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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br />REGION 8 <br />999 18T"STREET -SUITE 300 <br />DENVER, CO 80202-2486 <br />Phone 800-227-8917 <br />http://www.epa. govlregion08 <br />ADDENDUM <br />To The <br />Statement of Basis (SOB) <br />for <br />Permit Modification No. 9 <br />Major Modification <br />of <br />Environmental Protection Agency (EPA) Final Area Permit <br />No. C030858-00000 <br />Class III Solution Mining Wells <br />Yankee Gulch Project <br />Rio Blanco County, Colorado <br />On September 24, 2004, Steigers Corporation,'onthe behalf of American Soda, L.L.P., filed a <br />request for a modification of Area Permit No. C03858-00000. This Permit governs the Yankee Gulch <br />Sodium Minerals Project in northwest Colorado, where underground injection activities associated with <br />solution mining of sodium bicarbonate at the Piceance Facility have been carved out on a commercial scale <br />since 2000. For the purpose of this Permit and SOB, the term commercial scale means the injection, <br />circulation, recovery or production of fluids for sale or pilot testing of a new application. Additionally, for <br />the purpose of this SOB and the associated Permit Modification, the Assistant Regional Administrator, <br />Office of Partnerships and Regulatory Assistance is the approving Official for the Pernvt Modification and <br />is referred to as the "Director" throughout the SOB and Permit Modification. <br />Since American Soda began operating under the terms of its Class III UIC Area Permit (Permit No. <br />C03858-00000), American Soda has gained considerable operating and monitoring experience at the <br />Yankee Gulch Project (Project). Based on that experience and changes in the operating plans for the <br />Project, American Soda is requesting several modifications to the UIC permit. The requested modifications <br />pertain to 1) subsidence monitoring, 2) establishing an injection interval, 3) temporary suspension of <br />injection operations, and 4) ground water monitoring. The proposed request by American Soda is based on <br />consultation with EPA, Bureau of Land Management (BLM), and Colorado Division of Mines and Geology <br />(CDMG) to develop a common understanding and an acceptable approach to these issues for both American <br />Soda and the agencies. <br />Draft Addendum to SOB For Modification No. 9, UIC Area Permit No. C030858-00000 Page 1 of27 <br />