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requiring ISL pre -application requirements for the retention of Third Party Expert to assist in <br />planning for monitoring: <br />1.1 DEFINITIONS (20) (b) Any actual or imminent malfunction or nonperformance of any structure for in <br />situ leach mining operations designed to detect, prevent, minimize, or mitigate adverse impacts on ground <br />water, human health, wildlife, or the environment; <br />1.4.3 (2) (d) Monitoring Plan; (d) The prospective applicant shall pay the reasonable costs incurred by the <br />Office and the expert; <br />All of these questions from the Division's staff point to a larger issue —this process could harm <br />the drinking water aquifers; however, proper precautions will not be in place due to lack of an <br />Environmental Protection Plan. <br />No requirement for containment: <br />It should be noted that ISL is performed in a confined aquifer that is condemned after the <br />activity. By its very nature, UBHM has no such confinement. Only a promise of "short contact <br />time" (pg. 4, BLR Response to Deficiencies dated 4-29-15). However in a contradictory <br />statement on page 2 of that document BLR states that the cavern may be left open from 5-30 <br />days. During that time frame, contamination from even one test of UBHM could spread — <br />unchecked. BRM has already said that they cannot do ISL in our area because the geology is too <br />fractured for ISL. On one of their diagrams, BLR showed the Picnic Tree Fault. Could an <br />excursion of contaminated water follow fractures and faults? I would prefer to have a Third <br />Party Expert's opinion to allay fears for my drinking water. <br />Bond Amount: <br />Additionally, prospecting bond amounts are not as protective as for Designated Mining <br />Operations (DMO). By slipping an experimental uranium mining test underneath a NOI, the <br />bond amount is severely decreased. Would the prospecting bond amount be sufficient for <br />reclamation of contaminated groundwater? <br />Promises — not proof: <br />• A promise — not proof — has been offered as to a contract for water supply from Canon <br />City Water Department. <br />• A promise —not proof —has been offered to obtain an EPA UIC Class III Well Permit. <br />o BLR stating that it "will work with EPA" is not the same as an actual permit. <br />o "Dependent on the potential UIC permit conditions, this water will be ...." <br />Appears to be a statement suggesting that BLR has not "worked with EPA" <br />51 Page <br />