2015-01-20_REVISION - P2009025 (6)

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• 103(5.7) (24.1) —In Situ Leach Mining means in situ mining for uranium through the in- place dissolution of mineral components of an ore deposit by causing a chemical leaching solution, usually aqueous, to penetrate or to be pumped down wells through the ore body and then removing the mineral- containing solution for development or extraction of the mineral values. Underground Bore Hole Mining is - in essence - the same process; especially, when considering this mining technique for the Hansen deposit. Please find attached a report from Geohydrologist, Adrian Brown, showing that there is 3150 mg/L of Bicarbonate in the Echo Park Formation, which contains the uranium mineral. His report was meant as a disclaimer which was given to people who were purchasing property in the area. It stated which aquifers should and should not be used for drinking water purposes. Whether or not it is the intent of BRM to use a chemical leaching solution during UBHM that is the case. In essence - due to the high level of Bicarbonate already present underground - the aqueous solution created during UBHM becomes a leaching technique. ISL expressly uses Bicarbonate as its leaching agent. The in situ Bicarbonate will be dissolved by the injected water and the leaching process will begin with no requirement to monitor excursions. Cyprus Mines was permitted to open pit mine the deposit in 1980. It is a well -known fact that Cyprus Mines had come to the conclusion that In Situ Leach would not be viable due to the numerous fractures in the geology of the area. BRM's own Power Point pictographs show the Picnic Tree Fault as running through the area's formations. ISL requires a confined aquifer and this is not possible. UBHM has no such requirement. The Geohydrology of the area must be studied in a comprehensive application before permitting can be considered. Potential for cross contamination of drinking water aquifers should be studied. Regardless of the intent to harvest uranium from the resulting aqueous solution, the same underground changes in the radiological environment will results as when performing an In situ Leach operation. Should the Division wait until after unintended yet inevitable consequences of a change in the radiological environment underground takes place before requiring the proper safeguards? For this reason, DRMS must make a determination as to which rules apply. In this case, due to the high level of Bicarbonate which has the same effect as the In -Situ Leach process, the ISL rules should apply. Applying the ISL rules would help protect the area's four drinking -water aquifers and that of the Arkansas River which is 6 1/ miles down - gradient of the proposed mine. This is the first decision that should be made regarding an experimental type of uranium mining that has never been performed in the United States. It has been performed in Canada at Cigar Lake where the ore is frozen before extraction. This method is not possible in Colorado; therefore, this decision should be made with great care at this very stage in the process and all actions must be deferred until a determination is made as to which rules will be applied. If DRMS does not consider UBHM to be ISL, then new rules should be promulgated to govern UBHM with open and proper opportunity for public discourse. No DRMS requirement for monitoring of excursions: In July of 2012, BRM announced the intent to use Bore Hole Mining. At that time, I submitted the