2015-08-03_REVISION - P2009025 (5)

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Designated Mining Operation, including an Environmental Protection Plan -- especially the sections relating to the protection of groundwater integrity. We recognize that the requirements for authorization of a Notice of Intent for Prospecting are significantly less rigorous than those for a Reclamation Mining Permit, since, typically, the potential impact upon the environment is much lower. We submit that the situation in the case of UBHM is different. UBHM proposes the injection of water directly into the face of the underground uranium orebody -- in some ways similar to In -Situ Leach Solution Mining (ISL). The major differences, however, are that it is the intent of the water injection to fragment the orebody for recovery rather than to intentionally solubilize the uranium oxide; that the pressure, the rate, and the absolute quantity of water introduced underground are significantly greater than with ISL; and that there is little or no ability to control or mitigate any excursions of contaminated water into the aquifer and nearby domestic water wells. Arguably, UBHM operations may pose a greater threat to the groundwater than ISL. TAC believes that DRMS staff inadequately pursued the potential threat to the groundwater and the sole source of local drinking water in the Tallahassee watershed. There are a number of individual issues that were either not raised in the staff review, questions responded to by BLR with bald assertions without any data in support, or statements by BLR purporting to answer science related questions that were either incomplete, off point or incorrect. The Rules require the Operator, whether for a Prospecting NO1 or a Reclamation Mining Permit, to comply with Rules 3.1.6 and 3.1.7, to "minimize impacts to the hydrological balance" and to require specific protects for groundwater —whether mining plan or NO1 Groundwater Hydrology and the Hydrogeology of the Tallahassee Watershed It is known, and BLR acknowledges, that there are four to five aquifers that can supply drinking water to the more than six -hundred rural residential parcels in Tallahassee. At least one-third of the parcels are permanent or part-time seasonal residences. Considerably more than one -hundred domestic water wells have been drilled since the 1980s supplying the sole local source of drinking water. According to the hydrologist at the Pueblo Office of USGS, there has never been a mapping of the Tallahassee aquifers and there has been no determination of the extent of cross -communication among them or with the many local natural springs in the area. The domestic water wells in the area range in depth from 200 to greater than 600 feet. The limited sampling of a small number of those wells by BLR over the past number of years has varied in results and cannot be used to establish any definitive information of the hydrological balance in the area. BLR has constructed a total of five monitoring wells over their eight years of activity in Tallahassee, and has reopened seven of the numerous monitoring wells that were originally drilled by Cyprus Minerals more than thirty-five years ago. The sporadic and unscientific domestic well sampling program is not identified as to well location and cannot be used to map the aquifers. The minimal hydrologic mapping information requested in the first NO1 modification review in 2012 for the immediate vicinity of the Hansen site was never supplied to the Division due to BLR's withdrawal of the application, and was not requested again as part of this modification review process. Other than vague reference to the construction of an undisclosed number and location of new monitoring wells as part of the UBHM pilot 4