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<br />6. No mention of measuring total organic carbons in the Ground Water and Surface Water <br />Monitoring Program. This constituent should be included in lists WQ1 and WQ2. <br />7. In the event the EPA has reviewed and approved the American Soda Subsidence Monitoring <br />Plan. We Object. The plan as written is inadequate and the public should be allowed to review <br />the document and provide comment as part of this Class III UiC Area Permit process. <br />8. In the Draft SOB, American Soda references a Ground Water and Surface Water Monitoring <br />Program. Has the EPA reviewed and accepted this plan? In the event EPA has approved this <br />monitoring plan. We Object. <br />9. Ground-water flow direction: commentors noted that the ground-water flow direction used by <br />American Soda to site additional monitoring wells requved by the Groundwater and Surface <br />Water Monitoring Plan does not conform exactly to site specific or regional flow directions and <br />have indicated that data collected from these wells would be of little use if the flow direction is <br />different from that assumed. (This issue is also addressed in comment 6.) <br />10. Several commentors noted that laboratory Method Detection Limits (MDL) for many water <br />quality parameters listed in Tables 2 and 3 of the Ground water and Surface Water Monitoring <br />Plan are too high to be of use when evaluating whether a given result exceeds state water quality <br />standards. One commentor presented a list of MDLs and Practical Quantitation Limits (PQLs) <br />from a commercial laboratory, Core Laboratories, to demonstrate what he feels are reasonable <br />limits which in many cases are much lower than those shown in the Ground water and Surface <br />Water Monitoring Plan. <br />11. The ground water and surface water monitoring plan prepazed by Agapito Assoc. (April 22, <br />1999) has numerous inadequacies that will prevent development of a reasonable and adequate <br />baseline for this site. <br />12. Monitoring Plan should be revised so that all wells monitored during the baseline period are <br />sampled montlily. <br />13. EPA should require that the monitoring wells be single completion wells as opposed to the <br />multiple completion type proposed. <br />14. Given the poor quality of these data from the existing American Soda wells and the lack of <br />disclosure on the part of the proponent, a truly independent party, such as the USGS, should be <br />requved to design, oversee, and conduct the surface water and ground-water monitoring for this <br />project. <br />15. Having only one monitoring well at the Parachute Site is clearly inadequate. Baseline needs <br />to be determined at Parachute also. <br />17 <br />