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DATE: November 8, 2007 <br />TO: Russ Means <br />FROM: Kate Pickford <br />~; Hydrology Review, Energy Fuels Resources Corporation, <br />Whirlwind Mine, File No. M-2007-044 <br />The Division of Reclamation, Mining, and Safety (Division) conducted a review of the Energy Fuels <br />Resources Corporation, Whirlwind Mine permit application. This review focuses on issues related to <br />hydrogeology at the site and potential impacts of the operation on surface and groundwater within and <br />around the proposed permit area. <br />1. The submitted mining plan indicates that some areas that have previously been reclaimed at the site <br />will be redisturbed during the proposed new activity. The applicant should indicate whether any of <br />this new disturbance will compromise the integrity of any measures taken to encapsulate materials <br />that have the potential to release contaminants into the environment. <br />2. Section five of the Mining Plan and Exhibit T state that Energy Fuels will conduct sampling of the <br />sediment pond every six months for the first three years of the operation and then will reduce <br />sampling intervals to yearly. The Division believes that the initial sampling intervals should be <br />quarterly. If sample results merit a reduction in sampling frequency, the operator may submit a <br />technical revision to the permit requesting a reduction in sampling frequency to be reviewed by the <br />Division. <br />3. Exhibit T states that in the event of an exceedance of standards in the water sample results from the <br />sediment pond, the Division will be notified of the exceedance and any mitigation measures in the <br />annual report. The Division will require notification of an exceedance of standards within 30 days <br />of Energy Fuels' receipt of the sample results and the proposed or implemented measures to rectify <br />the situation must be included with the notification to the Division. This notice must be separate <br />from the annual report. <br />4. The hydrology exhibit submitted with the application states that the mine workings are "self <br />draining" with regard to water seepage from aquifers located above the mine workings. The <br />applicant should describe the fate of the water that seeps into the mine and subsequently drains out. <br />Additionally, the application states that the unattended mine, as is the current state of the site, <br />reached "equilibrium" with regard to the water entering the mine. The applicant should describe that <br />equilibrium state, specifically the amount of water entering and exiting the mine and the water level <br />throughout the workings that defines this state of equilibrium. The applicant should describe <br />whether this equilibrium will be reacfthe bullcheadscand wh ther the p~esencelof the bulkheadslwill <br />will be modified with the presence o <br />result in reverse flow of mine water or water in lower aquifers into overlying aquifers. <br />