permit to mine progress, page-8

Good morning all, thanks Vintage for the heads up. Its not possible to link direct to the doc as you have to search for it. I will copy the doc content here for you all.


Mr. Miles Bennett
Land Quality Division, District 3
Wyoming Department of Environmental Quality
2100 West 5th Street
Sheridan, WY 82801
RE: Submittal of Responses to Technical Comments on Strata Energy?s, Ross ISR Project Permit to Mine Application, TFN 5 5/217
Dear Mr. Bennett:
On behalf of Strata Energy, please find the enclosed original signed forms and two copies of the response package to the May 11, 2011 letter containing DEQ review comments to the Ross ISR Project Permit to Mine application. The package includes the following:
1) Original signed Form 1, Form 3, Appendix C and Form 8 documents,
2) Responses to technical comments in a question and answer format,
3) Change index detailing the volume number, pages to be removed and replaced along with a brief description of the change,
4) Labeled tabs for the Adjudication File,
5) Replacement pages, figures and exhibits.
Upon approval copies in Cheyenne and other locations will be updated with the revised material.
Strata appreciates the efficiency and equity with which LQD has reviewed this application. Feel free to contact myself or Mr. Simpson at any time if you have questions or concerns regarding the enclosed response package.
Sincerely,
Benjamin Schiffer, P.G.
Project Manager


Page 1
Response to 1st Round Technical Comments,
Ross ISR Project
TFN 5 5/217
Deanna Hill
Technical Review Comments
Form 1 UIC
1. Please submit ensuring the bottom of each page is initialed and dated.
Response:
The original signed, initialed and dated form is enclosed/attached for Deanna Hill, LQD/DEQ; Cheyenne office. No changes were necessary to the copies in the permit.
Form 3
1. Please submit ensuring the bottom of each page is initialed and dated.
Response:
The original signed, initialed and dated form is enclosed/attached for Deanna Hill LQD/DEQ; Cheyenne office. No changes were necessary to the copies in the permit.
Fees
Acceptable.
Appendix A
Acceptable.
Appendix B
Acceptable.
Appendix C
1. Please provide an originally signed appendix.
Response:
The original signed form is enclosed/attached for Deanna Hill, LQD/DEQ; Cheyenne office. No changes were necessary to the copies in the permit.

Page 2
2. Please advise the page number or provide the tabulation of lands where there is no right to mine claimed with acreage (Chapter II, 2.(b)(iv)(G)(I)
Response:
Page C1 as submitted, states: Applicants legal right to mine covers all lands listed within the permit area. Therefore, a listing of lands where ?no right to mine? is claimed (C-2) is not applicable. No changes were necessary to the copies in the permit.
Surface Landowner Consent
1. Originally signed Surface Landowner?s Consent Forms 8 must be submitted to the Cheyenne office.
Response:
Original signed Consent Form 8(s), less Berger are enclosed/attached for Deanna Hill of the Cheyenne office. No changes were necessary to the copies in the permit.
Reclamation Performance Bond
? not a completeness issue
1. An acceptable bonding instrument must be in place before approval may be granted.
Response:
An acceptable bonding instrument will be provided as a condition of final permit approval.
Miscellaneous
? not a completeness issue
1. Please provide labeled dividers to separate the various sections of the application.
Response:
Section dividers are provided for the Adjudication Volume. The change index indicates the location for the tabs.

Page 3
Glenn Mooney
Technical Review Comments
Adjudication
1.
Appendix A ? Surface Owners
This review found some serious structural problems with Appendix A
The major problem is with duplication. The listing of lands in Appendix A runs from Page A-16 to A-78c and then the listing is repeated in Pages A-79 through A-142.
Following is a summary of the makeup of Appendix A:
Pages A-16 to A-78c Pages A-79 to A-142
SESE-12 A-20/A36 A-119
Tract and Section Page No. Page No.__________
SWSW-12 A-36 A-119
NENE-13 A-20/A-20 A-121
NWNE-13 A-22 A-121
SWNE-13 A-22 A-121
SENE-13 A-22 A-121
NESE-13 A-22 A-121
NWSE-13 A-22 A-121
SWSE-13 A-25 A-123
SESE-13 A-25 A-127
NWNE-24 A-24 A-129
NENE-24 A-23 A-131
SWSW-7 A-38 A-79
SESW-7 A-39 A-81
SWSE-7 A-38 A-79
SESE-7 A-38 A-79
NWNW-18 A-50 A-86

