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(g) Disturbances to the prevailing hydrologic balance of the affected land and of the <br />surrounding area and to the quality and quantity of water in surface and groundwater <br />systems both during and after the mining operation and during reclamation shall be <br />minimized <br />C.R.S. § 34-32-116(7). <br />Lastly, this same section of the MLRA requires consultation with the affected local <br />governments: <br />Prior to approving any new reclamation plan or approving a change in any existing <br />reclamation plan as provided in this section, the board shall confer with the local board <br />of county commissioners and the board of supervisors of the conservation district if the <br />mining operation is within the boundaries of a conservation district. <br />C.R.S. § 34-32-116(7)0). No such consultation appears to have occurred in this case. <br />With respect to the content of Powertech's Request for Modification, substantial critical <br />information is lacking, including information necessary to establish compliance with the MLRA. <br />In particular, without full knowledge of the previously existing groundwater quality, there is no <br />rational way to comply with the specified land and groundwater protection requirements. As <br />amended by HB 08-1161, in the special case of in situ uranium leach mining, the MLRA <br />requires that baseline conditions must be protected during any site activities, especially when <br />these activities seek to extract 170,000 gallons from the aquifer which covers the target <br />uranium ore body. <br />This lack of groundwater quality information is highlighted by Powertech's statement <br />in its Request for Modification that the aquifer pumping tests are designed to "determine the <br />hydrogeologic properties of the sedimentary rock units that host uranium mineralization as well <br />as adjacent rock units." Request for Modification at 1(emphasis added). However, it appears <br />that Powertech has submitted as part of its Request for Modification data from only two sample <br />points for groundwater quality - one for the deep aquifer from which it hopes to extract, and one <br />from the shallow aquifer into which it hopes to dispose of its produced water. Apart from the <br />invalidity of relying on such a paucity of samples and the commensurate unsupportable <br />assumption of homogeneity of both aquifers, there is no data or information as to what <br />conditions and uses exist in, or what impacts may occur to, these amorphous "adjacent rock <br />units." <br />Additional critical technical infoianation is also lacking. For instance, there is no <br />discussion on the geometry of the wells with respect to the location of pumping wells versus <br />wells used to monitor the pressure drop. There is also no discussion of whether the monitoring <br />wells are in overlying and underlying aquifers as well as the target aquifer, as is appropriate. <br />Further, no models are identified to support the contention that Powertech will get the expected <br />response in 144 hours. <br />There is no demonstration as to how pumping some 170,000 gallons out of the aquifer is <br />likely to change the hydraulic flow within the aquifer, which can lead to changes in groundwater