2015-01-20_REVISION - P2009025 (6)

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Kay M. Hawklee 1739 Fremont County Rd 21A Canon City, CO 81212 January 17, 2015 Mr. Tim Cazier Environmental Protection Specialist Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 Via Email Re: Hansen Uranium Project, NOI P- 2009 -025, Modification #3 Dear Mr. Cazier: Thank you for taking my comments on the third proposed modification of NOI P- 2009 -025. I believe that by being situated within 1.5 miles of the NOI boundary, I am an affected party and my comments should be considered in this matter. First, I object to this modification on many grounds; but first, that this is not prospecting activity and does not fall under a prospecting NOI permit. Black Range Minerals (BRM) is proposing a test of Bore Hole Mining to produce 200 tons. The procedure is not recognized as "Underground Bore Hole Testing "; rather as, Underground Bore Hole Mining (UBHM). It is a mining activity and should be treated as such under a proper mining permit application for a Designated Mining Operation (DMO). However, the procedure for application of this type of testing does not exist as there has never been any Underground Bore Hole Mining (UBHM) for uranium in the United States; much less in Colorado. In addition, there is no regulatory provision for such a mining test to take place. The proper application procedure for this DMO must be clarified. This is the time for the Division to step back and seriously consider the consequences of permitting an experimental uranium mining method by an unproven Limited Liability Corporation. A slippery slope is to be entered into cautiously. Second, I believe that the actual technique of Underground Bore Hole Mining (UBHM) and In Situ Leach (ISL) are so similar in the resulting radiological changes to the underground environment that Underground Bore Hole Mining (UBHM) could and should come under the existing Hard Rock Mining Rules for In Situ Leach (ISL). The time has come to decide which rules will govern this experimental procedure. If UBHM cannot come under the ISL rules, new rules should be promulgated with the proper public discourse. IN SITU LEACH (ISL) rules should apps_ I would like to lay out a fact as to why - in our area specifically - I believe that UBHM is so similar in technique to In -Situ Leach that the Division could and should come to the conclusion that UBHM should fall under the ISL rules before an application is accepted.