2007-12-20_GENERAL DOCUMENTS - M2005050

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1. The plan implies, but does not state, or provide demonstration in the form of analysis and design, that the up gradient structures (water bars, bar ditches, berms) will completely divert the 25-year, 6-hour storm around the affected land. If the analysis and designs are not elsewhere in the permit, then they need to be provided. 2. The plan states that the only pollutant of concern is suspended solids (or as they incorrectly refer to it, sediment. The plan further states that the only discharges will be storm water. However, there will be an ore stockpile, and the uranium in the ore is quite soluble, so uranium is also a pollutant of concern. And although runoff from the ore stockpile may meet the regulatory definition of storm water, the quality of the water maybe significantly impacted. The Health Department, DRMS and BLM's authority provides that special handling of certain storm water maybe required on a case-by-case basis. Unless they can demonstrate that the ore pile runoff will not be contaminated, DRMS may require that ore pile water be segregated from other storm water and be separately evaporated or otherwise managed/treated. 3. The plan proposes complete capture of the 25-year, 6-hour event runoff from the affected land in a sediment pond. No outlet works or discharge facilities for the pond are proposed. The State Engineer requires that water captured out of priority be released within 72 hours. How will the Operator comply with this mandate? 4. Since the pond will have no outlet works, it will likely overtop and fail during an event larger than the 25-year, 6-hour event, or if there is a series of smaller events in sequence without sufficient intervening time for the pond to recover its capacity through evaporation. The Operator must provide an analysis of the consequences of a 100-year storm on the up gradient controls, the mine area, the pond, and the receiving stream. If the consequences of failure are significant, the Division may require outlet works in the pond to pass through larger events. As Blue Rock can see these issues are important during start up and development of the mine. Work may start on the December 27, 2007 as planned. However until these issues are addressed to DRMS satisfaction all work should be confined to establishing the portal and staging area. Although it is very unlikely at this stage of development: no ore may be deposited on the surface until Blue Rock receives DRMS approval in writing. Blue Rock needs to construct berms and use silt fencing to ensure zero stormwater run-off from the work area until the stormwater management plan is reviewed and approved by DRMS. If you need additional information, please contact me at the Division of Reclamation, Mining and Safety, Grand Junction Field Office, 101 S. 3rd St., Suite 301, Grand Junction, Colorado 81501, telephone no. 970.241.1117. Sincerely, •~ "J G. Russel Means Environmental Protection Specialist Cc: Lynn Lewis, BLM Uncompahgre Regional Office Cc: Allen Sorenson, DRMS Engineer, Denver (e-mail) Cc: Carl Mount, DRMS Senior EPS, North Supervisor.