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(Page 3) <br />MINE ID # OR PROSPECTING ID # M-1999-002 <br />INSPECTION DATE 06/29/04 <br />INSPECTOR'S INITIALS ESC <br />lines will be flushed, drained and protected as required to assure their future <br />availability for use. <br />• The existing Evaporation and Storm Water Ponds will remain in use and will be monitored <br />as required. <br />• After completion of Plugging and Abandonment of selected wells an evaluation will be <br />made as to partial or complete reclamation of effected well sites and roads. <br />Reclamation and re-vegetation will be conducted as prescribed by permit requirements <br />and as influenced by weather factors. <br />• A Technical Revision will be filed with the Colorado Division of Minerals and Geology <br />to place the operations in a status of Temporary Cessation. A request will be placed <br />with the Bureau of Land Management to temporarily suspend mining activities under the <br />Sodium Minerals Leases. A Modification to the UIC Area Wide Permit will be initiated <br />to make appropriate changes in the UIC Permit concerning construction requirements for <br />new Class III production wells and changes to the Ground water Monitoring Plan and <br />Subsidence Monitoring Plan to modify sampling requirements and types of monitoring <br />systems. <br />American Soda is in the process of permanently abandoning 8 production wells (20-2, 20-3, <br />20-11, 20-14, 21-15, 21-16, 28-17 and 28-41) and placing 22 wells in a Temporary Cessation <br />Status/Long Term Standby (20-36, 20-32, 20-35, 20-31, 20-74, 20-33, 20-30, 20-76, 29-34 <br />29-29, 29-78, 29-68, 29-28, 29-26, 29-23, 29-27, 29-22, 29-53, 29-24, 28-21, 29-20, 20- <br />19). One well was only completed to a depth of 250 feet (29-51), and another well is <br />being converted to a subsidence monitoring well (20-12). <br />The following well sites were inspected during the inspection; <br />• well 29-20; In the process of depressurizing. Will be placed in long term standby <br />• Well 20-12; This well was converted to a subsidence monitoring well. A TDR (Time <br />Reflectometry) Cable has been installed, but the bottom of the cable appears to be <br />deteriorating. According to American Soda pressure above 600 psi starts to collapse <br />the cable and takes away the resolution below 1,160 feet. The top of the well <br />casing will be removed down from 1' to 3' and capped. <br />• Well 20-11; completely plugged with Class G cement (35~ silica flour required by <br />BLM). <br />• Well 20-3; has been cemented to the top of the well. The casing will be cut. The <br />pipe removed from the well was stacked adjacent to the site. The well was in <br />production for 7 years, and the pipe is in good repair. Pipe will be sold for <br />salvage cost. <br />• Well 20-2; has been cemented to the top of the well. The skid will be removed and <br />the pipe will be used for future wells. <br />• Well 20-14; American Soda has experienced problems installing bridge plugs or <br />cement baskets. On 6-3-04, American Soda performed a video inspection on both of <br />the 7" casings. The video indicated a parted casing on both the long and short 7" <br />casings at a depth of 1,394 feet. American Soda proposed to set a 10'-20' bentonite <br />clay plug below the split casing in well 20-14 and fill the 7" casing with cement to <br />the surface. During the depresauring of the well, the hose was not hooked up into <br />the tubing and brine was released on the pad area. American Soda will remove the <br />material from the surface area and dispose of in a local landfill. It appears that <br />the brine extended down the hill and killed some sage brush within the permit area. <br />• Well 21-15; has been plugged with cement and the casing wellhead will be cut, capped <br />and labeled. <br />• Well 21-16; has been plugged with cement and the casing wellhead will be cut, capped <br />and labeled. <br />• Well 28-17; has been plugged with cement and the casing wellhead will be cut, capped <br />and labeled. <br />• Well 28-41; has been plugged with cement and the casing wellhead will be cut, capped <br />and labeled. <br />• Well 29-51; was only drilled to 250 feet. The well was sealed. The mud pit will <br />