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2007-11-14_PERMIT FILE - M2007044
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2007-11-14_PERMIT FILE - M2007044
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Last modified
8/24/2016 3:18:23 PM
Creation date
11/27/2007 1:18:12 PM
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Template:
DRMS Permit Index
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
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No
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5) The Lyntek Report (Appendix H) states that application of ferric sulfate and barium <br />chloride "will not result in increasing the concentrations of barium, chloride, iron, and <br />sulfate in the treated water above applicable water quality standards." Please provide <br />the projected effluent concentrations of barium, chloride, iron, and sulfate in discharge <br />water from the treatment plant. <br />6) Ground water monitoring: To monitor potential ground water impacts due to <br />leachate from waste rock piles, it may be necessary to install one or more downgradient <br />monitoring wells. The depth to ground water might be extreme, and if so, perhaps <br />Applicant should provide a rationale for why monitoring wells are not needed. Operator <br />proposes only one downgradient ground water monitoring location (PR Spring), and page <br />G-23 states that the PR Spring is not hydraulically connected to the mine workings. If <br />true, then the spring will not be representative of impacts to downgradient ground water <br />due to mining activities. <br />7) I am starting to have reservations about the SPLP as a lab test to assess long-term <br />leachate potential. For future hard rock mining applications, and especially DMO's, I <br />am going to start recommending longer term tests. However, in this case, the SPLP test <br />results appear to be very similar to the mine pool sample results (Appendix E), which <br />are a result of many years of mine inflow. The mine inflow in turn may be <br />representative of long term leachate from ore and waste, because the mine inflow <br />evolved as a result of ground water interaction with in situ ore minerals. So these <br />SPLPs look to have done an adequate job of revealing constituents that need to be <br />monitored for the project life cycle. I also think the Applicant did an adequate job of <br />obtaining representative samples o ults of the SPLPs forshe en ~ onmenta assessment <br />this case to hang my hat on the res <br />and EPP. <br />8) What personnel/ safeguards will be in place to guard/ secure explosives stored on <br />site? <br />9) The intermittent operational history of uranium mills, and reported problems at the <br />White Mesa Mill (J. Burnell, personal commun., Oct. 24, 2007), suggest a potential <br />shortage of uranium processing capacity in the near future. In such an event, does <br />EFRC have provisions for on-site stockpiling of ore for extended time periods, or would <br />the mine suspend operations? <br />10) I stated in (3) above that, due to the emplacement of underground bulkheads as <br />part of the reclamation plan, I was more concerned about post-mine discharge from new <br />springs than from the mine workings. After looking at the newly provided post-mining <br />bulkhead installation plan, I think there is also concern about adit discharge. The <br />applicant states that the bulkheads will be placed "to ensure that water seeping into the <br />decline from the lower Brushy Basin aquifer is not allowed to enter the mine workings." <br />However, as hydraulic head builds up behind the bulkheads, what is the possibility of <br />ground water migrating via fractures or along bedding planes back into the workings <br />ahead of the bulkhead? This perhaps should also be considered in light of the <br />
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