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,,,JUN-1B-1999 12 07 F.pTHGERBEP. JOHNSON&LYpNS ~_ ~lle~~~.Q~ 397 638 6252 P. 19 911 ILrv Ile l,., Hue I'.,niplmny. N, tl%U.Si Tel 773~.C i•nntN~ May 28, 1999 tRa FMeml Erprcss and Faz Mr. Allen Sorenson Reclamation Specialist Division of Minerals and Geology 1313 Sherman street., Rnom 215 Denver, Colorado 80203 RE: Adequacy of the Reelaxtatiox Application, Yankee Crsfch Project, File No. M-99-002 (Ametuax Soda) - third Commext Sabsnittal Dear Mr. Sorenson: Thank you for the opportunity to supplement and continue our review of the filings provided by American Soda in respotrse to the Rules and Regulations of the Colorado Mined Land Reclamation Board, and to the adequacy letters provided by the Division of Minerals and Geology (DMG). As we will explain below, each additional filing has served to inaease our concerns about the merits of the permit app]icatioa. Further, certain apparent inadequacies is such documents as the BLM Draft F~vironmratal Impact Statement have given rise to an independent concern that the information available for the evaluation oP the Ameritan Soda project is emerging too s]owly to allow for optimal review. We are also confused about why American Soda has not been asked to respond to one of our most important and long-standing concerns, which is the pmpazatioa of adequate baseline Pon water quality and quantity io advance of the approval of a permit. These concerns notwithstanding, the most recent filing prompts the following comments. The first listed item is the American Soda Adequacy Response of May ]3, 1999, recites. among other things, [hat the Groundwater and Surface Water Monitoring Plaa submitted as a [ethnical revision to its application fills one of the most significant gaps in that application. White the candor of the admission deserves applause, the wnclusion is indefeasrble. In support of the claim that Arntricaa Sada may now be relieved of submitting the basclinc data before permit approval, American Soda submits a letter from the Bureau of Land Management to Mr. Nielsen, dated April 26, 1999. In the letter, the BLM asserts that ground water and surface warn eoncesas have been adequately addressed by the Monitoring Plan, and it is therefore approved (by the BLM at least) far the Yankee Cuich Sodium Minerals Project. American Soda's Adequacy Response implicitly concludes that if the Monitoring Plaa in ins present form is good enough for the fedual agencies listed is the Icttrr, it should satisfy the requirements of the Colorado Mined Land Reclamation Act. q EXHIBIT 9 c