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<br />~`'~`E~ST"'~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />'' ~ REGION 8 <br />~~r/J ~ 999 18T" STREET -SUITE 300 <br />~~ DENVER, CO 80202-2466 <br />,~,T ~G.~ http://www.epa.gov/region08 <br />Ref: 8P-W-GW <br />ADDENDUM <br />TO THE <br />STATEMENT OF BASIS (SOB) <br />MINOR PERMIT MODIFICATION No. 8 <br />EPA FINAL AREA PERMIT <br />No. C030858-00000 <br />Class III SOLUTION MINING WELLS <br />YANKEE GULCH PROJECT <br />Rio Blanco County, Colorado <br />In the initial UIC Area Permit (No. C030858-00000) for the Yankee Gulch Sodium <br />Project, the operator was required to plug and abandon all wells used for injection once mining <br />was complete. The plugging and abandonment procedure was specified in Appendix C of the <br />Final Permit which is as follows: <br />Individual wells shall be plugged and abandoned upon retirement. Plugging and <br />abandonment will take place once it has been determined that there shall be no potential <br />further use of a well, either for mining, testing, monitoring, or other purpose. <br />Immediately prior to plugging and abandoning, the tubing system shall be <br />removed from the intermediate casing. <br />The plugging and abandonment plan (Appendix C), submitted by the Permittee <br />and revised by the EPA, consists of one (1) plug with the following specifications. A cast <br />iron bridge (CIBP) shall be set inside the intermediate casing at approximately the bottom <br />of the casing. American Soda will establish a cement plug from above the CIBP to the <br />surface. If it is not possible to run a CIBP inside the intermediate casing due to well bore <br />irregularities, acement basket shall be run in the hole to establish the cement plug at the <br />bottom of the intermediate casing. <br />Both the surface and intermediate casings shall be cut down to 1 to 3 feet below <br />ground level to salvage the wellhead. Cutting down the casings will also allow <br />for more complete surface reclamation, which was recently requested by the <br />BLM. This plan has been revised and approved by the EPA and is consistent with <br />UIC requirements. <br />The cement plug shall be set using one or more of the approved methods <br />described in 40 CFR § 146.10. The number of sacks used for the cement plug <br />SOB for Minor Modification No. 8 UIC Permit No. C030858-00000 Page 1 of 4 <br />Pdnted on Recycled Paper <br />