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The applicant drilled a minimum number of exploratory wells (three?) on the far <br />eastern margin of the permit area. For some reason, the applicant did not drill in the <br />area of the known old tunnels to the west. These exploratory bores fall far short of <br />fully characterizing the area, especially the western margins of the Northfield <br />permit, where they approach the Chandler workings. The applicant's claim that they <br />will not encounter any groundwater during their operation is not substantiated. <br />Unfortunately, their design and approval of their detention pond is based on the <br />unsubstantiated claim that no groundwater will be encountered, and there is no <br />mention of quality of any such water. <br />If groundwater is encountered, such as by unexpectedly intercepting abandoned, <br />flooded tunnels, the Northfield workings may also become flooded. If even moderate <br />dewatering must be undertaken, the existing detention structure will be inadequate. <br />There is potential for a disaster, since this water may be contaminated, as mentioned <br />above. Since the Northfield operation is uphill and dangerously close to the <br />Arkansas River, there is a real possibility of contamination of the River. As we are <br />aware, the Arkansas provides irrigation and drinking water all the way to Kansas and <br />-beyond.- ---- --- -- - ---- --_ _ - -- - - - - - - -- - - - -- - - <br />Although we hope that the potential combination of events, geology and topography <br />outlined above does not happen, it is prudent to address the possibility. Therefore, I <br />recommend a requirement in their DBMS permit, to the effect that: <br />If a~ pumping of anX water is required to operate the mine, operator must <br />cease operation until water is analyzed for radionuclides and heavy metals, as <br />well as normal contaminants of concern. Permit conditions should only allow <br />resumption of operations when fully engineered pumping, storage, and <br />treatment to minimum contaminant levels are achieved. Storage and disposal <br />must be addressed. Again, it is expected that current stormwater detention <br />structures will be unacceptable. <br />It is expected that this water will be tributary to the Arkansas River. As such <br />the State Engineer should rule on the extraction, storage and disposal. <br />If the Northfield operators are correct in their characterization of the hydrology and <br />potential risks from nearby abandoned mines, there will be no consequence. On the <br />other hand, should seepage or flooding from those abandoned mines be <br />encountered, it is prudent to require responsible actions by the operator. <br />Sincerely, <br />Mi a Stiehl <br />Fremont County Commissioner <br />