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Black Range Minerals submit a full groundwater remediation plan to correct any reductions in <br />water quality that occur after the UBHM experiment is conducted. <br />Black Range Minerals has proposed the first of what may be numerous UBHM or other <br />hydraulic -mining proposals in Colorado. At the sounds of it, pumping a high-speed jet of water <br />into a uranium ore body and pumping back out a radioactive slurry through a hose seems like a <br />prime opportunity to make errors with water and inadvertently create contamination problems. <br />An abundance of caution in the form of concrete data is in order here, and the burden is on the <br />operator to prove this new form of technology is feasible so that the results may be studied in the <br />future in order to improve upon the original concept. <br />2. Black Range Minerals did not provide adequate information about the volume and <br />source of water to be used, nor the volume of slurry material to be excavated, nor the <br />volume of waste material to be generated at the Hansen Project. In its deficiency response, <br />Black Range Minerals indicates that between 10,000 and 30,000 gallons of water supplied by <br />Canon City will be used at the project.2 First, this is problematic because a precise amount of <br />water should be identified in order to accurately determine how much oxidation will occur <br />during the injection process and extraction of mineralized slurry. Second, Black Range Minerals, <br />despite being asked specifically for the volume of water that will be used, does not identify the <br />total volume of uranium slurry to be created as a result. All that has been stated in the review <br />process is that 200 tons of uranium ore will be removed from the excavated cavern, but what <br />total volume of slurry material will be created, requiring special handling and haulage, is still <br />unknown. <br />3. The additional permits required from other government agencies should be submitted <br />and placed in the public permit file before the NOI is authorized. Due to the controversial <br />nature of this proposal and the untried and experimental aspects of the mining technology to be <br />used, the requirement that Black Range Minerals obtain and comply with all other permitting or <br />licensing requirements of local, state and federal agencies should actually be demonstrated in <br />public view. See MLRB Rule 5.3.6. Most critically, the deployment of UBHM technology will <br />require a Class III Underground Injection Control permit from the Environmental Protection <br />Agency, and Black Range Minerals should be required to obtain this permit first as a condition <br />of the NOI. At the current time, EPA has not indicated that a draft UIC permit has been <br />submitted or developed. Other permits required for this project are a Fremont County use permit, <br />demonstrated water rights, state water quality permits, and an approved Plan of Operations from <br />the Bureau of Land Management. <br />4. How contaminated water and waste streams generated by the UBHM process are to be <br />handled and disposed should be fully disclosed and planned for before the NOI is <br />approved. In Black Range Minerals' response to the Division's adequacy review, a final method <br />of waste disposal for the decanted jet water is not specified but rather the operator indicates that <br />it "will be either used for the cement backfill, shipped offsite for disposal at an appropriate waste <br />facility, or stored onsite and allowed to evaporate." 3 Further more, any waste water resulting <br />2 Ibid, p. 5, response to question 11. <br />3 Ibid, p. 3, response to question 5. <br />