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(Page 2) <br />MINE ID # OR PROSPECTING ID # M-1999-002 <br />INSPECTION DATB 06/29/04 INSPECTOR'S INITIALS ESC <br />OSS3RVATION3 <br />This was an inspection of the Yankee Gulch Sodium Minerals Project conducted by Erica <br />Crosby and Carl Mount of the Colorado Division of Minerals and Geology. Ed Cooley, Max <br />Ramey, Celina Akin and Tom Jacobson of American Soda L.L.P were present during the <br />inspection. <br />The mining and reclamation permit was issued to American Soda L.L.P. on July 16, 1999. <br />The total permit area is 4,084 acres whereas 512.5 acres is to be affected in the first <br />five-year panel block. The site is on land owned by the Bureau of Land Management (BLM). <br />The Division holds a bond in the amount of $236,424.00. The total reclamation cost <br />estimate for the Yankee Gulch Sodium Minerals Project totals $7,444,531.00, and the BLM <br />retains a majority of the bond. <br />The Division and American Soda discussed the Cavity Characterization Study for Well 28-21 <br />and the submittal of a revision to incorporate a reduced groundwater-monitoring plan based <br />on the mine shutdown status and changes to the NPL standards. On April 20, 2004 American <br />Soda notified the Division that the Piceance Operations will be phased down starting July <br />1, 2004. Due to the high energy costa and a depressed soda Ash market, the Sodium <br />Carbonate/Sodium Bicarbonate processing operations are operating at a net loss. American <br />Soda has started the process to phase down, curtail the mining operations, mothball the <br />facilities and maintain the operations so that they can be re-established in the future. <br />American Soda will place a number of wells in a state of temporary abandonment using the <br />following procedures: <br />• Injection into each well will be ceased and the well will be depressurized by allowing <br />production flow to continue with the assistance of a booster pump. During the period of <br />shutting in the well the volumetric flow and mass balance will be well outside of the <br />limits set by the UIC Permit, Commercial Mine Plan and 112 Permit. <br />• At the time a well is placed in Temporary Abandonment Status there will be no injection <br />into that well until such time that a Mechanical integrity Test has been conducted and <br />permission is received to once again commence injection. During the transition from <br />normal operation to Temporary Abandonment the requirement to maintain a plus or minus <br />158 volumetric flow balance will need to be waived. <br />• Once a well has been depressurized the production tubing will be removed and a cast <br />iron bridge plug or cement plug will be placed in the casing as close as possible to <br />the bottom of the crown pillar. Once the plugs are in place a Mechanical Integrity Test <br />will be performed on the well. A Mechanical integrity Test will be conducted on two- <br />year intervals for as long as the well is in Temporary Abandonment. <br />• All wells to be placed in Temporary Abandonment Status are deemed to be candidates for <br />future operation. Any wells that are not deemed to be candidates for future operations <br />will be plugged and abandoned. <br />• The pipeline system used to supply inject brine to the well field and recover <br />production brine from the well field will be flushed, drained, sealed and maintained in <br />a mothballed condition until such time as the operations are restarted. <br />• Once the well field is depressurized the well field pump house systems and gas <br />separator systems will be flushed, drained, and sealed. Instrumentation skids at well <br />sites that are scheduled for future operations will be mothballed, locked and left in <br />place. Instrumentation skids for wells that are to be Plugged and Abandoned will be <br />removed from the well site and placed in storage. <br />• The Process Plant Equipment at the Piceance Facility will be flushed, drained, sealed, <br />purged and blanketed as required to protect the equipment during the mothball period. <br />Required electrical power will remain to supply power as needed to conduct preventive <br />maintenance procedures during the mothball period. <br />• The two intra-plant pipelines will be evaluated as to other possible short-term uses <br />than their current operation of supplying water and production brine to and from the <br />Parachute and Piceance Facilities. If some other use is found then they will be placed <br />in that service and any modifications to existing permits and right of ways will be <br />made as necessary to allow for these changes. If no other options are found then these <br />