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areas and public lands. But the Notice of Intent lacks any specificity as to where prospecting activities will take <br /> place. Rule 5.1.2(d)(V)(a)requires a map that identifies the proposed prospecting sites or activity areas, <br /> including drill hole locations.The Notice of Intent available to the public included no map at all. <br /> There are multiple references to the construction of drill pads in the submitted application materials,yet the <br /> prospector states in the Notice form itself that there will be no surface disturbance.The use of pits in addition to <br /> drilling is mentioned in the cover letter but again not specified in the Notice.Will there be pits excavated,or not? <br /> Will the drill holes require the construction of drill pads,or not?This information is required in the Notice of <br /> Intent and their locations are required on a map that allows the public to determine where specific prospecting <br /> activities will occur,according to Rule 5.1.2(d)(V)(a). Rule 5.3.1(d)requires the operator to conduct drilling in <br /> such a way as to prevent cuttings and fluids from entering any drainage way,and how this will be handled <br /> should be included in the Notice. <br /> Rule 3.1.5(5)requires that all acid-forming or toxic-forming materials be handled and disposed of in a manner to <br /> prevent pollution of the environment, but there is no discussion of how the drill cuttings and mud will be handled <br /> and disposed. It is understood from previous exploration activities on the properties that sulfide ores are present <br /> in the general area and are likely to be encountered with such a large drilling program. Despite this,there is no <br /> information included in the Notice about how the release of acid or toxic-forming materials into the environment <br /> will be prevented. <br /> Affected land,as defined under Rule 1.1(4)must also include access roads that will be constructed in order to <br /> accommodate drilling, but the Notice of Intent fails to provide this information. Instead,the prospector states <br /> that"minimal roads will be constructed."A specific map that delineates all planned road construction should be <br /> provided,and a detailed plan for how roads will be constructed in order to minimize disturbances to the land <br /> and wildlife should be provided,and whether or not crossings or access over public lands will be necessary. <br /> Complete reclamation of all new roads should be stipulated. <br /> The Notice states that ground water will be encountered with each drill hole, increasing the potential for <br /> contaminants and radionuclides to be released and mobilized into aquifers.The same mitigation requirements <br /> that were placed on exploration activities conducted by the previous owner, Black Range Minerals,should be <br /> required here as well. In order to protect water resources in the Tallahassee Creek area, baseline water quality <br /> data should be collected from monitoring wells and baseline analysis of drinking water wells should be required. <br /> In addition, Usuran Resource should be required to identify its water source to be used in the exploration and <br /> should obtain the approval of the Colorado Division of Water Resources in advance of the approval of the <br /> Notice of Intent. <br /> During the last exploration effort on this property,as proposed then by Black Range Minerals,there was an <br /> extensive discussion about underground borehole mining and ablation processing for the uranium ore. In order <br /> to fairly evaluate the Notice of Intent, it must be understood what types of mining methods will be planned after <br /> exploration is done.Will new technologies and mining methods again be proposed for this property,or will <br /> conventional open pit mining be conducted?This information will be important for understanding the complete <br /> and final impact of any mining activities that will take place in the future. <br /> Due to the insufficient information provided in the Notice of Intent, INFORM objects to its approval.We <br /> appreciate the opportunity to comment. <br /> Respectfully submitted, <br /> Jennifer Thurston <br /> Executive Director <br /> Information Network for Responsible Mining <br /> 2205 W. 136th Ave. Ste. 106-311 <br /> Broomfield, CO 80023 <br /> (303)586-1437 <br /> jennifer@informcolorado.org <br /> Permit Number* <br /> Enter valid letter and then numbers,for example M1977999, M1999777UG or C1981201. <br /> P2021019 <br />