0



18. Page 43, Paragraph I (Mitigation/Contingency Measures):
       The discussion under this section is incomplete and no supplemental
       references are cited that one could use to better understand what
the
       applicant proposes to do. Since mitigation/contingency measures to
       prevent the "unreasonable detriment of public or private water
  f\supplies... (or) public rights in the waters of the state" are crucial
       to mitigating certain impacts of the mine's operation, this entire
       section should be expanded to more completely describe the measures
       beyond what is presented in the DEIS.

19. Page 47. Table 1-22:
       Why does the operations work schedule for "mine stope production
and
       development' and "primary crushing and .. .hoisting' include
only 340
       days as opposed to 365 days per year? Is there planned or anticipated
       'downtime" associated with these work tasks?

20. Paae 48. Table 1-27:
       Total natural gas consumption on an annual basis shown in the table
  (398)does not agree with the total mentioned in the preceding paragraph.
  '   Which is the correct figure?

21. Page 50. Paragraphs 2 and 3 (sections on bedrock geology):
       There are some geologic/technical problems in these sections:
       (a)..The Rhinelander-Ladysmith Greenstone Belt is used in the DEIS
as a
  (399Jformal designator, but this terrane is not defined. This may be DNR
  '"_terminology, but it is not the terminology of the Geological and
       Natural History Survey nor the U. S. Geological Survey. Reference
to
       published technical literature should be made to clarify the location
       of this terrane.
       (b)  The term "middle Precambrian" is properly used, however
  (    Archaen/Proterozoic terminology would be more appropiate, so that
the
       interested reader can relate to the recent geological literature.
       (c)   There is no evidence in Wisconsin that a mountain-building
  e0episode occurred in the state about 1.6 billion years ago.      The
       Penokean orogeny is generally recognized to have taken place 1.9 to
1.8
       billion years ago. This period is broadly accepted as the last
       mountain-building episode in the Lake Superior region.
  M (d) The discussion of the ore-formation process is adequate for this
  l:_,ldocument, but reference to better geologic literature is recommended.

22. Page 51. Paragraph 1 (Orebody Description):
       Significantly better descriptions of the orebody have been prepared
by
       Exxon personnel and published in the public, technical literature.
       These descriptions should be used, since they more clearly explain
to
       the knowledgable reader why the possibility of uranium mineralization
  U    is very limited and why asbestiform mineralization has not been



23. Page 51. Paragraphs 2 through 5 (Bedrock Weathering):
       What is a weathering "spike?"  This is not a term in common
use in the
       relevant technical literatures. The term "argillization"
is not
   ___adequately defined nor is the process by which argillization has
   (404formed. Such weathering zones may not be impermeable as stated in
the
       DEIS as such zones associated with the iron mines near Hurley, for
       example, are believed to be subject to the ingress of surface water.
       The assertion of impermeability should be documented.

24. Page 51. Paragraph 6 (Asbestiform Minerals):
       The source of the statements concerning asbestos should be identified.
       All relevant comment on this subject matter that is contained in the
       November 14-15, 1979 memo by Greenberg and Brown should be included
       here in some form.  The GNHS study dealt with 66 thin-sections of
drill
       core selected by Exxon personnel and did not purport to be a complete
       O r exhaustive asbestos evaluation. The DEIS should identify other
       sampling and evaluation procedures relevant to asbestos monitoring
       beyond the GNHS thin-section verification study.

25. Pase 52. Paragraph 1 (Radiological Studies):
       The radiological monitoring program completed by Exxon and its
       consultants and evaluated by the DNR, GNHS, and the Department of
       Health and Social Services adequately addresses the concerns with
the
   I>Npossibilities of excessive radiological components to the Crandon
      )orebody and associated rocks.  Since uranium enrichment does occur
in
  >X-the Lake Superior region, however, additional information
       distinguishing the Crandon geology from these other Lake Superior
sites
       would be useful for the general reader.

26. Page 52. Paragraph I (Glacial Geology):
       Because of the important relationship between the geology of surficial
       materials and shallow groundwater flow, the description of glacial
       geologic units, their stratigraphic relationships, and their hydrologic
  (    characteristics should be expanded and documented.  This will give
the
       reader a better understanding of the complex geologic/hydrologic
       setting of the project area.

27. Page 52. Paragraph (Study Area):
       What evidence has been used to determine that the 20 square mile
       groundwater study area is a bounded system? Some reference to
  X documents or meetings among involved parties to this determination
       should be added here.

28. Page 52. Paragraph 7:Page 53. Paragraph 1 (Groundwater Elevation &
Flow):
       These paragraphs imply that all lake levels in the project area are
       above the regional water table. While this may be true for some lakes.