Laserfiche WebLink
more extensive controls at the conclusion of operations. Energy Fuels believes that these <br />measures will reduce the amount of water entering the existing and proposed mine <br />workings and ultimately result in less impact to ground water than currently exists. In <br />summary, mine water discharge will not occur and perpetual water treatment will not be <br />needed upon closure because the mine is not in an aquifer and current inflows into the <br />mine will be sealed off or reduced wherever possible. <br />It has been our experience that DRMS takes a very conservative approach in their review <br />of permit applications and long-term water impacts. <br />Comment 3 <br />We would like DRMS to consider the following potential impacts to water quality, and <br />ensure mitigation and treatment that leaves no risk for unanticipated water quality <br />impacts: <br />Elements exceeding Colorado water standards at Whirlwind mine site: <br />Antimony standard (mg/L) = 0.06, SPLP ore samples = 0.008 (WW3) <br />Arsenic standard (mg/L) = 0.05-.1, SPLP ore samples = .715 (WW1), <br />.228 (WW), 1.1 S (WW3) <br />Selenium standard (mg/L) _ .02-.05, SPLP ore samples = .216 (WW1), <br />.064 (WW2), .173 (WW3) <br />Uranium standard (mg/L) _ . 03, SPLP ore samples = .110 (WW1), 1.60 <br />(WW2), 1.09 (YVW3) <br />Radionuclides exceeding Colorado water standards at Whirlwind mine site: <br />Radium 226, Radium 228 <br />Response <br />The Synthetic Precipitation Leaching Procedure (SPLP) test consists of crushing 100 <br />grams of material to a size smaller than 9.5 mm and mixing the sample with a weak acid <br />at a 20 (acid) / 1 (sample) weight ratio. This procedure was performed on three <br />representative ore samples and three representative waste rock samples to determine if <br />this material could potentially leach natural contaminants into surface or ground water <br />systems. From an environmental perspective, the test is conservative because mined <br />material is typically much coarser in size (i.e., up to 2 feet in diameter) and is not stored <br />in areas susceptible to 100% saturation. <br />There is no regulatory pass-fail criterion for an SPLP Test. The DBMS has chosen to <br />compare the SPLP results to surface and ground water standards to better understand the <br />potential toxicity of this material in the environment. If the leachate from the <br />conservative SPLP test does not contain constituent levels above these standards, then it's <br />a pretty safe bet that the material will have minimal impact on the environment. If the <br />leachate contains constituent levels above the standards, the DRMS requires that <br />protective controls be established for the material in question to reduce the potential for <br />adverse environmental impact. <br />~~~.t~c~r-~~ I~~~~:1, 1~~°~n,tr~~~~s C`t~t-}~ca~~~stil~r~ ~l~ t)ni«~~ I~~~~~1~~~~:~-cl. ~+~~it~~ ~,t}(7 3 <br />1,~~~c~~~~ac~~L ('t) ~t~)12~ 6~~t.~3~«' ~(a;_c~7~-~l:~t~ <br />