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Ms. Barbara Coria <br />November 9, 2015 <br />Page 2 <br />As part of the mining operations at the Nahcolite Mine, there are extensive monitoring <br />operations and studies with respect to surface and subsurface subsidence and other potential <br />impacts on structures in the vicinity of the Nahcolite Mine. Figure 1 shows the lease area with the <br />utilities that cross the lease area and surface structures. Figure 2 shows in more detail the utilities <br />and structures in the immediate vicinity of the plant and wellfield. Of interest are the "structures <br />located within two hundred (200) feet of the operation or affected land." On both Figure 1 and 2, <br />the white dotted line indicates the border 200 feet from the operation, in this case, the lease <br />boundary. In some locations, the white line is 200 feet from wellheads that lie outside the lease <br />area. <br />Of note is the fact that there are no buildings (other than Natural Soda's plant and associated <br />buildings) within the lease area or within the 200 -foot buffer around the lease area. <br />Of interest are buried gas pipelines, above -ground electric transmission lines and power <br />lines, some of which are owned by Natural Soda and some of which are owned by others. Also <br />shown on the figures is the proposed 20+ -year mining area. This area consists of a small percentage <br />of the lease area. There are no long-range plans for developing outside the 20 -year mining area at <br />this point in time although the areas where attractive nacholite is are limited to a narrow area <br />trending to the northwest from the 20 -year mine area as shown in the yellow zone in Figure 1. <br />Figure 2 shows the location of the historical solution mining, the proposed wells to be <br />drilled in the near future and the location of historical surface subsidence monitoring locations <br />above the historically mined areas. Surface and subsidence monitoring has been ongoing since <br />1997. Table 1 shows the historical data from the 18 surface subsidence monitoring locations. This <br />data has been submitted to the United States Bureau of Land Management (BLM) semi-annually <br />(once every two years). There is a shift in the data due to a change in reference point. The <br />explanation of this shift is explained in the footnote to Table 1 which is reproduced below: <br />SSM surveys were begun in 1990 and were historically collected by Midford <br />Coolbaugh of Shale Country Surveying. Coolbaugh collected SSM surveys until <br />2008 when he moved out of the area. The Coolbaugh survey elevations are <br />generally consistent from year to year and reflect no surface subsidence between <br />1990 and 2008. In 2011 Richard Bullen with DR Griffith & Associates Inc. (DRG) <br />was contracted for the NS surveying operations. A review of DRG's survey data <br />and comparison to Coolbaugh's survey data revealed discrepancies in well <br />locations and well elevations. These discrepancies are attributed to differences in <br />technology, equipment type, NAD conversions, and surveyor datum. Coolbaugh <br />surveys were done by differential leveling using NAD29 (NGVD 29) datum. DRG <br />uses NAD83 (NAVD88) datum. In general, the DRG SSM surveys were noted to <br />have an elevation that was approximately 2.4 feet higher than the Coolbaugh <br />SSM surveys. The DRG updated survey data was used to generate a <br />comprehensive survey database. Accurate elevation data is vital for monitoring <br />groundwater,establishing stratigraphic tops and controls, and topographic <br />considerations such as pad/pipeline construction and reclamation. <br />Agapito Associates, Inc. <br />