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key requirement for the process is a 22" borehole in order to accommodate both the hydraulic jet <br />cutting tool as well as the ore sample return system within the same bore hole. The first modification <br />request to conduct a UBHM test, which was ultimately withdrawn by BLR, sought approval for a 24" <br />bore hole diameter. NOI Modification 02 authorized an expansion of bore hole diameter from 6" to 12" <br />while this current request does not include any changes to bore hole diameter. It is not explained in this <br />application how the sample collection could be done with a 12" bore hole. <br />Nowhere in the proposed modification is the source of water for this activity disclosed. TAC has been <br />informed by an independent expert in Bore Hole Mining that up to 50,000 gallons per hour ( -800 <br />gal /minute) would be utilized in a single excavation of a sandstone cavern. BLR is not currently <br />authorized by DWR to draw water from any local streams or from the groundwater. The lesser amounts <br />of water required for previous drilling activities were trucked in from the Canon City Municipal Water <br />Department. It is unclear whether the water department would approve the acquisition of a much more <br />massive quantity of water for the purpose of this proposed activity. <br />The modification describes the drilling of a standard bore hole to the target depth. In the detailed BLR <br />description of UBHM, there is the requirement to case the bore hole to maintain its integrity during the <br />injection of the high pressure water. The likelihood of failure of an uncased bore bole is not considered. <br />The proposed activity is not a standard bore hole drilling to obtain core samples. Rather, it is the <br />construction of an injection well. There is no reference in the modification request or Mr. Siglin's cover <br />letter of BLR applying for the required authorization from both DWR and the EPA UIC Program. <br />The UBHM process requires very high pressure water to be delivered to the orebody by the jet cutting <br />tool. BLR and Kinley have reported, as confirmed by TAC from an independent source, that the water <br />would have to be pressurized up to one - hundred or more times standard atmospheric pressure in order <br />to fragment the sandstone at the Hansen site. As a result of basic Physical Chemistry principles, this <br />pressurized water will contain a substantially higher concentration of dissolved air -- approximately 20% <br />of which is oxygen -- than normally occurs in water. High concentration of oxygen in water, coupled with <br />the known existence of a significant amount of bicarbonates in the Hansen ore body, will create a highly <br />oxidizing environment in the cavern as the jet cutting tool is fragmenting the ore. As the water interacts <br />with the freshly cut surfaces of the ore fragments, some unknown but significant fraction of the uranium <br />oxide will be chemically converted from the insoluble to the soluble state and dissolved into the water. <br />The amount converted will depend on many undisclosed factors, including the amount of time the water <br />remains underground in the cavern in contact with the ore fragments -- the "dwell time ". <br />The radiological environment underground, in the cavern, will be changed by this process and the water <br />brought to the surface will contain dissolved uranium oxide and what other heavy metals found in the <br />ore body, i.e. iron, arsenic, etc. As this water is re- pressurized and recirculated into the bore hole, the <br />level of radiological and heavy metal contamination will increase. In addition, some unknown <br />percentage of this highly pressurized water will inevitably be forced out of the unconfined cavern into <br />and through the surrounding sandstone aquifer. The extent of this excursion of contaminated water will <br />