INSPEC42809

• Permit No: M1999002
• IBM Index Class Name: Inspection
• Doc Name: MINERALS PROGRAM INSPECTION REPORT
• Inspection Date: 1/20/2000
• Media Type: D
• Archive: No

(Page 3)
' •
MINE ID # OR PROSPECTING ID #
INSPECTION DATE 1-20-00
M-99-002
INSPECTOR'S INITIALS ACS
A portion of the area designated in the permit for the installation of the evaporation ponds
is being used as a lay down area in support of the construction of the Piceance site
facilities area. The disturbance associated with the lay down area includes clearing and
grubbing, removal of topsoil, and minor leveling. During the permitting process, the
Division requested detailed designs for the evaporation ponds. In response, American Soda
stated that the process plant flow sheet may be modified and the process ponds could be
eliminated or reduced in size. American Soda requested that the evaporation ponds remain as
a component of the permit with the stipulation that prior to construction detailed designs
would be provided as a technical revision. As a result, the evaporation pond area is
approved for eventual disturbance, but the approval was conditional. Since no disturbance in
the evaporation pond area is approved in the permit, either for pond construction or the use
of the area for lay down, no reclamation costs for this area are included in the bond that
has been posted by American Soda. The following two statements were included in the notes
attached to the Division's reclamation cost estimate that forms the basis for American Soda's
bond amount:
"Costs to reclaim the evaporation ponds would be added to the bond amount if and when the
ponds are approved for construction."
"Note that no cost to replace topsoil is included for the evaporation pond area. This
cost will be included if and when the evaporation ponds are approved for construction."
Since the inclusion of the evaporation ponds into the permit was conditional, the disturbance
in the evaporation pond area constitutes a deviation from the approved mine plan. It is also
problematic that the disturbance in the evaporation pond area is not specifically addressed
in the cost estimate used to determine the bond amount. These issues are considered minor
problems by the Division, particularly considering that American Soda has posted a $3,000,000
plus bond and only a fraction of the approved disturbances have occurred at this time. The
corrective action is to provide a technical revision modifying the mining and reclamation
plans to include a lay down area as an optional disturbance in the area conditionally
approved for the evaporation ponds. Based on the information included in the technical
revision, an adjustment in the amount of required bond will be made. At a minimum, the
technical revision should include and description and map showing the size and location of
the lay down area, and sufficient information to allow an estimate of reclamation costs,
e.g., cut and fill volumes and topsoil volumes. See problem PB-1 on page 4 of this report.
Since a bond adjustment will be made in conjunction with approval of the technical revision
to incorporate the lay down area into the permit, the Division will require that the portion
of bond held by the state be adjusted at the same time. With the bulk of the bond being held
by BLM, recently enacted Division policy requires that the minimum portion of the bond held
by the state be equal to the 5 percent Division of Minerals and Geology administrative costs
required under section 34-32-118(5), C.R.S.
I & E Contact Address
NAME Ed Cooley
OPERATOR American Soda, L.L.P.
STREET 2717 County Road 215
CITY/STATE/ZIP Parachute, CO 81635
L'Qr ~~ ~%Fi~ ~µ, ~ IVo'' P~~~790~~ l
cc: Carl Mount, DMG
^ CE
^ BL
^ FS
^ ~
^ HMWMD (CH)
^ SE
^ WQCD (CH)
^ OTHER