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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 86fr3567 <br />FAX: (303) 832.8106 <br />May 4, 2004 ~ <br />Mr. Ed Cooley <br />American Soda, LLP <br />2717 County Road 215 <br />Pazachute, CO 81635 <br />RE: American Soda, LLP, Yankee Gulch Minerals Project, Permit No. M-1999-002 <br />We1120-74 and Temporary Cessation Status <br />Deaz Mr. Cooley, <br />COLORADO <br />DIVISION OF <br />MIN&RALS <br />GEOLOGY <br />RECLANATION•MINING <br />rAf FTY•5<IENCf <br />Bill Owens <br />Governor <br />Russell Geolge <br />Executive Director <br />Ronald W. Cattany <br />Division Director <br />Natural Resource Trustee <br />This letter is to clarify your questions regazding We1120-74 and provide guidance for American Soda to <br />transition the Yankee Gulch Mine into Temporary Cessation (TC) status. <br />weu 2a~a <br />During the meeting on Apri122, 2004 between American Soda, DMG, EPA and BLM, American Soda <br />requested that We1120-74 be increased an additional 10 feet in diameter for a total diameter of 220 feet. <br />Well 20-74 is surrounded by two other active wells to the north and south a[ a distance of 3001ineaz feet <br />(wells 20-31 and 20-33). We1120-31 has been mined to a diameter of approximately 139 feet and well <br />20-33 has been mined to a diameter of approximately 143 feet. To the west, We1120-32 maintains a <br />distance of 600 linear feet. The 112 permit does address spacing between adjacent cavities at a <br />minimum intact pillaz width of 50 feet between adjacent cavities to prevent cross communication of the <br />mining fluids and cavity collapse in the direction of the dissolution surface. <br />It is the Division's understanding that wells 20-31 and 20-33 will continue to be mined until July 1, <br />2004, but will not increase substantially in size due to the phasing down of the operation. With the <br />additional 10 feet, the pillar spacing between wells 20-74 and 20-31 will be maintained at approximately <br />122 feet and the spacing between wells 20-74 and 20-33 will be approximately 123.5 feet. The <br />diameters provided by American Soda aze determined by volumes removed using the assumption that <br />the cavities have developed as uniform cylinders. Dissolution of rich beds of nahcolite could result in <br />non-uniform cavity shape where diameters in limited horizons could be substantially lazger than those <br />provided by the company. That is why the permit requires cavity chazacterization prior to infilling close <br />spaced wells in the mining pattern. The current well spacing prior to cavity chazacterization is <br />conservative to approve adding another 10 feet in diameter to 20-74 at this time. However, any <br />additional increase in diameters on well on 300 foot spacing will require results from the cavity <br />characterization study. <br />Temporary Abandonment of Production Wells and Temnorarv Cessation (TCl Status <br />American Soda informed the Division Uhat the Piceance Operations will be phased down starting July 1, <br />2004 and the facility and well field will be mothballed. American Soda is in the process of developing <br />the necessary plans and making required procedural changes to ensure that the temporary cessation of <br />the facilities will comply with all federal, state, and local regulations. American Soda intends to <br />maintain the status of permits, leases and bonding requirements so that operations can be re-established <br />at any time in the future. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />