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any of this new disturbance will compromise the integrity of any measures taken to encapsulate <br />materials that have the potential to release contaminants into the environment. <br />16) Section five of the Mining Plan and Exhibit T state that Energy Fuels will conduct sampling of <br />the sediment pond every six months for the first three years of the operation and then will <br />reduce sampling intervals to yearly. The Division believes that the initial sampling intervals <br />should be quarterly. If sample results merit a reduction in sampling frequency, the operator may <br />submit a technical revision to the permit requesting a reduction in sampling frequency to be <br />reviewed by the Division. <br />17) Exhibit T states that in the event of an exceedance of standards in the water sample results from <br />the sediment pond, the Division will be notified of the exceedance and any mitigation measures <br />in the annual report. The Division will require written notification of an exceedance of <br />standards within 30 days of Energy Fuels' receipt of the sample results and the proposed or <br />implemented measures to rectify the situation must be included with the notification to the <br />Division. All sample results will be required as part of the Annual Report, however excedence <br />notices must be separate from all other correspondence. <br />18) 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 <br />out. Additionally, the application states that the unattended mine, as is the current state of the <br />site, reached "equilibrium" with regard to the water entering the mine. The applicant.should <br />describe that equilibrium state, specifically the amount of water entering and exiting the mine <br />and the water level throughout the workings that defines this state of equilibrium. The applicant <br />should describe whether this equilibrium will be reached with the inclusion of the proposed <br />bulkheads; whether it will be modified with the presence of the bulkheads; and whether the <br />presence of the bulkheads will result in reverse flow of mine water or water in lower aquifers <br />into overlying aquifers. <br />19) The application materials do not contain any monitoring or mitigation plans for groundwater or <br />surface water, with the exception of the water in the sediment pond. In that the proposed <br />operation has the potential to negatively impact water quality in both surface and groundwater, <br />the applicant should submit a monitoring plan to the Division for review and include a <br />mitigation plan should the monitoring show impacts to water quality. <br />20) Following construction of the first bulkhead the applicant must commit to monitoring the water <br />elevation in the decline until it reaches equilibrium. Construction of the proposed second <br />(higher) bulkhead may not proceed until equilibrium is reached and shown to be below the <br />elevation of the middle Brushy Basin aquifer. <br />a) The Applicant must commit to a contingency plan and bond for installation of a water <br />impounding bulkhead at the upper bulkhead location. If the water level in the flooded <br />decline equilibrates below the upper bulkhead elevation, then installation of a concrete <br />block wall as proposed in the application will be acceptable. <br />b) The Applicant must commit to a contingency plan and bond for bulk heading of the Pack <br />Rat Mine. <br />c) A point of compliance for ground water quality must be established in the lower aquifer <br />of the Brushy Basin Member. This will involve the installation of a monitoring well <br />