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<br /> <br />PRELIMINARY RESPONSE PLAN <br />YANKEE GULCH SODIUM MINERALS PROJECT <br />AMERICAN SODA, L.L.P. <br />1.0 INTRODUCTION <br />The Yankee Gulch Sodium Minerals Project (Yankee Gulch Project), operated by <br />American Soda, L.L.P. (American Soda), is a proposed nahcolite solution mining <br />operation near Meeker, Colorado, with associated processing facilities near Parachute, <br />Colorado. The Yankee Gulch Project will involve a mining operation with vertical <br />solution mining wells to extract naturally occurring bedded and disseminated nahcolite <br />deposits in the Piceance Creek Basin. Nahcolite will be mined under American Soda's <br />Yankee Gulch Joint Venture Leases (U.S. Sodium Lease Nos. C-0118328 and C-0118329). <br />The nahcolite solution will be processed into two principal products: sodium <br />bicarbonate (baking soda) and sodium carbonate (soda ash). <br />American Soda has operated a test mining facility since 1996 and is currently <br />undergoing permitting for the commercial phase. American Soda submitted a <br />Commercial Mine Plan to the BLM in August 1998. The BLM is required by the <br />National Environmental Policy Act (NEPA) and Council on Environmental Quality <br />directives to analyze potential effects on the environment from proposed actions <br />involving federal land and leases (40CFR 1500-1508). BLM is currently in the process of <br />developing an Environmental Impact Statement (EIS) for this project. A draft EIS has <br />been prepared and public comments have been received. <br />Several comments received during the public review period consisted of requests for <br />various safety plans and environmental response plans. In response to those <br />comments, American Soda has prepared this document to assist BLM in it's NEPA <br />analysis and public disclosure process. <br />This document has been prepared as a preliminary Response Plan that identifies the <br />various regulatory requirements, which will apply to the Yankee Gulch Project when <br />commercial operations commence. Some of the regulatory requirements related to <br />evaluating hazards, developing planning and prevention procedures, and identifying <br />response measures have been satisfied and that information is included in this Plan. <br />Because some of the final engineering design data are not yet available for the Yankee <br />Gulch Project, other regulatory requirements will need to be met in the final Response <br />Plan. The final Response Plan will be developed prior to startup of commercial <br />operations. <br />1 <br />Prelimmarv Response Plan <br />Yankee Gulch Sodium Minerals Pro~ea <br />American Soda, L.L.P. <br />