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Request for Transfer of Minerals Permit <br /> and Succession of Operations <br /> Yankee Gulch Minerals Project <br /> Permit No. M-1999-002 <br /> Exhibit Y <br /> Certification of Prior and Current Violations <br /> The undersigned serves as Environmental Specialist of American Soda, LLC and its affiliates <br /> ("Solvay"), including the predecessor permit holders, has the requisite knowledge and <br /> experience to provide this Certificate, and hereby certifies as follows: <br /> 1. The Yankee Gulch Minerals Project(the"Project") has not operated as an active mine for <br /> the past 17 years. The changes in operator status that have occurred since 2015 relate to <br /> business structure changes rather than actual sales and/or purchases of the mine project. <br /> 2. At no time in the past 17 years has either legal entity, American Soda, LLP or its <br /> predecessor permittee, Solvay Chemicals, Inc., been the subject of a compliance <br /> enforcement action from any federal, state or municipal government agency with regard <br /> to the Project. <br /> 3. Compliance activities routinely completed since the cessation of mining activities have <br /> included but are not limited to: <br /> (a) Mechanical integrity testing ("MIT") of each production well according to schedule. <br /> Any wells that failed MIT were plugged and abandoned according to EPA-UIC <br /> criteria following the failed test as required. <br /> (b) Ground water monitoring and quarterly reporting with no indication of impacts from <br /> the mining. <br /> (c) Subsidence monitoring indicating no impact from the limited mining. Solvay placed <br /> wells at 600 foot spacing, not all planned wells were drilled, and due to the short time <br /> of mining the second pass at 300 foot spacing did not occur. Only one well produced <br /> the tonnage thought to represent nearly mined maximum cavity size. <br /> (d) Storm water monitoring and management of drainage features. <br /> (e) Regular regulatory inspections from EPA, DRMS and BLM. <br /> (f) Vegetation management for control of noxious weeds as defined by Rio Blanco <br /> County and BLM and maintenance of top soil piles and protection of arch and paleo <br /> sites. <br /> (g) Maintenance of security features when the mine was no longer staffed full time. <br /> (h) Plugging and abandonment of all remaining production wells and ground water <br /> monitoring wells. <br /> (i) Removal of all three buildings on the 0—5 year mine panel, including external <br /> process equipment and any waste materials. <br />