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on-going monitoring during the life of the Permit, will be made by modifying the Permit. As discussed in the response to comments 3 and 5, EPA received copies of the draft Water monitoring and the Subsidence Monitoring Plan dated Apri122, 1999. These plans were part of the administrative record and were open to public review and comment. It should be emphasized that neither of these plans had been approved by EPA. Extensive informal discussions took place regarding concerns and issues raised by all interested parties, including the public, that lead to the current version of the plan incorporated into the Permit. In addition to collecting public comments regazding the plans, EPA has consulted with other regulatory agencies regarding identified problems with the plans. Changes have been made to the both monitoring plans that address the various concerns, such as minimum detection limits. The EPA, other regulatory agencies (e.g., BLM, CDMG), and American Soda recognize that the Water Monitoring Plan and the Subsidence Monitoring Plan are "living" documents and revisions to the plans may be necessary as more data are gathered across the project area of approximately 4,500 acres over a period of 30 yeazs of operation. The Final Permit will allow for the flexibility to change and/or revise stipulations as necessary based on monitoring results by modifying the plans. If results from the planned wells indicate that additional wells or studies aze needed because of variations in direction of ground-water flow from that assumed, EPA will require installation of additional wells. This same concept applies to the Subsidence Monitoring Plan. A multi-agency meeting was held at the BLM ol£ces in Meeker, Colorado on March 25, 1999, in an effort to bring all agencies into consensus on a single Water Monitoring Plan for the Yankee Gulch Project. Those in attendance at this meeting included representatives from American Soda, BLM, CDMG, U.S. Geological Survey, and Rio Blanco County. Representatives of EPA participated via telephone. American Soda provided a draft Plan at that meeting. After the meeting another draft Plan was produced by American Soda and reviewed by the agencies. A revised Plan was finally produced Apri122, 1999, and distributed to the agencies. CDMG subsequently requested a review of Tables WQl and WQ2 from the Plan because the Method Detection Limits (MDLs) in these tables were higher than the Basic Standazds for Ground water provided in Colorado Department of Public Health and Environment, Water Quality Control Commission Regulation No. 41. Anew set of Tables WQ1 and WQ2 with MDLs at or below the Basic Standazds for Groundwater was submitted to CDMG on June 3, 1999. CDMG responded with a request to change the MDLs for cadmium, copper, silver, and chloride to a value lower than the Basic Standards for Ground water. EPA communicated with both American Soda and CDMG regazding the concerns over the original MDLs. On June 23, 1999, the Colorado Mmed Land Reclamation Board (MI,RB) reviewed American Soda's application fora 112 Surface Reclamation Permit, and approved the application provided certain conditions would be met prior to circulation of mining fluid. Two of these conditions, defined in the 112 Permit issued by CDMG to American Soda July 16, 1999, are applicable to the Plan. One condition required that the Plan incorporate the recommended MDLs for cadmium, copper, silver, and chloride. The other condition required a second review of the MDLs from Tables WQ1 and WQ2. CDMG and the MLRB required that the MDLs in these tables reflect the capability of the laboratory testing equipment used to analyze the samples, 19