2015-08-03_REVISION - P2009025 (4)

Home Browse Search

Protective rules "regardless of size": I do not believe that prospecting regulations were intended for an experimental test of a uranium mining method that has never been performed in the United States. There is no provision in the NOI regulations for an Environmental Protection Plan which should be required for this type of mining experiment. The extent and nature of this test is beyond the scope of the intent of a prospecting NOI.Before there are any unintended consequences to my and other water wells, care should be exercised. By allowing even a test of UBHM prior to determining statutory regulations for such activity — it is possible that the cart has been placed before the horse. Having searched DRMS rules, I find that the current situation most -closely matches that of Rule 1.4.3. Regardless of the intent of the operator, the underground hydrologic consequences are the same as that of In Situ Leach operations whichrequires a baseline site characterization and on-going monitoring plan; prior to any activity "regardless of size."I concur with the Mined Land Reclamation Board's decision in promulgating Rule 1.4.3 that protections of groundwater quality when dealing with uranium should begin at the pre -application level when water will be used to dissolve uranium. I believe that this same standard should be used in conjunction with Underground Bore Hole Mining (UBHM). Therefore, the time is upon the MLRB to decide whether or not UBHM is similar enough in essence toln Situ Leach Mining (ISL) mining to require pre -application measures such as pre - application requirements. This is the time for the Board to step back and seriously consider the consequences of permitting an experimental uranium mining method by an unproven Limited Liability Corporation. A slippery slope is to be entered into cautiously. Retention of a Third Party Expert is needed in conjunction with consideration of an experiment concerning a new uranium mining method: 1.4.3 Pre -Application Requirements - All In Situ Leach Mining Operations Regardless of Designated Mining Operation Status — Reclamation Permit Operations — Retention of Third Party Expert — Baseline Site Characterization and Plan for On -Going Monitoring (1) (a) All prospective applicants for any in situ leach mining operation, regardless of size or designated mining operation status, shall confer with the Office prior to conducting any baseline site characterization activities. At such conference, the prospective applicant shall submit for the Office's approval a plan for conducting the baseline site characterization and for on-going monitoring of the affected land and surface and ground water and reclamation and financial warranty requirements. The plan shall include all of the activities the prospective applicant proposes to conduct for the baseline site characterization, the methods of conducting such activities, including the operating procedures and standards, the proposal for on-going monitoring of affected land and water, and applicable reclamation requirements pursuant to Rule 3. The prospective applicant shall not conduct 21 Page