10-K/A - NRP - Equibles

--12-31FY2023

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UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-K/A

(Amendment No. 1)

☒	ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2023 or

☐	TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from to

Commission file number: 001-31465

NATURAL RESOURCE PARTNERS LP
	(Exact name of registrant as specified in its charter)
Delaware	35-2164875
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(State or other jurisdiction of<br> incorporation or organization)	(I.R.S. Employer<br> Identification No.)

1415 Louisiana Street, Suite 3325

Houston, Texas 77002

(Address of principal executive offices)

(Zip Code)

(713) 751-7507

(Registrant’s telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Act:

Title of each class	Trading Symbol(s)	Name of each exchange on which registered
Common Units representing limited partner interests	NRP	New York Stock Exchange

Securities registered pursuant to Section 12(g) of the Act: None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ☐ No ☒

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ☐ No ☒

Indicate by check mark whether the registrant: (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes ☒ No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes ☒ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting company, or an emerging growth company. See definition of "accelerated filer", "large accelerated filer", "smaller reporting company," and "emerging growth company" in Rule 12b-2 of the Exchange Act.

Large Accelerated Filer	☐	Accelerated Filer	☒
Non-accelerated Filer	☐	Smaller Reporting Company	☐
		Emerging Growth Company	☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report ☒

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act) Yes ☐ No ☒

The aggregate market value of the common units held by non-affiliates of the registrant on June 30, 2023, was $474 million based on a closing price on that date of $52.74 per unit as reported on the New York Stock Exchange.

12,960,064

Documents incorporated by reference: None.

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EXPLANATORY NOTE

On April 30, 2024, Natural Resource Partners L.P. (the “Partnership”) received a comment letter from the United States Securities and Exchange Commission (the "SEC") indicating that its Annual Report on Form 10-K for the fiscal year ended December 31, 2023, as originally filed with the SEC on March 7, 2024 (the “Original Report”) omitted mineral property disclosures and a Technical Report Summary related to Sisecam Wyoming LLC ("Sisecam Wyoming"). Following correspondence between the Partnership and the SEC, the SEC directed the Partnership to amend its Original Report. As such, the Partnership hereby files this Amendment No. 1 (the “Amendment”) to its Original Report to align with certain of the technical requirements of subpart 1300 of Regulation S-K (“S-K 1300”) as well as to include the related risk factors associated with these mineral property disclosures and Technical Report Summary. This Amendment is being filed to (i) amend “Items 1. and 2. Business and Properties,” “Item 1A. Risk Factors”, and (ii) file “Exhibit 96.1 Technical Report Summary for Sisecam Wyoming LLC.” These disclosures can be found in this Amendment on pages 11-18, 27 and Exhibit 96.1. The correspondence between the Partnership and the SEC will be posted in the future on the SEC's website at www.sec.gov.

The technical data underlying the mineral resources and reserves estimates included in this Amendment, including the internal controls for determining and reporting such mineral resources and reserves estimates, are maintained by Sisecam Wyoming, and our agreements with Sisecam Wyoming do not give us (i) access to such underlying technical data sufficient to specifically confirm the opinion of the qualified person with respect to such resources and reserves or (ii) the ability to monitor or enforce Sisecam Wyoming's internal controls for determining and reporting such resources and reserves. Sisecam Wyoming has, however, made representations to us and the qualified person that it does not have reason to believe that the underlying technical data is materially misleading, that and Sisecam Wyoming's internal controls were applied to the mineral resource and reserve information contained in the report are materially misleading. We are providing this information because it represents the information that we have in our possession and we do not have a reasonable ground to believe that it is inaccurate, but we caution investors that we have relied on the qualified person and Sisecam Wyoming with respect to the preparation of the mineral resources and reserves estimates included in this report and are not able to independently verify its accuracy. Investors are cautioned to consider such risks when reviewing the mineral resources and reserves estimates included in this report.

Outside of changes to the items and exhibit as noted above and the certifications of the Chief Executive Officer and Chief Financial Officer, this Amendment does not otherwise amend, supplement, update or revise any portion of the Original Report which remains unchanged since the date of its filing. Furthermore, this Amendment does not change any previously reported financial results, nor does it reflect events occurring after the date of the Original Report. Information not affected by this Amendment remains unchanged and reflects the disclosures made at the time the Original Report was filed. Accordingly, this Amendment should be read in conjunction with the Original Report and the Company’s other filings with the SEC subsequent to the filing of the Original Report.

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TABLE OF CONTENTS

Risk Factors Summary		ii
PART I
Items 1. and 2.	Business and Properties	1
Item 1A.	Risk Factors	23
PART IV
Item 15.	Exhibits, Financial Statement Schedules	34
Signatures		38

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RISK FACTORS SUMMARY

We are subject to a variety of risks and uncertainties, including risks related to our business, risks related to our indebtedness, risks related to our common units and certain general risks, which could have a material adverse effect on our business, financial condition, results of operations and cash flows. Risks that we deem material are described under “Risk Factors” in

Item 1A

of this Amendment. These risks include, but are not limited to, the following:

Risks Related to Our Business

•	Cash distributions are not guaranteed and may fluctuate with our performance and the establishment of financial reserves. In addition, our debt agreements and our partnership agreement place restrictions on our ability to pay, and in some cases raise, the quarterly distribution under certain circumstances.
•	Our leverage and debt service obligations may adversely affect our financial condition, results of operations and business prospects.
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•	Global pandemics, including the COVID-19 pandemic, have in the past and may continue to adversely affect our business.
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•	Prices for both metallurgical and thermal coal are volatile and depend on a number of factors beyond our control. Declines in prices could have a material adverse effect on our business and results of operations.
•	Prices for soda ash are volatile. Any substantial or extended decline in soda ash prices could have an adverse effect on Sisecam Wyoming’s ability to continue to make distributions to us.
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•	We derive a large percentage of our revenues and other income from a small number of coal lessees.
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•	Bankruptcies in the coal industry, and/or the idling or closure of mines on our properties could have a material adverse effect on our business and results of operations.
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•	Mining operations are subject to operating risks that could result in lower revenues to us.
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•	The adoption of climate change legislation and regulations restricting emissions of greenhouse gases and other hazardous air pollutants have resulted in changes in fuel consumption patterns by electric power generators and a corresponding decrease in coal production by our lessees and reduced coal-related revenues.
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•	Concerns about the environmental impacts of coal combustion, including perceived impacts on global climate issues, are also resulting in unfavorable lending and investment policies by institutions and insurance companies which could significantly affect our ability to raise capital or maintain current insurance levels.
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•	Increased attention to climate change, environmental, social and governance ("ESG") matters and conservation measures may adversely impact our business. ****
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•	In addition to climate change and other Clean Air Act legislation, our businesses are subject to numerous other federal, state and local laws and regulations that may limit production from our properties and our profitability.
•	If our lessees do not manage their operations well, their production volumes and our royalty revenues could decrease.
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•	We have limited approval rights with respect to the management of our Sisecam Wyoming soda ash joint venture, including with respect to cash distributions and capital expenditures. In addition, we are exposed to operating risks that we do not experience in the royalty business through our soda ash joint venture and through our ownership of certain coal transportation assets.
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•	Sisecam Wyoming's deca stockpiles will substantially deplete by 2024, and its production rates will decline if Sisecam Wyoming does not make further investments or otherwise execute on one or more initiatives to prevent such decline.
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•	Sisecam Wyoming's reserve and resource data are estimates based on assumptions that may be inaccurate and are based on existing economic and operating conditions that may change in the future, which could materially and adversely affect the quantities and value of Sisecam Wyoming's reserves and resources.
•	Fluctuations in transportation costs and the availability or reliability of transportation could reduce the production of coal, soda ash and other minerals from our properties.
•	Our lessees could satisfy obligations to their customers with minerals from properties other than ours, depriving us of the ability to receive amounts in excess of minimum royalty payments.
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•	A lessee may incorrectly report royalty revenues, which might not be identified by our lessee audit process or our mine inspection process or, if identified, might be identified in a subsequent period.
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Risks Related to Our Structure

•	Unitholders may not be able to remove our general partner even if they wish to do so.
•	The preferred units are senior in right of distributions and liquidation and upon conversion, would result in the issuance of additional common units in the future, which could result in substantial dilution of our common unitholders’ ownership interests.
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•	We may issue additional common units or preferred units without common unitholder approval, which would dilute a unitholder’s existing ownership interests.
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•	Our general partner has a limited call right that may require unitholders to sell their units at an undesirable time or price.
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•	Cost reimbursements due to our general partner may be substantial and will reduce our cash available for distribution to unitholders.
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•	Conflicts of interest could arise among our general partner and us or the unitholders.
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•	The control of our general partner may be transferred to a third party without unitholder consent. A change of control may result in defaults under certain of our debt instruments and the triggering of payment obligations under compensation arrangements.
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•	Unitholders may not have limited liability if a court finds that unitholder actions constitute control of our business.
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Tax Risks to Common Unitholders

•	Our tax treatment depends on our status as a partnership for U.S. federal income tax purposes as well as our not being subject to a material amount of entity-level taxation by individual states. If the Internal Revenue Service ("IRS") were to treat us as a corporation for U.S. federal income tax purposes or we were to become subject to material additional amounts of entity-level taxation for state tax purposes, then our cash available for distribution to unitholders would be substantially reduced.
•	The tax treatment of publicly traded partnerships or an investment in our units could be subject to potential legislative, judicial or administrative changes or differing interpretations, possibly applied on a retroactive basis.
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•	Certain U.S. federal income tax preferences currently available with respect to coal exploration and development may be eliminated as a result of future legislation.
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•	Our unitholders are required to pay taxes on their share of our taxable income even if they do not receive any cash distributions from us. Our unitholders' share of our portfolio income may be taxable to them even though they receive other losses from our activities.
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•	We may engage in transactions to reduce our indebtedness and manage our liquidity that generate taxable income (including income and gain from the sale of properties and cancellation of indebtedness income) allocable to our unitholders, and income tax liabilities arising therefrom may exceed any distributions made with respect to their units.
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•	If the IRS contests the U.S. federal income tax positions we take, the market for our units may be adversely impacted and the cost of any IRS contest will reduce our cash available for distribution to our unitholders.
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•	If the IRS makes audit adjustments to our income tax returns, it (and some states) may assess and collect any taxes (including any applicable penalties and interest) resulting from such audit adjustments directly from us, in which case our cash available for distribution to our unitholders might be substantially reduced.
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•	Tax gain or loss on the disposition of our common units could be more or less than expected.
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•	Our unitholders may be subject to limitation on their ability to deduct interest expense incurred by us.
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•	Tax-exempt entities face unique tax issues from owning our units that may result in adverse tax consequences to them.
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•	Non-U.S. unitholders will be subject to U.S. federal income taxes and withholding with respect to their income and gain from owning our units.
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•	We will treat each purchaser of our common units as having the same tax benefits without regard to the actual common units purchased. The IRS may challenge this treatment, which could adversely affect the value of the common units.
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•	We have adopted certain valuation methodologies in determining a unitholder’s allocations of income, gain, loss and deduction. The IRS may challenge these methodologies or the resulting allocations, and such a challenge could adversely affect the value of our common units.
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•	We generally prorate our items of income, gain, loss and deduction between transferors and transferees of our common units each month based upon the ownership of our common units on the first day of each month, instead of on the basis of the date a particular unit is transferred. The IRS may challenge this treatment, which could change the allocation of items of income, gain, loss and deduction among our unitholders.
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•	A unitholder whose units are the subject of a securities loan (e.g., a loan to a "short seller" to cover a short sale of units) may be considered as having disposed of those units. If so, such unitholder would no longer be treated for tax purposes as a partner with respect to those units during the period of the loan and may recognize gain or loss from the disposition.
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•	As a result of investing in our units, our unitholders are likely subject to state and local taxes and return filing requirements in jurisdictions where we operate or own or acquire property.
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General Risks

•	Our business is subject to cybersecurity risks.

Additional risks and uncertainties not presently known to us or that we currently deem immaterial also may have an adverse effect on our business, financial condition, results of operations, and cash flows.

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PART I

As used in this Amendment, unless the context otherwise requires: "we," "our," "us" and the "Partnership" refer to Natural Resource Partners L.P. and, where the context requires, our subsidiaries. References to "NRP" and "Natural Resource Partners" refer to Natural Resource Partners L.P. only, and not to NRP (Operating) LLC or any of Natural Resource Partners L.P.’s subsidiaries. References to "Opco" refer to NRP (Operating) LLC, a wholly owned subsidiary of NRP, and its subsidiaries. NRP Finance Corporation ("NRP Finance") is a wholly owned subsidiary of NRP and was a co-issuer with NRP on the 9.125% senior notes due 2025 (the "2025 Senior Notes").

ITEMS 1. AND 2. BUSINESS AND PROPERTIES

Partnership Structure and Management

We are a publicly traded Delaware limited partnership formed in 2002. We own, manage and lease a diversified portfolio of mineral properties in the United States, including interests in coal and other natural resources and own a non-controlling 49% interest in Sisecam Wyoming LLC ("Sisecam Wyoming"), a trona ore mining and soda ash production business.

Our business is organized into two operating segments:

Mineral Rights—consists of approximately 13 million acres of mineral interests and other subsurface rights across the United States. If combined in a single tract, our ownership would cover roughly 20,000 square miles. Our ownership provides critical inputs for the manufacturing of steel, electricity and basic building materials, as well as opportunities for carbon sequestration and renewable energy. We are working to strategically redefine our business as a key player in the transitional energy economy in the years to come.

Soda Ash—consists of our 49% non-controlling equity interest in Sisecam Wyoming, a trona ore mining and soda ash production business located in the Green River Basin of Wyoming. Sisecam Wyoming mines trona and processes it into soda ash that is sold both domestically and internationally into the glass and chemicals industries.

Our operations are conducted through Opco and our operating assets are owned by our subsidiaries. NRP (GP) LP, our general partner (the "general partner" or "NRP GP"), has sole responsibility for conducting our business and for managing our operations. Because our general partner is a limited partnership, its general partner, GP Natural Resource Partners LLC (the "managing general partner"), conducts its business and operations and the board of directors and officers of GP Natural Resource Partners LLC make decisions on our behalf. Robertson Coal Management LLC ("RCM"), a limited liability company indirectly owned by Corbin J. Robertson, Jr., owns all of the membership interest in GP Natural Resource Partners LLC. Pursuant to the Board Representation and Observation Rights Agreement entered into in 2017 with certain entities controlled by funds affiliated with Blackstone Inc. (collectively referred to as "Blackstone") and affiliates of GoldenTree Asset Management LP (collectively referred to as "GoldenTree"), Blackstone was entitled to appoint one person to the board of directors of GP Natural Resource Partners LLC (the "Board of Directors"). However, in 2023, we repurchased all of Blackstone's preferred units, which were subsequently retired and no longer remain outstanding, and all rights of Blackstone related thereto ceased as a result. In connection with the repurchase, Blackstone's board designee resigned from the Board of Directors and all members of the Board of Directors are now appointed by RCM.

The senior executives and other officers who manage NRP are employees of Western Pocahontas Properties Limited Partnership or Quintana Minerals Corporation, which are companies controlled by Mr. Robertson, Jr. These officers allocate varying percentages of their time to managing our operations. Neither our general partner, GP Natural Resource Partners LLC, nor any of their affiliates receive any management fee or other compensation in connection with the management of our business, but they are entitled to be reimbursed for all direct and indirect expenses incurred on our behalf.

We have regional offices through which we conduct our operations, the largest of which is located at 5260 Irwin Road, Huntington, West Virginia 25705 and the telephone number is (304) 522-5757. Our principal executive office is located at 1415 Louisiana Street, Suite 3325, Houston, Texas 77002 and our telephone number is (713) 751-7507.

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Segment and Geographic Information

The amount of 2023 revenues and other income from our two operating segments is shown below. For additional business segment information, please see "Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations—Results of Operations" and "Item 8. Financial Statements and Supplementary Data—Note 7. Segment Information" in our Annual Report on Form 10-K filed with the SEC on March 7, 2024.

(In thousands)	Amount
Mineral Rights	$	296,612	80	%
Soda Ash		73,397	20	%
Total	$	370,009	100	%

The following map shows the approximate geographic distribution of our ownership footprint:

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Mineral Rights Segment

Mineral Rights

We do not mine, drill or produce minerals. Instead, we lease our acreage to companies engaged in the extraction of minerals in exchange for the payment of royalties and various other fees. The royalties we receive are generally a percentage of the gross revenue received by our lessees. The royalties we receive are typically supported by a floor price and minimum payment obligation that protect us during significant price or demand declines.

The majority of our Mineral Rights segment revenues come from royalties related to the sale of coal from our properties. Our coal is primarily located in the Appalachia Basin, the Illinois Basin and the Northern Powder River Basin in the United States. We lease our coal to experienced mine operators under long-term leases. Approximately two-thirds of our royalty-based leases have initial terms of five to 40 years, with substantially all lessees having the option to extend the lease for additional terms. Leases include the right to renegotiate royalties and minimum payments for the additional terms. We also own and manage coal-related transportation and processing assets in the Illinois Basin that generate additional revenues generally based on throughput or rents. We also own oil and gas, industrial minerals and aggregates that generate a portion of the Mineral Rights segment revenues. Additional Mineral Rights segment revenues come from carbon neutral initiatives such the sale of carbon offset credits from our forestlands, potential sub-surface carbon dioxide sequestration in our pore space and opportunities to generate geothermal energy from our ownership.

Under our standard royalty lease, we grant the operators the right to mine and sell our minerals in exchange for royalty payments based on the greater of a percentage of the sale price or fixed royalty per ton of minerals mined and sold. Lessees calculate royalty payments due to us and are required to report tons of minerals mined and sold as well as the sales prices of the extracted minerals. Therefore, to a great extent, amounts reported as royalty revenues are based upon the reports of our lessees. We periodically audit this information by examining certain records and internal reports of our lessees and we perform periodic mine inspections to verify that the information that our lessees have submitted to us is accurate. Our audit and inspection processes are designed to identify material variances from lease terms as well as differences between the information reported to us and the actual results from each property.

In addition to their royalty obligations, our lessees are often subject to minimum payments, which reflect amounts we are entitled to receive even if no mining activity occurs during the period. Minimum payments are usually credited against future royalties that are earned as minerals are produced. In certain leases, the lessee is time limited on the period available for recouping minimum payments and such time is unlimited on other leases.

Because we do not operate, our royalty business does not bear ordinary operating costs and has limited direct exposure to environmental, permitting and labor risks. Our lessees, as operators, are subject to environmental laws, permitting requirements and other regulations adopted by various governmental authorities. In addition, the lessees generally bear all labor-related risks, including retiree health care costs, black lung benefits and workers’ compensation costs associated with operating the mines on our coal and aggregates properties. We pay property taxes on our properties, which are largely reimbursed by our lessees pursuant to the terms of the various lease agreements.

The SEC amended the property disclosure requirements for registrants with significant mining activities, effective for the fiscal year 2021, with new rules which we comply with in this Amendment. The rules contain exceptions that allow royalty companies, such as NRP, to omit information that they lack access to and cannot obtain without incurring an unreasonable burden or expense. As a royalty company, we do not have access to the information required to prepare the technical reports used to determine reserves under the rules, and we are not able to obtain such information without unreasonable burden or expense. The rules require that reserve estimates be based on and disclosures include technical reports prepared using extensive mine-specific geological and engineering data, as well as market and cost assumptions that we as a mineral owner do not have, including, but not limited to a) site infrastructure costs; b) processing plant costs; c) detailed analysis of environmental compliance and permitting requirements; d) detailed baseline studies with impact assessment; and e) detailed tailings disposal, reclamation and mitigation plans. Our leases do not require the operators of our material properties to prepare technical report summaries or permit us the access and information sufficient to prepare our own technical report summaries under the rules. As a result, we are relying on the royalty company exceptions and have ceased to report coal and other hard mineral reserves.

In addition to summary information about our overall portfolio of mineral rights, this section provides detailed information about four properties in our Mineral Rights segment. These properties were determined to be material to our business based on historical revenue compared to our Mineral Rights segment considered as a whole. These four properties are: 1) Alpha-CAPP (VA), 2) Oak Grove, 3) Williamson, and 4) Hillsboro. We have also included a description of other significant properties, which have had lower revenues historically than our material properties but are important to our business.

Coal

Metallurgical Coal

Metallurgical (“Met”) coal is used to fuel blast furnaces that forge steel and is the primary driver of our long-term cash flows. Met coal is a high-quality, cleaner coal that generates exceptionally high temperatures when burned and is an essential element in the steel manufacturing process. Metallurgical coal is a finite and declining resource, particularly in industrialized nations. We believe the indispensable role met coal plays in manufacturing steel combined with the increasing scarcity of the resource will provide support for this portion of our business for decades to come. Our metallurgical coal is located in the Northern, Central and Southern Appalachian regions of the United States.

Thermal Coal

Thermal coal, sometimes referred to as steam coal, is used in the production of electricity. The amount of thermal coal produced in the United States has been steadily falling over the last decade as energy providers shift from coal-fired plants to natural gas-fired facilities, and to a lesser extent, alternative energy sources such as geothermal, wind and solar. We believe the long-term secular decline experienced by thermal coal over the last decade will continue. That fact, combined with the long-term strength of our metallurgical business and the carbon neutral initiatives we discuss below, will result in thermal coal becoming a diminishing contributor to NRP in years to come. The vast majority of our thermal sales are located in Illinois and its operations are some of the most cost-efficient mines east of the Mississippi River. The remainder of our thermal coal is located in Montana, the Gulf Coast and Appalachia.

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Coal Production Information

The following tables present the type of coal sales volumes by major coal region for the years ended December 31, 2023, 2022 and 2021:

For the Year Ended December 31, 2023
	Type of Coal				****	****
(Tons in thousands)	Thermal		Metallurgical		Total
Appalachia Basin
Northern		794		351		1,145
Central		1,418		12,509		13,927
Southern		—		2,670		2,670
Total Appalachia Basin		2,212		15,530		17,742
Illinois Basin		8,119		—		8,119
Northern Powder River Basin		4,589		—		4,589
Gulf Coast		1,477		—		1,477
Total		16,397		15,530		31,927
For the Year Ended December 31, 2022
---	---	---	---	---	---	---
	Type of Coal				****	****
(Tons in thousands)	Thermal		Metallurgical		Total
Appalachia Basin
Northern		1,166		530		1,696
Central		1,186		12,460		13,646
Southern		93		1,691		1,784
Total Appalachia Basin		2,445		14,681		17,126
Illinois Basin		11,135		—		11,135
Northern Powder River Basin		4,288		—		4,288
Gulf Coast		385		—		385
Total		18,253		14,681		32,934
For the Year Ended December 31, 2021
---	---	---	---	---	---	---
	Type of Coal				****	****
(Tons in thousands)	Thermal		Metallurgical		Total
Appalachia Basin
Northern		718		617		1,335
Central		1,140		11,139		12,279
Southern		119		1,452		1,571
Total Appalachia Basin		1,977		13,208		15,185
Illinois Basin		9,388		—		9,388
Northern Powder River Basin		3,151		—		3,151
Gulf Coast		55				55
Total		14,571		13,208		27,779

Major Coal Producing Properties

The following table provides a summary of our significant coal royalty properties for 2023 and is followed by additional information for each property:

Region	Property/Lease Name	Operator(s)	Coal Type
Appalachia Basin
Central	Alpha-CAPP (VA)	Alpha Metallurgical Resources Inc.	Met
Central	Kepler	Alpha Metallurgical Resources Inc.	Met
Central	Elk Creek	Ramaco Royalty Company, LLC	Met
Central	Coal Mountain	ECP	Met
Southern	Oak Grove	Hatfield Metallurgical Coal Holdings, LLC	Met
Illinois Basin	Williamson	Foresight Energy Resources LLC	Thermal
Illinois Basin	Hillsboro	Foresight Energy Resources LLC	Thermal
Northern Powder River Basin	Western Energy	Rosebud Mining, LLC	Thermal

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Appalachia Basin—Central Appalachia

*Alpha-CAPP (VA).*The Alpha-CAPP (VA) property is located in Wise, Dickenson, Russell and Buchanan Counties, Virginia. Substantially all of the tons sold from this property in 2023 were metallurgical coal. We lease this property to subsidiaries of Alpha Metallurgical Resources Inc. ("Alpha") and previously leased it to subsidiaries of Contura Energy, Inc. The current lease with Alpha expires at the end of 2028 and will automatically renew unless otherwise notified. We receive payments based on the greater of a percentage of the sale price or fixed royalty per ton of coal mined and sold. In addition to the royalty obligations, this lease is subject to minimum payments, which reflect amounts we are entitled to receive even if no mining activity occurs during the period. Minimum payments are credited against future royalties that are earned as minerals are produced and the lessee is time limited on the period available for recouping minimum payments. Production comes from underground room and pillar and surface mines and is trucked to one of two preparation plants. Coal is shipped via the CSX and Norfolk Southern railroads to domestic and export metallurgical customers. The book value of this property was $46.3 million at December 31, 2023.

Below is a map of our Alpha-CAPP (VA) property:

Elk Creek. The Elk Creek property is located in Logan and Wyoming Counties, West Virginia. We lease this property to Ramaco Resources, Inc. Metallurgical coal is produced from surface and underground mines and is transported by belt and truck to a preparation plant on the property. Coal is shipped via the CSX railroad to both domestic and export metallurgical customers.

Coal Mountain. The Coal Mountain property is located in Wyoming County, West Virginia. We lease this property to ECP. Metallurgical coal is produced from a multi-seam surface mine and coal is transported by truck to a preparation plant on the property. Coal is shipped via the Norfolk Southern railroad to both domestic and export metallurgical customers.

Kepler. The Kepler property is located in Wyoming County, West Virginia. Substantially all of the coal sold from this property in 2023 was metallurgical coal. We lease this property to a subsidiary of Alpha. Coal is produced from underground mines and transported by belt or truck to the preparation plant on the property. Coal is shipped via the Norfolk Southern railroad to export metallurgical customers.

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Appalachia Basin—Southern Appalachia

Oak Grove. The Oak Grove property is located in Jefferson County, Alabama. We currently lease this property to a subsidiary of Hatfield Metallurgical Coal Holdings, LLC ("Hatfield Metallurgical"). Previous operators of this property were Murray Metallurgical Coal Holdings LLC, Mission Coal, LLC, and Seneca Resources, LLC. The current lease with Hatfield Metallurgical expires in 2024 and will automatically renew unless otherwise notified. We receive payments based on the greater of a percentage of the sale price or fixed royalty per ton of coal mined and sold. In addition to the royalty obligations, this lease is subject to minimum payments, which reflect amounts we are entitled to receive even if no mining activity occurs during the period. Minimum payments are credited against future royalties that are earned as minerals are produced and the lessee is time limited on the period available for recouping minimum payments. Metallurgical coal production comes from a longwall mine and is transported by beltline to a preparation plant. Metallurgical products are then shipped via railroad and barge to both domestic and export customers. The book value of this property was $3.5 million at December 31, 2023.

Below is a map of our Oak Grove property:

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Illinois Basin

Williamson. The Williamson property is located in Franklin and Williamson Counties, Illinois. This property is under leases to Williamson Energy, a subsidiary of Foresight Energy Resources LLC ("Foresight"). The current leases expire in 2026 and 2033 and will automatically renew unless otherwise notified. We receive payments based on the greater of a percentage of the sale price or fixed royalty per ton of coal mined and sold. In addition to the royalty obligations, these leases are subject to minimum payments, which reflect amounts we are entitled to receive even if no mining activity occurs during the period. Minimum payments are credited against future royalties that are earned as minerals are produced and the lessee is time limited on the period available for recouping minimum payments. Thermal coal production comes from a longwall mine. Coal is shipped primarily via the Canadian National railroad to export customers. The book value of this property was $37.0 million at December 31, 2023.

Below is a map of our Williamson property:

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Hillsboro. The Hillsboro property is located in Montgomery and Bond Counties, Illinois. This property is under lease to Hillsboro Energy, a subsidiary of Foresight. The current lease expires in 2033 and will automatically renew unless otherwise notified. We receive payments based on the greater of a percentage of the sale price or fixed royalty per ton of coal mined and sold. In addition to the royalty obligations, this lease is subject to non-recoupable minimum payments, which reflect amounts we are entitled to receive even if no mining activity occurs during the period. Thermal coal production comes from a longwall mine. Coal is shipped by rail via either the Union Pacific, Norfolk Southern or Canadian National railroads, or by barges to domestic utilities customers. The book value of this property was $209.3 million at December 31, 2023.

Below is a map of our Hillsboro property:

In addition to these properties, we own loadout and other transportation assets at the Williamson mine and at the Macoupin and Sugar Camp mines, which are also operated by Foresight. See "—Coal Transportation and Processing Assets" below for additional information on these assets.

Production at the Foresight Macoupin mine was temporarily ceased in March 2020. Foresight is no longer obligated to make royalty, transportation fee, or quarterly minimum payments to us under the Macoupin coal mining lease and transportation agreements. Foresight will instead pay an annual Macoupin fee of $2.0 million to NRP each year through 2026. Foresight also forfeited its right to recoup all previously paid but unrecouped minimum payments with respect to the Macoupin mine. At all times that the Macoupin mine remains in temporary cessation of production, Foresight will take reasonable actions to preserve, protect, and store the equipment, infrastructure, and property located at the mine.

Beginning January 1, 2027, we may at any time elect to cause Foresight to transfer the Macoupin mine and all associated equipment and permits to us for no consideration. If we make this election, we will assume all liabilities associated with the Macoupin mine. Also beginning January 1, 2027, Foresight may at any time elect to offer to sell the Macoupin assets to us for $1.00. If we accept Foresight’s offer, we will assume all liabilities associated with the Macoupin mine. If we do not accept Foresight’s offer, Foresight may proceed to permanently seal the Macoupin mine and conduct all reclamation activities. To the extent the elections described above are not made, Foresight will continue to pay the annual $2.0 million fee to NRP each year that the mine remains in temporary cessation of production. In addition, Foresight may determine at any time to recommence operations at the Macoupin mine, at which time we and Foresight will negotiate in good faith to enter into new coal mining lease and transportation agreements applicable to the Macoupin mine.

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Northern Powder River Basin

Western Energy. The Western Energy property is located in Rosebud and Treasure Counties, Montana. We lease this property to a subsidiary of Rosebud Mining, LLC. Thermal coal is produced by surface dragline mining methods. Coal is transported by either truck or beltline to the Colstrip generation station located at the mine mouth.

Coal Transportation and Processing Assets

We own transportation and processing infrastructure related to certain of our coal properties, including loadout and other transportation assets at Foresight's Williamson mine in the Illinois Basin, for which we collect throughput fees or rents. We lease our Williamson transportation and processing infrastructure to a subsidiary of Foresight and are responsible for operating and maintaining the transportation and processing assets at the Williamson mine that we subcontract to a subsidiary of Foresight. In addition, we own rail loadout and associated infrastructure at the Sugar Camp mine, an Illinois Basin mine also operated by a subsidiary of Foresight. While we own coal at the Williamson mine, we do not own coal at the Sugar Camp mine. The infrastructure at the Sugar Camp mine is leased to a subsidiary of Foresight and we collect minimums and throughput fees. We recorded $14.9 million in revenue related to our coal transportation and processing assets during the year ended December 31, 2023.

We also own transportation and processing infrastructure, including loadout and other transportation assets at Foresight's Macoupin mine. As previously mentioned, the Macoupin mine was temporarily ceased in March 2020 and Foresight is no longer obligated to make transportation fee payments to us under the transportation agreements.

Oil and Gas / Industrial Minerals / Construction Aggregates

Our oil and gas properties are predominately located in Louisiana and during 2023, we received $7.4 million in oil and gas royalty revenues. Our various industrial mineral and construction aggregates properties are located across the United States and include minerals such as limestone, frac sand, copper, lead and zinc. We lease a portion of these minerals to third parties in exchange for royalty payments. The structure of these leases is similar to our coal leases, and these leases typically require minimum rental payments in addition to royalties. During 2023, we received $2.9 million in aggregates royalty revenues, including overriding royalty revenues.

Carbon Neutral Initiatives

We continue to explore and identify alternative carbon neutral revenue sources across our large portfolio of surface, mineral, and timber assets, including the permanent sequestration of carbon dioxide ("CO2") underground and in standing forests, and the generation of electricity using geothermal, solar and wind energy, as well as lithium production. As with our existing mineral activities, we do not plan to develop or operate carbon sequestration or carbon neutral energy projects ourselves but we plan to lease our acreage to companies that will conduct those operations in exchange for payment of royalties and other fees to us. While the timing and likelihood of additional cash flows being realized from these activities is uncertain, we believe our large ownership footprint throughout the United States provides additional opportunities to create value in this regard and position us as a key beneficiary of the transitional energy economy with minimal capital investment.

We executed our first carbon neutral project in the fourth quarter of 2021 through the sale of 1.1 million carbon offset credits for $13.8 million. The offset credits were issued to us by the California Air Resources Board under its cap-and-trade program and represent 1.1 million metric tons of carbon sequestered in approximately 39,000 acres of our forestland in West Virginia. We have the ability to harvest and sell future timber growth and in 2023, we sold carbon offset credits related to 2022 growth for $0.6 million.

Carbon Sequestration. We own approximately 3.5 million acres of specifically reserved subsurface rights in the southern United States with the potential for permanent sequestration of greenhouse gases. The carbon capture utilization and storage industry (“CCUS”) is in its infancy and the future is highly uncertain, but a few facts are clear. A sequestration project requires acreage possessing unique geologic characteristics, close proximity to sources of industrial-scale greenhouse gas emissions or direct air capture capability, and the appropriate form of legal title that grants the acreage owner the right to sequester emissions in the subsurface. While carbon sequestration rights and ownership continue to evolve, we believe we own one of the largest inventory of acreage with potential for carbon sequestration activities in the United States.

In the first quarter of 2022 we executed our first subsurface CO2 sequestration lease on 75,000 acres of underground pore space we own in southwest Alabama with the potential to store over 300 million metric tons of CO2. In October of 2022, we announced our second subsurface CO2 transaction with the execution of a lease for approximately 65,000 acres of pore space we control near southeast Texas with estimated storage capacity of at least 500 million metric tons of CO2. In total, we have approximately 140,000 acres of pore space under lease for carbon sequestration with estimated CO2 storage capacity of 800 million metric tons.

Renewable Energy. In addition, we believe portions of our asset base across the United States possess the geologic characteristics and geographical locations necessary for geothermal, solar and wind energy development. With regards to geothermal, the technology to generate safe and reliable “green” electricity using heat found deep underground is advancing rapidly. Once limited to the geologic “hot spots,” new technology has made geothermal energy projects feasible in many places previously thought impossible. Our geothermal opportunities are predominately located in the South, Midwest and Northwest parts of the United States. In the third quarter of 2022 we executed our first geothermal lease with the potential to generate up to 15 megawatts of electricity. With regards to wind and solar energy opportunities, we are actively engaged in discussions for potential use of our acreage for these types of renewable energy developments predominantly in Kentucky and West Virginia. In the first quarter of 2023 we executed a new solar lease.

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Soda Ash Segment

We own a 49% non-controlling equity interest in Sisecam Wyoming. Prior to 2023, Sisecam Resources LP owned 51% interest in Sisecam Wyoming. Sisecam Resources LP was a publicly traded master limited partnership that depended on distributions from Sisecam Wyoming in order to make distributions to its public unitholders. In 2023, Sisecam Resources LP was dissolved and Sisecam Chemicals Wyoming LLC ("SCW LLC") became the direct owner of 51% of Sisecam Wyoming. SCW LLC, our operating partner, controls and operates Sisecam Wyoming. SCW LLC is 100% owned by Sisecam Chemicals Resources LLC ("Sisecam Chemicals,") which is 60% owned by Sisecam USA Inc. ("Sisecam USA") and 40% owned by Ciner Enterprises Inc. ("Ciner Enterprises"). Sisecam USA is a direct wholly-owned subsidiary of Türkiye Şişe ve Cam Fabrikalari A.Ş, a Turkish Corporation ("Şişecam Parent"), which is an approximately 51%-owned subsidiary of Turkiye Is Bankasi Turkiye Is Bankasi ("Isbank"). Şişecam Parent is a global company operating in soda ash, chromium chemicals, flat glass, auto glass, glassware glass packaging and glass fiber sectors. Şişecam Parent was founded over 88 years ago, is based in Turkey and is one of the largest industrial publicly-listed companies on the Istanbul exchange. With production facilities in several continents and in several countries, Sisecam is one of the largest glass and chemicals producers in the world. Ciner Enterprises is a direct wholly-owned subsidiary of WE Soda Ltd., a U.K. Corporation (“WE Soda”). WE Soda is a direct wholly-owned subsidiary of KEW Soda Ltd., a U.K. corporation (“KEW Soda”), which is a direct wholly owned subsidiary of Akkan Enerji ve Madencilik Anonim Şirketi (“Akkan”). Akkan is directly and wholly owned by Turgay Ciner, the Chairman of the Ciner Group (“Ciner Group”), a Turkish conglomerate of companies engaged in energy and mining (including soda ash mining), media and shipping markets. Sisecam Wyoming mines trona and processes it into soda ash that is sold both domestically and internationally into the glass and chemicals industries. As a minority interest owner in Sisecam Wyoming, we do not operate and are not involved in the day-to-day operation of the trona ore mine or soda ash production plant. We appoint three of the seven members of the Board of Managers of Sisecam Wyoming and have certain limited negative controls relating to the company. We have limited approval rights with respect to Sisecam Wyoming, and our partner controls most business decisions, including decisions with respect to distributions and capital expenditures.

Sisecam Wyoming is one of the largest and lowest cost producers of soda ash in the world, serving a global market from its facility located in the Green River Basin of Wyoming. The Green River Basin geological formation holds the largest, and one of the highest purity, known deposits of trona ore in the world. Trona, a naturally occurring soft mineral, is also known as sodium sesquicarbonate and consists primarily of sodium carbonate, or soda ash, sodium bicarbonate and water. Sisecam Wyoming processes trona ore into soda ash, which is an essential raw material in flat glass, container glass, detergents, chemicals, paper and other consumer and industrial products. The vast majority of the world’s accessible trona is located in the Green River Basin. According to historical production statistics, approximately 30% of global soda ash is produced by processing trona, with the remainder being produced synthetically through chemical processes. The costs associated with procuring the materials needed for synthetic production are greater than the costs associated with mining trona for trona-based production. In addition, trona-based production consumes less energy and produces fewer undesirable by-products than synthetic production.

Sisecam Wyoming’s Green River Basin surface operations consist of leased and licensed subsurface mining areas in Wyoming. The facility is accessible by both road and rail. Sisecam Wyoming uses large continuous mining machines and underground shuttle cars in its mining operations. Its processing assets consist primarily of material sizing units, conveyors, calciners, dissolver circuits, thickener tanks, drum filters, evaporators and rotary dryers.

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The following map provides an aerial overview of the Green River Basin surface operations:

The following map shows the known sodium leasing area within the Green River Basin, including the boundaries of Sisecam Wyoming's leased and licensed subsurface mining:

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The Green River Basin geological formation holds the largest, and one of the highest purity, known deposits of trona ore in the world. Sisecam Wyoming's reserves contain trona deposits having a purity between 80% and 89% by weight, which means that insoluble impurities and water make up approximately 11% to 20% of Sisecam Wyoming's trona.

Sisecam Wyoming's mining leases and license are located in two mining beds, designated by the U.S. Geological Survey as beds 24 and 25, at depths of 850 to 800 feet near their shaft locations, respectively, below the surface. Mining these beds affords Sisecam Wyoming several competitive advantages. First, the depth of Sisecam Wyoming's beds is shallower than other actively mined beds in the Green River Basin, which allows them to use a continuous mining technique to mine trona and roof bolt the ceiling simultaneously. In addition, mining two beds that are on top of one another allows for production efficiencies because Sisecam Wyoming is able to use a single hoisting shaft to service both beds.

The following graphic shows a cross-section of the strategic areas of the Green River Basin where Sisecam Wyoming mines trona:

In trona ore processing, insoluble materials and other impurities are removed by thickening and filtering liquor, a solution consisting of sodium carbonate dissolved in water. Sisecam Wyoming then adds activated carbon to filters to remove organic impurities, which can cause color contamination in the final product. The resulting clear liquid is then crystallized in evaporators, producing sodium carbonate monohydrate. The crystals are then drawn off and passed through a centrifuge to remove excess water. The resulting material is dried in a product dryer to form anhydrous sodium carbonate, or soda ash. The resulting processed soda ash is then stored in on-site storage silos to await shipment by bulk rail or truck to distributors and end customers. The facility is in good working condition and has been in service for more than 60 years.

Deca Rehydration. The evaporation stage of trona ore processing produces a precipitate and natural by-product called deca. "Deca," short for sodium carbonate decahydrate, is one part soda ash and ten parts water. Solar evaporation causes deca to crystallize and precipitate to the bottom of the four main surface ponds at the Green River Basin facility. The deca rehydration process enables Sisecam Wyoming to recover soda ash from the deca-rich purged liquor as a by-product of the refining process. The soda ash contained in deca is captured by allowing the deca crystals to evaporate in the sun and separating the dehydrated crystals from the soda ash. The separated deca crystals are then blended with partially processed trona ore in the dissolving stage of the production process. This process enables Sisecam Wyoming to reduce waste storage needs and convert what is typically a waste product into a usable raw material. Sisecam Wyoming anticipates that its current deca stockpiles will be exhausted by 2024 and that production rates will decline if that production capacity is not replaced.

Shipping and Logistics. For the year ended December 31, 2023, Sisecam Wyoming assisted the majority of its domestic customers in arranging their freight services. All of the soda ash produced is shipped by rail or truck from the Green River Basin facility. For the year ended December 31, 2023, Sisecam Wyoming shipped over 90% of its soda ash to its customers initially via a single rail line owned and controlled by Union Pacific Railroad Company ("Union Pacific"). The Sisecam Wyoming plant receives rail service exclusively from Union Pacific. The agreement with Union Pacific expires on December 31, 2025 and there can be no assurance that it will be renewed on terms favorable to Sisecam Wyoming or at all. If Sisecam Wyoming does not ship at least a significant portion of its soda ash production on the Union Pacific rail line during a twelve-month period, they must pay Union Pacific a shortfall payment under the terms of its transportation agreement. During 2023, Sisecam Wyoming had no shortfall payments and does not expect to make any such payments in the future. A leased fleet of hopper cars serve as dedicated modes of shipment to Sisecam Wyoming's domestic and international customers. For exports, soda ash is shipped on unit trains primarily out of Longview, Washington for bulk shipments. Sisecam Wyoming has contracts securing its export capacity in bulk vessels and containers vessels. From these ports, soda ash is loaded onto ships for delivery to ports all over the world. Sisecam Wyoming ships to customers on Cost and Freight ("CFR") and Cost, Insurance, and Freight ("CIF") basis where they pay for ocean freight and charge the customer directly for these freight costs. Sisecam Wyoming has yearly and multiyear contracts for a portion of its ocean freight with vessel owners and carriers securing capacity and reducing market risk fluctuation.

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Customers. Sisecam Wyoming generated approximately half of its gross revenue from export sales, which consist of both customers as well as distributors who serve as its channel partners in certain markets. For customers in North America, Sisecam Chemicals typically enters into contracts on Sisecam Wyoming’s behalf with terms ranging from one to three years. Under these contracts, customers generally agree to purchase either minimum estimated volumes of soda ash or a certain percentage of their soda ash requirements at a fixed price for a given calendar year. Although Sisecam Wyoming does not have “take or pay” arrangements with its customers, substantially all sales are made pursuant to written agreements and not through spot sales.

Sisecam Wyoming’s customers consist primarily of glass manufacturing companies, which account for 50% or more of the consumption of soda ash around the world, and chemical and detergent manufacturing companies.

Sisecam Chemicals has now completed three full years directly managing its international sales, marketing and logistics activities since exiting American Natural Soda Ash Corporation ("ANSAC") at the end of 2020. Sisecam Chemicals took direct control of these activities to improve access to customers and gain control over placement of its sales in the international marketplace. This enhanced view of the global market allows Sisecam Chemicals to better understand supply/demand fundamentals thus allowing better decision making for its business. Sisecam Chemicals continues to optimize its distribution network leveraging strengths of existing distribution partners while expanding as its business requires in certain target areas.

Leases and License. Sisecam Wyoming is party to several mining leases and one license for its subsurface mining rights. Some of the leases are renewable at Sisecam Wyoming’s option upon expiration. Sisecam Wyoming pays royalties to the State of Wyoming, the U.S. Bureau of Land Management and Sweetwater Royalties LLC, a subsidiary of Sweetwater Trona OpCo LLC and the successor in interest to the license with the Rock Springs Royalty Company LLC, an affiliate of Occidental Petroleum Corporation (formerly an affiliate of Anadarko Petroleum Corporation). The royalties are calculated based upon a percentage of the value of soda ash and related products sold at a certain stage in the mining process. These royalty payments may be subject to a minimum domestic production volume from the Green River Basin facility. Sisecam Wyoming is also obligated to pay annual rentals to its lessors and licensor regardless of actual sales. In addition, Sisecam Wyoming pays a production tax to Sweetwater County, and trona severance tax to the State of Wyoming that is calculated based on a formula that utilizes the volume of trona ore mined and the value of the soda ash produced. Sisecam Wyoming has a perpetual right to continue operating under these leases and license as long as it maintains continuous mining operations and intends to continue renewing the leases and license as has been historical practice.

As a minority interest owner in Sisecam Wyoming, we do not operate and are not involved in the day-to-day operation of the trona ore mine or soda ash production plant. Our partner, SCW, manages the mining and plant operations. We appoint three of the seven members of the Board of Managers of Sisecam Wyoming and have certain limited negative controls relating to the company.

Sisecam Wyoming produced 2.6 million, 2.8 million and 2.7 million short tons of soda ash (of which the Partnership's interest is 1.3 million, 1.4 million and 1.3 million short tons of soda ash) during the year ended December 31, 2023, 2022 and 2021, respectively. Sisecam Wyoming sold 2.7 million, 2.7 million and 2.8 million short tons of soda ash (of which the Partnership's interest is 1.3 million, 1.3 million and 1.4 million short tons of soda ash) during the year ended December 31, 2023, 2022 and 2021, respectively. Sisecam Wyoming had net sales of $773.6 million, $720.1 million and $540.1 million (of which the Partnership's interest is $379.1 million, $352.8 million and $264.6 million) during the year ended December 31, 2023, 2022 and 2021, respectively.

Cautionary Note to Investors Regarding Estimates Of Measured, Indicated And Inferred Resources And Proven And Probable Mineral Reserves

We are subject to the reporting requirements of the Exchange Act governed by S-K 1300 that aim to convey an appropriate level of confidence in the disclosures being reported. In our public filings we disclose proven and probable reserves and measured, indicated and inferred resources, each as defined in S-K 1300. The estimation of measured resources and indicated resources involve greater uncertainty as to their existence and economic feasibility than the estimation of proven and probable reserves, and therefore investors are cautioned not to assume that all or any part of measured or indicated resources will ever be converted into S-K 1300-compliant reserves. The estimation of inferred resources involves far greater uncertainty as to their existence and economic viability than the estimation of other categories of resources, and therefore it cannot be assumed that all or any part of inferred resources will ever be upgraded to a higher category. Therefore, investors are cautioned not to assume that all or any part of inferred resources exist, or that they can be mined legally or economically.

