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,/--A m, r M . <br /> / 1985'/2 SOUTH BROADWAY <br /> DAUB & ASSOCIATES, INC. ;r}'s GRAND JUNCTION, CO 81507-9649 <br /> (970)254-1224 <br /> 1/t FAX 71 FAX(970)242-8438 <br /> email: gjdaub @daubandassociates.com <br /> www.daubandassociates.com <br /> December 18, 2014 RECEIVED <br /> Division of Reclamation, Mining and Safety <br /> Attn: Minerals Division `�fFr. 2 3 2014 <br /> 1313 Sherman Street, Room 215 DIVISION OF RECLAMATION <br /> Denver, CO 80203 MiN!NOFREC1 FEry <br /> Re: Natural Soda Holdings, Inc.f‘-2014-014 Response to NOI Second Notice of <br /> Deficiencies <br /> Natural Soda Holdings, Inc. (NSHI) hereby responds to the DRMS Second Notice of <br /> Deficiencies correspondence dated December 15, 2014 (Revised) and relating to NSHI's <br /> Notice of Intent (NOI) to Conduct Prospecting Operations for the experimental RD&D Oil <br /> Shale Project located in Rio Blanco County, CO, Sec 35, T1 S, R98W. The DRMS has <br /> associated that NOI with permit number P-2014-014. <br /> The DRMS second notice of deficiencies requested: <br /> 1. "an explanation as to why the TDS levels found in the 90-4 are much higher than the <br /> levels found in other A-Groove aquifers in the region". <br /> 2. A review of the DRMS Reclamation Cost Estimate attached to the DRMS December <br /> 15, 2014 correspondence. <br /> NSHI responds: <br /> 1. The 90-4 (A-Groove Aquifer monitor well) has had anomalous water chemistry since <br /> water quality sampling began in August 1990 prior to any mining activities by Natural <br /> Soda, Inc. A piper plot indicated that this well is distinctly different from other monitor <br /> wells. The 90-4 well is distinguished from the other AG, BG and DS Aquifer wells by <br /> having higher chloride concentrations relative to bicarbonate plus carbonate <br /> concentrations. Simple mixing of water from the DS Aquifer would not produce the <br /> concentrations observed in 90-4. The mixing of these waters would produce a result <br /> that is higher in bicarbonate and lower in chloride assuming a background <br /> concentration similar to other A-Groove or even B-Groove Aquifer monitoring wells. <br /> The cause of the anomalous well 90-4 water chemistry is unclear because a water <br /> source capable of producing the chemical concentrations observed in this well is not <br /> apparent. The groundwater chemistry suggests deep basin brine-type water with <br /> high chloride, and lower bicarbonate and carbonate. Possible causes may include <br /> stratigraphic, geologic or structural anomalies feeding into the A-Groove Aquifer near <br /> the well. <br /> 2. A review of the DRMS Reclamation Cost Estimate that was attached to the DRMS <br /> December 15, 2014 correspondence found no issues. NSHI understands that <br /> reclamation bonding in the amount of$156,566.01 will need to be in place prior to the <br /> issuance of the NOI or commencement of construction activities. <br /> SPECIALIZING IN PROFESSIONAL GEOLOGICAL, ENVIRONMENTAL, HYDROLOGICAL, GEOTECHNICAL AND PERMITTING SERVICES <br />