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~9-Gu:. INSPECTION DATE: 5-22-00 OBSERVATIONS PACE: 2 INSPECTOR'S INITIALS: ACS A monitoring inspection of the Yankee Gulch Sodium Minerals Project was conducted. The Piceance Site upgrade facilities and the pipeline to the Parachute Plant are currently under construction. American Soda is also in the process of developing 34 production well pads and intends to drill 26 initial production wells as soon as the Underground Injection Control permit is secured and the amount of reclamation bond is adjusted to cover the cost of plugging and abandonment of production wells. The main Piceance Site access road, well field access road, roads to individual well pads, and well field piping were also under construction at the time of this inspection. The temporary lay down area approved through technical revision TR-002 was inspected. The following three pertinent observations were recorded: • The fuel storage tanks in the lay down area are surrounded by earthen berms and the basin formed under the tanks is lined with a high density polyethylene liner. The Division recommends that the liner be anchored into the berm such that no free edges are exposed. This will prevent wind from catching and damaging the liner. • The storm water controls at the perimeter of the lay down area consisted of low earthen berms and silt fence. A substantial percentage of the silt fence was down and ineffective. The earthen berms were observed to be effective at concentrating runoff and routing it along the berm's interior. However, it was observed that the berms were frequently breached at the location of natural drainage ways allowing the release of untreated storm water outside the disturbed area footprint. The Division recommends that the silt fence be eliminated in this area of application, and that the berms be inspected and repaired so that storm water is contained in the disturbed area and allowed to evaporate or soak into the ground. In locations where storm water must be released, the storm water treatment facilities described in the approved "Soil Conservation, Erosion and Sediment Control, Reclamation, and Revegetation Plan" must be installed. American Soda personnel and contractors are referred to Appendices A through E of the approved plan for details on the proper installation and maintenance of storm water controls. These treatment facilities may include rock check dams, straw or hay bale check dams, gabion baskets, sediment traps, and vegetative filters. Where silt fence is to be used, it must be keyed into the ground and must be inspected and maintained, particularly after rain and wind events. See problem PB-1 on the final page of this report. • One area where it was observed that water was exiting the perimeter of the lay down area, a saline crust had formed in the drainage way. American Soda was directed to investigate and report on the source of this discharge and to take measures to prevent a reoccurrence. It has subsequently been determined that a water wagon had been parked for several nights at the location in question, and water from the tank had leaked through the valve. Since this water was derived from water supply well 20-8 at the Test Mine Facility it contains approximately 2500 ppm bicarbonate, which explains the mineral crust. The Piceance Facility storm water pond was inspected. The spillway is located in the southwest corner of the pond and is constructed to direct overtopping flow into a lined and riprapped plunge pool. Pond inlets are two 24 inch corrugated plastic pipes located in the northeast corner of the pond. The pond is securely fenced. The Operator is storing a small amount of water in the pond, but is maintaining sufficient freeboard to fully contain a 100-year storm runoff. Based on this