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REVISION - 3/23/2009, 10:15:20 AM-JRC
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REVISION - 3/23/2009, 10:15:20 AM-JRC
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Last modified
6/15/2021 11:34:56 AM
Creation date
3/24/2009 10:37:14 AM
Metadata
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Template:
DRMS Permit Index
Permit No
P2008043
IBM Index Class Name
REVISION
Doc Date
3/23/2009
Doc Name
Objection Letter
From
Western Mining Action Project
To
DRMS
Type & Sequence
MD2
Email Name
DAB
Media Type
D
Archive
No
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quality (e.g., flow from reduction zones into more oxidizing zones could lead to iron <br />oxyhydroxide precipitation and well fouling). The proposed volume should be compared to local <br />use of the groundwater aquifer in order to determine the level of stress the proposed activities <br />may put on the aquifer flow geometry. The Request also lacks any information related to the <br />multitude of historically drilled wells, exploration and bore holes, or other holes in the immediate <br />vicinity that may affect the hydrologic balance or groundwater quality during any aquifer pump <br />tests. <br />The analytical result submitted in Appendix E shows elevated uranium and radium-226 <br />concentrations, and Powertech uses this one measurement to conclude that the entire aquifer has <br />elevated uranium and radium. This single analysis is insufficient, and inappropriately assumes <br />complete homogeneity of the aquifer. Further, there is no information as to the length of the <br />screened interval in the well. In order to provide sufficient information, it must be screened <br />through the entire thickness of the aquifer, rather than just the ore zone within the aquifer. The <br />well must be developed until the turbidity falls below acceptable standards, as suspended <br />particles in a water sample can result in high uranium and radium values. There is also no <br />information as to how long the well was developed and whether any turbidity measurements <br />were taken prior to taking the sample. <br />Powertech proposes to collect water samples from the pump wells. If the company its <br />permitted to perfonn the pump test, the water quality samples should be collected at the end. of <br />the pump test before it shuts down the pumps. This will provide some assurance that the <br />groundwater zone affected by drilling fluids has been flushed out prior to collecting the sample. <br />Additionally, the sample should be collected from a well that is screened through the entire <br />thickness of the aquifer. These issues all further demonstrate the need for not only a <br />comprehensive baseline characterization plan, but also for a third-party expert to oversee the <br />plan, monitor field operations, and review data collection. <br />Powertech asserts in its discussion of reclamation of the water and disposal pit that <br />radium-226 must not exceed 5 pCi/g above background, and uranium must be less than 30 pCi/g <br />above background in the top 15 em of soil. Higher levels are listed for soils lower than 15 cm. <br />There is no infornation as to where these standards derive from, nor any demonstration of <br />background samples to establish the baseline soil concentrations for radium-226 and uranium. <br />There is no information as to how will background levels will be established prior to disturbing <br />any soil. Further, there is no information as to the potential soil and groundwater contamination <br />associated with the other heavy metals contained in the aquifer water to be pumped out and <br />deposited in an unlined pit on the surface. <br />The extraction and deposition of radioactive materials on the surface also implicates the <br />jurisdiction of the Colorado Department of Public Health and Environment, Radiation <br />Management Unit, and the applicable soil standards and the jurisdictional issues must be <br />resolved prior to proceeding with any commencement of the proposed activities, including <br />whether the materials extracted and concentrated at the surface constitute Technically Enhanced <br />Naturally Occurring Radioactive Material (TENORM). <br />6
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