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5) The permit application identifies both the White Mesa Mill and the proposed Paradox Mill as <br />potential processing sites for the ore. This will result in a change in transportation routes. Nowhere <br />does the application fully detail the road impacts associated with either route. <br />6) The application asserts that for ventilation shafts, a "closure procedure will be submitted" (Ex. D at <br />p. 10). There is no reason given why this information cannot be submitted for review by the agencies <br />and the public. <br />7) Reclamation estimates are given, but there is some mention of a decrease in costs as a function of <br />the mine operator conducting the work itself. Of course, all reclamation costs must be calculated based <br />on the assumption that the regulators would hire 3 party contractors to conduct the work. <br />8) While the application indicates a dearth of groundwater in the area, there is a paucity of data <br />contained in the application. Indeed, the application admits that the ventilation bore -holes may <br />encounter ground water. In order to provide a complete application, the applicant should be required <br />to provide data demonstrating the full extent of the water resources on the site (surface and ground). <br />Further, the site, including any ventilation bore -hole sites, should be studied for baseline conditions <br />pursuant to determine the impacts on ground water associated with construction. <br />9) No sampling from stormwater is evident in the application. While stormwater designs are <br />provided, water quality monitoring information on existing quality ensures adequate water quality <br />protections. <br />10) The application asserts that "mining operations" have taken place on the site and that <br />"development" activities will continue at the site. Ex. C at pp. 4, 7. This should raise questions as to <br />what activity has taken place on the site, as the only lawful activities are those considered <br />"prospecting." Questions also arise in this regard as to compliance with U.S. EPA radon regulations, <br />as discussed above. The application should clarify the scope of activities that have occurred and verify <br />that no activities other than that approved via a prospecting NOI have occurred and that all radon <br />regulations have been complied with. <br />Thank you again for the opportunity to participate in this process, and Sheep Mountain <br />Alliance and Center for Biological Diversity look forward to working with you on this 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 />and Center for Biological Diversity <br />5 <br />