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<br />entire panel. As indicated, however, a periodic review of these data will be made whenever new <br />mining wells aze requested to allow EPA to determine if new monitoring well locations are <br />needed. <br />Regarding the sampling of springs and seeps, the existing data indicates that the quality of <br />nearby springs is relatively stable. Any problems likely to show up in these springs would, most <br />likely, be manifested initially in the ground-water monitoring results. EPA determined that <br />monitoring during the high and low flow periods was adequate for the initial commencement of <br />mining. If warranted by the sampling results, the Permit will be modified to require additional <br />monitoring. <br />After consideration of all comments, EPA believes that the data submitted by the <br />applicant was adequate to establish the necessary Permit conditions to ensure protection of <br />the aquifers overlying the injection zone. Further, the Water Monitoring Plan and the <br />Permit requires collection of an additional five quarters of monitoring data prior to <br />commencement of injection. These data will be used as a means of comparison with data <br />co-lected during the operation of solution mining wells to ensure that operational problems <br />do not go undetected. Therefore, no changes were made to the Permit in response to these <br />comments. <br />Comment 6: The water monitoring and the subsidence monitoring Mans required by the Permit <br />are inadequate. <br />The following nineteen (19) paraphrased comments discuss issues and concerns relating to <br />the Water and Subsidence monitoring plans: <br />1. The Subsidence Monitoring Plan is inadequate. <br />2. While the number of ground-water monitoring wells may vary based on experience and <br />geologic conditions of the mining panel, it must nevertheless, be a condition for issuing a Class III <br />Permit. American Soda should also be required to develop the baseline water-quality data at least <br />12 months prior to entering a new panel so these data can be scrutinized and the proper <br />monitoring constraints developed. <br />3. We are concerned that the EPA does not understand how important subsidence is in protecting <br />sources of USDWs. Subsidence monitor monuments should be placed on each well location. <br />4. EPA has not been provided the necessary information to arrive at a well thought-out plan <br />which protects all sources of USDWs. <br />5. The ground-water and surface-water monitoring program submitted by the applicant does not <br />protect sources of USDWs. <br />16 <br />