Trona Resources and Trona Reserves

Information concerning Sisecam Wyoming's mining property and estimated mineral resources and mineral reserves in this Amendment has been prepared in accordance with the requirements of S-K 1300 which requires us to disclose Sisecam Wyoming's mineral resources, in addition to Sisecam Wyoming's mineral reserves, at Sisecam Wyoming's mining property as of the end of our most recently completed fiscal year. The information that follows is derived, for the most part, from, and in some instances is an extract from the technical report summary prepared by Hollberg Professional Group (“HPG”) in compliance with Item 601(b)(96) and S-K 1300 completed on March 13, 2022 (the “2021 TRS”), as updated by HPG’s review and confirmation on January 8, 2025 of the validity of the estimates of remaining trona resources and trona reserves, based on the material assumptions and information in the 2021 TRS. Portions of the following information are based on assumptions, qualifications and procedures, that are not fully described herein. Reference should be made to the full text of the technical report summary prepared by HPG attached as Exhibit 96.1 and incorporated herein by reference and made a part of this Amendment. We have used the term “trona” as in “trona resources” and “trona reserves” interchangeably with “mineral.”

HPG has conducted an independent technical review of the lands held by Sisecam Chemicals referred to as the “Big Island Mine,” which is located in the area commonly referred to as the Known Sodium Lease Area (the “KSLA”) near the town of Green River, Sweetwater County. The KSLA is where trona thickness exceeds 1-meter, extends for over 300 km2, and is greater than 80% grade. The U.S. Geological Survey recognizes 25 trona beds of economic importance (at least 1 meter in thickness and 300 km2 in areal extent) within the Green River Basin. Identified in ascending order, the trona beds are numbered 1 through 25 from the oldest (stratigraphically lowest) to the youngest (stratigraphically highest). Sisecam Wyoming has approximately 23,999 acres of trona under lease made up of approximately 8,094 Federal acres, 2,986 State acres, 160 acres of 3 small acquisitions and 12,759 private acres. Sisecam Chemicals has mineral resources and mineable reserves in the shallowest mechanically mineable Trona beds 24 and 25, at depths of 850 and 800 feet below the surface, respectively, at our mine shaft locations. See also certain maps and graphics of Sisecam Wyoming's property above.

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HPG estimated the total of the Big Island Mine’s remaining leased and licensed proven and probable trona reserves as 211.3 million short tons (of which the Partnership’s interest is 103.5 million short tons) as of December 31, 2023, compared to 215.6 million short tons (of which the Partnership’s interest was 105.6 million short tons) as of December 31, 2022 and the total of the measured and indicated in-place trona resources exclusive of reserves as 162.3 million short tons (of which the Partnership’s interest is 79.5 million short tons) as of December 31, 2023, compared to 162.3 million short tons (of which the Partnership's interest was 79.5 million short tons) as of December 31, 2022. As of December 31, 2023, the decrease of 4.3 million short tons of the Big Island Mine’s proven and probable trona reserves, or 1.9%, as compared to December 31, 2022 is due to depletion of the reserves by the 2023 mined trona production as reported to the leaseholders. The cutoff grade of greater than 75% trona and thickness greater than 6 feet is applied to estimate the trona resources based upon successful mining and processing of the lower grade trona beds 19, 20 and 21 which were considered viable mining prospects by Texas Gulf Soda Ash (“TGSA”). The mineral resource inclusive of the mineral reserves is that portion of the ore body that is considered either economically viable for mining and can be converted to reserves or of economic interest but considered outside the current economic limits. This is the material considered of economic interest that has the potential to be converted to reserves. Sisecam Wyoming's trona resources are categorized as “Measured mineral resources,” “Indicated mineral resources,” and “Inferred mineral resources,” which are defined as follows:

•	Measured mineral resources - Mineral resources for which quantity and grade or quality are estimated on the basis of conclusive geological evidence and sampling. The level of geological certainty associated with a measured mineral resource is sufficient to allow a qualified person to apply modifying factors, as defined in this section, in sufficient detail to support detailed mine planning and final evaluation of the economic viability of the deposit. Because a measured mineral resource has a higher level of confidence than the level of confidence of either an indicated mineral resource or an inferred mineral resource, a measured mineral resource may be converted to a proven mineral reserve or to a probable mineral reserve.
•	Indicated mineral resources - Mineral resources for which quantity and grade or quality are estimated on the basis of adequate geological evidence and sampling. The level of geological certainty associated with an indicated mineral resource is sufficient to allow a qualified person to apply the modifying factors in sufficient detail to support mine planning and evaluation of the economic viability of the deposit. Because an indicated mineral resource has a lower level of confidence than the level of confidence of a measured mineral resource, an indicated mineral resource may only be converted to a probable mineral reserve. (The modifying factors are the factors that a qualified person must apply to indicated and measured mineral resources and then evaluate in order to establish the economic viability of mineral reserves. A qualified person must apply and evaluate modifying factors to convert measured and indicated mineral resources to proven and probable mineral reserves. These factors include but are not restricted to mining; processing; metallurgical; infrastructure; economic; marketing; legal; environmental compliance; plans, negotiations, or agreements with local individuals or groups; and governmental factors. The number, type and specific characteristics of the modifying factors applied will necessarily be a function of and depend upon the mineral, mine, property, or project.)
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•	Inferred mineral resources - Mineral resources for which quantity and grade or quality are estimated on the basis of limited geological evidence and sampling. The level of geological uncertainty associated with an inferred mineral resource is too high to apply relevant technical and economic factors likely to influence the prospects of economic extraction in a manner useful for evaluation of economic viability. Because an inferred mineral resource has the lowest level of geological confidence of all mineral resources, which prevents the application of the modifying factors in a manner useful for evaluation of economic viability, an inferred mineral resource may not be considered when assessing the economic viability of a mining project and may not be converted to a mineral reserve. We may issue additional common units or preferred units without common unitholder approval, which would dilute a unitholder’s existing ownership interests.

The following is a summary of the recoverable trona reserves for beds 24 and 25 as of December 31, 2023:

(in millions of short tons except percentage) ^(1) (2)^
Reserve Category	Proven mineral reserves			Probable mineral reserves			Total mineral reserves
	Amount	Grade ^(1)^		Amount	Grade ^(1)^		Amount	Grade ^(1)^
Lower Bed 24	62.2	86.0	%	83.2	85.8	%	145.4	85.9	%
Upper Bed 25	26.6	83.7	%	39.3	84.1	%	65.9	84.1	%
Total ^(3) (4) (5)^	88.7	85.2	%	122.6	85.2	%	211.3	85.2	%
^(1)^Numbers have been rounded; totals may not sum due to rounding.
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^(2)^ Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
^(3)^ The point of reference is run-of-mine (ROM) ore delivered to the processing facilities including mining losses and dilution.
^(4)^ Mineral reserves are current as of December 31, 2023, using depletion and the definitions in SK1300.
^(5)^Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned 51% by SCW LLC and 49% by NRP.

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Sisecam Wyoming's reserves are subject to leases with the State of Wyoming and the U.S. Bureau of Land Management and a license with Sweetwater Royalties LLC.

The following table presents Sisecam Wyoming's estimated proven and probable trona reserves by license and leases as of December 31, 2023:

(in millions of short tons except percentage) ^(1) (2)^
Reserve Category	Proven mineral reserves			Probable mineral reserves			Total mineral reserves
	Amount	Grade ^(1)^		Amount	Grade ^(1)^		Amount	Grade ^(1)^
License with Sweetwater Royalties LLC	46.1	85.3	%	59.4	85.2	%	105.6	85.2	%
Leases with the U.S. Government	34.7	84.9	%	44.5	85.0	%	79.2	85.0	%
Leases with the State of Wyoming	7.9	86.8	%	18.6	86.1	%	26.6	86.3	%
Total ^(3) (4) (5)^	88.7	85.2	%	122.6	85.2	%	211.3	85.2	%
^(1)^Numbers have been rounded; totals may not sum due to rounding.
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^(2)^ Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
^(3)^ The point of reference is ROM ore delivered to the processing facilities including mining losses and dilution.
^(4)^ Mineral reserves are current as of December 31, 2023, using depletion and the definitions in SK1300.
^(5)^Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned 51% by SCW LLC and 49% by NRP.

The following is a summary of the measured, indicated, and inferred mineral resources exclusive of reserves for trona beds 24 and 25 as of December 31, 2023:

(in millions of short tons except percentage and thickness) ^(1) (2)^
Reserve Category	Measured mineral resources			Indicated mineral resources			Measured + Indicated mineral resources				Inferred mineral resources
	Amount	Grade ^(1)^		Amount	Grade ^(1)^		Amount	Grade^(1)^		Thickness (ft)	Amount	Grade^(1)^
Lower Bed 24	44.8	88.7	%	54.1	86.9	%	98.9	87.7	%	8.5	0.05	90.0	%
Upper Bed 25	29.4	85.0	%	34.1	87.3	%	63.4	86.2	%	7.5	—	—	%
Total ^(3) (4) (5)^	74.2	87.2	%	88.2	87.0	%	162.3	87.1	%	8.1	0.05	90.0	%
^(1)^Numbers have been rounded; totals may not sum due to rounding.
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^(2)^ Based on a 6-foot minimum thickness and a 75% minimum grade cut-off.
^(3)^ The point of reference is in-place inclusive of impurities and insoluble content.
^(4)^ Mineral reserves are current as of December 31, 2023, by depletion using depletion and the definitions in SK1300.
^(5)^Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned 51% by SCW LLC and 49% by NRP.

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HPG estimated proven and probable reserves of approximately 211.3 million short tons of trona (of which the Partnership’s interest is 103.5 million short tons), which is equivalent to 114.4 million short tons of soda ash as of December 31, 2023 (of which the Partnership’s interest is 56.0 million short tons of soda ash). Based on Sisecam Wyoming's current mining rate of approximately 4.3 million short tons of trona per year, Sisecam Wyoming has enough proven and probable trona reserves to continue mining trona using current methods for approximately 50 years.

The mineral reserve is the economically mineable part of a measured or indicated mineral resource, which includes diluting materials and allowances for losses that may occur when the material is mined or extracted. Sisecam Wyoming's trona reserves are categorized as “Proven mineral reserves” and “Probable mineral reserves,” which are defined as follows:

•	Proven mineral reserves - The economically mineable part of a measured mineral resource and can only result from conversion of a measured mineral resource.
•	Probable mineral reserves - The economically mineable part of an indicated and, in some cases, a measured mineral resource.

In determining the reserve parameters and assumptions HPG considered the following circumstances:

•	Sisecam Wyoming’s 60-year long history and economics of mining the deposit and producing soda ash;
	◦ The 178.7 million short tons (“Mst”) of trona ore produced from these two beds;
•	The projected long life of the mine and resulting likely change in economics, mining, and processing methods over its projected 40 plus-year mine life (considering increased production over the current production rates) used in this technical summary. This 40 plus-year mine life consideration is based on the specific assumptions in this technical summary, including assumptions related to projected timing and estimated cost of two-seam mining, timing of related capital expenditures and sales price projections;
•	Sisecam Wyoming’s current processing facilities’ capabilities and projected future changes to these facilities;
•	The economics associated with Sisecam Wyoming’s current mining equipment and history of “high grading” the thickest portions of the deposit;
•	Sisecam Wyoming’s current mining equipment limitations and required future changes to these systems; and
•	HPG’s knowledge of operating and managing other trona and potash mines.

In determining whether the reserves meet these economic standards, HPG made certain assumptions regarding the remaining life of the Big Island Mine, including, among other things, that:

•	the cost of products sold per short ton will remain consistent with Sisecam Wyoming’s cost of products sold for the five years ended December 31, 2023;
•	the weighted average net sales per short ton of $226/ton will remain consistent with Sisecam Wyoming’s average net sales for the five years ended December 31, 2023;
•	Sisecam Wyoming’s mining costs will remain consistent with 2023 levels with two-seam mining costs 30% higher for the two-seam production (the Partnership estimates that this increase would not impact its overall production cost by more than 1% and thus would not have a material overall impact to the Partnership’s production costs);
•	Sisecam Wyoming’s processing costs will remain consistent with 2023 levels and rise in 10-years to account for lower grade material;
•	Sisecam Wyoming will achieve an annual mining rate of approximately 4.3 million short tons of trona in 2024 and beyond;
•	Sisecam Wyoming will process soda ash with a 90% rate of recovery, without accounting for the deca rehydration process;
•	the ore to ash ratio for the stated trona reserves is 1.835:1.0 (short tons of trona run-of-mine to short tons of soda ash);
•	The run-of-mine ore estimate contains dilution from the mining process;
•	Sisecam Wyoming will continue to conduct only conventional mining using the room and pillar method and a non-subsidence mine design;
•	Sisecam Wyoming will, in approximately 10 years, make necessary modifications to the processing facilities to allow localized mining of 75% ore grade in areas where the floor seam or insoluble disruptions have moved up into the mining horizon causing mining to be halted early due to processing facility limitations;
•	Sisecam Wyoming will continue to conduct “two-seam mining,” in production panels which means to perform continuous mining in Bed 24 beneath historically mined production panels of Bed 25 with interburden thickness of approximately 35-feet;
•	Sisecam Wyoming will, in approximately 20 years, make necessary equipment modifications to operate at a seam height of 7-feet, the current mining limit is 9-feet;
•	Sisecam Wyoming has and will continue to have valid leases and license in place with respect to the reserves, and that these leases and license can be renewed for the life of the mine based on their extensive history of renewing leases and license;
•	Sisecam Wyoming has and will continue to have the necessary permits to conduct mining operations with respect to the reserves; and
•	Sisecam Wyoming will maintain the necessary tailings storage capacity to maintain tailings disposal between the mine and surface placement for the life-of-mine.

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Sisecam Wyoming's estimates of mineral resources and mineral reserves will change from time to time as a result of mining activities, analysis of new engineering and geologic data, modification of mining plans or mining methods and other factors. For additional information, see "Item 1A, Risk Factors, Risks Related to Our Business” for more information regarding risks surrounding Sisecam Wyoming's reserves.

Internal Controls Disclosure over Trona Resources and Trona Reserves

Sisecam Wyoming has internal controls over the trona resources and trona reserves estimation processes that result in reasonable and reliable estimates aligned with industry practice and reporting regulations. Annually, qualified persons and other Sisecam Wyoming employees review the estimates of trona resources and trona reserves and the supporting documentation, and based on their review of such information recommend approval to use the trona resources and trona reserves estimates to Sisecam Wyoming senior management. Sisecam Wyoming's controls utilize management systems, including, but not limited to, standardized procedures, workflow processes, supervision and management approval, internal and external reviews and audits, reconciliations, and data security covering record keeping, chain of custody and data storage. Sisecam Wyoming's systems also cover sample preparation and analysis, data verification, trona processing, metallurgical testing, recovery estimation, mine design and sequencing, and trona resource and reserve evaluations, with environmental, social and regulatory considerations.

These controls and other methods help to validate the reasonableness of the estimates. The effectiveness of the controls is reviewed periodically to address changes in conditions and the degree of compliance with policies and procedures. For additional information regarding the risks associated with Sisecam Wyoming's estimates of trona resources and reserves, see “Item 1A, Risk Factors, Risks Related to Our Business—Sisecam Wyoming's reserve and resource data are estimates based on assumptions that may be inaccurate and are based on existing economic and operating conditions that may change in the future, which could materially and adversely affect the quantities and value of Sisecam Wyoming's reserves and resources.”

The technical data underlying the resources and reserves included in this Amendment, including the internal controls for determining and reporting such resources and reserves, are maintained by Sisecam Wyoming, and our agreements with Sisecam Wyoming do not give us (i) access to such underlying technical data sufficient to specifically confirm the opinion of the qualified person with respect to such resources and reserves or (ii) the ability to monitor or enforce Sisecam Wyoming's internal controls for determining and reporting such resources and reserves. Sisecam Wyoming has, however, made representations to us and the qualified person that it does not have reason to believe that the resource and reserve information contained in the report are materially misleading. We are providing this information because it represents the information that we have in our possession and we do not have a reasonable ground to believe that it is inaccurate, but we caution investors that we have relied on the qualified person and Sisecam Wyoming with respect to the preparation of the resources and reserves included in this report and are not able to independently verify its accuracy. Investors are cautioned to consider such risks when reviewing the resources and reserves included in this report.

Significant Customers

We have a significant concentration of revenues from Alpha, with total revenues of $86.1 million in 2023 from several different mining operations, including wheelage revenues and coal overriding royalty revenues. We also have a significant concentration of revenues with Foresight and its subsidiaries, with total revenues of $60.5 million in 2023 from all of their mining operations, including transportation and processing services revenues, coal overriding royalty revenues and wheelage revenues. For additional information on significant customers, refer to "Item 8. Financial Statements and Supplementary Data—Note 14. Major Customers" in our Annual Report on Form 10-K filed with the SEC on March 7, 2024."

Competition

We face competition from land companies, coal producers, international steel companies and private equity firms in purchasing coal and royalty producing properties. Numerous producers in the coal industry make coal marketing intensely competitive. Our lessees compete among themselves and with coal producers in various regions of the United States for domestic sales. Lessees compete with both large and small producers nationwide on the basis of coal price at the mine, coal quality, transportation cost from the mine to the customer and the reliability of supply. Continued demand for our coal and the prices that our lessees obtain are also affected by demand for electricity and steel, as well as government regulations, technological developments and the availability and the cost of generating power from alternative fuel sources, including nuclear, natural gas, wind, solar and hydroelectric power.

Sisecam Wyoming's trona mining and soda ash refinery business faces competition from a number of soda ash producers in the United States, Europe and Asia, some of which have greater market share and greater financial, production and other resources than Sisecam Wyoming does. Some of Sisecam Wyoming’s competitors are diversified global corporations that have many lines of business and some have greater capital resources and may be in a better position to withstand a long-term deterioration in the soda ash market. Other competitors, even if smaller in size, may have greater experience and stronger relationships in their local markets. Competitive pressures could make it more difficult for Sisecam Wyoming to retain its existing customers and attract new customers, and could also intensify the negative impact of factors that decrease demand for soda ash in the markets it serves, such as adverse economic conditions, weather, higher fuel costs and taxes or other governmental or regulatory actions that directly or indirectly increase the cost or limit the use of soda ash.

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Title to Property

We owned substantially all of our coal and aggregates mineral rights in fee as of December 31, 2023. We lease the remainder from unaffiliated third parties. Sisecam Wyoming leases or licenses its trona. We believe that we have satisfactory title to all of our mineral properties, but we have not had a qualified title company confirm this belief. Although title to these properties is subject to encumbrances in certain cases, such as customary easements, rights-of-way, interests generally retained in connection with the acquisition of real property, licenses, prior reservations, leases, liens, restrictions and other encumbrances, we believe that none of these burdens will materially detract from the value of our properties or from our interest in them or will materially interfere with their use in the operation of our business.

For most of our properties, the surface, oil and gas and mineral or coal estates are not owned by the same entities. Some of those entities are our affiliates. State law and regulations in most of the states where we do business require the oil and gas owner to coordinate the location of wells so as to minimize the impact on the intervening coal seams. We do not anticipate that the existence of the severed estates will materially impede development of the minerals on our properties.

Regulation and Environmental Matters

General

Operations on our properties must be conducted in compliance with all applicable federal, state and local laws and regulations. These laws and regulations include matters involving the discharge of materials into the environment, employee health and safety, mine permits and other licensing requirements, reclamation and restoration of mining properties after mining is completed, management of materials generated by mining operations, surface subsidence from underground mining, water pollution, legislatively mandated benefits for current and retired coal miners, air quality standards, protection of wetlands, plant and wildlife protection, limitations on land use, storage of petroleum products and substances which are regarded as hazardous under applicable laws and management of electrical equipment containing polychlorinated biphenyls ("PCBs"). Because of extensive, comprehensive and often ambiguous regulatory requirements, violations during natural resource extraction operations are not unusual and, notwithstanding compliance efforts, we do not believe violations can be eliminated entirely.

While it is not possible to quantify the costs of compliance with all applicable federal, state and local laws and regulations, those costs have been and are expected to continue to be significant. Our lessees in our coal and aggregates royalty businesses are required to post performance bonds pursuant to federal and state mining laws and regulations for the estimated costs of reclamation and mine closures, including the cost of treating mine water discharge when necessary. In many states our lessees also pay taxes into reclamation funds that states use to achieve reclamation where site specific performance bonds are inadequate to do so. Determinations by federal or state agencies that site specific bonds or state reclamation funds are inadequate could result in increased bonding costs for our lessees or even a cessation of operations if adequate levels of bonding cannot be maintained. We do not accrue for reclamation costs because our lessees are both contractually liable and liable under the permits they hold for all costs relating to their mining operations, including the costs of reclamation and mine closures. Although the lessees typically accrue adequate amounts for these costs, their future operating results would be adversely affected if they later determined these accruals to be insufficient. In recent years, compliance with these laws and regulations has substantially increased the cost of coal mining for all domestic coal producers.

In addition, the electric utility industry, which is the most significant end-user of thermal coal, is subject to extensive regulation regarding the environmental impact of its power generation activities, which has affected and is expected to continue to affect demand for coal mined from our properties. Current and future proposed legislation and regulations could be adopted that will have a significant additional impact on the mining operations of our lessees or their customers’ ability to use coal and may require our lessees or their customers to change operations significantly or incur additional substantial costs that would negatively impact the coal industry.

Many of the statutes discussed below also apply to Sisecam Wyoming’s trona mining and soda ash production operations, and therefore we do not present a separate discussion of statutes related to those activities, except where appropriate.

Air Emissions

The Clean Air Act and corresponding state and local laws and regulations affect all aspects of our business. The Clean Air Act directly impacts our lessees’ coal mining and processing operations by imposing permitting requirements and, in some cases, requirements to install certain emissions control equipment, on sources that emit various hazardous and non-hazardous air pollutants. The Clean Air Act also indirectly affects coal mining operations by extensively regulating the air emissions of coal-fired electric power generating plants. There have been a series of federal rulemakings that are focused on emissions from coal-fired electric generating facilities, including the Cross-State Air Pollution Rule ("CSAPR"), regulating emissions of nitrogen oxide ("NOx") and sulfur dioxide, and the Mercury and Air Toxics Rule ("MATS"), regulating emissions of hazardous air pollutants. In March 2021, the U.S. Environmental Protection Agency ("EPA") revised the CSAPR to require additional emissions reductions of NOx from power plants in twelve states. Further, in April 2022, EPA published a proposed rule to build on the CSAPR by imposing Federal Implementation Plans on over 20 states to implement the National Ambient Air Quality Standards ("NAAQS") for ozone. However, on August 21, 2023, the EPA announced a new review of the ozone NAAQS in combination with its reconsideration of EPA's December 2020 decision to retain the 2015 NAAQS. The EPA is expected to release its Integrated Review Plan in the fall of 2024. Installation of additional emissions control technologies and other measures required under EPA regulations make it more costly to operate coal-fired power plants and could make coal a less attractive or even effectively prohibited fuel source in the planning, building and operation of power plants in the future. These rules and regulations have resulted in a reduction in coal’s share of power generating capacity, which has negatively impacted our lessees’ ability to sell coal and our coal-related revenues. Further reductions in coal’s share of power generating capacity as a result of compliance with existing or proposed rules and regulations would have a material adverse effect on our coal-related revenues.

The EPA’s regulation of methane under the Clean Air Act may also affect oil and gas production on properties in which we hold oil and gas interests. In December 2023, the EPA issued its methane rules, known as OOOOb and OOOOc, that establish new source and first-time existing source standards of performance for GHG and VOC emissions for crude oil and natural gas well sites, natural gas gathering and boosting compressor stations, natural gas processing plants, and transmission and storage facilities. We are unable to predict at this time the impact of these requirements on any such oil and gas production on our properties.

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Carbon Dioxide and Greenhouse Gas ("GHG") Emissions

In December 2009, EPA determined that emissions of carbon dioxide, methane, and other GHGs present an endangerment to public health and welfare because emissions of such gases are, according to EPA, contributing to warming of the Earth’s atmosphere and other climatic changes. Based on its findings, EPA began adopting and implementing regulations to restrict emissions of GHGs under various provisions of the Clean Air Act.

In August 2015, EPA published its final Clean Power Plan ("CPP") Rule, a multi-factor plan designed to cut carbon pollution from existing power plants, including coal-fired power plants. The rule required improving the heat rate of existing coal-fired power plants and substituting lower carbon-emission sources like natural gas and renewables in place of coal. As promulgated, the rule would force many existing coal-fired power plants to incur substantial costs in order to comply or alternatively result in the closure of some of these plants, likely resulting in a material adverse effect on the demand for coal by electric power generators. The rule was being challenged by several states, industry participants and other parties in the United States Court of Appeals for the District of Columbia Circuit. In February 2016, the Supreme Court of the United States stayed the CPP Rule pending a decision by the District of Columbia Circuit as well as any subsequent review by the Supreme Court. In April 2017, the United States Court of Appeals for the District of Columbia Circuit granted EPA’s motion to hold the litigation in abeyance. In December 2017, EPA issued a proposed rule repealing the CPP Rule and issued an Advance Notice of Proposed Rulemaking soliciting information regarding a potential replacement rule to the CPP Rule. In August 2018, EPA formally proposed the Affordable Clean Energy ("ACE") Rule, which would replace the CPP Rule. The ACE Rule contemplates a narrower approach than the CPP Rule, focusing on efficiency improvements at existing power plants and eliminating the CPP Rule’s broader goals that envisioned switches to non-fossil fuel energy sources and the implementation of efficiency measures on demand-side entities, which the EPA now considers beyond the reach of its authority under the Clean Air Act. The ACE Rule would also omit specific numerical emissions targets that had been established under the CPP Rule. The ACE Rule went into effect on September 6, 2019. As a result, the United States Court of Appeals for the District of Columbia Circuit dismissed the pending challenges to the CPP Rule as moot. The ACE Rule was challenged by public health groups, environmental groups, states, municipalities, industry groups, and power providers. The legal challenges were consolidated as American Lung Assoc. v. EPA before the D.C. Circuit Court of Appeals. Dozens of parties and over 170 amici filed briefs on the merits, and oral argument was held before a three-judge panel in October 2020. In January 2021, the D.C. Circuit issued a written opinion holding that the ACE Rule was based on EPA’s “erroneous legal premise” that when it determines the “best system of emission reduction” for existing sources, the Clean Air Act mandates that EPA may only consider emission reduction measures that can be applied at and/or to a stationary source (often referred to as “inside-the-fence” measures). The Court vacated the rule, essentially reimplementing the CPP and leaving EPA to decide whether to stick with the CPP or to pursue a new rulemaking. In June 2022, the Supreme Court issued a written opinion, West Virginia v. EPA, in which the Court invalidated the CPP because EPA lacked the authority to promulgate such an expansive rule under the “Major Questions Doctrine.” It is unclear whether the Biden administration will issue a replacement of the CPP.

In October 2015, EPA published its final rule on performance standards for greenhouse gas emissions from new, modified, and reconstructed electric generating units. The final rule requires new steam generating units to use highly efficient supercritical pulverized coal boilers that use partial post-combustion carbon capture and storage technology. The final emission standard is less stringent than EPA had originally proposed due to updated cost assumptions, but could still have a material adverse effect on new coal-fired power plants. The final rule has been challenged by several states, industry participants and other parties in the United States Court of Appeals for the District of Columbia Circuit, but is not subject to a stay. In April 2017, the court granted EPA’s motion to hold the litigation in abeyance while EPA reviews the rule. In December 2018, EPA issued a proposed rule revising the best system of emission reduction (“BSER”) for newly constructed coal-fired electric generating units, among other changes, to replace the 2015 rule. In a status report filed with the Court on January 15, 2021, EPA requested that the case remain in abeyance until after the transition to the Biden administration. On March 17, 2021, in line with President Biden’s Executive Order 13990, EPA asked the D.C. Circuit to vacate and remand the “significant contribution” final rule. On April 5, 2021, the D.C. Circuit vacated and remanded the January 2021 final rule. Although the EPA has not taken further action on the December 2018 proposed rule, on May 23, 2023, the EPA issued a proposed rule setting proposed new source performance standards for greenhouse gas emissions from new, modified, and reconstructed fossil fuel-fired electric generating units; emission guidelines for greenhouse gas emissions from existing fossil fuel-fired electric generating units; and repeal of the ACE Rule. The final rule is expected in 2024.

Certain authorizations required for certain mining and oil and gas operations may be difficult to obtain or use due to challenges from environmental advocacy groups to the environmental analyses conducted by federal agencies before granting permits. In particular, those approvals necessary for certain coal activities that are subject to the requirements of the National Environmental Policy Act (“NEPA”) are subject to real uncertainty. In April 2022, the Council on Environmental Quality (“CEQ”) issued a final rule, which is considered “Phase I” of the Biden Administration’s two-phased approach to modifying the NEPA, revoking some of the modifications made to the NEPA regulations under the previous administration and reincorporating the consideration of direct, indirect, and cumulative effects of major federal actions, including GHG emissions. In July 2023, the CEQ announced a “Phase 2” Notice of Proposed Rulemaking, the “Bipartisan Permitting Reform Implementation Rule,” which revises the implementing regulations of the procedural provisions of NEPA and implements the amendments to NEPA included in the June 3, 2023, Fiscal Responsibility Act of 2023. The final rule is expected in 2024. If any mining, or oil and gas operations are subject to permitting requirements that trigger NEPA, there is likely to be some uncertainty about the viability of any approvals that our lessees may obtain.

In November 2014, President Obama also announced an emission reduction agreement with China’s President Xi Jinping. The United States pledged that by 2025 it would cut climate pollution by 26% to 28% from 2005 levels. China pledged it would reach its peak carbon dioxide emissions around 2030 or earlier, and increase its non-fossil fuel share of energy to around 20% by 2030. In December 2015, the United States was one of 196 countries that participated in the Paris Climate Conference, at which the participants agreed to limit their emissions in order to limit global warming to 2°C above pre-industrial levels, with an aspirational goal of 1.5°C. While there is no way to estimate the impact of these climate pledges and agreements, including, most recently, the 28th session of the United Nations Conference of the Parties ("COP28") in December 2023, they could ultimately have an adverse effect on the demand for coal, both nationally and internationally, if implemented. In 2019, President Trump withdrew from the Paris Climate Agreement. On February 19, 2021, the United States officially rejoined the Paris Climate Agreement per President Biden’s order signed January 20. Additionally, at COP28, the parties signed onto an agreement to transition “away from fossil fuels in energy systems in a just, orderly and equitable manner” and increase renewable energy capacity so as to achieve net zero by 2050, although no timeline for reaching net zero by that date was set.

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Hazardous Materials and Waste

The Federal Comprehensive Environmental Response, Compensation and Liability Act ("CERCLA" or the Superfund law) and analogous state laws impose liability, without regard to fault or the legality of the original conduct, on certain classes of persons that are considered responsible for having contributed to the release of a “hazardous substance” into the environment. We could become liable under federal and state Superfund and waste management statutes if our lessees are unable to pay environmental cleanup costs relating to hazardous substances. In addition, we may have liability for environmental clean-up costs in connection with Sisecam Wyoming's soda ash businesses.

Water Discharges

Operations conducted on our properties can result in discharges of pollutants into waters. The Clean Water Act and analogous state laws and regulations create two permitting programs for mining operations. The National Pollutant Discharge Elimination System ("NPDES") program under Section 402 of the statute is administered by the states or EPA and regulates the concentrations of pollutants in discharges of waste and storm water from a mine site. The Section 404 program is administered by the Army Corps of Engineers and regulates the placement of overburden and fill material into channels, streams and wetlands that comprise “waters of the United States.” The scope of waters that may fall within the jurisdictional reach of the Clean Water Act is expansive and may include land features not commonly understood to be a stream or wetlands. The Clean Water Act and its regulations prohibit the unpermitted discharge of pollutants into such waters, including those from a spill or leak. Similarly, Section 404 also prohibits discharges of fill material and certain other activities in waters unless authorized by the issued permit. In June 2015, EPA issued a new rule defining the scope of “Waters of the United States” (WOTUS) that are subject to regulation. The 2015 WOTUS rule was challenged by a number of states and private parties in federal district and circuit courts. In December 2017, EPA and the Corps proposed a rule to repeal the 2015 WOTUS rule and implement the pre-2015 definition. The repeal of the 2015 WOTUS rule took effect in December 2019. In December 2018, EPA and the Corps issued a proposed rule again revising the definition of “Waters of the United States.” The new rule (the Navigable Waters Protection Rule) took effect in June 2020. In most of the pending legal challenges to the 2015 WOTUS rule, the petitioners filed amended complaints to include allegations challenging the 2020 rule. In January 2023, the EPA and the Army Corps of Engineers published a final revised definition of WOTUS founded upon a pre-2015 definition and including updates to incorporate existing Supreme Court decisions. Judicial developments further add to this uncertainty. In October 2022, the Supreme Court heard oral arguments in Sackett v. EPA regarding the scope and authority of the Clean Water Act and the definition of WOTUS and in May 2023, issued a ruling invalidating certain parts of the January 2023 rule. A revised WOTUS rule was issued in September 2023. Due to the injunction in certain states, however, the implementation of the September 2023 rule currently varies by state.

States issue a certificate pursuant to Clean Water Act Section 401 that is required for the Corps of Engineers to issue a Section 404 permit. In October 2021, the U.S. District Court for the Northern District of California vacated a 2020 rule revising the Section 401 certification process. The Supreme Court stayed this vacatur and, in September 2023, the EPA finalized its Clean Water Act Section 401 Water Quality Certification Improvement Rule, effective as of November 27, 2023. While the full extent and impact of these actions is unclear at this time, any disruption in the ability to obtain required permits may result in increased costs and project delays. In connection with its review of permits, EPA has at times sought to reduce the size of fills and to impose limits on specific conductance (conductivity) and sulfate at levels that can be unachievable absent treatment at many mines. Such actions by EPA could make it more difficult or expensive to obtain or comply with such permits, which could, in turn, have an adverse effect on our coal-related revenues.

In addition to government action, private citizens’ groups have continued to be active in bringing lawsuits against operators and landowners. Since 2012, several citizen group lawsuits have been filed against mine operators for allegedly violating conditions in their National Pollutant Discharge Elimination System (“NPDES”) permits requiring compliance with West Virginia’s water quality standards. Some of the lawsuits alleged violations of water quality standards for selenium, whereas others alleged that discharges of conductivity and sulfate were causing violations of West Virginia’s narrative water quality standards, which generally prohibit adverse effects to aquatic life. The citizen suit groups have sought penalties as well as injunctive relief that would limit future discharges of selenium, conductivity or sulfate. The federal district court for the Southern District of West Virginia has ruled in favor of the citizen suit groups in multiple suits alleging violations of the water quality standard for selenium and in two suits alleging violations of water quality standards due to discharges of conductivity (one of which was upheld on appeal by the United States Court of Appeals for the Fourth Circuit in January 2017). Additional rulings requiring operators to reduce their discharges of selenium, conductivity or sulfate could result in large treatment expenses for our lessees. In 2015, the West Virginia Legislature enacted certain changes to West Virginia’s NPDES program to expressly prohibit the direct enforcement of water quality standards against permit holders. EPA approved those changes as a program revision effective in March 2019. This approval may prevent future citizen suits alleging violations of water quality standards.

Since 2013, several citizen group lawsuits have been filed against landowners alleging ongoing discharges of pollutants, including selenium and conductivity, from valley fills located at reclaimed mountaintop removal mining sites in West Virginia. In each case, the mine on the subject property has been closed, the property has been reclaimed, and the state reclamation bond has been released. Any determination that a landowner or lessee has liability for discharges from a previously reclaimed mine site could result in substantial compliance costs or fines and would result in uncertainty as to continuing liability for completed and reclaimed coal mine operations.

Endangered Species Act

The federal Endangered Species Act (“ESA”) and counterpart state legislation protect species threatened with possible extinction. The U.S. Fish and Wildlife Service (“USFWS”) works closely with state regulatory agencies to ensure that species subject to the ESA are protected from potential impacts from mining-related and oil and gas exploration and production activities. In October 2021, the Biden Administration proposed the rollback of new rules promulgated under the Trump Administration and published an advanced notice of proposed rulemaking to codify a general prohibition on incidental take while establishing a process to regulate or permit exceptions to such a prohibition. In February 2023, the USFWS published a proposed rule that revised the requirements for an incidental take permit application. A final rule is scheduled for release in 2024. Additionally, in June 2022, the USFWS and the National Marine Fisheries Service published a final rule rescinding the 2020 regulatory definition of “habitat.” If the USFWS were to designate species indigenous to the areas in which we operate as threatened or endangered or to redesignate a species from threatened to endangered, we or the operators of the properties in which we hold oil and gas or mineral interests could be subject to additional regulatory and permitting requirements, which in turn could increase operating costs or adversely affect our revenues.

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Other Regulations Affecting the Mining Industry

Mine Health and Safety Laws

The operations of our coal lessees and Sisecam Wyoming are subject to stringent health and safety standards that have been imposed by federal legislation since the adoption of the Mine Health and Safety Act of 1969. The Mine Health and Safety Act of 1969 resulted in increased operating costs and reduced productivity. The Mine Safety and Health Act of 1977, which significantly expanded the enforcement of health and safety standards of the Mine Health and Safety Act of 1969, imposes comprehensive health and safety standards on all mining operations. In addition, the Black Lung Acts require payments of benefits by all businesses conducting current mining operations to coal miners with black lung or pneumoconiosis and to some beneficiaries of miners who have died from this disease.

Mining accidents in recent years have received national attention and instigated responses at the state and national level that have resulted in increased scrutiny of current safety practices and procedures at all mining operations, particularly underground mining operations. Since 2006, heightened scrutiny has been applied to the safe operations of both underground and surface mines. This increased level of review has resulted in an increase in the civil penalties that mine operators have been assessed for non-compliance. Operating companies and their supervisory employees have also been subject to criminal convictions. The Mine Safety and Health Administration ("MSHA") has also advised mine operators that it will be more aggressive in placing mines in the Pattern of Violations program, if a mine’s rate of injuries or significant and substantial citations exceed a certain threshold. A mine that is placed in a Pattern of Violations program will receive additional scrutiny from MSHA.

Surface Mining Control and Reclamation Act of 1977

The Surface Mining Control and Reclamation Act of 1977 ("SMCRA") and similar statutes enacted and enforced by the states impose on mine operators the responsibility of reclaiming the land and compensating the landowner for types of damages occurring as a result of mining operations. To ensure compliance with any reclamation obligations, mine operators are required to post performance bonds. Our coal lessees are contractually obligated under the terms of our leases to comply with all federal, state and local laws, including SMCRA. Upon completion of the mining, reclamation generally is completed by seeding with grasses or planting trees for use as pasture or timberland, as specified in the reclamation plan approved by the state regulatory authority. In addition, higher and better uses of the reclaimed property are encouraged.

Mining Permits and Approvals

Numerous governmental permits or approvals such as those required by SMCRA and the Clean Water Act are required for mining operations. In connection with obtaining these permits and approvals, our lessees may be required to prepare and present to federal, state or local authorities data pertaining to the effect or impact that any proposed production of coal may have upon the environment. The requirements imposed by any of these authorities may be costly and time consuming and may delay commencement or continuation of mining operations.

In order to obtain mining permits and approvals from state regulatory authorities, mine operators, including our lessees, must submit a reclamation plan for reclaiming the mined property upon the completion of mining operations. Our lessees have obtained or applied for permits to mine a majority of the coal that is currently planned to be mined over the next five years. Our lessees are also in the planning phase for obtaining permits for the additional coal planned to be mined over the following five years. However, given the imposition of new requirements in the permits in the form of policies and the increased oversight review that has been exercised by EPA, there are no assurances that they will not experience difficulty and delays in obtaining mining permits in the future. In addition, EPA has used its authority to create significant delays in the issuance of new permits and the modification of existing permits, which has led to substantial delays and increased costs for coal operators.

Employees and Labor Relations

As of December 31, 2023, affiliates of our general partner employed 55 people who directly supported our operations. None of these employees were subject to a collective bargaining agreement.

Human Capital

We believe all individuals are entitled to courtesy, dignity, and respect, and we support a culture of integrity and personal and professional growth. We are strong leaders within our community, and we seek to uphold a positive presence in all areas where we live and work.

Website Access to Partnership Reports

Our internet address is www.nrplp.com. We make available free of charge on or through our website our Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 as soon as reasonably practicable after we electronically file such material with, or furnish it to, the Securities and Exchange Commission. Information on our website is not a part of this report. In addition, the SEC maintains a website at www.sec.gov that contains reports, proxy and information statements and other information filed by us.

Corporate Governance Matters

Our Code of Business Conduct and Ethics, our Disclosure Controls and Procedures Policy and our Corporate Governance Guidelines adopted by the Board of Directors, as well as the charter for our Audit Committee are available on our website at www.nrplp.com. Copies of our annual report, our Code of Business Conduct and Ethics, our Disclosure Controls and Procedures Policy, our Corporate Governance Guidelines and our committee charters will be made available upon written request to our principal executive office at 1415 Louisiana St., Suite 3325, Houston, Texas 77002.

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ITEM 1A. RISK FACTORS

Risks Related to Our Business

Cash distributions are not guaranteed and may fluctuate with our performance and the establishment of financial reserves. In addition, our debt agreements and our partnership agreement place restrictions on our ability to pay, and in some cases raise, the quarterly distribution under certain circumstances.

Because distributions on the common units are dependent on the amount of cash we generate, distributions fluctuate based on our performance. The actual amount of cash that is available to be distributed each quarter depends on numerous factors, some of which are beyond our control and the control of the general partner. Cash distributions are dependent primarily on cash flow, and not solely on profitability, which is affected by non-cash items. Therefore, cash distributions might be made during periods when we record losses and might not be made during periods when we record profits. The actual amount of cash we have to distribute each quarter is reduced by payments in respect of debt service and other contractual obligations, including distributions on the preferred units, fixed charges, maintenance capital expenditures, and reserves for future operating or capital needs that the Board of Directors may determine are appropriate. We have significant debt service obligations and obligations to pay cash distributions on our preferred units. To the extent our Board of Directors deems appropriate, it may determine to decrease the amount of the quarterly distribution on our common units or suspend or eliminate the distribution on our common units altogether. In addition, because our unitholders are required to pay income taxes on their respective shares of our taxable income, our unitholders may be required to pay taxes in excess of any future distributions we make. Our unitholders' share of our portfolio income may be taxable to them even though they receive other losses from our activities. See "—Tax Risks to Our Unitholders—Our unitholders are required to pay taxes on their share of our income even if they do not receive any cash distributions from us. Our unitholders' share of our portfolio income may be taxable to them even though they receive other losses from our activities."

Our partnership agreement requires our consolidated leverage ratio to be less than 3.25x in order to make quarterly distributions on the common units in an amount in excess of $0.45 per unit.

For more information on restrictions on our ability to make distributions on our common units, see "Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations—Liquidity and Capital Resources" and "Item 8. Financial Statements and Supplementary Data—Note 11. Debt, Net" in our Annual Report on Form 10-K filed with the SEC on March 7, 2024.

Our leverage and debt service obligations may adversely affect our financial condition, results of operations and business prospects.

As of December 31, 2023, we and our subsidiaries had approximately $155.5 million of total indebtedness. The terms and conditions governing the indenture for Opco’s revolving credit facility and senior notes:

•	require us to meet certain leverage and interest coverage ratios;
•	require us to dedicate a substantial portion of our cash flow from operations to service our existing debt, thereby reducing the cash available to finance our operations and other business activities and could limit our flexibility in planning for or reacting to changes in our business and the industries in which we operate;
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•	increase our vulnerability to economic downturns and adverse developments in our business;
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•	limit our ability to access the bank and capital markets to raise capital on favorable terms or to obtain additional financing for working capital, capital expenditures or acquisitions or to refinance existing indebtedness;
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•	place restrictions on our ability to obtain additional financing, make investments, lease equipment, sell assets and engage in business combinations;
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•	place us at a competitive disadvantage relative to competitors with lower levels of indebtedness in relation to their overall size or less restrictive terms governing their indebtedness;
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•	make it more difficult for us to satisfy our obligations under our debt agreements and increase the risk that we may default on our debt obligations; and
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•	limit management’s discretion in operating our business.
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Our ability to meet our expenses and debt obligations will depend on our future performance, which will be affected by financial, business, economic, regulatory and other factors. We will not be able to control many of these factors, such as economic conditions and governmental regulation. We cannot be certain that our cash flow will be sufficient to allow us to pay the principal and interest on our debt and meet our other obligations, including payment of distributions on the preferred units. If we do not have sufficient funds, we may be required to refinance all or part of our existing debt, borrow more money, or sell assets or raise equity at unattractive prices, including higher interest rates. We are required to make substantial principal repayments each year in connection with Opco’s senior notes, with approximately $31 million due thereunder during 2024. To the extent we borrow to make some of these payments, we may not be able to refinance these amounts on terms acceptable to us, if at all. We may not be able to refinance our debt, sell assets, borrow more money or access the bank and capital markets on terms acceptable to us, if at all. Our ability to comply with the financial and other restrictive covenants in our debt agreements will be affected by the levels of cash flow from our operations and future events and circumstances beyond our control. Failure to comply with these covenants would result in an event of default under our indebtedness, and such an event of default could adversely affect our business, financial condition and results of operations.

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Global pandemics, including the COVID-19 pandemic have in the past and may continue to adversely affect our business.

The COVID-19 pandemic adversely affected the global economy, disrupted global supply chains and created significant volatility in the financial markets. In addition, the pandemic resulted in travel restrictions, business closures and the institution of quarantining and other restrictions on movement in many communities and global trading markets. Coal markets faced substantial challenges prior to the pandemic, and widespread increases in unemployment and decreases in electricity and steel demand further reduced demand and prices for coal in 2020. In addition, demand for and prices of soda ash decreased in 2020, as global manufacturing slowed. Our Board of Directors determined to suspend cash distributions to our common unitholders with respect to the first quarter of 2020 in order to preserve liquidity due to uncertainties created by the pandemic. In addition, Sisecam Wyoming suspended cash distributions to its members in 2020 due to adverse effects of the pandemic on the global and domestic soda ash markets. Both companies have resumed distributions, however there remains a risk that distributions could be suspended in the future due to another global pandemic.

Prices for both metallurgical and thermal coal are volatile and depend on a number of factors beyond our control. Declines in prices could have a material adverse effect on our business and results of operations.

Coal prices continue to be volatile and prices could decline substantially from current levels. Production by some of our lessees may not be economic if prices decline further or remain at current levels. The prices our lessees receive for their coal depend upon factors beyond their or our control, including:

•	the supply of and demand for domestic and foreign coal;
•	domestic and foreign governmental regulations and taxes;
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•	changes in fuel consumption patterns of electric power generators;
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•	the price and availability of alternative fuels, especially natural gas;
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•	global economic conditions, including the strength of the U.S. dollar relative to other currencies;
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•	global and domestic demand for steel;
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•	tariff rates on imports and trade disputes, particularly involving the United States and China;
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•	the availability of, proximity to and capacity of transportation networks and facilities;
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•	global or national health concerns, including the outbreak of pandemic or contagious disease, such as the COVID-19 pandemic;
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•	weather conditions; and
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•	the effect of worldwide energy conservation measures.
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Natural gas is the primary fuel that competes with thermal coal for power generation, and renewable energy sources continue to gain market share in power generation. The abundance and ready availability of cheap natural gas, together with increased governmental regulations on the power generation industry has caused a number of utilities to switch from thermal coal to natural gas and/or close coal-powered generation plants. This switching has resulted in a decline in thermal coal prices, and to the extent that natural gas prices remain low, thermal coal prices will also remain low. Reduced international demand for export thermal coal and increased competition from global producers has also put downward pressure on thermal coal prices.

Our lessees produce a significant amount of metallurgical coal that is used for steel production domestically and internationally. Since the amount of steel that is produced is tied to global economic conditions, declines in those conditions could result in the decline of steel, coke and metallurgical coal production. Since metallurgical coal is priced higher than thermal coal, some mines on our properties may only operate profitably if all or a portion of their production is sold as metallurgical coal. If these mines are unable to sell metallurgical coal, they may not be economically viable and may be temporarily idled or closed. Any potential future lessee bankruptcy filings could create additional uncertainty as to the future of operations on our properties and could have a material adverse effect on our business and results of operations.

