2015-08-03_REVISION - P2009025 (5)

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somewhat lessor extent in the aqueous UBHM cavern with a high level of molecular oxygen along with the known high concentration of bicarbonates in the ore. Just how much of the uranium oxide would be solubilized into the ore fragment/water slurry in the cavern cannot be forecast but some significant fraction of the uranium will be chemically converted. BLR may have obtained experimental data about this from its consultants but it has not been disclosed. Once solubilized uranium oxide is in the water in the cavern, the question is "where would it go?" BLR states in its response to the Deficiency Notice that all of the slurry water would be brought to the surface by suction and that, due to the annular seals protecting the borehole casing, there can be no leakage into the aquifers. What BLR did not discuss, and DRMS staff did not inquire about, was the fact that the excavated cavern is not confined or cased, its outer walls consist of the same sandstone that had been fragmented, and the high pressure (or high velocity) water stream will continue to impact the cavern walls. It is unknown for what period of time the radiologically active water would remain in the cavern (the "dwell" time). Since BLR has not disclosed the hydraulic conductivity, permeability or porosity of the Hansen orebody sandstone, the amount of potential migration of the mobilized uranium oxide and other heavy metals into the local aquifers cannot be determined and cannot be controlled even if detected. There are at least two of the many domestic water wells within approximately one mile of Hansen (outside the South T -Bar NO1 boundary) drilled to 600+ feet (the Hansen orebody is at approximately 650 feet). Neither well currently has significant uranium concentration nor high levels of TDS in the drinking water despite being presumed to be drawing from the same aquifer as the orebody, since there has not yet been any significant uranium mobilization. Furthermore, since there has never been published a map of the many Tallahassee watershed aquifers there is no understanding as to the degree of cross - communication among them or with the many springs in the area. In other words, there is currently no data that would allow a forecast of the potential for groundwater contamination or the threat to the many nearby domestic water wells. Other Unresolved Issues To the best of TAC's knowledge, BLR has not made application to EPA Region 8 for a Class III Well Underground Injection Control Permit. Since an Aquifer Exemption would have to be granted prior to issuance of a UIC permit, the specific aquifer (or portion thereof) would have to be shown not to be a current or potential future source of drinking water. Much of the information that would be required by EPA is the same as what would be required for an Environmental Protection Plan under a DMO Permit. TAC requests that the NO1 modification not be approved until the complete UIC permit application has been submitted by BLR to EPA and evaluated by the Division. The source and proof of water for the BLR activity is not resolved. The quoted quantity of water required to drive the UBHM process is at odds with TAC's independent information as to the amount required per hour to fragment a sandstone orebody to yield 200 tons of ore. Also, the number of hours that the UBHM rig would be in operation is not disclosed. Considerably more than a small number of water trucks from Canon City would surely be required even if slurry water is reused. BLR has not provided any evidence that Canon City water would be available. If an alternate source of water is contemplated, the State Engineer would have to approve a new SWSP. A valid contract, including an estimate the total quantity of new water required for the test, should be submitted to the Division prior to approval. 7