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uranium in the United States and is an experimental and unregulated emerging mining <br />technology that bears a close resemblance to in-situ leach extraction. <br />INFORM raises the following concerns and issues for consideration at the appeal hearing: <br />1. The Division does not have adequate information to determine whether the hydrological <br />balance of the Hansen Project will be protected if additional activities are approved at the <br />site. The Colorado Mined Land Reclamation Act at C.R.S. 34-32-116(7)(g) requires that <br />"Disturbances to the prevailing hydrologic balance of the affected land and of the surrounding <br />area and to the quality and quantity of water in surface and groundwater systems both during and <br />after the mining operation and during reclamation shall be minimized." <br />The UBHM project will require drilling a borehole through at least three water -bearing <br />zones and extracting uranium slurry back up. Through the injection of pressurized water in large <br />volumes, the oxidation of uranium in the ore body can be expected to contaminate the water used <br />in this process. A full and complete geohydrological characterization of the Hansen Project area <br />is still not part of the Notice of Intent modification proposal but should include such information <br />as the velocity and direction of flow between water -bearing zones, the depths and specific <br />locations of water -bearing zones, the types of soil and rock that allow water to move between <br />zones that are present, and the connections to surface hydrology. Without this, the potential <br />impact to the Tallahassee Creek basin's groundwater supplies cannot accurately be analyzed or <br />mitigated. The Division should require additional characterization studies and groundwater <br />monitoring in advance of authorizing the amendment. Although Black Range Minerals plans to <br />install monitoring wells downgradient to the location of the borehole in order to sample ground <br />water, the wells have not been installed yet and the specific locations and monitoring program <br />have not been provided.' Before mining activities begin, these specific wells should be installed <br />and baseline data should be gathered for a minimum of five quarters. Under the Division's Hard <br />Rock/Metal Mining Rule 3.1.7(7), the Division is authorized to require a ground water <br />monitoring program on a case-by-case basis "where an adverse impact on groundwater quality <br />may be reasonably expected." <br />Specifically in relation to Notices of Intent, the Rules authorize the Division to establish <br />numeric protection levels for ground water supplies as well as imposing conditions on the NOI. <br />[Rule 3.1.7(2)(a)] Further, the Rules require the Division to impose conditions that will be <br />protective and prevent the lowering of ground water quality that impacts future uses. [Rule <br />3.1.7(2)(c)(i-ii)] The Division has not specified numeric limits for contaminants that Black <br />Range Minerals must meet in the likely event that groundwater supplies will become <br />contaminated as a result of the activity. So far, specific numeric limits are only being required for <br />the contents of the mud pits at the drill site. Numeric standards for the groundwater should be <br />specifically imposed as a condition of authorization. A condition should also be imposed that <br />' Please see Black Range Minerals' response to DRMS' deficiency review, dated April 29, 2015, on page <br />2, response to question 3. Available in the permit file at <br />http://drmsweblink.state.co.us/drmsweblink/0/doc/ 1066884/Electronic.aspx?searchid=339350b0-caf3- <br />49f2-9255-e990U7db085 <br />14 <br />