To the extent our lessees are unable to economically produce coal over the long term, the carrying value of our coal mineral rights could be adversely affected. A long-term asset generally is deemed impaired when the future expected cash flow from its use and disposition is less than its book value. For the year ended December 31, 2023, we recorded impairment charges of approximately $0.6 million related to properties that we believe our current or future lessees are unable to operate profitably. Future impairment analyses could result in additional downward adjustments to the carrying value of our assets.

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Prices for soda ash are volatile. Any substantial or extended decline in soda ash prices could have an adverse effect on Sisecam Wyoming’s ability to continue to make distributions to its members and on our results of operations.

The market price of soda ash directly affects the profitability of Sisecam Wyoming’s soda ash production operations. If the market price for soda ash declines, Sisecam Wyoming’s sales will decrease. Historically, the global market and, to a lesser extent, the domestic market for soda ash has been volatile, and those markets are likely to remain volatile in the future. The prices Sisecam Wyoming receives for its soda ash depend on numerous factors beyond Sisecam Wyoming’s control, including worldwide and regional economic and political conditions impacting supply and demand. In addition, the impact of the Sisecam Chemicals Resources' exit from ANSAC and Sisecam Wyoming’s transition to the utilization of Sisecam Group’s global distribution network for some of its export operations beginning 2021 could affect prices received for export sales. Glass manufacturers and other industrial customers drive most of the demand for soda ash, and these customers experience significant fluctuations in demand and production costs. Competition from increased use of glass substitutes, such as plastic and recycled glass, has had a negative effect on demand for soda ash. Substantial or extended declines in prices for soda ash could have a material adverse effect on Sisecam Wyoming’s ability to continue to make distributions to its members and on our results of operations.

We derive a large percentage of our revenues and other income from a small number of coal lessees.

Challenges in the coal mining industry have led to significant consolidation activity. We own significant interests in several of Alpha's mining operations, which accounted for approximately 23% of our total revenues in 2023. We also own significant interests in all of Foresight’s mining operations, which accounted for approximately 16% of our total revenues in 2023. Certain other lessees have made acquisitions over the past few years resulting in their having an increased interest in our coal. Any interruption in these lessees’ ability to make royalty payments to us could have a disproportionate material adverse effect on our business and results of operations.

Bankruptcies in the coal industry, and/or the idling or closure of mines on our properties could have a material adverse effect on our business and results of operations.

While current coal prices have recovered substantially, the recent coal price environment, together with high operating costs and limited access to capital, has caused a number of coal producers to file for protection under The U.S. Bankruptcy Code and/or idle or close mines that they cannot operate profitably. To the extent our leases are accepted or assigned in a bankruptcy process, pre-petition amounts are required to be cured in full, but we may ultimately make concessions in the financial terms of those leases in order for the reorganized company or new lessor to operate profitably going forward. To the extent our leases are rejected, operations on those leases will cease, and we will be unlikely to recover the full amount of our rejection damages claims. More of our lessees may file for bankruptcy in the future, which will create additional uncertainty as to the future of operations on our properties and could have a material adverse effect on our business and results of operations.

Mining operations are subject to operating risks that could result in lower revenues to us.

Our revenues are largely dependent on the level of production of minerals from our properties, and any interruptions to or increases in costs of the production from our properties may reduce our revenues. The level of production and costs thereof are subject to operating conditions or events beyond our or our lessees’ control including:

•	difficulties or delays in acquiring necessary permits or mining or surface rights;
•	reclamation costs and bonding costs;
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•	changes or variations in geologic conditions, such as the thickness of the mineral deposits and the amount of rock embedded in or overlying the mineral deposit;
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•	mining and processing equipment failures and unexpected maintenance problems;
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•	the availability of equipment or parts and increased costs related thereto;
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•	the availability of transportation networks and facilities and interruptions due to transportation delays;
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•	adverse weather and natural disasters, such as heavy rains and flooding;
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•	labor-related interruptions and trained personnel shortages; and
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•	mine safety incidents or accidents, including hazardous conditions, roof falls, fires and explosions.
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While our lessees maintain insurance coverage, there is no assurance that insurance will be available or cover the costs of these risks. Many of our lessees are experiencing rising costs related to regulatory compliance, insurance coverage, permitting and reclamation bonding, transportation, and labor. Increased costs result in decreased profitability for our lessees and reduce the competitiveness of coal as a fuel source. In addition, we and our lessees may also incur costs and liabilities resulting from third-party claims for damages to property or injury to persons arising from their operations. The occurrence of any of these events or conditions could have a material adverse effect on our business and results of operations.

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The adoption of climate change legislation and regulations restricting emissions of greenhouse gases and other hazardous air pollutants have resulted in changes in fuel consumption patterns by electric power generators and a corresponding decrease in coal production by our lessees and reduced coal-related revenues.

Enactment of laws and passage of regulations regarding emissions from the combustion of coal by the U.S., some of its states or other countries, or other actions to limit such emissions, have resulted in and could continue to result in electricity generators switching from coal to other fuel sources and in coal-fueled power plant closures. Further, regulations regarding new coal-fueled power plants could adversely impact the global demand for coal. The potential financial impact on us of existing and future laws, regulations or other policies will depend upon the degree to which any such laws or regulations force electricity generators to diminish their reliance on coal as a fuel source. The amount of coal consumed for domestic electric power generation is affected primarily by the overall demand for electricity, the price and availability of competing fuels for power plants and environmental and other governmental regulations. We expect that substantially all newly constructed power plants in the United States will be fired by natural gas because of lower construction and compliance costs compared to coal-fired plants and because natural gas is a cleaner burning fuel. The increasingly stringent requirements of rules and regulations promulgated under the federal Clean Air Act have resulted in more electric power generators shifting from coal to natural-gas-fired power plants, or to other alternative energy sources such as solar and wind. These changes have resulted in reduced coal consumption and the production of coal from our properties and are expected to continue to have an adverse effect on our coal-related revenues.

In addition to EPA’s greenhouse gas initiatives, there are several other federal rulemakings that are focused on emissions from coal-fired electric generating facilities, including the Cross-State Air Pollution Rule ("CSAPR") as revised in 2021, regulating emissions of nitrogen oxide and sulfur dioxide, and the Mercury and Air Toxics Rule ("MATS"), regulating emissions of hazardous air pollutants. Installation of additional emissions control technologies and other measures required under these and other EPA regulations have made it more costly to operate many coal-fired power plants and have resulted in and are expected to continue to result in plant closures. Further reductions in coal’s share of power generating capacity as a result of compliance with existing or proposed rules and regulations would have a material adverse effect on our coal-related revenues. For more information on regulation of greenhouse gas and other air pollutant emissions, see "Items 1. and 2. Business and Properties—Regulation and Environmental Matters.”

Concerns about the environmental impacts of coal combustion, including perceived impacts on global climate issues, are also resulting in unfavorable lending and investment policies by institutions and insurance companies which could significantly affect our ability to raise capital or maintain current insurance levels.

Global climate issues continue to attract public and scientific attention. Numerous reports have engendered concern about the impacts of human activity, especially fossil fuel combustion, on global climate issues. In addition to government regulation of greenhouse gas and other air pollutant emissions, there have also been efforts in recent years affecting the investment community, including investment advisors, sovereign wealth funds, public pension funds, universities and other groups, promoting the divestment of fossil fuel equities and also pressuring lenders to limit funding to companies engaged in the extraction of fossil fuels, such as coal. One example is the Net Zero Banking Alliance, a group of over 100 banks worldwide representing over 40% of global banking assets who are committed to aligning their investment portfolios with net zero emissions by 2050. Further, in October 2023, the Federal Reserve, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corp. released a finalized set of principles guiding financial institutions with $100 billion or more in assets on the management of physical and transition risks associated with climate change. The impact of such efforts may adversely affect our ability to raise capital. In addition, a number of insurance companies have taken action to limit coverage for companies in the coal industry, which could result in significant increases in our costs of insurance or in our inability to maintain insurance coverage at current levels.

Increased attention to climate change, environmental, social and governance ("ESG") matters and conservation measures may adversely impact our business.

Increasing attention to climate change, societal expectations on companies to address climate change, and investor and societal expectations regarding ESG matters and disclosures, may result in increased costs, reduced profits, increased investigations and litigation, and negative impacts on our access to capital. The SEC has also announced that it is scrutinizing existing climate-change related disclosures in public filings, increasing the potential for enforcement. Any laws or regulations imposing more stringent requirements on our business related to the disclosure of climate related risks may increase compliance costs, and result in potential restrictions on access to capital to the extent we do not meet any climate-related expectations or requirements of financial institutions. The possible promulgation later this year by the SEC of additional reporting requirements for registrants regarding climate risks, targets and metrics may add to the cost of preparing filings and could result in additional disclosures that may further restrict our access to capital.

Organizations that provide information to investors on corporate governance and related matters have developed ratings processes for evaluating companies on their approach to ESG matters, and many of these ratings processes are inconsistent with each other. Such ratings are used by some investors to inform their investment and voting decisions. Unfavorable ESG ratings and recent activism directed at shifting funding away from companies with energy-related assets could lead to increased negative investor sentiment toward us and our industry and to the diversion of investment to other industries, which could have a negative impact on our stock price and our access to and costs of capital. Furthermore, if our competitors’ ESG performance is perceived to be greater than ours, potential or current investors may elect to invest in our competitors instead.

In addition to climate change and other Clean Air Act legislation, our businesses are subject to numerous other federal, state and local laws and regulations that may limit production from our properties and our profitability.

The operations of our lessees and Sisecam Wyoming are subject to stringent health and safety standards under increasingly strict federal, state and local environmental, health and safety laws, including mine safety regulations and governmental enforcement policies. Failure to comply with these laws and regulations may result in the assessment of administrative, civil and criminal penalties, the imposition of cleanup and site restoration costs and liens, the issuance of injunctions to limit or cease operations, the suspension or revocation of permits and other enforcement measures that could have the effect of limiting production from our properties.

New environmental legislation, new regulations and new interpretations of existing environmental laws, including regulations governing permitting requirements, could further regulate or tax mining industries and may also require significant changes to operations, the incurrence of increased costs or the requirement to obtain new or different permits, any of which could decrease our revenues and have a material adverse effect on our financial condition or results of operations. Under SMCRA, our coal lessees have substantial reclamation obligations on properties where mining operations have been completed and are required to post performance bonds for their reclamation obligations. To the extent an operator is unable to satisfy its reclamation obligations or the performance bonds posted are not sufficient to cover those obligations, regulatory authorities or citizens groups could attempt to shift reclamation liability onto the ultimate landowner, which if successful, could have a material adverse effect on our financial condition.

In addition to governmental regulation, private citizens’ groups have continued to be active in bringing lawsuits against coal mine operators and land owners that allege violations of water quality standards resulting from ongoing discharges of pollutants from reclaimed mining operations, including selenium and conductivity. Any determination that a landowner or lessee has liability for discharges from a previously reclaimed mine site would result in uncertainty as to continuing liability for completed and reclaimed coal mine operations and could result in substantial compliance costs or fines. For more information on regulation of greenhouse gas and other air pollutant emissions, see "Items 1. and 2. Business and Properties—Regulation and Environmental Matters.”

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If our lessees do not manage their operations well, their production volumes and our royalty revenues could decrease.

We depend on our lessees to effectively manage their operations on our properties. Our lessees make their own business decisions with respect to their operations within the constraints of their leases, including decisions relating to:

•	the payment of minimum royalties;
•	marketing of the minerals mined;
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•	mine plans, including the amount to be mined and the method and timing of mining activities;
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•	processing and blending minerals;
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•	expansion plans and capital expenditures;
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•	credit risk of their customers;
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•	permitting;
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•	insurance and surety bonding;
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•	acquisition of surface rights and other mineral estates;
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•	employee wages;
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•	transportation arrangements;
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•	compliance with applicable laws, including environmental laws; and
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•	mine closure and reclamation.
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A failure on the part of one of our lessees to make royalty payments, including minimum royalty payments, could give us the right to terminate the lease, repossess the property and enforce payment obligations under the lease. If we repossessed any of our properties, we would seek a replacement lessee. We might not be able to find a replacement lessee and, if we did, we might not be able to enter into a new lease on favorable terms within a reasonable period of time. In addition, the existing lessee could be subject to bankruptcy proceedings that could further delay the execution of a new lease or the assignment of the existing lease to another operator. If we enter into a new lease, the replacement operator might not achieve the same levels of production or sell minerals at the same price as the lessee it replaced. In addition, it may be difficult for us to secure new or replacement lessees.

We have limited approval rights with respect to the management of our Sisecam Wyoming soda ash joint venture, including with respect to cash distributions and capital expenditures. In addition, we are exposed to operating risks that we do not experience in the royalty business through our soda ash joint venture and through our ownership of certain coal transportation assets.

We do not have control over the operations of Sisecam Wyoming. We have limited approval rights with respect to Sisecam Wyoming, and our partner controls most business decisions, including decisions with respect to distributions and capital expenditures. During 2020, Sisecam Wyoming suspended cash distributions to its members due to adverse developments in the soda ash market resulting from the COVID-19 pandemic. Distributions resumed in 2021 but no assurance can be made that additional suspensions will not occur in the future. In December 2021, the parent of the 51% owner of Sisecam Wyoming sold 60% of its interest to Sisecam Chemicals USA Inc., a wholly owned subsidiary of Türkiye Şişe ve Cam Fabrikalari A.Ş. As a result of the transaction, we will continue to appoint three of the seven Board of Managers of Sisecam Wyoming, Sisecam USA will appoint three and Ciner Enterprises Inc. will appoint one. Any changes to the distribution policy or the capital expenditure plans approved by the newly constituted Board of Managers could adversely affect the future cash flows to NRP and the financial condition and results of operations of Sisecam Wyoming.

In addition, we are ultimately responsible for operating the transportation infrastructure at Foresight’s Williamson mine, and have assumed the capital and operating risks associated with that business. As a result of these investments, we could experience increased costs as well as increased liability exposure associated with operating these facilities.

Sisecam Wyoming’s deca stockpiles will substantially deplete by 2024 and its production rates will decline if Sisecam Wyoming does not make further investments or otherwise execute on one or more initiatives to prevent such decline.

In 2024, Sisecam Wyoming’s deca stockpiles will be substantially depleted and Sisecam Wyoming's production rates will decline, which would impact Sisecam Wyoming's profitability. While Sisecam Wyoming is currently evaluating whether and when to pursue one or more initiatives that could offset this decline as well as provide additional soda ash production above current rates, there is no guarantee that any such initiatives or investments will be executed successfully, in a timely manner, or if at all to enable Sisecam Wyoming to maintain its current rates of production.

Sisecam Wyoming's reserve and resource data are estimates based on assumptions that may be inaccurate and are based on existing economic and operating conditions that may change in the future, which could materially and adversely affect the quantities and value of Sisecam Wyoming's reserves and resources.

Sisecam Wyoming's reserve and resource estimates may vary substantially from the actual amounts of minerals Sisecam Wyoming is able to recover economically from their reserves. There are numerous uncertainties inherent in estimating quantities of reserves and resources, including many factors beyond Sisecam Wyoming's control. Estimates of reserves and resources necessarily depend upon a number of variables and assumptions, any one of which may, if incorrect, result in an estimate that varies considerably from actual results. These factors and assumptions relate to, among other aspects:

•	future prices of soda ash, mining and production costs, capital expenditures and transportation costs;
•	future mining technology and processes;
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•	the effects of regulation by governmental agencies; and
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•	geologic and mining conditions, which may not be identified by available exploration data and may differ from their experiences in areas where they currently mine.
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Please read Item 1, “Business—Trona Resources and Trona Reserves” for more information including pertinent additional assumptions regarding Sisecam Wyoming's reserve estimates in this Amendment. Actual production, revenue and expenditures with respect to Sisecam Wyoming's reserves will likely vary from their estimates, and these variations may be material.

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Fluctuations in transportation costs and the availability or reliability of transportation could reduce the production of coal, soda ash and other minerals from our properties.

Transportation costs represent a significant portion of the total delivered cost for the customers of our lessees. Increases in transportation costs could make coal a less competitive source of energy or could make minerals produced by some or all of our lessees less competitive than coal produced from other sources. On the other hand, significant decreases in transportation costs could result in increased competition for our lessees from producers in other parts of the country.

Our lessees depend upon railroads, barges, trucks and beltlines to deliver minerals to their customers. Disruption of those transportation services due to weather-related problems, mechanical difficulties, strikes, lockouts, bottlenecks and/or other events could temporarily impair the ability of our lessees to supply coal to their customers and/or increase their costs. Many of our lessees are currently experiencing transportation-related issues due in particular to decreased availability and reliability of rail services and port congestion. Our lessees’ transportation providers may face difficulties in the future that would impair the ability of our lessees to supply minerals to their customers, resulting in decreased royalty revenues to us.

In addition, Sisecam Wyoming transports its soda ash by rail or truck and ocean vessel. As a result, its business and financial results are sensitive to increases in rail freight, trucking and ocean vessel rates. Increases in transportation costs, including increases resulting from emission control requirements, port taxes and fluctuations in the price of fuel, could make soda ash a less competitive product for glass manufacturers when compared to glass substitutes or recycled glass, or could make Sisecam Wyoming’s soda ash less competitive than soda ash produced by competitors that have other means of transportation or are located closer to their customers. Sisecam Wyoming may be unable to pass on its freight and other transportation costs in full because market prices for soda ash are generally determined by supply and demand forces. In addition, rail operations are subject to various risks that may result in a delay or lack of service at Sisecam Wyoming’s facility, and alternative methods of transportation are impracticable or cost prohibitive. For the year ended December 31, 2023, Sisecam Wyoming shipped over 90% of its soda ash from the Green River facility on a single rail line owned and controlled by Union Pacific. Any substantial interruption in or increased costs related to the transportation of Sisecam Wyoming’s soda ash or the failure to renew the rail contract on favorable terms could have a material adverse effect on our financial condition and results of operations.

Our lessees could satisfy obligations to their customers with minerals from properties other than ours, depriving us of the ability to receive amounts in excess of minimum royalty payments.

Mineral supply contracts generally do not require operators to satisfy their obligations to their customers with resources mined from specific locations. Several factors may influence a lessee’s decision to supply its customers with minerals mined from properties we do not own or lease, including the royalty rates under the lessee’s lease with us, mining conditions, mine operating costs, cost and availability of transportation, and customer specifications. In addition, lessees move on and off of our properties over the course of any given year in accordance with their mine plans. If a lessee satisfies its obligations to its customers with minerals from properties we do not own or lease, production on our properties will decrease, and we will receive lower royalty revenues.

A lessee may incorrectly report royalty revenues, which might not be identified by our lessee audit process or our mine inspection process or, if identified, might be identified in a subsequent period.

We depend on our lessees to correctly report production and royalty revenues on a monthly basis. Our regular lessee audits and mine inspections may not discover any irregularities in these reports or, if we do discover errors, we might not identify them in the reporting period in which they occurred. Any undiscovered reporting errors could result in a loss of royalty revenues and errors identified in subsequent periods could lead to accounting disputes as well as disputes with our lessees.

Risks Related to Our Structure

Unitholders may not be able to remove our general partner even if they wish to do so.

Our managing general partner manages and operates NRP. Unlike the holders of common stock in a corporation, unitholders have only limited voting rights on matters affecting our business. Unitholders have no right to elect the general partner or the Board of Directors on an annual or any other basis.

Furthermore, if unitholders are dissatisfied with the performance of our general partner, they currently have little practical ability to remove our general partner or otherwise change its management. Our general partner may not be removed except upon the vote of the holders of at least 66 2/3% of our outstanding common units (including common units held by our general partner and its affiliates and including common units deemed to be held by the holders of the preferred units who vote along with the common unitholders on an as-converted basis). Because of their substantial ownership in us, the removal of our general partner would be difficult without the consent of both our general partner and its affiliates and the holders of the preferred units.

In addition, the following provisions of our partnership agreement may discourage a person or group from attempting to remove our general partner or otherwise change our management:

•	generally, if a person (other than the holders of preferred units) acquires 20% or more of any class of units then outstanding other than from our general partner or its affiliates, the units owned by such person cannot be voted on any matter; and
•	our partnership agreement contains limitations upon the ability of unitholders to call meetings or to acquire information about our operations, as well as other limitations upon the unitholders’ ability to influence the manner or direction of management.
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As a result of these provisions, the price at which the common units will trade may be lower because of the absence or reduction of a takeover premium in the trading price.

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The preferred units are senior in right of distributions and liquidation and upon conversion, would result in the issuance of additional common units in the future, which could result in substantial dilution of our common unitholders’ ownership interests.

The preferred units rank senior to our common units with respect to distribution rights and rights upon liquidation. We are required to pay quarterly distributions on the preferred units (plus any PIK units issued in lieu of preferred units) in an amount equal to 12.0% per year prior to paying any distributions on our common units. The preferred units also rank senior to the common units in right of liquidation and will be entitled to receive a liquidation preference in any such case.

The preferred units may also be converted into common units under certain circumstances. The number of common units issued in any conversion will be based on the then-current trading price of the common units at the time of conversion. Accordingly, the lower the trading price of our common units at the time of conversion, the greater the number of common units that will be issued upon conversion of the preferred units, which would result in greater dilution to our existing common unitholders. Dilution has the following effects on our common unitholders:

•	an existing unitholder’s proportionate ownership interest in NRP will decrease;
•	the amount of cash available for distribution on each unit may decrease;
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•	the relative voting strength of each previously outstanding unit may be diminished; and
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•	the market price of the common units may decline.
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In addition, to the extent the preferred units are converted into more than 66 2/3% of our common units, the holders of the preferred will have the right to remove our general partner.

We may issue additional common units or preferred units without common unitholder approval, which would dilute a unitholder’s existing ownership interests.

Our general partner may cause us to issue an unlimited number of common units, without common unitholder approval (subject to applicable New York Stock Exchange ("NYSE") rules). We may also issue at any time an unlimited number of equity securities ranking junior or senior to the common units (including additional preferred units) without common unitholder approval (subject to applicable NYSE rules). In addition, we may issue additional common units upon the exercise of the outstanding warrants held by Blackstone. The issuance of additional common units or other equity securities of equal or senior rank will have the following effects:

•	an existing unitholder’s proportionate ownership interest in NRP will decrease;
•	the amount of cash available for distribution on each unit may decrease; and
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•	the relative voting strength of each previously outstanding unit may be diminished; and the market price of the common units may decline.
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Our general partner has a limited call right that may require unitholders to sell their units at an undesirable time or price.

If at any time our general partner and its affiliates own 80% or more of the common units, the general partner will have the right, but not the obligation, which it may assign to any of its affiliates, to acquire all, but not less than all, of the remaining common units held by unaffiliated persons at a price generally equal to the then current market price of the common units. As a result, unitholders may be required to sell their common units at a time when they may not desire to sell them or at a price that is less than the price they would like to receive. They may also incur a tax liability upon a sale of their common units.

Cost reimbursements due to our general partner may be substantial and will reduce our cash available for distribution to unitholders.

Prior to making any distribution on the common units, we reimburse our general partner and its affiliates, including officers and directors of the general partner, for all expenses incurred on our behalf. The reimbursement of expenses and the payment of fees could adversely affect our ability to make distributions. The general partner has sole discretion to determine the amount of these expenses. In addition, our general partner and its affiliates may provide us services for which we will be charged reasonable fees as determined by the general partner.

Conflicts of interest could arise among our general partner and us or the unitholders.

These conflicts may include the following:

•	We do not have any employees and we rely solely on employees of affiliates of the general partner;
•	under our partnership agreement, we reimburse the general partner for the costs of managing and for operating the partnership;
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•	the amount of cash expenditures, borrowings and reserves in any quarter may affect cash available to pay quarterly distributions to unitholders;
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•	the general partner tries to avoid being liable for partnership obligations. The general partner is permitted to protect its assets in this manner by our partnership agreement. Under our partnership agreement the general partner would not breach its fiduciary duty by avoiding liability for partnership obligations even if we can obtain more favorable terms without limiting the general partner’s liability;
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•	under our partnership agreement, the general partner may pay its affiliates for any services rendered on terms fair and reasonable to us. The general partner may also enter into additional contracts with any of its affiliates on behalf of us. Agreements or contracts between us and our general partner (and its affiliates) are not necessarily the result of arm’s-length negotiations; and
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•	the general partner would not breach our partnership agreement by exercising its call rights to purchase limited partnership interests or by assigning its call rights to one of its affiliates or to us.
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In addition, GoldenTree also has certain limited consent rights. In the exercise of their applicable consent rights, conflicts of interest could arise between us and our general partner on the one hand, and GoldenTree on the other hand.

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The control of our general partner may be transferred to a third party without unitholder consent. A change of control may result in defaults under certain of our debt instruments and the triggering of payment obligations under compensation arrangements.

Our general partner may transfer its general partner interest to a third party in a merger or in a sale of all or substantially all of its assets without the consent of our unitholders. Furthermore, there is no restriction in our partnership agreement on the ability of the managing general partner from transferring its general partnership interest in our general partner to a third party. The new owner of our general partner would then be in a position to replace the Board of Directors and officers with its own choices and to control their decisions and actions.

In addition, a change of control would constitute an event of default under our debt agreements. During the continuance of an event of default under our debt agreements, the administrative agent may terminate any outstanding commitments of the lenders to extend credit to us and/or declare all amounts payable by us immediately due and payable. In addition, upon a change of control, the holders of the preferred units would have the right to require us to redeem the preferred units at the liquidation preference or convert all of their preferred units into common units. A change of control also may trigger payment obligations under various compensation arrangements with our officers.

Unitholders may not have limited liability if a court finds that unitholder actions constitute control of our business.

Our general partner generally has unlimited liability for our obligations, such as our debts and environmental liabilities, except for those contractual obligations that are expressly made without recourse to our general partner. Under Delaware law, however, a unitholder could be held liable for our obligations to the same extent as a general partner if a court determined that the right of unitholders to remove our general partner or to take other action under our partnership agreement constituted participation in the "control" of our business. In addition, Section 17-607 of the Delaware Revised Uniform Limited Partnership Act provides that under some circumstances, a unitholder may be liable to us for the amount of a distribution for a period of three years from the date of the distribution.

Tax Risks to Our Unitholders

Our tax treatment depends on our status as a partnership for U.S. federal income tax purposes as well as our not being subject to a material amount of entity-level taxation by individual states. If the Internal Revenue Service ("IRS") were to treat us as a corporation for U.S. federal income tax purposes or we were to become subject to material additional amounts of entity-level taxation for state tax purposes, then our cash available for distribution to unitholders would be substantially reduced.

The anticipated after-tax economic benefit of an investment in our units depends largely on our being treated as a partnership for U.S. federal income tax purposes. Despite the fact that we are organized as a limited partnership under Delaware law, we would be treated as a corporation for U.S. federal income tax purposes unless we satisfy a "qualifying income" requirement. Based on our current operations and current Treasury Regulations, we believe we satisfy the qualifying income requirement. However, we have not requested, and do not plan to request, a ruling from the IRS on this or any other matter affecting us. Failing to meet the qualifying income requirement or a change in current law could cause us to be treated as a corporation for U.S. federal income tax purposes or otherwise subject us to taxation as an entity.

If we were treated as a corporation for U.S. federal income tax purposes, we would pay U.S. federal income tax on our taxable income at the corporate tax rate and would likely be liable for state income tax at varying rates. Distributions to our unitholders would generally be taxed again as corporate distributions, and no income, gains, losses, deductions or credits would flow through to our unitholders. Because tax would be imposed upon us as a corporation, our cash available for distribution to our unitholders would be substantially reduced. Therefore, treatment of us as a corporation would result in a material reduction in the anticipated cash flow and after-tax return to our unitholders, likely causing a substantial reduction in the value of our units.

At the state level, several states have been evaluating ways to subject partnerships to entity-level taxation through the imposition of state income, franchise and other forms of taxation. We currently own assets and conduct business in several states, many of which impose a margin or franchise tax. In the future, we may expand our operations. Imposition of a similar tax on us in a jurisdiction in which we operate or in other jurisdictions to which we may expand could substantially reduce the cash available for distribution to our unitholders.

The tax treatment of publicly traded partnerships or an investment in our units could be subject to potential legislative, judicial or administrative changes or differing interpretations, possibly applied on a retroactive basis.

The present U.S. federal income tax treatment of publicly traded partnerships, including us, or an investment in our units, may be modified by administrative, legislative or judicial changes or differing interpretations at any time. Members of Congress have frequently proposed and considered substantive changes to the existing U.S. federal income tax laws that would affect publicly traded partnerships, including proposals that would eliminate our ability to qualify for partnership tax treatment. Recent proposals have provided for the expansion of the qualifying income exception for publicly traded partnerships in certain circumstances and other proposals have provided for the total elimination of the qualifying income exception upon which we rely for our partnership tax treatment. Further, while unitholders of publicly traded partnerships are, subject to certain limitations, entitled to a deduction equal to 20% of their allocable share of a publicly traded partnership’s “qualified business income,” this deduction is scheduled to expire with respect to taxable years beginning after December 31, 2025.

In addition, the Treasury Department has issued, and in the future may issue, regulations interpreting those laws that affect publicly traded partnerships. There can be no assurance that there will not be further changes to U.S. federal income tax laws or the Treasury Department’s interpretation of the qualifying income rules in a manner that could impact our ability to qualify as a partnership in the future.

Any modification to the U.S. federal income tax laws and interpretations thereof may or may not be retroactively applied and could make it more difficult or impossible for us to meet the exception for certain publicly traded partnerships to be treated as partnerships for U.S. federal income tax purposes. We are unable to predict whether any changes or other proposals will ultimately be enacted. Any future legislative changes could negatively impact the value of an investment in our units. You are urged to consult with your own tax advisor with respect to the status of regulatory or administrative developments and proposals and their potential effect on your investment in our units.

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Certain U.S. federal income tax preferences currently available with respect to coal exploration and development may be eliminated as a result of future legislation.

Changes to U.S. federal income tax laws have been proposed in a prior session of Congress that would eliminate certain key U.S. federal income tax preferences relating to coal exploration and development. These changes include, but are not limited to (i) repealing capital gains treatment of coal and lignite royalties, (ii) eliminating current deductions and 60-month amortization for exploration and development costs relating to coal and other hard mineral fossil fuels, and (iii) repealing the percentage depletion allowance with respect to coal properties. If enacted, these changes would limit or eliminate certain tax deductions that are currently available with respect to coal exploration and development, and any such change could increase the taxable income allocable to our unitholders and negatively impact the value of an investment in our units.

Our unitholders are required to pay taxes on their share of our taxable income even if they do not receive any cash distributions from us. Our unitholders' share of our portfolio income may be taxable to them even though they receive other losses from our activities.

Because our unitholders are treated as partners to whom we allocate taxable income that could be different in amount than the cash we distribute, our unitholders are required to pay any U.S. federal income taxes and, in some cases, state and local income taxes on their share of our taxable income even if they receive no cash distributions from us. Our unitholders may not receive cash distributions from us equal to their share of our taxable income or even equal to the actual tax due from them with respect to that income.

For our unitholders subject to the passive loss rules, our current operations include portfolio activities (such as our coal and mineral royalty businesses) and passive activities (such as our soda ash business). Any passive losses we generate will only be available to offset our passive income generated in the future and will not be available to offset (i) our portfolio income, including income related to our coal and mineral royalty businesses, (ii) a unitholder’s income from other passive activities or investments, including investments in other publicly traded partnerships, or (iii) a unitholder’s salary or active business income. Thus, our unitholders' share of our portfolio income may be subject to U.S. federal income tax, regardless of other losses they may receive from us.

We may engage in transactions to reduce our indebtedness and manage our liquidity that generate taxable income (including income and gain from the sale of properties and cancellation of indebtedness income) allocable to our unitholders, and income tax liabilities arising therefrom may exceed any distributions made with respect to their units.

We may engage in transactions to reduce our leverage and manage our liquidity that would result in income and gain to our unitholders without a corresponding cash distribution. For example, we may sell assets and use the proceeds to repay existing debt, in which case, our unitholders could be allocated taxable income and gain resulting from the sale without receiving a cash distribution. Further, we may pursue opportunities to reduce our existing debt, such as debt exchanges, debt repurchases, or modifications of our existing debt that would result in “cancellation of indebtedness income” (also referred to as “COD income”) being allocated to our unitholders as ordinary taxable income. Our unitholders may be allocated income and gain from these transactions, and income tax liabilities arising therefrom may exceed any distributions we make to our unitholders. The ultimate tax effect of any such income allocations will depend on the unitholder's individual tax position, including, for example, the availability of any suspended passive losses that may offset some portion of the allocable income. Our unitholders may, however, be allocated substantial amounts of ordinary income subject to taxation, without any ability to offset such allocated income against any capital losses attributable to the unitholder’s ultimate disposition of its units. Our unitholders are encouraged to consult their tax advisors with respect to the consequences to them.

If the IRS contests the U.S. federal income tax positions we take, the market for our units may be adversely impacted and the cost of any IRS contest will reduce our cash available for distribution to our unitholders.

We have not requested a ruling from the IRS with respect to our treatment as a partnership for U.S. federal income tax purposes or any other matter affecting us. The IRS may adopt positions that differ from the positions we take. It may be necessary to resort to administrative or court proceedings to sustain some or all of the positions we take. A court may not agree with some or all of the positions we take. Any contest by the IRS may materially and adversely impact the market for our units and the price at which they trade. In addition, our costs of any contest by the IRS will be borne indirectly by our unitholders and our general partner because the costs will reduce our cash available for distribution.

If the IRS makes audit adjustments to our income tax returns, it (and some states) may assess and collect any taxes (including any applicable penalties and interest) resulting from such audit adjustments directly from us, in which case our cash available for distribution to our unitholders might be substantially reduced.

If the IRS makes audit adjustments to our income tax returns, it (and some states) may assess and collect any taxes (including any applicable penalties and interest) resulting from such audit adjustments directly from us. To the extent possible, our general partner may elect to either pay the taxes (including any applicable penalties and interest) directly to the IRS or, if we are eligible, issue a revised information statement to each unitholder and former unitholder with respect to an audited and adjusted return. Although our general partner may elect to have our unitholders and former unitholders take such audit adjustments into account and pay any resulting taxes (including applicable penalties or interest) in accordance with their interests in us during the tax year under audit, there can be no assurance that such election will be practical, permissible or effective in all circumstances. As a result, our current unitholders may bear some or all of the tax liability resulting from such audit adjustment, even if such unitholders did not own units in us during the tax year under audit. If, as a result of any such audit adjustment, we are required to make payments of taxes, penalties and interest, our cash available for distribution to our unitholders might be substantially reduced.

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Tax gain or loss on the disposition of our common units could be more or less than expected.

If our unitholders sell their common units, they will recognize a gain or loss equal to the difference between the amount realized and their tax basis in those common units. Distributions in excess of a common unitholder's allocable share of our net taxable income result in a decrease in the tax basis in such unitholder's common units. Accordingly, the amount, if any, of such prior excess distributions with respect to the common units sold will, in effect, become taxable income to our common unitholders if they sell such common units at a price greater than their tax basis in those common units, even if the price they receive is less than their original cost. In addition, because the amount realized includes a unitholder’s share of our nonrecourse liabilities, if our unitholders sell their common units, they may incur a tax liability in excess of the amount of cash they receive from the sale.

A substantial portion of the amount realized from a unitholder’s sale of our units, whether or not representing gain, may be taxed as ordinary income due to potential recapture items, including depletion and depreciation recapture. Thus, a unitholder may recognize both ordinary income and capital loss from the sale of units if the amount realized on a sale of such units is less than such unitholder’s adjusted basis in the units. Net capital loss may only offset capital gains and, in the case of individuals, up to $3,000 of ordinary income per year. In the taxable period in which a unitholder sells its units, such unitholder may recognize ordinary income from our allocations of income and gain to such unitholder prior to the sale and from recapture items that generally cannot be offset by any capital loss recognized upon the sale of units.

Our unitholders may be subject to limitation on their ability to deduct interest expense incurred by us.

In general, we are entitled to a deduction for interest paid or accrued on indebtedness properly allocable to our trade or business during our taxable year. However, our deduction for “business interest” is limited to the sum of our business interest income and 30% of our “adjusted taxable income.” For the purposes of this limitation, our adjusted taxable income is computed without regard to any business interest expense or business interest income. If our “business interest” is subject to limitation under these rules, our unitholders will be limited in their ability to deduct their share of any interest expense that has been allocated to them. As a result, unitholders may be subject to limitation on their ability to deduct interest expense incurred by us.

Tax-exempt entities face unique tax issues from owning our units that may result in adverse tax consequences to them.

Investment in our units by tax-exempt entities, such as employee benefit plans and individual retirement accounts (known as IRAs) raises issues unique to them. For example, virtually all of our income allocated to organizations that are exempt from U.S. federal income tax, including IRAs and other retirement plans, will be unrelated business taxable income and will be taxable to them. Additionally, all or part of any gain recognized by such tax-exempt organization upon a sale or other disposition of our units may be unrelated business taxable income and may be taxable to them. Tax-exempt entities should consult a tax advisor before investing in our units.

Non-U.S. unitholders will be subject to U.S. federal income taxes and withholding with respect to their income and gain from owning our units.

Non-U.S. unitholders are generally taxed and subject to income tax filing requirements by the United States on income effectively connected with a U.S. trade or business. Income allocated to our unitholders and any gain from the sale of our units will generally be considered to be “effectively connected” with a U.S. trade or business. As a result, distributions to a non-U.S. unitholder will be subject to withholding at the highest applicable effective tax rate and a non-U.S. unitholder who sells or otherwise disposes of a unit will also be subject to U.S. federal income tax on the gain realized from the sale or disposition of that unit. In addition to the withholding tax imposed on distributions of effectively connected income, distributions to a non-U.S. unitholder will also be subject to a 10% withholding tax on the amount of any distribution in excess of our cumulative net income. As we do not compute our cumulative net income for such purposes due to the complexity of the calculation and lack of clarity in how it would apply to us, we intend to treat all of our distributions as being in excess of our cumulative net income for such purposes and subject to such 10% withholding tax. Accordingly, distributions to a non-U.S. unitholder will be subject to a combined withholding tax rate equal to the sum of the highest applicable effective tax rate and 10%.

Moreover, the transferee of an interest in a partnership that is engaged in a U.S. trade or business is generally required to withhold 10% of the “amount realized” by the transferor unless the transferor certifies that it is not a foreign person. While the determination of a partner’s “amount realized” generally includes any decrease of a partner’s share of the partnership’s liabilities, the Treasury regulations provide that the “amount realized” on a transfer of an interest in a publicly traded partnership, such as our common units, will generally be the amount of gross proceeds paid to the broker effecting the applicable transfer on behalf of the transferor, and thus will be determined without regard to any decrease in that partner’s share of a publicly traded partnership’s liabilities. For a transfer of interests in a publicly traded partnership that is effected through a broker, the obligation to withhold is imposed on the transferor’s broker. Current and prospective non-U.S. unitholders should consult their tax advisors regarding the impact of these rules on an investment in our common units.

We will treat each purchaser of our common units as having the same tax benefits without regard to the actual common units purchased. The IRS may challenge this treatment, which could adversely affect the value of the common units.

Because we cannot match transferors and transferees of our common units and for other reasons, we have adopted depreciation and amortization positions that may not conform to all aspects of existing Treasury Regulations. A successful IRS challenge to those positions could adversely affect the amount of tax benefits available to our unitholders. It also could affect the timing of these tax benefits or the amount of gain from the sale of common units and could have a negative impact on the value of our common units or result in audit adjustments to our unitholders' tax returns.

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We have adopted certain valuation methodologies in determining a unitholder’s allocations of income, gain, loss and deduction. The IRS may challenge these methodologies or the resulting allocations, and such a challenge could adversely affect the value of our common units.

In determining the items of income, gain, loss and deduction allocable to our unitholders, including when we issue additional units, we must determine the fair market value of our assets. Although we may from time to time consult with professional appraisers regarding valuation matters, we make many fair market value estimates using a methodology based on the market value of our common units as a means to measure the fair market value of our assets. The IRS may challenge these valuation methods and the resulting allocations of income, gain, loss and deduction.

A successful IRS challenge to these methods or allocations could adversely affect the timing or amount of taxable income or loss being allocated to our unitholders. It also could affect the amount of gain recognized from the sale of our common units, have a negative impact on the value of our common units or result in audit adjustments to our unitholders’ tax returns without the benefit of additional deductions.

We generally prorate our items of income, gain, loss and deduction between transferors and transferees of our common units each month based upon the ownership of our common units on the first day of each month, instead of on the basis of the date a particular unit is transferred. The IRS may challenge this treatment, which could change the allocation of items of income, gain, loss and deduction among our unitholders.

We generally prorate our items of income, gain, loss and deduction between transferors and transferees of our common units each month based upon the ownership of our common units on the first day of each month (the "Allocation Date"), instead of on the basis of the date a particular unit is transferred. Similarly, we generally allocate (i) certain deductions for depreciation of capital additions, (ii) gain or loss realized on a sale or other disposition of our assets, and (iii) in the discretion of the general partner, any other extraordinary item of income, gain, loss or deduction based upon ownership on the Allocation Date. Treasury Regulations allow a similar monthly simplifying convention, but such regulations do not specifically authorize the use of the proration method we have adopted. If the IRS were to challenge our proration method, we may be required to change the allocation of items of income, gain, loss and deduction among our unitholders.

A unitholder whose units are the subject of a securities loan (e.g., a loan to a "short seller" to cover a short sale of units) may be considered as having disposed of those units. If so, such unitholder would no longer be treated for tax purposes as a partner with respect to those units during the period of the loan and may recognize gain or loss from the disposition.

Because there are no specific rules governing the U.S. federal income tax consequence of loaning a partnership interest, a unitholder whose units are the subject of a securities loan may be considered as having disposed of the loaned units. In that case, the unitholder may no longer be treated for tax purposes as a partner with respect to those units during the period of the loan to the short seller and the unitholder may recognize gain or loss from such disposition. Moreover, during the period of the loan, any of our income, gain, loss or deduction with respect to those units may not be reportable by the unitholder and any cash distributions received by the unitholder as to those units could be fully taxable as ordinary income. Our unitholders desiring to assure their status as partners and avoid the risk of gain recognition from a loan of their units are urged to consult a tax advisor to determine whether it is advisable to modify any applicable brokerage account agreements to prohibit their brokers from borrowing their units.

As a result of investing in our units, our unitholders are likely subject to state and local taxes and return filing requirements in jurisdictions where we operate or own or acquire property.

In addition to U.S. federal income taxes, our unitholders are likely subject to other taxes, including state and local taxes, unincorporated business taxes and estate, inheritance or intangible taxes that are imposed by the various jurisdictions in which we conduct business or own property now or in the future, even if our unitholders do not live in any of those jurisdictions. Our unitholders are likely required to file state and local income tax returns and pay state and local income taxes in some or all of these various jurisdictions. Further, our unitholders may be subject to penalties for failure to comply with those requirements. We own property and conduct business in a number of states in the United States. Most of these states impose an income tax on individuals, corporations and other entities. As we make acquisitions or expand our business, we may own assets or conduct business in additional states that impose a personal income tax. It is the unitholder's responsibility to file all U.S. federal, state and local tax returns and pay any taxes due in these jurisdictions. Unitholders should consult with their own tax advisors regarding the filing of such tax returns, the payment of such taxes, and the deductibility of any taxes paid.

General Risks

Our business is subject to cybersecurity risks. ****

Our business is increasingly dependent on information and operational technologies and services. Threats to information technology systems associated with cybersecurity risks and cyber incidents or attacks continue to grow. Although we utilize various procedures and controls to mitigate our exposure to such risks, cybersecurity attacks and other cyber events are evolving, unpredictable, and sometimes difficult to detect, and could lead to unauthorized access to sensitive information or render data or systems unusable.

In addition, the frequency and magnitude of cyber-attacks is increasing and attackers have become more sophisticated. Cyber-attacks are similarly evolving and include without limitation use of malicious software, surveillance, credential stuffing, spear phishing, social engineering, use of deepfakes (i.e., highly realistic synthetic media generated by artificial intelligence), attempts to gain unauthorized access to data, and other electronic security breaches that could lead to disruptions in critical systems, unauthorized release of confidential or otherwise protected information and corruption of data. We may be unable to anticipate, detect or prevent future attacks, particularly as the methodologies used by attackers change frequently or are not recognized until deployed. We may also be unable to investigate or remediate incidents as attackers are increasingly using techniques and tools designed to circumvent controls, to avoid detection, and to remove or obfuscate forensic evidence.

While we presently maintain insurance coverage to protect against cybersecurity risks, we cannot ensure that it will be sufficient to cover any particular losses we may experience as a result of such cyber-attacks. Our implementation of various procedures and controls to monitor and mitigate security threats and to increase security for our information, facilities and infrastructure may result in increased capital and operating costs. Moreover, there can be no assurance that such procedures and controls will be sufficient to prevent cyber-attacks or other incidents from occurring. If a cyber-attack was to occur, it could lead to losses of sensitive information, critical infrastructure or capabilities essential to our operations, misdirected wire transfers, an inability to settle transactions or maintain operations, disruptions in operations, or other adverse events. If we were to experience an attack and our security measures failed, the potential consequences to our business and the communities in which we operate could be significant and could harm our reputation and lead to financial losses from remedial actions, loss of business or potential liability, including regulatory enforcement, violation of privacy or securities laws and regulations, and individual or class action claims. Any cyber incident could have a material adverse effect on our business, financial condition and results of operations.

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PART IV

ITEM 15. EXHIBITS AND FINANCIAL STATEMENT SCHEDULES

(a)(1) and (2) Financial Statements and Schedules

(1) See "Item 8. Financial Statements and Supplementary Data." in our Annual Report on Form 10-K filed with the SEC on March 7, 2024.

(2) All schedules are omitted because they are not required or because the information is immaterial or provided elsewhere in the Consolidated Financial Statements and Notes thereto in our Form 10-K filed with the SEC on March 7, 2024.

(a)(3) Sisecam Wyoming LLC Financial Statements

The financial statements of Sisecam Wyoming LLC required pursuant to Rule 3-09 of Regulation S-X are included in as Exhibit 99.1 in our Annual Report on Form 10-K filed with the SEC on March 7, 2024.

