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<br />adequate. sensitivity to detect such changes. Evidence of a leak would require corrective action <br />that could include the well being shut in until the problem is resolved or the well is plugged and <br />abandoned. As mentioned in Comment 17, EPA also has authority under 40 CFR 146.10 (d) to <br />require that the operator modify the plugging and abandorunent plan to address any clean-up or <br />monitoring needed to assure protection of USDWs necessary as a result of the problem well. <br />As a result of the review of this comment and the associated information, EPA has <br />determined that no changes to the Permit are needed in response to this specific concern. <br />Comment 21: There aze potential problems regazding damage to the oil shale resource. <br />The following two (2) paraphrased comments discuss issues and concerns relating to the <br />protection of the oil shale resource. <br />1. Please make a complete evaluation of whether partial distillation of the oil shale can occur as a <br />result of this process and incorporate the Endings in the Final Permit (See Page 2 SOB). <br />2. The American Soda test wells have already caused some breakdown of oil shale organic <br />compounds. We aze concerned about the future mineability of the oil shale. <br />Response: EPA does not believe that the future mineability of oil shale within the Yankee Gulch <br />Leases is within the scope of the Class III UIC Area Permit. The scope of the SDWA, which <br />estabhshed the UIC program, is protection of ground-water resources and does not cover the <br />protection of mineral resources. <br />The BLM, however, has authority over the Yankee Gulch Leases and is responsible for <br />protection of other mineral resources on federal lands. It is EPA's understanding that BLM has <br />required American Soda to develop and implement a plan, subject to BLM approval, to monitor <br />operations to assure compliance with lease stipulations concerning protection of the oil shale. <br />The plan will include sampling of the production stream for dissolved organic cazbon to identify if <br />destructive distillation of the oil shale is occurring. The Ground Water and Surface Water <br />Monitoring Plan includes the measurement for specific organic compounds in solution mining <br />production fluid, which will assess the effects on oil shale in the Saline Zone. Action levels for <br />increased amounts of organic constituents in production fluid would trigger the implementation of <br />lower mining temperatures or the implementation of other protective measures <br />The monitoring of various organic compounds as required by BLM is included in the <br />Water Monitoring Plan, which is incorporated in the Pernut. EPA will be provided this process <br />monitoring information that will be collected to evaluate potential oil shale degradation. <br />EPA obtained information from the BLM's Record of Decision (ItOD) associated with <br />the Yankee Gulch Project, especially as it relates to oil shale related issues. EPA agrees with the <br />BLM assessment that potential contamination of ground water from historic operations in the <br />vicinity of American Soda's test mine facility (Sauhrier, September, 1999) could account for <br />higher than expected TOC values. As indicated in the ROD, American Soda contracted with <br />Agapito Associates, Inc. to determine the potential impacts to the oil shale resulting from the <br />37 <br />