2020-04-06_PERMIT FILE - M2019054 (2)

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the 4.5 mm/day recommended rate,the mine would consume its annual allotment of 325,851 gal (1 ac- ft/yr) in 18.8 days. 325,851 gal x 1 day =4.2 days 76,925 gal 325,851 gal x 1 day =0.085 days= 1 hr 3,846,234 gal 325,851 gal x 1 day = 18.8 days 17,284 gal Even if the assumed acreage of active mine requiring dust suppression is over estimated,and only 5%of the mine is worked at any point in time, 5%of the 140 acre mine=7 ac,+7.98 ac of CR 104= 14.98 ac requiring dust suppression.At the 4.5 mm/day recommended rate,the mine would consume its annual allotment of 325,851 gal (1 ac-ft/yr) in 4.5 days. 4.5 mm x 14.98 ac x 43,560 ft2 x 1 inch x 1 ft x 7.48 gal = 72,061 gal per day day 1 ac 25.4 mm 12 in ft3 325,851 gal x 1 day = 4.5 days 72,061 gal These calculations demonstrate that regardless of the assumptions that are made with respect to the number of acres requiring dust suppression and the rate of application of water to provide that dust suppression,the proposed mine's well,at 15 gpm and 1 acre-ft per year, is grossly inadequate to provide dust suppression to the affected area. Two conclusions can be drawn from these calculations and the literature reviewed. If the mine provides adequate water to suppress dust in the footprint of the mine and surrounding county roads that will see dramatically increased truck traffic,given the historical presence of uranium mines and resulting surface disturbances, significant water introduced in an effort to suppress dust could result in radionuclide contamination being carried into the subsurface aquifer as occurred at the Hanford DOE site (Water Application for Dust Control in the Central Plateau: Impacts,Alternatives,and Work Strategies; September 2018,by Yonkofski, CMR et al., Prepared for the U.S. Department of Energy, under Contract DE-AC05-76RL01830, Pacific Northwest National Laboratory). The second conclusion that can be drawn is that if inadequate dust suppression occurs, significant quantities of dust will be entrained due to heavy truck traffic resulting from mining and transportation activities in an area that usually sees only residential traffic volumes. The nature of that dust, due to the presence of historic mine tailings and residuals that contain radionuclides,will present air quality and public health issues to the surrounding residents. The mine should be required to monitor the air along Moffat CR 104 and Old Mine Road to determine pre-and post-mine PM 10 and PM 2.5 concentrations, and analyze the particulate matter collected in PM 10 and 2.5 collection devices for hazardous air pollutants including uranium, radium, and vanadium. If levels are detected which exceed human health standards,the mine must be required to abate the problem at once. Skull Creek Homeowners pg 3