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<br />effective date of the Permit. <br />If the construction of well 17-I is determined to be a potential problem, the operator <br />will be required to submit a corrective action plan which must be completed no later than <br />three years of the effective date of the Permit. The corrective action section of the Permit <br />has been modified to stipulate the actions mentioned above. <br />Regazding the concerns that future corrective action may be required as a result of the in- <br />situ mining operation, the regulations provide EPA with the authority to ensure that the operation <br />of the injection wells does not result in movement of fluid into underground sources of drinking <br />water (40 CFR 144.12). The Permit requves the operator to take all reasonable steps to minimize <br />or correct any adverse impact on the environment resulting from non-compliance with this Permit <br />(See 144.51(d) and 40 CFR 146.10(d}). 40 CFR 146.10(d) also requires that the Director <br />prescribe aquifer clean-up and monitoring where he deems it necessary and feasible to ensure <br />adequate protection of USDWs. As explained in previous comments, the applicant does not <br />propose to mine in aquifers. Authority to inject is limited to the non-water producing Saline <br />Zone. <br />At this time, no aquifers have been contaminated by the mining process that pose a <br />threat to any USDWs. Thus, no corrective action involving clean-up is being required <br />prior to or during implementation of the commercial phase of the Yankee Gulch Project. <br />A requirement will, however, be added to the plugging and abandonment section of <br />the Permit (Section E. 4.) that provides for modification of the plugging and abandonment <br />plan per 40 CFR 146.10 (d). This addition allows the Director to require changes in the <br />operators plugging and abandonment plan relating to the protection of USDWs may be <br />required, if ezcursions or well failures occur. Under this provision, the Director shall <br />prescribe aquifer clean up and monitoring where he deems it necessary and feasible to <br />insure adequate protection of USDWs. <br />Comment 18: Driller's loss and comments should be reviewed bean independent aartv to <br />determine whether pH and specific conductance (SC) measurements were made during drilling of <br />all American Soda wells. <br />Response: Prior to commencing injection in any specific well, the Permittee must submit the <br />information on the construction and completion of the solution mining well, including the results <br />of the initial MIT. This information is requved under Section C. 1, for newly drilled or converted <br />wells. The completion results must include all logs, core descriptions, core analyses, geologic <br />summaries, well-test data, sampling results and all other surveys or data obtained during the <br />drilling, completion and/or workover operations. The logging requvements are specifically listed <br />Section A. 6. It is EPA's opinion that any pH and SC data would be included in any completion <br />report. EPA will review these records prior to granting authority for the operator to commence <br />injection in each individual well. <br />34 <br />