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4 `oo t ,.boo meo <br />P ti - '--~ <br />W ~~~~IN: <br />j ' ~i "\, <br />`~ "'oil <br />a, <br />•,;Dip lane u+~~ <br />• <br />RIO BLANCO COUNTY DEPARTMENT OF DEVELOPMENT <br />County Courthouse <br />post Otfice Boz 599 <br />Meeker, CO 81641 <br />(970)818-5081 <br />FAX (910)878-5796 <br />March 3, 1999 <br />CERTIFIED MAIL Z 102 521 319 <br />Larry Shults <br />USDI Bureau of Land Management <br />White River Resource Area <br />73544 Highway 64 <br />Meeker, CO 81641 <br />RE: Draft Environmental Impact Statement/Yankee Gulch <br />Sodium Minerals Project-American Soda, L.L.P. <br />(January 1999) <br />Dear Mr. Shults: <br />Rio Blanco County would like to provide the following comments <br />for the Draft Environmental Impact Statement (DEIS) for the Yankee <br />Gulch Sodium Minerals Project. We have serious concerns with <br />reference to the hydrogeologic characterization and proposed water- <br />monitoring plan. The information provided could lead to erroneous <br />conclusions by regulatory agencies and others about existing conditions <br />in Piceance Basin. It is important that decisions about a project of this <br />size be based on good science. <br />Significant data in the water-quality characterization in the DEIS <br />appear anomalous when compared with the large database that exists for <br />the Piceance Basin. Abnormal background concentrations of a number <br />of constituents such as chromium, zinc, dissolved solids, nitrates, <br />nitrites, etc. are ten to one-thousand times or more greater than other <br />samples taken from nearby and elsewhere in the basin (pages 3-20, 3-21, <br />throughout the report). In addition, data appear to have been selectively <br />retrieved from the database and past reports to imply that existing water- <br />quality conditions do not meet Colorado groundwater standards, even <br />when the bulk of the data, from the site and elsewhere, do not support <br />these conclusions (pages 3-17, 3-19). Hydrologic statements of facts are <br />inconsistent and inaccurate in the report, i.e., gradients and flow <br />directions (pages 3-17, 3-20), and concentrations of constituents and <br />TDS (pages 3-17, 3-20 and throughout the report). <br />