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i <br />C, <br />1n its discvsaion of Comment Number 20, the DMG offers no response to General Chemical's <br />statement of the statutory requirements. <br />General Chemical later learned that the DMG intended to relieve American Soda from <br />submitting baseline data before permit approval. By this time, General Chemical was in a position <br />to anchor its statutory concerns in what was then (mown about the Monitoring Prog2m, and did <br />so in a letter of May 28, 1999, excerpts attached as Exhibit C. The May 281etter does not <br />address the legal arguments made in the DMG Recommendation, because the DMG did not <br />disclose the rationale for its acceptance of the Monitoring Program until the DMG <br />recommendation was made available. Several of the concerns stated in the May 28 letter remain <br />unaddressed. One example is a concern that American Soda has been improperly wnducting pilot <br />plant operations under a prospecting permit. <br />To this day, the DMG has not contested ar responded to the majority of General <br />Chemical's comments. Instead, it has taken the position that the Hard Rock/Metal Mining Rules <br />and Regulations authorize approval of the Monitoting Program. <br />The DMG Rrapoose to Comment 20 <br />The DMG has countered General Chemical's concerns with an explanation which relies on <br />Rule 3.1.7(3) of the Hard Rock/Metal Mrning Rules and Regulations, with that provision's aoss- <br />reference to Rule 3.1.7(2). This single page of Rules is attached as Exhibit D_ The DMG <br />Response applies the Rules by addressing two types of risks to groundwater. <br />