Page 4
Pages A-16 to A-78c Pages A-79 to A-142
NENW-18 A-50 A-86
Tract and Section Page No. Page No.__________
NWNE-18 A-27 A-84
NENE-18 A-28 A-99
SWNW-18 A-50 A-86
SENW-18 Not found A-86
SWNE-18 A-27 A-96
SENE-18 A-27 A-96
W/2SENW-17 A-37 A-141
NWSW-18 Not found A-86
NESW-18 Not found A-86
NESE-18 A-27 A-96
NWSE-18 A-76 (Claim only) A-96, A-133
SWSW-18 Not found A-86
SESW-18 Not found A-86
SWSE-18 A-42 A-89
W/2SESE-18 A-42 A-92
NWNE-24 A-24 A-129
NENE-24 A-23 A-131
NWNW-19 A-16 A-111
NENW-19 A-16 A-111
NWNE-19 A-45 A-103
W/2NENE-19 A-42 A-107
E/2SWNW-19 A-16 A-111
SENW-19 A-16 A-111
SWNE-19 A-42 A-104
SENE-19 A-42 A-104
E port. NWSW-19 A-16 A-111
NESW-19 A-16 A-111
NWSE-19 A-42 A-104
NESE-19 A-42 A-104
Please correct and eliminate the above-listed duplications.
Response:
A 9:00 am, May 13, 2011 meeting at the District 3 LQD/DEQ office with Glenn Mooney and Niles Veal, concluded that Adjudication pages A-16 thru A-142 are acceptable as originally submitted. No further response is required.
2. Appendix B, Adjacent Surface Owners
No problems were found with this section. No response is required.
Response:
No response required.

Page 5
3. Appendix C, Legal Land Description
No problems were found with this section. No response is required.
Response:
No response required.
4. Surface Owner Consent
Surface Owner Consent is required for the Harry J. Berger Trust lands in Sections 17 and 19.
Response:
Required Surface Owner Consent for Harry J. Berger trust lands will be provided during the final round of technical comments.
5. Appendix E
Many of the features required on the Appendix E maps are shown instead on adjudication Maps Exhibit 1, Surface Ownership, Structures, and Grazing Leases and Exhibit 4, Rights of Ways and Easements. This is acceptable; no response is required.
Response:
No response required.
Mine Plan
6. Section 4.1, Well Field Data Package, Page 4-1
a. It is not clear what items will be submitted in the well field data packages.
Please provide a bulleted list of the package contents.
b. The discussion in Section 4.1.5, Constructions Considerations and Topsoil Handling should be limited to stating that the locations of topsoil stockpile for each well field will be depicted on the map in the well field data package for that well field. There should be a cross-reference to the main section on topsoil handling in Section 2.4 on Page 2-3.

Page 6
Response:
a. Section 4.1 was modified to include a bulleted list of the well field package contents.
b. The text in Section 4.1.4 (please note that the response to comment 7 eliminated the original Section 4.1.4; Section 4.1.5 is now Section 4.1.4) has been revised as suggested and now includes a cross reference to Section 2.4. Reference Exhibits MP.2-1 and MP.2-2 for topsoil stockpile locations.
7. Section 4.3, Conceptual Wellfield Package, Page 4-14
Please explain how the ?Conceptual Wellfield Data Package in this section is different from the Wellfield Data Page described in Section 4.1 discussed above?
Please consolidate these sections into one concise section.
Response:
The text was revised to clarify the differences between the two sections as well as to minimize redundancy. Sections 4.1 and 4.3 were revised. Section 4.1 now presents the contents of the well field package and includes an introductory section that further clarifies the contents of the well field package. Section 4.3 discusses the procedures for developing the well field package. To minimize redundancy Section 4.1.4 was combined with Section 4.3.1, which resulted in Section 4.1.5 being renumbered to Section 4.1.4.
8. Section 5.8, Water Balance, Page 5-8
The water balance calculations must show the system is capable of handling an excursion while both restoration and mining operations are occurring in other well fields. Likelihood of an excursion seems high because of the nearness of well fields.
Response:
A new paragraph was added to the end of section 5.8 to further describe the available liquid waste capacity in the event of an excursion. As is discussed in the new paragraph, excess capacity will be maintained within the lined retention ponds that would be available in the event of an excursion. Furthermore, excess capacity is also available within the deep disposal wells. In the event that more capacity is needed to control an excursion, Strata will make operational changes as necessary to manage the additional waste streams resulting from the excursion.
9. Section 5.9.1, Upper Control Limits and Excursion Monitoring, Page 5-13
Strata proposes to use sulfate as a substitute for chloride as an excursion parameter in the deep monitor wells because of the high chloride values now found there. Sulfate as an excursion parameter was tried as an excursion parameter before, admittedly in the Wasatch Formation, but its high natural variability caused false excursion problems. False excursions would be also more likely because Strata proposes to call an excursion if only one parameter increases more than 20%.

