HYDRO31470

• Permit No: M1999002
• IBM Index Class Name: Hydrology
• Doc Date: 6/21/1999
• Doc Name: FAX COVER VIC INFO
• From: GENERAL CHEMICAL
• To: D EDWIN HOGLE
• Media Type: D
• Archive: No

JUN-21-1999 1107 GENERAL CHEMICRL 201 515 19[35 F. bFJil~`J
references a Groundwater and Surface Water Monitoring Program. Has the EPA
reviewed and accepted this plan? In the event that EPA has approved this monitoring
plan as it pertains to the issuance of the Class lil UIC Area Permit, we object. The
monitoring plan contains numerous inadequacies and should be included iu t11is
document so that the public can review the plan and provide comment.
5. In general, we disagree with the sunlrnation of water quality characterization contained
the Draft Statement of Basis on pages 6 and 7. American Soda came under extreme
scrutiny for their characterization of water quality data in the Drai't Environmental
Impact Statement for the Yankee Gulch Minerals Project. As a result, American Soda
is being required implement a Groundwater and Surface Water Monitoring Program.
Until format and content of this program are finalized and the required 13 month data
collection is completed, it would be premature for the EPA to accept the water quality
characterization contained in pages 6 and 7 as fact. Until the data is gathered and
reviewed, the EPA should not issue a class III Permit because ilte condition of
protection of all USDW's has not been met.
6. The following is a direct excerpt from the Draft Statement of Basis (pg. 11, paragraph
4): "Cavity development would be monitored to estimate cavity size. Because the
leached solution cavity will he a matrix of oil shale rather than a voiii, size and shape
must be determined by inducct methods and standard logging methods used in mining
operations will not be accurate." if it is true that the cavern will be a matrix of oil
shale rather than a void, our experience in solution mining indicates gas blanketing of
the cavern will not work. Fluids will have the potential to do an cod :!round on the gas
blanket and eventually eat upwards to the lower aquifer. By only using mass balances
to guestimate cavern size and shape, American Soda is being permitted to solution mine
out of control. We say "out of conUol" because in reality, American Soda has
provided no information about actual cavern development or growth. American Soda
!!could be required to use some other method to validate mass balancE• as an acceptable
method for detertniniug cavern shape and gruwth and not vice-versa. These other
methods for consideration could be 3-D seismic, cross-borehole tt:lemetry or cross
bore-hole geophysical techniques. Known oil and gas field techniques could apply to
this project should be mandated to determine cavern characteristics. Reliance on mass
balances is dangerous because American Soda would be operating blind. The EPA
should require use of techniques that will maximize the protection of IJSDWs.
7. The following is a direct excerpt from the document Specific Permit Conditions
"Additional monitoring wells may be installed and added to the monitoring program, if
necessary, as development of the commercial solution mining well field progresses."
1n order for the EPA to guarantee protection of all USDWs with the issuance of the
Class Ill UIC Area Permit then the EPA must require American Soda to commit to a
Groundwater Quality Monitoring Plan for each mining interval. WYiile the number of
groundwater monitoring wells may vary based on experience and hydrogeography of
the mining pane], it must nevertheless, be a condition for issuing a Class III permit.
American Soda should also be required to develop the baseline water quality data at
,