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mining techniques. All three of these criteria are met even with the simple descriptions offered in <br />the amended NOI application. At minimum, Black Range must be required to specifically <br />identify and disclose the nature and amounts of all materials it might expose, disturb or extract, <br />so that a DMO determination may be made based on full and necessary information. <br />The proposed use of UBHM at the Hansen Project is further complicated by the lack of a <br />regulatory regime that specifically addresses this experimental mining technology. Because it is <br />a hydraulic form of underground mining, is water - intensive in its use, and is impactful to ground <br />water supplies, the Division should require Black Range Minerals to complete a mining <br />application for in -situ leach uranium extraction, to which UBHM bears a close resemblance. The <br />Colorado Department of Public Health and Environment is required to also exercise its oversight <br />obligations in this permitting as well. <br />The amended NOI application does not identify the specific location of the proposed <br />UBHM operation nor which of the existing 16 drill holes will be utilized. The application is also <br />not specific in identifying how many additional disturbances will be created, but the drilling and <br />clustering of additional monitoring wells is mentioned. [Application, question #12.] In the <br />enclosed map, the general location of drill holes is identified, including one on a Bureau of Land <br />Management parcel. The BLM must be consulted and an amendment to Black Range Minerals <br />federal Notice of Intent must also be submitted and separately approved. <br />The Division must also take a careful look at the existing bond in place for the currently <br />approved Notice of Intent and activities that have previously been authorized. The deployment of <br />UBHM creates a mineralized slurry material; results in the extraction of uranium ore and toxic - <br />forming materials; requires the underground injection of high- pressure water flows; and creates a <br />significant amount of processed waste water (although these details are omitted in the amended <br />NOI application). In short, what is being proposed is a water - intensive, hydraulically based <br />mining operation that normally would require a significant bond in order to prevent the public <br />from bearing the costs of groundwater restoration in the likely event that groundwater supplies <br />will become contaminated. Such a complex operation is also likely to require a WQCD <br />stormwater permit, a CDPHE water discharge permit, approval from the Colorado Division of <br />Water Resources, and an EPA underground injection control permit. Those agencies should be <br />informed and consulted on the application. <br />The amended NOI application is deficient in a number of additional ways: <br />1) Rule 5.1.2(d)(V)(a) requires a map that identifies the proposed prospecting sites or <br />activity areas, including drill holes. This information is not included in the application. <br />2) Rule 5.1.2(f) requires a "narrative description" of the methods to be used. As noted in <br />comments above, the amended NOI application lacks a detailed narrative description and omits a <br />number of pertinent details that have readily been disclosed by the applicant elsewhere. <br />3) Rule 5.4.2 requires the plugging and abandonment of drill holes in a timely manner. <br />The amended NOI application is not specific in how many drill holes will be plugged and <br />abandoned, but it does say that the excavated cavern will be plugged in the same manner as bore <br />