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Mr. Dustin Czapla <br /> Page 3 of 7 <br /> • Advancement of 25 characterization boreholes and reagent injection/monitoring <br /> wells within the former Pinnacle Mine Dump boundary (Figure 3) in a phased <br /> approach between 2019 and 2021. Elevated uranium concentrations were <br /> identified in this area during 2018 characterization activities. <br /> o In 2019, up to five characterization boreholes will be advanced. Up to three <br /> of the boreholes may be converted into injection/recirculation/monitoring <br /> wells. <br /> o In subsequent years (tentatively planned for 2020 and 2021), additional <br /> drilling will be conducted in this area, including installation of up to 20 <br /> characterization boreholes and conversion of up to 12 of the boreholes into <br /> injection/recirculation/monitoring wells. <br /> • Expanded phosphate-based injections into the Indian Rock Dump. Associated <br /> activities will include the installation of piping to connect the newly installed <br /> Pinnacle Mine Dump wells to the treatment systems installed in 2017. <br /> • Continued operation of the phosphate injection system at the underground mine <br /> workings and the engineered treatment cells constructed in 2018 to treat water <br /> emanating from the Chester Fault springs (Figure 3). <br /> • Implementation of active management strategies, should they become necessary, <br /> to control "treatment residuals" (i.e., residual dissolved constituents present in <br /> water resulting from reagent usage) in surface water upstream of the CDPS permit <br /> outfall (SW-33). In particular, residual phosphate in surface water resulting from <br /> phosphate injections will be managed if needed. <br /> The following sections provide the proposed work to be conducted to support alternatives <br /> advancement and design, and information on reclamation of disturbed areas following <br /> LPL implementation. Additional details associated with prior field work is provided in the <br /> 2016 Alternatives Analysis Report, submitted to the Water Quality Control Division, the <br /> U.S. Environmental Protection Agency, and DRMS on December 6, 2016 (Arcadis 2016). <br /> In advance of the uranium load reduction field work, approvals will also be requested from <br /> the Colorado Department of Public Health and Environment (CDPHE) Water Quality <br /> Control Division as required by the CDPS permit, the CDPHE Radiation Management <br /> Program (RMP) as required by the site Radioactive Materials License (RML), and the <br /> United States Environmental Protection Agency for Class V aquifer remediation injection <br /> well "authorization by rule" in accordance with Title 40 Code of Federal Regulations (40 <br /> CFR) Sections 144.24 and 144.84(a). <br /> Monitoring Well Construction and Borehole Advancement <br /> Advancement of up to 25 characterization boreholes are proposed at the Pitch <br /> Reclamation Project in a 3-phased approach starting in 2019. The purpose of the <br /> boreholes is to characterize solid materials and assess the area for of the potential for <br /> subsurface water. Based on the screening results, boreholes may be converted to wells <br /> for use in the injection, recirculation, and/or monitoring of phosphate-based reagents and <br /> conservative tracer(s) at the Site. <br /> HOMESTAKE MINING COMPANY '. 1 1 2 MARSHALL STREET, SARGENTS, COLORADO a 1 248 <br />