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Strata should be certain the variability of sulfate levels in the deep aquifer and the proposed 20% increase will not result in false excursions.
Response:
Strata agrees with the reviewer that there is variability in sulfate concentrations within individual wells in the DM aquifer. Strata is continuing to conduct quarterly water quality monitoring of DM wells, which will determine if the variability in sulfate concentrations noted between the first four quarterly samples will continue over time, or if variability decreases over time. Ultimately, the reliability of sulfate as an excursion parameter will be addressed in the baseline well field package assembled for the first mining unit, which will include a statistical analysis of sulfate variability along with proposed UCL concentrations.
The major ion chemistry of groundwater from the DM unit is very distinct from that of the OZ unit. The 2010 quarterly water quality sampling of the six DM monitoring wells indicates consistent water quality, both spatially and temporally. The most distinctive water quality characteristic of the DM unit relative to the other monitored aquifers in the area is relatively high concentrations of chloride, which is the dominant anion. As discussed in Section 5.9.1, sulfate concentrations in the DM unit are consistently low however, being typically less than 150 mg/L. However, the ambient levels of sulfate in the OZ unit range between 300 to more than 900 mg/L and are expected to increase by at least 150 mg/L during mining operations. Strata commits to the use of sulfate along with conductivity and alkalinity as an excursion parameter in the DM unit. As such, the fourth sentence of the first full paragraph on page 5-13 was revised to make this commitment.
10. Section 7.2.2.1.3, Land Application, Page 7-13
Strata states that radium is likely to pass through the reverse osmosis (r/o) units in undesirable amounts. Selenium is also known to pass through r/o units. Is there likely to be significant quantities of selenium in the waste water to be treated and if so, how will it be handled?
Response:
Strata does not anticipate that selenium concentrations in the permeate will be present in concentrations above 0.1 mg/L (See Table MP.7-1) Further, selenium does not become an issue unless water containing selenium is proposed for land application or surficial discharge. In order for land application to occur, a permit revision will be required. The topic of permeate selenium concentrations would be addressed in detail in the revision that would be required to accommodate land application as a water management alternative. No changes were made to the permit in response to this comment.
11. Section 7.2.2.1.3, Land Application, Page 7-13
Because of the potential for contamination by radium, any system that uses land application or SDI should be designed as fail-safe so that a wrong valve setting, blocked

Page 8
filter or similar situation cannot result in untreated water allowed to flow to the disposal site. The clean-up of lands contaminated by radium is likely to be extremely expensive.
Response:
In order for land application or SDI to occur, a permit revision will be required. The topic of radium removal prior to land application would be addressed in detail in the revision that would be required to accommodate land application as a water management alternative. No changes were made to the permit in response to this comment.
12. Section 9.5.2.4.3, Potential Reclamation Impacts to the SM, OZ and DM Aquifers., Page 9-45
Please remove the reference to Non Coal Rules and Regulations, Chapter 8. Chapter 8 covers the abandonment of exploration drill holes under Drilling Notifications only. Refer to Section 8 of Chapter 11 for the regulations relating to wells using during in situ mining.
Response:
The text in Section 9.5.2.4.3 has been updated as suggested.
13. Section 9.5.2.4.3, Potential Reclamation Impacts to the SM, OZ and DM Aquifers, Page 9-45
The last sentence of this section states ?A well abandonment and plugging methodology will be provided in the Class III Injection Permit Application.? This mining permit application is
the Class III Injection Permit Application under Wyoming law. Please provide well abandonment and plugging information in this document.
Response:
The well abandonment plan is included as Addendum RP-1. The text in Section 9.5.2.4.3 has been updated to reference this addendum.
14. Section 11.0, Reporting Procedures, Page 11-1
This section only refers to the information presented in the Annual Report. Please add the information and procedures to be presented in the Quarterly Reports, Excursion Reports, Spill Reports and other required reports.
Response:
Table 11-1 includes the items that will be presented on the quarterly reports and on the special reports, such as excursion reports, submitted on an as needed bases. A special section was devoted to describing the annual report because many of the items presented in the annual report are not included on Table 11.1. The first and second paragraphs within Section 11.0 were rewritten to further clarify what will be contained within the quarterly reports and special reports.

