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Page 2 of 2 <br />2) To allow monitoring of the potential increase in mine inflow over time as a result of mine <br />expansion, during those periods when pumping of standing water from the mine is <br />performed, I recommend that Energy Fuels be required to include the quantity of water <br />pumped in their periodic reporting obligations. <br />3) Pg. 6. Applicant states that "drinking water standards do not apply to mine water <br />discharge." Please provide the rationale for this statement. Is applicant implying that the <br />mine discharge is sufficiently distant from any drinking water intake that the site specific <br />conditions allow this generalization, or is the applicant citing a specific regulation? <br />Additionally, applicant contradicts this assertion by presenting a rationale for why sulfate, <br />for which the only regulatory limit relates to drinking water, will not exceed its regulatory <br />limit of 250 mg/ L. <br />4) Pg. 7. Applicant states that the probability of contaminating the strata beneath the <br />waste rock piles and other surface facilities is "virtually nil" because of the low permeability <br />and extensive thickness of the intervening mudstones. Vertical permeability values iri the <br />range of 10-~ t 10-11 cm/sec are referenced. DRMS acknowledges this, but reminds <br />applicant to be cognizant of the potential for fracture flow beneath those facilities, in which <br />case a downgradient monitoring well is clearly justified. <br />5) Pg. 7. In reference to the proposed monitoring well, applicant states "if the lower Brushy <br />Basin sandstones are not present, the boring will be abandoned....." DRMS suggests that <br />the monitoring well be installed even under such conditions, providing ground water is <br />encountered. Even completing the well in the Salt Wash Formation, despite the poor water <br />quality that characterizes the formation, could provide indications of mine-related impacts <br />and allow an early warning to prepare mitigation measures. Furthermore, reference is <br />made to establishing baseline conditions, and so far baseline conditions are limited to data <br />from the mine pool, mine inflows, springs, and historic information. A monitoring well will <br />provide essential baseline data. <br />6) Pg. 8. Applicant refers to established baseline data. DRMS reminds the applicant that <br />establishing baseline conditions is an extremely important step in protecting the operator <br />from culpability in the event of future environmental impacts for which the ultimate origin <br />is in question. <br />7) Pg. 15. Regarding the statement that the bulkhead will be installed below the mir.~e <br />seepage to prevent that water from entering the mine. DRMS is not clear on what is to <br />prevent mine seepage from building up in the drift and flowing out of the mine portal. Even <br />if the mine entrance area is backfilled, the backfill material will likely not be impermeable. <br />2/6/2008 <br />