2011-08-24_PERMIT FILE - P2011012

• Permit No: P2011012
• IBM Index Class Name: PERMIT FILE
• Doc Date: 8/24/2011
• Doc Name: Second Technical Adequacy Review Letter
• From: DRMS
• To: RM Potash
• Email Name: RCO
• Email Name: AJW
• 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]
August 24, 2011
Jon P. Thorson
RM Potash
5515 Nuthatch Road
Parker, CO 80134
Dear Mr. Thorson,
Office of
Mined Land Reclamation
STATE OF COLORADO
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Re: Colorado Potash Project, NOI File No. P -2011 -012, Second 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. Pitteda
Director
On August 15, 2011 the Division received the responses to the June 21, 2011 adequacy letter, concerning the NOI
application named above. Your letter arrived prior to the 60 -day deadline stated in our letter to you. It appears that
most of the issues identified earlier have been satisfactorily addressed and are no longer considered deficiencies to
the NOI. I still have a couple items which merit clarification, which are listed below. Please respond to each item.
1. Affected acreage: The affected acreage was originally stated in the NOI to be 2.00 acres, which the Division
considers to be too low, even if only three of the drill pads and appurtenant roads are included in the affected
acreage. Your response letter referred back to the BLM scoping document, in which a figure of 5.3 acres is
presented. It is unclear, however, if that 5.3 -acre figure is what you are revising the affected acreage to in the
NOI application to the Division. Please clarify. If no clarification or revised figure is received from you, the
Division will interpret this to mean that the figure should be revised to 5.3 acres.
2. Groundwater protection: The plan states that the drilling operation may encounter groundwater, and that it
may consist of more than one aquifer. The narrative information provided concerning placement of cement
plugs to isolate and protect the aquifers was a bit unclear and did not appear to comport perfectly with the
information shown in the plugging diagram. Are the plugs to be placed 50 feet above and 50 feet below each
aquifer, or continuously throughout and beyond the column where the aquifer is? Additionally, the narrative
does not make clear how the lower limit of each plug will be supported, as there is no information
concerning mechanical plugging device or backfill of cuttings. Please provide more information.
3. Diesel -based mud and Reclamation: The NOI states that the diesel -based mud to be used in the project will
be pre -mixed and delivered by the manufacturer, and stored in dedicated tanks onsite. An estimate of the
likely amount needed in each borehole was provided, and an extra amount will be available onsite if needed,
up to 15,000 gallons per drill hole. Recovery of the used diesel mud, while imperfect, was nevertheless
estimated to be high (97 -99 %). In order to maximize the removal of diesel mud residue from the hole, this
office will require the additional measures of flushing and use of surfactants. The details of recovery rate
and clean -up practices will be required in the drill hole permanent abandonment reports.
4. Reclamation cost: The supplier of the mud will be contracted to remove the mud from the site and properly
dispose of it. As you know, this office must hold a financial warranty (bond) throughout the life of the
project, in an amount adequate to perform the necessary reclamation, in the case of an operator not
Office of
Denver • Grand Junction • Durango Active and Inactive Mines