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15. Duplication
The duplication of several sections is confusing. For instance, Deep Disposal Wells are discussed in Section 2 on Page 2-7, in Section 7 on Page 7-15 and in Section 9 on Page 9-63. Lined Detention Ponds are discussed in Section 2.8 on Page 2-8, in Section 7 on Page 7-24 and also in Section 9 on Page 9-63. Excursions are discussed in Section 5 on Page 5-12 and in Section 9 on Page 9-60. This duplication is confusing and misleading because the subject is not discussed in the same detail in every section, leading one to the belief that the subject is not adequately addressed if only one section is found. It will also cause problems in updating the permit document. Please address each subject in adequate detail in one section and cross-reference that section to the other sections.
Response:
Revised text in Sections 2.7, 2.8, and 5.9.2 were revised to clarify where formal commitments for deep disposal wells, lined ponds and excursions are located.
16. Exhibit MP.2.6, Continuous Barrier Wall
This exhibit depicts a fence around the plant and ponds area, but not as separate fence for the ponds. It is necessary for the ponds to be fenced separately in order to bar access to big game animals and loose livestock from the ponds area. These animals could be trapped in the ponds and would severely damage the pond liners.
Response:
The entire CPP perimeter will be enclosed by a livestock and big game-proof fence. Access into the facility will be through gates (tipping type, also livestock and big game proof) that will be closed at all times except when a vehicle is entering the site. The site perimeter will be secure to big game and livestock, eliminating the need for additional fencing around the ponds. No changes were made to the permit in response to this comment.
17. Exhibit MP.2.6, Continuous Barrier Wall
This exhibit depicts one of the deep disposal wells being located at the back corner of the pond enclosures. Strata should ensure that large equipment such as drilling rigs and work-over rigs will be able to negotiate the tight access route to this well or provide an alternate access route.
Response:
The disposal well depicted on this Exhibit would be drilled prior to construction of the other facilities, eliminating the need for drill rig access. Workover rigs are truck mounted, and will be able to access the disposal well using the proposed access road without modification. No changes were made to the permit in response to this comment.

Page 10
18. Exhibit MP.2.6, Continuous Barrier Wall
This exhibit states that the containment well will be installed into bedrock. However, this exhibit describes the underlying Lance Formation bedrock as consisting of very fine sandstone, siltstone and claystone which are saturated. This type of rock could transmit large quantities of groundwater.
Please show evidence that a facility constructed to handle waste water will not in itself generate large amounts of water requiring handling and disposal.
Response:
Please see response to Larry Barbula Comment 5. Due to the low permeabilities of the underlying material, very little inflow is anticipated after the initial dewatering efforts. No changes were made to the permit in response to this comment.
19. Exhibit MP.2-7, Facilities Sediment Control Reservoir
Since this reservoir is to be fitted with a geosynthetic liner, it should be fenced to prevent big game animals and loose livestock from becoming entrapped in it and also damaging the liner. Fencing of the plant area compound that also encloses the ponds is not enough because unless the gate is kept closed at all times except when a vehicle is passing through, animals will enter the compound.
Response:
As discussed in the previously, to ensure security of the facility, access will be controlled through tipping gates that will be closed at all times other than when a vehicle is entering the site, eliminating the need for fencing inside the perimeter. No changes were made to the permit in response to this comment.
20. Exhibit MP.4-2, Proposed Drill Hole Installation Methods
This map is mislabeled as it actually depicts well installation methods. Please relabel as ?Proposed Well Installation Methods.?
Response:
Exhibit MP.4-2 was relabeled as ?Proposed Well Installation Methods.?
Reclamation Plan
21. Section 3.2.2, Estimated Topsoil Volumes and Replacement Depths, Page 3.3
This section should contain a commitment to rip the substrate for compaction reduction prior to topsoil replacement. This is especially true for areas such as roads and parking lots.

