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sus n6 z i STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />August 12, 2010 <br />Mr. Bob Warneke <br />Natural Soda, Inc. <br />3200 RBC Road 31 <br />Rifle, CO 81650 <br />Re: Natural Soda, Inc., Nacholite Project, Pe ,m it <br />Technical Revision No. 30 application, TR-30. 'vl <br />Dear Mr. Warneke, <br />Division a I-\"Ibi „atlon. <br />/ Mining and Safety <br />No.M-1983No1983-194,, LPPrrliminary Adequacy Review of <br />The Division of Reclamation, Mining and Safety (DRMS) has reviewed the application for a technical revision, <br />TR-30, to the above referenced 112 permit. The purpose of the technical revision is to update the environmental <br />monitoring plan, mine plan and reclamation plan. A review of the application has revealed a few issues and <br />clarifications to address. <br />1) Please clarify what monitoring well(s) are proposed as the point(s) of compliance for the revised water <br />quality monitoring plan. Also, show the proposed point of compliance well(s) location(s) on a figure that <br />clearly shows the spatial and down dip relation to Panel 1 and Panel 2 and proposed future mining <br />locations. :Based on the map titled "Proposed Groundwater Monitoring Locations and Schedule" <br />additional monitoring wells may need to be installed to establish an accurate point of compliance. <br />2) In section 2.5.2 Groundwater Quality it is stated "In addition, select monitor wells (Table 1) may be <br />analyzed for both major and minor constituents. " Please clarify what is meant by this statement. Is the <br />statement in support of the sampling parameters and schedule proposed in Table I? <br />3) Due to the ability of the process fluids to have a negative impact on soil composition, <br />surface/groundwater water quality, wildlife and vegetation; what measures are taken to minimize process <br />fluid releases? In the event of an accidental spill of process fluids, what secondary containment structures <br />exist at the site? Please specify the containment structure's capacity and location. <br />4) In Section 6.8 Affected Acreage, it is stated "Construction and operations at the solution mine site are <br />anticipated to ultimately affect a maximum of 260 total acres of land." Currently the approved permit <br />Natural Soda holds with the Division consists of 73 acres. If Natural Soda plans to affect more than the <br />approved 73 acres an amendment to the permit must be completed to add more acreage to the permit. <br />Please revise section 6.8 to state that no more than 73 acres will be affected. <br />5) Section 6.9.3 discusses the reduction of potentiometric head due to the use of submersible pumps in the <br />recovery wells. The use of the pumps came after a variance occurred in the A-groove aquifer in 1995. <br />Are the pumps ran continuously or only during active mining. What happens to the potentiometric head <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />James B. Martin <br />Ct /?+pEExecutive Director <br />RECEI y EMetta E. Pineda <br />Director <br />AUG 16 2010 <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines