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monitoring and evaluations will be performed as described in Attachment A. This issue is <br />addressed in more detail in response to Kate Pickford's and Russ Means' comments below. <br />Kate Pickfor•d: <br />The Division is not convinced that the materials submitted accurately depict the <br />hydrologic system at the site. Therefore the Division has concerns related to the effects <br />of future activities on groundwater and surface water quality and impacts that may occur <br />as a result of installation of the proposed bulkhead at the site. The Division, however, <br />does not believe it ~vor~ld be appropriate to delay approval of the permit until the <br />hydrologic regime is filly defined, as it has typically regr~ired for other applications, <br />becartse the Division believes that the operator' hill acgteir•e applicable information as <br />preparations are made to recommence mining activities at the site. <br />Therefore, the Division is willing to consider approval of the permit prior to submittal of <br />a complete hydrologic model of the site if Energy Fuels agrees to commit to performing <br />further activities aimed at defining the hydrologic regime at the Whirhvind site. Energy <br />Fuels should submit to the Division, prior to approval of the permit, a plan and timetable <br />for f stt~re activities that Ener•~ Fuels will perform in order to further define the <br />hydrologic system at the site. Such activities may include dye tracer tests to determine <br />the fate of standing water in the Whirlwind decline and Packr•nt Mine, rater level <br />measurements, gror~ndivater snapping, and modeling. <br />Energy Fuels believes that it has provided a thorough characterization of the ground water <br />conditions at the site based on the historic data and sampling conducted within the mine <br />where safe access is currently available (i.e., Whirlwind decline and Packrat portal area). <br />We appreciate DRMS's understanding of our "Catch-22" position where we cannot <br />investigate your remaining concerns without first having safe access to the Packrat Mine. <br />Safe access to the Packrat can optimistically be established in about 9 months given the <br />current work force at the mine. This will include about 2 to 3 months of rehabilitating the <br />lower portion of the Whirlwind Mine (which was recently dewatered), 4 months to drive a <br />ventilation drift from the lower portion of the Whirlwind Mine to the Packrat Mine, and 3 <br />to 6 months for installing fans, constructing ventilation seals, cleaning up roof falls, and <br />installing ground control measures (e.g., roof bolts and mats, cribbing, timbers, etc.). <br />Section 10 of Exhibit T, Ground Water Control and Monitoring, has been revised (see <br />Attachment A} to include systematic monitoring and continuing evaluation of ground water <br />conditions at the site. It is our intention to collect water data at various points as soon as <br />they become available. Some of these locations are already available, which would allow <br />monitoring to stark in 1St Quarter 2008. Other locations are dependant on safe access to the <br />underground workings or BLM approval (e.g., installation of Well W-1). A tentative <br />schedule is presented below based on the mining schedule presented in the preceding <br />paragraph and a May 2008 approval of the Plan of Operations by BLM. <br />Tentative Sampling and Reporting Schedule <br />1St Qtr. 2008: Sample and measure Whirlwind decline inflow and sump. Sample PR <br />Spring and measure water flows at both PR and DP Spring. <br />4 <br />