Page 11
Response:
Preparation of the surface prior to topsoil placement is discussed in Section 3.2.1, which indicates that the surface will be ripped as needed to a depth of at least 2 feet. No changes were made to the permit in response to this comment.
22. Section 5.2, Description of Work, Page RP-3-9
The proposed groundwater restoration plan does not call for the use of any kind of reductant. While the use of a reductant may not be necessary, its use is considered BPT and it should be listed as a potential restoration technique.
Response:
Strata will evaluate the use of chemical reductants during groundwater restoration. However, at this time, safety implications and feed mechanisms have not been addressed sufficiently to allow for proper analysis. Following the necessary analysis and if determined to be effective and safe, Strata would prefer to pursue this restoration alternative as a revision to the Ross ISR Project Permit to Mine at a later date. No changes were made to the permit in response to this comment.
23. Section 5.7, Containment Wall, Page RP3-3
The last sentence of the first paragraph of this section states ?The remaining trench will be backfilled with topsoil and seeded.? This is not acceptable. The use of topsoil for backfilling trenches is not acceptable. Please change to ?The remaining trench will be backfilled with subsoil, retopsoiled and seeded.?
Response:
The text in Section 5.7 of Addendum RP-3 has been updated as requested.
24. Section 6.0, Reclamation Cost Estimates, Page 6-1
A detailed review of the reclamation costs will follow once certain costs have been worked out within Land Quality internally and it is certain no major changes will be made to mine and reclamation plans.
Response:
No response necessary.

Page 12
Mark Taylor
Technical Review Comments
Appendix D-5, Geology
1. Addendum D5-2, Drillhole Tabulations: This addendum contains a list of abandoned drill holes as required by LQD R&R Chapter 11, Sec. 3(a)(xii), however, the map of these holes is provided in the Reclamation Plan. Please revise this addendum to provide a cross-reference to Reclamation Plan Exhibit RP-1-1. (MT)
Response:
A reference to Exhibit RP-1-1 has been added to the Appendix D-5 narrative (page D5-10) and to Addendum D5-2, Table 1.
Appendix D-6, Hydrology
2. Section D6.2.2.2, Monitoring/Testing Program, pg. D6-16, last paragraph: This text, as well as text at several other locations in this permit application state ??centralizers were placed at 60-foot intervals.? However, LQD R&R Chapter 11, Section 6(e) requires ?centralizers placed at a maximum spacing of one per forty feet.? Please explain this apparent deficiency. (MT)
Response:
The six existing baseline monitoring well clusters consist of 27 wells, and each well was constructed with 5-inch (O.D. of 5.56 inches) CertainTeed Certa-LokTM SDR 17 (rated 250 psi) PVC well casing that extends from ground level to the top of the target aquifer interval. Borehole diameters are 8.75 inches and the integral bell (female) end of each 20-foot long casing section has an O.D. of 6.25 inches. Manufactured PVC centralizers having an I.D. of 5.82 inches and an O.D. of approximately 8.63 inches are slid over the male end of every third joint of casing as the casing string is assembled and lowered into the borehole. The centralizers are designed to slide freely on the casing and thus ?float? as necessary between the adjacent bell ends. Only the deepest centralizer, which is set just above the top of the target aquifer, is solidly affixed to the casing with stainless steel screws that do not penetrate the inner wall of the casing. As the casing string is lowered through the final 20 feet, the centralizers tend to stay in the most constricted segments of the borehole, effectively centering the casing in the tightest intervals and ensuring optimum annular space for a continuous, 360-degree seal between the casing and borehole. Placement of each well?s annular seal was witnessed by an experienced, professional geologist (registered in Wyoming).
The spacing for the casing centralizers is described in Section D6.2.2.2 as 60 feet; however, depending on the position of the most constricted segments of the borehole, the centralizer spacing could be as little as approximately 40 feet and as much as approximately 80 feet, with the average spacing at approximately 60 feet.
To comply with the LQD R&R Chapter 11, Section 6(e) requirement, Strata has committed to placing a PVC centralizer ?on the casing string at a maximum spacing of one per 40 feet,? for all new monitor, recovery, and injection wells (see Section 4.2.1 in

