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<br />Comment 7 Presence Creek Watershed Aas Not Been Accurately Characterized (Section <br />G.1.1.1 Presence Creek Watershed, Pg. Gl) <br />There aze numerous references to the ionic constituents and surface water quality types, <br />none of which are cited by any literature references. Where aze the data to support <br />these statements? <br />Comment 8 The Reclamation Permit Is Not Complete In That It Must Address 17te <br />Potential Of A Pipeline Failure (Section G.1.2 -Groundwater, Pg. G2) <br />There is 80 miles of pipeline (40 each way) associated with the American Soda project. <br />Why is there no consideration for the potential environmental effect and contamination <br />of the shallow alluvial aquifers if there is a pipeline break, rupture or leaf? This is a <br />very real possibility yet there is no mitigation plan to accommodate such an event. <br />Comment 9 Without An Accurate Characterization Of The Water Quality Contained In <br />The Aquifers Within The Presence Site A Reclamation Permit Should Not Be Issued <br />(Section G.1.2 -Groundwater, Pg. G3) <br />With reference to the Lower Aquifer there aze no literature citations, why not? Why <br />doesn't American Soda draw upon the most recent available USGS data? The middle <br />and upper portions of the Lower Aquifer are ]mown to have relatively good water <br />quality and only when the Dissolution Surface is approached does the water quality <br />degrade with a corresponding increase in TDS. Why doesn't the American Soda <br />Reclamation Permit Application accurately depict the true water quality conditions of <br />the Lower Aquifer? Since discrepancies exist between existing data and data developed <br />by American Soda, water quality should be characterized by an independent third party <br />before a Site Reclamation Permit is considered. <br />Comment 10 Without An Accurate Characterization Of The Water Quality Contained In <br />The Aquifers Within The Presence Site A Reclamation Permit Should Not Be Issued <br />(Section G.1.2 -Groundwater, Pg. G-4) <br />When the Upper Aquifer water sample at 811 feet was taken, across what interval was <br />this sample representative? Was the hole open to the Lower Aquifer? Were proper <br />QA/QC protocols followed? Are these water quality data verifiable and reproducible? <br />These data are contrary to most other data in similaz hydro-stratigraphic intervals. <br />Why? Since discrepancies exist between existing data and data developed by American <br />Soda, water quality should be characterized by an independent third party before a Site <br />Reclamation Permit is considered. <br />Page 3 <br />