DSHW-2024-007491

Mine Office:Mailing Address:
Utah Iron, LLC Utah Iron, LLC 435-986-4900
2708 Comstock Rd P O Box 747 435-986-4851
Cedar City, UT 84720 Cedar City, UT 84721 435-986-4926
Permitting – Mike McCandless 435-749-1368
July 25, 2024
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
Via Email
Subject: Re: March 28th, 2024, correspondence on Notice of Insufficient Information to Discontinue
Post-Closure at Comstock Mountain Lion Iron Mine Landfill, Iron County SW310 – Request to reduce
bond.
Mr. Hansen,
Utah Iron has reviewed the correspondence relating to Post Closure at Comstock Mountain Lion Landfill
and is asking the Division to modify the original request. We are requesting a reduction in the $250,000
surety obligation that accompanies this permit, a surety that is currently held by the Utah Division of Oil,
Gas & Mining. Given the current state of the landfill and the success the company has had with
reclamation and revegetation of the site, we are requesting the bond amount be lowered to $80,000 or
less, if the Division feels this is warranted.
The site is currently in Post Closure and the surrounding ground, formerly an active mine waste pile, has
been reclaimed and has been approved for full bond release from the Division of Oil, Gas and Mining.
The only expenses forecast for the site would be for regular site inspections and to hold some funds for
administrative work that may be done in the future. Due to the location of the landfill on the mine site,
erosion risk is extremely limited and will be monitored aggressively by the companies staff.
While we will still continue to work on responses to the specific items in the March 28th letter regarding
insufficient information to discontinue Post Closure, we feel in the interim, a reduction of bonding is
warranted. Utah Iron will continue to conduct semi-annual inspections and will host WRMC staff for site
inspections as requested.
As stated in previous correspondence, the reclamation efforts for the landfill began in earnest in 2014,
under previous ownership. The landfill and all of the ground surrounding the landfill was graded and
seeded in February 2021. As a result of this reclamation, the landfill is no longer directly accessible via
road or other access ways. An earthen berm has been constructed to block any vehicular access and
the surrounding area has been reclaimed and approved for bond release by OGM.
Vegetation is in excellent condition, access has been blocked, erosion has been controlled and since the
site lies totally within the boundaries of the rest of the active mine, the public has no access to the site.
Utah Iron is committed to working WMRC staff to facilitate any additional inspections, remediation
practices, and post-closure so that the WMRC Permit SW310 can be closed. Utah Iron recognizes that
the regulations for WRMC are listed under R315-302. Solid Waste Facility Location Standards, General
Facility Requirements, and Closure Requirements fully apply as well as the rules for OGM under R647-1.
Minerals Regulatory Program and R647-4. Large Mining Operations would also fully apply under this
modified request.
Your consideration of this request is sincerely appreciated. Thank You.
Michael McCandless, Permitting & Govt. Relations
Utah Iron, LLC
6249 West Gilbert Industrial Court
Hurricane, Utah 84737
[e-mail]
[e-mail] – [phone]
cc:
Bryon Reyna – OGM
Adam Urquidez – Utah Iron
Kary Jensen – Utah Iron
Miken Larson – Utah Iron
Cyndi Gilbert – Utah Iron
Landfill Permit
Detailshttp://168.178.6.56/TabsPage.aspx?AI_PageConfigID=100136&DivName=DSHW&ID=SW310&NAME=COMSTOCK%20MOUNTAIN%20LIO
N%20LANDFILL&ADDRESS=2708%20Comstock%20Road&CITY=CEDAR%20CITY&TYPE=n%2Fa .