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holes. The final size of such a cavern is not described in the amended NOI. Filling an <br />underground cavern with cement is significantly different than plugging a bore hole, and the <br />amended NOI application lacks any detail about how this will be undertaken or how adverse <br />impacts to the site's hydrology will be prevented. The Division should require Black Range <br />Minerals to provide adequate information and studies to understand this process, its potential <br />impacts and how to avoid them. <br />4) Rule 3.1.5(5) requires that all acid - forming or toxic - forming materials be handled and <br />disposed of in a manner to prevent pollution of the environment. The amended NOI application <br />does not adequately meet this requirement. The excavated material is described as "up to 200 <br />tons" of "bulk sample" in the application, but in fact will be mineralized uranium slurry. The <br />application does not describe the precise nature of this slurry, how it will be stored and handled <br />on site, how acid or toxic runoff will be controlled, how it will be disposed of, how it will be <br />processed, and how it will be transported offsite. Nor does the application describe how the <br />waste water created by this process will be handled, or even whether all water used in the UBHM <br />process will be removed from the underground cavern. <br />Additionally, the amended NOI application states that mud pits will be allowed to <br />evaporate and then be backfilled, without consideration for the likely presence of uranium and <br />other toxic constituents. The Division should require the use of pit liners and other controls to <br />prevent the release of contaminants and protect wildlife. <br />5) The amended NOI application does not adequately demonstrate that the proposed <br />UBHM activity will meet the requirement of Rule 3.1.5(l 1) which prohibits the unauthorized <br />release of pollutants to groundwater. Again, UBHM is an experimental mining technology that <br />has not been used in the United States. The information included in the amended NOI application <br />falls far short of the body of studies and detailed plans necessary to determine whether <br />conducting hydraulic mining into a uranium ore body in the presence of groundwater aquifers <br />can adequately protect the environment and groundwater supplies. <br />6) Rule 3.1.6(1)(a) requires the applicant to comply with additional Colorado water laws <br />and regulations. The proposed activities are likely to require the consumption of large quantities <br />of water, including by evaporation. The applicant should be required to specify the amount of <br />water to be used, the source, whether water rights are secured, and how the water will be handled <br />during the various stages of UBHM activity. <br />7) Rule 3.1.6(1)(b) requires the applicant to comply with water quality standards. The <br />applicant should be required to describe in detail how the ground water quality will be restored if <br />it is contaminated through UBHM activity. A water restoration plan should be required and <br />reviewed by the Division and CDPHE. <br />8) Rule 3.1.7 identifies, among numerous requirements, the necessary information to <br />characterize and protect groundwater standards, including a groundwater monitoring program. <br />These items include but are not limited to the specific location of drill holes, procedures for <br />sampling and monitoring, procedures for reporting data and evaluating it, and the analysis <br />methods. This will naturally require a characterization of the Hansen deposit's ore body and the <br />