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It is stated within the Plan of Operations (POO) that "ore would be transported to the <br />White Mesa Mill or another existing uranium mill in the region." This description is not <br />sufficient. Depending on where the ore is milled may result in major differences in <br />environmental, socio-economic, and transportation impacts associated with the <br />Whirlwind Mine. Indeed, recent reports indicate that the White Mesa Mill operators aze <br />accepting ore only at rates drastically below the current uranium spot price. This could <br />directly affect the profitability of the Whirlwind Mine and the operator's ability to <br />successfully implement required mitigation measures or account for future unanticipated <br />impacts. Thus, DRMS should require the operator to specify mill location to be analyzed <br />so that the environmental analysis performed will adequately represent impacts <br />associated with the mining and transportation of ore. Further, to the extent processing of <br />Whirlwind ore at the White Mesa mill is tenable, as numerous other Western Colorado <br />mines may also utilize Denison Mine Corporafion's White Mesa Mill, cumulative <br />impacts associated with mining and ore transportation are potentially great. <br />Transportation: <br />Impacts associated with the transportation of ore, to mill sites, represents a significant <br />hazard associated with the mining of uranium. Concerns over accidents and truck- <br />overturns aze especially troublesome considering the radioactive nature of the uranium <br />ore in transport and the potential for spills into rivers and streams, azeas within close <br />proximity to businesses and residences, and county roads and highways. Transportation <br />frequency at the rate of 20 roundtrips per week, increasing to 40 roundtrips per week, as <br />defined by the anticipated increase in production, would represent a significant increase <br />in local traffic throughout many of the proposed transportation routes. These impacts <br />would require substantial road and right of way maintenance. <br />It is stated within the POO, that although primary haulage would be via Mesa County <br />roads to Colorado Highway 141, "three secondary routes via Grand County, Utah roads <br />to Utah highways may also be used." We expect DRMS to analyze all transportation <br />alternatives to identify impacts. <br />When analyzing impacts associated with the transportation of uranium ore from the <br />Whirlwind mine site, cumulative analysis associated with the regional uranium mining <br />boom must also be studied and considered. <br />Revived uranium ore production at the Whirlwind Mine would increase mining related <br />air and water impacts, and require a sharp increase in haulage truck traffic to distant <br />processing facilities. The Whirlwind Plan of Operations, as proposed, would result in: <br />• unearthing 200 tons of uranium ore per day, 4000 tons of uranium ore per month <br />• average truck traffic of up to 40 round trips per week to/from White Mesa <br />(Blanding, UT), or other mill <br />• uranium ore haul routes adjacent to major waterways <br />• transport through several Colorado Counties <br />• transport of uranium ore through several Colorado communities <br />