Laserfiche WebLink
DATE: November 13, 2007 <br />TO: Russ Means <br />FROM: David Bird <br />RE: Review Comments on Energy Fuels Permit Application <br />Whirlwind Mine, File No. M-2007-044 <br />1) Pg D-32 and Appendix H. Treatment process for removal of uranium, radium, <br />arsenic, and selenium is described. SPLP indicates other regulated constituents have <br />been detected in leachate, including Cd, Pb, V, Zn, although not at the elevated <br />concentrations of those proposed for treatment. Additionally, underground blasting <br />could introduce elevated concentrations of nitrate /nitrite /ammonia in mine water. In <br />the event that these constituents appear in mine water at concentrations greater than <br />anticipated, are provisions being made in the water treatment process to address these <br />contingencies? <br />2) With the understanding that development of new workings will depend largely on the <br />ore encountered, how many linear feet of new underground workings are currently <br />proposed (has a bearing on the following question)? <br />3) I am concerned about the possibility of a permanent post-mining discharge, not from <br />the workings as they will be bulkheaded, but from new springs that might emerge on the <br />hillside as the mine pool fills. <br />Given the following: <br />- the mine historically discharged one gpm (pg. G-16); <br />- there are perennial springs in the general vicinity producing up to 20-30 gpm; <br />- mine workings will expand, potentially propagating up-section and across <br />hydrostratigraphic units, across water-conducting structures, or perhaps <br />intersecting feeder sources for the DP or PR springs; <br />- the Rajah 30 was plugged relatively recently (2001), and the 15 gpm previously <br />discharging from the portal may be looking for another way out; <br />......what is the potential for increased quantities of ground water inflows that could <br />potentially, in the post-mining situation, build up head behind the double bulkheads <br />and escape the mountain via newly formed springs? (Internal note: should we <br />require in the Reclamation Plan a provision for ground water level monitoring for a <br />number of years to monitor the mine pool level and subsequent buildup of hydraulic <br />head to provide an indication of the possibility of mine pool leakage?) <br />4) Pg D-4: Was the treatment plant sized to accommodate the flow that might occur if <br />the measures proposed to minimize mine inflow, e.g., grouting of the Ten Straight and <br />plugging of historic bore holes, are unsuccessful, and in the event of increased mine <br />inflow due to the reasons stated in (3) above? <br />