2011-10-06_INSPECTION - M1984014

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OBSERVATIONS PERMIT #: M- 1984 -014 INSPECTOR'S INITIALS: GRM INSPECTION DATE: September 15, 2011 This inspection is part of the normal inspection schedule for Designated Mining Operations by the Colorado Division of Reclamation, Mining, and Safety (Division). It is also the pre - operational inspection for the submitted Environmental Protection Plan (EPP). The underground was not inspected due to the lack of recent activity. The JD -8 Mine is a 112d -1 permitted site located on the south side of the Paradox Valley, north of DD -19 Road, in Montrose County. Glen Williams, Cotter's representative, accompanied the inspector on site. 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 entrance to the site on County Road DD19. The required public notice per Rule 1.6.2 (1) (b) for the amendment was observed posted at this point. Permit boundaries were observed as t -posts and other easily distinguishable markers. The permit disturbance area "may" include an upper disturbance area. Discussions and recommendations to Cotter on the proposed upper area are outlined in the Preliminary Adequacy Review issued on October 3, 2011. For the purpose of this inspection it is observed that the area is undisturbed with several two -tract roads criss- crossing the area. The area is relatively flat juniper / pinyon canopy sloping back from the mesa rim on the north to the south. No major drainages are noted. Purposed disturbances appear not to have impacts not being addressed within the EPP amendment. No utilities or pre- existing structures were observed. The lower area is the primary mining facility and the focus of current surface disturbances and EPP. The JD -8 Mine was actively mining in 2005. Uranium ore was shipped out and waste rock dumps expanded. A stockpile of ore was left upon shut down. Cotter relocated some of the ore to inside the mine willingly; the remainder was placed back in the mine earlier this year per a Division enforcement action. The main portal is actually part of the old Opera Box Mine complex. A compressor house, office trailer, and equipment trailer are located at the portal collar. An empty fuel tank with secondary containment is located in this area as well. Electrical utilities are as indicated on maps. No other utilities were observed. The area of the topsoil stockpile is well vegetated. On maps it appears that there is an overlap of the soil area with waste dumps. A clarification has been requested. The existing dump has been used as a staging area for the portal and will be expanded to continue that support. A new dump area was stripped of top soil in 2005. That area has volunteer natural vegetation coming back in very well to provide stability. The ore stockpile area is bermed off to prevent storm run -on and off. No issues were observed in this area. The pad and stormwater designs are under discussion and review as part of the EPP. The current stormwater control system directs flows to a created basin between the old and new dumps. It is well vegetated and stable. Flow and retention volumes will be reviewed. On issue that has come up is the indication of a perennial stream just below the mine. Visual observations do not support what is marked on the USGS map which is not uncommon. But, because it is shown it must be addressed. As part of the EPP review the Division is requesting a reconnaissance report of the small drainage to confirm that no springs or seeps exist that would require sampling. No issues or problems are cited at this time. A review of the financial warranty will be undertaken when the EPP process is completed. Responses to this inspection report should be directed to Russ Means at the Division of Reclamation, Mining, and Safety, Grand Junction Field Office, 101 South 3rd Street, Room 301, Grand Junction, Colorado 81501, phone no. 970 - 241 -1117. Page 2 of 3