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7UN-21-1999 11 06 GENERAL CHEMICRL 201 515 19C~ r.t7~r~~~ M y EXCERPT 2 (Dodson Letter to Mehlhoff, 5/14/99, pg. 6 -Item 10) "Well 20.9 (Lower Aquifer, A-Groove) Monitoring Wcll Date Dicarb TDS Chloride Fluoride 02-U2-99 14,322 9,390 210 M/D 01-21-99 0? 2,995 4U7U 4.9 12-22-98 7,392 9,616 2,156.6 23.8 Huwcvm7, there is a subtle issue that arises by examination of the data summrrirxd above. Since the TDS values all fell below 10,00(1 mg/l, this aquifer should be considered as an EPA Drinking Water Aquit'cr which contradicts the data submitted to the L•PA in order to obtain the UlC permit Cor injection in Well 20-6. These date should havu prompted BLM to cottununicate with EPA in Denver to reevaluate [he acceptabiliry of using the aquifer for discharge of fluids in the ponds whir][ began on February G, 1999. The discharges [nay bu in violation of American Soda's UIC permit." 3. The following is a direct excerpt from the Drat't Statement of Basis (pg. 2, paragraph 4): "No fluids would he injected into any Underground Source of Drinking Water." How can this statement be made if proper characterization of baseline water quality data is not yet completed? Inherent in this comment is an even more disturbing problem: Even if the actual statement is correct, i.e. No fluids would be injected into any USDW, what if tluids injected into anon-USDW migrated to a USDW because of fracturing of the zone, subsidence created fractures or faults, or because of failure of a well casing? While the intent of the statement and permit conditions may be accurate, the potential for indirect consequences is very real. While American Soda may Maim their mining technique is safe, subsidence will be minimal, and precautions are being made to test well casing integrity, the issue of high TDS fluid mobilization into USDW's remains real. American Soda references a subsidence monitoring plan in the Draft Statement of Basis but does not include the information for the EPA to review. By not reviewing and approving the monitoring plan, the EPA has not guaranteed the protection of USDW's as stated in the determination for approving the permit application. In the event the EPA has reviewed and approved the American Soda Subsidetlce Monitoring Plan, we object. The plan as it is written is inadequate and the public should be allowed [o review the document and provide comment as part of this Class Ill UIC Area Permit process. 4. The following is a direct excerpt from the Draft Statement of Basis tpg. 3, paragraph 1): "In addition to wells 20-2 and 20-3, EPA has recently approved well 20-14 under the class V Rule Authorization" If the Dodson Letter to Mehlhoff referenced above is correct, isn't the issuance of a Class V Rule Authorization for well 20-14 potentially contradictory to the statement that USDW's will be protected? How will the EPA resolve the issue of whether or not American Soda's Test Mine Plan is affecting baseline groundwater quality? In the Draft Statement of Basis, American Soda