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

• Permit No: M2007044
• IBM Index Class Name: PERMIT FILE
• Doc Date: 1/15/2008
• Doc Name: Response to PAR
• From: Energy Fuels Resources Corporation
• To: DRMS
• Media Type: D
• Archive: No

volume of ground water entering the mine, both during and after mining, that could
potentially migrate laterally and create a new seep(s) within Lumsden Canyon.
20) Following construction of the first bulkhead the applicant must commit to monitoring
the water elevation in the decline until it reaches equilibrium. Construction of the
proposed second (higher) bulkhead may not proceed until equilibrium is reached and
shown to be below the elevation of the middle Brushy Basin aquifer.
a) The Applicant must commit to a contingency plan and bond for installation of
a water impounding bulkhead at the upper bulkhead location. If the water
level in the flooded decline equilibrates below the upper bulkhead elevation,
then installation of a concrete block wall as proposed in the application will
be acceptable.
b) The Applicant must commit to a contingency plan and bond for bulk heading
of the Pack Rat Mine.
c) A point of compliance for ground water quality must be established in the
lower aquifer of the Brushy Basin Member. This will involve the installation
of a monitoring well down gradient of the proposed bulkhead, between the
bulkhead and the canyon wall. Since the mine will not flood until the
bulkhead is installed at the time of mine closure, the collection of baseline
data from the point of compliance well can proceed concurrently with mining.
d) Cost estimates for the design, construction and monitoring of the bulk head
appear to be insufficient. Division experience indicates costs in the
magnitude of 40 to SO times the $7, 000.00 figure given. Enclosed is the
Division's estimate for the cost to construct one required and two contingency
bulkheads. Please clarify.
a. Water Monitoring and Elimination of Upper Bulkhead at Whirlwind Decline
Energy Fuels commits to monitoring the water elevation above the lower seal until it
reaches equilibrium. This will be done by manual measurement since the upper seal
will not be installed. The seal will be approximately 380 feet downdip (at a 6% grade)
of the ground water inflow into the decline. As discussed in Dick White's memo in
Attachment A, after sealing the water levels could potentially increase by a maximum
of approximately 15 vertical feet above the current inflow point. This is equivalent to
an additional 250 feet of flooded drift or about 630 feet of total drift that is partially
or totally under water. Given that the drift has nominal dimensions of 9 feet by 12
feet and assuming the current inflow rate of 1.5 gpm will continue over time, the
expected time for the pool to form and equilibrate is about six to nine months.
The pool is not expected to migrate because it will be contained within low-
permeable Brushy Basin mudstones and shales. A schedule for taking water level
measurements and water quality samples will be proposed to DBMS and the BLM
prior to sealing based on the inflow rates measured at that time. Once the pool reaches
equilibrium, the portal will be backfilled and reclamation of the site can be
completed.
L::net•~~ 1:uels (~e5c~tu-ces C'<>rp{:~rat~c~n 44 t!t7ic~t~ t3~~~tli;t-ard, quite CiOt~ 17
Lal:e~~~~:~~d, C;d;3 f~(}12~ t'hc~tz~; :303-t)7~-2~1~{}