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No changes were made to the Permit as a result of these comments. <br />Comment 3: A commentor was concerned that there is no comprehensive independent <br />monitorine of the basin by a third partv, such as the USGS This was the case during the Oil <br />Shale development period where the USGS carried out a program of basin-wide monitoring The <br />monitoring is instead left up to the individual permitted facilities Thus sampling and analvsis <br />by the individual facilities may lead to inconsistencies in data because of variations in the <br />monitoring and lab analvsis procedures The commentor recommends that the various regulatory <br />agencies and Lease operators put together abasin-wide comprehensive. multi-participant <br />approach for funding and taming out a monitoring plan that would reauire development of a data <br />base covering all of the potentially effected area, not just individual sites <br />Response: EPA supports the proposal of a comprehensive basin-wide monitoring program as a <br />means of supplementing the on-site monitoring performed by the operators in the basin. <br />However, neither the Safe Drinking Water Act nor the applicable UIC regulations provide <br />authority for EPA to require the operator to participate in such a program. Although American <br />Soda contracted with the USGS for a QA/QC program at the Yankee Gulch Lease, this was a <br />cooperative effort between the USGS and American Soda. EPA supports the concept of basin <br />wide monitoring by a third party and would be willing to work with the operators and other <br />regulatory agencies to identify options for establishing such a network. If the State or local <br />Government Agencies create such a program, EPA may be able to provide technical assistance. <br />There was no modification to the Permit as a result of these concerns. <br />