GENERAL30488

• Permit No: M1977285
• IBM Index Class Name: General Documents
• Doc Date: 9/25/2006
• Doc Name: Notification of DMO
• From: Brian Farnsworth
• To: DRMS
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

09-25-D6
11:44A11 FROt1-DMG GRAND JUNCTION FIELD OFFICE 9T0 241 1516 T-2D0 P.002/D03
As the Division tuzdertakes this review, we anticipate a notification of
pending DMO considerations by DRMS in the monthly agenda report followed
by another notificarion in the event that a determination has been made as
required by DRMS regulation. Lard Roelr/Metal Mining Rule 7.2,2(1) explicitly
states:
Any time after the effective date of this Subsection 7.2.2, the Office
may nok; fy an Operator of the Off ce's determination that an
existing or proposed mining operation is, or has a reasonable
potential to be, a Designated Mining Operation. The monthly
Agenda shall Notice those operations for which the O, ffice may
have any pending Designated Mining Operation considerations,
and upon a determination that an operation so considered, is ar is
not a Designated Mining Operation, the Off ce shall provide
Notice in the next regular monthly agenda.
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Although the laggttage of Rule 7,2.2 plainly requires notification itt the
monthly agenda of any pending DMO consideration as well as notice that such a
deterr»;nation has been made, it does not appear that tltis regulation has been
consistently adhered to in the past. For instance, in the case of the Robin
Redbreast Mine (Permit No. M-2005-058), the Division's records indicate that a
determination as to DMO status was made, but a review of past montlily agendas
does not reveal any notification that DMO status was ever under consideration,
nor that such a determination was made. The same appears to hold true for the
Special Sessions Mine (Ferrell No. M-1984-176), which also underwent some
DMO consideration, yet does not appear to have been noticed in the monthly
agenda. Lastly, while the Division did give notice that a DMO determination had
been made with respect to the Cotter Corporation uranium mines JD-6 (Permit
No, M-1977-3I0}, JD-8 (Permit No. M-19840I4), JD-9 (Permit No. M-1977-
306), and SM-18 (Permit No. M-1978-116), no fottnal notice appears to have
been previously given that the Division was considering these mines for DMO
status.
As you lrnow, the deteaniuation as to DMO status formed a central aspect
of the post-Summitville revisions to the state reclamation laws and has significant
impact on the public's ability to n;tonitor, track, and assess the impacts associated
with proposed mining operations. As such, early and consistent public notice as
to the Division's consideration of DMO status for a particular mine is critical to
the public's ability to participate in the mine permitting process,
We ask that you conduct a full regulatory review, including DMO states
review, with respect to International Uranium Corp.'s Notice of Intent to resume
uranium mining in San Miguel County and that you provide the required notice in
the monthly agenda, so that the public may be fully informed, as contemplated by
Rule 7.2.2. Thank you for your time and consideration of this letter. We would
appreciate a response to this inquiry.
F-03T