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amount of water treated in these batch runs will be approximately 50,000 to 90,000 <br />gallons per month. This is just a small fraction of the permit limit of 900,000 gallons per <br />month (based on 0.03 million gallons per day). <br />Energy Fuels is required to take samples on a weekly basis in accordance with the <br />Whirlwind Mine discharge permit number CO-0047562. In accordance with this permit, <br />Energy Fuels will take composite samples of every batch run discharge and analyze the <br />samples for weekly, monthly, or quarterly parameters, as appropriate. This sampling <br />compositing and frequency is designed to provide representative samples of the treatment <br />plant discharge. The sampling is supervised by the wastewater treatment operator who <br />has a minimum of a Class B water treatment license. It requires considerable training and <br />years of experience to obtain a water treatment license with the State of Colorado. <br />Penalties which can be imposed by the USEPA under the Clean Water Act for <br />falsification of information are very harsh. Under section 309 of the Clean Water Act: <br />"Any person who knowingly makes any false material statement, representation, <br />or certification in any application, record, report, plan, or other document filed <br />or required to be maintained under this Act or who knowingly falsifies, tampers <br />with, or renders inaccurate any monitoring device or method required to be <br />maintained under this Act, shall upon conviction, be punished by a fine of not <br />more than $10, 000, or by imprisonment for not more than 2 years, or by both. If <br />a conviction of a person is for a violation committed after a first conviction of <br />such person under this paragraph, punishment shall be by a fine of not more than <br />$20, 000 per day of violation, or by imprisonment of not more than 4 years, or by <br />both. " <br />Energy Fuels will not put any of its employees, who collect the samples and report the <br />data, or senior management, who sign off on the data, at risk by intentionally falsifying <br />data (e.g., by not following standard sampling procedures or directly altering data). <br />Energy Fuels also conducts periodic training of its employees to insure that they <br />understand the appropriate procedures for collecting, preserving and shipping <br />environmental samples. <br />The laboratory that Energy Fuels is using to analyze the weekly, monthly, and quarterly <br />samples (excluding WET tests) is Energy Laboratories, Inc. (Energy Labs). Energy Labs <br />is highly qualified to analyze the water samples for general and radiochemistry. The <br />Casper, Wyoming branch of Energy Labs, where the discharge samples are sent for <br />analysis, holds 23 certifications for analysis of environmental samples. Among those <br />certifications, they hold CDPHE Safe Drinking Water Act General Chemistry, CDPHE <br />Safe Drinking Water Act Radiochemistry, and USEPA Region VIII Safe Drinking Water <br />Act/Radiochemistry certifications that are directly applicable to the types of analysis they <br />provide for the Whirlwind Mine discharge samples. These certifications are granted only <br />after a painstaking procedure to qualify the lab is performed based on physical <br />inspections and validation of analytical data provided by the lab. Energy Fuels considers <br />the analytical data provided by Energy Labs to be accurate and feels that the certifications <br />held by Energy Labs bear proof that this is the case. All data provided by Energy Labs is <br />I~,ner~~ t't.teis, Iric.. 4~ lJrSit~n i~l~tt., ~SUi~e fi~i6,l <br />aww,a.eraer~y~ii.ieas.ca>ri~i i,~kea~vso~~, E;~~h>ra:i;~l~~12~ <br />Yhcs~e: 3C~;3-~)7~1-~? t-~U <br />r~4: 3 (~3-r?'74-2141 <br />