2010-07-23_INSPECTION - M2000158

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PERMIT #: M-2000-158 INSPECTOR'S INITIALS: JLE INSPECTION DATE: July 8, 2010 OBSERVATIONS This was a pre-operation inspection of the S & H Mine; DRMS File No. M-2000-158, operated by Platte Sand and Gravel, LLC (Platte S &G) for the Amendment 02 application. This site is located approximately 2.5 miles northwest of Platteville, Colorado in Weld County. I, Jared Ebert of the Colorado Division of Reclamation, Mining and Safety (Division) conducted the inspection. Mrs. Danna Ortiz and Mr. Christopher M. Crowley of Civil Resources, LLC. and Mr. Steve O' Brian of Environment, Inc. accompanied me on the inspection. This inspection was conducted in order to evaluate the current mining operation and the proposed future operation described in the Amendment 02 application. Currently, the approved permit area of the site is 1,239.4 acres. The operator would like to add an additional 269.23 acres to the permit area. To summarize, the proposed plan is to create six slurry wall lined water storage cells throughout the mine site by mining the area and by the placement of 40 foot tall embankments around the excavations. A 2009 aerial photograph is attached, highlighting several of the items discussed in this report The current processing area is located west of the entrance of the mine site from County Road 38 and east of the open ground water excavation. The processing area contains washer units, many portable conveyor systems, material stockpiles and waste rock piles. As the mined material is processed sediment is pumped into the northern portion of the ground water lake. Large concrete pillars were constructed to hold up the washer units. These pillars are not accounted for in the current financial warranty, but will be'accounted for in the financial warranty calculation for the current amendment application. There are several oil and petroleum products stored around the processing area. Some of the containers are stored in proper secondary containment, however several containers are not, and have leaked onto the ground (See Figures 17-23). This issue is cited as a problem and will require corrective action to be taken by the Operator. A copy of this report has been sent to the Colorado Department of Public Health the Environment, Water Quality Control Division. The Operator will need to demonstrate they have an approved Spill Prevention Control and Countermeasure Plan (SPCC) and photo documentation the plan has been implemented for the improperly stored containers. The contaminated soil will need to be excavated and be disposed of by an approved method (such as sent to an approved landfill, land farming, recycling center, etc.) and evidence such as a receipt of disposal will need to be submitted to the Division. Also, the storage tanks will need to be placed into proper secondary containment structure such as a lined berm (structure must have a capacity to contain 110% of the substance stored in it). The Operator is reminded they are required by Rule 3.1.13 to provide notice to the Division within 24 hours of any spill that is required to be reported to any of the following agencies: the Division of Colorado Department of Health and Environment, the National Response Center, the Colorado Emergency Planning Commission, any local Emergency Planning Commision, Local Emergency planning committee, or the State oil Inspector. There are two excavation areas located at the site. One is north of the processing area, which is enclosed in the Sharkey Lake slurry wall; this is where the current active excavation is occurring. This pit was operating at the time of the inspection. The second excavation is located west of the processing area. This pit is now an open groundwater lake. The Operator does not appear to be actively mining this area. According to the latest annual report, about 68 +/- acres have been mined inside the Sharkey Lake slurry wall. Mining appears to be advancing to the northwest and northeast. The highwall covers the majority of the circumference of the excavation. The highwall ranges in slope from vertical, to a .5:1 to 1:1 horizontal to vertical ratio. According to the current approved mining plan for mining inside the slurry wall, the operator committed to the following, "we will mine the lake slopes at a uniform 3:1 rate from top to bottom to allow for changing lake elevations as the water is added and removed from the reservoir" Exhibit D, AMO 1 (DRMS Date Stamp May 21, 2004). The Division will need to hold a bond for grading the current highwall to the required 3:1 slope. The current financial warranty appears to take into account a cost for grading the ground water lake excavation but not the excavation inside the slurry wall. The groundwater lake excavation west of the processing area is about 10-12 acres in size. The slopes above the water line appear to be set at about a 1:1 ratio. According to Mr. Crowley, the slopes under the water level range from 2:1 to 3:1 Page 3 of 12