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• 3.0 PREVENTION AND PREPAREDNESS Normal values for operating parameters, such as pressure, temperature, density, and flow rate will be measured, recorded, and reported to a central control system at 10- minute intervals. Therefore, information regarding fluctuations in parameter values would be promptly available to operating personnel. Additionally, the central control system will include an alarm that will be activated in the event of a substantial pressure drop. Measurements for all parameters will be taken at each well head and pressure will be measured at select points along the main header. Therefore, should a piping failure occur, determination of the failure location would be simplified. The Yankee Gulch Project will operate 24 hours per day, 365 days per year. Personnel will be on site at all times. Specific personnel will be assigned to the well field area of the Piceance Site. A complete visual inspection of the well field piping will be performed at least twice per shift. Personnel that perform inspections of piping will undergo regular spill recognition and response training. Well field personnel will communicate with the plant operator via 2-way radio. 4.0 SPILL RESPONSE American Soda will designate a Response Coordinator and Response Team as described in the preliminary Response Plan. All designated personnel will receive sufficient training on how to recognize and respond to well field piping spills. Depending on the nature, location, and quantity of a spill, American Soda personnel or a contracted spill response company will clean up spills. A list of emergency contacts will be located near all on site telephones. The list will include contracted spill response companies. In the event of a fluctuation in operating parameters that indicate a failure within the well field piping (such as a pressure drop or differing inflow and outflow values in a piping segment), the plant operator would take the following response actions. In the event of an obvious release of sodium solutions from well field piping (such as a catastrophic pipe failure), the operator response steps would be limited to steps three through five. 1. Notification would be made to the well field personnel and/or the Response Coordinator and instrumentation would be checked to confirm that it is calibrated properly and in good working order. 2. If instrumentation is in good working order, the operator would then provide additional information to the Response Coordinator. The Response Coordinator would subsequently notify the Plant Manager and/or General Manager and the portion of the well field that is served by the failed piping segment would be shut Preliminary Response Plan Yankee Gulch Sodium Minerals Project Amencan Soda, L.L.P, 4