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_ i III IIIIIIIIIIIII III ~oM DODSON & Assoc~a-TE~ 2150 N. ARROWHEAD AVENUE , ~~- SAN BERNARDINO, CA 92405 ~ TEL (909) 882-3612 FAX (909) 882-7015 `~y I E-MAIL tdaa~empirenet.com YRprvc:lm»ti Dmdgm,ti~FJ-}sac~at.~5 ~o: j>Wt(r j>eG• Na..,...e~.cmPy ~~ t'e~tt~ ent~~~0.-~r'ng Co*~c.c•e,rres w~ ~L--~'c LLr~S DECEIVED May 14, ] 999 MAY 17 1999 Mr. John Mehlhoff, Area Manager Bureau of Land Management Division of Mineray & Geology White River Resource Area 73544 Highway 64 Meeker, CO 81641 Dear Mr. Mehlhoff: It has taken awhile, but I was finally able to review all of the materials that you provided my office in response to my Freedom of Information Act (FOIA) request of February 17, 1999. This letter is submitted as a follow-up to discuss several concerns raised by the monitoring data that was included in your April 1, 1999 letter. In keeping with my first letter and your response, I have summarized my concerns in the same numerical order as presented in those letters. However, there are several critical issues that standout in my review ofthe information package transmitted by your April 1 •letter which cause me a great deal of concern. These issues are: 1) modifications to conditions of approval contained in your 1997 Decision Record for the American Soda Test Mine Plan (CO-O17-97-48) and its implications for the Commercial Mine Plan currently under consideration; 2) water quality issues raised by the monitoring data submitted by American Soda for the Test Mine Plan project and its potential implications for the commercial mine plan currently under consideration; and 3) the Bureau's continued consideration of the Commercial Mine Plan when the Test Mine Plan has not yet demonstrated the commercial viability of the mining methodology proposed by American Soda. I address these issues in the order.presented in the following text. Modi in Mitigation Measures and Conditions of Approval The Decision Record and Environmental Assessment issued in May 1997 contained 30 mitigation measures and conditions of approval (COA) which were deemed necessary to protect the environment while allowing the Test Mine Plan to be implemented. Of these conditions four were subsequently altered. Specifically, the freeboard of the pond was modified from four feet to two feet (COA 2); critical cone of depression data has not been generated (COA 7); the 2,000 mg/I TDS limitation contained in COA 8 was waived; violation of COA 17 (notification of spills, leaks, pressure losses) has apparently not received any enforcement action (notification of the leak at Well 20-4 came two months after the release and even then .vas apparently only submitted to the BLM because of a