2012-09-28_REVISION - M1977307 (23)

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mobilization of these constituents is unlikely. There is no indication of a continuous groundwater system that could provide a pathway for these constituents to migrate from the mine into the environment. Transport modeling has shown that vertical migration from the upper Salt Wash sandstone to the upper -most aquifer in the area (Wingate Formation) is highly unlikely due to the lack of water, low permeability of the strata and the sorption of uranium related constituents. 8.7 Proposed Groundwater Monitoring Plan If water is encountered during mining, then the water will be sampled and a chemical analysis performed. If levels of uranium related constituents are above established regulatory guidelines, then a well will be placed down gradient of the mining area that contains groundwater and monitored according to DRMS regulations. This approach will provide a better chance of encountering groundwater in a monitoring well rather than drilling a hole at a random location down gradient of the mine workings. The data gathered by Cotter indicates that this approach has a high probability of encountering groundwater. (9) Groundwater Quality Data Considering the depth to water, especially to the Wingate Formation, and the low quantities of available water, it is unlikely that the groundwater resources in this area will be developed. Hydraulic tests were conducted on several wells in the area but there is no report of samples sent to the laboratory for water quality analysis. The Wingate was used for domestic water supplies for the town of Uravan and therefore should be potable water. (10) Surface Water There are no perennial streams, rivers, or drainages in the area surrounding the CM -25 mine. The nearest continuously flowing river to the site is the San Miguel River that is located approximately 1.1 miles from the mine. Surface runoff from the site would eventually flow into Hieroglyphic Canyon, which does not contain perennial surface flow, before discharging to the San Miguel River. (11) Surface Water Quality Data Mining at CM -25 does not have any effects on surface water as discussed above; therefore there is currently no need for a monitoring plan. (12) Water Quality Monitoring Plan Future use of water from the San Miguel River could include municipal and irrigation applications. As discussed above in (7) and (8), it is not anticipated that the CM -25 Mine will have any adverse effect on any surface waters, thus it is not necessary at this time to implement a monitoring plan. O'Connor Design Group Inc. T - 16