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(9) <br />mine site to establish a site specific baseline of current conditions. The levels of radiation from <br />natural and man -made radioactive materials needs to be clearly defined for the purposes of <br />establishing reclamation bench marks. While bioaccumulation and sequestration are important <br />tools for evaluation, they are not required by the Division and do not help establish the <br />necessary baselines. A survey shall be required on a maximum 50 foot by 50 foot grid and must <br />include current and future affected lands, with offsite control measurements. It is highly <br />advisable that areas of stormwater discharge and other critical areas be given additional <br />attention. Please note the requirement in Rule 6.4.21 (7) - Facilities Evaluation. Please submit a <br />plan for conducting a radiometric survey, for Division approval, prior to initiation. The survey <br />must be completed and submitted as part of the AM -01 EPP application. <br />(7) Section 6, Page 25 should have detailed discussions on the handling of the toxic materials such <br />as ore and waste rock, to prevent cross contamination of unaffected waste rock. How are <br />different grades of ore going to be handled and isolated from waste rock? <br />(8) On Page 0-1, Paragraph 2, it notes that water diversions and impoundments are covered under <br />the attached EPP. Per Rule 6.4.7(2) all structures need to be clearly identified and shown on the <br />Exhibit C - Mining Plan Map. The submitted Exhibit C maps do not clearly show the proposed <br />structures. <br />The groundwater data provided under Section 9 primarily appears to have been extracted from <br />the information gathered on the Pinion Ridge Mill site located north of the mine and <br />substantially lower in elevation on the Paradox Valley floor. The geological stratigraphy, as <br />presented, indicates the dip goes away from this area to the south as well as being isolated by <br />several block faults. None of the information addresses the areas to be mined but appears to <br />focus solely on the surface disturbance area of the lower mine. Per Rule 6.4.21 (8) (c) the EPP <br />must address "all geological media down to and including the upper most aquifer under <br />proposed sites of material storage, stockpiles, waste piles, disposal sites...or proposed affected <br />area where such subsurface materials and any associated waters have the potential to be <br />contaminated by ...materials that are toxic..." The submitted plan does not address the <br />potential impacts to groundwater potentially flowing under or through current or proposed <br />mining areas. The applicant needs to submit relevant geological information and a plan to <br />characterize groundwater, or lack thereof, for the areas being or proposed to be mined, not just <br />the surface disturbance area. An example cross - sectional map of a site under similar review <br />near the JD -8 is attached for reference. Also a map showing elevations in relation to mining will <br />be needed. A three dimensional evaluation is needed to analyze where compliance and monitor <br />wells may need to be placed. It is suggested that the applicant gather as much data as possible <br />and meet with the Division to discuss the groundwater characterization plan prior to submittal. <br />(10)Rule 6.4.21(8) (d) requires the identification and location on a map, in Exhibit C, "of known <br />major fracture systems that affect rock formations under proposed sites..." The Division does <br />not note the information on Maps C -1, C -2, or C -3. <br />