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JUN-21-1999 1106 GENERRL CHEMICAL 201 `_•15 lyki5 r.ebia7ti <br />2. 1rr the Public Notice, "Announcement of Public Heazing and Public C:~omment Period - <br />Intent to Issue An tinderground Injec[inn Conlro] Class III Area Permit to American <br />5oda, L.L.P." page 2, paragraph 4, the EPA states: "EPA has ma~1e a preliminary <br />determination to approve the permit application and by doing so, it has determined that <br />the underground sources of drinking water (USDWs) will be protected." Exactly how <br />does the EPA propose to protect USDWs when baseline data has not yet been collected <br />for the American Soda project and the data tltat has been reported so far (i.e. in the <br />DEIS) has been proven to be anomaloaa to all other existing data previously collected <br />by the USGS? Which agrncy(s) is(are) responsible for determining the status of <br />underground USDWs? <br />In principle, we have three very serious concerns regarding [his matter. Below are two <br />excerpts taken from a lel[er submitted to John Mehlhoff of the BLM by Tom Dodson. <br />The first excerpt raises the issue of whether the current Test Mine Plan covered by the <br />Class V UIC permi[ is effecting baseline water quality data. Sin~:e baseline water <br />quality data was rtot subtitted prior to the beginning of [he Test Mine Plan and since <br />baseline data will not be available according to American Soda's application until the <br />fall of 2000, it would be inappropriate for the EPA to issue a permit that could further <br />bias the results of collecting the baseline water quality data. The second excerpt raises <br />the question of whether information provided by American Soda in support of a Class 1 <br />UIC permit should be re-evaluated since American Soda has already! been scrutinized <br />for providing misleading water characterization data in it's published DEIS. Finally, <br />this same excerpt raises the question of whether the Lower Aquifer (El-Groove} contains <br />USDWs and further supports the azgumen[ that until baseline water quality data is <br />collected and scrutinized, the EPA will be unable to guarantee [he protection of <br />USDW's as defined under the terms of the EPA's intent to issue American 5oda a <br />Class 111 Area Permit. (Note: the May 14, 1999 letter from Tom Dodson to Juhn <br />Mehlhoff of the BLM can be obtained under the FOIA. We highly recommend the <br />EPA review this document as part of the public comment process. in the event the <br />EPA is time constrained, we would be happy to provide a copy of this document. <br />Please contact me at (973)-599-5514). <br />EXCERPT 1 (Dodson Letter to Meblhoff, 5114199, pg. 2 -Water Quality ]ssuesl <br />"If my intetpretatign of the water quality data summarized below is correct, the <br />mining method being implemented by American Soda is intpacting groundwater <br />quality. Not only is the data itself questionable, the implications of dtc data for <br />American Soda's mining method is that significant degradation of the Upper Aquifer <br />has occurrt:d from the impleme~tlalion of the TcSt Mine Plan. First, fluoritle values in <br />the Upper Aquifer monitoring welts would seem to indicate that fluids frotrt the Lower <br />Aquifer have been released into the Upper Ayuifcr. Second, when an isolated Total <br />Dissolved Solid (TDS) value such as 29,41X1 TDS (Well 20-5, 6-29-9g) occurs in an <br />aquifer that is supposedly a designated Drinking Water Aquifer, it should ring hells <br />and result in an immediate investigation as to the cause of that value, be it s sampling <br />error or a release of drilling fluid into the affected area......" <br /> <br />