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The Division offers the following guidance regazding the temporary abandonment of production wells <br />and changing the mine status to temporary cessation for the Yankee Gulch 112 Permit. <br />The temporary abandonment of production wells will need to be filed as a technical revision to <br />the permit prior to initiating the activity. American Soda will need to specify the temporary <br />abandonment method and describe how the wells will be modified and be brought back into <br />production. This would essentially enable American Soda to have a temporary abandonment <br />plan in addition to a permanent closure plan. The revision will need to include the volumetric <br />flow and mass balance of the well outside of the limits set by the Commercial Mine Plan and <br />112 Permit. American Soda will also need to describe the methods to remove the production <br />tubing and the placement of the cast iron bridge plug or cement plug to the depth of the crown <br />pillar. <br />2. Upon the temporary and permanent abandonment of a production well, American Soda will <br />need to file an abandonment report to be included in the Annual Reclamation Report (unless <br />American Soda requests that the bond be released in part, then it should be filed with the release <br />request). The temporary/permanent abandonment report should include at a minimum; the well <br />number, the date of completion of abandonment, the location of the hole, a description of the <br />plugging, sealing and capping techniques and a completion diagram of the well. If such <br />information is also required by the BLM and EPA, then it may be submitted to the Division <br />under their format. <br />3. Temporary Cessation is where an operator temporarily ceases production of the mining <br />operation for 180~ays or more. American Soda can file for TC status prior to the completion of <br />the temporary or permanent abandonment of the production wells and other reclamation <br />activity. A copy of Rule 1.13 of the Hazd Rock/Metal Mining Rules pertaining to Temporary <br />Cessation status is enclosed for reference. American Soda my elect to reduce the water <br />monitoring program in the TC application, or as a separate revision to the permit. <br />4. If American Soda elects to have the bond reduced for wells that have been permanently plugged <br />and abandoned or other areas that have been reclaimed, the procedures of 4.13 and 4.16 of the <br />Hazd Rock/Metal Mining Rules and Regulations will need to be followed. Such request must be <br />in writing, and specify the amount of bond to be reduced based on reclamation of the site. The <br />Division will coordinate with the BLM regarding any release request. <br />If you have any questions, please do not hesitate to contact me at 303-866-4943. <br />Sitjc~ erely, f 1 <br />Enca S".p/Cvl,(r`odsby <br />Environmental Protection Sp ialist <br />Enclosure: <br />cc: Carl Mount; DMG (via e-mail) <br />Kent Walter; BLM <br />Paul Daggett; BLM <br />Dan Jackson; EPA <br />Elisabeth Evans; EPA <br />Sandy Stavncs; EPA <br />