GENERAL32022

• Permit No: M1983194
• IBM Index Class Name: General Documents
• Doc Name: COVER SHEET-2 PUBLIC COMMENTS ON DRAFT EIS & RESPONSES TO COMMENTS
• Media Type: D
• Archive: No

2. PUBLIC COMMENTS ON THE DRAFT EIS AND
RESPONSES TO COMMENTS
2.2 Responses to Public Cororoents
2.2.1 Introduction
The numbered responses below correspond to the
bracketed numbers on the comment letters and public
hearing transcript in Section 2.1.3. Responses are listed, by
subject, in alphabetical order. Responses may consist of a
text change, a clarification of the draft eovirottmental impact
statement (EIS), or an explanation of why a particular issue
was or was not addressed.
2.2.2 Responses
necessary before approval of the 500,000 Tons Per Year
(TPY) Alternative.
Response No. 3. The U.S. Environmental Protection
Agency (EPA), along with several other federal and state
agencies, universities, industrial and environmental groups,
are cooperatively studying the physical, chemical, biological,
and legal aspects of atmospheric deposition. The Bureau
of land Management (BLM) a a formal participant ofseveral
research programs (including the National Acid Precipitation
Assessment Program, National Atmospheric Deposition
Program-National Trends Network, Western States Acid
Deposition Program, EPA Regional YIII-Western Atmos-
pheric Deposition Task Force, and Forest Service-Rocky
Mountain Forest and Range Experiment Station Atmos-
pheric Deposition Research Project) to asseu stateof-the-
art knowledge for incorporation into management decisions.
Air Quality
Response No. 1. Meteorologic data from Rio Blanco
Oil Shale Company's Tract C-a monitoring station on
Sagebrush Hill (approximately 10 miles west of the proposed
facilities) were used because of their completeness and
proximity. Data from 1982 was selected because of its high
recovery, availability of 60 meter winds, and site-specific
sigma theta sensors (standard deviation of wind direction).
The data is typical (nonanomalous) when compared to all
data collected since 1975, and well suited for defining annual
and worst-case conditions. The terrain at both locations is
similar; both are located on top of benches (plateaus) in
the Piceance Basin. Monitoring data were collected at 7,300
tees mean sea level; the proposed facilities are at 6,600 feet
mean sea level.
Response No. 1. All activities associated with the sodium
leases must comply with applicable federal, state, and local
air quality regulations and implementation plans. The State
of Colorado, Department of Health, has the responsibility
and authority to enforce the Prevention of Significant
Deterioration program (including determining Best
Available Control Technology and tracking increment
consumption). The appropriate federal land manager of the
Prevention of Significant Deterioration. Class f or state
Category I areas is responsible for determining whether
predicted impacts to air quality related values would be
adverse. These determinations cannot b<: made until Wolf
Ridge Corporation (W RC) presents very specific engineering
plans to the State. Thus, additional analysis would be
ABernatives
Response No. 4. The alternatives were developed to
show a range of possible development scenarios in order
to contrast potential impacts from WRC's proposal-the
125,000 TPY Alternative. The 500,000 TPY Alternative
represents a maximum production rate projen that could
conceivably be viable based upon existing and projected
future economic and market conditions. Market expansion,
such as acid rain legislation requiring dry-sodium
desulfurvation conVOls, would make this a viable alternative.
Aquatic, Wetland, and Riparian Habitats
Response No. S. BLM's identification criteria and
concept of riparian/wetland habitats is consistent with
definitions provided within Executive Order 11990,
Protection of Wetlands (Federal Register Vol. 45, No. 25,
page 7895, February 5, 1980) and is in principle identical
with that used in FWS/OBS-79/31. Per your request, we
have incorporated Cowardin's wetland classification system.
Please note that the entire wetland section has been rewritten
to reBect revised groundwater pumping rates, corrected
hydrologic evaluations, and current wetland inventory data.
During recent reconnaissance of Yellow Creek, we found
the estimated wetland acreage used in the draft EIS in error.
Our former estimate was based on interpretation of 1979
color serial photos--channel character and the extent of
habitats supported by Yellow Creek have changed
dramatically since that time, apparently in response to
increased mean precipitation received in this watershed
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