2010-06-08_INSPECTION - M1977424

• Permit No: M1977424
• IBM Index Class Name: INSPECTION
• Doc Date: 6/8/2010
• Doc Name: Response to inspection report
• From: Western Water & Land, Inc.
• To: DRMS
• Inspection Date: 3/18/2010
• Email Name: THM
• Media Type: D
• Archive: No

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wwl - Western Water & Lana, Inc.
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June 4, 2010
Mr. Travis Marshall
Environmental Protection Specialist
Division of Reclamation, Mining and Safe
101 South 3`d St., Suite 301
Grand Junction, CO 81501
RE: Permit No. M-1977424
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RECEIVED
JUN 0 8 2010 i/
GRAND Jl1NiJIO N IIEF D OFFICE
RECLAMATION MINING & SAFETY
Response to Logan Wash Mine Evaporation Pond Inspection Report
Dear Travis:

Western Water & Land, Inc. (WWL), on behalf of Occidental Oil Shale, Inc. (OOSI), has prepared this
letter in response to your inspection report for the inspection conducted at Logan Wash Mine
Evaporation Pond on March 18, 2010. WWL received a copy of your report by way of U.S. Postal
Service on April 2, 2010.
The purpose of the DRMS inspection was to become familiar with the Logan Wash Mine site and to
specifically examine the Evaporation Pond liner and leak detection system. As reported by WWL to
DRMS on February 5, 2010, the detection system vault at the pond was collecting water and it was
suspected that the liner was leaking water to the underlying detection/collection system.
WWL first recognized water in the vault on November 5, 2009 during normal pond inspection and
monitoring work. A shallow depth of water in the in vault is not unusual after rains as the vault cap
allows precipitation to enter and collect in the bottom sump. During this inspection, no water was
flowing into the vault through the 3 PVC collection pipes that convey water from the detection system
underlying the pond. During subsequent inspections, it was observed that the water level in the vault
was rising. WWL began pumping the vault water to the pond on January 13, 2010. WWL sampled the
vault water on January 27, 2010 and installed an automated pumping system. Preliminary analytical
results were received on February 0 and the results indicated the water in the vault was likely pond
water. On February 5, 2010, Travis Marshall of DRMS, Julia Christiansen and Bob Hartman of
U.S. Bureau of Land Management (BLM), and Gary Beers of the Colorado Department of Public
Health and Environment (CDPHE) were notified by phone of the potential liner leak. A message
was left for Mr. Beers; he did not return my call.
WWL conducted confirmation sampling of the vault and sampling of the pond on February 11",
2010. The samples confirmed that the vault water was consistent with the composition of pond
water. WWL submitted a formal notification letter to the DRMS, BLM, and CDPHE on February
9'b, 2010. The letter summarized the pertinent events associated with the observations and actions
taken by WWL at the pond related to the liner leak (see Attachment A). WWL continued to
monitor the leak detection system and record the pump cycle through the use of a pressure
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