2015-08-03_REVISION - P2009025 (4)

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enough to understand the specifics of EPA's requirement for injection and recirculation downhole of uranium -laden produced water. o How is the produced water to be "decanted"? • Promises — not proof — havebeen offered to obtain a water well permit from Division of Water Resources (DWR). This permit must be proffered to DRMS before this activity is condoned, per rule 3.1.6 (a) compliance with applicable Colorado water laws and regulations governing injury to existing water rights. Black Range states that the "the flow of the water to the surface will be greater than the flow of water from the jet cutting tool." This statement validates the need for a water well permit from DWR, as more water will be taken out than is injected in. • Promise —not proof —of an application to DWR for anywhere from one to twenty four promised Monitoring Holes. o Dec. 16, 2014, BLR states: "Prior to bulk sample a groundwater monitoring well will be installed directly down gradient from and within the same formation and hydro -geologic horizon as the bulk sample zone." o Dec. 22, 2014, BLR states: Where possible, installation of groundwater monitoring wells will be in clusters. The clusters would typically range from 2-4 but up to 6 wells per drill pad location. Within the clusters, wells could be located within 15' to 20' of one another. o This statement allows for anywhere from oneto twenty four monitoring holes. Exactly how many holes will be used to monitor possible excursions and what is the exact placement of those holes at the surface? • Will highly -pressurized water force contaminated water up the approximately 1500, 35 - year -old Cyprus prospecting holes and/or up monitoring holes? • What is the test hole location in relation to the historic Cyprus holes? o The USGS also says that there is a possibility that when the 2600 proposed UBHM holes are drilled at the Hansen site those bore holes could encounter the approximately 1500, 35 -year-old Cyprus holes resulting in groundwater and process water excursions up the old Cyprus holes. • Promise — not proof —that the water in the cavern will provide "nearly the same roof support as if there were no cavity at all"; however, the cavity will be left open for 5 — 30 days. • Echo Park Formation water tested at 210 mg/L of Uranium. BLR claims that this is a low amount of dissolved uranium; however, it is seven times higher than the limit for my domestic water well within 1.5 miles. • Why was there no promise or requirement to line the drilling pits? BLR states: "Middle Tallahassee Creek and its [sic] run through center of the N01 area. 5-10% of the drill holes could be within 200 feet of the creek." 61 Page