmental impacts for EPA to consider <br />approving an Area Permit for a smaller area or to require American Soda to obtain a Permit for <br />each well. {See pg. 10 of DSOB). {This issue is also addressed in the response to comment 3.) <br />4. The SDWA requires that EPA prevent degradation of USDWS. However, in this case, because <br />of the lack of baseline water quality data, EPA cannot even identify with certainty which ground <br />water in the area qualifies as a USDW. Unless EPA knows where USDWs aze and what the <br />quality of water in those USDWS is, it cannot predict or control the impact of underground <br />injection on USDWs. <br />5. There are so little baseline data that any new information is significant. The more extensive <br />ground-water monitoring plan proposed by American Soda will yield more accurate information <br />about the baseline ground-water conditions than did its review of state literature and its samples <br />from three wells for the BLM's DEIS. The proposed plan is the minimum necessary to determine <br />whether there are USDWs in the area of review and whether they may be degraded by the <br />injection activities. These aze questions EPA must answer before it can fulfill its Permitting <br />delegation under the SDWA <br />6. EPA cannot issue a UIC Permit to protect drinking water unless it obtains valid, accurate, pre- <br />projectbaseline data. <br />7. EPA's proposal to issue a Permit and then requue the gathering of baseline data is backwards <br />and begs the question: why is EPA in such a hurry to issue this Permit? (This comment is also <br />addressed in comment 1.) <br />8. How does the EPA propose to protect USDWs when baseline data has not yet been collected? <br />Which agency(s) is(aze) responsible for determining the status of USDWs? <br />9. Define the local baseline water quality (both surface and ground water) prior to issuing a UIC <br />Perntit. <br />Response: As mentioned previously, neither the SDWA nor the UIC regulations themselves <br />stipulate the exact nature or areal extent of the geologic, hydroiogic and engineering data that <br />must be submitted as a prerequisite to the issuance of an area or individual well Permit. The <br />regulations do require the submittal of sufficient information on the geology, the hydrology and <br />the proposed well construction for the UIC D'uector to make a determination that USDWs will be <br />protected and to determine if additional well constriction or monitoring requirements need to be <br />established in the Permit. As part of the Permit application review and determination, it was <br />decided that periodicground-water monitoring was needed during the life of the Permit. The <br />applicant was required to submit a Ground Water and Surface Water Monitoring Plan (Water <br />Monitoring Plan) and a Subsidence Monitoring plan. These were submitted in preliminary draft <br />form on April 11, 1999. The final drafts of the Water Monitoring and the Subsidence Monitoring <br />14 <br />