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• Remain stable under considerations of gravity, seismic activity, and specified design flood events. <br />• Support appropriate vegetation. <br />• Effectively control radiation exposure pathways. <br />• Endure for a defined period (e.g., 1000 years if technically feasible, and no less than 200 years). <br />If a new waste rock disposal facility were to be constructed, a technically feasible and likely preferred <br />location would be on the previously disturbed hillside on the north side of Ralston Creek across from the <br />current location of the water treatment building. This area is already included in the mine permit area, <br />and an engineered waste rock repository may require only a Technical Revision to the existing permit. <br />Other potential repository locations may or may not be technically or environmentally suitable. Aside <br />from engineering design challenges, difficulties of constructing a new WRP would include space <br />limitations at the site for interim stockpiling and there may not be geotechnically suitable and/or sufficient <br />quantities of borrow material at the site to use for the repository cap (may need to import capping <br />materials). <br />Offsite Disposal <br />Offsite disposal options would include transport of the material to Cotter's tailings impoundments at the <br />Canon City Milling Facility. There is plenty of space available in these impoundments, and respective <br />design criteria are sufficient to provide long -term protection of public health and the environment. <br />However, current regulatory and public acceptance issues may preclude this option. <br />A second option for offsite disposal would be at the nearby Foothills Landfill. This landfill, operated by <br />Allied Waste Services, is a Subtitle D industrial disposal facility located about 7 miles north of Golden, <br />Colorado. Mine waste from the Schwartzwalder site, considered naturally occurring radioactive material <br />(NORM), may meet the criteria for disposal at the Foothills Landfill. <br />Offsite disposal has the advantage of permanent removal of mine waste rock from the site and elimination <br />of the potential for impacts to local surface or groundwater from this source term material. However, <br />there are several potentially important disadvantages to this option. First, offsite disposal would be <br />extremely expensive. Colorado law requires DRMS to consider economic reasonableness when <br />evaluating remedial options. Onsite disposal options can provide effective long -term protection of human <br />health and the environment at significantly lower cost. <br />Secondly, offsite disposal could set a regulatory precedent in Colorado for management of waste rock <br />from a uranium mine. This could result in an economic deterrent to future conventional uranium mining <br />in a state known to contain among the largest reserves in the country. With the resurgence of interest in <br />nuclear power due to concerns associated with climate change and overreliance on fossil fuels, this could <br />represent a significant loss of future economic activity in the state. In many cases, the high costs of <br />offsite disposal could be far beyond realistically achievable levels for most companies, rendering uranium <br />mining, and potentially other types of mining, untenable economic endeavors in the State of Colorado. <br />Third, transport of alluvial fill mine waste offsite could involve over 3,100 twenty-five ton truckloads of <br />source term material being shipped through the Bear Tooth Ranch residential community and along State <br />22 <br />