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3. Issues regarding wastes, hazardous or solid: (Page 4) <br />INFORM brings up several issues regarding the handling, storage and disposal of solid <br />waste. <br />DRMS by policy inspects all DMO sites on a quarterly basis. Any debris or waste <br />which is deleterious in nature will be addressed accordingly. Energy Fuels has set up a <br />regular disposal schedule for trash removal so large accumulations of trash and debris are <br />not foreseen. <br />All DRMS permit holders are required to report reportable quantity accidental spills of <br />hazardous materials to the Division within 24 hours along with the EPA and other pertinent <br />state agencies (see Rule 3.1.13). A comprehensive emergency response plan is included in <br />Appendix F which meets the requirements of the Rule. DRMS ensures that adequate <br />measures are taken to mitigate any accidental spills or releases. This process includes a <br />review of the incident to ensure proper clean-up and help prevent future similar incidents from <br />occurring. This review focuses on the incident and specific area impacted, a full review of the <br />reclamation plan is not required. <br />Waste rock geochemical analysis as required under Rule 6.4.20(14) indicates that the waste <br />material is inert. Therefore, the lining of waste pile areas is not considered necessary. <br />Energy Fuels has agreed to construct their ore pad with DRMS engineering review and <br />construction oversight. Upon reclamation the area will be excavated down 18 to 24 inches <br />and either deposited in the portal prior to sealing or shipped to a mill for processing. Any <br />location of underground rock disposal must be located above the highest post-mine water <br />levels or protected by the proposed bulkhead to prevent possible groundwater interaction. <br />Reclamation plans clearly indicate capping of waste dumps with all available soils, <br />establishment of vegetative cover and leaving permanent stormwater diversions to <br />lessen moisture infiltration into waste piles. These measures are the best available practices <br />and coupled with the semi-arid environment offer an acceptable reclamation method that <br />should prevent any type of leachate development. It is also important to note that geo- <br />chemical analysis shows no constituents of concern in the waste rocks that have a potential to <br />leach out even if unforeseen moisture invades the waste piles post reclamation. <br />4. Concerns expressed regarding milling facilities: (Page 4 and 5) <br />DRMS notes that no milling or other processing activities are proposed within the permit <br />as defined by Rule 1.1(18). <br />5. Issues of Transportation: (Page 5 and 6) <br />DRMS does not have the jurisdiction to address transportation issues beyond the permit <br />boundaries. Transportation of materials beyond the permit area are addressed by other <br />agencies. <br />6. Issues of Public Health: (Page 6) <br />DRMS addresses certain public health issues such as water quality through the Act <br />to minimize impacts from activities related to the disturbance of excavated materials. <br />DRMS is only one of several agencies that have oversight of such issues. DRMS policy is to <br />report possible issues of health and safety to the appropriate oversight agency if observed <br />