REP47802

• Permit No: M1983194
• IBM Index Class Name: Report
• Doc Date: 1/7/2004
• Doc Name: Sundry Notice and Spill Report Response
• From: DMG
• To: Natural Soda Inc.
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215 C O L D RA D O
Denver, Colorado 80203 DIVISION o F
Phone: [phone] MINERAL S

FAX: [phone] G E O L O G Y
RECLAMATION•MI NING
SAFETY•SCIENCE
January 7, 2004
Bill Owens
Governor
Mr
Ed Baker Greg E. Walther
. Executive Director
EHS Manager Ronald W. Cattany
Natural Soda, IT1C. Division Director
3200 County Road 31 tJat°ai Res°urce rr°stee
Rifle, CO 81650
RE: October 4, 2003 Sundry Notice and Spill Report, Nahcolite Project, Natural Soda Inc., Permit
No. M-1983-194.
Deaz Mr. Baker:
On December 31, 2003 the Division received a cc of a "Sundry Notice for 200 Foot Pull Back on 6H"
and a "Submittal of Undesirable Event Report". The originals of both of these documents were
addressed to the White River Resource Area Bureau of Land Management. In response to the note
which you enclosed, since the pull back apparently did not affect any surface azea which had not
already been permitted, and apparently will not increase the required reclamation warranty, no TR will
be required.
After examining the "Undesirable Event Report", it appeazs that because of the relatively small volume
of the spill, the fact that the spill material was the barren liquor, and that the contaminated dirt was
removed to an active mud pit the Division feels that appropriate measures were taken. The Division
has reviewed your Technical Revision (TR) 14 -Technical Revision for Undesirable Event Reports
and its attached White River Nahcolite Action Plan for Bicazb Spills. It was observed that the action
plan calls for different actions based on the levels of soluble salt in the affected soils. Because of the
different action plans based on soluble salt levels, as well as the fact that the Division now has a
stipulation, which is incorporated into all new permits and permit amendments, which requires the
reporting of any spill of a toxic or hazardous substance, the Division is requesting that you provide us
with a general characterization ofthe chemical composition of the barren liquor, including the levels of
the most abundant chemicals and the average soluble salt content. It was also noted during the review
of TR-14 that there was no commitment as to a time frame for reporting spills. The enclosed
stipulation does set a time frame for reporting toxic or hazazdous substance spills. However, even
when spills are not of a toxic or hazardous nature, the Division would like a commitment to report such
spills within a reasonable time frame. Please provide the Division with a clarification to TR-14 that
commits Natural Soda, Inc. to a time frame as discussed above. Please provide the general
chazacterization of the barren liquor, and the clarification of TR-14 in reference to a reporting time
frame, within 30 days of the receipt of this document.
Office of Office of Colorado
Mined Land Reclamation Active and Inactive Mines Geological Survey