(a)(4) Exhibits

Exhibit<br> Number	Description
3.1	Fifth Amended and Restated Agreement of Limited Partnership of Natural Resource Partners L.P., dated as of March 2, 2017 (incorporated by reference to Exhibit 3.1 to Current Report on Form 8-K filed on March 6, 2017).
3.2	Fifth Amended and Restated Agreement of Limited Partnership of NRP (GP) LP, dated as of December 16, 2011 (incorporated by reference to Exhibit 3.1 to Current Report on Form 8-K filed on December 16, 2011).
3.3	Fifth Amended and Restated Limited Liability Company Agreement of GP Natural Resource Partners LLC, dated as of October 31, 2013 (incorporated by reference to Exhibit 3.1 to Current Report on Form 8-K filed on October 31, 2013).
3.4	Amended and Restated Limited Liability Company Agreement of NRP (Operating) LLC, dated as of October 17, 2002 (incorporated by reference to Exhibit 3.4 of Annual Report on Form 10-K for the year ended December 31, 2002).
3.5	Certificate of Limited Partnership of Natural Resource Partners L.P. (incorporated by reference to Exhibit 3.1 to the Registration Statement on Form S-1 filed April 19, 2002, File No. 333-86582).
4.1	Note Purchase Agreement dated as of June 19, 2003 among NRP (Operating) LLC and the Purchasers signatory thereto (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed June 23, 2003).
4.2	First Amendment, dated as of July 19, 2005, to Note Purchase Agreement dated as of June 19, 2003 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.2 to Current Report on Form 8-K filed on July 20, 2005).
4.3	Second Amendment, dated as of March 28, 2007, to Note Purchase Agreement dated as of June 19, 2003 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.2 to Current Report on Form 8-K filed on March 29, 2007).
4.4	First Supplement to Note Purchase Agreement, dated as of July 19, 2005 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on July 20, 2005).
4.5	Second Supplement to Note Purchase Agreement, dated as of March 28, 2007 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on March 29, 2007).
4.6	Third Supplement to Note Purchase Agreement, dated as of March 25, 2009 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on March 26, 2009).
4.7	Fourth Supplement to Note Purchase Agreement, dated as of April 20, 2011 among NRP (Operating) LLC and the purchasers signatory thereto (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on April 21, 2011).
4.8	Subsidiary Guarantee of Senior Notes of NRP (Operating) LLC, dated June 19, 2003 (incorporated by reference to Exhibit 4.5 to Current Report on Form 8-K filed June 23, 2003).
4.9	Form of Series A Note (incorporated by reference to Exhibit 4.2 to Current Report on Form 8-K filed June 23, 2003).
4.10	Form of Series D Note (incorporated by reference to Exhibit 4.12 to Annual Report on Form 10-K filed February 28, 2007).

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Exhibit<br> Number	Description
4.11	Form of Series E Note (incorporated by reference to Exhibit 4.3 to Current Report on Form 8-K filed March 29, 2007).
4.12	Form of Series F Note (incorporated by reference to Exhibit 4.2 to Quarterly Report on Form 10-Q filed May 7, 2009).
4.13	Form of Series G Note (incorporated by reference to Exhibit 4.3 to Quarterly Report on Form 10-Q filed May 7, 2009).
4.14	Form of Series H Note (incorporated by reference to Exhibit 4.2 to Quarterly Report on Form 10-Q filed May 5, 2011).
4.15	Form of Series I Note (incorporated by reference to Exhibit 4.3 to Quarterly Report on Form 10-Q filed May 5, 2011).
4.16	Form of Series J Note (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on June 15, 2011).
4.17	Form of Series K Note (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on October 3, 2011).
4.18	Registration Rights Agreement, dated as of January 23, 2013, by and among Natural Resource Partners L.P. and the Investors named therein (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on January 25, 2013).
4.19	Third Amendment, dated as of June 16, 2015, to Note Purchase Agreements, dated as of June 19, 2003, among NRP (Operating) LLC and the holders named therein (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on June 18, 2015).
4.20	Fourth Amendment, dated as of September 9, 2016, to Note Purchase Agreements, dated as of June 19, 2003, among NRP (Operating) LLC and the holders named therein (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on September 12, 2016).
4.21	Indenture, dated April 29, 2019, by and among Natural Resource Partners L.P. and NRP Finance Corporation, as issuers, and Wilmington Trust, National Association, as trustee (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on May 2, 2019).
4.22	Form of 9.125% Senior Notes due 2025 (contained in Exhibit 1 to Exhibit 4.21).
4.23	Registration Rights Agreement dated as of March 2, 2017, by and among Natural Resource Partners L.P. and the Purchasers named therein (incorporated by reference to Exhibit 4.2 to Current Report on Form 8-K filed on March 6, 2017).
4.24	Form of Warrant to Purchase Common Units (incorporated by reference to Exhibit 4.1 to Current Report on Form 8-K filed on March 6, 2017).
4.25	Description of Equity Securities of Natural Resource Partners L.P. (incorporated by reference to Exhibit 4.25 to Annual Report on Form 10-K filed on February 27, 2020).
10.1	Third Amended and Restated Credit Agreement, dated as of June 16, 2015, by and among NRP (Operating) LLC, the lenders party thereto, Citibank, N.A. as Administrative Agent and Collateral Agent, Citigroup Global Markets Inc. and Wells Fargo Securities LLC as Joint Lead Arrangers and Joint Bookrunners, and Citibank, N.A., as Syndication Agent (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on June 18, 2015).
10.2	First Amendment, dated as of June 3, 2016, to Third Amended and Restated Credit Agreement, dated as of June 16, 2015, by and among NRP (Operating) LLC, the lenders party thereto, Citibank, N.A. as Administrative Agent and Collateral Agent, Citigroup Global Markets Inc. and Wells Fargo Securities LLC as Joint Lead Arrangers and Joint Bookrunners, and Citibank, N.A., as Syndication Agent (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on June 7, 2016).
10.3	First Amended and Restated Omnibus Agreement, dated as of April 22, 2009, by and among Western Pocahontas Properties Limited Partnership, Great Northern Properties Limited Partnership, New Gauley Coal Corporation, Robertson Coal Management LLC, GP Natural Resource Partners LLC, NRP (GP) LP, Natural Resource Partners L.P. and NRP (Operating) LLC (incorporated by reference to Exhibit 10.1 to Quarterly Report on Form 10-Q filed May 7, 2009).
10.4	Limited Liability Company Agreement of Sisecam Wyoming LLC, dated June 30, 2014 (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed by Sisecam Resources LP on July 2, 2014).
10.5	Amendment No. 1 to the Limited Liability Company Agreement of Sisecam Wyoming LLC dated November 5, 2015 (incorporated by reference to Exhibit 10.22 to Annual Report on Form 10-K filed by Sisecam Resources LP on March 11, 2016).

Table of Contents

Exhibit<br> Number	Description
10.6	Second Amendment, dated as of March 2, 2017, to Third Amended and Restated Credit Agreement, dated as of June 16, 2015, by and among NRP (Operating) LLC, the lenders party thereto, Citibank, N.A. as Administrative Agent and Collateral Agent, Citigroup Global Markets Inc. and Wells Fargo Securities LLC as Joint Lead Arrangers and Joint Bookrunners, and Citibank, N.A., as Syndication Agent (incorporated by reference to Exhibit 10.3 to Current Report on Form 8-K filed on March 6, 2017).
10.7	Fourth Amendment, dated as of April 3, 2019, to Third Amended and Restated Credit Agreement, dated as of June 16, 2015, by and among NRP (Operating) LLC and the lenders party thereto (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on April 9, 2019).
10.8	Master Assignment Agreement and Fifth Amendment to Third Amended Credit Agreement, dated as of August 9, 2022 by and among NRP (Operating) LLC, the Lenders party thereto, the Exiting Lenders, and Zions Bancorporation, N.A. dba Amegy Bank, as administrative agent for the Lenders, as Swingline Lender, and as an Issuing Bank (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on August 11, 2022).
10.9	Sixth Amendment to the Third Amended and Restated Credit Agreement, dated as of May 11, 2023, by and among NRP (Operating) LLC, the lenders party thereto and Zions Bancorporation, N.A. dba Amegy Bank, as administrative agent and collateral agent (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on May 15, 2023).
10.10	New Lender Agreement, dated as of May 11, 2023, by and among NRP (Operating) LLC, Zions Bancorporation, N.A. dba Amegy Bank, and Gulf Capital Bank (incorporated by reference to Exhibit 10.2 to Current Report on Form 8-K filed on May 15, 2023).
10.11	New Lender Agreement, dated as of February 1, 2024, by and among NRP (Operating) LLC, Zions Bancorporation, N.A. dba Amegy Bank, and Summit Community Bank (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on February 6, 2024).
10.12	Commitment Increase Agreement dated as of February 14, 2024, by and among NRP (Operating) LLC, Zions Bancorporation, N.A. dba Amegy Bank, and Frost Bank (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on February 20, 2024).
10.13	New Lender Agreement, dated as of September 1, 2022 by and among NRP (Operating) LLC, the Borrower, Zions Bancorporation, N.A. dba Amegy Bank, in its capacity as administrative agent under the Fifth Amendment to Third Amended Credit Agreement and Prosperity Bank, the New Lender (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on September 8, 2022).
10.14	New Lender Agreement, dated as of April 8, 2019, by and among NRP (Operating) LLC and the lenders party thereto (incorporated by reference to Exhibit 10.2 to Current Report on Form 8-K filed on April 9, 2019).
10.15	Board Representation and Observation Rights Agreement dated as of March 2, 2017, by and among Natural Resource Partners L.P., Robertson Coal Management LLC, GP Natural Resource Partners LLC, NRP (GP) LP, BTO Carbon Holdings L.P. and the GoldenTree Purchasers named therein (incorporated by reference to Exhibit 10.2 to Current Report on Form 8-K filed on March 6, 2017)
10.16	Master Amendment and Supplement to Coal Mining and Transportation Lease Agreements and Parent Guaranty dated June 30, 2020 by and among NRP (Operating) LLC, WPP LLC, Hod LLC, Independence Land Company, LLC, Williamson Transport LLC, Foresight Energy LP, Foresight Energy GP LLC, Foresight Energy LLC, Macoupin Energy, LLC, Williamson Energy, LLC, Sugar Camp Energy, LLC, Hillsboro Energy LLC, Foresight Energy Resources LLC, and Foresight Energy Operating LLC (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on July 1, 2020).
10.17	Limited Waiver dated February 28, 2020 by Natural Resource Partners L.P., GP Natural Resource Partners LLC, NRP (GP) LP, and NRP (Operating) LLC (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on March 3, 2020).
10.18	Right of First Offer Agreement dated as of February 28, 2020 by and among Pocahontas Royalties LLC, Natural Resource Partners L.P., GP Natural Resource Partners LLC, NRP (GP) LP, and NRP (Operating) LLC. (incorporated by reference to Exhibit 10.2 to Current Report on Form 8-K filed on March 3, 2020).
10.19+	Natural Resource Partners L.P. 2017 Long-Term Incentive Plan (incorporated by reference to Exhibit 10.1 to Current Report on Form 8-K filed on January 17, 2018).
10.20+	Form of Phantom Unit Award Agreement (Employees and Service Providers) (incorporated by reference to Exhibit 4.5 to Registration Statement on Form S-8 filed on February 9, 2018).
10.21+	Form of Phantom Unit Award Agreement (Directors) (incorporated by reference to Exhibit 4.6 to Registration Statement on Form S-8 filed on February 9, 2018).
10.22+	Form of Phantom Unit Award Agreement (Employees and Service Providers) (incorporated by reference to Exhibit 10.13 to Annual Report on Form 10-K filed on February 27, 2020).
10.23+	Form of Phantom Form of Phantom Unit Award Agreement (Directors) (incorporated by reference to Exhibit 10.14 to Annual Report on Form 10-K filed on February 27, 2020).
10.24+	Form of Phantom Unit Award Agreement (Directors with Deferral Election) (incorporated by reference to Exhibit 10.15 to Annual Report on Form 10-K filed on February 27, 2020).
21.1	List of Subsidiaries of Natural Resource Partners L.P (incorporated by reference to Exhibit 21.1 to Annual Report on Form 10-K filed on March 7, 2024).
23.1	Consent of Ernst & Young LLP (PCAOB ID 42) (Houston, Texas)(incorporated by reference to Exhibit 23.1 to Annual Report on Form 10-K filed on March 7, 2024).
23.2	Consent of BDO USA, P.C (PCAOB ID 243) (incorporated by reference to Exhibit 23.2 to Annual Report on Form 10-K filed on March 7, 2024).
23.3	Consent of Deloitte & Touche LLP (PCAOB ID 34) (incorporated by reference to Exhibit 23.3 to Annual Report on Form 10-K filed on March 7, 2024).
31.1*	Certification of Chief Executive Officer pursuant to Section 302 of Sarbanes-Oxley.
31.2*	Certification of Chief Financial Officer pursuant to Section 302 of Sarbanes-Oxley.
32.1**	Certification of Chief Executive Officer pursuant to 18 U.S.C. § 1350.
32.2**	Certification of Chief Financial Officer pursuant to 18 U.S.C. § 1350.
96.1*	S-K 1300 Technical Report Summary on the Big Island Mine, Sweetwater County, Wyoming, USA, dated March 13, 2022.
97.1	Natural Resource Partners L.P. Incentive-Based Compensation Recoupment Policy, dated August 2, 2023 (incorporated by reference to Exhibit 97.1 to Annual Report on Form 10-K filed on March 7, 2024).
99.1	Financial Statements of Sisecam Wyoming LLC as of December 31, 2023 and 2022 and for the years ended December 31, 2023, 2022 and 2021 (incorporated by reference to Exhibit 99.1 to Annual Report on Form 10-K filed on March 7, 2024).

Table of Contents

Exhibit<br> Number	Description
101.INS*	Inline XBRL Instance Document
101.SCH*	Inline XBRL Taxonomy Extension Schema Document
101.CAL*	Inline XBRL Taxonomy Extension Calculation Linkbase Document
101.DEF*	Inline XBRL Taxonomy Extension Definition Linkbase Document
101.LAB*	Inline XBRL Taxonomy Extension Labels Linkbase Document
101.PRE*	Inline XBRL Taxonomy Extension Presentation Linkbase Document
104*	Cover Page Interactive Data File (formatted as inline XBRL with applicable taxonomy extension information contained in Exhibit 101)
*	Filed herewith
**	Furnished herewith
+	Management compensatory plan or arrangement

Table of Contents

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

	NATURAL RESOURCE PARTNERS L.P.
	By:	NRP (GP) LP, its general partner
	By:	GP NATURAL RESOURCE
		PARTNERS LLC, its general partner
Date: January 30, 2025
	By:	/s/ CORBIN J. ROBERTSON, JR.
		Corbin J. Robertson, Jr.
		Chairman of the Board, Director and
		Chief Executive Officer
		(Principal Executive Officer)

ex_722821.htm

Exhibit 31.1

CERTIFICATION OF CHIEF EXECUTIVE OFFICER

I, Corbin J. Robertson, Jr., certify that:

1	I have reviewed this report on Form 10-K/A of Natural Resource Partners L.P.
2	Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
---	---
3	Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;
---	---
4	The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:
---	---
a.	Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
---	---
b.	Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
---	---
c.	Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and
---	---
d.	Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
---	---
5	The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions);
---	---
a.	All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and
---	---
b.	Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.
---	---
By:	/s/ Corbin J. Robertson, Jr.
---	---
	Corbin J. Robertson, Jr.
	Chief Executive Officer
Date:	January 30, 2025

ex_722822.htm

Exhibit 31.2

CERTIFICATION OF CHIEF FINANCIAL OFFICER

I, Christopher J. Zolas, certify that:

1.	I have reviewed this report on Form 10-K/A of Natural Resource Partners L.P.
2.	Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
---	---
3.	Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;
---	---
4.	The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and have:
---	---
a.	Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
---	---
b.	Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
---	---
c.	Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and
---	---
d.	Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
---	---
5.	The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions);
---	---
a.	All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and
---	---
b.	Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.
---	---
By:	/s/ Christopher J. Zolas
---	---
	Christopher J. Zolas
	Chief Financial Officer
Date:	January 30, 2025

ex_722823.htm

Exhibit 32.1

CERTIFICATION OF

CHIEF EXECUTIVE OFFICER

OF GP NATURAL RESOURCE PARTNERS LLC

PURSUANT TO 18 U.S.C. § 1350

In connection with the accompanying report on Form 10-K/A for the year ended December 31, 2023 filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Corbin J. Robertson, Jr., Chief Executive Officer of GP Natural Resource Partners LLC, the general partner of the general partner of Natural Resource Partners L.P. (the “Company”), hereby certify, to my knowledge, that:

1.	The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and
2.	The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company.
---	---
By:	/s/ Corbin J. Robertson, Jr.
---	---
	Corbin J. Robertson, Jr.
	Chief Executive Officer
Date:	January 30, 2025

ex_722824.htm

Exhibit 32.2

CERTIFICATION OF

CHIEF FINANCIAL OFFICER

OF GP NATURAL RESOURCE PARTNERS LLC

PURSUANT TO 18 U.S.C. § 1350

In connection with the accompanying report on Form 10-K/A for the year ended December 31, 2023 filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Christopher J. Zolas, Chief Financial Officer of GP Natural Resource Partners LLC, the general partner of the general partner of Natural Resource Partners L.P. (the “Company”), hereby certify, to my knowledge, that:

1.	The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and
2.	The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company.
---	---
By:	/s/ Christopher J. Zolas
---	---
	Christopher J. Zolas
	Chief Financial Officer
Date:	January 30, 2025

nrp20241127_corresp.htm

Exhibit 96.1

SISECAM WYOMING, LLC

TECHNICAL REPORT SUMMARY

STATEMENT OF RESOURCES AND RESERVES

CURRENT AS OF

DECEMBER 31, 2021

Big Island Mine

Sweetwater County

Wyoming, USA

FINAL-2

(01-22-001)

March 13, 2022

Prepared By:

HOLLBERG PROFESSIONAL GROUP, PC

Consulting Mining Engineers

3615 South Huron, Suite 203

Englewood, Colorado 80110

Phone 303-761-9995

hpg@hollberg.com

Hollberg Professional Group, PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Table of Contents

1.0	EXECUTIVE SUMMARY			12
	1.1	BACKGROUND		12
	1.2	HISTORY		12
	1.3	MINERAL DEPOSIT AND MINERAL LEASES		12
	1.4	MINERAL RESOURCE AND RESERVE ESTIMATE		15
		1.4.1	Factors That May Affect the Mineral Resource Estimate	17
	1.5	MINERAL RESERVE ESTIMATE		17
		1.5.1	Factors That May Affect the Mineral Reserve Estimate	19
	1.6	MINING METHOD LIFE OF MINE PLAN		19
	1.7	MINERAL PROCESSING AND RECOVERY		20
	1.8	ECONOMIC ANALYSIS		21
	1.9	OBSERVATIONS AND CONCLUSIONS		23
	1.10	RECOMMENDATIONS		24
2.0	INTRODUCTION			25
	2.1	BACKGROUND		25
	2.2	SOURCES OF INFORMATION		26
3.0	PROPERTY DESCRIPTION			27
	3.1	BIG ISLAND MINE OPERATIONS		27
	3.2	OWNERSHIP		29
		3.2.1	Trona Lease Area	29
		3.2.2	Mineral Leases and License	30
4.0	ACCESSIBILITY, CLIMATE, LOCAL RESOURCES, INFRASTRUCTURE AND PHYSIOGRAPHY			38
	4.1	ACCESS	38
---	---	---	---
	4.2	CLIMATE	38
	4.3	LOCAL RESOURCES	38
	4.4	INFRASTRUCTURE	39
	4.5	PHYSIOGRAPHY	39
5.0	HISTORY		40
	5.1	PRODUCTION HISTORY	41
---	---	---	---
6.0	GEOLOGICAL SETTINGS, MINERALIZATION, AND DEPOSIT		42
6.1	GEOLOGIC SETTING	42
---	---	---
6.2	TRONA DEPOSITION	42
6.3	TRONA BEDS OF THE GREEN RIVER BASIN	44
6.4	LOCAL GEOLOGY AND LITHOLOGY	46
6.4.1	Local Geology	46
---	---	---
6.4.2	Trona Bed Lithology	47
6.4.3	Sedimentary Structures	49
7.0	EXPLORATION		52
---	---	---	---
8.0	SAMPLE PREPARATION, ANALYSIS, AND SECURITY.		56
9.0	DATA VERIFICATION		57
	9.1	SITE VISITS	57
9.1.1	Mine Visit	57
---	---	---
9.1.2	Shafts and Hoisting Facilities	61
9.1.3	Surface Facilities Site Visit	61
	9.2	GEOLOGIC DATA VERIFICATION	63
---	---	---	---
10.0	MINERAL PROCESSING AND TRONA BED THICKNESS, TRONA GRADE, TESTING		65
Project 01-21-001	i	HPG
---	---	---
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Table of Contents

	10.1	CONVERSION OF TRONA TO SODA ASH	65
	10.2	PROCESSING FACILITIES	65
	10.3	TESTING AND ANALYSIS	66
11.0	MINERAL RESOURCE ESTIMATES		67
	11.1	INTRODUCTION	67
	11.2	GEOLOGICAL AND MINERALIZATION MODELING	67
	11.3	MINERAL RESOURCE AND RESERVE CLASSIFICATION	70
	11.4	MINERAL RESOURCE ESTIMATE - PARAMETERS AND ASSUMPTIONS	71
	11.5	GRADE ESTIMATION	72
	11.6	IN-PLACE MINERAL RESOURCE ESTIMATE	73
	11.7	UNCERTAINTIES (FACTORS) THAT MAY AFFECT THE MINERAL RESOURCE ESTIMATE	74
12.0	MINERAL RESERVE ESTIMATE		77
	12.1	LIFE OF MINE PLAN	77
	12.2	MINERAL RESERVE ESTIMATION	79
12.2.1	Reserve Estimate Reconciliation	80
---	---	---
12.2.2	Reserve Estimate Comments	80
12.2.3	Recoverable Trona Table Description	80
12.3	UNCERTAINTIES (FACTORS) THAT MAY AFFECT THE MINERAL RESERVE ESTIMATE	87
---	---	---
12.4	SECONDARY RECOVERY AND HIGH EXTRACTION MINING	87
12.4.1	Non-Subsidence Areas	87
---	---	---
13.0	MINING METHOD		90
---	---	---	---
	13.1	TWO SEAM MINING	90
	13.2	RESERVE ACCESS	91
13.2.1	Inaccessible Areas	92
---	---	---
13.2.2	Mining Limit	95
14.0	PROCESSING AND RECOVERY METHODS		96
---	---	---	---
	14.1	INTRODUCTION	96
	14.2	MONOHYDRATE PROCESS	96
	14.3	SODA ASH PROCESSING FACILITIES	96
14.3.1	Ore Crushers	97
---	---	---
14.3.2	Unit 7	98
14.3.3	Unit 3 and 4	98
14.3.4	Unit 5	98
14.3.5	Unit 6	98
14.3.6	Tailings Return to the Mine Plant	98
	14.4	DECA MINING AND PROCESSING	100
---	---	---	---
	14.5	EXPANSION PLANS	100
15.0	INFRASTRUCTURE		101
	15.1	INTRODUCTION	101
	15.2	OFFICES, WAREHOUSES	104
	15.3	MINE	104
	15.4	STORAGE	105
	15.5	PRODUCT SHIPPING & LOADING	105
15.5.1	Rail Yards	105
---	---	---
15.6	TAILINGS FACILITIES	105
---	---	---
15.7	UTILITIES	107
Project 01-21-001	ii	HPG
---	---	---
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Table of Contents (continued)

15.7.1	Electrical	107
15.7.2	Natural Gas	108
15.7.3	Steam	108
15.7.4	Water	108
16.0	MARKET STUDIES		109
---	---	---	---
17.0	ENVIRONMENTAL STUDIES, PERMITTING, AND PLANS, NEGOTIATIONS OR AGREEMENTS WITH LOCAL INDIVIDUALS OR GROUPS		110
	17.1	ENVIRONMENTAL STUDIES	110
	17.2	CLIMATE	110
17.2.1	Temperature and Precipitation	110
---	---	---
17.2.2	Winds	111
17.3	HYDROLOGY	111
---	---	---
17.3.1	Surface Water	111
---	---	---
17.3.2	Groundwater	111
17.4	WASTE AND TAILINGS DISPOSAL	112
---	---	---
17.4.1	Surface Tailings and Evaporative Impoundments	112
---	---	---
17.4.2	Mine Tailings Deposal	112
17.4.3	Refuge	112
17.5	VEGETATION	112
---	---	---
17.6	WILDLIFE	114
17.7	PERMITTING AND ENVIRONMENTAL REPORTING	115
17.7.1	Air Quality Permit	117
---	---	---
17.7.2	Land Quality Permit	119
17.7.3	Underground Injection Permits	119
17.7.4	Storm Water Discharge Permit	119
17.7.5	Drinking Water System	119
17.7.6	Sewage Permit	119
17.8	SITE MONITORING	119
---	---	---
17.9	CLOSURE PLANS AND ESTIMATES	120
17.9.1	Reclamation Plan	120
---	---	---
17.9.2	Reclamation Bond	120
17.10	SOCIAL OR COMMUNITY IMPACTS	120
---	---	---
18.0	CAPITAL AND OPERATING COSTS		121
---	---	---	---
	18.1	OPERATING COSTS	121
	18.2	COSTS DISCUSSION	121
	18.3	CAPITAL COSTS	123
19.0	ECONOMIC ANALYSIS		124
	19.1	METHODOLOGY USED	124
	19.1	FINANCIAL MODEL PARAMETERS	124
	19.2	ECONOMIC ANALYSIS SENSITIVITY ANALYSIS	129
	19.3	ECONOMIC ANALYSIS DISCUSSION	130
20.0	ADJACENT PROPERTIES		132
	20.1	GENESIS WESTVACO	132
	20.2	GENESIS GRANGER	132
	20.3	TATA CHEMICAL PARTNERS	132
	20.4	SOLVAY CHEMICALS	132
21.0	OTHER RELEVANT DATA AND INFORMATION		133
	21.1	WEST END ROOF COLLAPSE AND WATER INFLOW	133
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Table of Contents (continued)

22.0	INTERPRETATION AND CONCLUSIONS	135
23.0	RECOMMENDATIONS	136
24.0	REFERENCES	137
24.1	SCANNED FILES LISTING	138
24.2	SISECAM WYOMING DATA SOURCES	139
25.0	RELIANCE ON INFORMATION PROVIDED BY THE REGISTRANT	145
26.0	PROJECT TEAM CVS	146
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List of Tables

Table 1.1	Sisecam Wyoming Sodium Mineral Leases and License	14
Table 1.2	Estimated In-Place Trona Resources Within Big Island Exclusive of Reserves Mining License as of December 31, 2021 Based on $188/TSA	15
Table 1.3	Estimated In-Place Trona Resources Within Big Island Inclusive of Reserves Mining License as of December 31, 2021 Based on $188/ TSA	16
Table 1.4	Recoverable Trona Reserves – Big Island Mine and Refinery Trona Beds 24 and 25 As of December 31, 2021 Within the Contiguous Leases and License Based on $188/TSA	19
Table 1.5	Five Years Historical Income Cash Basis	22
Table 1.6	LOM Projected Cash Flow	23
Table 3.1	Sisecam Wyoming Sodium Mineral Leases and License	32
Table 5.1	Sisecam Historical Soda Ash Production By Year	41
Table 7.1	Big Island Mine Exploration Drilling History	53
Table 11.1	Estimated In-Place Trona Resources Within Big Island Exclusive of Reserves Mining License as of December 31, 2021 Based on $188/ TSA	73
Table 11.2	Estimated In-Place Trona Resources Within Big Island Inclusive of Reserves Mining License as of December 31, 2021 Based on $188/ TSA	74
Table 12.1	Estimated Recoverable Trona Reserves for Bed 24 & 25 By Category and Mineral Owner as of December 31, 2021 Based on $188/TSA	82
Table 12.2	Estimated Recoverable Trona Reserves for Bed 24 Only By Category and Mineral Owner as of December 31, 2021 Based on $188/TSA	83
Table 12.3	Estimated Recoverable Trona Reserves for Bed 25 Only By Category and Mineral Owner as of December 31, 2021 Based on $188/TSA	84
Table 14.1	Sisecam Historical Production	97
Table 17.1	Other Mammal Species	114
Table 17.2	Sisecam Wyoming Operating Permits	116
Table 17.3	Sisecam Total Facility Estimated Emissions	117
Table 17.4	2020 Sisecam Total Greenhouse Gas Emissions	118
Table 17.5	Sisecam Total Greenhouse Gas Emissions by year 2011-2020	118
Table 18.1	Sisecam Five Year Historical Net Cashflow	122
Table 19.1	Sisecam LOM Cashflow Analysis	126
Table 19.2	Sisecam LOM Cashflow Analysis (Cont.).	127
Table 19.3	Sisecam LOM Cashflow Analysis (Cont.)	128
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List of Figures

Figure 3.1	Big Island Mine General Location	28
Figure 3.2	KSLA Lease Map	31
Figure 3.3	Sisecam Wyoming – Sodium Lease Tenure Location Map	33
Figure 3.4	Surface Ownership	36
Figure 3.5	Mineral Ownership	37
Figure 6.1	Deposition Basin – Lake Gosiute	42
Figure 6.2	Deposition Cross Section	43
Figure 6.3	Schematic Section Through the Trona Deposits	44
Figure 6.4	Green River Basin Trona Bed Extents	45
Figure 6.5	Generalized Cross Section – Bed 24 and 25	46
Figure 6.6	Trona Bed 24 & 25 Lithological Section	48
Figure 6.7	Filled Desiccation Crack within Trona Bed	49
Figure 6.8	Blow-out Feature within Trona Bed	50
Figure 6.9	Geologic Faulting within Trona Bed	50
Figure 6.10	Post Depositional Dissolution within the Trona Bed	51
Figure 6.11	Post Depositional Soft Sediment Folding within the Trona Bed	51
Figure 7.1	Surface Exploration Drilling Locations with Surface Topo	54
Figure 7.2	Underground Exploration Drilling Locations with Upper and Lower Bed Mining Outlines	55
Figure 9.1	Floor Roll Panel 10 South UBE	59
Figure 9.2	Floor Roll Panel 7 South UBE	60
Figure 11.1	Upper Bed 25 Thickness Isopachs	68
Figure 11.2	Lower Bed 24 Thickness Isopachs	69
Figure 11.3	Upper Bed 25 Resource Blocks	75
Figure 11.4	Lower Bed 24 Resource Blocks	76
Figure 12.1	Upper Bed 25 Life of Mine Plan	85
Figure 12.2	Lower Bed 24 Life of Mine Plan	86
Figure 12.3	Non-Subsidence Areas – Lower Bed 24	88
Figure 12.4	Non-Subsidence Areas – Upper Bed 25	89
Figure 13.1	Lower Bed 24 Flooded Area	94
Figure 14.1	Sisecam Processing Facilities	97
Figure 14.2	Sisecam Wyoming Simplified Process Flow Diagram	99
Figure 15.1	Sisecam Site Access and Rail Infrastructure	102
Figure 15.2	Sisecam Site Infrastructure Aerial View	103
Figure 15.3	Aerial View Tailings Facilities	107
Figure 17.1	Sisecam Tailings Impoundments and Evaporative Ponds	113
Figure 17.2	Sisecam Tailings Pond #1	113
Figure 19.1	5% NPV Sensitivity to Revenue and Production Costs	129
Figure 19.2	5% NPV Sensitivity to Two Seam Mining Cost	130
Figure 21.1	West End Subsidence Progression	134
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Glossary of Terms and Abbreviations
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Term/Abbreviation	Description	Definition
BIM	Big Island Mine	Sisecam’s Mine Workings
CAPEX	Capital Expenditures	Expenditures that are not charged to production costs but are either depreciated or amortized.
Conventional mining methods	Drill and Blast Mining	Mining drill and blast methods or undercut, drill and blast mining.
CM	Continuous Miner	Mining using continuous mining machines. These can be drum type or rotor type.
Crosscut (X-Cut)	underground passageway	Mined at or near right angles to the mining direction
DECA	Decahydrate Crystal	Sodium Carbonate Decahydrate
EIS	Environmental Impact Statement	A specific study of a project’s environmental impacts.
FOB	Free-on-Board	Basis of selling cargo excluding freight and insurance but including loading costs.
GR RMP	Green River Resource Management Plan	Resource plan produced by the BLM for management of the multiple resources on BLM lands in the Green River area.
Gate Entry	Longwall Entry	Access entries specifically configured to support longwall mining.
Headgate	Longwall Entry	Longwall gate entry on fresh air side of longwall face containing main access facilities and conveyors.
IRR	Internal Rate of Return	Annual rate of growth that an investment is expected to generate.
JICOG	Joint Industry Committee on Oil and Gas	Committee created to help resolve lease conflicts in the KSLA between oil and gas producers and sodium mineral producers.
JORC	Joint Ore Reserve Committee	Part of the Australian Institute of Mining and Metallurgy issuing internationally recognized criteria for defining trona resource and reserves.
JV	Joint Venture	A combination of two or more parties that seek the development of a single enterprise or project for profit
KSLA	Known Sodium Lease Area	Area in Southwest Wyoming designated for sodium mineral leasing
K gal	1000 gallons	Raw water measurement
LB	Lower Bed	Trona Bed 24
LW	Longwall	Highly productive method of underground trona mining and a specific type of trona mining equipment.
LOM	Life of Mine Plan	Mining plan for the life of the property.
NPV	Net Present Value	The present value of the expected future cash flows minus the cost.
OPEX	Operating Expenses	Expenses for labor and expendable items used in the mining and processing of minerals.
O&G	Oil and Gas Production	The production of oil and gas from the surface.
MST	Million Short Tons	Million short tons of material.
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Glossary of Terms and Abbreviations
---	---	---
Term/Abbreviation	Description	Definition
MTPY	Million Short Tons per Year	Million short tons of material per year.
Mono	Monohydrate Process	Process to convert trona to soda ash
MMTA	Mechanically Mining Trona Area	Area designated by the BLM in southwest Wyoming that can be mechanically mined.
MM gallons	Million Gallons	Raw water measurement
ROM Trona	Run-of-Mine Trona	Raw trona production from mines prior to trona preparation.
RS RMP	Rock Springs Resource Management Plan	Resource plan produced by the BLM for management of the multiple resources on BLM lands in the Rock Springs, Wyoming District.
RFDS	Reasonably Foreseeable Development Scenario	BLM study to determine a resource’s probability of development in the foreseeable future.
SSDA	Special Sodium Drilling Area	Area designated under the 1997 Green River Resource Management Plan to limit O&G drilling
TA	Total Alkalinity	Measure of soda ash level in solution mine water.
TSA	Short Tons of Soda Ash	Measure of production capacity
Tons	Short Tons	All references to “tons” in this report shall refer to “short tons.” A short ton is equal to 2000 pounds.
tph	tons per day	Measure of production capacity.
tph	tons per hour	Measure of production capacity.
types	tons per unit shift	Measure of mining productivity.
toy	tons per year	Measure of production capacity.
TRM	Tailings Return to the Mine	Process by which the refinery tailings are thickened and pumped into old mine workings for disposal.
UB	Upper Bed	Trona Bed 25
USGS	United States Geologic Survey	Branch of the US Government charged with mapping and surveying the resources of the US.
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APPROACH

Hollberg Professional Group, PC (“HPG”) has conducted an independent technical review of the lands held by Sisecam Wyoming, LLC (“Sisecam Wyoming”) referred to as the “Big Island Mine,” which is located in the area commonly referred to as the Know Sodium Lease Area (the “KSLA”), near the town of Green River, Sweetwater County, Wyoming. HPG professionals involved in the preparation of this independent technical report (“Report”) have visited the mine on multiple occasions and are knowledgeable concerning the Big Island Mine and the KSLA trona deposits. HPG has reviewed technical data, reports, and studies produced by other consulting firms, as well as information provided by Sisecam Wyoming, and others listed in Sections 24.0 and 25.0. This review was conducted on a reasonableness basis, and HPG has noted herein where such provided information engendered questions. Except for the instances in which we have noted questions or made specific comments regarding the nature of the information, HPG has relied upon the information provided by Sisecam as being accurate and suitable for use in this Report. Consent has been given for the distribution of this independent technical review in the form and context in which it appears. HPG has no reason to doubt the authenticity or substance of the information provided.

INDEPENDENCE

HPG and its principals and employees are not and do not intend to be a director, officer, or other direct employee of Sisecam Wyoming and has no material interest in the Big Island Mine or Sisecam Wyoming. The relationship with Sisecam Wyoming is solely one of professional association between client and independent consultant. The review work and this Report are prepared in return for professional fees based upon agreed commercial rates, and the payment of these fees is in no way contingent on the results of this Report.

ELECTRONIC DISCLAIMER

Electronic mail copies of this Report are not official unless authenticated and signed by HPG and are not to be modified in any manner without HPG’s express written consent.

UNITS OF MEASUREMENT AND CURRENCY

Measurement units used in this Report are in the English system. The currency is United States (US) dollars unless specifically stated otherwise.

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NOTE REGARDING FORWARD-LOOKING INFORMATION

This Technical Report Summary contains forward-looking statements within the meaning of the U.S. Securities Act of 1933 and the U.S. Securities Exchange Act of 1934, that are intended to be covered by the safe harbor created by such sections. Such forward-looking statements include, without limitation, statements regarding Hollberg Professional Group (HPG) expectation for Sisecam’s mine and any related development or expansions, including estimated cashflows, production forecasts, mine plans, revenue, income, costs, taxes, capital, rates of return, mine, material mined and processed, recoveries and grade, future mineralization, future adjustments and sensitivities and other statements that are not historical facts.

Forward-looking statements address activities, events, or developments that HPG expects or anticipates will or may occur in the future and are based on current expectations and assumptions. Although Hollberg Professional Group believes that its expectations are based on reasonable assumptions, it can give no assurance that these expectations will prove correct. Such assumptions, include, but are not limited to: (i) there being no significant change to current geotechnical, trona bed thickness, trona grades, hydrological and other physical conditions; (ii) permitting, development, operations and expansion of operations and projects being consistent with current expectations and mine plans; (iii) political developments in jurisdiction in which Sisecam Wyoming operates being consistent with current expectations; (iv) certain exchange rate assumptions being approximately consistent with current levels; (v) certain price assumptions for soda ash; (vi) prices for key supplies being approximately consistent with current levels; and (vii) other planning assumptions.

Important factors that could cause actual results to differ materially from those in the forward-looking statements include, among others, risks that estimates of mineral reserves and mineral resources are uncertain and the volume and grade of ore actually recovered may vary from our estimates, risks relating to fluctuations in soda ash prices; risks due to the inherently hazardous nature of mining-related activities; risks related to the jurisdictions in which Sisecam operates, uncertainties due to health and safety considerations, including COVID-19, uncertainties related to environmental considerations, including, without limitation, climate change, uncertainties relating to obtaining approvals and permits, including renewals, from governmental regulatory authorities; and uncertainties related to changes in law; as well as those factors discussed in Sisecam Wyoming’s filings with the U.S. Securities and Exchange Commission, including Sisecam Wyoming’s latest Annual Report on Form 10-K for the period ended December 31, 2021.

This notice is an integral component of the Technical Report Summary (TRS) and should be read in its entirety and must accompany every copy made of the TRS.

HPG has used their experience and industry expertise to produce the estimates in the TRS. Where HPG has made these estimates, they are subject to qualifications and assumptions, and it should also be noted that all estimates contained in the TRS may be prone to fluctuations with time and changing industry circumstances.

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HPG<br><br> <br>Hollberg Professional Group PC.<br><br> <br>Consulting Engineers	3615 South Huron S., Suite 203<br><br> <br>Englewood, CO USA 80110<br><br> <br>303.761.9995<br><br> <br>Fax 303.783.3678<br><br> <br>hpg@hollberg.com
---	---

Kurt F. Hollberg, PE

Hollberg Professional Group, PC

QUALIFIED PERSON

I, Kurt F. Hollberg, certify as the Qualified Person that the attached report titled “Statement of Resources and Reserves as of December 31, 2021– Big Island Mine, Sweetwater County, Wyoming, USA” and dated March 10, 2022 (the "Technical Report Summary") by Hollberg Professional Group PC has been carried out in accordance with the requirements of US Securities and Exchange Commission (SEC Regulation S-K Item 102 and Subpart 1300).

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1.0 EXECUTIVE SUMMARY

1.1	BACKGROUND

Sisecam Wyoming LLC. (“Sisecam Wyoming”), engaged Hollberg Professional Group (HPG) to update HPG’s December 2019 Mineral Reserve Estimate on the trona mineral assets of Sisecam Wyoming LLC comprising Sisecam’s Green River Property (Big Island Mine & Refinery), Sweetwater County, Wyoming, United States of America (“USA”). Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%. Sisecam Resources LP is the registrant.

1.2	HISTORY

Sisecam Wyoming owns and operates the Big Island Mine complex that consists of an underground trona mine and associated refinery (“Sisecam Wyoming Mine and Refinery”). The Sisecam Wyoming Mine and Refinery lies northwest of the town of Green River in Sweetwater County, Wyoming (Figure 3.1). Mining occurs in two trona seams, Bed 24 and Bed 25, nominally at 850-feet and 900-feet deep, respectively. The Big Island Mine was started in 1962 by the Stauffer Chemical Company and has been in continuous operation since that time. Through Ciner Enterprises Inc., a Ciner Group affiliate and parent of Sisecam Chemicals Resources LLC (“Sisecam Chemicals” formerly known as Ciner Resources Corporation), Ciner Group acquired control of the property in 2015 and sold a controlling interest (60%) of the outstanding units of Sisecam Chemicals to Sisecam Chemicals USA Inc. as of December 21, 2021. Sisecam Chemicals indirectly owns approximately 72% limited partner interest in Sisecam as well as its 2% general partner interest and related incentive distribution rights. Through Ciner Enterprises Inc., Ciner Group continues to hold 40% of the interests in Sisecam Chemicals.

The Sisecam Wyoming refinery purifies trona ore into soda ash (sodium carbonate). Soda ash is an essential raw material in glass making, chemicals, detergents, and other industrial products. Sisecam Wyoming’s refining facility is well established and has been converting trona into salable soda ash for over 60 years. Sisecam Wyoming sells the soda ash domestically through Sisecam Resources LP and its affiliates. Product is shipped via truck or rail from loadouts at the Sisecam site and a rail spur to the Union Pacific Railroad mainline along Interstate 80 (I-80).

1.3	MINERAL DEPOSIT AND MINERAL LEASES

The trona deposits of SW Wyoming are the world’s largest occurrence of natural soda ash. The deposit was formed from the evaporation of a shallow lake, Lake Gosiute, that covered SW Wyoming and NE Utah 50-60 million years ago (wyomingmining.org, 2020) (Lake Gosiute, Figure 6.1).

Trona is a non-metallic industrial mineral of the compound sodium sesquicarbonate which is a partially hydrated double salt of sodium carbonate (commonly known as soda ash (Na2CO3)) and sodium bicarbonate (commonly known as baking soda (Na2CO3.NaHCO3.2H2O)). The US Geological Survey recognizes 25 trona beds of economic importance (at least 1 meter in thickness and 300 km^2^ in areal extent) within the Green River Basin. Identified in ascending order, the trona beds are numbered 1 through 25 from the oldest (stratigraphically lowest) to the youngest (stratigraphically highest). Sisecam Wyoming has mineable reserves in the shallowest mechanically minable Trona Beds 24 and 25 (800 to 1,100-feet. deep). Figure 6.2, Figure 6.3, and Figure 6.5 show cross sections of the Green River Basin and Bed 24 25 lithology.

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The Bureau of Land Management designates available sodium leasing as the Known Sodium Leasing Area (“KSLA”). The KSLA is where trona thickness exceeds 1-meter, extends for over 300 km^2^, and is greater than 80% grade. The known Mechanically Mining Trona Area (“MMTA”) is defined where trona exceeds 8-feet thickness, has a grade greater than 85%, contains less than 2% salt (NaCl), and is at a depth no greater than 2,000-feet. Figure 3.2 shows the KSLA and MMTA boundaries along with the major leaseholders.

Sisecam Wyoming holds both private and public mineral leases and license over the Big Island Mine within the KSLA boundary. In addition to the mineral leases and license, Sisecam Wyoming has several other permits with both U.S. Federal and Wyoming state agencies that give it the right to operate the Big Island Mine.

Sisecam Wyoming has approximately 23,612 acres of sodium (Trona) under lease made up of approximately 7,934 Federal acres, 3,079 State acres, and 12,599 private acres. Table 1.1 lists the current sodium leases and the license owned by Sisecam Wyoming and their status. The location of Sisecam’s trona leases is illustrated in Figure 3.2 and Figure 3.3.

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Table 1.1

Sisecam Wyoming Sodium Mineral Leases and License

(2) All US BLM Leases have a 2 percent royalty rate for a period of 10 years, as of January 1, 2021, based on Industry-Wide Royalty Reduction Soa Ash and Sodium Bicarbonate issued by the Secretary of the Interior, for all existing and future Federal soda ash or sodium bicarbonate leases.

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1.4	MINERAL RESOURCE AND RESERVE ESTIMATE
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Using the data provided by Sisecam Wyoming, HPG has completed its review of the Big Island Mine and concludes that the Big Island Mine’s remaining leased and licensed Measured and Indicated in-place trona Resources exclusive of reserves **** as of December 31, 2021, total 162.3 million short tons (MST), of which 98.9 MST remain in the Lower Bed 24 and 63.4 MST remain in the Upper Bed 25. Measured In-Place Resources are calculated as 74.2 MST and Indicated In-Place Resources calculate as 88.1 MST and Inferred In-Place Resources are calculated at 0.05 MST. Table 1.2 summarizes the estimated In-Place Trona Resource exclusive of the mineral reserves .

The Mineral Resource exclusive of the mineral reserves is that portion of the ore body that has not been extracted because it was outside what is considered the economic limits, has been left in place to support the mine openings or has been sterilized by previous mining and cost-effective access is not considered practical. Mineral resources that are not mineral reserves do not have demonstrated economic viability.

Table 1.2

Estimated In-Place Trona Resources Within Big Island

Exclusive of Reserves

Mining License as of December 31, 2021

Based on $188/TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 6-foot minimum thickness and an 75% minimum grade cut-off.
---	---
3)	The point of reference is in-place (insitu) inclusive of impurities and insoluble content.
---	---
4)	Mineral resources are current as of December 31, 2021, using the definitions in SK1300.
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5)	Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
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Based on the current study, the Sisecam Wyoming Big Island remaining leased and licensed Measured and Indicated in-place trona Resources inclusive of reserves as of December 31, 2021, total 578.9 million short tons (MST), of which 382.5 MST remain in the Lower Bed 24 and 196.4 MST remain in the Upper Bed 25. Measured In-Place Resources are calculated as 291.5 MST and Indicated In-Place Resources calculate as 287.5 MST and Inferred In-Place Resources are calculated at 0.26 MST. Table 1.3 provides the In-Place Trona Resource Inclusive of the mineral reserves.

The Mineral Resource inclusive of the mineral reserves is that portion of the ore body that is considered either economically viable for mining and can be converted to reserves or of economic interest but considered outside the current economic limits. Figure 11.3 and Figure 11.4 present the remaining in-place trona showing measured, indicated, and inferred resource areas. This is the material considered of economic interest that has the potential to be converted to reserves.

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Table 1.3

Estimated In-Place Trona Resources Within Big Island

Inclusive of Reserves

Mining License as of December 31, 2021

Based on $188/ TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 6-foot minimum thickness and an 75% minimum grade cut-off.
---	---
3)	The point of reference is in-place (insitu) inclusive of impurities and insoluble content.
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4)	Mineral resources are current as of December 31, 2021, using the definitions in SK1300.
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5)	Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
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Only the contiguous mineral leases were considered for this resource and reserve estimate. Section 16, T21N, R108W was excluded from this estimate because this state lease is isolated from the other contiguous lease blocks. The one-mile isolation makes accessing this for mechanical mining unlikely.

Criteria for this analysis are based upon a 6.0-feet minimum ore thickness and 75% minimum seam grade. This Resource evaluation is based upon 81 exploration drill holes, 44 borings from the mine workings, and several thousand available mine observations and measurements. The in-seam ore horizon includes the T2 to T4 zones and excludes the T1 zone Additionally, this updated report considers the 2020-2021 mine advancement in the northeast and southwest extents of Bed 25.

Because of Sisecam’s proximity to the Green River this resource and reserve estimate does not consider solution mining due to its likely subsidence and impact to this major water source. Therefore, HPG is only considering mechanical mining of the deposit using established systems and methods.

The reference point for the mineral resources are reported in-place (insitu) inclusive of impurities and insoluble content. The grade is percent trona, sodium sesquicarbonate (Na2CO3.NaHCO3.2H2O), the double salt of sodium carbonate (soda ash) and sodium bicarbonate (baking soda). A bulk density of 133 pounds per cubic foot (2.13 g/cc), was applied to convert volumes to tonnage. Several published documents list bulk densities of trona between 2.11 and 2.17 g/cc.

