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• The dimensions of the bulkheads (perimeter area, perimeter length, cross sectional <br />area, volume). <br />• The distance to the bulkheads from the portal affects the productivity during <br />construction and therefore affecting the cost of construction. <br />• The costs of materials have gone up since the Terry Tunnel was constructed in <br />1996 although fewer materials are needed. <br />• The Terry Tunnel had a significant amount of flowing water that had to be dealt <br />with during the seal installation. The Whirlwind seal does not have that problem. <br />This reduces the amount of pumping that will be needed and removes the need for <br />a bypass pipe during construction. <br />• The Terry Tunnel was designed for 347 feet of head and the Whirlwind bulkhead <br />is designed for 38 feet (although the actual design would handle 147 feet). <br />• A smaller bulkhead needs fewer materials and less labor to build. It also requires <br />less engineering, auxiliary equipment, bracing, timber, etc. <br />• Energy Fuels believes the seal can be formed and poured in 2 weeks, which is <br />about half the time required for the Terry Tunnel. <br />• A number of other minor items described in the cost estimates. <br />21) Please identify potential areas for underground ore storage. The issue of the potential <br />contact with groundwater can not be adequately addressed unless these areas are <br />identified. <br />No ore will be stored underground. The plan calls for placing mine waste underground <br />during the later stages of mining. The waste rock will be placed near where it is mined <br />in dry areas updip (i.e., west) of the standing water identified on Map G-3 (see <br />Attachment C). The waste rock, as previously discussed, did not generate elevated <br />concentrations of radionuclides or metals during SPLP testing. <br />22) It is noted that topsoil will be used for safety berms at both the Whirlwind and Packrat. <br />Based on the fact that there is limited topsoil, the Division will require that waste rock <br />is used for such berms to protect topsoil loss frompotential erosion or mixing with non- <br />topsoil materials. <br />The recommended change will be made on the waste rock pile. Energy Fuels would <br />prefer to continue using the material scraped off the Packrat Road for the road's <br />berms. This material is not true topsoil, but rather gravels and subsoils that were <br />vegetated during previous reclamation activities. The reclamation plans calls for <br />pulling this material plus additional soil that was historically cast down the side of the <br />hill back up the slope during reclamation to create a surface that better blends with <br />the surroundings. The soil berm can be seeded during operations to minimize erosion <br />and growth of weeds, and create an improved growth media for final reclamation. <br />23) Please clam stormwater control measures for the fueling station area. There should <br />be a zero run-off design to contain spillage in the area. Also please clarify that the <br />area will be monitored on a regular basis for fuel spillage and clean-up procedures. <br />1_ncr~~, ~ui;ls Res«trrLes ~;c>r~c~ratic~~~ ~~ 11~~ac~t~ I3c;~u3eva~~d, SuiTe EiOt) 20 <br />l,al.cr~c~t~~i. C:`C) fiO12$ I'hc~~~e::3(l5-~)7~-2~f40 <br />