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Response to DRMS Adequacy Review — Cotter SR -13A Mine Reclamation Plan Amendment <br />9. Addressing Rule 6.4.21(7) – The EPP states that a radiometric survey will be completed prior <br />to mining in order to document baseline conditions at the site. Baseline conditions shall be <br />established as part of this amendment process. Please conduct a radiometric survey of the <br />affected area and submit the results to the Division along with an evaluation of the expected <br />effectiveness of the proposed EPP, which specifically addresses the risks, from uranium, <br />uranium byproducts, and any other radionuclides expected to be encountered during this <br />operation, to human health, property and the environment. <br />The baseline radiometric survey is included as Attachment 3 in this response to <br />DRMS comments. Cotter procedures for separating ore from waste rock are <br />designed to minimize the addition of uranium ore to the waste rock pile —an <br />approach that makes sense from an economic and environmental standpoint. The <br />EPP addressed several issues that evaluate the risks to human health and the <br />environment. The potential of acid mine drainage from the waste rock piles was <br />quantified by the SPLP tests that indicated this was not an issue. The hydrogeologic <br />evaluation presented in the EPP showed that factors of low precipitation, low <br />permeability, and geochemical conditions restricted potential leachate from the <br />waste rock piles from impacting groundwater resources. A detailed Drainage <br />Design Plan (Appendix 11 in the EPP) routes off -site surface runoff around the <br />waste pile and captures and contains on -site runoff from a 100 -year 24 -hour <br />precipitation event. <br />10. Addressing Rule 6.4.21 (8) – In the last paragraph on page T -12, the EPP states that <br />uranium and related constituents would be transported through the Salt Wash sandstone in an <br />east - northeast direction. It then states that transport through the Entrada Formation would <br />occur in the same northwesterly direction. Please clarify. <br />The second sentence of the last paragraph on page T -12 should read, "Average <br />transport rates in the upper -most aquifer for the area which is the Entrada <br />Formation for the Slick Rock area are approximately 40 feet per year in the same <br />northeasterly direction." <br />11. Addressing Rule 6.4.21 (8) – On page T -14, the EPP states that several "borings continued <br />through the ore zone and into the upper portion of the Salt Wash Formation". It has been <br />previously stated that the upper portion of the Salt Wash Member is the ore zone. Please <br />clarify. <br />The borings penetrated the ore zone that is located in the upper sandstone unit of <br />Salt Wash Member but did not penetrate into the middle or lower portions of the <br />Salt Wash Member. The ore zone is located within the upper sandstone. <br />12. Addressing Rule 6.4.21 (9) – On page T -17, the EPP provides information about an <br />Entrada/Navajo Sandstone well. Please provide the Division with the location of this well. <br />3 <br />