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(Page 2) <br />MINE ID # OR PROSPECTING ID # M-1999-002 <br />INSPECTION DATE 12/18/03 INSPECTOR'S INITIALS ESC <br />OBSERVATIONS <br />This was an inspection of the Yankee Gulch Sodium Minerals Project conducted by Erica <br />Crosby of the Colorado Division of Minerals and Geology. Kit Reed and Tom Jacobson of <br />American Soda L.L.P were present during the 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 inspection started at the Piceance Site Processing Facility. Construction of the <br />facility was completed in 2000 and includes solution mining equipment, control room, <br />administrative offices, maintenance shop, and pumps and boilers used to facilitate the <br />solution mining process. The evaporation pond northwest of the processing facility was <br />under a light blanket of snow cover. The HDPE liner and spillways appeared to be in <br />good repair. <br />According to the 2002-2003 Annual Report, 34 drill pads were constructed during the summer <br />and fall of 2000. From 2000 to 2003, it appears that a total of 26 wells were drilled and <br />completed. The inspection focused on the lower well field of the lat five-year mining <br />panel. <br />Over the last several months, solution-mining activities have been curtailed in a number <br />of production wells in the lower well field. Well 20-14 ceased operation on August 27, <br />2003 due to nitrogen leak at the well head, well 20-12 ceased operation on September 23, <br />2003 due to negative mass balance after depressurization was initiated on well 20-14, well <br />20-12 ceased operation on September 23, 2003 due to loss of mechanical integrity of the <br />well casing, well 20-11 ceased operation on September 26, 2003 due to negative mass <br />balance after initial pressure decrease from shut in of well 20-12 and well 21-15 ceased <br />operation on September 26, 2003 due to negative mass balance. All of the wells noted <br />above were placed on standby to determine if pressure and possibly fluids from the mining <br />operations have entered the Dissolution Surface Aquifer. According to American Soda, <br />L.L.C. during the third quarter of 2003 there was a significant increase in the water <br />level as measured in monitoring well 21-4DX and a slight increase in the level measured in <br />monitoring well 21-3D. It was initially not detected in well 21-4Dx due to an <br />instrumentation problem with the electronic probe. The problem has since been corrected <br />and a new series of manual measures are made on the monitoring wells. <br />Wells 21-15 and 20-14 are currently being depressurized. American Soda plans to also <br />depressurize, plug and abandon wells 20-02 (along with 21-15 and 20-14) during the la` <br />quarter of 2004 to prevent any future effects on the dissolution zone. Well 20-11 will be <br />further evaluated after these wells are plugged to determine if it can be brought back <br />into operation or needs to be plugged and abandoned. Wells that will stay on line in the <br />lower well field include 20-19, 20-16, 29-20 and 29-24. In addition, future drilling in <br />the lower well field may be abandoned. <br />The following well sites were inspected during the inspection; <br />• Well 29-24; Close to completion and location of the cavity characterization study. <br />During a meeting on 12-16-03 between American Soda, DMG, EPA and BLM a new <br />technology was presented to characterize the cavity (TRT Survey) at the Yankee Gulch <br />Mine. Sonar is placed down 2 holes containing sources and receivers where the <br />velocity of the distribution is measured. A combined tomogram from the three subset <br />of sources and receivers delineates the cavern boundaries (source and receivers <br />placed at the top of cavern, at the same elevation below the top of the cavern and <br />receivers above the sources in both caverns). This method is vertically more <br />precise than horizontally and would have a minimum and maximum range. The precise <br />