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Your letter goes on to excerpt passages from DRMS's regulations regarding DMOs <br />including: Sections 7.1.3 Compliance Requirements (1) and (2), 7.1.4 Environmental <br />Protection Plan Requirements (1) and (2), Notification of Designation or Pending <br />Designation by Office (1) and (2), 7.2.2 Notification of Designation or Pending <br />Designation by Office (1) and (2), and 7.2.8 Plan Inadequacy. <br />Response <br />Energy Fuels filed the permit application as a Designated Mining Operation (DMO) <br />because of our need to treat and discharge mine water at the start of operations. The <br />DBMS typically interprets its rules and defmitions in such a manner that a site with a <br />wastewater treatment plant is considered a DMO. We believe that our application is <br />thorough and complete and meets the requirements fora 112d permit. <br />Comment 2 <br />It is stated within the mine plan that "...ground water is seeping into the Whirlwind mine <br />from aquifers located above the mine workings" (Whirlwind Mine, D-4). Additionally, it <br />is stated that "ground water is also entering around the casing of the Ten Straight vent <br />shaft into the Packrat mine and through open drill holes and fractures in the formation" <br />(Whirlwind Mine, D-4). While Energy Fuels has agreed to pump excess water for <br />treatment and eventual discharge into an ephemeral drainage or utilize water for drilling <br />and dust suppression, what type of water treatment will be required during operations, <br />and equally important, following termination of mining activities after ten years of <br />operation? Will perpetual water treatment be required following mine closure? Given the <br />past and ongoing water quality impacts associated with uranium mining, we strongly <br />suggest that DRMS take a very conservative approach in any modeling or tests of <br />potential water quality problems, and design mitigation to accommodate a "worst case" <br />scenario. <br />Response <br />Energy Fuels will use a portable water treatment system that was designed and <br />constructed by Lyntek Incorporated. Barium chloride and ferric sulfate will be added to <br />the water in dilute concentrations to precipitate radionuclides and metals. Lyntek's design <br />report is included in Appendix H of our 112d application. A revised design report was <br />also recently submitted to the DRMS that documents the as-built configuration. Based on <br />comments received from DBMS, the proposed lined treatment ponds were replaced with <br />portable tanks equipped with multiple liners and leak detection. <br />There are areas of standing water in the Packrat and other nearby inactive mines in <br />Lumsden Canyon. In each case the water is entering the mines through historic mine <br />features such as open drill holes and ungrouted shafts. The inflow rates are relatively low <br />and none of these mines discharge water. Energy Fuels has proposed mitigation measures <br />in Exhibit T of the 112d application that includes point source controls of water inflow <br />during mining (i.e., sealing of old vent shafts and open drill holes) and implementation of <br />~t~c~~•~~~~ 1~~:~€ l~ess~~rc~c°, ~'c~~-l~~~r~tti~7z-~ ~t~ ll~~ic~~ I~~,E~l~vttrc), ;~tfitc° t~{3tl 2 <br />I,aj.cti~,~r~c~~a, E,'(:i ~f_")17~ i'(tt~e7e: ;t}~-X74-~1~3t) <br />