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The Act defines a "mining operation" as development or extraction of a mineral from its natural <br />occurrences on affected land. Since the proposed activity is development rather than <br />prospecting, the applicant must apply for a reclamation permit. Because the proposed activity is <br />new and unproven, and involves the extraction of uranium, the Division should classify the <br />proposed activity as a Designated Mining Operation ( "DMO ") and apply the rules for DMOs <br />accordingly. <br />2. The description of the proposed activity in the application is vague and omits <br />necessary details. <br />Even if one assumes the proposed activity is prospecting, which it clearly is not, the application <br />is incomplete and lacks the details needed for the Division and members of the public to <br />determine what the applicant intends to do and to assess potential impacts to groundwater and <br />the environment. <br />The applicant's cover letter appears to imply that the proposed UBHM testing will be conducted <br />in a single drill hole, but there is no definitive statement that only one drill hole will be used. <br />In addition, the following details of the proposed activity are missing: <br />a. Location of the drill hole used for UBHM testing. The map provided by the applicant <br />does not identify the location of the drill hole or the location of related surface facilities <br />including rigs, pumps, holding tanks, and other equipment. <br />b. Distance between the drill hole used for UBHM testing and any groundwater monitoring <br />wells. <br />c. Procedures for baseline water quality sampling and testing from monitoring wells, <br />including a list of constituents to be analyzed. <br />d. Frequency of water quality sampling and testing from groundwater monitoring wells <br />during and after UBHM testing. <br />e. Procedures for reporting baseline water quality data and subsequent sampling and testing <br />data to the Division. <br />f. Water source for the injection water, expected quantity required, expected consumptive <br />use, and compliance with the State Engineer's regulations. <br />g. Water quality of the injection water and any expected treatment prior to injection or re- <br />injection. <br />h. Steps to be taken to ensure that any water storage tanks are adequately cleaned prior to <br />use and will not contaminate injection water. <br />i. Estimated amount of naturally- occurring dissolved oxygen contained in the injection <br />water. <br />j. Target depth for UBHM testing and the related geological formation(s). <br />