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<br /> <br />DMG Response: American Soda ha_s provided a comprehensive Soil Conservation, Erosion and <br />Sediment Control, Reclamation, and Revegetation Plan. This plan provides detailed descriptions <br />of the erosion control measures that may be employed at the site under a variety of conditions <br />that may be encountered. <br />Comment #9: Piceance Creek watershed has not been accurately characterized. <br />DMG Response: The Surface Water Monitoring Plan requires characterization of the watershed <br />prior to initial solution mining and includes a spring and seep study, a tracer dilution study, and <br />reactivation of USGS stations up and down gradient from the mine site. Also, there is copious <br />published USGS data available for the Piceance Creek watershed. <br />Comment #10: No mitigation plan for a pipeline break between the Piceance and Parachute <br />sites. <br />DMG Response: The pipeline is an off-site transportation facility (Rule l.l(31)) and is not <br />included in American Soda's reclamation permit. <br />Comment # 11: Without an accurate chazacteriza[ion of the water quality contained in the <br />aquifers within the Piceance site a reclamation permit should not be issued. Water quality should <br />be chazacterized by an independent third parry before a reclamation permit is considered. <br />DMG Response: The reclamation permit application requires a rigorous characterization of <br />ground water quality in the vicinity of the Piceance site. The ground water characterization plan <br />was developed by American Soda with input from DMG, BLM, USGS, EPA and Rio Blanco <br />County. The ground and surface water monitoring plan includes a third party validation <br />component, with USGS as the preferred third party. <br />Comment #12: What corrective action would be taken if the wells and/or cavities leaked high <br />TDS fluids into the aquifers? <br />DMG Response: Corrective actions aze listed in section 6.9.2 of the "Ground Water and Surface <br />Water Monitoring Plan" and include discontinuing the injection of mining solution. <br />Comment #13: Why doesn't American Soda net ponds to protect wildlife? <br />DMG Response: The reclamation permit application requires netting of evaporation and cooling <br />ponds. These ponds will also be surrounded by eight-foot high fencing. <br />Comment #14: The application should address the chemistry and process which will be <br />employed to avoid the formation of acids during solution mining and processing of acids. <br />D1~IG Response: As discussed previously, the Yankee Gulch Project is a DMO. All facilities <br />used to store or convey process solution are Environmental Protection Facilities that will be <br />