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RECEII6L© <br />Date: April 11, Zoos JUL 31 2006 <br />To: /.~M ~i~ Russ Means, Carl Mount, Allen Sorenson Division of Minerels and Geology <br />From: /~nti(~y Harry Posey <br />RE: Uranium. <br />M-1977 -306 <br />Here are a few comments on Russ Means' excellent commentary on Cotter Corp's active uranium mine <br />permits. Without contrary evidence, sites should be considered DMOs based on site-specific conditions. <br />1. The text indicates that one purpose of the review was "to ensure that the sites do not fall under the <br />Designated Mining Operations ... portion o£ .. the Rules..." If this is expressed accurately, it seems <br />to pre judge the issue. If an operation, uranium or otherwise, meets the definition of a DMO, then I <br />~~ think the division should so designate, pending Board approval. <br />2. The JD-9 site requires water treatment to remove radium, I believe. (Or is it radon? Well, whatever, <br />the purpose of water treatment is to remove the contaminant.) When barium chloride is added to <br />sulfate-bearing water, barium sulfate precipitates. The contaminant co-precipitates with barium <br />sulfate, and thereby is removed as a solid through settling or filtering. In my opinion, the JD-9 water <br />requires treatment and that indicates the operation qualifies as a DMO. <br />Question D. Required control measures to prevent groundwater contamination. The determination <br />should be site specific. Some uranium etc. will leach into the ground from ore stockpiles, regazdless <br />of the holding time; at issue is whether it will reach a stream (as a seep or spring) or groundwater in <br />concentrations exceeding standards. The amount contaminant leached depends on the amount in the <br />ore, and on precipitation rate; the amount reaching ground or surface water depends on the initial <br />concentration and the dilution rate. Cotter is collecting a composite sample to answer this question. <br />4. Question E. Additional groundwater monitoring needed? Groundwater monitoring should be required <br />only if the leaching results coupled with the dilution calculation that Cotter is to prepare indicates a <br />potential for groundwater contamination. <br />s. Question D; last page. I don't agree that if one site is set as a DMO then all similar sites should <br />follow. Site-specific conditions should dictate. For these mines, proximity of the ores to ground <br />and/or surface water will determine whether the individual sites warrant DMO status. <br />Cc: Bruce Humphries <br />