Mineral resources are current as of December 31, 2021, using the definitions in SK1300. Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.

Mineral resources are not mineral reserves. Mineral reserves are the economically mineable part of a measured or indicated mineral resource based upon application of modifying factors such as costs and revenues associated with the proposed operation and producing the final product in an economic and environmental assessment. Section 11.3 describes these factors. There is no certainty that any mineral resources in this report will ultimately be reclassified as reserves. Please refer to the note regarding forward-looking information at the front of the Report.

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1.4.1 ****	Factors That May Affect the Mineral Resource Estimate
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Factors that may affect the mineral resource estimate include: changes to long-term soda ash price assumptions; changes in local interpretations of mineralization geometry and continuity of mineralized zones; changes to geological and grade shape and geological and grade continuity assumptions; changes to the cut-off grades used to constrain the estimates; variations in geotechnical, mining, and processing recovery assumptions; and changes to environmental, permitting and social license assumptions.

1.5	MINERAL RESERVE ESTIMATE

This independent Mineral Resource and Mineral Reserve estimate is completed in accordance with the requirements of the US Securities and Exchange Commission (SEC Regulation S-K Item 102 and Subpart 1300). The Mineral Resource Estimates included in this report have been used in conjunction with current dry mining operations to establish the “Proven” and “Probable” Mineral Reserves. The remaining in-place (insitu) and mineable trona reserves for the Big Island Mine are based on a life-of-mine plan (“LOM”) using current mining methods.

No independent feasibility study was prepared in the determination of this reserve estimate. Instead HPG used the plus 60 years of mining and processing history at the Big Island to determine the mining, processing and economic parameters used for this reserve estimate. Based on this information the capital and operating cost estimates are at a minimum at a pre-feasibility level of confidence, having an accuracy level of ±25% and a contingency range not exceeding 15%.

In determining the reserve parameters and assumptions HPG considered the following circumstances:

●	Sisecam’s 60-year long history and economics of mining the deposit and producing soda ash;
○	The 170.1 MST of trona ore produced from these two beds;
---	---
●	The projected long life of the mine and resulting likely change in economics, mining, and processing methods over its projected 40-year mine life;
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●	Sisecam’s current processing facilities capabilities and projected future changes to these facilities.
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●	The economics associated with Sisecam’s current mining equipment and history of “high grading” the thickest portions of the deposit;
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●	Sisecam’s current mining equipment limitations and required future changes to these systems; and
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●	HPG’s knowledge operating and managing other trona and potash mines.
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Using current mining and refining technologies, it is our professional opinion that Sisecam Wyoming can realistically expect to economically recover 220.0 MST of trona ore at an average grade of 85.2 percent from these reserves as of the end of December 2021. This is made up of 72.7 MST from Bed 25 and 147.3 MST from Bed 24. Proven recoverable tons are calculated as 97.4 MST, of which 33.4 MST remain in the Upper Bed and 64.0 MST remain in the Lower Bed. Probable recoverable tons are calculated at 122.6 MST of which 39.3 MST remain in the Upper Bed and 83.2 MST remain in the Lower Bed. This is based on Sisecam continuing to mine using its existing mining methods and extraction rates for the remaining life of the currently controlled reserves. Estimated finished soda ash reserves are 119.1 MST. Table 1.4 below and Section 12.2 summarizes these findings.

In determining whether the reserves meet these economic standards, HPG made certain assumptions regarding the remaining life of the Big Island Mine, including, among other things, that:

●	The point of reference is run-of-mine (ROM) ore delivered to the processing facilities;
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●	The cost of products sold per short ton will remain consistent with Sisecam Wyoming’s cost of products sold for the five years ended December 31, 2021;
---	---
●	The weighted average net sales per short ton, $188/ton, will remain consistent with Sisecam Wyoming’s average net sales for the five years ended December 31, 2021;
---	---
●	Sisecam Wyoming’s mining costs will remain consistent with 2021 levels until they begin two-seam mining, at which time mining costs for the two-seam mining tonnage could increase by as much as 53%;
---	---
●	Sisecam Wyoming’s processing costs will remain consistent with 2021 levels and rise in 10-years to account for lower grade material;
---	---
●	Sisecam Wyoming will achieve an annual mining rate of approximately 5.0 million short tons of trona in 2024 and beyond;
---	---
●	Sisecam Wyoming will process soda ash with a 90% rate of recovery, without accounting for the deca rehydration process;
---	---
●	The ore to ash ratio for the stated trona reserves is 1.835:1.0 (short tons of trona run-of-mine to short tons of soda ash);
---	---
●	The run-of-mine ore estimate contains dilution from the mining process;
---	---
●	Sisecam Wyoming will continue to conduct only conventional mining using the room and pillar method and a non-subsidence mine design;
---	---
●	Sisecam Wyoming will, in approximately 10 years, make necessary modifications to the processing facilities to allow localized mining of 75% ore grade in areas where the floor seam or insoluble disruptions have moved up into the mining horizon causing mining to be halted early due to processing facility limitations;
---	---
●	Sisecam Wyoming will, within one year, conduct ‘‘two-seam mining,’’ in production panels which means to perform continuous mining in Bed 24 beneath historically mined production panels of Bed 25 with interburden thickness of approximately 35-feet;
---	---
●	Sisecam Wyoming will, in approximately 20 years, make necessary equipment modifications to operate at a seam height of 7-feet, the current mining limit is 9-feet;
---	---
●	Sisecam Wyoming has and will continue to have valid leases and license in place with respect to the reserves, and that these leases and license can be renewed for the life of the mine based on their extensive history of renewing leases and license;
---	---
●	Sisecam Wyoming has and will continue to have the necessary permits to conduct mining operations with respect to the reserves; and
---	---
●	Sisecam Wyoming will maintain the necessary tailings storage capacity to maintain tailings disposal between the mine and surface placement for the life-of-mine (LOM).
---	---

This reserve estimate is based on Sisecam Wyoming’s current basis for mine design that is predicated upon no subsidence. Higher mining extraction rates could be achieved, but are complicated by the overlying Green River Drainage, plant facilities, and gas pipelines, which are sensitive to mine induced subsidence. HPG does not recommend that Sisecam Wyoming alter the current ‘no subsidence’ mine design.

Long-term recovery of the remaining mine trona pillars by secondary extraction methods, including solution mining, is not considered in this reserve estimate but may be available to Sisecam Wyoming in the future. Any secondary recovery will be limited by the non-subsidence zones surrounding the Green River and plant facilities discussed in Section 12.4. Where mining induced subsidence is possible, subsidence mitigation will be required over a large portion of the available mine resource.

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Table 1.4 Recoverable Trona Reserves – Big Island Mine and Refinery Trona Beds 24 and 25 As of December 31, 2021 Within the Contiguous Leases and License Based on 188/TSA
---	---	---	---	---	---
Bed	Average Grade % Trona	Probable (millions) Tons	Average Grade % Trona	Total Reserves (Millions) Tons	Average Grade % Trona
Lower Bed 24	86.0	83.2	85.8	147.3	85.9
Upper Bed 25	83.7	39.3	84.1	72.7	83.9
Total	85.2	122.6	85.2	220.0	85.2

All values are in US Dollars.

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
---	---
3)	The point of reference is run-of-mine (ROM) ore delivered to the processing facilities including mining losses and dilution.
---	---
4)	Mineral reserves are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---
1.5.1 ****	Factors That May Affect the Mineral Reserve Estimate
---	---

Factors that may affect the mineral reserve estimate include: changes to long-term soda ash price assumptions; changes in local interpretations of mineralization geometry and continuity of mineralized zones; changes to geological and grade shape and geological and grade continuity assumptions; changes to the cut-off grades used to constrain the estimates; variations in geotechnical, mining, and processing recovery assumptions; and changes to environmental, permitting and social license assumptions.

1.6	MINING METHOD LIFE OF MINE PLAN

The underground mining operation uses continuous miners mining in a modified room and pillar method employing a ‘no surface subsidence’ mine design.

To accommodate this reality, HPG has developed a detailed Life-of-Mine (LOM) plan that in HPG’s opinion is a reasonable mining sequence for this deposit over its remaining 40 plus years assuming Sisecam choses to mine as much of the resource as possible. A two-stage mine plan has been developed. The first stage “high-grades” the deposit based upon the current mining equipment and processing plant limitations mining to the 9-foot isopach. This matches the practice employed over the last 20 years and should be viable for another 20 years.

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The second stage mining is based upon smaller mining equipment and assumes changes to the dissolver sections of the processing plants. These changes should allow mining to the 7-foot isopach and processing areas of the trona resource where disruptions to the ore body have been and will be encountered as mining progresses towards the edge of the ore body. The 7-foot mining limit was selected based on current economics and practices at similar operations.

This type of two-stage mining is only possible when underground conditions allow access to the bypassed areas long after the first stage of mining was completed. This is true for the Big Island Mine where old mine workings developed 60 years ago are still open, accessible, and currently in use. Where possible the LOM plan accounts for future access to the thinner areas. In areas where future access was determined to be too difficult or costly, the thinner trona resource have been considered sterilized and are not reserves.

Portions of the remaining Bed 24 trona are located under previously mined areas in Bed 25. These areas are where ‘two-seam mining’ is required. Two-seam mining extracts the mineral from both beds. Due to the thin interburden (25 to 40-feet) between Bed 24 and 25 and wide entries mined, mining induced stresses are higher in these areas of two-seam mining, Sisecam Wyoming has conducted significant computer modeling of the rock mechanics and predicted mine entry stability surrounding two-seam mining. Additionally, three test panels and one production panel have been mined in areas where lower extraction conventional mining techniques were employed. These panels were mined successfully and remain accessible and stable many years after mining.

To date, Sisecam Wyoming has not completed Lower Bed two-seam mining of continuous miner panels below existing historic Upper Bed continuous miner panels. For this reason, two-seam mining using continuous miners and existing geometries is considered unverified. To account for this risk, higher mining costs have been used in the economic analysis. Given the work completed, the existing test panels, and the cost structure at Sisecam Wyoming, it is reasonable to conclude that these areas can be economically mined and therefore are considered reserves in this study.

To fully prove the proposed two-seam mining geometry it will be necessary to complete two or three test panels based on the wider continuous miner (CM) entries below the existing Upper Bed CM panels. In 2021 Sisecam extended the main entries in the two-seam area and stubbed in the test panels. Visual examination of the ground conditions in this area were good with little additional stress evident. Sisecam expects to start the first panel mining in this area in early 2022. Based on this progress it will be four to six years before Sisecam is able to fully demonstrate the viability of two-seam mining with the current mining equipment.

Portions of the LB West mine have been flooded and areas have collapsed limiting access to trona resource west of the existing mine workings. This area is considered a resource but is not part of the LOM plan due to the risks and high costs associated with seismicity, water inflow, less competent roof strata, and soft ore.

1.7	MINERAL PROCESSING AND RECOVERY

The Big Island Mine and Refinery complex is well established having been developed over the plus 60 years of operation. Sisecam utilizes the monohydrate (Mono) process to convert raw trona into soda ash in five (5) processing plants. The plants are well established and have a long production history. Unit 6 is an integrated stand-alone plant constructed in 1998 and Unit 7 is a large calcining dissolver constructed in 2006 to feed liquor to Units 3 through 5. All the plants have had significant upgrades over the years to both improve recovery, energy efficiency, and increase soda ash production.

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Sisecam currently has two ore calcining and dissolving units with four soda ash processing plants. The first two processing plants, Unit 1 and Unit 2 built in 1962 used triple effect evaporators were taken out of service after being replaced by the integrated Unit 6 plant. Unit 7 calciner and dissolving unit was constructed to replace the front ends for Units 3, 4 and 5. The dissolver units liquor output is interconnected to the multiple evaporator units to optimize production.

The site infrastructure is established and adequate for the purposes including: four existing surface to ore bed shafts, offices, warehouses, processing plants, product storage, dedicated rail spur with rail yard, tailings facilities, and dedicate utilities including natural gas, electricity, and water.

1.8	ECONOMIC ANALYSIS

Cost effective mining and processing has been conducted since the early 1960’s at Sisecam Wyoming generally under the same mine design assumptions utilized in this reserve estimate. Overall costs are not expected to change significantly in the future; thus, using historical costs for mining the reserves and producing soda ash are considered a reliable basis to forecasting future costs.

With the information provided in previous reviews and this review HPG has been able to examine the last ten years of actual production costs and revenues. This long history shows a stable and predictable cost structure and consistent revenue. The only exception was 2020 and 2021 where costs and revenues were lower due to the worldwide COVID-19 slowdown. Despite this historic business interruption both years were cash positive with 2021 rebounding to near normal levels.

For the basis of determining the economic viability of the reserves stated here and in Section 12.0, HPG has utilized the last five years of financial data provided by Sisecam. Sisecam provided both audited and unaudited financial information including detailed production cost, capital expenditures and revenues. Previous reviews were based upon three years of data but due to the extraordinary impact of COVID-19 a more extensive analysis was conducted. Some consideration was given to dropping 2020 and 2021 from the analysis but was rejected as recent cost data is materially important to this type of analysis and the ultimate outcome of COVID-19 is unknown. The analysis conducted is therefore considered conservative given the inclusion of such an unusual event. Capital and operating cost estimates are at a minimum at a pre-feasibility level of confidence, having an accuracy level of ±25% and a contingency range not exceeding 15%.

Five years of operational data has been summarized as a cash statement of Net Income which is provided in Table 1.5. Detailed discussions of the cost analysis, capital expenditures, and revenues can be found in Sections 16.0, 18.0, and 19.0.

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Table 1.5

Five Years Historical Income

Cash Basis

Note: Numbers have been rounded; totals may not sum due to rounding.

The basis for the economic analysis is the previous five years of actual performance adjusted for expected changes in operating costs and necessary capital expenditures to execute the proposed LOM. Table 1.6 illustrates the expected cash flows for the LOM in ten-year increments. The economic model indicates positive cash flow, an 11.9% internal rate of return (IRR) and a positive net present value (NPV) of $425.4 million at a 5% discount rate. The full financial model by year is shown in Table 19.1 through Table 19.3. This analysis shows that the operation will provide positive cash operating profits and is therefore considered to be economically viable.

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Table 1.6

LOM Projected Cash Flow

Note: Numbers have been rounded; totals may not sum due to rounding.

1.9	OBSERVATIONS AND CONCLUSIONS

Approximately 118 MST of the reported recoverable Trona (48%) is dependent upon Sisecam confirming the viability of two-seam mining over the next four to six years. Most of these two-seam reserves (approximately 71.5 MST, 60%) are in areas with thickness over 9-feet.

The November 2021 site visit revealed that since the 2019 report was completed, Sisecam has made significant progress developing the LB North mains and panel entries. Ground conditions were found to be good for the mains entries confirming the current design. Development of the lower extraction main entries does not evaluate the true impacts that will be experienced when conducting two-seam panel mining. Until two or three test panels are successfully completed and analyzed two-seam mining with the current equipment remains unverified. Based on current projections it will be four to six years before Sisecam will verify the viability of two-seam mining. It is possible that two-seam mining may require significant variations from current mining equipment and practices.

Approximately 148 MST of the reported 220 MST recoverable tonnage is greater than 9-feet thick and can be mined and processed with the existing equipment, some localized areas will require ore blending or modification of the processing facilities to handle lower grade ore for several days or several weeks. These areas comprise 39.5 MST of the total reserves. It is anticipated that these plant modifications need to be implemented within 10-15 years.

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The practice of “high grading” the deposit and only mining the thicker reserves first risks sterilization of the thinner areas if access is compromised. Recovery of the reserves less than 9-feet will require changes to the mining and utility equipment, will incur higher mining costs, require access rehabilitation costs and is dependent upon the ability to access these areas through old workings or via extensions of old mains entries as shown in the LOM plan developed for this estimate. This material makes up 72 MST of the estimated recoverable tonnage. There is some risk that access to these areas 20 years after mining might not be possible.

The roof failure, water inflow and associated subsidence of the Lower Bed West mine area has intrinsic risks to an evaporite mine below a major waterway that must be continuously monitored and evaluated for any changes. These include increased water flow or changes in water type indicating its source could be surface waters. Risks due to high inflow of water can range from higher mining costs to loss of access.

1.10	RECOMMENDATIONS

HPG supports Sisecam’s plan to perform additional exploration drilling to improve data density. Additional exploration drilling would result in a higher percentage of the reserve base classified as proven and should better define the trona grades near the drilling locations. Drilling south of the existing lease boundary would help to identify available future reserves and grades. Additionally, it is recommended that Sisecam undertake Bed to Bed drilling from areas in the Upper Bed that overly future LB two-seam mining. For example, the LB South resource block could be drilled from the UBSW Mains or UB South Butts. Bed to Bed core drilling is significantly less expensive than surface exploration but is limited to two-seam areas.

Sisecam should continue to move forward in a prudent and timely fashion with validation of the two-seam mining to confirm both the geotechnical and economic assumptions.

It is recommended that Sisecam continue to pursue optimization of the refinery facilities to allow efficient processing of the predicted long-term decline in run-of-mine (ROM) trona grades as mining moves to the edges of the ore bodies. A more robust processing facility would allow a more complete recovery of the remaining ore reserves in areas where localized seam rolls and post depositional insoluble infilling has impacted recovery and stopped mining.

It is recommended that Sisecam optimize its ability to blend ore from multiple production areas of the mine to minimize the impact of the lower grade ore from the miners producing from the edge of the deposit or encountering seam rolls. This would also allow improved recovery of the deposit by maintaining a higher average ore grade and minimize sterilization of the thinner or lower grade areas of the deposit.

It is recommended that Sisecam continue close monitoring of the LB West water inflows and associated subsidence. HPG would advise more frequent isotope testing of the inflow as well as additional hydrologic studies including source tracing. HPG would advise more frequent subsidence monitoring and evaluations of the area.

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2.0 INTRODUCTION

2.1	BACKGROUND

Sisecam Wyoming LLC. (“Sisecam Wyoming”) engaged Hollberg Professional Group (HPG) to update HPG’s December 2019 Mineral Reserve Estimate on the trona mineral assets of Sisecam Wyoming LLC comprising Sisecam’s Green River Property (Big Island Mine & Refinery), Sweetwater County, Wyoming, United States of America (“USA”). Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%. Sisecam Resources LP is the registrant.

The primary goal is to provide an independent Mineral Resource and Mineral Reserve estimate in accordance with the requirements of the US Securities and Exchange Commission (SEC Regulation S-K Item 102 and Subpart 1300). This resource and reserve estimate of the remaining in-place and mineable trona reserves for the Big Island Mine is based on a life-of-mine plan (“LOM”) using current mining methods.

HPG personnel involved in this project include:

●	Kurt F. Hollberg, PE, Project Manager, Mining Specialist, Competent Person.
●	Terry Leigh, AIPG, CPG, PG, (Leigh Geological Services, Inc.) Resource Specialist.
---	---

This report was authored by Mr. Hollberg and Mr. Leigh.

Mr. Hollberg is a Licensed Professional Engineer in Wyoming, Colorado, Utah, and Nevada as well as being a Registered Professional Member of the Society for Mining, Metallurgy, and Exploration (SME).

Mr. Leigh is an AIPG Certified Professional Geologist and a Licensed Professional Geologist (PG) in Wyoming.

Both Mr. Hollberg and Mr. Leigh are considered ‘qualified persons’ for trona reserve estimation as defined by the JORC, SEC, and NI 43-101 Codes. Mr. Hollberg has over 35 years of experience and Mr. Leigh has over 40 years of experience in the Green River Trona Basin. Section 26.0 contains summary information on the team members.

Neither HPG nor any of its employees and associates employed in the preparation of this report has any beneficial interest in Sisecam Wyoming or in the assets of Sisecam Resources. HPG will be paid a fee for this work in accordance with normal professional consulting practice as a consultant to Sisecam Wyoming. Sisecam Wyoming’s predecessor OCI Wyoming (OCI) employed Mr. Hollberg from 1999 to 2003 and employed Mr. Leigh from 2003 to 2010. Mr. Hollberg left OCI Wyoming in 2002 to engage in consulting work and started HPG. Mr. Leigh retired from OCI Wyoming in 2010.

Mr. Hollberg and Mr. Leigh have over 70 years of combined experience in the Green River Trona Basin and its mining operations. They have performed engineering and geological services for Sisecam Wyoming, Genesis Alkali Corporation, Tata Chemicals, and TG Soda Ash Inc. HPG has served as a consultant to Sisecam Wyoming and its predecessor OCI performing mine engineering services since 2003 as well as other trona operators. Mr. Leigh has performed numerous geological services for Sisecam Wyoming and its predecessor OCI including supervision of exploratory drilling, seismic exploration, in-mine geologic mapping, and construction of a geologic model for the Big Island Mine as well as two other Green River Trona Basin operations.

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The individuals responsible for this report have extensive experience in the mining industry, in the Green River Trona Basin, and are members in good standing of appropriate professional organizations.

Kurt F. Hollberg, BSc, PE Colorado (PE-36599), Wyoming (PE-6599), Nevada (PE-018102), Utah, (PE 10385339), Registered Professional Member SME # 1475226. Richard Terry Leigh, MSc, AIPG (6708), CPG, Wyoming (PG-53).

No independent feasibility study was prepared in the determination of this reserve estimate. HPG has utilized the 60-year history of the Big Island Mine and Refinery mining trona and processing soda ash along with the past five years of operational and economic data demonstrating that the operation is economically viable.

2.2	SOURCES OF INFORMATION

This study uses the existing Sisecam Wyoming geologic database, drilling information, recent mine Trona thickness observations, current and historical financial information, and market studies, to estimate the trona resources available to Sisecam Wyoming. Based on this Mineral Resource Estimate and current business economics, a LOM plan was developed to estimate the recoverable trona and finished soda ash reserves which are the basis of this Mineral Reserve Estimate.

Section 24.0 contains a listing of the data files and sources provided by Sisecam Wyoming.

In addition to their historical knowledge of the subject property, both Mr. Hollberg and Mr. Leigh visited property for multiple days in September, October, and November of 2021. The purpose of these visits was to inspect both the surface and underground facilities, collect information for this effort and interview technical personnel working for Sisecam. During the visits HPG interviewed the following Sisecam technical and management personnel:

●	Guray Eken (VP, Manufacturing and Operational Excellence);
●	John Lewis (Mine Engineering Superintendent);
---	---
●	Hakki Ketizmen (Mine Planning and Business Development Superintendent);
---	---
●	Jeramy Spicer (Technical Services Manager);
---	---
●	Tyler Schiltz (Environmental Superintendent);
---	---
●	Hilary Huckfeldt (Principal Environmental Engineer);
---	---
●	Jim Spurrier (Principal Engineer - Surface Production);
---	---
●	Charley Walters (Surface Production Supervisor);
---	---
●	Scott Wilkes (CoGen Manager); and
---	---
●	Shannon Larson (QC QA Laboratory Supervisor)
---	---

Sisecam Wyoming’s excellent mine ground conditions allows examination of most areas of the existing mine and old workings. Mr. Leigh and Mr. Hollberg have examined many of these areas for this study. Mr. Leigh spent several days underground taking spot measurement of the Trona thickness in several areas of interest. Section 9.0 contains additional information on these inspections.

Surface tours included examination of the processing facilities (Units 3, 4, 5, 6 and 7), tailings facilities, DECA ponds and processing facility, Cogen plant, and Quality Control Laboratory.

During the interviews it was clear that Sisecam personnel have a good understanding of current mine operations, of the geology and mine planning, chemical processing and environmental obligations and are in good standing with their responsibilities.

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3.0 PROPERTY DESCRIPTION

3.1	BIG ISLAND MINE OPERATIONS

The location of Sisecam Wyoming’s trona mining and refining operation is shown in Figure 3.1.

The underground mining operation uses continuous miners mining in a modified room and pillar method. As of December 31, 2021, 170.1 MST of trona ore have been mined from these two beds, according to Sisecam Wyoming production records.

The Sisecam Wyoming refinery purifies the trona ore into soda ash (sodium carbonate). Soda ash is an essential raw material in glass making, chemicals, detergents, and other industrial products. Sisecam Wyoming sells the soda ash domestically through Sisecam Resources LP and its affiliates, which act as Sisecam Wyoming’s marketing and sales agent for all its domestic sales. Ciner Resources was a member of the American Natural Soda Ash Corporation (ANSAC), which handled the majority of Ciner Wyoming’s overseas sales and marketing. ANSAC was set up in 1984 to act as the international sales, marketing, and distribution cooperative for the leading producers of natural soda ash in the United States. ANSAC was established under the Webb-Pomerene Export Act and the Export Trading Company Act, which allows member companies to create a joint export venture. On November 9, 2018, Ciner announced its intention to withdraw from ANSAC effective December 31, 2021, with an option to exit effective December 31, 2020. Ciner exercised its option to withdraw on December 31, 2020, with the full withdrawal completed in 2021. There remain some sales commitments to ANSAC, at substantially lower volumes, through 2022.

In addition to partially owning Sisecam Wyoming, the Ciner Group has two other soda ash operations in Turkey, Eti Soda and Kazan Soda Elektrik Uretim A.S.

On December 21, 2021, Ciner Enterprises Inc. (CEI) completed the previously announced sale of 60% of Ciner Resources Corporation (“CRC”) to Sisecam Chemicals USA Inc., a wholly owned subsidiary of Turkiye Sise ve Cam Fabrikalari A.S. (“Sisecam”) of Istanbul, Turkey. Sisecam was founded in 1935 and is a global leader in chemicals and glass industries with operations in 14 countries and 22 thousand employees.

“Şişecam is the only global producer operating in all three key areas of the global glass industry: flat glass, glassware and glass packaging. It ranks among the world’s top two producers in glassware, and among the top five global producers in glass packaging and flat glass. Şişecam is also one of top three largest producers of soda and a world leader in chromium chemicals." (Ref: Sisecam Website)

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Figure 3.1 Big Island Mine General Location

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3.2	OWNERSHIP
---	---
3.2.1 ****	Trona Lease Area
---	---

Trona is defined by the US government as a “solid leasable mineral,” subject to the Mineral Leasing Act of 1920. Federally owned sodium resources are controlled by the Department of the Interior and managed by the Bureau of Land Management (“BLM”) and limited by Title 30§184(b). The act stipulates 10-year renewable lease periods, subject to annual rental and royalty fees, and demonstrated diligence. The federal government limits sodium leases to 5,120 acres by any one operator in one state but an exception in 30§184(b)(2) allows the Secretary, at his discretion, sodium leases or permits on up to 30,720 acres in any one State. Privately controlled sodium resource acreage is not limited.

Other mineral owners in the Green River Basin include the State of Wyoming, along with Sweetwater Royalties and other private mineral owners. Sweetwater Royalties is the second largest mineral owner in the KSLA. Sweetwater Royalties’ current holdings were part of the Pacific Railroad Act of 1864 granting every other section 20 miles on either side of the railroad to the Union Pacific Railroad. Sweetwater Royalties acquired ownership through a spin off from Occidental Petroleum’s recent acquisition of Anadarko Petroleum in 2019. In 2020 Occidental sold the Land Grant to Sweetwater Royalties, LLC who now owns the mineral.

Because the Green River Basin is also an area of extensive oil and gas exploration and production (“O&G”), there is a possibility of conflict between O&G and underground mining. The regional BLM and the Joint Industry Committee on Oil and Gas (“JICOG”) have established an O&G drilling moratorium area along with a Special Sodium Drilling Area (“SSDA”) under the 1997 Green River Resource Management Plan (“GR RMP”) (BLM 2011) within the KSLA that completely restricts O&G drilling. The area was largely defined by the BLM MMTA boundary. The KSLA is in the Kemmerer and Rock Springs Districts of the BLM. The BLM is currently in the process of developing a revision to the GR RMP, to be known as the Rock Springs RMP Revision (“RS RMP”) (BLM 2011). The Rock Springs RMP is planned to replace the 1997 Green River RMP, as necessitated by emerging resource issues and legislative changes. An associated Environmental Impact Statement (EIS) is also being developed along with a Mineral Resources Potential Report, including an updated Reasonably Foreseeable Development Scenario (RFDS), and is intended to forecast leasing and development activities over the next 20 years. The BLM will use the RFDS to help in determining the most appropriate land use planning alternatives to be evaluated in the RS RMP and associated EIS. It is unclear what impact this revision will have on the drilling moratorium in the KSLA leasing area or the KSLA. Several amendments to the existing RMP have been published but the final draft RMP along with its related draft EIS has not been published as of this writing. The BLM continues to report Q4 2018 for the final RMP and Q2 2019 for the Record of Decision but to date no official documents have been published or changes to these dates. Two changes to the current RMP have been published, one on Sage Grouse and the other on Wild Horse Management.

There are three Federal O&G leases dated in the late 1980’s that coincide with the Sisecam Sodium leases as well as a recent, 2020, “Area of Interest” Memorandum of Agreement covering most of the Sisecam Sodium Lease Area that is limited to O&G operations.

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In the area between the KSLA and MMTA moratorium areas, existing permitted O&G work is allowed, and new work is approved on a case-by-case basis under specific drilling rules.

Sisecam Wyoming’s leases and license are bounded on the north and east by the KSLA and MMTA boundaries (Figure 3.2). As long as the SSDA O&G moratorium area stays in effect, the current Sisecam Wyoming Federal holdings are protected from concurrent O&G exploration. Sisecam’s privately held leases are available for drilling under restrictive O&G drilling rules. Sweetwater Royalties reportedly supports the BLM moratorium and has not allowed drilling in the moratorium area.

3.2.2 ****	Mineral Leases and License

Sisecam Wyoming holds both private and public mineral leases and license over the Big Island Mine. In addition to the mineral leases and license, Sisecam Wyoming has several other permits with both U.S. federal and Wyoming state agencies that give it the right to mine the Big Island Mine.

Sisecam Wyoming has approximately 23,612 acres of sodium (Trona) under lease made up of approximately 7,934 Federal acres, 3,079 State acres, and 12,599 private acres.

Table 3.1 lists the current sodium leases and the license owned by Sisecam Wyoming and their status.

The location of Sisecam’s trona leases are illustrated in Figure 3.2 and Figure 3.3.

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(Source US BLM KSLA June-2019– Modified by HPG to include basin lease additions and ownership changes.)

Figure 3.2 KSLA Lease Map

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Table 3.1

Sisecam Wyoming Sodium Mineral Leases and License

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Figure 3.3 Sisecam Wyoming – Sodium Lease Tenure Location Map

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For the purposes of this study, it has been assumed that all the relevant mineral leases, license, and permits that are in place, that the terms and conditions of all agreements relative to tenure have been met, that there are no encumbrances to the tenures, and they can be renewed into the future for the life of the operations. HPG has conducted a general review of mineral titles and license documents provided by Sisecam. HPG has not verified title or otherwise confirmed the legal status of any of the leases or the license but has relied upon documents provided by Sisecam Wyoming’s representatives regarding the current status of the leases and license shown.

All federal leases are renewable on a 10-year cycle with the terms and royalty rate adjusted at the time of renewal. By Notice of Industry-Wide Royalty Reduction Soda Ash and Sodium Bicarbonate Leases dated February 8, 2021, the Secretary of the Interior authorized an industry-wide royalty reduction from currently set rates by establishing a 2 percent royalty rate for a period of 10 years, as of January 1, 2021, for all existing and future Federal soda ash or sodium bicarbonate leases.

Wyoming state leases are renewable on a 10-year cycle with the terms and royalty rate adjusted at the time of renewal.

On September 20, 2010, Sisecam Wyoming exercised its right to renew the original Union Pacific (Anadarko/Sweetwater Royalties) license for an additional 50-year period. The current Sweetwater Royalties UP-702 license extends to July 18, 2061. There are no provisions in the available documents for extension past this period. On October 12, 2015, Anadarko informed Sisecam’s predecessor OCI Wyoming that, per the License Agreement the royalty rate would be raised to 8%. OCI Wyoming and now Sisecam Wyoming disputed that claim, the litigation was settled in favor of Sisecam with the current royalty rate on these leases now 8%.

In 2017, the BLM granted Sisecam’s request to renew three Federal Sodium leases for their 10-year extension totaling 7,617 acres (W-0111730, W-0111731, and W-079420). On June 1, 2018, BLM renewed Sisecam’s Federal lease No. W-101824 of 316.9 acres also for 10 years.

Sisecam requested renewal of all five Wyoming State leases that expired in 2019. All five of the leases, 0-42570, 0-25779 0-42571, 0-25971, and 0-26012 were granted renewal for 10 years.

Sisecam still has lease rights to the B. Pal property private lease of 160 acres, “for as long as monthly rental payments are made”. Sisecam has reported that they continue to make the payments. Both the Upper Bed 25 and Lower Bed 24 areas of the PAL lease have been mined. The Bed 24 area has been used for TRM paste disposal and the Bed 25 Panels are some of the first two-seam mining test panels. Because we are not considering secondary mining and this area has been mined it was not considered for this reserve estimate.

Sisecam Wyoming’s predecessor, OCI Wyoming, owned another private sodium lease, the Hoefelt lease. This lease expired in 1997, and no parts of those lands are considered for this reserve estimate. The Bed 25 mining area for the Hoefelt property has been completed. The available Bed 24 trona for the Hoefelt property has been excluded from this analysis but might be available if a lease agreement were to be completed with Hoefelt’s heirs. This area contains an estimated 2.48 million recoverable trona tons at an estimated 88.9% trona grade. The lease also stipulated a perpetual easement for the workings contained in this lease.

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The Sisecam facilities are located on leased and deeded surface rights on T20N R109W Sections 1, 2, 3, 9, 10, 11, 12, 13, 14, and 15; and T20N R108W Sections 5, 6 and 7. The mineral rights and surface estate for Sections 2, 6, 10, 12, and 14 are Federal leases administered by the BLM. Sections 1, 3, 5, 7, 9, 11, and 15, are private lands and are leased from Rock Spring Grazing Association (RSGA) to Sisecam to sink wells and shafts for sodium related mining activities and related pipelines, power and telephone lines, roadways, wells, and all other associated facilities so long as Sisecam has licenses to mine. The Mineral rights for Sections 1, 3, 5,7 9, 11, and 15 are owned by Sweetwater Royalties LLC.

Figure 3.4 shows the boundaries of the current mining permit and the surface ownership for the subject property. Figure 3.5 shows the boundaries of the current mining permit and mineral ownership for the Big Island Mine.

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Source: Sisecam Wyoming

Figure 3.4 Surface Ownership

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Source: Sisecam Wyoming

Figure 3.5 Mineral Ownership

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4.0 ACCESSIBILITY, CLIMATE, LOCAL RESOURCES, INFRASTRUCTURE AND PHYSIOGRAPHY

4.1	ACCESS

Sisecam Wyoming’s mine and refinery are located 23 miles northwest of the town of Green River, Wyoming. The operation is accessible from Interstate 80 (I80), a four-lane divided highway, west to Exit 83, La Barge Road, then north on Wyoming Highway 372 (WY372) 12 miles to the OCI road, County Road 4. Both WY372 and County Road 4 are established paved two-lane highways that are maintained by Sweetwater County and the state of Wyoming Department of Transportation (WDOT).

The Sisecam site is serviced by a dedicated railroad spur line off the main East West Union Pacific rail line. Sisecam’s spur line connects to the Union Pacific Main line just east of the FMC/Genesis Westvaco Facilities.

In addition to the onsite railyard, Sisecam utilizes a contract railyard along La Barge Road (Highway 372) which is privately owned and maintained by others. There are between one and five track lines at the facility to assist with switching empty and loaded cars and prepping them for shipment offsite. There is an estimated 18,400-feet of track owned by the Big Island Mine and Refinery.

4.2	CLIMATE

The Sisecam facilities are located in the Green River drainage of the upper Colorado River system. Situated in a high intermountain basin bounded by the Wyoming Range to the West, Uinta Mountains to the south and the Wind River Range to the northeast, mean elevation exceeds 6,000-feet. Climate is dry, cold-temperate-boreal and characterized by limited rainfall (less than 8 inches) with long, cold, dry winters and warm-hot, summers with occasional storm producing flash floods. Evaporation exceeds 36 inches resulting in little excess water, limiting the majority of vegetation to the Green River flood plain. Wind generally blows from a southwesterly direction.

4.3	LOCAL RESOURCES

Green River (pop.11,825, 2020 Census), and Rock Springs Wyoming (pop. 23,526) are the two closest towns to Sisecam, 23 miles and 42 miles respectively. Evanston Wyoming (pop. 11,747) is 111 miles to the west and the major metropolitan area of Salt Lake City (pop. 1,185,238) is 194 miles to the West. Green River and Rock Springs are well established communities with histories dating back to the 1800’s as stops along the Union Pacific railroad with coal mining. The area has established oil and gas production, coal mining, major power generation, and five established trona mines that have been in business for 40 to 60 years. As a result, the surrounding communities have well developed industrial support capabilities. Both Green River and Rock Springs have developed school systems with a community college located in Rock Springs that has specific programs for training the technical and mechanical workers needed in the area. The community college has close ties to Wyoming University in Laramie, 200 miles to the east.

The population is stable and well diversified and considered the city of “56 nationalities” according to the Rock Springs Chamber of Commerce. The mines and oil and gas industry have higher than average compensation and benefits resulting in a stable community and workforce.

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4.4	INFRASTRUCTURE
---	---

The Sisecam Facility has been in operation for over 60 years and the infrastructure is more than adequate and well developed for its purposes. The site infrastructure includes among other things:

●	Soda Ash Process facilities;	●	Truck and rail loadout;
●	Electrical generation and transmission facilities;	●	Railyard and rail maintenance facilities
●	Natural gas pipelines and distribution facilities;	●	Mine access shafts. ore hoists, and ventilation fans;
●	Water supply and pumping station;	●	Mine infrastructure, belt haulage, crushing, and mining equipment; and
●	Water pipelines, treatment, and distribution;	●	Ample buildings for offices, labs, change rooms, warehouses, and maintenance shops.
●	Process waste tailings facilities;
●	Sewage waste and runoff treatment facilities;

Section 15.0 contains a more detailed discussion of the site infrastructure.

4.5	PHYSIOGRAPHY

Sisecam is located in the semi-arid high plateau region of southwestern Wyoming at elevations between 6,200 and 6,600-feet above mean sea level (MSL). Only about one percent (1%) of the land is barren, but the short growing season, rugged topography, poor soils, and limited availability of precipitation make vegetation rather sparse in both variety and productivity. Over most of the area, vegetation is homogeneous in appearance consisting of about 90 percent brush and shrubs, chiefly sagebrush, saltbush, with greasewood and winter fat in drainage areas. The area has historically been utilized for livestock grazing, wildlife habitat, and recreational hunting. This area provides limited winter grazing for cattle, sheep, and horses. However, stocking rates are low primarily due to sparse vegetation (Soil Conservation Service [SCS]1988).

The Sisecam property is crossed by the Green River which is a primary tributary to the Colorado River and located in the Upper Green Slate Watershed and designated Class 2AB waterway.

Figure 3.4 illustrates the topography of the Sisecam leases along with the surface ownership.

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5.0 HISTORY

During the late 1950’s into the early 1960’s, Stauffer Chemical Company was the second business to commence permitting for a soda ash facility in the Green River Basin. The area of interest was along the banks of the Green River. The permit area is located on the Big Island Bridge USGS Topographic Quadrangle. The Big Island is a predominate geographic feature in the Green River and is currently part of the Seedskadee Wildlife Refuge. From the initial permitting, the property has been known as the Big Island Mine and Refinery.

The former Stauffer Chemical Company initiated Trona exploration in August 1959. With the completion of 26 exploration drill holes by August 1960, the first reserve estimated was calculated; "A total of at least 360 million tons of better than 90 percent trona in beds 8.5 to 14-feet thick was proved up." (Trona Exploration in the Big Island Area, 1960). The Upper Bed (east of the Green River) contained 170 million tons and the Lower Bed, 190 million tons.

During 1961 minerals leases were obtained from Federal and private landowners, including the Union Pacific Railroad, totaling 33 ¼ Sections.

In 1962 Stauffer Chemical opened the Big Island Mine and Refinery in Green River, Wyoming with the purpose of producing all-natural soda ash from mined trona. Two shafts were sunk, and Refinery Units 1 & 2 constructed to produce dense soda ash. Mining commenced in the Lower Bed 24.

Four supplemental exploration drill holes were completed in 1967 and the acquisition of 2-1/4 Sections from the State of Wyoming and private ownership. Unit 3 was constructed to increase soda ash production.

Exploration activity increased substantially in the late 70’s and early 80’s more than doubling the database with 36 additional drill holes, now totaling 69 borings. Lease activity increased with addition of 4 ¼ Sections from Wyoming and private mineral ownerships. Then totaling 39 ¾ Sections or 24,736.89 Acres.

Over the next two decades Stauffer expanded production by adding Unit 4 and Unit 5 processing facilities. Production increased from 400,000 tons of soda ash per year to over 950,000 tons per year.

In 1985, the Big Island Mine and Refinery was acquired by Chesebrough Ponds and changed ownership several times over the next few years first to Imperial Chemical Industries in 1986 and a year later, to Rhone-Poulenc. Under Rhone-Poulenc continuous miners were introduced and Units 3 and 4 processing facilities were converted from triple effect crystallizers to mechanical vapor recompression.

Additional leases were acquired in 1988 (W-101824) increasing the area to 43-1/4 Sections or 26,653.79 Acres.

In 1996, Rhone-Poulenc sold its interest in the soda ash business to OCI Company, LTD, later renamed OCI Chemical Corporation.

OCI added Unit 6, a standalone processing facility, in 1998 and decahydrate mining in 2006 to increase the sites production to over 2.5 million tons per year.

In 1997 the Hoefelt private lease totaling 160 acres expired and was not renewed.

Former Union Pacific Lease TR708 was not renewed in June 2008. This acreage was deleted from the resources in the 2010 update with leased acreage now totaling 23,612 (Table 3.1).

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Since the exploration program was completed in 1980, additional thickness and quality information was collected in the early 2000’s. Twelve additional surface exploration drill holes were completed, now totaling 81 data points. Supplementing this are 10 borings completed in the Lower Bed from the Upper Bed and 34 borings into the Upper Bed from the Lower Bed. A more detailed description of the exploration efforts is described in Section 7.0 and the exploration drilling history is tabulated in Table 7.1.

Since 1999, over 4000 thousands of mine observations have been tabulated verifying the data interpretation. The geological depositional and post depositional features, described below, have been recognized from the mine mapping.

In September of 2013, OCI announced its Initial Public Offering (IPO) on the NYSE under ‘OCIR’.

Through Ciner Enterprises Inc., a Ciner Group affiliate and parent of Sisecam Chemicals Resources LLC (“Sisecam Chemicals” formerly known as Ciner Resources Corporation), Ciner Group acquired control of the property in 2015 and sold a controlling interest (60%) of the outstanding units of Sisecam Chemicals to Sisecam Chemicals USA Inc. as of December 21, 2021. Sisecam Chemicals indirectly owns approximately 72% limited partner interest in Sisecam as well as its 2% general partner interest and related incentive distribution rights. Through Ciner Enterprises Inc., Ciner Group continues to hold 40% of the interests in Sisecam Chemicals.

Sisecam is an international company with operations in 14 countries on four continents. ‘It ranks among the world’s top two producers in glassware, and among the top five global producers in glass packaging and flat glass. Şişecam is also one of top three largest producers of soda and a world leader in chromium chemicals.’ (Sisecam Website). Today, Sisecam Resources LP is on the NYSE as ‘SIRE’.

With Sisecam as the ‘controlling partner’ the Big Island Mine and Refinery is now vertically integrated with an end user of their product providing a base load for their plant and strengthening their international sales and logistics.

5.1	PRODUCTION HISTORY

Sisecam Wyoming has a long and consistent production history extending over 60 years. This long history forms the basis for our reporting of the trona reserves and resources. Table 5.1 shows the sites trona and soda ash production for the last six years. The only year of decreased production was 2020 due to the worldwide impact of COVID-19 virus.

Table 5.1

Sisecam Historical Soda Ash Production

By Year

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6.0 GEOLOGICAL SETTINGS, MINERALIZATION, AND DEPOSIT

6.1	GEOLOGIC SETTING

6.2	TRONA DEPOSITION

The trona mineral deposits within the Sisecam Wyoming lease area are correlated with the lacustrine sequences of the Eocene Green River Formation. Trona and other associated evaporates occur within the Upper Wilkins Peak Member.

The lacustrine sequences of the Green River Formation were deposited in a series of lakes. Approximately fifty million years ago, Lake Gosiute (Lake Gosiute, Figure 6.1), fluctuated in areal extent in response to climatic and tectonic events. At its smallest size, during restrictive phases, the lake was very saline and contained large quantities of dissolved solids. When evaporation of the water reached critical levels, dissolved solids precipitated to form trona, shortite, halite, and other saline minerals. Trona formed as a chemical precipitate and required a specific range of weight percent of sodium and carbon dioxide in solution, a specific range of temperatures, and a specific range of relative concentrations of other ions (calcium, magnesium, chlorides, sulfates, etc.) within the water column.

Figure 6.1 Deposition Basin – Lake Gosiute

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Sediments eroding from the peripheral mountains created extensive alluvial plains and broad flat pediments. Clastic wedges of the Wasatch and Bridger-Washakie formations intertongue and grade laterally with the lacustrine sequences of the Green River Formation (Figure 6.2).

Figure 6.2 Deposition Cross Section

Within the hydrogeographic basin of approximately 77,300 km^2^ (48,500 square miles), the greatest expanses of Lake Gosiute and surrounding mudflats occurred during the Tipton and Laney stages. Bradley (1964) estimated the lake expanded to over 24,000 km^2^ (15,000 square miles). Total evaporation of Lake Gosiute during the restrictive phases of the Wilkins Peak stage is indicated by the presence of sedimentary structures in the deposit.

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6.3	TRONA BEDS OF THE GREEN RIVER BASIN
---	---

The US Geological Survey recognizes 25 trona beds of economic importance (at least 1 meter in thickness and 300 km^2^ in areal extent) within the Green River Basin. Identified in ascending order, the trona beds are numbered 1 through 25 from the oldest (stratigraphically lowest) to the youngest (stratigraphically highest), as shown in Figure 6.3. Sisecam Wyoming has mineable reserves in the shallowest mechanically minable Trona Beds 24 and 25 (800 to 1,100-feet deep). Currently Genesis Alkali, Solvay, and Tata are mining Bed 17 occurring at greater depth. Pacific Soda is focused on the lower trona beds, Bed 1 through Bed 4, utilizing solution mining due to the trona depth.

Figure 6.3 Schematic Section Through the Trona Deposits

Trona Bed 1 through 18 of the Lower Wilkins Peak are relatively tabular with a fine grain sugary appearance. Various amounts of halite are present and can become more salt, halite, than trona towards the southwestern portion of the depositional basin. Halite is a significant contaminate in the refining process and reduces recovery and increases production cost. A stable depositional environment is implied by uniformity and minimal variation of the depocenters of Beds 1 through 18.

Trona Beds 19 through 25 are relatively halite free and consist of amber translucent coarse-crystalline blades to coarse granular “sugary” textured masses. Trona Beds 19 through 22 are located in the northwestern corner of the Green River Basin saline depositional basin. Trona Beds 24 and 25, mined by Sisecam Wyoming, are located in the northeastern corner of the Green River Basin.

Figure 6.4 shows the areal extent of the major trona beds in the Green River Basin.

