Laserfiche WebLink
k. Expected dimensions of the underground cavity excavated during UBHM testing. <br />1. Expected concentration of uranium in fragmented ore extracted during UBHM testing. <br />m. Procedures for controlling fugitive dust, particularly from the gravel shaker. <br />n. Steps to be taken if water sampling and testing indicates that uranium and/or other heavy <br />metals are being mobilized during UBHM testing. <br />o. Final disposition of all process water, slurry, and up to 200 tons of dry material produced <br />by UBHM testing, including whether any of the material will undergo further processing <br />for its uranium content. <br />p. Expected amount of time between cessation of UBHM testing and backfilling of the <br />underground cavity. <br />q. Discussion of impacts to existing groundwater flow patterns in a future large scale <br />operation caused by the cement bentonite mixture used to fill the cavities. <br />This lack of detail renders the application incomplete and incapable of being properly reviewed <br />by the Division and the public. <br />Also, the applicant's Form 2 does not clearly describe which information is a change to the <br />original NOI or a change to a previous modification. For example, Number 12 Proposed <br />Disturbances appears to contain information that may be from the original NOI and/or from a <br />later modification, but there is no explanation to clarify whether this information is or is not a <br />change to previously- approved activities. <br />3. The proposed activity involves underground fluid injection, but the application <br />omits any mention of compliance with federal Underground Injection Control <br />regulations. <br />As authorized by the federal Safe Drinking Water Act, underground injection control regulations <br />promulgated in 40 CFR Part 146 categorize wells and regulate activities that can contaminate <br />underground sources of drinking water. The drill hole proposed to be used for UBHM testing <br />would likely be considered a Class III well, which includes wells that inject fluid for the <br />extraction of minerals. According to the application, the well and hydraulically jet -cut cavern <br />will be "within the Hansen Uranium Deposit ", and uranium ore will be extracted. <br />Such a well requires a UIC Class III permit from the U.S. Environmental Protection Agency, but <br />the application is silent on this matter. Since the Act requires compliance with all laws and <br />regulations of the United States before the Division can grant a permit, and the application does <br />not address compliance with UIC regulations, the application is incomplete. <br />CARD requests that the NOI modification application be denied by the Division due to <br />incompleteness and the fact that the proposed activity is not prospecting. <br />4 <br />