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Page 4 <br />ongoing characterization activities under the Act are sufficiently overseen, field operations are <br />adequately monitored, and that baseline information collected, developed, submitted is completely and <br />expertly reviewed. One tool the Act provides to accomplish this goal is to employ a third-party expert. <br />Importantly, the Act at § 112.5(5)(a) requires the DRMS to define the scope of work to be accomplished <br />by the expert. DRMS has determined that a third-party expert will be engaged to, among other things, <br />oversee and monitor Powertech's up-coming aquifer pump test in section 33, T10N, R67W, and to <br />review the April 2009 Site Characterization Plan. The aquifer pump test involves numerous wells, <br />management and disposal of naturally contaminated ground water, 24-hour operations over several days, <br />and the results of the test will be relevant to determination of whether the targeted mineralized zone can <br />be leached while minimizing impacts to overlying, underlying, and laterally adjacent ground water. The <br />stated objective of the April 2009 Site Characterization Plan is to "thoroughly characterize the pre- <br />mining site conditions at the Centennial Project prior to Powertech's mining permit application." Thus, <br />the April 2009 Site Characterization Plan is an important submittal. DRMS will conduct complete and <br />thorough oversight, monitoring, and review, and will engage a third-party expert to assist. Other aspects <br />of the scope of work for the third-party expert are still being developed. <br />d. The Fognani letter states "the potential operator will be required to conduct a thorough baseline site <br />characterization under the supervision of a third-party reviewer and submit the information to the (Mined <br />Land Reclamation Board) if and when it determines to mine the site, at which stage it will be required to <br />include all this information in its application for a Reclamation Permit." This statement seems to indicate <br />that once Powertech makes the decision to apply for a reclamation permit, it will commence a thorough <br />baseline site characterization, and that the approximately 14,000 water quality data points collected from <br />eight samplings of 21 monitoring wells in 2007 and 2008, aquifer pumping test results, samplings of <br />additional wells drilled in 2009, etc. would not form the basis of the baseline characterization required to <br />be included in the permit application. DRMS doubts this is the case but please clarify this point. The <br />DRMS has determined that it is critical that the important characterization work, pertinent to the Act, that <br />remains to be done at the Centennial and Indian Springs Uranium Project prior to the potential submittal <br />of a reclamation permit application, be done with a third party reviewer engaged. <br />Please find enclosed a letter from the Division's attorney, Cheryl Linden, to John Fognani responding to <br />certain other assertions in the Fognani letter. If you have any questions, please contact me. <br />ce ely, , <br />W <br />Allen C. Sorenson <br />Reclamation Specialist <br />enclosure(s) <br />cc: Ron Cattany, DRMS <br />David Berry, DRMS <br />Cheryl Linden, AGO <br />cAacs files\My Documents 4-19-06 thru\centennial md2 wd req md3.doc