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Figure 6.4 Green River Basin Trona Bed Extents

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6.4	LOCAL GEOLOGY AND LITHOLOGY
---	---
6.4.1 ****	Local Geology
---	---

Mineral reserves within the Sisecam Wyoming lease area are confined to Trona Beds 24 and 25. Isotope analysis of a volcanic layer, known as the Big Island Tuff, located between these beds, has dated deposition at approximately 49 million years. Local structural gradient is oriented west/southwest at a grade of approximately 50-feet per mile and was influenced by the structural high of the Rock Springs Uplift to the east. Overburden depths of Beds 24 and 25 increases along the strike of the dip from typically 800-feet to 1,100-feet with increasing surface topography. Figure 6.5 shows a generalized east-west cross section across the Big Island Mine property.

Figure 6.5 Generalized Cross Section – Bed 24 and 25

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6.4.2 ****	Trona Bed Lithology
---	---

A review of the exploration database and ore characteristics was initiated in 1999, by Korte and others, with greater emphasis on correlating mine observations with available drill core and lithological core descriptions. Mine mapping of trona ore thickness occurred along the perimeter of the mine developments as well as interior portions of the mine where access was available. A database of approximately 500 mine observations was developed. Documentation of this investigation was presented in 2002 with recommendations for continual study from supplemental exploration and mine observations. To date, the mine observations exceed over 4,000 measurements with emphasis on active mine areas. Mine observations in critical areas are on a 100-foot spatial density.

The 1999 investigation identified four distinct lithological horizons (geological facies changes) within each bed that may represent repetitive depositional occurrences. These horizons have been designated Trona 1 through Trona 4, or T1 through T4. The basal unit labeled T1 is composed of very fine grain sugary textured trona forming lenticular pods of varying thickness and is probably post depositional in origin. In the original 1980 database, sometimes the T1 was included, and sometimes it was excluded. T1 unit is not part of the reserve base for this study because it is separated from the mineable horizons by several layers of oil shales and marlstone. Dilution from these non-soluble minerals decreases ore grade to unacceptable levels.

The intermediate T2 through T4 horizons are currently mined by Sisecam Wyoming with the continuous miner fleet. During mining, the T4, and occasionally T2, are omitted. The T2 unit is stratigraphically at the basal contact with the floor shales. T2 is separated from the T3 unit by a thin marker seam of shale. This marker seam assists the miner operator with horizon control. The T4 unit is located at the top of the trona bed and represents the conclusion of deposition. An increase in insoluble materials in the T4 unit can reduce grades in this horizon. The T3 unit is the primary high-grade horizon. Only the T2 through T4 horizons are considered ore in this reserve update. Figure 6.6 illustrates this general lithological section.

The geological depositional and post depositional features, listed above, have been recognized from the mine mapping, and confirmed by several thousand mine observations.

Prior to trona formation, a layer of rich organic marlstone was deposited. This material can be classified as an oil shale but does not have sufficient organics to combust. Initial trona deposition of both beds was precipitated as layers up to 3-feet thick of a finer texture with some organic material giving this layer a darker color, illustrated as T2 Ore Zone on Figure 6.6 lithological section. An interruption of trona deposition is illustrated by the occurrence of a laminated marlstone. The marker seam might represent a brief climate change or a storm event, washing clay material into the lake. Subsequently, the primary trona precipitation followed as illustrated by T3 Ore Zone with purities up to 99%. Closure of trona precipitation is illustrated as T4 Ore Zone and contains greenish-grey marlstone lamination resulting in a decrease in quality. Post-deposition fluid migration from below produced a secondary layer of trona illustrated as T1 Zone. This zone probably was the result of hydrofracturing to floor shales to form lenses of trona varying in thickness from zero to six feet. The T1 unit has a fine sugary grain texture and can contain organics associated with the oil shales. Sisecam Wyoming’s mining is focused on a Mineable Ore Zone of T2 through T4 containing an average grade exceeding 89%.

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Figure 6.6 Trona Bed 24 & 25 Lithological Section

Interburden between Beds 24 and 25 is composed of laminated dolomitic marlstones with occurrences of volcanic tuff laminations and layers. Within the interburden are zones of organic rich marlstones and numerous occurrences of an associated mineral, shortite (calcium sodium carbonate).

Overburden above Bed 25 is composed of the same material listed above with increasing layers of hard dolomitic cemented detrital silts and fine grain sands. The detrital sediment probably represents storm events.

Other than microscopic material and algal debris within the trona, no fossils have been observed in trona beds.

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6.4.3 ****	Sedimentary Structures
---	---

Depositional and post-depositional sedimentary structures have been observed in the Sisecam Wyoming Mine and have had some impact on production grades and/or mining. These structures include:

Polygonal, vertically oriented, clay filled features are common, suggesting intense evaporation and desiccation, resulting in the formation of large “mud-cracks” within the deposit. Sisecam Wyoming Bed 25 exhibits these features in greater detail than Bed 24, Figure 6.7.

Figure 6.7 Filled Desiccation Crack within Trona Bed

“Blow-outs” occurring in both beds, represent a massive dewatering event from vertical brine movement eroding the trona bed. Results of this movement have been observed to completely obliterate the beds from a 12-foot seam thickness to zero within a 50-foot distance span, Figure 6.8.

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Figure 6.8 Blow-out Feature within Trona Bed

Geological faulting, movement, and fracturing have been observed in Bed 25. The occurrence of locally identified “root-beer” seams is associated with this type of disturbance, Figure 6.9.

Figure 6.9 Geologic Faulting within Trona Bed

Post-depositional dissolution from moisture/groundwater has been observed in the Lower Bed 24. Relatively isolated, the trona bed appears to be dissolved from the top after deposition, resulting in thinning of the bed and an increase in insoluble content in the upper portion of the seam, Figure 6.10.

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Figure 6.10 Post Depositional Dissolution within the Trona Bed

Post-depositional soft sediment folding and rolling of the ore bodies (observed in both beds), Figure 6.11.

Figure 6.11 Post Depositional Soft Sediment Folding within the Trona Bed

Originally, the trona beds were formed close to sea level but now reside at a mile above sea level. During this transition period, compressional forces squeezed the tabular deposits. Where trona was thick and competent, little impact occurred, but as the ore bodies thin and become less competent, pinching and rolling could occur. Severe seam rolling can result in localized production grade dilution from increased insoluble minerals at the basal contact.

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7.0 EXPLORATION

Exploration drilling has been the primary method to delineate trona Beds 24 and 25. The former Stauffer Chemical Company initiated trona exploration in August 1959 and completed 26 exploration drill holes by August 1960. Four supplemental exploration drill holes were completed in 1967 and the acquisition of 2-1/4 Sections from the State of Wyoming and private ownership. Exploration activity increased substantially in the late 1970s and early 1980s more than doubling the database with 39 additional drill holes, bringing the total to 69 borings. Two solution wells were drilling in 1994 bringing the total to 71. The final 10 exploration drill holes were completed from 2000 to 2011. A total of 81 surface to bed drill holes supplemented with 44 bed-to-bed borings comprise the basis of the data set. Enhancing this data set are over 4,000 observations and measurements from the existing mine developments.

In general, the core samplings were collected from each boring and prepared for analysis. Methodology utilized for coring varied through time and have included mud drilling, saturated brine drilling, air-foam drilling, wireline drilling and continuous coring from surface. A limited number of borings were logged with geophysical techniques including gamma, sonic, neutron, caliper, and high-resolution rock mechanics tools.

Only four of the 30 exploration drill cores from the 1959 to 1967 drilling programs have survived. The more recent core from 1975 through 2011 is stored in the mine at a constant climate. Verification of trona thickness and quality has been difficult for the 1975 through 1980 exploration cores due to decomposition and desiccation of the marlstone clays.

No supplemental exploration has been conducted since 2011 and drilling records remain unchanged. Mine observations from Sisecam’s 2020 and 2021 mine advance in the northeastern and southern portions of Bed 25 have been incorporated into this analysis.

Since 2017 the only mining in Bed 24 was the extensions of the LB East Mains and LB North Mains, Two Seam area. Examination of this area did not indicate any requirement to modify the Bed 24 geologic model.

Table 7.1 shows the history of the exploration drilling on the Big Island Mine, Figure 7.1 and Figure 7.2. illustrates the location of the exploration drilling.

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Table 7.1

Big Island Mine Exploration Drilling History

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Figure 7.1 Surface Exploration Drilling Locations with Surface Topo

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Figure 7.2 Underground Exploration Drilling Locations with Upper and Lower Bed Mining Outlines

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

8.0 SAMPLE PREPARATION, ANALYSIS, AND SECURITY.

For recent exploration drilling the core samples were examined, photographed, and logged in the field then boxed, labeled, and prepared for transportation. Early exploration had minimal documentation on preparation and core logging. More recent exploration campaigns are better documented with photographs of the core prior to boxing.

Standard practice was to split the core samples along the length of the core with half the sample sent to in mine storage. Sample intervals were generally between six and twelve inches in length. The split sample was then analyzed by the Sisecam plant laboratories. The Sisecam Wyoming laboratory has multiple certifications including ISO 9001-2015 and NSF. The lab has multiple well documented quality control and quality assurance processes which were reviewed during the site visit. The more recent samples remain available for further analysis if results are out of the norm.

Earlier core samples were subjected to external and internal analysis. Analytical methodology evolved over time. Initially, samples were reported for sodium carbonate and sodium bicarbonate content with weight percent trona calculated. The exact procedure for the early analysis is unknown. Analysis of more recent core simulates the existing refinery process:

1.	Crushing to 3/8 inch or less;
2.	Dried in oven;
---	---
3.	Dissolved with water;
---	---
4.	Filter insoluble;
---	---
5.	Prepare filtrate;
---	---
6.	Titration with acid;
---	---
7.	Calculate total alkalinity; and
---	---
8.	Convert to weight percent trona.
---	---

Records from the exploration projects are stored in a locked storage location in Sisecam Wyoming’s technical office building at the mine site with the core samples stored in the mine where the stable humidity and temperature helps preserve the samples.

Project 01-21-001	56	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

9.0 DATA VERIFICATION

9.1	SITE VISITS

In performance of these services and preparation of this study, Mr. Hollberg and Mr. Leigh have made numerous site visits to the Big Island Mine with the most recent visits on the 29^th^ of September 2021, 2^nd^, 12^th^, 13^th^, 14^th^ and 28^th^ of October and 16^th^ of November 2021.

9.1.1 Mine Visit

Mr. Leigh visited the mine on Sept 29^th^, October 2^nd^, and 28^th^ examine and workings and take thickness measurements for conformation of drill hole data and to add to the database used for this estimate. During his visits he examined the following areas:

●	Upper Bed 25
○	UBE Submain Buttes;
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○	UBE P10S;
---	---
○	UBE P9S;
---	---
○	UBE P7S Start;
---	---
○	UBSW P8E End of Panel;
---	---
○	UBSW P9E End of Panel;
---	---
○	UBSW Buttes;
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○	UBSW P11 W End of Panel;
---	---
○	UBE P7S Completion; and
---	---
○	UBE Submain Completion
---	---

On 12-Oct-21 Mr. Hollberg examined the underground with John Lewis, Sisecam’s Engineering Superintendent. Areas examined during this visit included:

●	Lower Bed 24
○	LBNE Butts #1 North to X-cut 114 N – two-seam mining;
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○	LBNE 1W and LBNE 2W Panel Stub out, two-seam mining; and
---	---
○	Lower Bed Southwest #2 Butts- X-Cut 60 S – Water inflow pumping station.
---	---
●	Upper Bed 25 –
---	---
○	UB East Mains to X-Cut 121 end of mining east;
---	---
○	UBE 7 South Southeast Mains to X-Cut 21– end of mining;
---	---
○	UBE- Panel 10 South to X-Cut 31 – end of mining;
---	---
○	UBE Panel 7 South first half;
---	---
○	UBSW Butts #1 to X-Cut 265 – end of mining;
---	---
○	Panel 9 East UBSW LH Mining to X-Cut 41E (CM02);
---	---
○	Panel 10 East UBSW RH Mining to X-Cut 29E (CM06); and
---	---
○	Panel 11 East UBSW to X-Cut #6W.
---	---
Project 01-21-001	57	HPG
---	---	---
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

The following are some general observations based on these examinations:

LB Two Seam

The Lower Bed two-seam mining area was visited and is of interest because a large part of the remaining reserves are two-seam mining. Since the report in 2019, Sisecam has made a concerted effort to develop the mains so that panel mining can begin. Higher extraction panel mining below the existing upper bed panels is necessary to validate the viability of the two seam mine designs. In the last two years, Sisecam has developed the LB NE Mains to X-Cut 123N and has stubbed in the first two panels to the west. In 2021, Sisecam produced approximately 585,000 tons (13.7% of total ore production). Sisecam expects to begin mining in Panel 1West in Q1 of 2022 and increase ore production from two seam areas to approximately 880,000 tons (21% of total ore production).

The October 2021 examination of the LB two-seam mine workings indicated favorable ground conditions with plus 14-foot thick trona, little if any floor heave, corner spalling or roof cutters. The panel stub-out entries which are driven on a herringbone pattern also indicated favorable ground conditions. The only indication of increased geotechnical stresses, likely due to the Upper Bed mining, are shallow roof spalling perpendicular to the mining direction. These v-shaped breakouts are near linear, generally less than 2-inches deep and run perpendicular to the mining direction. These small spalls rarely impact overall roof stability unless the remaining roof trona is extremely thin or the spalling is parallel to an associated Natron seam. Similar spalling was also encountered in the Lower Bed West Panels to the south where high concentrations of roof gases were encountered.

The Lower Bed West was visited due to multiple events that occurred impacting access to that area since 2017. Reserve reports prior to 2019 assumed long term access to this area to recover the trona west to the 8-foot trona thickness contour line. Multiple seismic events occurred between 2017 - 2019, likely caused by large roof falls in the adjacent panels to the north and south, producing large methane discharges and water inflow(s) that flooded down dip areas of the LB below the 5,310 MSL elevation. Water inflow subsequently diminished prior to Sisecam needing to take action by pumping water out of the mine. Water inflow has stabilized at around 85 gallons per minute (gpm) which is now pumped from a newly developed pumping station in the Lower Bed Southwest #2 Butts. Earlier examination of the West mains revealed the entries to be caved tight at X-Cut 223W and the area has been blocked off and abandoned with a crib and post breaker line installed. Without extraordinary efforts, access to the outer reserve boundaries in through the LB West Mains is no longer possible. This topic is covered in more detail in Section 13.2.

UB East Mains, UBE Panel 10 South

An area of concern reported in the 2017 and 2019 reserve reports is the thinning ore in the UBE Mains where areas of ore less than eight feet caused by floor rolls and ore disruptions were encountered. Variable ore thickness from 7.7 to 13.3-feet in the eastern extent of the UBE Mains caused Sisecam to stop mining and develop UBE 7 South Mains to the south and then extend the mains to the east (7 South Southeast Mains). Mining was halted at X-cut 21 east due to floor rolls and disruptions in the trona bed.

Since the 2019 Reserve report, the UBE 7 South Southeast Mains were extended past the SBI-20 drill hole at X-cut 17 East. SBI-20 is shown as 15.1-feet of ore at an average grade of 89.4%, but examination of the drill log shows the bottom 11.3-feet to be 97.1% grade and the top 4-feet to be 65.7%. Sisecam reports that cutting of the lower grade top trona has negative impacts upon the processing facilities and must be avoided. Examination of this area confirmed over 11-feet thickness good quality trona with low grade trona in the roof. In the 2019 Reserve estimate, the bed thickness for this drill hole was adjusted to 11.3-feet. The more current examination of this area confirms this change was correct.

Project 01-21-001	58	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Examination of UBE Panel 10 South off these mains showed increasing frequency of the floor shale horizon rolling up into then back down out of the trona bed mining horizon as the entries advanced east and south. With floor rolls initially occurring every 7 or 8 x-cuts and increasing in frequency with floor rolls every 2-3 x-cuts. The processing facilities can process this material but only at reduced rates. Without modifications to the processing facilities, or extensive efforts to blend this ore with higher-quality ore from other mining areas, ore from this area negatively impacts Sisecam’s soda ash production. UBE Panel 10 South was stopped at room 31. Figure 9.1 shows one of the floor rolls in this panel.

Figure 9.1 Floor Roll Panel 10 South UBE

Upper Bed 25 East Mining Area

UBE Panel 7 South has been developed approximately two miles south from the Upper Bed 25 East Buttes. At the terminus in Room 114 through Room 104, thin variable ore was encountered with deteriorating quality. Adjacent Panel 6 South UBE was mined an additiona1 1,400-feet south and was terminated with the same deteriorating ore conditions. The examination of the remainder of Panel 7 South exhibited sections with nominal ore conditions and sections with floor rolls and post-depositional disruptions including numerous vertical mud seams. Panel 7 South will require production quality control with blending ore from high quality production areas in other panels. Figure 9.2 shows one of the floor rolls in this area.

Project 01-21-001	59	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 9.2 Floor Roll Panel 7 South UBE

Upper Bed 25 Southwest Mining Area

The UB Southwest mining area has three continuous miner sections working and is currently the primary production area for Sisecam. Over the course of this work and our previous report, all the production panels in this area have been examined to their furthest mining extents.

UBSW Panel 7 East was examined, in a previous review, to its farthest extent Room 180E showing good ore thickness until Room 160 along the northside of the panel. The panel was terminated with thin variable ore and deteriorating quality within the upper 3 to 4-feet of the trona bed.

Examination of UBSW Panel 8 East showed advance east to Room 205E with good ore thickness to Room 190 along the northside of the Panel followed by an abrupt thinning and quality change similar to Panel 7 East. The southside of Panel 8 East exhibited less effects of thinning. Trona bed thickness averaging 11.8-feet with a range of 8.9 to 12.8-feet with improving quality as mining retreated to the west. Sisecam has mined this panel on the south and north to take advantage of reduced Federal Lease Royalty rates. The southern rooms, 1 through 65E, also contained good quality and thickness. The 11-foot thickness and quality found in this area is consistent with drill hole SBI-43 located near Room 65. The 10.6-feet ore thickness at Room 196 also correlates with the 10.71-feet indicated by drill hole SBI-07 which is located 240-feet to the south.

UBSW Panel 9 East had advanced to Room 44E. Ground conditions and ore thickness were excellent with minimal floor rolls and quality issue identified.

UBSW Panel 10 East had advanced to Room 31E at the time of the inspection. Ground conditions and ore thickness were excellent with no floor rolls identified. This panel appeared to possess the best ore quality of the mining sections examined with seam thickness greater than 11ft and minimal floor waste, resulting in an estimated production grade of approximately 92%.

Project 01-21-001	60	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

UBSW Panel 11 East had been stubbed in four rooms. Examination of this area shows good ore thickness and stable ground conditions. UBSW Panel 11 East mining is planned to commence in 2023.

USBS Panel 11 West advanced to Room 43 and mining was suspended to take advantage of federal royalty rate reductions. At Room 43, ore thickness and quality remain excellent with average seam thickness approximately 11-feet. At the section neck-off, the 3^rd^ room, contains ore thickness over 14-feet in places with good quality and no observable floor rolls. SBI-42 to the southwest shows 14.3-feet of ore but a grade of 83%. Given the start of Panel 11 West and the UBSW Butts faces, the lower grade of SBI-42 is likely caused by a localized mud seam and is not considered representative of the ore grade in this area.

Mr. Leigh examined UBSW Panel 10 West, in a previous review, to its western extents and confirmed SBI-41’s ore thickness of 11-feet and grade of 89%, with thickness ranging from 9.8 to 12.2-feet. This panel was stopped at the property boundary, but the ore thickness and quality could have warranted extension to the west. Sisecam is in the process of acquiring the ¼ section to the west to allow for potential extension of mining of USBS Panel 11 West to the west beyond that of USBS Panel 10 West in 2024 - 2025. Potential recoverable reserves on this ¼ section are estimated at approximately 1Mt, however these potential reserves to the west are not included in this study as they were not currently controlled by Sisecam at the time of this study.

9.1.2 ****	Shafts and Hoisting Facilities

On 12-Oct-2021 Mr. Hollberg toured the mine hoisting facilities with Mr. Lewis. Since 2017 Sisecam has been working to upgrade and modernize its hoisting systems by updating the controls systems, motors, and braking systems. Hoist #3 has been updated with new AC VDF drives and updated control systems. Hoist #2 has been updated with improved DC drives, braking systems and new bull gear. These changes have been designed to allow for improved major component spares and redundancy.

Additionally in 2020 and 2021, Sisecam developed a new ventilation shaft, Shaft #4 with two new ventilation fans which will support the expanding mine and improve mine ventilation. This facility was nearing completion at the time of the visit and was commissioned in November 2021. The new fans and shaft have the capacity to nearly double the airflow into the mine which can support the planned increase in production as well as extension of the mine workings in all directions. During the underground visit the bottom of the shaft was examined and later the fan facilities were examined. The shaft and fan facilities are of excellent design and workmanship, incorporating what is now best practice for mine fan configuration and mechanical design.

Adjacent to the Shaft #4 fan house was a new electrical switch house (Switch House #4). This switch house will replace old and outdated electrical gear for Hoist #3 and TRM as well as supplying Shaft #4 and future expansion in this area. This is an example of Sisecam’s commitment to updating and modernizing the Green River facilities and verifies implementation of the capital expenditure plans.

9.1.3 ****	Surface Facilities Site Visit

On 14-Oct-2021 Mr. Hollberg and Mr. Leigh examined the Sisecam surface processing facilities with Charley Walters (Surface Production Supervisor), the tailings facilities with Jim Spurrier (Principal Engineer - Surface Production), the Cogen Plant with Scott Wilkes (CoGen Manager), and the analytical lab with Shannon Larson (QC QA Laboratory Supervisor).

Project 01-21-001	61	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Surface facilities visited include the following:

●	Ore storage and reclaimer;
●	Units No 3 and No 4 Filters, evaporators/crystallizers, and dryers;
---	---
●	Unit 5 Filters, evaporators/crystallizers, and dryers;
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●	Unit 7 calciner, Verta-mill, dissolver, classifier;
---	---
●	Unit 6 Standalone processing, crushing, calcining, dissolvers, classifier, filtration, evaporation/crystallization, thickeners, and tailings pumps;
---	---
●	Decahydrate Plant;
---	---
●	Tailings Facilities, and;
---	---
●	Analytical and QC Laboratory.
---	---

While the age of Sisecam’s soda ash processing facilities, 50 to 20 years old, are obviously a challenge, HPG’s examination revealed an operation that has been investing the capital necessary to maintain its productive capabilities. During the brief visit multiple areas were observed where significant capital expenditure has been expended to maintain and improve production. Examples include multiple heat exchangers (Unit 4), filters (Unit 4), upgraded calciner and dryer burners (Units 3, 4, & 6), upgraded compressors for the MVR system (Unit 6). While HPG’s examination was not a comprehensive analysis of each piece of equipment, Sisecam’s long history of consistent soda ash production would not be possible without proper maintenance of processing facilities of this age.

Sisecam’s recently commissioned, 2020, Co-Gen facility is a state-of-the-art combined cycle gas turbine that supplies approximately 25 MW of electrical power to the site as well as producing excess steam for the production process and site heating. The gas turbine and heat steam recovery generator are approximately 60-65% efficient and use best available control technology (BACT) for emission control. During the visit, the system was in operation producing approximately 24 MW.

Sisecam’s tailing facilities are over 60 years old and are not without their challenges due to poor early construction methods in the 60’s, 70’s and 80’s, and have required Sisecam to do extensive mitigation work and development of a new tailings facility Pond 2. Based upon the voluminous documentation provided the tailing pond system is closely monitored by both Sisecam and Barr Engineering, an outside consultant. HPG’s examination revealed that Sisecam has been following the current designed plans, continues to monitor structures and make necessary repairs where needed. Additional information on the Tailing Facilities is available in Section 17.4.

Sisecam’s analytical laboratory contains up to date equipment and analytical capabilities. The lab processes both ‘in stream’ samples (dry trona and liquor) as well as final soda ash product testing. Ms. Larson walked HPG’s representatives through a typical soda ash testing procedure, documentation, and sample retention for the final product. The lab continually sends portions of samples for third party verification of results. The lab is 9001:2015 certified and holds certifications for NSF, 2021 Halal, and Kosher-2021.

Additional information on Sisecam’s production facilities can be found in Section 14.0 Processing and Recovery Methods and Section 15.0 Infrastructure.

Project 01-21-001	62	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
9.2	GEOLOGIC DATA VERIFICATION
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Sisecam Wyoming’s available geologic data is well documented and has been vetted over the history of the property. The fact that the property has been in successful operation for over 60 years and has extracted trona from both beds gives confidence in the available geologic information and proposed mining methods.

Data density, or the spatial relationship between drill holes, has become more prevalent in industry classifications. Sisecam Wyoming’s drill hole spacing was designed first to establish a resources area. Initially, twenty-seven exploration borings were completed on 1 to 2-mile spacing. Subsequent exploration developed the remaining 54 borings to increase the data density and to assist with mine planning and lease acquisitions. Trona exhibits greater continuity and less spatial variability than coal or metal deposits. There are many examples of evaporite deposits that have been developed on wider drill hole spacing than the recommended standards for other minerals. In comparison, while Sisecam Wyoming’s drill hole spacing exceeds these recommendations, the historical record for the Sisecam Wyoming Big Island Mine demonstrates a reasonable correlation between drill hole data and available reserves.

In the above referenced 1999 work (Section 6.4.2), a database was created for each Trona Bed, 24 and 25, located within the Sisecam Wyoming lease area. That database was the basis of this MRE and previous estimates. Sisecam Wyoming provided available drill hole data for all 81 exploration borings including core descriptions, analytical results, available geophysical well logs, and available archived reserve reports. Supplementing this information was documentation of trona thickness observations from the existing mine developments collected over the past 20 years. The 1999 review work expressed concern about the data quality of some of the older core analysis. There was concern that some of the reported analysis did not match the core descriptions indicating mislabeling or perhaps the core boxes broke and not properly sorted. The general analysis is considered correct, but some of the geologist logged the holes from the bottom up and others from the bottom down and as such the orientation of the analysis was questioned. For example, SBI-42, analysis appears to be reverse. Where possible the logs were vetted or corrected where definitive information was available. The best supplemental information is documentation of trona thickness observations from the existing mine developments collected over the past 20 years.

The exploration reports were evaluated for accuracy of trona picks for thickness and quality. The drilling database described has been spot checked multiple times over the long history of HPG’s work at Sisecam. Additionally, whenever mine workings intersect or approach these drillings the associated workings have been examined to confirm the drilling data. Description of the examinations undertaken for this effort are offered below. In general, exploration information matched published assessments. The data are considered acceptable for use in mineral resource and mineral reserve estimates and in mine planning.

A comparison of a trona thickness model based on mine observation points and a model derived from the drill hole data shows a reasonable correlation over the mined areas. In Bed 24, the mine observations averaged 11.7-feet thickness compared to 11.4-feet using the drill hole data over the same area. Bed 25 correlation resulted in similar results, with the mine observations model averaging 11.3-feet, while the drill hole data model averaged 10.7-feet. Example: two exploration drill holes were recently encountered, SBI-41, and SBI-43. SBI-41 has a reported trona thickness of 10.97-feet, average mine observations estimate 10.9-feet. SBI-43 has a reported thickness of 11.69-feet, average mine observations estimate of 11.2-feet. Mine observation points are based on the measured ore thickness at each point and not the total mining height providing a direct comparison to the drill hole data set.

Project 01-21-001	63	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

In the 2013 and subsequent reports drill hole D02-05 was removed from the data base because of a high percentage of core loss in the area of the LB trona seam. Of two five-foot core runs over 2-feet of core was not recovered. This was likely due to dissolution of the seam but without conformation of actual trona the drill hole was dropped from the database. HPG recommends that additional exploration drilling be done in this area to determine the actual thickness.

In the 2019 report, the minable thickness of two drill holes was modified based on available mine measurements in the vicinity.

●

Drill hole SBI-20, now within the Upper Bed East extension of the modified mains, was modified from 15.1 -feet to 11.3-feet. While the full bed thickness quality, 89.4%, meets the 85% cut-off, the mine is limited to the purer bottom 11.3-feet at 97.1% as the impure roof trona negatively impacts processing. This is an older drill hole, so the core is not available for examination. Nearby mine observations indicated an average thickness of 11.2-feet, adding justification to the modification. Planned mining was completed near SBI-20 confirming the 11.3-feet thickness.

●

Drill hole SBI-42, near the UBSW Butts extension, was adjusted from 14.3-feet with a grade of 83.9% to 13.87-feet and a grade of 85.0% based on the nearby mining indicating plus 11-feet of ore with good quality in the lower portions of the trona seam. Mining in this area will also be limited to the higher quality trona. Additionally, the current equipment mining height is limited to 13.5-feet. This modification results in the area to the northwest to be classified as resources and reserves.

---

No other changes were made to the geologic data base.

Project 01-21-001	64	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
10.0	MINERAL PROCESSING AND TRONA BED THICKNESS, TRONA GRADE, TESTING
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10.1	CONVERSION OF TRONA TO SODA ASH
---	---

As was previously discussed, trona is a compound of sodium sesquicarbonate with the following formula, Na2CO3.NaHCO3.2H2O. It is the combination of sodium carbonate and sodium bicarbonate. The finished product, soda ash, is sodium carbonate. In very general terms, the conversion of trona into soda ash is the conversion of the sodium bi-carbonate portion of the trona into sodium carbonate and then a purification process to remove the insoluble minerals by dissolution and recrystallization.

There are two primary ways in which sodium carbonate is recovered from the trona ore, the sodium sesquicarbonate process, and the monohydrate process. The main difference between these processes is when the bicarbonate is converted into carbonate. In the sesquicarbonate process, the trona ore is dissolved first and the conversion of the bicarbonate takes place by calcining the purified crystals. The monohydrate process converts the bicarbonate by calcining the dry ore in rotary kilns at temperatures between 150^o^ and 200^o^ C. Sisecam Wyoming uses the monohydrate process. The general formula for this conversion follows:

2NaCO3♦NaHCO3♦2H2O 3Na2CO3 + CO2 + 5H2O

By molecular weight:

2(226.03) / 3(105.98) = 452.06 / 317.94 = 1.4218

After calcining, the ore is dissolved in water to allow the insoluble minerals to be removed prior to recrystallization.

10.2	PROCESSING FACILITIES

Sisecam Wyoming’s refining facility is well established and has been converting dry trona into salable soda ash for over 60 years. Over this period, much of the refining facility has been replaced or upgraded with newer facilities and equipment. Sisecam Wyoming currently is operating five soda ash processing units. Unit 6 is a single large integrated plant, combined with a large calcining dissolver, Unit 7, which feeds liquor to crystalizing Unit 3, Unit 4, and Unit 5.

Unit 6 was constructed in 1998 and has its own crushing plant, rotary kiln, dissolvers, crystallizers, and TRM (tailings) pumps. In 2006, OCI Wyoming constructed a large rotary kiln and dissolver, Unit 7, capable of feeding liquor to the older crystallizer Units 3 through 5 use the existing crushers and TRM facilities. In 2009 the Decahydrate plant was built and mining of the decahydrate crystals in the tailings pond was started as a supplementary liquor feed to the soda ash plants.

A more detailed discussion of the processing facilities is available in Section 14.0.

Project 01-21-001	65	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
10.3	TESTING AND ANALYSIS
---	---

Sisecam has had an onsite laboratory throughout its history that is used to test and analyze plant feeds (trona), intermediate process streams (liquor) as well as the final product to ensure compliance with Sisecam published standards. The testing and analysis procedures and protocols are well established and have been developed and refined over the 60 years of operation. The analytical lab holds multiple certifications including ISO 9002 since 1994 and 9001:2008 since 2010. The lab is regularly audited by the certification agencies as well as customer audits. Additionally, the Sisecam laboratory does regular blind testing with outside laboratories as part of their standard protocol.

Composite samples of the trona ore are generally tested for insoluble minerals, grade (total alkalinity), moisture and organics. Intermediate liquor testing is used to monitor efficiencies and help in the operation of the plant. Composite sample testing of the final soda ash product is done on every truck or train car shipped. This analysis looks at purity (Sodium Carbonate % and Sodium Oxide %), moisture, density, and any contaminates (sulfate, chloride and insoluble).

Project 01-21-001	66	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

11.0 MINERAL RESOURCE ESTIMATES

11.1	INTRODUCTION

HPG has organized the available data and information in order to complete this Mineral Reserve Estimate for December 2021 from a variety of sources including:

●	Drill Hole data from 81 surface to bed core holes;
●	Drill hole data from 44 bed-to-bed core holes;
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●	In-mine measurements and observations; and
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●	Historical reports.
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11.2	GEOLOGICAL AND MINERALIZATION MODELING
---	---

Carlson’s Advance Mining module, StrataCalc, a supplement to Autodesk’s AutoCAD, was utilized to create the geological models. Both programs are standard for the mining industry. Gridding with the triangulation module was used to evaluate the Sisecam Wyoming reserve database. The data was modeled using triangulation which provided the best routine for verification.

Carlson’s Advance Mining module and StrataCalc, applies the gridding information within a user defined area (reserve area) and computes statistical parameters from the data set. Average thickness and grade values, area of the defined limits, volumes, and tonnages are posted as a spreadsheet output. Gridding density, contouring methods, volumetric computations, and bulk densities were unchanged from the previous study.

A bulk density of 133 pounds per cubic foot (2.13 g/cc), was applied to convert volumes to tonnage. Several published documents list bulk densities of trona between 2.11 and 2.17 g/cc.

Figure 11.1 Upper Bed Isopach and Figure 11.2 Lower Bed 24 Isopachs delineate trona thickness for each bed.

Project 01-21-001	67	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 11.1 Upper Bed 25 Thickness Isopachs

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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 11.2 Lower Bed 24 Thickness Isopachs

Project 01-21-001	69	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
11.3	MINERAL RESOURCE AND RESERVE CLASSIFICATION
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The following definitions, which can be found in the Securities and Exchange S-K 1300 rules Subparts 229, 230, 239, and 249, have been used for this resource and reserve estimate.

Mineral resource:

A concentration or occurrence of material of economic interest in or on the Earth’s crust in such form, grade or quality, and quantity that there are reasonable prospects for economic extraction. A mineral resource is a reasonable estimate of mineralization, taking into account relevant factors such as cut-off grade, likely mining dimensions, location, or continuity, that, with the assumed and justifiable technical and economic conditions, is likely to, in whole or in part, become economically extractable. It is not merely an inventory of all mineralization drilled or sampled.

Inferred mineral resource:

That part of a mineral resource for which quantity and grade or quality are estimated on the basis of limited geological evidence and sampling. The level of geological uncertainty associated with an inferred mineral resource is too high to apply relevant technical and economic factors likely to influence the prospects of economic extraction in a manner useful for evaluation of economic viability. Because an inferred mineral resource has the lowest level of geological confidence of all mineral resources, which prevents the application of the modifying factors in a manner useful for evaluation of economic viability, an inferred mineral resource may not be considered when assessing the economic viability of a mining project and may not be converted to a mineral reserve.

Indicated mineral resource:

That part of a mineral resource for which quantity and grade or quality are estimated on the basis of adequate geological evidence and sampling. The level of geological certainty associated with an indicated mineral resource is sufficient to allow a qualified person to apply modifying factors in sufficient detail to support mine planning and evaluation of the economic viability of the deposit. Because an indicated mineral resource has a lower level of confidence than the level of confidence of a measured mineral resource, an indicated mineral resource may only be converted to a probable mineral reserve.

Measured mineral resource:

That part of a mineral resource for which quantity and grade or quality are estimated on the basis of conclusive geological evidence and sampling. The level of geological certainty associated with a measured mineral resource is sufficient to allow a qualified person to apply modifying factors, as defined in this section, in sufficient detail to support detailed mine planning and final evaluation of the economic viability of the deposit. Because a measured mineral resource has a higher level of confidence than the level of confidence of either an indicated mineral resource or an inferred mineral resource, a measured mineral resource may be converted to a proven mineral reserve or to a probable mineral reserve.

Modifying factors:

Are the factors that a qualified person must apply to indicated and measured mineral resources and then evaluate in order to establish the economic viability of mineral reserves. A qualified person must apply and evaluate modifying factors to convert measured and indicated mineral resources to proven and probable mineral reserves. These factors include but are not restricted to mining; processing; trona bed thickness, trona grade, infrastructure; economic; marketing; legal; environmental compliance; plans, negotiations, or agreements with local individuals or groups; and governmental factors. The number, type and specific characteristics of the modifying factors applied will necessarily be a function of and depend upon the mineral, mine, property, or project.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Mineral reserve:

An estimate of tonnage and grade or quality of indicated and measured mineral resources that, in the opinion of the qualified person, can be the basis of an economically viable project. More specifically, it is the economically mineable part of a measured or indicated mineral resource, which includes diluting materials and allowances for losses that may occur when the material is mined or extracted.

Probable mineral reserve:

The economically mineable part of an indicated and, in some cases, a measured mineral resource.

Proven mineral reserve:

The economically mineable part of a measured mineral resource and can only result from conversion of a measured mineral resource.

11.4	MINERAL RESOURCE ESTIMATE - PARAMETERS AND ASSUMPTIONS

In determining the resource parameters and assumptions for the Sisecam property, HPG considered the following circumstances:

●	Sisecam’s 60 year long history of successfully mining the deposit;
●	Projected 40-year mine life and likely change in economics, mining, and processing methods over the life of the property;
---	---
●	Mining methods of the other trona producers in the area;
---	---
●	Mining methods of historically successful mining of similar laminar deposits including coal;
---	---
●	The extensive database of in-mine measurements and drilling data; and
---	---
●	HPG’s knowledge operating and managing other trona mines in the area.
---	---

If both mechanical and solution mining is considered, a cutoff grade and thickness is not essential for trona mining in the Green River Basin. Other trona operations in the green river basin and other trona deposits are successfully using solution mining methods in thin and low grade trona areas. Because of Sisecam’s proximity to the Green River this resource and reserve estimate does not consider solution mining due to its likely subsidence and impact to this major water source. Therefore, HPG is only considering mechanical mining of the deposit using established systems and methods.

Based on this knowledge and experience the following parameters were used to estimate the in-place trona resources that are considered to have reasonable prospect of economic extraction:

Parameters

●	Cut off -
●	Measured -
●	Indicated -
●	Inferred -
●	A soda ash price of 188 per ton was used to determine the stated trona resources.

All values are in US Dollars.

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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Assumptions

Only trona on contiguous leases was considered resource for mechanical mining. Section 16, T21N, R108W was excluded from this estimate because this state lease is isolated from the other contiguous lease blocks. The one-mile isolation makes accessing this for mechanical mining unlikely.

The measured, indicated, and inferred distances are based upon known drilling, in-mine measurements, mining extents and experience with historically successful mine planning based on this information.

The cutoff thickness of six feet is based upon successful mining of similar deposits, to and even below 6-feet in thickness including trona, coal and potash. Additionally, other operations in the trona basin are mining to the 7-foot thickness in areas of their trona resources.

The cutoff grade of greater than 75% trona is based upon successful mining and processing of the lower grade trona Beds 19, 20 and 21 which were considered viable mining prospects by Texas Gulf Soda Ash (TGSA). TGSA operated as a dry mine from 1976 through 2002 mining Bed 20. The TGSA processing facility was designed to handle these lower grade ores and successfully mined and processed these lower grades.

11.5	GRADE ESTIMATION

For the purposes of this study, the minimum grade for the reported in-place resource tonnage is 75%. The Upper Bed 25 drill hole grades analysis range, for thicknesses greater than 6-feet, is 41.21 to 94.18%. All Upper Bed drill hole grades ranged from 38.64% to 98.81%. The Lower Bed 24 drill hole grades analysis range, for thicknesses greater than 6-feet, is 74.74% to 93.77%. All Lower Bed drill hole grades ranged from 74.74% to 94.10%. Based examination of available core and mine observations by previous geologist and others, many of the low-grade drill holes intersected vertical post depositional mud seams and are not considered representative of the overall average grade for the deposit at that particular location. Because of the limited core to definitively confirm this hypothesis, no changes were made to the database other than the three drill holes noted earlier.

Carlson’s Advance Mining module, StrataCalc, was used to model the grades for each resource parameter for each trona bed. Lower Bed 24 measured resources compute to have an average grade of 88.8% trona. Lower Bed 24 indicated resources have a computed average grade of 88.3% trona. The Upper Bed 25 computed measured resources grade is 87.6%, while the computed indicated resources grade is 87.6%.

Out-of-seam dilution during production has a significant impact on production grade. Production grade is the quality of the run of mine (“ROM”) material sent to the refinery. Production quality is dependent upon the geological consistency of the ore body; the mining equipment used for extraction; and the operators mining skill. Ore body fluctuations are the greatest contributor to quality control issues. In general, with a 10-foot-high entry, 90% seam grade, 6-inches of waste will reduce production grade by 5%. Forecasting seam variability from the existing wide drill hole spacing is not possible. Currently, the best tool to help identify and predict problem areas is consistent mapping of the mine entries as mining advances providing feedback to operators and utilized in the short-term planning processes. When they are encountered, localized geological disturbances of the ore bed negatively impact the ROM grade.

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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
11.6	IN-PLACE MINERAL RESOURCE ESTIMATE
---	---

Using the data provided by Sisecam Wyoming, HPG has completed its review of the Big Island Mine and concludes that the Big Island Mine’s remaining leased and licensed Measured and Indicated in-place trona Resources exclusive of reserves **** as of December 31, 2021, total 162.3 million short tons (MST), of which 98.9 MST remain in the Lower Bed 24 and 63.4 MST remain in the Upper Bed 25. Measured In-Place Resources are calculated as 74.2 MST and Indicated In-Place Resources calculate as 88.1 MST and Inferred In-Place Resources are calculated at 0.05 MST. Table 11.1 summarizes the estimated In-Place Trona Resource exclusive of the mineral reserves .

Based on the current study, the Sisecam Wyoming Big remaining leased and licensed Measured and Indicated in-place trona Resources inclusive of reserves as of December 31, 2021, total 578.9 million short tons (MST), of which 382.5 MST remain in the Lower Bed 24 and 196.4 MST remain in the Upper Bed 25. Measured In-Place Resources are calculated as 291.5 MST and Indicated In-Place Resources calculate as 287.5 MST and Inferred In-Place Resources are calculated at 0.26 MST. Table 11.2 provides the In-Place Trona Resource Inclusive of the mineral reserves

Criteria for this analysis are based upon a 6.0-feet minimum ore thickness and 75% minimum seam grade. This Resource evaluation is based upon 81 exploration drill holes, 44 borings from the mine workings, and several thousand available mine observations and measurements. Of the 81 surface exploration drill holes, 28 borings are within the Lower Bed 24 Resource area and 21 borings are within the Upper Bed 25 Resource area. Additionally, this updated report considers the 2020 to 2021 mine advancements. The in-seam ore horizon includes the T2 to T4 zones and excludes the T1 zone.

The reference point for the trona resources reporting is insitu inclusive of impurities and insoluble content. The grade is percent trona, sodium sesquicarbonate (Na2CO3.NaHCO3.2H2O), the double salt of sodium carbonate (soda ash) and sodium bicarbonate (baking soda).

Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.

Figure 11.3 and Figure 11.4 present the remaining in-place trona showing measured, indicated, and inferred resource areas.

Table 11.1

Estimated In-Place Trona Resources Within Big Island

Exclusive of Reserves

Mining License as of December 31, 2021

Based on $188/ TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 6-foot minimum thickness and an 75% minimum grade cut-off.
---	---
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
3)	The point of reference is in-place (insitu) inclusive of impurities and insoluble content.
---	---
4)	Mineral resources are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---

Table 11.2

Estimated In-Place Trona Resources Within Big Island

Inclusive of Reserves

Mining License as of December 31, 2021

Based on $188/ TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 6-foot minimum thickness and an 75% minimum grade cut-off.
---	---
3)	The point of reference is in-place (insitu) inclusive of impurities and insoluble content.
---	---
4)	Mineral resources are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral resources are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---

11.7	UNCERTAINTIES (FACTORS) THAT MAY AFFECT THE MINERAL RESOURCE ESTIMATE

Areas of uncertainty that may materially impact the mineral resource estimates include:

●	Changes to long-term soda ash price and exchange rate assumptions;
●	Changes in local interpretations of trona seam thickness and grade such as sedimentary structures described in Section 6.4.3;
---	---
●	Changes to geological and grade shape, and geological and grade continuity assumptions;
---	---
●	Changes to soda ash recovery assumptions;
---	---
●	Changes to the forecast dilution and mining recovery assumptions;
---	---
●	Changes to the cut-off values applied to the estimates;
---	---
●	Variations in geotechnical (including seismicity), hydrogeological and mining method assumptions; and
---	---
●	Changes to environmental, permitting, and social license assumptions.
---	---
Project 01-21-001	74	HPG
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 11.3 Upper Bed 25 Resource Blocks

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 11.4 Lower Bed 24 Resource Blocks

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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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12.0 MINERAL RESERVE ESTIMATE

This mineral reserve estimate contains “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, which are intended to be covered by the safe harbor created by such sections and other applicable laws. Please refer to the note regarding forward-looking information at the front of the Report. Investors are cautioned that the estimate is based on a high-level mine plan and certain assumptions which may differ from Sisecam Wyoming’s long-term outlook or actual financial results, including, but not limited to commodity prices, escalation assumptions and other technical inputs. Please be reminded that significant variation of soda ash prices, costs and other key assumptions may require modifications to mine plans, models, and prospects.

12.1	LIFE OF MINE PLAN

Sisecam like all mining companies, for lack of a better term “high grades” the mineral deposit where possible. Sisecam utilizes large highly productive continuous miners incorporating on-board roof bolters and a large on-board ventilation fan that require a minimum mining height of 9-feet. The required 9-feet mining height of this equipment limits how far mining may be extended to the edge of the ore body. Additionally, Sisecam’s processing facilities have limited ability to handle lower grade ore even if it is over a short period of a few hours. This plant limitation impacts what can be mined when disruptions in the ore body are encountered (Section 6.4.3). The lower grade material can be processed with minimal impact to recovery, but it must be processed at a slower rate which impacts total production. Sisecam has chosen to bypass this material and/or stop mining before the overall seam thickness and associated grade severely impacts the plant. Both of these choices are economic, made by Sisecam to minimize production costs. High grading is common and even standard practice for the mining industry. At some point in the future, Sisecam will have to make modifications, like other operators in the trona basin have done, to facilitate mining of these areas. This reserve estimate forecasts modification of the mining equipment and processing facilities in the future at a point when mining of the thicker trona (>9-feet) has been completed.

To account for this reality, HPG has developed a detailed Life-of-Mine (LOM) plan that in HPG’s opinion is a reasonable mining sequence for this deposit over its remaining 40 plus years assuming Sisecam choses to mine as much of the resource as possible. A two-stage mine plan has been developed. The first stage “high-grades” the deposit based upon the current mining equipment and processing plant limitations mining to the 9-foot isopach. This matches the practice employed over the last 20 years and should be viable for another 20 years. Based on this plan, thinner areas (less than 9-feet) or areas where disruptions have been encountered are not mined until later in the property life, assuming reasonable access is available at that time. This results in areas of the deposit that require a change in both mining equipment and processing facilities. The capital expense and changes to the operating costs for these changes has been accounted for in the economic analysis and a detailed mine plan has been developed showing potential access and mining of these areas.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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This type of two-stage mining is only possible when underground conditions allow access to the bypassed areas long after the first stage of mining was completed. This is true for the Big Island Mine where old mine workings developed 60 years ago are still open, accessible, and currently in use. Additionally, Sisecam has a history of accessing resource blocks from old mine workings. The UBSW slopes were developed in 2005 between old mine workings that had been mined in the 1970’s. After 50 years of being mined these areas continue to be the primary access to the UB Southwest reserve blocks.

Carlson Software’s Advance Mining module 2021^TM^ was used to calculate tonnages and schedule mine development. Carlson’s Advance Mining module applies the geologic bed thickness and grade information from the resource model to a user defined mining sequence with user defined equipment specifications.

