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place and "erosion control measures and fuel tank security aze noted as issues of concern for future monitoring." Id. The DOE has released an Environmental Assessment and a decision to continue and expand its uranium leasing program in Western Colorado. DRMS has participated in the DOE analysis, although no documentation of the DRMS comments or other DRMS participation is reflected in DOE records. In sum, SM-18 is an old underground uranium mine with currently exposed uranium ore and wastes which has operated sporadically for several decades, has been restarted and operated for a short time in 2005, and has significant problems that are identified in public records. As of April 5, 2006, mining operations at the mine have again ceased. The federal owner is currently considering whether or not to reissue the tease, subject to auite-specific NEPA analysis. The DOE depends heavily on the state regulation of the SM-18 uranium mine and has based its leasing program decision on the assumption that these federal mines will receive full regulation under Colorado State law. IV. ADDITIONAL TOXICITY FACTORS, ACID-FORMING PROPERTIES, AND PROTECTIVE MEASURES ASSOCIATED WITH URANIUM MINING Contrary to the underlying assumption of the Division and Cotter, uranium mining adds a level of toxicity and acid forming potential that is not found at other mining operations. In addition to the typical suite of potential problems, uranium mines pose unique factors. These issues are summarized in the federal Environmental Protection Agency's January 2006 report: Technologically Enhanced Naturally Occurring Radioactive Materials from Uranium mining, Volume 1 Mining and Reclamation Background (June 2007 revision) ("EPA TENORM Report") Excerpts have been provided as attachments and a full electronic copy has been provided to all parties. The human health impacts of radon is well established. Pursuant to the Clean Air Act, the "EPA limits emissions of radon from operating underground uranium mines such that exposures to a member of the public is limited to no more than 10 millirems annually, and the operator must provide a report of their compliance to that requirement to EPA yearly." Exh. 5 (EPA TENORM Report) at 3-23. Although this information should be readily available, Cotter has not presented any information on its efforts to conform to the radon emissions limits applicable to the SM-18 mine. Although the radon from the ore, protore, and waste rock stockpiles at the SM-18 mine are likely to pose a significant health threat, no analysis of the radon emissions is included in the Division's non-DMO determination. Further, radon in underground mines poses ongoing threats to the public and to miners. Radon measurements in some abandoned underground mines where mechanical ventilation has ceased aze quite high, and pose risks for prolonged human exposure by members of the public visiting for recreation, exploration of old workings for geologic purposes, or reclamation workers.