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DAUB & ASSOCIATES, INC. I� S <br />/7\ <br />RECEIVED <br />Nov 3 0 2015 <br />DIVISION OF RECLAMATION <br />MINING AND SAFETY <br />NATURAL SODA <br />1985 % SOUTH BROADWAY <br />GRAND JUNCTION, CO 81507-9649 <br />(970) 254-1224 <br />FAX (970) 242-8438 <br />email: gjdaub@daubandassociates.com <br />www.daubandassociates.com <br />y(fq3.)q9( <br />November 23, 2015 Submitted by Certified Mail/Return <br />Receipt on 11/23/15 <br />Ms. Wendy Cheung <br />U.S. Environmental Protection Agency, Region 8 <br />Mail Code: 8P-W-UIC <br />1595 Wynkoop Street <br />Denver, CO 80202-1129 <br />Subject: Comments Concerning the Natural Soda LLC Draft UIC Area Permit <br />(C030358-00000), 15H -I, 16H -I, 17H -I well permits, Aquifer Exemption, <br />and Statement of Basis <br />Dear Ms. Cheung: <br />Enclosed are Daub & Associates, Inc. and Natural Soda LLC comments regarding the <br />Draft UIC Permit C030358-00000 for Natural Soda's Nahcolite (sodium bicarbonate) <br />Solution Mine. Please refer to the attached six pages of comments. We feel that the <br />EPA has done a good job and should be commended on their efforts. <br />Daub & Associates has based our comments on over 35 years of detailed work, site <br />specific to the central Piceance Creek Basin and in particular, to the Natural Soda <br />sodium leases. Our work has included the geologic, hydrologic, engineering, drilling, <br />and rock mechanics aspects of Natural Soda's sodium leases. Daub & Associates has <br />also based their comments on the detailed evaluation of over 150,000 feet of drill core <br />from the Piceance Creek Basin. <br />Natural Soda utilizes solution mining of underground nahcolite deposits and recovers <br />the sodium bicarbonate (baking soda) in a surface processing and refining facility. The <br />sodium bicarbonate produced is currently available in several grades, meeting FSSC <br />22000, NSF/ANSI 60, ISO 9001 and other standards and certifications. National and <br />international (export) food, industrial and specialty markets are currently supplied by <br />NS. Examples of the many uses of sodium bicarbonate (to include environmentally <br />beneficial and friendly uses) are: water treatment, animal feed, fire extinguishers, baking <br />products, household cleaning, and flue gas treatment for removal of sulfur, nitrogen <br />oxides, and acid gases. <br />SPECIALIZING IN PROFESSIONAL GEOLOGICAL, ENVIRONMENTAL, HYDROLOGICAL, GEOTECHNICAL AND PERMITTING SERVICES <br />hW <br />