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the Mine Plan). By placing a sliding-type PVC centralizer on every other 20-foot long joint of casing rather than on every third joint, the centralizer spacing could be as little as approximately 20 feet to as much as approximately 60 feet, with an average of approximately 40 feet.
Other than the statement LQD references in Section D6.2.2.2 on page D6-16 and the baseline monitoring well completion schedules that are included in Addendum D6-6, there are no other locations in this permit application where it is stated that casing centralizers were placed at 60-foot intervals.
No changes were made to the permit application in response to this comment.
3. Section D6.2.4, Groundwater use, pg. D6-28, last paragraph: This text as well as text, tables, maps, etc. at several other locations in this permit application indicate that groundwater rights were provided for lands within the permit area and within the surrounding 2-mile area. However, W.S. ? 35-11-406(a)(ix) and LQD R&R Chapter 2, Section 2(a)(i)(I)(II) requires an area three miles adjacent to the proposed permit area. Please explain/correct this apparent deficiency. (MT)
Response:
In preparation of the Ross ISR Project Application for a Permit to Mine, records of the Wyoming State Engineer?s Office were searched for groundwater rights within a 3-mile radius of the permit area, however, Strata inadvertently inserted the tabular listings, maps, etc. of water rights within a 2-mile radius, which were prepared for the U.S. Nuclear Regulatory Commission (USNRC) Environmental Report for the Ross ISR Project License Application, into Appendix D-6. The USNRC guidance to prepare an Environmental Report in support of an application for a Materials License (NUREG-1569-3, Standard Review Plan for In Situ Uranium Extraction License Application, Section 2.2.1) requires information on surface and groundwater uses within 3.3 kilometers (2 miles) of the site boundary.
The text in Section D6.2.4 (Groundwater Use) and Section D6.2.5.2.3 (Existing Water Supply Wells) has been revised to indicate that groundwater rights within a 3-mile radius of the Ross ISR Project permit area were evaluated. Tables D6-22 and D6-24 and Map D6-3 were likewise revised to include any additional groundwater rights within the 3-mile radius area.
4. Section D6.2.5.2.1, Regional Baseline Monitoring Network Results, Plant Area Piezometric
, pg. D6-41: Please incorporate the results of the groundwater samples for well SA43-18-1, SA43-18-2 and SA43-18-3 into the data presented in Table D6-26, Table D6-31, Table D6-32, Figure D6-23, Figure D6-24 and Figure D6-25. (MT)
Response:
The four 2-inch diameter piezometers were installed to assess baseline shallow groundwater conditions in the proposed plant area. Therefore, the discussion on the groundwater quality sample analyses for the plant area piezometers was included in a


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separate subsection, Plant Area Piezometers, and was not included in the discussion on the groundwater quality sample analyses for the regional baseline SA zone monitoring wells at the six well clusters (the SA Zone subsection). Statements as such were added to the first paragraph of sections D6.2.5.2.1 and D6.2.2.2 and subsection SA Zone
in order to emphasize this structural element of the groundwater quality section of Appendix D6.
For clarification, additional details about the construction of each plant area piezometer and respective contributing aquifer were added to the Plant Area Piezometers
subsection (D6.2.5.2.2). Likewise, additional groundwater quality information was added to the discussion.
As requested, the results of the groundwater samples for piezometers SA43-18-1, SA43-18-2 and SA43-18-3 were incorporated into the data presented in Table D6-26, Table D6-31, Table D6-32, Figure D6-23, Figure D6-24 and Figure D6-25.
5. Table D6-19: If available, please consider augmenting the OZ baseline data with any water levels or water quality analysis from wells OW1B57-1, OW1B58-1 and OW1B60-1. (MT)
Response:
These three monitoring wells, which target specific roll front sands within the ore zone aquifer, are located approximately 70 feet from monitoring well 12-18OZ. These wells were completed only for the purpose of conducting multiple-well aquifer pumping tests at the 12-18 well cluster. Two multiple-well aquifer pumping tests were conducted at this particular well cluster (refer to Addendum D6-7). Wells OW1B57-1, OW1B58-1 and OW1B60-1 were included in Table D6-19 although they have not been monitored for water levels or water quality.
No revisions to Appendix D-6 were made.
6. Tables D6-28, Table D6-30, Table D6-33, Table D6-36 and D6-39: For WQD?s groundwater classification purposes it would be appreciated if these tables were revised to include SAR. (MT)
Response:
Tables D6-28, D6-30, D6-33, D6-36 and D6-39 were revised as requested. Table D6-42, Plant Area Piezometer Monitoring Results, was also revised to include SAR values.
7. Addendum D6-6: Please provide lithologic logs and completion schedules for baseline groundwater wells SA43-18-1, SA43-18-2, SA43-18-3 and SA13-17-1. (MT)
Response:
As stated in Section D6.2.2.2, the regional baseline groundwater monitoring program consists of six monitoring well clusters and each cluster consists of at least four wells, each completed in a separate, consistent stratigraphic horizon. This section describes the

