2010-10-08_INSPECTION - M1977306

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PERMIT #: M-1977-306 INSPECTOR'S INITIALS: GRM INSPECTION DATE: September 23, 2010 OBSERVATIONS This inspection was conducted as part of the normal program monitoring program of the Colorado Division of Reclamation, Mining, and Safety (DRMS). DRMS inspector Russ Means was accompanied by Cotter Representative Glenn Williams. The JD-9 underground mine is a 112d-1 uranium mine located in Bull Canyon in Western Montrose County. The mine has intermittent status and is currently on stand-by. The mine identification sign and affected area boundary markers are in place and in compliance with Rule 3.1.12. The sign is located at the main entrance gate. Permit boundaries are mostly identified by t-posts and geological features. Some areas around disturbances are not well marked. The inspector notes that the permit boundary maps for this area are very old and outdated. Many are from 1977 to 1994 and lack the detail and information that new maps require. While not an issue currently DRMS will request new, up to date maps with the details and information with the next permittting action. Currently there are no underground activities taking place. The site appears to be being minimally maintained with no issues being observed. The portal is secured by a heavy steel double gate. Equipment is parked next to the the main shop area. The portal area and staging area are orderly free of trash with only minimal supplies stored. There is some volunteer vegetion on dumps and around buildings such as rabbit brush and native grasses. The vegetation does not meet any set reclamation standards. No noxious or problematic weeds were noted. The inspector observed a subsidence approximately 150 to 200 feet north from the portal entrance. The subsidence is a result of a failure in the main access adit for the mine. The subsidence appears to be very close to but within the permit boundaries for this area. The subsidence is fenced off for safety and appears to be approximately 30 feet in diameter and goes into the workings approximately 75 feet below. Cotter is evaluating the issue and must address it as part of any reactivation plans. DRMS will have to include backfilling of the structure in its review of the reclamation liability until the issue is corrected. DRMS notes in the file that a CDPHE stormwater plan was filed in 1994. DRMS files do not indicate any updates since that time. At this time the plan appears to be minimal and needs to be updated. If Cotter has updated the plans with CDPHE DRMS should be sent copies of those updates. Any stormwater plans and control structures will have to be incorporated into the pending Environmental Protection Plan (EPP) and meet the specifications outlined in Rule 7.3.1(3)for a two year/24 hour event up to the Probable Maximum Precipitation (PMP) event plus the ten year 24 hour storm event. The plan for stormwater controls will need to include run off from dumps and roads, ore stockpile sedimentation containment, site run-off containment and sedimentation structures, and site run-on diversions. The JD-9 underground mine has a dewatering treatment system. The water is treated for radium using barium chloride. The primary precipitation pond and secondary holding pond are located in a fenced area near the headframe on the upper portion of the mine permit. The pits are lined, however they are beyond their life expectancy. Wethering and tearing of the liners for the treatment and clean water ponds was observed. CWQD reportedly inspected the pond liners and found them to be unacceptable as well. DRMS is notifiying the operator that no dewatering of any kind may occur until a new treatment pond system plan is submitted, reviewed, and approved by DRMS. Since dewatering and treatment only occur when the mine is in operation this is not a problem currently but must be addressed prior to any reactivation and withion the EPP. A review of the permit notes very little information on hydrology for the mine. The EPP will require a full analysis of the groundwater regime in relation to mining activities. Some initial information was submitted in 2006 but the information is basic and requirements have changed. All information will have to meet the EPP requirements for baseline characterization and monitoring. The operator notes some issues with the monitor well located south of the main portal which may require construction of a new one of gain useful data. The shallower waste pile pizometer has to date shown no measurable water. No petroleum products, fuels, ore or other hazardous materials issues were noted or observed at this time. Page 2 of 3