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1 (Page 21 • MINE ID # OR PROSPECTING ID # M-81-021 INSPECTION DATE 07/10/97 INSPECTOR'S INITIALS RCO OBSERVATIONS This inspection by the Division was conducted as part of the monitoring of 1 12 metal permits and as a result of the recent transfer of the permit from Energy Fuels Nuclear Inc. to International Uranium (USA) Corp., for which an updated bond recalculation is required. The operator was contacted about the inspection, and a time was arranged to meet first at his office in Dove Creek then proceed to the site. The operator was present throughout the inspection. The permit area is stated to be 20 acres in the original application. There are several different maps in the file, a couple of which indicate that the permit area is 450 acres Ithe total block of claims?I; other maps variously show the area delineated at the portal as being 10 acres vs 7.2 acres. The application did state however, that "extra" land was being included in the permit, since remote surface activity (such as vent hole sites) would be needed but their locations were not known at the time of permit application. Subsequent revisions (TR-01 and TR-021 which specified several vent hole locations, added about 0.55 acres of disturbance to the original 3+/- acres at the portal. Because: there is not a definite permit boundary either marked on the ground nor consistently described in the file, especially for the ported/pad area, the topic of "records" is noted as a problem in this report. The operator must provide a permit map, including the features and according to the standards described in Rule 6.3.5121 and (31, by the date shown on the last gage of this report. The map)=•) must show all separate portions of the permit area. The required permit ID sign was observed to be posted at the entrance to the site. IThe operator should modify the sign to show the current operator's name.) As noted strove, there were no markers noted as present, though surface features appeared to be roughly consistent with the size and configuration depicted on the detailed permit maps, which made estimating the approximate boundary location feasible. The topic of signs and markers is not being noted as a problem at this time, because of the recent permit transfer and the recent site reactivation. The operator is reminded that the markers to be placed, and the permit boundary defined on the maps to be submitted, must completely encompass all areas of surface: activity which has occurred and will occur under this permit. This mention is made specifically because a significant expansion of the pad las compared to the 1981 map) was noted at its east end and north side, due to additional material dumped over the face. IThe operator will note that, since there are 20 acres permitted and only a small fraction of them affected, there is an opporb~nity to perhaps define the boundaries of the permit to allow the best room for expansion of mining activity, plus inclusion of all affected roads and stormwater structures.) The existing bond is 528,000, and is felt to be sufficient to perform the required reclamation. The bond will be recalculated soon to verify that its amount is adequate. The new estimate will not occur, however, until the operator has provided the maps of the permit area, showing all affected areas in :sufficient detail to reasonably figure the bond. The cut slope wall is low )average of 4 ft tall) and wood cribbed for about 1 50 lineal feet. Uncribbed portions totalled another several hundred feet. Since the slope height is low, little material will be required to be pushed up against it to recontour the area during final reclamation; most grading will be pushing down pad material. Structures included the steel and wood portal shed with steel grate closure, two metal buildings on <:oncrete foundations, timber platforms at the portal, metal powder magazine (emptyland a 500-gallon diesel tank on a skid. There were numerous pieces of underground mining equipment present on the pad near the shop. The problem noted in the inspection of August 1993, which was related to spilled oil needing clean up, was specifically checked at the site during this inspection. It was located near the shop building, and the soil had been ripped and graded repeatedly during the last few years. The area now shows rip sign of the prior contamination. The problem was abated previously. The operator should ensure that future soil contamination is prevented, which is felt to be important at this site if significant numbers of equipment are stored or serviced here. The above-mentioned fueltank was observed, but not checked to verify whether it contained fuel. It had no containment structure under or around it, though no spillage was observed either. The topic of hydrologic balance is not noted as a problem a this time. Discussion occurred during the inspection. involving secondary containment at fuel and tube stations. The Division makes no distinction about fuel depots vs short-term rue) locations, which would require vs not require adequate secondary containment. All fluid storage vessels inherently have a possibility of leaking; all fluid handling is subject to accidental spillage. Rule 3.1 .7 describes the Division's jurisdiction in groundwater quality and defines the operator's responsibility to adequately control and contain anything which would adversely impact the groundwater quality. Several hundred gallons of diesel would definitely contaminate a large volume of soil and possibly contaminate groundwater (or surface water, depending on the time of the spilll~ The operator must therefore provide secondary containment, of adequate size and appropriate construction, for each storage tank to be used. Please refer to Rule 3.1.7 if questions. If the operator wishes to discuss these further, please contact this office.