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well site selection process and details about monitoring well construction. Addendum D6-6, Lithologic Logs and Completion Schedules for Baseline Groundwater Monitoring Wells, which is referenced in this section, includes information for only the 27 baseline monitor wells.
Section D6.2.3.4 states that four shallow piezometers (SA43-18-1, SA43-18-2, SA43-18-3 and SA13-17-1) were installed in the SA unit for a geotechnical study in the proposed plant area, and the lithologic logs and completion details for these piezometers are included in Addendum D6-8. In addition to providing geotechnical information during their completion, the piezometers serve to provide information on baseline shallow groundwater conditions in the proposed plant area. Having effectively enhanced the shallow groundwater potentiometry within the permit area, Strata elected to incorporate the proposed plant area piezometers into the baseline groundwater monitoring network. The four shallow piezometers are therefore included in Table D6-19, although their logs and completion information are intentionally separated from those of the regional cluster wells.
Please also refer to the response to Mark Taylor?s Comment No. 10. No changes were made to the permit in response to this comment.
8. Addendum D6-7, Section 3.1.1, Exploration Hole Abandonment, pg. D6-7-18: This text indicates that Strata Energy used meticulous abandonment procedures proximate to 12-18 well cluster to ensure the hydraulic characteristic and confinement of the ore zone were not anthropogenically compromised by historic exploration drill holes. Strata Energy intends to locate and abandon all exploration boreholes in the same manner at all areas targeted for ISR production. (MT)
Response:
To emphasize Strata?s commitment to seal every exploration borehole, the following statement is included in Section 9.5.4.2.1 of the Mine Plan:
To reduce the potential of an excursion due to an improperly abandoned exploration hole, Strata will make best professional efforts to locate and abandon all exploration drill holes within the perimeter monitor well ring and beneath the central plant area. Procedures are detailed in Addendum RP-1 of the Reclamation Plan.
9. Addendum D6-7, Aquifer Test Report: This report indicates that a number of historical unsealed drill holes may have been attributed to the drawdown (ref: Section 4.3.3 and Section 4.4.3) seen during the pump test of wells 34-18OZ and 14-18OZ. I request that Strata revise this report to provide a discussion concerning the validity of the hydraulic characterization results of these pump test given these unsealed drill holes likely allowed some degree of hydraulic communication between the OZ zone and the DM zone. (MT)
Response:
Sections 4.3.3 and 4.4.3 of Addendum D6-7 state that very slight (?apparent?) drawdowns were observed in the DM wells during the 24-hour pumping phase of the

