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

recharge from crop irrigation above the mine and directly from John Brown Creek,
which is a perennial stream. Water contained within the Raja 30 Mine cannot migrate
into the proposed Whirlwind drifts because the Whirlwind Mine is located more than
'/4-mile away and the Top Rim sandstone has very limited hydraulic conductivity.
Energy Fuels has proposed a 200-foot buffer between any future mining on Beaver
Mesa and the Raja 30 Mine.
Energy Fuels will be sealing the water inflows into the mine from both existing and
future water sources. This will include grouting the 10-Straight Vent Shaft, plugging
historic drill holes, and constructing bulkheads, where necessary. At this time, only
one bulkhead has been determined to be necessary. This bulkhead will be constructed
near the base of the Whirlwind Decline, as discussed in detail under Items 9 and 20
below. The bulkhead is designed to prevent the water which is seeping into the
decline from entering the mine workings after mine closure. Energy Fuels believes
that installation of this bulkhead and the other aforementioned seals will result in
substantially less standing water within the mine workings than is currently the case.
In summary, source control measures are designed to prevent water from
accumulating in the mine and creating pools that could produce a seep or spring on
the surrounding hillside. Although the potential for encountering additional sources
of significant ground water inflows is low, Energy Fuels will post a surety bond to
cover the installation of a second bulkhead seal, should it become necessary. This
"contingency seal" is discussed in more detail in Item 20 below.
S) Pg D-4: Was the treatment plant sized to accommodate the flow that might occur if
the measures proposed to minimize mine inflow, e.g., grouting of the Ten Straight
and plugging of historic bore holes, are unsuccessful, and in the event of increased
mine inflow due to the reasons stated in (4) above?
The treatment plant has a minimum capacity of 20 gpm and was sized to
accommodate the existing known flows in the Whirlwind Mine (1.5 to 5 gpm) and
Packrat Mine (3 to 4 gpm) while operating 40 to 60 hours per week. Source control
measures and use of the water for mining purposes is expected to result in a situation
where water treatment may only be necessary during temporary shutdown periods.
Should additional water inflows be encountered during development, the plant could
be operated more hours (e.g., 24/7) until source control measures could be
implemented.
6) The Lyntek Report (Appendix H) states that application of ferric sulfate and barium
chloride "will not result in increasing the concentrations of barium, chloride, iron,
and sulfate in the treated water above applicable water quality standards. " Please
provide the projected effluent concentrations of barium, chloride, iron, and sulfate in
discharge water from the treatment plant.
Lyntek's recommended dosage rates were 4.875 milligrams per liter (mg/L) for ferric
sulfate (Fe2(SO4)3) and 30 mg/L for barium chloride (BaCI). These dosage rates
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