2025-08-28_HYDROLOGY - M1983194 (7)

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Natural Soda LLC 2024 Project Status Report & Annual Plan of Development 13 January 2025 4.0 2024 Project Activities 4.1. On-Site Facilities and Process Description 4.1.1. General Arrangement (Figure 5 provides an overview of the NS process flow.) 4.1.2. Lab Operation / Sanitation / ISO In 2024, activities continued in the NS laboratory to provide analysis for process control, quality assurance, and regulatory requirements. • Plant operators performed process control analyses. • Chloride levels were monitored by both operations and laboratory personnel on USP grades to ensure USP standards were met. • The USP test for insoluble materials was conducted on a per lot basis by laboratory personnel and a filter test for insoluble materials was conducted on the dry product once per shift by NS operators. • Pests were controlled with the use of two UV bug lights and rodent traps around the interior and exterior walls of the plant. Bait stations replaced external traps at the Rifle warehouse. • GMP/ISO/Sanitation training was provided for employees as required. • A food safety audit for FSSC 22000 was conducted for which NS maintained GFSI certification. • CDPHE, NSF, OMRI, Kosher, Halal, Non-GMO, CleanGredients and ISO 9001 certifications were maintained. 4.1.3. Process, Utilities, Facilities • On March 5, 2024, NS noted a pinhole leak in the barren pipeline fitting weld. This small leak affected soil near the southwest portion of the parking lot area and was contained within a soil berm. The leak was repaired, and the affected soil was disposed of properly. NS submitted a Report of Undesirable Event to BLM and DRMS the same day the leak was identified and followed up with agencies on remediation options. • June 10 – 17, the NS plant underwent the yearly common outage, where all production wells were shutdown. NS boiled out both production trains and completed annual maintenance and inspections on common systems (boilers, electrical switchgear, cooling tower, wellfield pipelines, etc.). • The NS truck scale removal and replacement project began on June 10th. The replacement was successful, and the scale began operations on June 20th.