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Bore Hole Mining (UBHM); especially given the experimental nature and the unclear regulatory <br />status of this endeavor. <br />. Rules recap• <br />• Neither the Mined Land Reclamation Act nor DRMS Hard Rock mining rules contemplate <br />this type of mining test. <br />o Testing an experimental uranium mining method was never meant to take place <br />under a prospecting NOI. <br />• Mining regulations for UBHM have yet to even be contemplated; much less, written and <br />placed into law. There are sufficient similarities between the threat to groundwater <br />quality between ISL and UBHM that ISL rules should be adopted. <br />• Even without intent to recover uranium from the resulting solution — underground <br />conditions causing dissolution of uranium in the injected water is a fact. <br />• It might be determined that UBHM is so similar in the underground results it creates to <br />In Situ Leach (ISL), that the ISL rules should apply in order to protect groundwater. <br />o ISL rules require a Third Party Expert to assist in placement of Monitoring Holes <br />at the application phase. <br />o If, at a later date it is established that ISL rules should be required, this provision <br />would be rendered moot. This provision should be instituted at the time it was <br />intended to be performed; lest, the Tallahassee Area be — once again — <br />considered only after an activity disturbing uranium has already taken place. <br />• Does the "Shaker" shown on the Kinley diagram, in Attachment 4 to Form 2 of MOD03 <br />dated Dec. 22, 2014, constitute uranium milling; therefore, requiring a Radioactive <br />Materials License? <br />• To what extent will naturally -occurring carbonates solubilize the uranium, and does this <br />inevitability in produced water constitute 11e2 by product material; thus constitute <br />uranium milling requiring a Radioactive Materials license? <br />Closing requests: <br />I, respectfully request, that the MLRB require BLR to produce the necessary documentation of <br />permits and contracts from Fremont County, Canon City Water, DWR, and the EPA before <br />allowing this experiment to proceed. Because BLR failed to obtain a County Permit in 2007. <br />Drilling 70+ holes without a Fremont County Conditional Use Permit or the necessary DWR <br />water source permit it is not an unreasonable request for the MLRB to require such <br />documentation. <br />81 Page <br />