Figure 12.1 and Figure 12.2 show a LOM plan for both the Upper and Lower Beds using current panel layouts, extraction rates and mining equipment based on the two-stage mining.

While some effort was made to time the future mine plan over its 40-year plus predicted life, as measured from December 2021, this model should only be considered a generalization of the proposed timing and an illustration of how the deposit could be mined. This LOM incorporated the following assumptions:

●	Production of 5.0 million ROM short tons per year starting in 2024;
●	9-foot plus material is mined first then the thinner 9-foot to 7-foot ore is mined;
---	---
●	Mining limit cut-off of 7-feet and 85% minimum trona grade;
---	---
●	Eastside of mine – Westside of mine production balance was maintained whenever possible. This exercise indicates that additional work is needed for long term planning, as the equal east-west split breaks down in the mine plan. This results from the concentration on mining Upper Bed Ore instead of Lower Bed Ore. East west balance of ore into the crusher area is needed because of infrastructure limitations in the crusher area;
---	---
●	Access to mining areas outside the 9-foot mining limit are provided by access through old workings, new development, or extensions of future mining panels;
---	---
●	Out-of-seam dilution of 4-inches;
---	---
●	Minimum entry mining height of 7-feet;
---	---
●	Maximum mining height of 13.5-feet; and
---	---
●	Mirror image two-seam panel layouts were used based on current two-seam mining designs.
---	---

To calculate the highest expected ROM feed grade optimally sized equipment was assumed and modeled as follows. Out of seam dilution was estimated at 4-inches of rock due to over mining the top or bottom. Additionally, a minimum entry height of 7-feet was assumed allowing the equipment to cut to the 7-foot thickness isopach. Trona seam thickness varies, and it is predicted that the areas near the 7-foot isopach contain localized trona thickness areas less than 7-feet and even less than 6-feet in places. When seam thickness is less than 7-feet, out-of-seam rock is cut to maintain the 7-foot minimum mining height or entry height. The net out-of-seam dilution is the over/under cut of 4-inches plus any rock cut to maintain an entry height of seven feet.

A maximum equipment mining height of 13.5-feet was assumed which is the current limit of Sisecam’s Joy 12HM26 roof bolters. Any trona ore thicker than 13.5-feet is assumed left in place, the historical mining practice using continuous miners at Sisecam. Based on the long history with continuous miners, this study did not consider larger equipment or bench mining to capture the in-place reserves thicker than 13.5-feet.

Project 01-21-001	78	HPG
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
12.2	MINERAL RESERVE ESTIMATION
---	---

In determining the reserve parameters and assumptions HPG considered the following circumstances:

●	Sisecam’s 60-year long history and economics of mining the deposit and producing soda ash;
○	The 170.1 MST of trona ore produced from these two beds;
---	---
●	The projected long life of the mine and resulting likely change in economics, mining, and processing methods over its projected 40-year mine life;
---	---
●	Sisecam’s current processing facilities capabilities and projected future changes to these facilities.
---	---
●	The economics associated with Sisecam’s current mining equipment and history of “high grading” the thickest portions of the deposit;
---	---
●	Sisecam’s current mining equipment limitations and required future changes to these systems; and
---	---
●	HPG’s knowledge operating and managing other trona and potash mines.
---	---

In determining whether the reserves meet these economic standards, HPG made certain assumptions regarding the remaining life of the Big Island Mine, including, among other things, that:

●	The point of reference is run-of-mine ore delivered to the processing facilities;
●	The cost of products sold per short ton will remain consistent with Sisecam Wyoming’s cost of products sold for the five years ended December 31, 2021;
---	---
●	The weighted average net sales per short ton, $188/ton, will remain consistent with Sisecam Wyoming’s average net sales for the five years ended December 31, 2021;
---	---
●	Sisecam Wyoming’s mining costs will remain consistent with 2021 levels until they begin two-seam mining, at which time mining costs for the two-seam mining tonnage could increase by as much as 53%;
---	---
●	Sisecam Wyoming’s processing costs will remain consistent with 2021 levels and rise in 10-years to account for lower grade material;
---	---
●	Sisecam Wyoming will achieve an annual mining rate of approximately 5.0 million short tons of trona in 2024 and beyond;
---	---
●	Sisecam Wyoming will process soda ash with a 90% rate of recovery, without accounting for the deca rehydration process;
---	---
●	The ore to ash ratio for the stated trona reserves is 1.835:1.0 (short tons of trona run-of-mine to short tons of soda ash);
---	---
●	The run-of-mine ore estimate contains dilution from the mining process;
---	---
●	Sisecam Wyoming will continue to conduct only conventional mining using the room and pillar method and a non-subsidence mine design;
---	---
●	Sisecam Wyoming will, in approximately 10 years, make necessary modifications to the processing facilities to allow localized mining of 75% ore grade in areas where the floor seam or insoluble disruptions have moved up into the mining horizon causing mining to be halted early due to processing facility limitations;
---	---
●	Sisecam Wyoming will, within one year, conduct ‘‘two-seam mining,’’ in production panels which means to perform continuous mining in Bed 24 beneath historically mined production panels of Bed 25 with interburden thickness of approximately 35-feet;
---	---
●	Sisecam Wyoming will, in approximately 20 years, make necessary equipment modifications to operate at a seam height of 7-feet, the current mining limit is 9-feet;
---	---
●	Sisecam Wyoming has and will continue to have valid leases and license in place with respect to the reserves, and that these leases and license can be renewed for the life of the mine based on their extensive history of renewing leases and license;
---	---
●	Sisecam Wyoming has and will continue to have the necessary permits to conduct mining operations with respect to the reserves; and
---	---
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
●	Sisecam Wyoming will maintain the necessary tailings storage capacity to maintain tailings disposal between the mine and surface placement for the life-of-mine (LOM).
---	---

Table 12.1 through Table 12.3 summarizes the estimated recoverable trona from the Big Island Mine based on the LOM. Section 12.2.3 provides additional details and explanation of the information contained in these tables.

Based on this analysis, Sisecam Wyoming can realistically expect to economically recover 220.0 MST of trona ore at an average grade of 85.2 percent from these reserves as of the end of December 2021. This is made up of 72.7 MST from Bed 25 and 147.3 MST from Bed 24. Proven recoverable tons are calculated as 97.4 MST, of which 33.4 MST remain in the Upper Bed and 64.0 MST remain in the Lower Bed. Probable recoverable tons are calculated at 122.6 MST of which 39.3 MST remain in the Upper Bed and 83.2 MST remain in the Lower Bed. This is based on Sisecam continuing to mine using its existing mining methods and extraction rates for the remaining life of the currently controlled reserves. Estimated finished soda ash reserves are 119.1 MST

Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.

12.2.1 ****	Reserve Estimate Reconciliation

HPG has not previously filed a technical report summary on this property.

12.2.2 ****	Reserve Estimate Comments

HPG offers the following additional details concerning these recoverable reserves:

●	148.2 MST of the recoverable reserves average greater than 9.0-feet in thickness while 71.8 MST are less than 9.0-feet thick
●	Future mining areas that will require processing plant modifications prior to mining comprise 39.5 MST of the total reserves, which is made up of 7.1 MST in the Upper Bed East Block and 32.4 MST in the Upper Bed North Block. It is anticipated that these plant modifications need to be made within 10-15 years.
---	---
●	118.1 MST (48%) of the recoverable reserves are two-seam mining with 71.5 MST in areas with thickness over 9-feet.
---	---
12.2.3 ****	Recoverable Trona Table Description
---	---

The following descriptions were used in calculating Table 12.1, Table 12.2, and Table 12.3:

Reserve Category and Lease or License –

Reported reserves are broken down into reserve classification, Proven or Probable, and divided by lessor or licensor.

Trona Seam Mined (Short Tons) –

Summarizes the total trona tons mined for each category. Calculated by multiplying the subject area times the estimated bed thickness. The trona seam is made up of pure trona interbedded with other soluble and insoluble minerals.

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Out of Seam Rock (Short Tons) –

The out-of-seam rock is a calculation of the tons produced from the inaccuracies of the mining process. The continuous mining machine is not capable of perfectly cutting the trona ore seam. For the purposes of this study 4-inches of out-of-seam, material has been included in the mined material.

Total ROM Mined (Short Tons) –

The total ROM material mined is calculated as follows:

Total ROM Mined = Trona Seam Mined + Out of Seam Rock.

These are the tons that the refinery will process and are the reported recoverable reserves at a given ROM grade.

Average In-Seam Grade (% Trona) –

The average in-seam grade summarizes the average trona grade for the seam over the reported category based upon the geologic model.

Total Trona (Short Tons) –

Total Trona reports the short tons of pure trona for the given category and is calculated as follows:

Total Trona = Trona Seam Mined x Average In-Seam Grade

This is the tonnage of trona ore available for processing into soda ash.

Total Rock (In-seam + Out-of-Seam) (Short Tons) –

Total Rock, in-seam plus out-of-seam reports the total insoluble material in the ROM ore for the given category and is calculated as follows:

Total Rock Tons = Out of Seam Rock Tons + Insoluble Tons within the mined bed

Total Rock Tons = Out of Seam Rock Tons + (Trona Seam Mined Tons – Total Trona Mined Tons)

Total ROM Mined (Short Tons) –

This column is a back check to ensure the calculations are accurate and equals:

Total ROM Mined = Total Trona + Total Rock.

Average ROM Final Grade (% Trona) –

Average ROM final grade estimates the final grade, in percent trona, of the material sent to the refinery and is calculated as follows:

Average ROM Final Grade = 1 – (Total Rock / Total ROM Mined /100)

Total Soda Ash Tons (90% Recovery) –

Total Soda Ash Tons reports the estimated soda ash that can be produced over the reported category and is calculated as follows:

Total Soda Ash Tons = Total Trona Tons / 1.4218 * 0.90.

The conversion factor for trona to soda ash of 1.4218 is explained in Section 10.1.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Table 12.1

Estimated Recoverable Trona Reserves for Bed 24 & 25

By Category and Mineral Owner

as of December 31, 2021

Based on $188/TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
---	---
3)	The point of reference is run-of-mine (ROM) ore delivered to the processing facilities including mining losses and dilution.
---	---
4)	Mineral reserves are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Table 12.2

Estimated Recoverable Trona Reserves for Bed 24 Only

By Category and Mineral Owner

as of December 31, 2021

Based on $188/TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
---	---
3)	The point of reference is run-of-mine (ROM) ore delivered to the processing facilities including mining losses and dilution.
---	---
4)	Mineral reserves are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Table 12.3

Estimated Recoverable Trona Reserves for Bed 25 Only

By Category and Mineral Owner

as of December 31, 2021

Based on $188/TSA

1)	Numbers have been rounded; totals may not sum due to rounding.
2)	Based on a 7-foot minimum thickness and an 85% minimum grade cut-off.
---	---
3)	The point of reference is run-of-mine (ROM) ore delivered to the processing facilities including mining losses and dilution.
---	---
4)	Mineral reserves are current as of December 31, 2021, using the definitions in SK1300.
---	---
5)	Mineral reserves are reported on a 100% ownership basis. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.
---	---
Project 01-21-001	84	HPG
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Figure 12.1 Upper Bed 25 Life of Mine Plan

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Figure 12.2 Lower Bed 24 Life of Mine Plan

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
12.3	UNCERTAINTIES (FACTORS) THAT MAY AFFECT THE MINERAL RESERVE ESTIMATE
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Areas of uncertainty that may materially impact the mineral reserve estimates include:

●	Changes to long-term soda ash price and exchange rate assumptions;
●	Changes in local interpretations of trona seam thickness and grade such as sedimentary structures described in Section 6.4.3;
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●	Changes to geological and grade shape, and geological and grade continuity assumptions;
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●	Changes to soda ash recovery assumptions;
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●	Changes to the forecast dilution and mining recovery assumptions;
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●	Changes to the cut-off values applied to the estimates;
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●	Variations in geotechnical (including seismicity), hydrogeological and mining method assumptions; and
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●	Changes to environmental, permitting, and social license assumptions.
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12.4	SECONDARY RECOVERY AND HIGH EXTRACTION MINING
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Due to non-subsidence limitations, this reserve estimate does not include any trona resources that could be recovered by solution mining or secondary recovery. Sisecam Wyoming has limited ability to implement high extraction mining or secondary solution mining due to the Green River crossing the property.

12.4.1 ****	Non-Subsidence Areas

Non-subsidence areas for the Big Island Mine include but are not limited to, the Green River, Sisecam Wyoming Refining Facility, tailings complex, railroad spurs, gas pipelines, highways, and surface access for return or injection systems.

While subsidence of rivers, roads, rail, and pipelines has been successfully done in the Trona Basin, the degree of subsidence and the features subsided dictate what mitigation efforts are necessary.

Due to its low drainage gradient and the proximity of Seedskadee National Wildlife Area, the Green River flood plain should be considered a non-subsidence area. Unfortunately, LB West seismic activity in combination with water inflow has resulted in subsidence next to a small section of the Green River. The DEQ and LQD have been made aware of this situation and they have not voiced any concerns at this time. Sisecam is in the process of notifying other relevant regulatory agencies and interested parties. The area is being monitored closely for any surface changes or impact to the underground mine. Further information on this topic is available in Section 13.2.1.

The Sisecam Wyoming Refining Facility, along with the mine shafts, are also considered non-subsidence areas. The other overlying features, roads, rails, and pipelines can be subsided if the proper mitigating work is complete. These areas are indicated on the maps by the blue ‘subsidence mitigation required’ hatching.

High extraction mining or solution recovery of mine pillars results in subsidence at the surface by increasing the seam extraction ratio. Subsidence is typically estimated by a “cone of influence or draw” between 45 to 50 degrees upward from the impacted area the mine. At Sisecam Wyoming, this equates to an area at the surface of two-times the depth plus the area of the mine where high extraction mining is conducted. For example, a mine panel that is 1,000-feet wide at a depth of 1,000-feet has the potential of subsiding a width of 3,000-feet at the surface.

Sisecam has no plans to change its non-subsidence mining plans. Figure 12.3 and Figure 12.4 illustrate the complexity of the non-subsidence zones over the Big Island Mine.

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Figure 12.3 Non-Subsidence Areas – Lower Bed 24

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Figure 12.4 Non-Subsidence Areas – Upper Bed 25

Note: Reserve areas and mine workings not updated.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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13.0 MINING METHOD

Mining extraction at the Big Island Mine is designed to avoid any surface subsidence due to its proximity to the Green River and multiple natural gas pipelines (see Section 12.4.1 Non-Subsidence Areas).

Conventional mining equipment (drill and blast) was used at the Big Island Mine until the mid-1980’s, when continuous miners fully replaced that method of ore production. A total of 59.2 MST was recovered conventionally at a 42% to 45% areal extraction rate. Undercutters were used to ‘top-cut’ the trona seam prior to drilling and blasting. This equipment limited the mining height and tended to leave one to two feet of roof trona, resulting in a volumetric extraction of 35% to 40%. Including barrier pillars between panels, historic conventional extraction averaged in the low 30% range.

The change to continuous miner (CM) panel layouts increased entry widths from 22-feet to 30-feet, and areal extraction increased to an average of 56% with some CM panel extraction rates as high as 68%. Volumetric extraction also increased, as the continuous miners could mine up to 13.5-feet high. It is common for the continuous miners to mine the full seam height leaving little, if any, top or bottom trona. Given full seam height extraction, and with barrier pillars, the historic continuous miner volumetric extraction ranges between 45% and 55%.

The current CM fleet is made up of seven Joy 12HM26 drum miners with integral roof bolting and ventilation fans. These are highly productive machines due to their ability to mine and roof bolt simultaneously. The height of the roof bolters and fan limit the current minimum mining height to 9-feet. When thinner seam areas are encountered, floor or roof rock must be mined for clearance. This out-of-seam material adversely affects the refining process. To maintain feed grade, the current minimum mining limit is 9-feet. For this study, future mining of seam areas below 9-feet is assumed to utilize smaller continuous miners.

13.1	TWO SEAM MINING

Since 2017 Sisecam has completed an extensive study of the interburden between Beds 24 and 25 to characterize the extent and magnitude of the trapped gases that have impacted LB two-seam mining. In the last year Sisecam has made a concerted effort to develop Mains Entries and Panel neck-offs so that additional test mining can be completed to better prove the proposed two-seam mining geometries. In 2021 Sisecam extracted a total of 585,871 tons from this area, 13.7% of all production. Sisecam expects to start the first panel mining in this area in early 2022. This mining experience will be necessary to fully understand the impact and mitigations for these gases and confirm the proposed two-seam mining methods. Based on this progress it will be four to six years before Sisecam is able to fully demonstrate the viability of two-seam mining with the current mining equipment.

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For the purposes of this study, it has been assumed that future two-seam mining will use current CM mining methods and panel geometries with the upper bed mined prior to the lower bed being mined. Due to interaction of the mining stresses created by mining both beds, additional roof support (roof bolts) throughout the two-seam mining area of Bed 24 will be required. Sisecam recently completed a study of the inter-seam gas pressures between Beds 24 and 25. This study concluded that the gas pressures are higher than previously assumed, will require closer spaced de-gas drill holes during mining, and might require narrower entries. The de-gas drill holes primarily impact productivity. Narrower entries will impact the LB extraction and the recoverable reserves. Given that two-seam mining, in the context of this report is unverified, and the lack of a defined mining layout different than what has been proposed, no changes have been made to the two-seam area extraction. If a change to the proposed layout is made, recoverable reserves estimates must be revised to reflect those changes.

To date, Sisecam Wyoming has not completed two-seam mining with continuous miner panels below existing historic Upper Bed continuous miner panels. For this reason, two-seam mining using continuous miners and existing geometries is considered unverified. To account for this risk, higher mining costs have been used in the economic analysis and the affect is discussed in Section 19.0. Given the work completed, the existing test panels, and the cost structure at Sisecam Wyoming, it is reasonable to conclude that these areas can be economically mined and therefore are considered reserves in this study.

Approximately 118 MST of Bed 24 recoverable reserves are located in projected two-seam mining areas. Test mining of two-seam panel mining is projected to start the first quarter of 2022. The earlier that two-seam mining at the Big Island Mine can be technically and economically demonstrated, the earlier a long-term mine plan can be developed with confidence. It is possible that two-seam mining may require significant variations from current mining equipment and practices. This is dependent upon many factors that impact the long-term mine planning process.

13.2	RESERVE ACCESS

The Big Island Mine is regulated by the Mine Safety and Health Administration (“MSHA”) as a metal and non-metal mine. For the purposes of this analysis, it is assumed that MSHA will continue to allow Sisecam Wyoming to mine for the LOM under the metal and non-metal rules.

Four existing surface to ore bed shafts are used to access the trona reserves of Beds 24 and 25. All four shafts terminate below Bed 24, are fully concrete lined, and none have stations in Bed 25. Shaft #1 and Shaft #2 are the original shafts and were installed in 1961. Shaft #1 contains a service hoist for man and material access, is 16-feet in diameter and is used as an intake airway. Shaft #2 is 20-feet in diameter, has a concrete divider wall, and one-half is used as an intake airway while the other half contains a production hoist with 10-ton skips. Shaft #2 has newly installed direct fire natural gas heaters for the intake air. Shaft #3 was constructed in 1981, is 20-feet in diameter, and has a divider wall with half the shaft used as in intake airway heated by steam. The other half contains a production hoist with 10-tons skips. Hoisting capacity is approximately 1,000 tons per hour with the existing systems. The recently completed, 20-foot diameter, Shaft #4 is the main return airway with two 12-ft diameter ventilation fans. The other three shafts provide intake air. Shaft #4 does not have a conveyance but does have a repair deck that can be lifted by a crane.

For the purpose of this estimate, HPG has assumed Sisecam Wyoming will maintain the shafts and hoists for the LOM.

Sisecam is currently in the process of permitting/constructing a new production shaft, Shaft #5, to access the trona reserves of Beds 24 and 25. The production shaft will be installed with plans to increase mine production to feed the proposed Unit 8 Processing Facility. The locations of the new and proposed shafts and necessary barrier pillars have been considered for this estimate.

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The deposit is accessed from the shafts through existing and new mine entries. Ore transport from the mining face is by belt conveyors to the hoists at the shaft locations. For the purposes of this study, HPG assumed Sisecam Wyoming will continue to advance and maintain all infrastructure needed to access the ore for the LOM.

The Big Island mine is considered a gassy mine because it produces methane gas. The mine is currently ventilated by two newly installed Spendrup 12-ft diameter ventilation fans. Only one fan is needed for operations with the second a full operational spare. Ventilation is approximately 725,000 cubic feet per minute (CFM) of air. Each fan can be upgraded from 1,500 hp to 3,000 hp which would allow airflow to be increased to 1,300,000 CFM which is considered more than adequate for the long-term needs of the mine.

In general, long-term mine roof conditions are excellent. Most of the old workings can still be accessed. Panels mined in the 1960s are still accessible.

13.2.1 ****	Inaccessible Areas

Areas that cannot be accessed are the TRM panels and the LB West Mains and Panel areas.

TRM panels are not accessible, they have been filled with the paste tailings from the refining process and are in the center of the deposit near the shafts.

The LB West Mains area west of X-Cut 223W are inaccessible due to roof falls across the mains that occurred in 2019. This area was mined in late 1990s and early 2000s with the last panel mined in 2005. During mining the panels to the north and south of the LB Mains encountered multiple roof falls and required secondary roof support. Roof falls in these panels have continued and recently increased in magnitude. On July 1^st^ and 2^nd^ 2016, two seismic events of magnitude 3.4 and 3.2 occurred with an epicenter in the vicinity of the Granger solution mine approximately 9-miles to the West of the Big Island Mine (BIM). Concurrent with these events the BIM experienced an air blast along the West Mains past X-Cut 152W blowing down 26 stoppings along with an increase in methane emissions. The USGS did not record any seismic activity in the vicinity of the BIM at this time. The likely cause of the air blast was roof falls in the panels adjacent to these mains. The location of these falls is not known due to lack of access in these old panels. Examination of the mains during this time indicated that they were stable. Additional roof falls likely occurred in these panels as indicated by methane spikes in November 2016, December 2016, June 2017, and February 2018. None of these methane spikes were associated with damage to any ventilation structures.

In February 2017, the area was examined. Ground conditions along the West Mains were considered to be deteriorating, but stable and no water was observed. In early 2018 examinations of the West Mains discovered ponding water covering most of the Lower Bed West workings below the 5310 MSL elevation. Figure 13.1 shows the extent of the flooded area. Chemical analysis of the water indicated that the source was not the Tailing Return to the mine water. Further analysis using radio isotopes indicated the age of the water as pre-nuclear age or fossil water older than 1952. The hydrologist concluded that the source is likely a sandstone unit 50 to 75-feet above Bed 25 that is a known low permeability aquifer and not directly the result of leakage from the Green River.

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On February 22, 2019, the USGS recorded multiple seismic events with the epicenters in the mining panels north and south of the LB West mains west of X-Cut 219W. These events resulted in additional damage to ventilation structures in the area as well as a significant spike in methane emissions high enough to warrant shutting down the mine for six days until methane outgassing decreased to safe levels. Standing supports were placed in the LB West Mains at X-Cut 221W to create a break line if the mains became unstable. Monitoring of the area continued, and the water continued to subside. On April 5, 2019, the LB West Mains west of X-Cut 223W fell and caved tight between the floor and roof across the entire set of main entries.

Ground conditions in this area were considered problematic so Sisecam has established a new long-term pumping station located in the Lower Bed Southwest #2 Butts-X-Cut 60 S. Water from the area is pumped into the adjacent TRM sumps and then pumped out of the mine. Current pumping capacity at this location is approximately 200 gpm with the current long term average flow of approximately 85 gpm and 55 million gallons have been pumped since October of 2020.

Access to remaining LB West reserves west of the existing workings using the LB West Mains is now not possible without extraordinary effort. This reserve area could be accessed from the LB North Butts by driving mains to the west as shown in the proposed LOM plan accessing the LB Northwest reserve block. Panels could be developed from this new set of mains to the south to access these reserves. There are several risks associated with this area:

●	These new panels would be down dip, lower in elevation, than the flooded areas. Mining down dip from flooded workings increases risk;
●	The ore in this area has a modulus of elasticity that is half other areas of the BIM. Mining conditions similar to historic panels are likely and will require additional roof support; and
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●	The historic mined area continues to have roof falls as evidenced by 2019 seismic activity.
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HPG does not consider this area to be minable and has removed it from the recoverable trona estimate due to the risks associated with seismicity, water inflow and soft ore. Removal of this area decreased recoverable trona by approximately 10.2 MST.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Figure 13.1 Lower Bed 24 Flooded Area

Source: 20220125 Subsidence Potential of Lower Bed West Section at Big Island Mine - RMC Final with Appendix.pdf (after Straub, 2021)

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13.2.2 ****	Mining Limit
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The assumed 7-foot mining limit and 85% grade limit were selected based on the mining limit that has been successfully employed by the other basin trona mines.

Given the current minimum mining height limit of 9-feet and a reserve limit of 7-feet, there are areas outside the existing mining that are considered reserves but have not been mined based on these limits. In areas where the existing mining limit of 9-feet did not reach to the 7-foot isopach, it has been assumed that future access to these reserves would be through old workings or from newly driven development entries (see Life of Mine Plan Figure 12.1, Figure 12.2 and Section 12.1). For this study, these reserve remnants have been evaluated based on size and access to decide future extraction. Where the remnant was deemed too small or access too expensive, the remnant was excluded from the reserve estimate. As future mining continues, with the current large mining equipment, some loss of portions of the edge of the ore bodies will occur, especially when long production panels are developed. The length of recent production panels, greater than 10,000-feet long, likely precludes rehabilitation in the future to access reserves between the 9-foot and 7-foot isopachs. This estimate assumes that access to the UB Southeast Reserve block will be bypassed in this way, Figure 12.1. For the purposes of this study, these areas were considered on a case-by-case basis assuming Sisecam’s typical mining methods and current cost structure.

A two-stage mine plan has been developed. The first stage “high-grades” the deposit based upon the current mining equipment and processing plant limitations mining to the 9-foot isopach. The second stage mining is based upon smaller mining equipment and assumes changes to the dissolver sections of the processing plants. The second stage mines the material between the 9-foot and 7-foot isopachs.

The mining limit, ore thickness and grade, is an economic one. Mining thinner material will be less productive and costlier. Mining costs of reserves between 9-feet and 7-feet thick could increase by 50% to 75%, making the economics of these reserves sensitive to variations in soda ash price. Approximately 148.2 MST of the recoverable reserves average greater than 9.0-feet in thickness while 71.8 MST are less than 9.0-feet thick.

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14.0 PROCESSING AND RECOVERY METHODS

14.1	INTRODUCTION

Sisecam utilizes the monohydrate process to convert raw trona into soda ash in five (5) processing plants. The plants are well established and have a long production history which is illustrated in Table 14.1 below. Unit 6 is an integrated stand-alone plant constructed in 1998 and Unit 7 is a large calcining dissolver constructed in 2006 to feed liquor to Units 3 through 5. All the plants have had significant upgrades over the years to both improve recovery, energy efficiency, and increase soda ash production.

The primary feedstock to these plants is raw mined trona with a minor secondary feed from liquor produced from mining the DECA crystals, sodium carbonate decahydrate, from the evaporation ponds of the tailing disposal areas. The DECA crystals are mined using tracked backhoes, dewatered, and dissolved into liquor for feed into the dissolver circuit.

For operational flexibility and to improve efficiencies there are multiple lines, ties, between the plants to optimize the liquor produced by the dissolver sections. Excess liquor from Unit 6 can be shared with Units 3 through 5 and similarly excess liquor from Unit 7 can be shared with Unit 6.

14.2	MONOHYDRATE PROCESS

Figure 14.2 is a simplified process flow diagram of the monohydrate (Mono) process operated at Sisecam. The Mono process starts with screening and crushing the trona feed to minus 3/8” which is then calcined in a gas fired rotary kiln at approximately 150-200 degrees Celsius converting the raw trona into crude soda ash and insoluble material (shale and marlstones). The conversion of trona (sodium sesquicarbonate) to sodium carbonate improves the dissolution in water so that the insoluble material can be removed by gravity separation using spiral classifiers and counter current thickeners. The overflow liquor from the thickeners is put through multiple stages of filtration to remove insoluble material.

The sodium carbonate is recrystallized from the filtered liquor in forced circulation evaporators heated by mechanical vapor recompression (MVRs). The crystalized dense soda ash is dewatered using pusher centrifuges and dried in gas fired rotary driers, screened, and sent to storage for shipping by truck or rail.

The underflow from the classifiers and thickeners is sent to the TRM paste plant where it is ground and dewatered using deep cone thickeners and pumped as a paste via positive displacement pumps underground into the old mine workings or on the surface into the tailings pond system.

14.3	SODA ASH PROCESSING FACILITIES

Sisecam currently has two ore calcining and dissolving units with four soda ash processing plants. The first two processing plants, Unit 1 and Unit 2 built in 1962 used triple effect evaporators were taken out of service after being replaced by the integrated Unit 6 plant. Unit 7 calciner and dissolving unit was constructed to replace the front ends for Units 3, 4, and 5. The dissolver units liquor output is interconnected to the multiple evaporator units. Figure 14.1 illustrates the relationships between the units and Figure 14.2 shows a simplified process flow diagram from the mine to the product silos.

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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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Figure 14.1 Sisecam Processing Facilities

As discussed earlier the Big Island Refinery has a consistent and long production history that is shown in Table 14.1 below.

Table 14**.**1

Sisecam Historical Production

Short Tons
	Trona Ore	Soda Ash
2011	3,676,000	2,308,300
2012	3,865,400	2,455,500
2013	3,921,500	2,492,200
2014	3,869,500	2,548,300
2015	4,040,300	2,655,400
2016	4,050,400	2,735,700
2017	4,001,325	2,705,400
2018	4,018,329	2,613,200
2019	4,157,009	2,759,100
2020	3,653,830	2,221,900
2021	4,276,837	2,682,203

The details of the existing processing facilities are described in more detail below.

14.3.1 ****	Ore Crushers

Mined ore is crushed in two separate areas. The first is a crusher and screening building upgraded in 1980 that supplies crushed ore to Unit 7 that is then fed to Units 3 through 5. This area has two closed loop crushers. The second is a dedicated single closed loop crusher that was built with Unit 6 and only supplies ore to that unit.

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14.3.2 ****	Unit 7
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Unit 7 was constructed in 2006 as an alternative energy project to update the dissolver sections of Units 3 through 5. Unit 7 consists of a large rotary calciner, Verti-mill grinder, and classifiers that supply liquor to Units 3 through 5. Originally the rotary calciner could be dual fired by coal or natural gas. The coal burner had low NOx emissions and was BACT at the time of construction. The unit was converted to only natural gas firing in November of 2010 due to economics and ability to increase production on gas.

14.3.3 ****	Unit 3 and 4

Units 3 and 4 were constructed in 1967 and 1972, respectively. Both originally used triple effect evaporators with steam from gas fired boilers in the powerhouse and had their own dedicated calciners and dissolvers. In the 1980’s Rhone-Poulenc converted the evaporators to MVRs. Unit 3 has two MVRs for the three evaporator bodies. Unit 4 uses two MVRs in series to drive the first two evaporator bodies (System 1) and two smaller MVR’s to drive the third evaporator body (System 2). In 2006 Unit 7 replaced the calciners and dissolver sections. Unit 3 has the ability to produce 450 KTPY of soda ash and Unit 4 can produce 750 KTPY.

14.3.4 ****	Unit 5

Rhone-Poulenc expanded soda ash production between 1977 and 1980 adding an additional mine production Shaft #3, upgrading the crushing facilities, automating the surface ore stockpile, and constructing the fifth soda ash plant. Unit 5 has one large evaporator body with two heat exchangers driven by one large MVR compressor. Unit 5 is capable of producing 500 KTPY. Unit 5’s calciner and dissolver sections were replaced by Unit 7 in 2006.

14.3.5 ****	Unit 6

OCI Chemical expanded soda production in 1998 with the construction of Unit 6 a standalone integrated plant with crushing, calcining, dissolving, filtering, crystalizing, thickeners, and tailings pumps. Current annual production from Unit 6 is about 1,000,000 TPY. Unit 6 consists of two large MVR evaporator bodies with two heat exchanges for each.

Unit 6 Tailing TRM is made up a dedicated rod mill crusher, deep cone thickener, high pressure positive displacement pumps and a dedicated borehole to the mine where a pipeline transports the paste to the underground TRM storage panels.

14.3.6 ****	Tailings Return to the Mine Plant

The TRM Plant was constructed concurrently with the Unit 6 expansion. Commissioned in 1995, TRM processes the tailings from Units 3 through 5 and produces a thickened paste that is pumped into the old mine workings or to the surface tailings pond facility, where it is dewatered for permanent storage. Originally TRM had its own rod mill grinder and wet screens to produce paste. The Unit 7 Verti-mill has replaced that grinder and TRM now only consists of the deep cone thickener, high-pressure positive displacement pumps, a borehole into the mine and high-pressure piping to the underground storage panels or to the surface tailings pond facility. More information on tailings disposal is available in Section 17.4.

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Figure 14.2 Sisecam Wyoming Simplified Process Flow Diagram

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14.4	DECA MINING AND PROCESSING
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DECA mining was started in 2009 by harvesting the DECA crystals from the evaporative areas of the tailings ponds. DECA precipitates during the fall and winter when temperatures drop. DECA crystallization is an exclusionary process that results in a relatively pure sodium carbonate crystal leaving behind impurities of bicarbonates, chlorides, and sulfides. During the long 50-year history of Sisecam’s tailings disposal facilities using Pond 1 and Pond 4 for evaporation, many feet of DECA was deposited. To harvest the DECA Sisecam has utilized Ponds 1, 3, and 4 for evaporation and water storage. Water is pumped between the ponds allowing selected areas to be dewatered to harvest the DECA crystals. DECA mining occurs in the late winter when the pond area is relatively frozen allowing mining with conventional tracked backhoes and rough terrain haul trucks. The DECA is dewatered and hauled to a 1.8-million-ton stockpile next to the DECA processing plant. DECA is stockpiled during the winter and fed into the plant from the stockpile throughout the year. The DECA processing uses a pick breaker feeder to feed a heated and agitated melt tank. The resulting liquor is feed back into the process in the dissolver sections at the thickeners. Approximately 1.2 MTPY of DECA is harvested producing approximately 300-400 KTPY soda ash.

Based on the remaining amount of DECA in the ponds and future anticipated DECA precipitation, the DECA mining is anticipated to end in late September of 2024. To maintain the current soda ash production rates this feed stock will need to be replaced by trona or another sodium source.

14.5	EXPANSION PLANS

Sisecam Wyoming has announced several plans to expand the facilities production capabilities. The largest is construction of an additional processing plant (Unit 8) and an additional production shaft (Shaft #5). Unit 8 is planned to be an integrated plant, similar to Unit 6, with crushing, calcining, dissolving, filtration, evaporation and drying. Shaft #5 will be serviced by two hoists: one for mine production and the other for men and materials. Sisecam has received regulatory approval for construction of Unit 8, including the Air Quality (New Source Review Construction Permit), Land Quality Permit, Bureau of Land Management On-Lease Action Approval, and Industrial Siting Permit. Due to business uncertainties including COVID-19, the Unit 8 capital expansion is shown outside the 5-year capital budget. Because the operation is considered profitable as-is and given the uncertainties, these expansions were not considered for the economic analysis for this reserve estimate.

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15.0 INFRASTRUCTURE

15.1	INTRODUCTION

Sisecam Wyoming’s mine and refinery are located 23 miles northwest of the town of Green River, Wyoming. Sisecam Wyoming accessible from Interstate 80 west from Green River then north on La Barge Road, Wyoming Highway 37, to the OCI road, 254 County Road 4.

The Sisecam site is serviced by a dedicated railroad spur line off the main East West Union Pacific rail line. The dedicated railroad spur line connects to the Union Pacific Main line just east of the Genesis Westvaco facilities.

The site infrastructure has been developed over the plus 60 years of operation, is established and is adequate for the purposes of producing soda ash. While the infrastructure is showing its age, Sisecam has demonstrated the willingness to update those areas as necessary. Examples of this are the ongoing update of the electrical mechanical control centers (MCC’s), the addition of Shaft #4 with new ventilation fans, the electrical updates of the shaft hoisting systems, the new office change house building, as well as many improvements to the processing facilities.

The Sisecam site road access and rail access can be seen in Figure 15.1. An aerial view of the site indicating major infrastructure is shown in Figure 15.2.

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Figure 15.1 Sisecam Site Access and Rail Infrastructure

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Figure 15.2 Sisecam Site Infrastructure Aerial View

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15.2	OFFICES, WAREHOUSES
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Sisecam has sufficient office and warehouse facilities. There are multiple buildings for offices, change houses, laboratories, control rooms, maintenance shops, safety offices, machine shops and warehouses. Where necessary, for large equipment and motor spares, Sisecam uses vendors offsite warehouses. In 2020 Sisecam completed the construction of a new office and change house facility to eventually replace the 1960’s building.

In the mine there are underground offices, underground shops, and an underground warehouse all dedicated to the mine operations.

15.3	MINE

Sisecam is currently operating six trona mining sections, with each made up of a Joy 12HM26 drum miner, two Joy shuttle cars and a feeder breaker. The mine maintains spare production equipment including a spare CM used for utility or to allow major rebuilds, two spare shuttle cars and a spare feeder breaker. Ore is transported from the working faces by 42” belt conveyors which discharge to 48” mainline conveyors. The mine has over 10 miles of conveyor structure and belting installed and has ample spares.

Underground trona ore storage is limited to approximately 700 tons of capacity between the mine and the hoisting systems. This limited surge capacity does impact overall hoisting efficiencies and production capabilities.

Mine ore is crushed underground in the UG Crushing Facilities which includes two McManaman dual roll crushers.

The mine has four surface to ore bed shafts used for access and ventilation. Shafts #1 and #2 were developed in 1961 with a common hoist house containing the mechanical hoists. Shaft #3 was constructed in 1981 as a production and ventilation shaft. Shaft #3 has a dedicated hoist house (Hoist House #2) and double drum hoist. Shaft #4 was completed in 2021, as a dedicated ventilation shaft. The shafts are inspected weekly and are repaired as required.

Shaft #1 is 16-feet in diameter and serves as the man and material shaft. Shaft #1 is serviced by a 1970’s Vulcan Iron Works Hoist that has been upgraded over the years with updated braking systems and electrics but is nearing its mechanical life and will likely need replacement within 5-years. Shaft #1 is an intake air shaft with steam heaters.

Shaft #2 is 20-feet in diameter and used as a ventilation and production shaft. With the addition of Shaft #4, Shaft #2 has been converted from the main exhaust ventilation shaft to an intake and production. The shaft is now heated by direct fire natural gas burners. Shaft #2 is serviced by a 1961 Nordberg double drum hoist with dual 500 HP DC motors driven by ABB converters. Over the years this hoist has been upgraded with new braking systems, new ring gear and pinions, and control systems. The hoist has 10-ton balanced production skips with the capability of lifting 500 tons per hour of ROM trona.

The #3 Shaft was constructed in 1981 as a ventilation and production shaft. It is 20-feet in diameter and heated by steam heaters. The shaft is serviced by a 1961 Nordberg double drum hoist with recently installed dual 500 HP AC VFD motors driven by ABB controls. Over the years this hoist has been upgraded with new braking systems, motors, and controls. The hoist has 10-ton balanced production skips with the capability of lifting 500 tons per hour of ROM trona.

Shaft #4 is 20 feet in diameter with two parallel 12-foot diameter Spendrup fans driven by 1,500 hp direct drive motors that can be upgraded in the future to 3,000 hp. Only one fan is required to ventilate the mine with the second being a spare. Each fan has a peak capacity of 1,300,000 CFM (cubic feet per minute) of air but are currently being operated at 725,000 CFM which is all the mine currently requires. The additional capacity allows for future production increases.

Project 01-21-001	104	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
15.4	STORAGE
---	---

Sisecam has a 100,000-ton covered and automated trona ore stockpile that is used for ore storage between the mine and processing facilities. This system is filled with ROM or screened trona via a belt conveyor tripper and reclaimed by a Thyssenkrupp drag reclaimer. The stockpile has a working storage capacity of less than 40,000 tons which is not adequate to separate mine production from the processing feed. This does impact overall hoisting efficiencies and production capabilities.

As stated earlier there is a 1.8-million-ton DECA stockpile between the Pond #1 stacking area and the Pond #1 evaporation pond.

Finished soda ash is stored in seven vertical storage silos totaling 27,300 tons, which is considered adequate for the current production rates.

15.5	PRODUCT SHIPPING & LOADING

Finished dense soda ash is shipped in bulk by rail and truck with a smaller portion bagged and shipped by truck. There are dedicated rail and truck loadouts with scales and a warehouse with bagging lines and storage for supper sacks or 50-pound bags. Union Pacific is now requiring more of Sisecam’s soda ash cars to be shipped via unit trains constructed in the site railyard or at the Big Island rail yard.

Union Pacific is the rail service, but cars can be transferred to other carriers when necessary. There is a small portion of product that is transported by tandem pneumatic trucks from Sisecam to Bonneville, Wyoming where the produce is transloaded from truck to the BNSF Railway.

Sisecam has a dedicated rail car fleet. Sisecam does not own any rail cars but leases approximately 2300 cars. Sisecam plans to add approximately 20 cars to its rail fleet in 2022.

15.5.1 ****	Rail Yards

To accommodate assembly of unit trains Sisecam utilizes a contract railyard along the La Barge Road (Highway 372) which is privately owned and maintained by others. There are up to five track lines at the facility to assist with switching empty and loaded cars and prepping them for shipment offsite. There is an estimated 18,400-feet of track owned by the Big Island Mine and Refinery

15.6	TAILINGS FACILITIES

Process tailings disposal, made up of shales, mudstones, and process purge, is split between underground mine workings and surface. Underground disposal is placed as thickened slurry into old lower bed mined out panels. Surface disposal is placed as thickened slurry into a series of tailings ponds that have been maintained over the life of the facility. For the past few years, Unit 6 tailings have been pumped underground and Units 3 through 5 have been pumped to the surface tailings storage. This is about a one-third to two-third split with the majority of the tailings being place on the surface in the tailings basin.

Project 01-21-001	105	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

The Sisecam surface tailings facilities are shown in Figure 15.3. The tailings basin facilities have multiple dams and internal dikes. A dam safety review is done annually by a third-party engineering firm. For the purposes of this review HPG has examined three years of the annual Dam Safety Reports completed by Barr Engineering. Barr Engineering has been doing the design work at these reviews at Sisecam for over 30 years. Barr has recommended an updated dam break analysis to determine downstream impacts of a dam failure. This work is reported to be in progress.

Surface tailings disposal is currently placed in the Pond 1 Stacker and Upper Delta area where it is allowed to dewater into the Pond 1 evaporation DECA recovery area. Ponds 3 and 4 are used for evaporation and water management to allow for DECA mining.

The recently completed Pond 2, which is a lined tailings pond, was constructed in 2014-2015 has had minimal use to date. Capital plans call for the geomembrane liner to be expanded in 2022 and tailings disposal to begin in the lined portions of Pond 2. Pond 2 has a predicted life of over 20-years based on mine disposal of 30-40%.

Based on the current surface tailings basin life of over 20 years and available alternative disposal areas and methods, this study assumes that Sisecam Wyoming will maintain adequate tailings disposal storage for the life of the reserves.

Additional information on the surface tailings facilities is available in Section 17.4

Project 01-21-001	106	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Source: Sisecam-2020_Dam-Safety-Report_20210224.pdf (Barr Engineering)

Figure 15.3 Aerial View Tailings Facilities

15.7	UTILITIES

The energy sources and utilities for the Sisecam site include natural gas, electricity, steam, and raw water. Natural gas is used for steam generation, electrical generation, and process heating. Electricity is purchased from Rocky Mountain Power (RMP) and generated with a Co-Gen gas turbine and a backpressure steam turbine. Steam is produced from gas fired boilers and the Co-Gen plant. Water is pumped from the Green River, which crosses the lease area.

15.7.1 ****	Electrical

The site electrical demand is approximately 60-62 megawatts (MW). The primary electrical source is provided by RMP via the RMP Raven Substation located on La Barge Road. The substation is fed by two 230 kV independent high voltage lines that are switched to two independent 34.5 kV power lines to the Sisecam site main MCC. This MCC has an additional 34.5 kV independent feed line.

Sisecam also has in-house co-generation. The oldest is a 12.0 MW backpressure steam turbine driven by either the three conventional gas boilers (H03, H04 & H05) or excess steam from the Co-Gen Plant. The second electrical generation source is a recently commissioned combined cycle gas turbine. The Co-Gen facility produces up to 25 MW of electricity and steam for generation and process use.

Project 01-21-001	107	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
15.7.2 ****	Natural Gas
---	---

Natural gas is supplied to Sisecam by Midstream-Ottco through a supply line with a capacity of approximately 50,000MMBTU/day to the slug catcher with current required usage around half of available supply. From the slug catcher there are two natural gas pipelines. One pipeline feeds the processing plants and powerhouse and the second pipeline services the Co-Gen Plant. The capacity of the original pipeline was sized for when the processing plants were triple effect steam evaporators. Conversion to electrically driven MVR’s has reduced the process plant demand, resulting in the main natural gas pipeline being oversized for the current facility. The Co-Gen line was designed for multiple processing units and has capacity for the Co-Gen plant, as well as an additional similarly sized unit.

15.7.3 ****	Steam

Steam is produced by three natural gas heated boilers and the newly constructed Co-Gen gas turbine. The original powerhouse has been in service since 1961 but has had multiple upgrades over the years and is still a viable powerhouse for the foreseeable future. The Co-Gen plant uses a heat recovery steam generator (HRSG) heated by the gas turbine to produce steam that drives the associated backpressure turbine and generator for the combined cycle. The boilers produce 600-pound steam that is lowered via let down stations or backpressure generators to either 150-pound or 35-pound steam for boiler superheaters, processing, and heating.

15.7.4 ****	Water

Raw water for the site is pumped from the Green River filtered for use in the process or treated to potable water standards for internal and sanitary use. Sisecam has adjudicated water rights equal to 7.756 MM (7756K) gallons per day (12.0 cfs) under State Engineer’s Office of Wyoming Permit No. P22075D. These rights are more than adequate for the site needs. The average water withdrawal between 2018 and 2021 averaged 67.52 MM gallons per month or 2,220 MM gallons per day.

Process water, tailings decant water and steam condensate water are recycled to minimize water usage.

Water for domestic and sanitary use is processed using carbon/sand filters, mixed media pressure filters, and chlorinated to the same standards as municipal water systems. The water is sampled and tested according to municipal water standards regulated by the Environmental Protection Agency. Sisecam has had deviations to these standards of a total organic carbon running annual average (RAA) ratio below 1.00 during the periods from October 2019 through September 2020, and January 2020 through December 2020, and April 2020 through March 2021. Sisecam received a notice of violation and an administrative order on August 6, 2021, from the EPA. Sisecam made modification and repairs to the systems and reported on August 23, 2021, that the systems were in compliance and that test showed a steady increase in the TOC ratio through the second quarter of 2021. There have not been any deviations since.

Project 01-21-001	108	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

16.0 MARKET STUDIES

As stated earlier, the economic viability of these reserves is based upon the long profitable history of the Big Island Mine and Refinery producing and selling soda ash. Sisecam has an extensive history of consistent sales with an established customer base, logistics and marketing. Sisecam has multiple contracts for soda ash sales both short and long term.

HPG concludes that this history along with the five years of historical sales provided is a reliable basis for the assumption that the future weighted average net sales per short ton will remain consistent with Sisecam Wyoming’s average net sales for the five years ended December 31, 2021.

