2007-11-14_PERMIT FILE - M2007044

• Permit No: M2007044
• IBM Index Class Name: PERMIT FILE
• Doc Date: 11/14/2007
• Doc Name: Staff initial review memos
• From: DRMS
• To: Whirlwind Mine
• Media Type: D
• Archive: No

DATE: November 6, 2007
TO: Russ Means
FROM: Allen Sorenson
~; Underground Bulkhead Review, Energy Fuels Resources Corporation,
Whirlwind Mine, File No. M-2007-044
The permit application includes plans to install a water impounding bulkhead into the decline below the level of
ground water inflows to the decline from the lower aquifer of the Brushy Basin Member. The intent of the
bulkhead is to prevent Brushy Basin ground water from flowing down the decline and into the mine workings in
the uraniferous Salt Wash Member. This is analogous to drill hole abandonment procedures designed to prevent
commingling of aquifers. If the bulkhead is effective, ground water will build up in the decline to some
dynamically equilibrated elevation, and flow into and out of the decline through the aquifer will be similar to the
pre-decline condition. If the bulkhead leaks, it is likely that water would eventually emerge to surface at the
Pack Rat Mine Portal. If the flooded decline equilibrates at the elevation of the intersection with the middle
aquifer of the Brushy Basin Member or higher, unacceptable commingling of aquifers would result.
The following items must be addressed by the Applicant to the Division's satisfaction for the bulkheading plan
to be approved.
1. The Applicant must commit to monitoring the water elevation in the decline until it reaches equilibrium.
Construction of the proposed second (higher) bulkhead may not proceed until equilibrium is reached and
shown to be below the elevation of the middle aquifer.
2. The Applicant must commit to a contingency plan and bond for installation of a water impounding
bulkhead at the upper bulkhead location. If the water level in the flooded decline equilibrates below the
upper bulkhead elevation, then installation of a concrete block wall as proposed in the application will be
acceptable.
3. The Applicant must commit to a contingency plan and bond for bulkheading of the Pack Rat Mine.
4. A point of compliance for ground water quality must be established in the lower aquifer of the Brushy
Basin Member. This will involve the installation of a monitoring well down gradient of the proposed
bulkhead, between the bulkhead and the canyon wall. Since the mine will not flood until the bulkhead is
installed at the time of mine closure, the collection of baseline data from the point of compliance well
can proceed concurrently with mining.
The Division is concerned the bulkhead installation cost estimates provided in the application are too low for
bonding purposes. An estimate of bulkheading costs for the Whirlwind Mine is being prepared by Division staff
at Denver headquarters and will be ready in the next day or two.
cc: Carl Mount, DRMS (via email)
Berhan Keffelew, DBMS (via email)
Kate Pickford, DRMS (via email)
David Bird, DRMS (via email)
c:\acs files\My Documents 4-19-06 thru\whirlwind bulkhead memo.doc