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e. <br /> COLORADO LEGACY LAND <br /> Please provide some additional discussion regarding the location at which the Schwartz Trend intersects Section 8(d) of the Schwartzwalder Mine Environmental Protection Plan(Whetstone Associates Inc.,2016)provides the <br /> the creek downgradient of the mine site,and whether this geologic feature might act as a migration following description of Fracture Systems near the Site: <br /> corridor for mine water downgradient of the site(at mine pool levels at or below the regulatory limit of <br /> 150 feet below Steve Level).Please include in this discussion an evaluation of elevation differences "The area is characterized by extensive vertical fracturing, dominated by the West Rogers, East Rogers, and Illinois fault <br /> between the mine pool and the creek bed at the location where the Schwartz Trend intersects the creek,as systems. The West Rogers Fault System extends from about 600 feet north of the main mine portal(SteveAdit)to about 1,100 <br /> well as a discussion of how monitoring well MW-15 was installed to identify any offsite mine water flows feet south of the portal. The West Rogers Fault has not been mapped as intersecting Ralson Creek,but instead terminates in <br /> through this feature. the upper reaches of a drainage, tributary to Ralston Creek. Therefore, the West Rogers Fault does not appear to directly <br /> connect to Ralston Creek,downstream(southeast)of the mine. <br /> The Schwartz Trend, however, intersects to Ralston Creek about 1,900 feet southeast of the mine(Figure 8-17).At the mine <br /> site, the Schwartz Trend is characterized by brittle fracturing and is the primary host for uranium. 1,900 feet southeast, <br /> where the creek flows over a 300 ft wide exposure of Schwartz Trend rocks, the Schwartz Trend has a measurable effect on <br /> electrical conductivity(E.C.)in Ralston Creek.E.C. is an indirect measurement of total dissolved solids(TDS).An E.C.survey, <br /> conducted by Whetstone and the Operator's personnel in November 2008, indicated that E.C. abruptly increased 21 PS/cm <br /> at the contact with the Schwartz trend rocks(Section 8(e)(ii)).Because no similar E.C.survey exists prior to mining or during <br /> mining operations, it is not known whether water in the flooded underground mine is influencing water quality in Ralston <br /> Creek at the Schwartz Trend intersection,or whether the Schwartz trend discharged water with higher TDS than the creek <br /> at this location." <br /> Section 8(e) of the Schwartzwalder Mine Environmental Protection Plan (Whetstone Associates Inc.,2016) continues by <br /> describing: <br /> • the technical rationale for the location of MW-15 to monitor groundwater from the Schwartzwalder Trend near Ralston <br /> Creek,and <br /> • a series of environmental studies conducted to evaluate the potential connectivity of the Schwartzwalder Trend <br /> downgradient of the mine and Ralston Creek: <br /> o evaluation of stream flow rates and mine pumping rates, <br /> o an electrical conductivity,temperature,and pH profile of Ralston Creek, <br /> o a gamma survey across the Schwartzwalder Trend, <br /> o a water quality survey across the Schwartzwalder Trend and Ralston Creek, <br /> o Stable Isotopic Analysis of the Mine Water and Ralston Creek,and <br /> o Tritium Dating study of the Mine Water. <br /> The culmination of these investigations is provided Section 8(e)(i)of the Schwartzwalder Mine Environmental Protection Plan <br /> (Whetstone Associates Inc.,2016)which concludes the following: <br /> "Summary of Hydraulic Connection. The available evidence indicates there is not a strong direct hydraulic connection <br /> between Ralston Creek and the Schwartzwalder Mine.However,a weak hydraulic connection may exist,so that while some <br /> water may have flowed from the creek into the mine during dewatering,flows from the creek to the mine were small and <br /> controlled by the inherent low permeability of the rock mass(2.8x10-7 cm/sec average bulk hydraulic conductivity). The <br /> low permeability of the bedrock limited flow from the creek into the mine,and dewatering the mine did not drain Ralston <br /> Creek." <br /> This'weak hydraulic connection'has since been eliminated by CLL's commitment to maintain a dewatered mine pool below <br /> the regulatory limit(Figure E-3). The capture zone associated with the dewatered mine is illustrated on Figure E-4. The <br /> accompanying technical discussion in Appendix 3 of the AM-06 concludes: <br /> "This technical memorandum presents solid evidence that the Schwartzwalder water management program, which uses <br /> pumping to depress the mine water level,has converted the mine workings to a large-scale groundwater sink. Hydraulic <br /> mechanisms do not exist whereby mine pool water can exit the workings and migrate towards Ralston Creek and Ralston <br /> Reservoir. This hydraulic behavior should continue as long as the water level in the mine is depressed below the <br /> re ulatory level." <br /> 15 Exhibit E-Reclamation Plan(Rule 6.4.5): <br /> PAGE 5 OF 12 <br />