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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />~~~, <br />COLORADO <br />DIVISION O F <br />RECLAMATION <br />MINING <br />- &- <br />SAFETY <br />Bill Owens <br />I ~~ ~ Governor <br />Russell George <br />1/ ~OV 19 2007 Executive Director <br />November 15, 2007 Ronald W. Cattany <br />Division of Reclamation, Division Director <br />Mining and Safety Natural Resource Trustee <br />Frank Filas <br />Energy Fuels Resources Corporation <br />44 Union Boulevard, Suite 600 <br />Lakewood, Colorado 80228 <br />Re: Whirlwind Mine File No. M-2007-044, Preliminary Adequacy Review of a 112 DMO <br />application. <br />Dear Mr. Filas: <br />The Division of Reclamation, Mining and Safety (DBMS) has begun the review process of the above <br />referenced DMO application. The review is being conducted by the Division's geochemist, engineers, <br />hydrology specialist and environmental protection specialists. The review to date has brought up the <br />following issues that need clarifications, correction or responses. Please note that some issues may be <br />repetitive due to multiple reviews and cross over of expertise: <br />1) Please provide written permission for the Division to release all information regarding the review <br />and installation of the water treatment plant approved under the Whirlwind Notice of Intent. <br />2) Pg D-32 and Appendix H. Treatment process for removal of uranium, radium, arsenic, and <br />selenium is described. SPLP indicates other regulated constituents have been detected in <br />leachate, including Cd, Pb, V, Zn, although not at the elevated concentrations of those proposed <br />for treatment. Additionally, underground blasting could introduce elevated concentrations of <br />nitrate/nitrite/ammonia in mine water. In the event that these constituents appear in mine water <br />at concentrations greater than anticipated, are provisions being made in the water treatment <br />process to address these contingencies? <br />3) With the understanding that development of new workings will depend largely on the ore <br />encountered, how many linear feet of new underground workings are currently proposed (has a <br />bearing on the following question)? <br />4) Please address the possibility of a permanent post-mining discharge, not from the workings as <br />they will be bulk headed, but from new springs that might emerge on the hillside as the mine <br />pool fills. Given the following: a) the mine historically discharged one gpm (pg. G-16); b) <br />there are perennial springs in the general vicinity producing up to 20-30 gpm; c) mine workings <br />will expand, potentially propagating up-section and across hydrostratigraphic units, across <br />water-conducting structures, or perhaps intersecting feeder sources for the DP or PR springs; d) <br />Office of <br />Office of Active and Inactive Mines <br />Mined Land Reclamation <br />