Laserfiche WebLink
<br />As we have already observed, it is impossible for an independent evaluator to presently <br />prepare a more thorough critique. For example, while the EPA is prepared to allow the <br />reinjection of "boiler blow down," the hazardous materials to be used in the boiler (as <br />described on DEIS Table 2-5) are identified merely as "corrosion inhibitor," scale inhibitor," <br />and "oxygen scavenger." One would have to guess not only at what the substances are, but <br />also how they would interact with the other substances that may be employed in the injection <br />fluid under various temperatures. <br />Similarly, the water quality information which appears on Table 2-4 of the DEIS lists <br />only four select sodium compounds, without disclosing measurements of the specific <br />components of the compounds, or any other elements or substances that are mobilised by <br />American Soda's solution mining process. (The utility of Table 2-4 is further limited by the <br />fact that the information is presented in an aggregated summary.) American Soda is <br />employing a process designed to leach sodium compounds out of rock, and such a process will <br />unavoidably mobilize other substances along with the sodium compounds. Further, there is no <br />dispute that changing temperature and pressure pazameters will affect both the effectiveness of <br />sodium recovery, and the range of substances that are mobilized. Table 2-4 of the DEIS <br />discloses neither the details of substances mobilised by current pilot project operations, nor the <br />range of substances that may be mobilized by the full scale facility if it is operated at different <br />temperatures and pressures. However, under the draft UIC permit, almost any solution which <br />comes out of the ground or is used in processing may be reinjected. This is a subject which <br />deserves more thoughtful treatment than the dismissal offered to the DMG by American Soda. <br />Nor is it persuasive to claim that some other agency will take Gaze of the problem. <br />Consider the EPA. The central premise of the Statement of Basis for the draft UIC permit is <br />that the American Soda injection wells will be drilled through the Lower and Upper Aquifers <br />into a stratum which is not itself an aquifer, so that if the integrity of the injection wells can be <br />assured, there can be no risk of harm to the aquifers. The DMG's Second Adequacy Letter <br />gives General Chemical considerable comfort that the DMG already appreciates some of the <br />ways in which this approach may be catastrophically flawed. The key point here is that if the <br />EPA is wrong, the proposed performance bond is a mere $68,400, i.e., EPA's estimate of the <br />cost to plug and abandon each solution mining well. Drawing the larger picture together, <br />then, American Soda would have DMG ignore the risks to aquifers for which there is <br />admittedly inadequate baseline data, on the theory that a bond of $68,400 is a sufficient <br />fallback in the event that the EPA's regulatory approach fails. Note that actual failure may be <br />for reasons such as subsidence or fracturing which may be unrelated to the adequacy of the <br />EPA's own regulatory constraints, and that the authorized injections can make it impossible to <br />ever know what the baseline was. General Chemical submits that this result should be <br />unacceptable to the DMG. Each state and federal agency has its own role to play, and no <br />agency should be persuaded to refrain from asserting its authority on the premise that informal <br />reliance on another agency will assure an undefined yet acceptable regulatory climate. <br />President Harry Truman had a sign on his desk which read, "The buck stops here." <br />American Soda is both explicitly and implicitly urging the DMG to accept the notion that the <br />environmental buck stops somewhere else. Neither the drafr Environmental Impact Statement <br />