2021-03-08_GENERAL DOCUMENTS - M1983194 ‎(2)‎

• Permit No: M1983194
• IBM Index Class Name: General Documents
• Doc Date: 3/8/2021
• Doc Name: Correspondence
• From: Daug & Associates / Natural Soda LLC
• To: DRMS
• Email Name: ACY
• Email Name: THM
• Media Type: D
• Archive: No

1985'/s SOUTH BROADWAY
DAUB & ASSOCIATES, INC. �� GRAND JUNCTION, CO 81507-9649
f _ r 11� [phone]
�' 1 �� FAX[phone]
email: [e-mail]
www.daubandassociates.com
March 3, 2021
Division of Reclamation, Mining and Safety
Attn: Minerals Division,Amy Yeldell
1313 Sherman Street, Room 215
Denver, CO 80203
Re: Natural Soda LLC Nahcolite Project, File No. M-1983-194, Request for Technical Revision
Response
Dear Ms. Yeldell:
The following are the responses to the statements in the DRMS review of the 15H-IR-E courtesy pull
back notification dated February 22, 2021.
• DRMS statement: On February 26, 2021 the Division of Reclamation, Mining and Safety
(Division) received notification from Natural Soda, LLC of their intent to pull-back well 15H-IR-E.
Based on the information received, the Operator shall submit a Technical Revision, with the
required $1,006 revision fee, prior to modifying the well. The request should include the
proposed well configuration for 15H-IR-E and the revised abandonment prognosis.
o NS response: NS will provide the proposed well configuration (refer to amended
diagram). However, the proposed pull back operation does not affect the
abandonment prognosis in any way whatsoever. The pull back operation is isolated to
the production tubing within the lateral portion of the hole in the mining interval
below the Dissolution Surface. The well plug and abandonment prognosis remains
unchanged. This process is approved by the EPA in the NS UIC area permit as a
standard procedure, and does not require prior approval as it does not affect the
intermediate casing.
DRMS statement: A modification to a production well is considered a change to an
Environmental Protection Facility (EPF). Pursuant to Rule 7.3 approval must be granted by the
Division prior to work beginning on a facility. Similarly the Operator shall submit a certification
(completion report) to the Division once facility construction has concluded.
o NS Response: The production liner, as NS colloquially names it, or the production
tubing as the drilling industry might refer to it, only affects the mining interval below
the Dissolution Surface within the nahcolite bed. The liner, or tubing, is not cemented
and only controls the injection point and fluid movement within the nahcolite bed.
The production liner is not and should never be considered or referenced as an
Environmental Protection Facility; it does not protect environmental assets in any
way. The intermediate casing, however, is specifically designed to isolate the mined
interval from the aquifers above, and to isolate these aquifers from each other. The
pull back operation does not affect the intermediate casing in any way. As stated
before, the EPA allows NS to perform pull back operations on a routine basis as they
do not affect the cemented intermediate casing and the associated USDWs, or
Underground Sources of Drinking Water.
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