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despite the poor water quality that characterizes the formation, could provide indications <br />of mine-related impacts and allow an early warning to prepare mitigation measr~res. <br />Furthermore, reference is made to establishing baseline conditions, and so far baseline <br />conditions are limited to data from the mine pool, mine inflows, springs, and historic <br />infor•rnation. A monitoring well will provide essential baseline data. <br />Agreed. Monitoring Well W-1 will be maintained for the life of the permit, even in the <br />case where it is installed and no water is encountered, as long as a zone is encountered <br />the potentially transmit water. See Attachment A. <br />6) Pg. 8. Applicant refers to established baseline data. DRMS reminds the applicant that <br />establishing baseline conditions is an exb•emely important step in protecting the operator <br />from culpability in the event of future environmental impacts for which the ultimate <br />origin is in question. <br />Agreed. <br />7) Pg. I5. Regarding the staternent that the bulkhead tivill be installed below the mine <br />seepage to prevent that tivater from entering the mine. DRMS is not clear on tivhat is to <br />prevent mine seepage from building up in the drift and floti~~ing out of the rnine portal. <br />Even if the mine entrance area is bacl~lled, the bac1~11 material will likely not be <br />impermeable. <br />The water-bearing zone in question is an unconfined perched aquifer within channel <br />sandstones of limited lateral extent. The ground water is currently present only near the <br />base of the Brushy Basin sandstone unit and is flowing into the decline at a very low rate <br />(less than 2 gpm). Since the ground water is unconfined, it will not flood elevations <br />higher than the point of entry. Therefore, water from this source will not flood the mine <br />such that water discharges fiom the portal. This will be verified by additional 5 quarters <br />of monitoring after the pool of water behind the seal stabilizes (see response to Allen <br />Sorenson's comments below). <br />Allen Sorenson, <br />The Applicant proposes four samples from the new monitoring i~~ell over one year for <br />baseline characterization; DRMS will require a minimum 8-samples, relatively equally <br />spaced, over 1.25 years. The Applicant has provided per•rneability testing results for a <br />sample of the top r•im of the Salt Wash Member of the Morrison Formation. It is <br />important to recognize that the permeability of the intact rock does not control gr•orrnd <br />water velocity in the formation, where primary ground tivater movement is likely to be <br />fractrn•e controlled. DRMS will require ongoing ground water evaluations as mining <br />pr•ogr•esses, and in par•tictrlar• is concerned with the potential for• surface emergence of <br />mine water at the PR Spring or elsewhere. <br />Energy Fuels agrees to collect 8 samples from Monitoring Well W-1 over the first 5 <br />quarters after well completion to establish baseline conditions. Ongoing ground water <br />