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Monitoring Plan---Major Flaws. (see Moran report, May 1999 for other details) 1-Why was this not included in the DEIS? 2-This plan assumes that baseline data collection will commence in September 1999, even though the test mining and brine injection have gone on since about April 1997. 3- Neither the DEIS nor the Monitoring Plan present actual monitoring well water level data to verify that the site specific ground water flow directions are known. Page 5 refers to "assumed flow directions." 1t is likely that the information presented on Figure I was simply extrapolated from the historic, more regional compilations of the USGS. Detailed site-specific water level maps need to be prepared, showing the actual locations of the actual data points, before one could reasonably choose the locations of future monitoring wells. Il is not possible to evaluate whether the number of proposed wells or their locations are adequate without such information. 4- Clearly the same form of evaluation also needs to be presented for the Parachute site. One monitoring well for this site is obviously inadequate. 5-Many of the Method Detection Limits (MDL) included on Tables 2,3,and 5 are unacceptably high, especially for constituents that would normally be considered mobile, thus good tracers of contaminant migration (i.e. chloride, sulfate, alkalinity, sodium, fluoride, etc.). The same is true for the MDLs for many of the trace constituents. It is likely that, iF such high MDLs were accepted, one would be unable to develop a meaningful baseline, or evaluate significant impacts if they were to occur. 6- The proposed surface water sampling needs to include local sites. The downstream USGS gage is too far away to provide meaningful monitoring of possible local impacts to surface waters. There are numerous other inadequacies' in this proposed Monitoring Plan, thus it should not be hurriedly- approved. I suggest that your agency require that the inadequacies in the Monitoring Plan and baseline data set be addressed, and that these changes be presented to the public as a revised DEIS. Once the intended NEPA process has been followed, all parties will then be able [o better evaluate the potential impacts that may occur, and the costs likely to be borne by the taxpayers. With the present information, such an evaluation is' not possible. Sincerely, Robert E. Moran, Ph.D. CC: Mr. Allen Sorenson, DMG Mr. Chuck Williams, EPA Mr. Pat Sweeney, WORC Mr. Steve D'Esposito, MPC Mr. ]. Ehmann, General Chem.