2010-11-19_REVISION - M1983194

• Permit No: M1983194
• IBM Index Class Name: REVISION
• Doc Date: 11/19/2010
• Doc Name: Request to update the Permit & Inccrease permit acreage AM-03
• From: Daub & Associates, Inc.
• To: DRMS
• Type & Sequence: AM3
• Email Name: THM
• Media Type: D
• Archive: No

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DAUB & ASSOCIATES, INC. .'° tI)(yq` ?' °°a ate;
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November 19, 2010
Mr. Travis Marshall
Colorado Division of Reclamation Mining & Safety
Grand Junction Field Office
101 South 3`d, Suite 301
Grand Junction, CO 81501
1985'/2 SOUTH BROADWAY
GRAND JUNCTION, CO 81507-9649
[phone]
FAX [phone]
Email: [e-mail]
www.daubandassociates.com
NOV 19 21310
Subject: Natural Soda - Nahcolite Project, Request to Update the Permit and Increase
Permit Acreage for Permit No. M-1983-194, Amendment No. AM-03
Dear Mr. Marshall:
Natural Soda, Inc. (NSI) requests this amendment to increase NSI's permitted acreage from 73
acres (permitted in 1991) to 8223 acres. NSI currently holds four Department of Interior, Bureau
of Land Management (BLM) Sodium Leases which combine for a total acreage of approximately
8223 acres. NSI wishes to have its DRMS 112 mining permit acreage consistent with its four
federally issued Sodium Leases. This increase in permitted acreage will allow NSI to utilize its
lease areas, remain commercially viable and fulfill its federal mandate to extract sodium
minerals, for which, NSI pays royalties. Currently, NSI has 73 acres permitted for the plant site,
process and evaporation ponds and well field. As mining progresses, additional exploration
core holes and mining wells will need to be drilled. As stated in NSI's 2010 mine plan, affected
acreage is not expected to exceed approximately 260 acres. To enhance efficiency and reduce
the mine's footprint many of these wells will be recompleted as groundwater monitor wells and
undergo interim surface reclamation as approved by the DRMS in NSI's Mine Plan and
Environmental Monitoring Plan. It is NSI's policy to reclaim all disturbed areas as soon as
practical per established and approved guidelines.
In 1991, Amendment 02 to the M-1983-194 permit increased the permitted acreage from 43 to
73 acres. Original estimates from the 1987 BLM Environmental Impact Statement (EIS),
projected that NSI would disturb approximately 6 acres per year. The 73 acre permit limit was
the predicted amount of disturbance for the next five years (up through 1996). NSI remains
within the 73 acre permit limitation nineteen years after it was established and fourteen years
after that limit was projected to be reached. To date, in areas where nahcolite solution mining is
ongoing or has occurred, NSI's well field and access footprint is less than 1 acre in 10 (8.9%).
NSI is however, currently operating near the 73 acre permit limit and therefore, to continue to
function, as the responsible corporate citizen it has proven to be, requires an increase in
permitted acreage.
The 260 affected acre limit is based on an estimate of affected acreage over the operational life
of the mine from the EIS developed by the BLM. The DRMS approved 2010 Mine Plan was
written with the original EIS estimate of 260 affected acres in mind, and therefore requires no
changes. NSI wishes to explore for and solution mine, sodium minerals, on it's lease areas with
minimal impact to the land and environment.
SPECIALIZING IN PROFESSIONAL GEOLOGICAL, ENVIRONMENTAL, HYDROLOGICAL, GEOTECHNICAL AND PERMITTING SERVICES