2015-08-03_REVISION - P2009025 (4)

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Staff Requirements: The requirements by DRMS staff border on – but do not rise to the level of—requirements of a Designated Mining Operation (DMO) and/or an In Situ Leach Mining operation due to the amount of the 200 ton sample. DRMS staff's question "13) Groundwater Baseline Monitoring" asks for monitoring data which has been collected for the purpose of submitting a mining application. Yet Black Range Minerals (BLR) stops short of submitting a full mining proposal; thus, BLR is circumventing the need for an expensive Environmental Protection Plan (EPP) causing concern for nearby residents. Exactly where will the test be performed? • Monitoring data shows that the dissolved uranium levels are in places over the regulatory limit (see MW -27-290, page 1 of 13, in BLR letter dated April 9, 2015). • MW -27-291 data shows that the levels are perilously close to the .03 mg/L limit and exceeded the limit in the final quarter of 2014. • MW -27-292 was below the limit for every quarter of 2014. • MW -27-293 was above the limit for every quarter of 2014. • MW -27-294 was above the limit for every quarter of 2014. • MWC-109 was at times below and at times above the limit in 2013 and 2014. • MWC-21-150 located up -gradient was far below the limit upon every test. (Possible background test station?) • MWC-21-202 located down -gradient of MWC-21-150 was double the allowed limit upon every test. • MWC-21-210 was located near MWC-21-202, but was below the limit upon every test. • MWC-21-216 in the same grouping as the two holes above was below the limit. The depth of Monitoring Holes was not provided on the letter, which could assist in understanding the test results. But it is not clear in the staff's questions, or in the submittals by BLR if there was any analysis of the data provided. Once again begging the intervention of a Third Party Expert. Staff's question on hydrogeology in the May 12, 2015, Notice of Deficiency asking, "Please describe how the aquifers above the ore zone are protected from cross contamination; especially consider the high pressure of the proposed system." The Division's asks for drawings, specifications and analyses to demonstrate the water lines have sufficient factor of safety against rupture for the high pressures involved. BLR's response was to send an advertisement of the Kinley system which doesn't include specifications and analyses that apply to the Division's question. Staff asks questions alluding to the possibility of excursions: "b. Please indicate the maximum expected horizontal and vertical extents of the high pressure water intrusion;" but stops short of 41 Page