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surrounding geologic formations. See Attachment C, hereto, "Supplemental Geology Report," <br />dated July 19, 2006. <br />There are two issues that need to be discussed in order to evaluate the <br />environmental impacts of the 7D-9 mine. First is the issue that the mining is occurring in a Salt <br />Wash sandstone that is a perched aquifer. Mining operations oxidize several of the species of <br />concern resulting in their mobility. The question then becomes how far will these species of <br />concern migrate and can they impact human health. <br />There are no records of wells completed in the Salt Wash in the area <br />surrounding the JD-9 mine. In fact, in the entire region, the sandstones of the Salt Wash are not <br />a viable source of water. Limited population is one factor, but the limited quantities of water and <br />poor water quality available from the Salt Wash sandstones excluded them as a source of water <br />Further, geochemical conditions will prevent the migration of species of <br />concern. While the mine may result in oxygenating conditions and may induce migration, <br />background reducing conditions will quickly precipitate species of concern. The Uravan Mineral <br />Belt would not exist without these redox conditions. <br />The monitoring well recently drilled downgradient of the JD-9 mine shows <br />species of concern levels which are an order of magnitude lower than those in the mine. Springs <br />downgradient of the mine are the result of surface rwroff and not the discharge of groundwater <br />from the perched aquifer. <br />The second issue related to the JD-9 mine involves the impact on regional <br />groundwater resources. While the focus of the Division's review has been on the location of <br />groundwater levels underlying the Cotter mine sites, the Division has largely ignored the <br />conservative analysis of the migration pathways. While leaching tests of the waste piles have <br />