2011-06-21_PERMIT FILE - P2011012

• Permit No: P2011012
• IBM Index Class Name: PERMIT FILE
• Doc Date: 6/21/2011
• Doc Name: Adequacy review letter
• From: DRMS
• To: RM Potash
• Email Name: RCO
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
June 21, 2011
Jon P. Thorson
RM Potash
5515 Nuthatch Road
Parker, CO 80134
Dear Mr. Thorson,
Office of
Mined Land Reclamation
STATE OF COLORADO
JUN Z7 2011
Division of Reclamation,
Mining and Safety
Re: Colorado Potash Project, NOI File No. P- 2011 -012, Technical Adequacy Review Letter.
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pifieda
Director
The Division is reviewing the Notice of Intent (NOI) named above, and has identified several items that require
clarification. Please respond to each item listed below. These are the issues that staff has identified to -date, and if
additional issues are identified through further review, we will write to you requesting additional response.
1. Affected acreage: The affected acreage is stated to be 2.00 acres, though a breakdown of the acreages of the
various activities shows this figure to be too low. The acreage figure must include all lands to be disturbed
by drilling pad construction, and all new and significantly upgraded roads. The types of activities and
disturbance to be included in the total acreage are: topsoil stockpiles, piles of stripped brush, cut and fill
slopes, sediment controls, new roads and significantly upgraded roads. "Significant" road upgrades are
defined as widening, changes in grade, and realignment. Certain drainage structures may also apply. Please
provide a revised affected acreage figure, and how that figure was estimated.
2. BLM claims: In the "General Information" attachment, there is a list of BLM claims numbered D -1 through
D -21. The list does not exactly match the map of the claims, since on the map there is no claim number D-
18, but there is a claim number D -22. Please state if this was just a typo or if further claim description is
needed.
3. Groundwater protection: The plan states that the drilling operation may encounter groundwater. By virtue of
the extensive depth of drilling it is possible that more than one aquifer may be encountered. Please provide
detailed information as to how you will prevent mixing between aquifers, during drilling and as part of drill
hole closure during final reclamation.
4. Drilling will involve certain water -based mud and diesel -based mud. Please confirm that all drilling fluids to
be used on the site will be completely contained: mixed, stored and recycled in secure vessels and tanks, and
fully lined pits. Please state how water -based mud will be dewatered and disposed of during reclamation.
5. Diesel -based mud: The NOI states that due to the solubility of the potash that is being explored, a diesel -
based mud will be used in the potash bed section of the bore hole. Injection of a hydrocarbon into a bore
hole, especially when its recovery and/or full containment is not certain, making groundwater contamination
possible, raises concerns for this office. Please provide better description of diesel -based mud to be used,
including (on a one - drill -hole basis) how much will be stored on the pad surface at any one time, an estimate
Office of
Denver • Grand Junction • Durango Active and Inactive Mines