2015-08-03_REVISION - P2009025 (5)

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test, there has been no attempt by BLR to provide any rigorous information about the hydrological environment in the area nor any demonstration that their proposed activity would not adversely impact the local groundwater as was requested in the first NOI modification review by DRMS staff. In the BLR response to the latest adequacy review it was argued that migration of any water from the UBHM cavern would not occur due to the low hydraulic conductivity of the sandstone aquifer. No data was provided to support this claim. At the very least, BLR should be required to provide "darcy" measurements to describe the porosity and permeability of the aquifer in the area of the orebody as is routinely required prior to approval of ISL activities, as well as data supporting the "low hydraulic conductivity" claim, and specific detail as to their intent to construct additional monitoring wells. The Technological Details of Underground BoreHole Mining In its numerous announcements about UBHM, including its "cartoon" animation [https://www.youtube.com/watch?v=rptNdp8NLcs&feature=youtu.be], BLR describes the procedure proposed to be employed at Hansen. However, the company has avoided disclosure of a number of key technical details. Similarly, BLRs consultant, Kinley Exploration [www. kin leyexploration.com], in both its website and commercial literature does not provide much detail, especially as related to uranium recovery. The UBHM process is the injection of pressurized water into the underground orebody to create a slurry of ore fragments and water to be recovered on the surface. The key missing data are the degree of pressurization of the water and the rate that it is applied that would be required to break-up the sandstone into the proper size pieces for recovery. Other than the claim of 10-30,000 gallons of water to be purchased from the Canon City Water Department, BLR has never discussed water requirements other than proposing to reuse and reinject the water recovered from the slurry. The pressurization of the injected water for this test has not been disclosed. Kinley web statements refer to a range from less than1000 to as high as 5000 psi for various potential applications of UBHM — not specifically for uranium recovery. TAC, in the course of its independent research, identified a competitor company to Kinley that offers a process virtually identical to that described by BLR and Kinley. Borehole Mining International, based in Littleton, CO [www.boreholemining.com], and its founder, Gregory Abramov provided TAC with detailed information about using borehole mining for uranium recovery in an email string in 2012 [Emails Abramov/Alter, 2/18/20121. Mr. Abramov confirmed that friable sandstone hosted uranium ore at —650 feet underground could be fragmented and brought to the surface with the injection of 200 cubic meters per hour of water [approximately 52,800 gallons/hour] pressurized to 80 to 100 Atmospheres [approximately 1000-1500 psi or 80-100 Bar]. He also discussed criteria for recycling the water and the estimated performance characteristics depending on whether or not there would be groundwater infiltration into the cavern during operations. This specific data is crucial to gaining an understanding of the geochemistry that will occur during operation of UBHM. Obviously, the information obtained by TAC from an outside source is not directly applicable to the BLR process; it should be considered merely a guide. BLR and its consultant should be required to provide the specific information prior to the process being authorized.