As part of this evaluation HPG reviewed confidential marketing studies provided by Sisecam. These studies indicate a steady rising price over the next 10-years. Price fluctuations are forecast based on expected additional new production and/or shutdowns of synthetic plants, but the overall trend is a steady increase in price. For the purposes of this estimate a constant soda ash price of $188/ton was assumed.

HPG offers the following remarks that support the above conclusions:

●	As a basic industrial mineral, soda ash demand has historically increased 2-3% per year. The rapid increase in industrialization in emerging economies of China, India, Thailand, and Indonesia are expected to continue to drive this demand for the foreseeable future;
●	Green River’s naturally produced soda ash has a historic cost advantage over synthetically produced soda ash as illustrated by the long history of the Green River Basin production being exported successfully throughout the world to countries with local synthetic soda ash production (i.e., China, Mid-East, and Europe);
---	---
●	The high cost and environmentally undesirable synthetic soda ash plants will continue be under pressure by the naturally produced ash and will continue to shut down over time;
---	---
●	Sisecam’s international ties through its holding company We Soda are part of a global conglomerate that controls over 7.5 million tons of soda ash production from Turkey and the US reflecting a strong market presence; and
---	---
●	Sisecam’s new majority owner, Sisecam, is an end user. As one of the largest glass producers in the world Sisecam is creating a vertically controlled supply chain from raw soda ash to finished glass.
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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

17.0 ENVIRONMENTAL STUDIES, PERMITTING, AND PLANS, NEGOTIATIONS OR AGREEMENTS WITH LOCAL INDIVIDUALS OR GROUPS

17.1	ENVIRONMENTAL STUDIES

Sisecam Wyoming operates a facility located approximately 23 miles north of the City of Green River in Sweetwater County. The facility includes the processing and refinement of Trona ore into Soda Ash, an underground mine (Big Island Mine), ore hoist, mine fans, surface tailings disposal ponds, evaporation ponds, sewer ponds, site containment ponds, and administration and supporting structures.

Access to Sisecam Wyoming is by County Highway 6 from Wyoming Highway 372 and County Highway 4. Union Pacific Railroad provides a rail spur to transport product. Adjoining this spur is a rail holding yard adjacent to WY 372.

Sisecam has maintained current permitting requirements. The most recent Environmental Analysis studies include:

●	Tailings Pond 2 rehabilitation and expansion;
●	Refinery Unit 8 proposed construction;
---	---
●	Refinery Cogen and pipeline for electrical energy production; and
---	---
●	Trona lease expansion for Section 34, Township 20 North, Range 109 West.
---	---
17.2	CLIMATE
---	---

The Sisecam Wyoming facilities are located in the Green River drainage of the upper Colorado River system. Situated in a high intermountain basin bounded by the Wyoming Range to the West, Uinta Mountains to the south and the Wind River Range to the northeast, mean elevation exceeds 6,000-feet. Climate is dry, cold-temperate-boreal and characterized by limited rainfall (less than 8 inches) with long, cold, dry winters and warm-hot, summers with occasional storm producing flash floods. Evaporation exceeds 36 inches resulting in little excess water, limiting the majority of vegetation to the Green River flood plain. Wind generally blows from a southwesterly direction.

17.2.1 ****	Temperature and Precipitation

Climate is classified as semi-arid with little rainfall. The average annual precipitation measured at the monitoring station located in Farson, Wyoming, near this facility is 7.83 inches. Data from 1991 through 2020 show precipitation peaks during May through July, with the heaviest snow months occurring in November into March. The region has relatively cool temperatures. The average annual temperature at the facility is 37.8 degrees F, with average extremes ranging from -4^◦^F to 82^◦^F. On the average, the hottest day occurs in July and August, the coldest in January and February, and the frost-free season lasts approximately 3 to 4 months.

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		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
17.2.2 ****	Winds
---	---

The Green River basin is subject to strong and gusty winds. During the winter months, strong winds are often accompanied by snow, which produces blizzard conditions and drifting snow.

The frequency and strength of windy conditions greatly affects dispersion and transport of pollutants in the region. Winds from the west and southwest account for 37 percent of the total winds in the area. Prevailing westerly winds are fairly consistent throughout the year. Low humidity and constant wind, accelerates evaporation. Evaporation at times is five times greater than precipitation.

17.3	HYDROLOGY
17.3.1 ****	Surface Water
---	---

The Green River, a tributary of the Colorado River, flows through the Sisecam Wyoming lease area and is located immediately west of the facilities. Dry peripheral gullies and washes flow through the lease are into the Green River. The intermitted flow regime is mainly the result of snowmelt or high intensity short duration storm events in the summer and are Class 4 surface waters because of hydrologic or natural water quality conditions do not have the potential to support fish (WDEQ 1997). The Green River is under the jurisdiction of the U.S. Army Corps of Engineers (USACE) and the State Engineer’s Office of Wyoming.

Surface water monitoring, Green River, is performed in accordance with the approved monitoring plan. Sisecam is a non-discharge facility.

17.3.2 ****	Groundwater

Regional groundwater is characterized by shallow and deep resources. An alluvial zone composed of unconsolidated sand and gravel range in depths to 50-feet is associated with the Green River flood plain. Immediately below the alluvium are consolidated sediments of the Bridger Formation and the Laney Member of the Green River Formation. There is a veneer of weathered rock to depths of 60-feet which act as groundwater flow paths. The consolidated Bridger and Laney contain perched sandstone lenses at various depths that yield limited flows.

In primary source of groundwater at the Sisecam Wyoming facility is seepage from the exiting tailings storage complex. Evaporation concentrates the pond brines resulting in elevated specific conductance found in the groundwater in the surficial fractured bedrock and alluvium beneath the facility. At the present, three groundwater containment pump-back systems (System 1 & 2, System 3, and System 4) intercept groundwater migrating from the tailings complex towards the Green River. Engineering data indicated the pump-back systems also promotes tailings dam safety by lowering fluid levels and therefore reduces uplift pressures on the structures.

Supplementing the groundwater capture through the pump-back system, a continuous grout wall exists on the downstream side of Pond 1 in the West Dike and South Dam. This grout wall was constructed by drilling into the unconsolidated bedrock to depth below weathering. Purpose was twofold: groundwater containment and dam safety.

A Groundwater and Surface Water Monitoring Plan is in effect under the Land Quality Permit. Fluid levels, specific conductance, and general chemistry are measured semi-annually at wells across the site to monitor the extent and migration of seepage from the tailings complex. Quarterly monitoring is performed at critical locations, specifically around Pond 2. Mass flux of total dissolved solids are estimated from measured specific conductance values and water elevations using a site-specific relationship that has been developed over decades of monitoring.

Project 01-21-001	111	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
17.4	WASTE AND TAILINGS DISPOSAL
---	---

Process tailings disposal is split between underground mine workings and on the surface. Underground disposal is placed as thickened slurry into old lower bed mined out panels. Surface disposal is placed as thickened slurry into a series of tailings ponds that have been maintained over the life of the facility. Sisecam Wyoming recently completed construction of an additional tailings disposal area, Pond 2, which has a predicted life of over 20 years with approximately 30-40% of the tailings disposed of in the underground mine. This study assumes that Sisecam Wyoming will maintain adequate tailings disposal storage for the life of the reserves.

17.4.1 ****	Surface Tailings and Evaporative Impoundments

The Sisecam Wyoming facility has four surface evaporation tailings ponds that are located primarily within prehistoric playa lakes. Except for Pond 2, which has a lined membrane, the remaining ponds seep into the underlining rock formations. Seepage controls are in place and discussed. Figure 17.1 shows the Sisecam tailings impoundments and evaporative ponds.

Historical (pre-1995) mine tailings produced through the refining process of trona were deposited initially into an unlined paleo playa lake identified as Pond 1. Playa at Pond 2 was briefly utilized for tailings disposal and abandoned shortly after initial startup. Pond 4 was established in the drainage into Pond 1 for fluid management. Tailings solids management was engineered as a series of stacker dams within the Pond 4 drainage and identified as Pond 3.

Current tailings management is comprehensive. Pond 1 is split into two portions with the installation of a cross-delta dike, the Upper Delta and DECA recovery areas (Figure 17.2). The Upper Delta is the primary disposal area for tailings through a series of containment cells. Because the tailings are distributed as a heavy slurry, brines, and fluids flow down gradient into the lower DECA recovery area of Pond 1. Fluid level in this area is manage by pumping excess to Pond 4. Pond 2 was rebuilt with a liner for future tailing disposal. Pond 3 area is utilized to enhance evaporation.

17.4.2 ****	Mine Tailings Deposal

A portion of the tailings produced during the refinement of trona ore is disposed through a series of pipelines into the abandoned area of the underground mine. The process is identified as TRM (Tailings Return to Mine) unit permitted under UIC (Underground Injection Control) permit and regulations. Based on current deposition rates, the currently available LB panels can accept tailings for another 10-15 years.

17.4.3 ****	Refuge

Sisecam Wyoming maintains a permitted landfill for refuge and trash within their Land Quality Permit.

17.5	VEGETATION

In general, five major vegetation communities have been identified in the lease area: Upland Sagebrush, Rocky Breaks, Saline Flats, Sagebrush Riparian, and River Floodplains. The high semi-arid climate of the area is dominated by upland drought-resistant plants: sagebrush, rabbitbrush, saltbush, small forbes and other limited plants. Confined area of the Green River flood plain contains cottonwoods, willows, shrubs, and grasses which require more moisture.

The Sisecam Wyoming lease area is dominated by upland drought-resistant plants except for the confined area of the Green River flood plain, where more moisture-requiring plants grow.

Project 01-21-001	112	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Source: Barr- Ciner-2020_Dam-Safety-Report_20210224-signed.pdf

Figure 17.1 Sisecam Tailings Impoundments and Evaporative Ponds

Source: Barr Engineering, 50191095_Upper_Delta_2015_Tailings_Plan_Final.pdf

Figure 17.2 Sisecam Tailings Pond #1

Project 01-21-001	113	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
17.6	WILDLIFE
---	---

Wildlife species found in the Sisecam lease area are closely associated with available vegetation and habitat.

Big game (moose, deer, and elk) is frequently found along the Green River, while the uplands contain herds of pronghorn antelope.

Greater sage-grouse mate and nest near the Sisecam lease area and are considered a threatened species. The birds are most often seen from late spring to late fall, especially in the early mornings or late evenings. Sisecam lease area is not within the core sage-grouse management area, nor does it have any defined lek areas within the lease.

Raptors including Golden Eagle, Bald Eagle, Osprey, Turkey Vulture, Prairie Falcon, Hawk, and owl inhabit the area. Lessor birds include dove, woodpecker, crow, raven, magpie, swallow, wren, thrush, starling, warbler, lark, finch, and hummingbird.

Waterfowl include, goose, swan, duck, teal, loon, pelican, heron, Sandhill crane, and gull.

Sisecam Wyoming maintains permits to capture waterfowl that land on the tailings evaporation ponds during migration with US Fish and Wildlife Services and Wyoming Game and Fish Department. The alkaline waters of the ponds reduce the oils in the waterfowl plumage and precipitate salts out in the feathers causing hypothermia and the birds to be too heavy to fly off on their own. The ponds are monitored daily in the fall and any captured birds are cleaned and supported until they can be released on the Green River. Activity is reported annually to the regulatory authorities.

Game fish including trout, salmon, catfish, and bass have been noted in the Green River. Other species of fish, reptiles, amphibians, and insects are common. Table 17.1 lists other mammals in the area.

Table 17.1

Other Mammal Species

Mountain Lion	Red squirrel	Boreal vole
Bobcat	Ground squirrel	Mountain vole
Coyote	House mouse	Sagebrush vole
Badger	Pocket mouse	Beaver
White-tail jackrabbit	Deer mouse	Foxes
Cottontail rabbit	Pack rat	River otter
White-tail prairie dog	Kangaroo rat	Bats
Porcupine	Woodrat	Shrews
Project 01-21-001	114	HPG
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17.7	PERMITTING AND ENVIRONMENTAL REPORTING
---	---

Sisecam Wyoming permitting, and environmental reporting appear to be current. The primary permit agencies include, Federal and Wyoming State Departments and are listed in below in Table 17.2 below.

Areas where Sisecam has incurred issues with environmental compliance include process emissions, fugitive dust, tailings, pond seepage, site containment, and drinking water TOC. The drinking water TOC problem and site containment overflow were primarily operational in nature and appear to be solved.

Process emissions will continue to be challenged by ever tightening regulations. This will require periodic upgrades of both the natural gas burners as well as the pollution control equipment, precipitators, and baghouses.

Based upon the reports and documentation provided by Sisecam, the tailings pond and associated seepage continues to be controlled and managed successfully. Sisecam has a long history of controlling this issue and through the daily monitoring and annual third-party reviews has shown the necessary efforts to identify issues and manage them into the future. The third-party review recommendations are reportedly being acted upon.

Fugitive dust is the area that needs further effort as observed by the site visit, reporting of periodic excursion of high particulate and recent violations covered below.

Project 01-21-001	115	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Table 17.2

Sisecam Wyoming Operating Permits

Project 01-21-001	116	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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17.7.1 ****	Air Quality Permit
---	---

Criteria pollutant concentrations are measured by the State of Wyoming Department of Environmental Quality Air Quality Division and are subject to the Clean Air Act and Wyoming Air Quality Standards and Regulation.

The Sisecam Wyoming refinery is located above the underground mining operation. This plant is operated in accordance with the provisions of W.S. 35-11-203 through W.S. 35-11-212 and Chapter 6, Section 3 of the Wyoming Air Quality Standards and Regulations. Air Quality Operating Permit (Permit No. P0024380) requires monitoring for a variety of air quality pollutants including particulate matter.

Particulate matter is the primary pollutant from the surface processing, ore storage, DECA and tailings activities and is an area where Sisecam has exceeded standards. Sisecam has an active violation notice received in December of 2021, from Air Quality concerning PM10 monitoring, the No. 2 Crusher Area and Ore Stockpile building. Sisecam is working to correct these issues and has meetings set up with Air Quality in March 2022 to discuss possible required remedies or withdrawal of the violation. Dust control and particulate matter is an area of focus for the operation, but will require significant effort.

Current air quality total estimated emissions are located on Table 17.3.

Table 17.3

Sisecam Total Facility Estimated Emissions

POLLUTANT	EMISSIONS (TPY)
CRITERIA POLLUTANT EMISSIONS
Particulate Matter	1,026
PM10 Particulate Matter	908
PM2.5 Particulate Matter	538
Sulfur Dioxide (SO2)	7
Nitrogen Oxides (NOX)	729
Carbon Monoxide (CO)	5,060
Volatile Organic Compounds (VOCs)	259
HAZARDOUS AIR POLLUTANT (HAP) EMISSIONS	181
GREENHOUSE GAS EMISSIONS (CO2e)	1,553,077
OTHER REGULATED POLLUTANTS
Ammonia (NH3)	22

Source: Emission estimates are from the operating permit application and Ch 6, Sec 2 permits P0024224 and P0021348 (Corrected), and represent the authorized equipment configuration. For informational purposes only. These emissions are not to be assumed as permit limits.

US EPA Agency Identification No. for Sisecam Wyoming is GRGRP 528326.

Greenhouse gasses (GHGs) have been raised as a concern due to the greenhouse effect. The greenhouse effect is a theory that certain gases in the atmosphere impede the release of radiation from the earth, trapping heat in the atmosphere like glass in a greenhouse. Major GHGs currently include carbon dioxide (CO2), methane (CH4), and nitrous oxide (NO2). Currently, the WDEQ-AQD does not have regulations regarding GHG emissions, although these emissions are regulated indirectly by various other regulations.

Project 01-21-001	117	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

In October 2009, the US EPA issued the final mandatory reporting rule for major sources of GHG emissions. The rule requires the reporting selected GHG emissions, including CO2, CH4, NO2, and some halogenated compounds. USEPA/GHGP reported at the Sisecam Wyoming facility for 2020, 813,131 total metric tons of GHSs, representing approximately 50% of the other soda ash produces annual GHG production. Table 17.4 is the 2020 printout of the Sisecam Wyoming GHG inventory for 2020. Table 17.5 shows Sisecam’s historical total greenhouse gas emissions totals by year.

Table 17.4

2020 Sisecam Total Greenhouse Gas Emissions

Source: USEPA/GHGP Facility Details, https://ghgdata.epa.gov/ghgp/service/facilityDetail/2012

Table 17**.**5

Sisecam Total Greenhouse Gas Emissions

by year 2011-2020

2011	2012	2013	2014	2015	2016	2017	2018	2019	2020
677.7	705.0	692.6	703.4	741.4	767.6	752.2	732.6	800.0	813.1

Note: 2011-2012 Type of Fuel was Coal and Natural Gas, 2013-2020 Natural Gas Source: Sisecam

Project 01-21-001	118	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
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17.7.2 ****	Land Quality Permit
---	---

Wyoming Department of Environmental Quality Land Quality Division issued Large Mining Permit No. 257. Sisecam annually reports topics including changes in permittee information, quantity of ore mined, mine planning, acres disturbed, new construction, environmental areas, monitoring activities, exploration report, and reclamation report and performance bond estimate.

Supplemental to this document, US Bureau of Land Management on a five-year basis receives and similar report with more detail on mining activities. The 5-year BLM report is a stipulation of the mineral lease.

17.7.3 ****	Underground Injection Permits

Wyoming Department of Environmental Quality Water Quality Division issues UIC Permit Facility WYS037-043. Reported annual under the 5B1-98-1 General Permit. Sisecam Wyoming tailings has two disposal streams. The primary disposal method is the surface tailings pond. Secondary disposal is tailings injected into abandoned areas of the underground mine. This permit requires annual reporting of a summary of tailings material injected into the mine.

17.7.4 ****	Storm Water Discharge Permit

Wyoming Department of Environmental Quality Water Quality Division authorizes storm water discharge under permit No. WYR320025. This general permit was issued in 2018 and is reviewed on a five-year basis. In June 2020, a major storm event occurred causing erosion and discharge of process water onto previously reclaimed lands. No water was discharged to the Green River. The spill was reported immediately after the event to Wyoming Department of Environmental Quality Land Quality Division as well as the BLM. After inspection by the LQD office, recommendations were made and completed.

17.7.5 ****	Drinking Water System

US EPA is the lead agency for drinking water standards. Sisecam Wyoming is public water system number WY5600634 and is a non-transient non community public water system.

17.7.6 ****	Sewage Permit

Wyoming State Engineers Office issued P10445.0R in 1996. No modifications have been identified.

17.8	SITE MONITORING

Sisecam Wyoming is generally in compliance with all known environmental permits that require monitoring. Critical monitoring for air quality, groundwater containment, drinking water, and other land quality issues are monitored either continuously or on a scheduled routine basis. Federal agencies including US EPA, Bureau of Land Management, Bureau of Reclamation, US Fish and Wildlife, NRC, and State divisions, Department of Environment Quality, Wyoming Game and Fish, State Engineers Office, and Sweetwater County are involved.

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17.9	CLOSURE PLANS AND ESTIMATES
---	---
17.9.1 ****	Reclamation Plan
---	---

The 1975 Reclamation Plan focus on three general categories:

●	Lands with buildings and structures;
○	All surface buildings and structures to be removed. Foundations removed and used to fill mine openings;
---	---
●	Roads, travel ways, railroads, etc.;
---	---
○	All roadbeds, travel ways, railroad beds and other like developments to be scarified and seeded with perennial grasses and in accordance with regulatory requirements; and
---	---
●	Tailings ponds and waste areas;
---	---
○	Tailings to be left in place as dry lakes. Berms and dams to remain in place. Diversion ditched to be constructed around the tailings facilities. Surface of the “dry lakes” to be stabilized with a “standard asphaltic” material to eliminate windblown contamination. Fencing to be erected and maintained for wildlife protection.
---	---

Reclamation plan was intended to return lands to their original usage, grazing, and wildlife habitat, as much as possible. Return affective lands to a condition compatible with the surrounding lands.

17.9.2 ****	Reclamation Bond

1975 reclamation cost estimate was $351,000.

1979 WYDEQ/LQD issued a permit to develop an acceptable reclamation for the tailings disposal areas.

1987 WYDEQ/LQD issued a revised permit with a more comprehensive and detailed reclamation plan. Twenty tasks were identified and included post-closure reclamation cost.

2020 WYDEQ/LDQ approved permit 257 with a revised reclamation bond of $36,211,000. The 1987 revision served as a template for the over 50 permit revision requests. The 2021 revision with the construction of Unit 8 will increase the reclamation bond to an estimated $46,132,000 after construction is completed.

17.10	SOCIAL OR COMMUNITY IMPACTS

The social and community impacts of the Sisecam Wyoming operations are a net positive to the area as shown by the Industrial Siting Council approval for the Unit 8 Expansion Project. The trona operations are one of the largest employers in the area and contribute significantly to the tax base. This is a long and established relationship developed over decades.

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18.0 CAPITAL AND OPERATING COSTS

Cost effective mining and processing has been conducted for over 60 years at Sisecam Wyoming generally under the same mine design assumptions utilized in this reserve estimate. Overall costs are not expected to change significantly in the future; thus, using historical costs for mining the reserves and producing soda ash are considered a reliable basis to forecast future costs. Capital and operating cost estimates are at a minimum at a pre-feasibility level of confidence, having an accuracy level of ±25% and a contingency range not exceeding 15%.

18.1	OPERATING COSTS

For the basis of determining the economic viability of the reserves stated in Section 12.0, HPG has utilized the last five years of financial data provided by Sisecam. Sisecam provided both audited and unaudited financial information including detailed production cost, capital expenditures and revenues. Previous reviews were based upon three years of data but due to the extraordinary impact of COVID a more extensive analysis was conducted. Some consideration was given to dropping 2020 and 2021 from the analysis but was rejected as recent cost data is materially important to this type of analysis and the ultimate outcome of COVID is unknown. The analysis conducted is therefore considered conservative given the inclusion of such an unusual event.

Five years of operational data has been summarized as a cash statement of Net Income which is provided in Table 18.1.

18.2	COSTS DISCUSSION

Several observations are offered concerning Table 18.1:

●	Production and sales volume has been steady with the exception of 2020;
●	Revenues costs and net income has been steady with the exception of 2020;
---	---
●	Energy, labor, and royalties are the largest contributors to cost;
---	---
●	Royalty payments have decreased dramatically with the reduction in Federal Royalty from 6% to 2% and Sisecam’s focus on mining federal leases;
---	---
○	There is a limit to the duration for which Sisecam can continue to shift mining to federal leases, therefore for this study the five-year average has been used; and
---	---
●	Mining costs represent approximately 18% of overall soda ash production cost.
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Table 18.1

Sisecam Five Year Historical Net Cashflow

Note: Numbers have been rounded; totals may not sum due to rounding.

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18.3	CAPITAL COSTS
---	---

Since the 2019 reserve estimate, Sisecam has continued to invest in the Big Island property to improve production and reduce costs. Major expenditures include the Co-Generation facility to allow in-house generation of power for the soda ash processing plants and construction of a new ventilation shaft, upgraded mine ventilation fans and shaft heaters. Past business economics have supported these large capital expenditures, which are part of the normal business operation. Capital cost estimates are at a minimum at a pre-feasibility level of confidence, having an accuracy level of ±25% and a contingency range not exceeding 15%.

Sisecam provided HPG with a five-year capital plan which was reviewed along with capital plans from the 2019 review. Based on this information, Sisecam continues to demonstrate a consistent history of investing in both sustaining capital as well as larger expansion and large capital replacement investments. Based upon past performance and current economics this study assumes similar capital expenditures will be made so that the production facilities will be viable for the LOM with the mine producing 5.0 MST of trona ore per year.

The following assumptions and parameters were used for this study:

●	Because the operation is currently profitable as configured and is predicted to be profitable into the future, the Unit 8 and Shaft 5 expansion projects are not necessary for profitability and are therefore not considered in this analysis due to the uncertainty surrounding their implementation;
●	It is assumed that the sustaining capital of approximately $30 million per year continues as a conservative estimate;
---	---
●	The capital necessary to convert to low seam mining equipment is assumed to occur during the normal equipment replacement cycle for the mining production equipment which is part of sustaining capital;
---	---
○	An additional capital expenditure for lower equipment of $20 million has been assumed when the thicker reserves are nearly mined out in approximately 20 years; and
---	---
●	The capital necessary to upgrade the dissolver ends of Unit 7 and Unit 6 is estimated at $100 million and is predicted to occur in ten years.
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19.0 ECONOMIC ANALYSIS

19.1	METHODOLOGY USED

As previously noted, HPG considers the plus 60-year history of profitably operating the mine and processing units to be a reasonable basis for forecasting future costs and revenues. Based upon the Big Island’s average costs and revenues for the past five years, a cash flow forecast was generated to estimate economic viability. Capital and operating cost estimates are at a minimum at a pre-feasibility level of confidence, having an accuracy level of ±25% and a contingency range not exceeding 15%.

The financial model that supports the mineral reserve declaration is a standalone model that calculates annual cashflows based on scheduled ore production, assumed processing recoveries, soda ash sale prices, projected operating and capital costs.

Because the entity is a Master Limited Partnership and taxes are paid by the “partners”, no taxes were included in the economic analysis. The financial analysis is based on a before-tax discount rate of 5%. All costs and prices are in un-escalated “real” dollars. The currency used to document the cashflow is US$.

19.1	FINANCIAL MODEL PARAMETERS

Several core assumptions have been employed in constructing this model. First, the analysis is on a cash cost basis with the assumption that viable economics implies positive cash flow. This is a higher standard than other common economic measures such as earnings before interest, taxes, depreciation, and amortization (EBITA). In general, if an operation has positive cash flow its EBITA is more positive. Because of the conservatism built into this cash flow assumption, a minimum 5% rate of return is assumed for viability. Secondly, where possible, a conservative approach to both costs and revenues was applied. A good example of this conservative approach is the inclusion of data from 2020 and 2021 which were a historic anomaly. Exclusion of these years would improve the financial forecast significantly.

The economic analysis is reported on a 100% project ownership basis. The economic analysis assumes constant prices with no inflationary adjustments. Sisecam Wyoming is owned by Sisecam Resources LP ("Sisecam") 51% and by NRP Trona LLC ("NRP") 49%.

This financial analysis includes the following assumptions:

●	Constant soda ash production of 2.725 MTPY;
●	Constant dry ore soda ash conversion of 1.835 ore to ash;
---	---
●	Increased mine production from 4.2 MTPY to 5.0 MTPY with constant cost per ton ore.
---	---
○	Incremental tonnage is generally less expensive;
---	---
●	Increased mining costs for two-seam mining and low seam mining;
---	---
○	Two-seam mining costs 53% higher with two-seam tonnage at 25% of production until 2029 when two-seam tonnage rises to 50% of production
---	---
○	Thin seam mining costs 24% higher in year 2051 when the +9-foot ore has been depleted;
---	---
●	DECA mining reduced to 25% in 2024 and beyond with a rise in processing costs due to production from mechanically mined trona ore;
---	---
●	Plant configuration remains unchanged until upgrades for lower grade ore implement in 10 years;
---	---
●	Operating costs are based on five years actual costs seen during operations and are projected through the LOM plan; and
---	---
●	Constant soda ash price of $188/ton based on the last five years revenue data.
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Capital Expenditure Assumptions:

●	Capital costs are based on actual costs seen during operations and are projected through the LOM plan with adjustments for estimated future changes including:
○	Sustaining capital of $30 million per year for LOM;
---	---
○	Plant upgrade in 2032 to mitigate slugs of low-grade ore due to floor rolls; and
---	---
○	Mining equipment changes to allow mining below 9-feet;
---	---

Table 19.1, Table 19.2, and Table 19.3 illustrate the expected cash flows for the LOM based upon the above assumptions. The model indicates a 11.9% internal rate of return (IRR) and a positive net present value (NPV) of $425.4 million at a 5% discount rate.

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Table 19.1

Sisecam LOM Cashflow Analysis

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Table 19.2

Sisecam LOM Cashflow Analysis

(Cont.).

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Table 19.3

Sisecam LOM Cashflow Analysis

(Cont.)

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Table 19.1, Table 19.2, and Table 19.3 contain “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, which are intended to be covered by the safe harbor created by such sections and other applicable laws. Please refer to the note regarding forward-looking information at the front of the Report. The cashflow is only intended to demonstrate the financial viability of the Project. Investors are cautioned that the above is based on a high-level mine plan and certain assumptions which may differ from Sisecam Wyoming’s long-term outlook or actual financial results, including, but not limited to commodity prices, escalation assumptions and other technical inputs. For example, Table 19.1, Table 19.2, and Table 19.3 use the price assumptions stated in the table, including a soda ash commodity price assumption of US$188.00/ton. Please be reminded that significant variation of soda ash prices, costs and other key assumptions may require modifications to mine plans, models, and prospects.

19.2	ECONOMIC ANALYSIS SENSITIVITY ANALYSIS

To assess the viability of the Sisecam operation the sensitivity of the operation to changes in soda prices, and operating cost assumptions was tested using a range of 20% above and below the base case values.

Due to the high percentage of fixed costs the economics for large mines and processing facilities the operation is most sensitive to net revenue (soda ash price) and sales volume, followed by variable operating costs, then fixed costs and lastly mining costs.

The sensitivity analysis is shown in Figure 19.1 which illustrates the sensitivity of the 5% NPV to soda ash sales price, fixed costs, variable processing costs and two seam mining cost. Soda Ash displays typical sensitivity of a commodity to pricing which reinforces the importance of being one of the lowest cost producers.

Figure 19.1 5% NPV Sensitivity to Revenue and Production Costs

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The second sensitivity graph varies the mining cost for the two-seam areas due to the uncertainty in this area. The model assumes 50% of trona production will be mined from the two-seam area based 48% of the remaining reserves being two seam mining. Figure 19.2 illustrates the change in expected NPV as mining costs increase or decrease. Mining costs in this figure are a 50-50 blend of higher two-seam costs and the current costs which are assumed to be stable. For the base case the operation remains NPV positive over a wide range of increased mining costs.

Figure 19**.**2 **** 5% NPV Sensitivity to Two Seam Mining Cost

19.3	ECONOMIC ANALYSIS DISCUSSION

Future mining and refining costs are predicted to increase due to thinning seam thickness and two-seam mining, but the overall impact on costs is not shown to be material with proper mine development sequencing and equipment replacement planning. Mining costs average approximately 18% of the overall production cost for soda ash. If future two-seam mining costs increase by the predicted 53%, overall profitability is decreased by 15%.

HPG considers the operation economic even at this increased cost. Based on this analysis the stated reserves are considered economically extractable.

Sisecam Wyoming faces the following risks to increased costs:

●	Two-seam mining will require additional ground support and/or will require a wholly different mining method. The final details are unknown until test mining of the proposed geometry is complete;
●	Recent two-seam mining tests indicate that certain areas contain high concentrations of methane in the immediate lower bed roof strata and may require degassing prior to mining which might increase mining costs or require decreased extraction in these areas;
---	---
●	Two-seam mining’s production costs will be higher due to the increased ground support and decreased productivity. An allowance has been included in the cost analysis;
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●	TRM tailings disposal could impede access to some of the less than 10-foot reserves if the panels are filled prior to mining the thin material;
---	---
●	Ore bed variability and degradation near the margins of the deposit could cause ore grades to decrease to an unacceptable level. The margins of the ore body have been penetrated in several areas, and while the ore grade was lower, mining costs were not significantly higher. The current model does show ore grades to deteriorate due to a rise of in-seam impurities at the edges of the deposit, which will require some additional processing costs or changes to the processing facilities. Proper short-term planning can determine the best combination of grade and processing costs when mining is near the ore body margins. Continuous miner units can be scheduled to blend some of the ore variability and reduce the impact on the refinery. For the purposes of this analysis the dissolver end of the processing plants is upgraded to handle this ore and processing costs increased to reflect the lower ore grade; and
---	---
●	External economic drivers are beyond the scope of this study. They include, but are not limited to, labor issues and disputes, increases in royalty rates, change in the supply and demand structure for soda ash, and regulatory and environmental law changes.
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20.0 ADJACENT PROPERTIES

The Green River Basin is home to five mining operations, Genesis Westvaco, Genesis Granger, Tata Chemicals, Solvay Chemicals, and Sisecam Wyoming, the subject of this report. Figure 3.2 shows the location of these operations along with their sodium leases.

20.1	GENESIS WESTVACO

Genesis Westvaco was the first trona mine in the basin. The trona bed was discovered in 1938 by oil and gas drilling. Westvaco Chemicals Corporation sunk the first shaft in the basin near there in 1947 to mine Bed 17. The Westvaco operation lies nine miles to the southwest of Sisecam and owns sodium leases adjacent to Sisecam’s. In 1948 Food Machinery Corporation (FMC) purchased Westvaco and operated the property continuously until it was sold to Tronox in April of 2015 and then to the current owner Genesis in September of 2017. Since the start, there have been eight shafts developed into Bed 17. Genesis produces dense soda ash from three soda ash plants based on dry trona. Two plants use the Mono process and the third is based on the Sesqui process producing light soda ash. Additionally, Westvaco is solution mining the old mine workings and processing the resultant liquor in the fourth liquid feed plant based on a decahydrate crystallizer. Genesis also produces bicarbonate and caustic soda. Annual soda ash production exceeds 4.0 MTPY. The operation reported 898 employees and trona production of 3,768,938 in 2020.

20.2	GENESIS GRANGER

The Granger mine and processing plant was constructed in 1976 by TexasGulf (TG). The TG mine and refinery is located eleven miles to the west of Sisecam. There are three shafts from the surface to trona Beds 19 and 20. The operation dry mined Bed 20 between 1976 and 2002 then converted to a solution mine in 2005. Elf Aquitaine purchased TexasGulf in 1985 and named the operation TG Soda Ash. The underground mine and processing facility had production capacity of over 1.2 MPTY. In 1999 the operation was purchased by FMC (now Genesis) and the plant mothballed in 2002. In 2005 the operation was restarted using solution liquor from the now flooded mine. Using liquid feed, the plants soda ash capacity was reduced to approximately 400,000 TPY. Genesis is currently in the process of constructing a decahydrate crystallizer front end to the plant which will return the production back to the original nameplate of over 1.2 MTPY.

20.3	TATA CHEMICAL PARTNERS

In 1968 Allied Chemical and General Chemical started a mine in Bed 17 just to the east of the Westvaco Mine. Tata Chemicals purchased the property in 1989. The Tata operation lies 9.5 miles to the southwest of Sisecam. Tata has a production capacity of over 2.5 MTPY produced from dry mined trona and using the mono process in three processing units. The operation reported 508 employees and produced 4,070,944 tons of trona in 2020.

20.4	SOLVAY CHEMICALS

In 1979, Tenneco minerals started the Solvay mine just south of Genesis and Tata also mining Bed 17. The Solvay operation lies fifteen miles to the southwest of Sisecam. In 1992, the Belgium company, Solvay Chemicals purchased the process. Solvay produces soda ash primarily by dry mining, but also does some limited solution mining of old workings. The operation reported 508 employees and production of 4,070,944 tons of mined trona in 2020. Soda ash production capacity is over 2.5 MTPY.

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21.0 OTHER RELEVANT DATA AND INFORMATION

21.1	WEST END ROOF COLLAPSE AND WATER INFLOW

Sisecam provided several recent studies by a hydrologist and geotechnical engineer concerning the Lower Bed West roof collapse and water inflow described in Section 13.2.1. There is a large area of surface subsidence adjacent to the Green River above the LB West underground fall area that is increasing in size as shown in Figure 21.1. The subsidence is likely caused by the roof collapse and failure of the mine pillars in that area. Both reports indicate that the water flow is not from surface waters but from subsurface aquifers based on isotope analysis. Both consultants conclude that due to the depth and multiple aquitards above the mine the probability of a hydraulic connection between the Green River and the mine workings is very low.

The water inflow to the mine ranges from 40 to 140 gpm with the average, since October 2020, around 85 gpm. The water inflow is fresh water which will, over time, dissolve the mine support pillars which are trona. Removal of the support pillars will continue to subside the area. The analysis concludes that at current inflow rates dissolution of all the trona will take 150 years resulting in a very gradual trough-type subsidence basin that is not expected to impact the watershed drainage area. At the current rate of 2 inches of subsidence per year it will take 50 years to reach the expected 8 feet of subsidence. Any large change in flow over an extended period would alter these predictions. Over time the subsidence will impact some of the surface features and infrastructure requiring relatively simple mitigation measures that are well understood.

The likely cause of the seismic event in this area is a large roof fall and pillar failures. Roof falls in the Big Island mine are infrequent but a map of the historic roof falls shows a large cluster of falls in the LB West area. The modulus of elasticity in this area is half of other areas of the mine and likely contributing to the extent of the falls.

The rest of the Big Island Mine with similar geometries remain open, in good condition and have not experienced the large number of roof falls experienced in this area. Other than to increase the size of the barrier pillars there are no plans to modify the mining geometries in other areas of the mine.

As part of the above-mentioned studies extensive subsidence monitoring has been installed over the area, the area is examined regularly, the inflow water is measured, and the water is isotope tested yearly.

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Source: Sisecam - Subsidence Report to LQD 8.18.21.pdf

Figure 21.1 West End Subsidence Progression

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22.0 INTERPRETATION AND CONCLUSIONS

Approximately 118 MST of the reported recoverable Trona (48%) is dependent upon Sisecam confirming the viability of two-seam mining in the next four years. Most of these tons (approximately 71.5 MST, 60%) are in areas with thickness over 9-feet.

Approximately 148 MST of the reported recoverable tonnage is above 9-feet thick and can be mined and processed with the existing equipment, but areas will require ore blending or modification of the processing facilities to handle lower grade ore for short periods. These areas comprise 39.5 MST of the total reserves. It is anticipated that these plant modifications need to be made within 10-15 years.

The practice of “high grading” the deposit and only mining the thicker material first risks sterilization of the thinner areas if access is lost. Recovery of the reserves less than 9-feet will require changes to the mining and utility equipment, will incur higher mining costs, require access rehabilitation costs and is dependent upon the ability to access these areas through old workings or via extensions of old mains entries as shown in the LOM plan developed for this estimate. As future mining continues, with the current large mining equipment, some loss of portions of the edge of the ore bodies will occur, especially when long production panels are developed. This material makes up 72 MST of the estimated recoverable tonnage. There is some risk that access to these areas 20 years after mining might not be possible.

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23.0 RECOMMENDATIONS

Sisecam should continue to move forward as rapidly as possible with validation of the two-seam mining to confirm both the geotechnical and economic assumptions.

It is recommended that Sisecam continue close monitoring of the west end water inflows and associated subsidence. HPG would advise more frequent isotope testing of the inflow as well as additional hydrologic studies including source tracing. HPG would advise more frequent subsidence monitoring and evaluations of the area.

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24.0 REFERENCES

BAYARI, C. Serdar. 2021, Source of the Momentary Groundwater Inflows in Big Island Mine, Sisecam LLC, Green River Wyoming, April 2021, p.1-57

Boyer, B.W., 1982, Green River laminates: does the playa-lake model really invalidate the stratified-lake model?": Geology, v.10, p. 321-324.

Bradley, W.H., 1964, Geology of Green River Formation and associated Eocene rocks in southwestern Wyoming and adjacent parts of Colorado and Utah," U.S. Geological Survey Professional Paper 496-A, 88 p.

Burnside, M., and Culbertson, W., 1979, Trona deposits in the Green River Basin, Sweetwater, Uinta and Lincoln Counties, Wyoming, U.S. Geological Survey Open File Report 79-737, 10 p.

CFR-17 CFR Part 229 Subpart 229.1300, -- Disclosure by Registrants Engaged in Mining Operations: Code of Federal Regulations, 83 FR 66448, Dec. 26, 2018.

Culbertson, W.C., 1966, Trona in the Wilkins Peak Member of the Green River Formation, southwestern Wyoming: U.S. Geological Survey Professional Paper 550-B, p. 159-164.

Culbertson, W.C., 1971, Stratigraphy of the trona deposits in the Green River Formation, southwest Wyoming: University of Wyoming Contributions to Geology, v. 10, p. 15-23.

Eugster, H.P., and Surdam R.C., 1973, Depositional environmental of the Green River Formation of Wyoming: A Preliminary Report: Geology Society of America Bulletin, v. 84, p. 1115-1120.

Gaines, R.V., Skinner, H.C., Foord, E.E., Mason, B., and Rosenzweig, A., Dana’s New Mineralogy, John Wiley and Sons, Inc. (ISBN: 047119310-0)

Garrett, Donald E. Natural Soda Ash: Occurrences, Processing, and Society Use. New Yorek: Van Norstrand Reinhold, 1992. Print. Pages 538, 270.

Leigh, R.T., 1998, Wyoming Trona: An Overview of the Geology, Wyoming State Geological Survey Public Information Circular 40

Roehler, H.W., 1992, Geology of the Eocene Wasatch, Green River, and Bridger (Washakie) Formations, Greater Green River Basin, Wyoming, Utah, and Colorado, U.S. Geological Survey Professional Paper 1506 A-E

Richland Mining Consulting LLC, 2021, Subsidence Potential of the Lowerbed West Area at Big Island Mine, Prepared for Sisecam Wyoming, December 2021

Sullivan, R., 1980, A stratigraphic evaluation of the Eocene rocks of southwestern Wyoming: Geological Survey of Wyoming Report of Investigations no. 20 p. 50. 1985, "Origin of lacustrine rocks of Wilkins Peak Member, Wyoming: American Association of Petroleum Geologist Bulletin, v. 69, no. 6, p. 913-922.

Surdam, R.C., and Wolfbauer, C.A., 1975, Green River Formation, Wyoming: a playa lake complex: Geological Society of America Bulletin, v. 86, p. 335-345.

Wood, G.H., Kehn, T.M., Carter, M.D., and Culbertson, W.C., 1983, Coal Resource Classification System of the U.S. Geological Survey, U.S. Geological Survey Circular 891

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24.1	SCANNED FILES LISTING
---	---
File/Folder Name	Size
---	---
Jefferson_17-DEC-62_Densities_Trona_and_Rock.pdf	323,741
Lee_5-AUG-88_Trona_Reserves_Memo_with_Tables.pdf	2,858,739
Mannion_01-AUG-61__Wyoming Eploration-1960 Progress Report.pdf	3,689,977
Mannion_09-MAY-61_Ore Reserve Calculations.pdf	4,503,326
Mannion_12-MAY-61_Ore_Reserve_Calculations_and_Tables.pdf	7,667,741
Mannion_26-OCT-73_Planning_and_Supplemental_Drilling_Program.pdf	4,825,097
Parratt_17-JUL-73_GR_Trona_Reserves_Trona_District Land Holdings.pdf	1,665,154
Parratt_24-MAR-11_1976_Trona_Development_Drilling.pdf	5,068,341
Wendt_19-DEC-67_Test_Drilling_North_1967_Drilling Program.pdf	3,499,956
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SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL
24.2	SISECAM WYOMING DATA SOURCES
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Project 01-21-001	139	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Project 01-21-001	140	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Project 01-21-001	141	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Project 01-21-001	142	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Project 01-21-001	143	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

Project 01-21-001	144	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

25.0 RELIANCE ON INFORMATION PROVIDED BY THE REGISTRANT

HPG has reviewed technical data, reports, and studies produced by other consulting firms, as well as information provided by Sisecam Wyoming, and others listed in Sections 24.0 and 25.0. This review was conducted on a reasonableness basis, and HPG has noted herein where such provided information engendered questions. Except for the instances in which we have noted questions or made specific comments regarding the nature of the information, HPG has relied upon the information provided by Sisecam as being accurate and suitable for use in this Report. Sisecam’s staff of professional engineers are considered experts in their field and as such HPG has no reason to doubt the authenticity or substance of the information provided.

HPG has conducted a general review of mineral titles and license documents provided by Sisecam. HPG has not verified title or otherwise confirmed the legal status of any of the leases or the license but has relied upon documents and information provided by Sisecam Wyoming’s representatives regarding the current status of the leases and license shown. HPG’s reliance on such information and representations applies to Section 3.2 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations and documentation regarding environmental permitting and compliance. HPG’s reliance on such information and representations applies to Section 17.0 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations and documentation from Barr Engineering concerning surface tailings placement and impoundment structures. HPG’s reliance on such information and representations applies to Section 17.0 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations concerning any outstanding active adverse legal or liability issues including statutory and regulatory interpretations. HPG’s reliance on such information and representations applies to Section 3.2, 17.0 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations and information concerning manufacturing costs and revenues. HPG’s reliance on such information and representations applies to Section 11.0, 18.0, 19.0 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations concerning marketing information and soda ash pricing trends. HPG’s reliance on such information and representations applies to Section 11.0, 17.0, 18.0, 19.0 and the relevant portions of Section 1.0.

HPG has relied on Sisecam representations and information concerning governmental factors relating to taxation, royalties, monitoring requirements and frequency, bonding requirements, violations, and fines. HPG’s reliance on such information and representations applies to Section 9.0, 11.0, 12.0, 18.0, 19.0 and the relevant portions of Section 1.0.

HPG has relied upon a report by Richland Mining Consulting LLC concerning the subsidence and water inflow over the western edge of the mine. HPG’s reliance on this information and representations applies to Sections 9.0, 12.0, 21.0, and relevant portions of Section 1.0.

HPG has relied upon a report by C. Serdar BAYARI Ph. D hydrogeologist concerning the subsidence and water inflow over the western edge of the mine. HPG’s reliance on this information and representations applies to Sections 9.0, 12.0, 21.0, and relevant portions of Section 1. 0..

Project 01-21-001	145	HPG
		hollberg professional group PC

SISECAM WYOMING - TRONA MINERAL RESERVE ESTIMATE
MARCH 2022	FINAL

26.0 PROJECT TEAM CVS

Mr. Kurt Hollberg has over 35 years of experience in the mining industry including 17 years in operations management and technical services. He has an in-depth understanding and experience with operational and capital budgeting and procurement. His experience encompasses green field feasibility studies through mine rehabilitation and re-opening. He is experienced in project management and construction. His international experience includes work in Colombia, Africa, Spain, and the Middle East doing feasibility studies on coal, potash, and phosphate properties and as the lender’s technical advisors for world-class phosphate and aluminum projects. He has served as the technical advisor to the adjuster on numerous large mine insurance claims. He has advised and audited underground and surface safety and health programs for the DOE. He has extensive geotechnical experience related to mining and is well versed in mining systems and mine infrastructure design including solution mining. He is familiar with statistical testing techniques for process improvement. Using statistical techniques, he helped increased continuous miner productivity by 20% with minimal capital expenditure. Mr. Hollberg holds a B.A. degree in Economics from Colorado College and a BS in Mining Engineering with a minor in Civil Engineering from the Colorado School of Mines. He is a registered Professional Engineer in Colorado, Wyoming, Utah, and Nevada.

Mr. Richard Terry Leigh has over 40 years of experience in the mining industry, including management and technical services. He has extensive experience in mineral exploration and mineral estimation. He is knowledgeable in the use of computers for mineral estimation and geostatistics. Mr. Leigh has spent the past 30 years working in the Green River Basin Trona mines as a geologist and hydrologist and in environmental services, technical services, and mine management. Mr. Leigh has been highly active in the professional certification of geologists. He has served on the Wyoming Board of Professional Geologists, Wyoming Geological Survey Board, ASBOG, National Association of States Boards of Geology, and as a member of the Council of Examiners for PG certification. Mr. Leigh has published numerous papers on Wyoming geology and trona deposition. He has published several papers on tailing disposal and ground water remediation. Mr. Leigh holds a BS degree and MS degree in earth sciences from the State University of New York. Mr. Leigh is an AIPG Certified Professional Geologist and a Licensed Professional Geologist (PG) in Wyoming.

Project 01-21-001	146	HPG
		hollberg professional group PC