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treatment and eventual dischazge into an ephemeral drainage or utilize water for drilling <br />and dust suppression, what type of water treatment will be required during operations, <br />and equally important, following termination of mining activities after ten years of <br />operation? Will perpetual water treatment be required following mine closure? Given <br />the past and ongoing water quality impacts associated with uranium mining, we strongly <br />suggest that DBMS take a very conservative approach in any modeling or tests of <br />potential water quality problems, and design mitigation to accommodate a "worst case" <br />scenario. <br />We would like DRMS to consider the following potential impacts to water quality, and <br />ensure mitigation and treatment that leaves no risk for unanticipated water quality <br />impacts: <br />Elements exceeding Colorado water standazds at Whirlwind mine site: <br />o Antimony standazd (mg/L) _ .006, SPLP ore samples = .008 (WW3) <br />o Arsenic standazd (mg/L) _ .OS-.1, SPLP ore samples = .715 (WW1), .228 <br />(WW2), 1.15 (WW3) <br />o Selenium standard (mg/L) _ .02-.05, SPLP ore samples = .216 (WW1), <br />.064 (WW2), .173 (WW3) <br />o Uranium standard (mg/L) _ .03, SPLP ore samples = .110 (W W 1), 1.60 <br />(WW2), 1.09 (WW3) <br />Radionuclides exceeding Colorado water standazds at Whirlwind mine site: <br />o Radium 226, Radium 228 <br />Diversion Channels: <br />o It is stated that "surface drainage controls would consist o£ (1) permanent <br />diversion of potential run-on storm water azound portal azeas using ditches <br />and culverts" (POO, 16). Will ditches and culverts adequately contain <br />10,100, and 500 year precipitation events? <br />o Surface water is to be directed "azound the waste disposal azea and other <br />surface facilities via diversion channels." Will diversion channels be lined <br />with synthetic liner which is proposed for ponds? <br />Ventilation Shafts and Aquifers: <br />o It is stated that "location of these vent shags may change by several <br />hundred feet depending on the ultimate location of the drift and ventilation <br />needs," and that "steel casing would be grouted where it passes through <br />aquifers to prevent intermixing of waters between formations." <br />Dischazge into Lumsden Canyon: <br />o We request that DRMS require frequent water quality monitoring of any <br />and all dischazges into ephemeral drainages and other drainages, including <br />dischazges into Lumsden Canyon. As it is stated within the Whirlwind <br />Environmental Protection Plan that "water will be dischazged into an <br />ephemeral tributary to Lumsden Creek, which when flowing, dischazges <br />into the Dolores River," we request DRMS evaluate any dischazges into <br />the Dolores River and the resulting impacts to aquatic life, including <br />impacts to threatened and endangered species. DRMS should ensure that <br />