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D) Will the Division look at constituents from the perspective that some may be over <br /> limits naturally? Selenium background levels may very well fit this category. <br /> E) They propose to use the Nevada Meteoric Water Mobility Procedure instead of <br /> the SPLP test. They feel the SPLP is too aggressive and by grinding the material <br /> down to -100 it releases way more of constituents than will naturally occur. The <br /> NMWMP does not use as fine of a grind and the acid solution is more <br /> representative of natural rain water in Ph than the SPLP. Would the Division <br /> have an issue with this? It is still conservative in nature but more representative <br /> of the material on the ground. <br /> As noted above, Energy Fuels is actively gathering samples and needs guidance from <br /> staff as soon as possible. Their plan is to gather the information and submit a"rough <br /> draft"to the Division for initial analysis and comments prior to finishing up the mining <br /> permit application for submittal. If the Division after review decides the project must be <br /> submitted as a DMO they are fine with that. However, their hope is to be able to address <br /> as much of the issue as possible and submit plans that would keep them out of that <br /> designation if possible. They think they can submit as part of their mining and <br /> reclamation plans measures that will mitigate any environmental issues upfront and avoid <br /> the DMO moniker and hopefully reduce objectionable plans. <br /> Your review and reply will be much appreciated. We have already discussed a field visit <br /> to this site and others in the near future. With the latest developments, I think we should <br /> schedule that field visit at your earliest convenience. <br /> Thanks <br /> Russ Means <br /> EPS / GJ Field Office. <br /> Cc: David Berry, Acting Supervisor for Division of Reclamation <br /> Cc: Carl Mount,North Team Senior Environmental Protection Specialist <br /> Cc: Bob Oswald, South Team Environmental Protection Specialist <br />