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<br />r7 <br />Comments on American Soda Colorado Mined Land <br />Reclamation Board Regular Operation (112) <br />Reclamation Permit Application <br />January 1999 <br />Comment 1 The American Soda Operation Solution Mines Nacholite And Should Be <br />Designated A Mining Operation (Regular 112 Reclamation Permit Application Yankee <br />Gulch Minerals Project -Letter No. 124-486 and Exhibit T) <br />Why isn't the American Soda mining operation a °designated mining operation "? <br />Why doesn't American Soda want to be included in this category? What are the <br />various ramifications regarding this designation? What would American Soda be <br />required to do if they were included in this category? What scientific evidence and <br />discussion has been provided by American Soda to conclude that the solution mining <br />process will not result in the exposure or disturbance of any acid- or toxic- forming <br />materials (Also see comment 20). <br />Comment 2 Extraction Temperatures Exceed Sodium Lease Limitations (Mining Method, <br />Pg. D-2 and Preference Right Sodium Lease Serial Number C-0118328) <br />American Soda has two preference right sodium leases which authorize it to develop <br />the sodium resource. The terms of these preference right leases explicitly state that the <br />lessee is not to "utilize process solutions in excess of 300° Fahrenheit for in situ <br />solution mining of sodium compounds without the express permission of the authorized <br />officer." (Lease, Part I, Sections 4(a)(1)). While American Soda has been provided <br />written authorization to operate at temperatures as high as 400°F for the two preference <br />right sodium leases being evaluated in the experimental phase (Bureau of Land <br />Management Letter to American Soda Dated May 8, 1998 Re:Sodium Leases C- <br />0118328, C-0118329 and C-0120057 Mining Temperatures), the Federal Sodium <br />Leases pertaining to this permit application contain stipulations which limit American <br />Soda to operate at 300°F. The Reclamation Permit Application specifically states <br />American Soda will operate at temperatures as high as 420°F. Under what <br />circumstances does the Division of Minerals and Geology approve permit applications <br />which violate their current Federal Sodium Lease stipulation? Has all the information <br />provided in this permit application been developed based on operating American Soda's <br />operation at 420°F? If not, how can the Permit be approved to operate at 420°F when <br />the impact and consequences of such activities have not yet been characterized? <br />Page 1 <br />