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by staff. <br />7. Concerns of cumulative impacts: (Page 6, 7 and 8) <br />The Act and Rules do not address cumulative impacts from mining activities. Therefore, DRMS <br />has no jurisdiction to review such impacts. With regard to Environmental Impact Studies and <br />the National Environmental Policy Act, the BLM as a Federal agency has this authority and is <br />addressing those issues through their processes. <br />8. Proposed future operations: (Page 8) <br />Energy Fuels notes the possible future connection to historic mines adjacent to the Whirlwind <br />Mine. Such connections are not a part of this application and review process. DRMS will <br />require a technical revision or amendment to the Whirlwind Mine permit as deemed appropriate <br />if and when such activities are formally submitted. Any proposed disturbances or other impacts <br />will be reviewed under the Act. <br />9. General Environmental Issues: (Page 9) <br />DRMS review of water resources has been noted in prior issues. DRMS review indicates that <br />geochemical analysis of waste and ore rocks has been addressed appropriately under the Act <br />and Rules. <br />Impacts to air quality are the jurisdiction of the CDPHE Air Pollution Control Division. The <br />permit application indicates an Air Pollution Emission Notice (APEN) has been applied for <br />through that Division. By Rule, all required local, state and federal permit applications must be <br />applied for; however, DRMS approval of a reclamation permit is independent of those <br />processes. All proposed required licenses are noted in Exhibit M, Other permits and Licenses <br />per Rule 6.4.13. <br />10. Bonding Concerns: (Page 9) <br />DRMS has calculated the final reclamation liability currently to be $375,078.00. This calculation <br />is based on information supplied to DRMS or proposed within the application. As to the issue of <br />long term water treatment, data does not support the need for treatment in any post mine <br />reclamation. DRMS has the ability to review all warranty calculations at anytime to ensure that <br />adequate financial surety is available for reclamation or when changes to the permit dictate a <br />review. <br />11. Temporary cessation Issues: (Page 9 and 10) <br />Rule 1.13 for temporary cessation (TC) applies to permit holders not sites. Energy Fuels has <br />applied for a new permit, this is held independent of any past permits or activities. No active <br />reclamation permits are issued for the site to any other entities. Therefore, DRMS can find no <br />issue with regard to the TC rule. If Energy Fuels were in the future to apply for a TC it would be <br />considered a Technical Revision by DRMS and would be processed under Rule 1.13. <br />