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constant discharge tests conducted at the 34-18 and 14-18 well clusters, and that they may be attributed to the compromised integrity of the shale layer (Lower Confining Unit) between the OZ and DM intervals caused by unplugged exploration holes. A discussion was added to both sections concerning the validity of the pump test results given the possibility of some degree of hydraulic communication between the OZ and DM zones. Briefly, this text includes the following: ?If unsealed drill holes did allow for some degree of hydraulic communication between the OZ and DM zones during the pumping test, the component of vertical recharge within the zone of influence of the pumped well was so minimal as to be inconsequential to the validity of the hydraulic characterization results of the test.?
10. Addendum D6-8: This addendum contains the well logs and completion details for the baseline wells in the proposed plant area. Please revise page Addendum D6-6-1 to include a note or a reference to Addendum D6-8 for the well logs and completion details for the baseline wells in the proposed plant area. In addition, please revise the text in the last sentence of the second paragraph on page D6-17 to read ??The lithologic logs and completion schedules for each of Strata?s baseline monitoring wells are included in Addendum D6-6 and Addendum D6-8.? (MT)
Response:
As requested, page D6-6-1 of Addendum D6-6 was revised to include a note stating the lithologic logs and completion schedules for the shallow piezometers located in the proposed plant area are included in Addendum D6-8.
A new paragraph was added as the last paragraph in Section D6.2.2.2 to address the shallow groundwater monitoring piezometers that are located in the proposed plant area. This new paragraph states the lithologic logs and completion schedules for the piezometers are included in Addendum D6-8.
Please also refer to the response to Mark Taylor?s Comment No. 7.
11. Addendum D6-9: If available, please consider augmenting the OZ baseline data with any water levels from wells OW1B57-1, OW1B58-1 and OW1B60-1. (MT)
Response:
Please refer to the response to Mark Taylor?s Comment No. 5.
12. Addendum D6-12, pg. D6-12-1: Please provide a note indicating that the pink boxes indicate the number of baseline samples whose results exceed the underground water class use suitability as defined by WQD, Chapter 8, Table 1. (MT)
Response:
As requested, Addendum D6-12 was revised to include a note stating the pink boxes indicate the number of baseline samples whose results exceed the underground water class use suitability as defined by WQD, Chapter 8, Table 1.

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Mine Plan
13. Section MP2.10, Containment Barrier Wall: Strata should commit to conducting additional detailed geotechnical drilling within and immediately adjacent to the proposed CPP area to gather site specific hydrogeological information prior to any construction at this site. (MT)
Response:
As part of the detailed design for the CPP, a detailed geotechnical drilling and hydrological testing program will be conducted in the area prior to any construction at the site. The near-surface geologic conditions and the hydraulic characteristics of these materials (surficial alluvial/colluvial sediments and underlying Lance Formation bedrock) will be evaluated in order to design the potential shallow groundwater control measures (i.e., containment barrier wall, well point dewatering and French drains). The results will be provided to DEQ in a separate document. No changes were made to the permit in response to this comment.
14. Section MP4.2.1, Well Construction and Completion: Strata describes the use of an end cap and wiper plug as optional. The use of a wiper plug and a cement guide shoes and have long been shown to be beneficial in primary cementing operations. Wiper plugs are used to cement casing in a wellbore. They wipe mud sheath from the casing ID, separate cement from wellbore fluids, help prevent over-displacement of cement slurry, and provide a surface indication when the cementing job is complete. Cement guide shoe guides the casing into the hole, prevents damage to the bottom of the casing and provides a landing seat of the wiper plug preventing over-displacement of the cement slurry. I strongly recommend the use of cement guide shoes and wiper plugs on all primary cementing operations. (MT)
Response:
Strata is appreciative of DEQ?s recommendation and agrees that it can be beneficial to employ the use of wiper (cementing) plugs and cement guide shoes in cementing operations. Wells used in the ISR industry in Wyoming have been installed both with and without the use of these cementing aids. Strata is of the opinion, however, that with the implementation of adequate quality control measures it is not necessary to use cement guide shoes and wiper plugs for the well completion depths in the Ross Project area. For example, as stated in the response to Mark Taylor?s Comment No. 2, the deepest casing centralizer is solidly affixed to the casing at a depth just above the top of the target aquifer; therefore, the centralizer effectively guides and centers the leading edge of the casing as it is being lowered into the borehole. Instead of using a wiper plug to prevent over-displacement of cement slurry, the volume of water necessary to displace the cement within the casing is calculated and placed in a separate holding tank. To ensure that over-displacement does not occur, the volume of displacement water is calculated based on leaving approximately 10 feet of cement within the bottom of the casing string. In addition, it has been Strata?s experience that the residual cement slurry that is left on the inside wall of the casing has not been a noticeable problem.