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COMMENTS RECEIVED FROM Private Companies Chris Freeman, Environmental Engineer, American Soda L.L.P. September 15, 2000, letter on the Draft Area Permit for the Rock School Lease Project ORAL COMMENTORS AT PUBLIC MEETING September 28, 2000 RIO BLANCO COUNTY COURTHOUSE MEEKER, COLORADO 1. Leon Pahler, Private citizen 2. Chris Coyle, General Counsel, American Soda L.L.P. 3. Robert L. Tobin, Member, Rio Blanco County Planning Commission, Water Quality Hydrologist (USGS), Ret. None of the commentors opposed the project. The comments received on the Draft Statement of Basis (SOB) and the Permit, have been paraphrased and grouped into three areas of common interest with responses provided that address the issues within the listed topic. This response to comments is considered to be an addendum to the existing SOB and is part of the EPA's Administrative Record for the Rock School Lease Class III Permit. Response To Issues and Comments Comment 1: commentors believe that the Permit should include well construction, well operation, monitoring, record keepin and reportine requirements that are consistent with those of the recentl~ssued Yankee Gulch Class III Permit. Response: EPA seeks to incorporate permit requirements that are consistent with USDW protection under the proposed operating conditions and site conditions. However, as a result of this comment, EPA has reviewed the Draft Permit and compared the requirements in it with those in the recently issued Permit for the Yankee Gulch Sodium Lease. Although some changes were made in the Permit to clarify the language of the Permit. related to monitoring and in some cases to strengthen the actual monitoring program, the requirements for the initial phase of the Rock School lease are generally similar to those for other commercial nahcolite facilities in the basin, and differences are commensurate with the small, non-commercial, scale of the initial test phase proposed by AmerAlia. Specifically, the monitoring requirements reflect differences in scale between the initial three cavities allowed under this Permit and a larger scale project, such as that recently permitted at Yankee Gulch.