Via Hand Delivery

OMYA, Inc.
61 Main Street
Proctor,Vermont 05765
802 459 3311
fax 802 459 3428

May 22, 2000

Brian Kooiker
Vermont Agency of Natural Resources
Wastewater Management Division
103 South Main Street, Sewing Building
Waterbury, VT 0567l-0405

RE: Response to NOAV Dated April 14, 2000

Dear Brian:

Enclosed please find a copy of OMYA's Integrated Contingency Plan for its Verpol Plant in Florence. This plan was prepared by Marin Environmental of Richmond, VT. with OMYA's assistance and is designed to satisfy the pollution prevention, spill control, and hazardous materials management planning requirements of both our storm water and process water discharge permits.

As requested in the NOAV, OMYA also contracted the services of an independent registered Professional Engineer to evaluate the structural integrity of the berms surrounding the two (east and west) flotation "ponds" and comment on the possibility of future leakage as was experienced in March of this year.

The geotechnical engineer's review found that the berms surrounding the east pond are constructed primarily of natural bedrock and, at the northernmost end, up to six feet of earthen material over natural bedrock. The water level in the east pond is normally maintained at a level 5' +/- below the crest of the berm. The western and southern berms of the west pond are located over the original deep quarry and are constructed of earthen material placed on top of the settled mineral tailings within. The enclosed plan titled "OMYA Verpol Plant Flotation Process Settling Basin Site Sketch" by Geodesign, Inc. dated 4/20/00 shows these features.

As was expected, given the nature of the material underlying the western and southern berms of the west pond, the geotechnical engineer concluded that they may be susceptible to future instances of excessive leakage. However, the lower-elevation "dogleg" portion of the quarry would be the recipient of any lost material from the west pond, and it has more than enough capacity to accommodate and contain the full volume of that pond. The real problem experienced during the March incident was related to the configuration of the pump house from which water is recycled from the dogleg quarry back into the plant process, and the fact that the pump house was flooded rendering it unsafe and essentially unusable.

Since it is impractical if not impossible to address the negative aspects of the western and southern berms of the west pond given the underlying foundation, and since the issue is not one of containment but rather the functionality of the present pump house configuration, OMYA proposes the following actions to prevent a repeat of the situation experienced in March where we were forced to quickly reduce the water level in the dogleg quarry:

Brian Kooiker Vermont Agency of Natural Resources May 22, 2000 page 2 of 2

1) evaluate the use of submersible pumps in the dogleg quarry, thereby rendering moot the issue of a rise in dogleg quarry water level -- by August 1, 2000; and

2) regardless of whether the use of submersible pumps will be economically and technically feasible, OMYA will install an engineered concrete barrier wall to prevent flooding of the pump house -- by September 15, 2000.

In the event of any future loss of flotation pond water to the dogleg quarry, either of the above modifications would allow for the water in the dogleg quarry to be maintained at a higher-than-normal level for the period of time necessary to reclaim the extra water into the plant process.

Please note that OMYA considers the content of this letter and the two enclosures to be confidential business information since it involves production process, chemical, and equipment information which is proprietary in nature. Such information could be used by knowledgeable individuals to compromise OMYA's competitive position. If necessary, OMYA would be willing to complete an Application for Confidential Treatment of Proprietary Information, similar to that provided by and returned to the ANR's Air Pollution Control Division relative to permit applications and annual emissions inventories.

If you have questions or require additional information, feel free to call me at (802) 770-7261.

Sincerely,

Neal Jordan
Manager of Environmental & Regulatory Affairs

Enclosures (2)

Cc: S. Thompson