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COLORADO MINED LAND RECLAMATION BOARD REGULAR OPERATION (112) RECLAMATION PERMIT APPLICATION ADEQUACY RESPONSE 1. The Division of Mineral and Geology (DMG) has preliminarily determined that the Yankee Gulch Sodium Minerals Project (Yankee Gulch Project) is a Designated Mining Operation (DMO) as defined in Rule 1.1(14) of the Hard Rock/Metal Mining Rules and Regulations of the Mined Land Reclamation Board (Rules). As a DMO, American Soda is required to complete an Environmental Protection Plan (EPP), the required elements of which are listed in Rule 6.4.20. Each of the 19 elements of the EPP, as required in Rule 6.4.20, have been addressed in the Summary Reference Document, attached as Appendix A. DMG has determined that most of the elements required for an EPP have been included in American Soda's Colorado Mined Land Reclamation Board Regular Operation (112) Reclamation Permit Application (112 Permit Application) for the Yankee Gulch Project. A Groundwater and Surface Waver Monitoring Plan and a Subsidence Monitoring Plan have been submitted as technical revisions to the Application by letters dated April 16 and Apri123, 1999. As indicated by the DMG, these documents fill the most significant gaps in the current application relative to the requirements of the EPP. Included with this document, as Appendix B, is a letter from the Bureau of Land Management (BLM) granting approval of the Groundwater and Surface Water Management Plan. Available chemical analyses of the process solution have been included with this document as Appendix C. The information in Appendix C is confidential and proprietary. The data provided in this analysis have been collected for evaluation of the process and not as an environmental sample. A sample of the process solution will be collected and tested for the constituents listed in Table 3 Water Quality Parameters List 2 (WQ2) of the Groundwater and Surface Water Monitoring Plan. Please note that Table 3 has been revised to include aluminum and bromide. A copy of these data will be submitted to the DMG as soon as they are available. Data from the test phase indicate that the process solution is of very high quality with little contamination. Because concentrations of dissolved constituents other than product components are so low, there is no need to refine dissolved trace elements out of the process solution at the Piceance Site; therefore, a plan for disposal of these materials will not be required. The process solution would only be filtered to remove minor quantities of particulates from the solution. The filtered material is suitable For disposal in a landfill. ~:.\VYl~~nn AJFurv Ynp~ \~nlw W VT.~~YT Muunb fl,~ 1 Anwr~n StlL LLf.