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in-situ treatment which may also reduce uranium concentrations.This type of activity would also <br /> cause site disturbance, and depending on what type of treatment is pursued, it may be more than <br /> just temporary disturbance. At the same meeting DRMS had expressed preference to not disturb <br /> areas that have been undergoing reclamation activities such as revegetation. <br /> In order to develop a closure plan with specific benchmarks that will govern activities leading to <br /> closure, HMC, WQCD and DRMS will all need to work together to determine what the <br /> definition of LPL will be and what can actually be achieved at the site in terms of uranium <br /> reductions. All parties will need to work together to be able to meet everyone's objectives which <br /> HMC looks forward to collaborating upon in the future. <br /> As mentioned in your letter, there are numerous complexities at the site that need to be <br /> considered. These include the north pit, overall site stability, waste rock sites,sediment removal <br /> and disposal from the Sedimentation Pond, the revegetation processes, site access during winter <br /> months,the lack of power at the site and the fact that uranium concentrations are heavily driven <br /> by precipitation and snow melt. These constraints will need to be taken into consideration to <br /> determine the acceptable level of disturbance and the activities that will be conducted to meet <br /> and define the LPL. <br /> If the LPL is determined as a BMP based or narrative standard, HMC will be able to implement <br /> the needed actions and will have met the standard. If the LPL is determined to be a numeric <br /> value, HMC will need to implement the appropriate actions,take time to monitor the results, and <br /> then determine if any additional steps are needed. As such, a numeric definition will take <br /> significantly more time to develop than the narrative or BMP based approach. <br /> Once the LPL is determined, HMC will be able to work with DRMS to determine what will need <br /> to be accomplished for site closure. At that point, HMC will be able to develop and update the <br /> closure plan that will identify the activities that will occur, a timeframe for completion, and the <br /> steps needed to move toward site closure. Currently, HMC requests that the update to the closure <br /> plan be delayed until January 2020 in order to provide time necessary to evaluate the LPL <br /> options. If a numeric LPL standard is required,this may have to be delayed further. <br /> We thank you in advance for your consideration. If you have any questions,please feel free to <br /> contact us. <br /> Sim5rely <br /> AV <br /> Holton Burns <br /> Homestake Mining Company <br /> Director—Closure, Water Treatment& Uranium <br />