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PERMIT FILE - 11/20/2009, 9:37:00 AM-JWD
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PERMIT FILE - 11/20/2009, 9:37:00 AM-JWD
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Last modified
8/24/2016 11:28:22 PM
Creation date
11/20/2009 10:22:00 AM
Metadata
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Template:
DRMS Permit Index
Permit No
P2009012
IBM Index Class Name
PERMIT FILE
Doc Date
11/19/2009
Doc Name
Comments on Baseline Characterization
From
Western Mining Action Project
To
DRMS
Email Name
ACS
Media Type
D
Archive
No
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C-1 ' . <br />It appears from the Division's files that some of this information may already have been <br />gathered via Powertech's Notice of Intent to Conduct Prospecting File No. P- 2007 -015. For <br />instance, in a recently submitted document associated with Powertech's Notice of Intent to <br />Conduct Prospecting File No. P- 2008 -043, Powertech concedes that submittals in File No. P- <br />2007 -015 relating to previous aquifer pumping tests contain "evidence of subsurface geology and <br />hydrogeology at the proposed [site]." "Response to Division of Reclamation, Mining, and <br />Safety, September 25, 2009, Letter" NOI File No. 2007 -043 (October 28, 2009) at 2. To date, it <br />does not appear that any such data has been considered in regard to the site characterization plan, <br />despite the fact that Powertech admits its existence and relevance. While the methodology and <br />accuracy involved in the collection of this data must be reviewed, the Division should require <br />that all such data be placed in the site characterization file for review by the DRMS, its experts <br />and the public. To the extent such data is deemed scientifically defensible and reliably gathered, <br />it should be incorporated into the design of the site characterization plan. Any failure to consider <br />and use existing information to ensure the effectiveness and integrity of the site characterization <br />plan in the future not procedurally or scientifically defensible. <br />Also absent from the proposed plan submitted by Powertech is discussion of a monitoring <br />plan designed to "evaluate the effectiveness of postmining reclamation and ground water <br />reclamation plans" as required by the MLRB. Such a plan is necessary for protection of <br />groundwater and for compliance with the MLRA. The need for long -term groundwater <br />monitoring of in -situ leach uranium mining sites to ensure full reclamation in accord with the <br />explicit standards in the MLRA cannot be overstated. Indeed, as recently described by the U.S. <br />Geological Survey, "to date, no remediation of an ISR operation in the US has successfully <br />returned the aquifer to baseline conditions. Often at the end of monitoring, contaminants <br />continue to increase by reoxidation and resolubilation of species reduced during <br />remediation." J.K. Otton, S. Hall, "hl -situ recovery uranium mining in the United States: <br />Overview of production and remediation issues," U.S. Geological Survey, 2009 (IAEA -CN- <br />175/87)(emphasis added). Similar post- mining increases in contamination levels in impacted <br />aquifers are described in more detail in other USGS publications. See Hall, S. "Groundwater <br />Restoration at Uranium In -Situ Recovery Mines, South Texas Coastal Plain," USGS Open File <br />Report 2009 -1143 (2009). <br />The baseline characterization plan that was submitted by Powertech does not provide a <br />".scientifically defensible" method for a thorough characterization of baseline site conditions. As <br />detailed by Dr. Abitz in the attached report, the currently proposed methodology is neither <br />legally nor scientifically sufficient. In short, a much more comprehensive and rigorous analysis <br />of the baseline for the site area is necessary for an accurate baseline study. This includes water <br />quality information throughout the vertical extent of the affected aquifers and a spatially <br />representative sampling protocol to provide the necessary information on ground water <br />characteristics outside of the proposed mining zone, to accurately characterize site conditions. <br />Lastly, as noted by Dr. Abitz, the proposed methodology seeks to average site conditions, which <br />results in a baseline plan which is inappropriately skewed toward demonstrating a lower overall <br />water quality. Such an approach could exaggerate the true extent of any naturally diminished <br />water quality resulting from the presence of uranium and other heavy metals in the aquifer <br />region. <br />
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