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16. How did the monitoring plan get approved by the BLM, and to what extent does the EPA rely on the BLM's DEIS and its findings? 17. EPA is currently requiring monthly water level monitoring of ground water (Page 22 SOB). A continuous water level monitoring system is not an unreasonable expense for the value gained in this instance, and it is strongly suggested that EPA consider requiring such a monitoring system on all monitoring wells. 18. There is no map given of the locations of the monitoring wells, nor are the locations described in any detail. 19. The Unita Formation is discussed as having only one monitoring well. This is completely inadequate. Response: It must be emphasized that EPA had not approved either the draft Water Monitoring Plan or the draft Subsidence Monitoring plan as part of the Draft Permit. It should be noted that the revised Water Monitoring Plan and Subsidence Monitoring Plan have been approved by incorporation into the Final Permit. Recent regulatory agency requirements have been incorporated into the latest revision of both of these plans, which are dated December 23, 1999. The draft Water Monitoring Plan and the draft Subsidence Monitoring Plan (both dated Apri122, 1999) were available in the EPA administrative record for the Yankee Gulch Permit for public review. Whether or not the monitoring plans were available for review as part of BLM's draft EIS process is not relevant to EPA's UIC permitting action. EPA's permitting action is completely separate from BLM's actions and does not rely on BLM's administrative record. Although the revised plans approved by EPA and referenced by the UIC Permit incorporate changes made in response to comments and requirements ofBLM and other agencies, BLM's approval of the monitoring plans is not relevant to EPA's process. It should be noted that the details regazding the elements of acceptable plans were still being discussed with American Soda by the various agencies, including EPA, BLM, CDMG and Rio Blanco County during the draft comment period. The SOB and the Draft Permit simply referenced the fact that an approved Water Monitoring Plan was needed and the Permit referenced several portions of the draft plan. This was also true of the Subsidence Monitoring Plan. The Permit requved that the operator submit the results of the subsidence monitoring collected during the year utilizing the final plan. Because of the potential need for modifications of both the Subsidence and the Water Monitoring Plans during the life of the Permit, EPA has modified the Permit to adopt both the Subsidence and Water Monitoring plans into the Permit entirely. The applicant was required to submit revised Water Monitoring and Subsidence plans which incorporate changes made by CDMG, BLM and EPA in response to public comments and requests made by Rio Blanco County. These revised plans are incorporated as appendices to the Permit. Any modifications in either of those plans deemed necessary as a result of 18