2015-08-03_REVISION - P2009025 (4)

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any baseline site characterization activities until the Office approves of the plan for conducting such activities and a financial warranty is posted pursuant to Rule 4. [my emphasis] (2) The Office may retain, and the prospective applicant shall pay the costs of, an independent third -party professional expert to oversee baseline site characterization, monitor field operations or review any portion of the information collected, developed, or submitted for the Baseline Site Characterization and Monitoring Plan to be included in a permit application as follows... Technically, the uranium from the produced uranium -laden solution will not be extracted for its mineral values. However, the underground changes to the radiological environment — downhole conditions and downhole risk of excursion — are the same as for ISL mining due to high levels of Bicarbonate present in the Hansen mineral deposit, 3150mg/L, which will be mixed with high levels of oxygen -pressurized water (see attached Adrian Brown letter),In reality, the danger of excursion of contamination will be the same as for ISL mining; with no language requiring containment of the solution, which is the reason for protective language in the Regulations instituted for ISL mining: 1.1 DEFINITIONS(12.1) —Description of ISL Mines means that description required to be in applications for all in situ leach mining operations of at least five (5) in situ leach mining operations that demonstrates the ability of the applicant to conduct such a proposed mining operation without any leakage, vertical or lateral migration, or excursion of any leaching solutions or groundwater -containing minerals, radionuclides, or other constituents mobilized, liberated or introduced by the in situ leach mining process into any groundwater outside of the permitted in situ leach mining area. A solid first step — before approving a test of an experimental uranium mining process — would be to determine which current rules might apply to this process. If the Division allows the experimental uranium mining test; then, at a later date, determines that protective rules such as 1.4.3 should be followed for UBHM, the Tallahassee Area has once again been the victim of a situation in which a baseline cannot be established due to prior activity. Myself and other Tallahassee Area residents feel as though we are the guinea pigs for the uranium mining industry. If UBHM is determined not to fall under the ISL rules; then rules must be promulgated for this type of activity and all actions must cease until protective measures are in place that are in keeping with the Divisions and the MLRB's intent to protect groundwater quality. By allowing a test of an experimental uranium mining method under a prospecting NOI, the Division has side-stepped a necessary protection: the Environmental Protection Plan. 31 Page