2007-11-27_PERMIT FILE - M2007044

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Response The solid wastes and hazardous materials that you mention will be handled in accordance with applicable rules and regulations. Handling and disposal procedures for each are addressed in our 112d application and within other more detailed plans that are required by other regulatory agencies. The Preliminary Emergency Response and MC/SPCC Plans, provided in Appendix F of the 112d application, will be finalized once we have received all comments from DRMS, BLM, and Mesa County. A quick summary of the regulatory requirements and proposed plans follow. • Solid waste will be placed in containers and disposed of at an appropriate off-site landfill. • Explosives will be stored, transported, and used in accordance with MSHA regulations. • Fuels and oils will be stored and used in accordance with MSHA and Colorado Division of Oil and Public Safety regulations. All tanks will have secondary containment provisions. A Material Containment and Spill Prevention, Control and Countermeasure (MC/SPCC) Plan will be prepared in accordance with EPA and WQCD guidelines and include emergency notification information. • The water treatment chemicals will be stored and used in accordance with the provisions of the MC/SPCC Plan that is required by WQCD in the discharge permit. • The magnesium chloride tank will be bermed to provide secondary containment in the event of a leak. The tank will be removed upon mine closure. • The propane tank was previously installed as part of exploration activities under an approved permit from Mesa County. The Whirlwind waste rock, as previously discussed, did not generate unacceptable levels of metals or radionuclides when SPLP tested. Therefore, liners are not justified for this facility. Furthermore, the waste pile would sit on over 100 feet of low permeable mudstone from the Brushy Basin geologic unit of the Morrison Formation, so it is unlikely that DRMS would require a liner in any case. The surface drainage systems, both during mining and after reclamation, are designed in accordance with DRMS guidelines to minimize the potential for erosion. As stated in the plan, some waste rock will be disposed of underground in mined out areas. This is generally a preferred practice as it reduces the area of surface disturbance. The waste is not acid generating nor does it contain elevated levels of metals or radionuclides. The uranium content of the waste rock averages less that 10 parts per million (ppm). In contrast, the Salt Wash ore averages 2,500 ppm uranium. The reclamation plan specifies that a minimum of 12 inches of clay loam will be placed over the regraded areas of the mine including the waste pile and seeded with a seed mix approved by the BLM in the fall. The reclaimed surfaces will be self draining with slopes of 3H/1V or less steep. Recontouring of the waste pile and other areas is expected to E3~~rg~,~ I~~~~1:: E~~~~:crt.~is.•cw; C'a>>~a~~~t~tii~r~ s,~ tlnic~n ~~.y<~l~r~~t~~~l. ~l~i9c~ ~it~iO 7 ! t~~~c~v~~n~l, ~~~:J ~iil"?t; E'}~c~~~~: ~(1i-_c~~.~_2l~~i)