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Pitch Reclamation Project Colorado Mined Land Reclamation Board — 2016 Annual Reclamation Report <br /> achievable for Indian Creek, which is the underlying uranium site-specific standard. Following expiration of <br /> the Temporary Modification on June 31,2015,the underlying site-specific narrative standard of LPL applied, <br /> which has the potential to be specifically quantified by the Commission based on the HMC technical <br /> evaluations. <br /> In response to these regulatory changes, HMC initiated technical evaluations to support development of <br /> the LPL-based narrative standard on Indian Creek.An integral component to establishing a reasonable and <br /> defensible LPL is development of BMPs for uranium load reduction. Work performed since 2013 has <br /> established a fundamental understanding of surface water and groundwater flow and geochemical <br /> conditions at the Pitch Reclamation Project. Specifically: <br /> • An initial conceptual site model (CSM)was developed to provide an understanding of the natural <br /> and anthropogenic sources of uranium at the Pitch Reclamation Project as well as the <br /> geochemical processes that control uranium concentrations in surface water and groundwater. A <br /> summary of the CSM was provided to the WQCD in August 2014. <br /> • With the CSM established in 2014 an alternatives evaluation was performed to assess viable <br /> clean water diversion, uranium source control, in-situ, and passive/semi-passive options to <br /> achieve uranium mass load reduction and establish the LPL for uranium at SW-33. <br /> • "Proof of concept" bench testing performed in 2014 demonstrated that addition of phosphate(as <br /> pH-neutralized phosphoric acid)to the Pitch Reclamation Project surface water and groundwater <br /> resulted in rapid and near complete immobilization of uranium. As a result, phosphate-based <br /> treatment was identified as a primary means of achieving source control in the underground mine <br /> workings and North Pit Lake. <br /> • In 2015, initial field-scale pilot testing of in-situ source treatability in the underground workings via <br /> phosphate injection was implemented to investigate the viability of full-scale treatment at the high <br /> elevation mine site with limited year-round access. <br /> • In 2016, the field-scale pilot testing activities were expanded to include larger-scale phosphate <br /> injections in the underground workings, injection pilot testing in the Indian Rock Dump, and <br /> testing of solid-phase reactive media for achieving dissolved uranium removal in a downstream <br /> ETC approach (Photographs 26 through 30). <br /> The knowledge gained from pre-design pilot-testing and associated monitoring,conducted during the 2015 <br /> and 2016 field seasons,will be used to design, permit,and implement load reduction/treatment approaches <br /> to establish the LPL for uranium. <br /> 28 <br />