2015-02-12_REVISION - C1981014 - Laserfiche WebLink

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George V. Patterson, Energy Fuels Coal, Inc. Page 14 February 12, 2015 The material submitted by EFCI does not analyze the available data for trends in water quality. Chemical analyses of roof and floor samples are described in section 2.04.6 of the PAP. The following statement was made to summarize the findings: "Moderately alkaline pH values will decrease the potential for dissolution of soluble metals including iron, nickel and zinc and should result in no significant potential for adverse hydrologic impacts. Sample pH values indicate no potential for development of acidic conditions and only marginal potential for development of excessively alkaline conditions in the hydrologic system" (page 2.04.6 -23) To date it has not been possible to verify these predictions. i) Please provide a detailed analysis of the impact of the Southfield Mine on groundwater quality, allowing the identification of trends in the data (perhaps a selection of individual water quality parameters could be plotted against time, for example: TDS, [Fe], [Mn], [Se]...) ii) Please include data collected from each groundwater monitoring point in the analysis, including MWNW (which may be dry), in accordance with the approved water monitoring plan described in Exhibit 25, and make a comparison to predictions made in the PAP. 2) Surface Water Three streams drain the mine Southfield Mine permit area. Newlin Creek is considered a perennial stream from its headwaters to the point of diversion (upstream of the permit area), but the entire base flow is diverted by the City of Florence, rendering it an ephemeral stream below this point. Magpie Creek and Second Alkali Creek are both ephemeral streams. a) Surface Water Monitoring There are two parts of the approved water monitoring program that relate to surface water. The first is sampling of streams for water quality and flow at five locations: upper and lower Magpie Creek; upper and lower Newlin Creek; and Second Alkali Creek, near MW65. Sampling frequency is semi - annual on Newlin Creek and opportunistic, whenever flows allow, on the other two streams. Prior to 2004, sampling was reported on a quarterly basis. EFCI provided stream flow data from 2000 through 2013 with the TR43 application. During this period no flow was reported on either Magpie Creek or Second Alkali Creek, with one exception: in the second quarter of 2004 flow in upper and lower Magpie Creek was reported as "minimal' (a volumetric flow rate was not reported). Table 3 lists the flow data for Newlin Creek that is found in the TR43 application. The TR43 data for all three creeks is in agreement with past Af Rs. The data shows that on the three occasions when larger flows were recorded (greater than 3 cfs), there was essentially no difference between the upstream flow and the downstream flow. For recorded flows less than 3 cfs, the reach between the two stations acted as a losing reach, as some of the flow infiltrated into the creek bed.