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.~ ~~ .A ,.~ ~~ ~. o~ W^ v v ~F~ o~ 0 w~ ~~ .. ;; , ~. A ~ '~ .. z U ~ N G ,j N mavwran" American Soda Change in Operation Status ~/til-/99j- oat ~.' ~~ ~O, /~yLJ~ 4merican Soda's Sodium Minerals Solution Mining and Sodium :,arbonate/Sodium Bicarbonate processing operations are currently operating at a net loss due to high energy costs and a depressed Soda Ash market. In order :o adjust to these economic factors and maintain a reasonable opportunity for short term profitability and long term viability for the recovery of Nacholite from :he Sodium Mineral Leases, American Soda is proceeding with the following plan ~f action: the Piceance Operations which are conducted on Federal Lands will be phased sown starting July 1, 2004 and the facility and well field will be mothballed. 4merican Soda is in the process of developing the necessary plans and making ~equired procedural changes and notifications to Federal, State and Local agencies to assure that actions taken during the phase down, curtailment of operations and mothballing of the facilities comply with all regulations and that the status of permits, leases and bonding are maintained so that operations can be re-established at any time in the future. This document is to inform the BLM, CDMG and EPA of the actions that have been taken to date and the proposed actions going forward. We are requesting your guidance in the formulation and execution of these actions to ascertain that compliance with permits is maintained at all times. In order to assure the possible restart of well field operations at a future time the wells will be placed in a state of Temporary Abandonment using the following procedures: Injection into each well will be ceased and the well will be depressurized by allowing production flow to continue with the assistance of a booster pump. During this period of shutting in the well the volumetric flow and mass balance will be well outside of the limits set by the UIC Permit, Commercial Mine Plan and 112 Permit. By copy of this communication American Soda is notifying the EPA, CDMG and BLM that at the time a well is placed in Temporary Abandonment Status there will be no injection into that well until such time that a Mechanical Integrity Test has been conducted and permission is received to once again commence injection. During the transition from normal operation to Temporary Abandonment the requirement to maintain a plus or minus 15% volumetric flow balance will necessarily need to be waived. Once a well has been depressurized the production tubing will be removed and a cast iron bridge plug or cement plug will be placed in the casing as close as possible to the bottom of the crown pillar. Once the plugs are in place a Mechanical Integrity Test will be performed on the well. As per EPA Regulations