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Historic discharge data for the mines in Lumsden Canyon (see Appendix E, Table E-2 <br />of the 112d application) show that these constituents were not present in any of the <br />mine water discharges above regulatory standards. Energy Fuels will, however, <br />monitor for these constituents and will implement additional water treatment and/or <br />corrective measures if their concentrations exceed regulatory limits. Our discharge <br />permit with the Water Quality Control Division (WQCD) requires that we monitor <br />weekly for cadmium and zinc and monthly for lead and vanadium when discharging <br />treated water. These constituents will also be added to our quarter sampling of <br />stormwater. Nitrate is not one of the WQCD required sampling parameters. However, <br />nitrate concentrations in the mine water will likely increase once routine blasting <br />operations commence on site due to the use of ammonium nitrate and fuel oil <br />(ANFO). Therefore, nitrate will be added to our monthly sampling program for <br />treated discharge water and to our quarterly stormwater sampling program (see Item <br />16 below). <br />The treatment trailer has been equipped with an additional reagent tank that will <br />allow for the addition of lime should treatment for Cd, Pb, V, or Zn be required. The <br />lime would increase the pH during treatment and these metals typically precipitate out <br />of solution as an insoluble hydroxide with an increase in pH. Nitrate can be removed <br />from water using filtration methods; however, these methods are relatively expensive <br />and produce considerable volumes of waste that must be disposed of at an appropriate <br />landfill. If nitrate levels become elevated, we would first attempt to modify our <br />underground water control procedures to limit contact of mine water with the blasted <br />rock containing ANFO. <br />3) With the understanding that development of new workings will depend largely on the <br />ore encountered, how many linear feet of new underground workings are currently <br />proposed (has a bearing on the following question)? <br />Energy Fuels anticipates driving approximately 9,500 feet of development drift to <br />access known and inferred ore zones over a 10-year period. This is roughly equivalent <br />to about 2/3rds of the existing drift system within the Packrat Mine. The new drifts <br />could encounter historic open drill holes or natural fractures that allow for seepage of <br />water from the overlying Brushy Basin water-bearing zones into the mine workings. <br />As documented in detail in Exhibit T, Energy Fuels plans to seal these potential <br />ground water conduits as they are encountered and/or upon closure. <br />4) Please address the possibility of a permanent post-mining discharge, not from the <br />workings as they will be bulk headed, but from new springs that might emerge on the <br />hillside as the mine pool fills. Given the following: a) the mine historically <br />discharged one gpm (pg. G-16); b) there are perennial springs in the general vicinity <br />producing up to 20-30 gpm; c) mine workings will expand, potentially propagating <br />up-section and across hydrostratigraphic units, across water-conducting structures, <br />or perhaps intersecting feeder sources for the DP or PR springs; d) the Rajah 30 was <br />plugged relatively recently (2001), and the 1 S gpm previously discharging from the <br />portal may be looking for another way out; <br />i=?~~ert•g~ l~uel5 l~escx~r•cLs ~:c~r~c~ratio~i ~?~ l.)nic~n [3c~trlevarci. `quite Ei4t) 2 <br />L,al:eE~~{:~a~j. C"C~ ~t)12~ t=~cr~~c: 3t}3-97~-21 ~t0 <br />