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Given the broad discretion inherent in DRMS via these Rules, and given that lined and closed <br />loop pit systems are regular practice in the oil and gas industry, DRMS should strongly consider <br />implementing these measures here. At minimum, DRMS should require the applicant to set forth in <br />detail the sampling, testing, and monitoring protocols and practices that it will implement to ensure <br />compliance with its commitment that "[n]o mineralized (radioactive) cuttings will be buried within the <br />surface containment pits." <br />Regarding baseline characterization, on page 2 of Appendix A to the NOI, the applicant asserts <br />a lack of any need for any pre - drilling surveys. However, later (as discussed below), the application <br />admits that flowing groundwater may be encountered during drilling. In cases such as this, DRMS <br />should consider requiring the operator to conduct baseline characterization of groundwater quantity <br />and quality, and to line its drill pits to avoid potential for groundwater contamination. <br />Groundwater <br />Drill pits used during prospecting or mining shall be constructed and operated to minimize <br />impacts to public health, safety, welfare and the environment, including soil, waters of the <br />State, including groundwater, and wildlife. In its discretion, the Office may require the use of <br />pit liners, fencing, netting or other measures to minimize impacts to the public health, safety, <br />welfare and the environment. <br />On pages 3 and 5 of Appendix A to the NOI, the applicant acknowledges the potential for <br />intercepting groundwater during drilling. However, the NOI materials contain no specifics for how the <br />drilling operation will deal with this potential should it occur. Rather, on page 4 of Appendix A to the <br />NOI, the applicant asserts that if drilling intercepts flowing aquifer, the "drilling will pause and the <br />permitting agencies will be consulted for recommended abandonment methods." However, rather than <br />leave these issues entirely to future analysis, DRMS should require the operator to provide a more <br />detailed description of the measures to be employed should groundwater be encountered. <br />Given the DOE's suspension of all exploration permitting on DOE lands, such as those <br />proposed for exploration here, DRMS and the applicant should use the time to gather additional <br />information to ensure protection of the hydrologic balance, and the quantity and quality of ground and <br />surface waters. <br />Sheep Mountain Alliance looks forward to working with you on this NOI application. <br />Sincerely, <br />/s /Jeffrey C. Parsons <br />Jeffrey C. Parsons <br />Western Mining Action Project <br />on behalf of Sheep Mountain Alliance <br />3 <br />