2008-01-15_PERMIT FILE - M2007044 (2)

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1 S) The submitted mining plan indicates that some areas that have previously been reclaimed at the site will be redisturbed during the proposed new activity. The applicant should indicate whether any of this new disturbance will compromise the integrity of any measures taken to encapsulate materials that have the potential to release contaminants into the environment. As documented in the 112d Application (see Exhibit D-Sections 5 and 6, Exhibit T- Section 1, and Appendix A), SPLP testing indicates that the uranium ore has the potential to release contaminants into the environment. Testing of the waste rock, however, did not indicate a potential for leaching contaminants to the environment. The historic records indicate that Pioneer Uravan mined 2,743 tons of ore containing 0.15% U308 and 0.75% V205 and that this ore was shipped off site to a mill. The approximately 40,000 to 50,000 tons of waste rock placed on-site by Pioneer Uravan consists of Brushy Basin mudstones and barren sandstones and shale from the Salt Wash. No special precautions, such as encapsulation, were employed during previous reclamation of the waste pile. Proposed activity at the Packrat Mine is limited to the very top of the waste pile where a small pad will be constructed in front of the portal. The pad was designed to minimize impacts to the majority of the waste pile that was previously regraded, covered with imported topsoil, and revegetated. 16) Section five of the Mining Plan and Exhibit T state that Energy Fuels will conduct sampling of the sediment pond every six months for the first three years of the operation and then will reduce sampling intervals to yearly. The Division believes that the initial sampling intervals should be quarterly. If sample results merit a reduction in sampling frequency, the operator may submit a technical revision to the permit requesting a reduction in sampling frequency to be reviewed by the Division. As requested, Energy Fuels will increase the sampling frequency for stormwater to quarterly at the sediment pond. Most stormwater runoff from the site will occur as a response to larger summer storm events and the melting of winter snowfall. The sediment pond is expected to be dry during a large portion of the year and it may not always be possible to collect a water sample during all four quarters. The sampling program will generally be consistent with and include most of the same inorganic analytes specified in our discharge permit with WQCD. As discussed in Item 2 above, nitrate will be added to monitor potential impacts from blasting operations. The proposed analyte list for quarterly stormwater monitoring includes TSS, pH, TDS, As, Cd, Mn, Se, Zn, U, Ra-226, Ra-228, B, Be, Cr, Pb, Ni, V, and nitrate as N. The major ions will also be added to provide additional water chemistry information in the event that regulatory standards are exceeded. 17) Exhibit T states that in the event of an exceedance of standards in the water sample results from the sediment pond, the Division will be notified of the exceedance and any mitigation measures in the annual report. The Division will require written T~.r1e~•g~ 1`ui,15 RLsc~~irues C'~~r~c~r~Cit~m~ 44 1:J~lit~~1 13cn~levard, ~uit~ Ei()t) 13 L,.alceti~~r;~ocl. CSC:) 8~12~ Ph{}«~: 303-~~~74-2140