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~ = h m~l ~ ~ _~ e 90 East Halsep RuaJ Parsippany, iv.l 07054 Tel: 973•i 150900 May 12, 1999 Mr. Allen Sorenson Reclamation Specialist Division of Minerals and Geology 1313 Sherman Street., Room 215 Denver, Colorado 80203 RE: Comments on Adeqaacy of the Reclamation Application, Yankee Gulch Project, File No. M-99-002 (American Soda) Dear Mr. Sorenson: We are in the process of reviewing the information provided by American Soda in support of their reclamation permit in order to provide comments no later than May 18th. Instead of waiting until all of our comments are assembled and sending you one packet we have assimilated some immediate concerns, based principally on apparent omissions, and will forward additional comments in an organized format as the comments become available. The immediate concerns are as follows: I. Missing Information The last information provided to us was that American Soda was classified as a designated mining operation (DMO) pursuant to C.R.S. 34-32-112.5. We agree that American Soda should be treated as a DMO. As a DMO, American Soda must provide an environmental protection plan (EPP). As of this writing we have not seen any summary reference document detailing each of the nineteen required elements of an EPP as listed in Rule 6.4.20. From what we have been provided in the original permit application and subsequent application submittals, the nineteen required elements have not been addressed in sufficiently organized fashion for us or for the DMG to provide a reliable evaluation. If the DMG believes that existing documents correspond to each of the nineteen required elements, we would be satisfied, for the purposes of being able to complete our comments, if you could contact us by telephone to draw our attention to the manner in which Rule 6.4.2.0 has been met. As a separate concern, Mr. Posey's hydrogeochemical review of April 17, 1999, wisely indicated that American Soda should provide supporting evidence that temperature controlled reprecipitation of dissolved solids can be considered an effective means to control leaks of process water to the upper aquifer, or other USDW's. We have not yet seen such evidence, or any related documentation or reference which support American Soda's assumption that such solids will form. As with the previous item, we would be satisfied, for purposes of being able to complete our comments, if you could direct our attention to materials which you believe constitute such evidence.