GENERAL31010

• Permit No: M1981021
• IBM Index Class Name: General Documents
• Doc Date: 9/25/2006
• Doc Name: Inquiry
• From: INFORM Colorado
• To: DRMS
• Permit Index Doc Type: General Correspondence
• Media Type: D
• Archive: No

As the Division undertakes this review, we anticipate a notification of
pending DMO considerations by DRMS in the monthly agenda report followed
by another notification in the event that a determination has been made as
required by DRMS regulation. Hazd Rock/Metal Mining Rule 7.2.2(1) explicitly
states:
Arty time after the effective date of this Subsection 7.2.2, the Off ce
may notify an Operator of the Office'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 Office may
have any pending Designated Mining Operation considerations,
and upon a determination that an operation so considered is or is
not a Designated Mining Operatiott, the Office shall provide
Notice in the next regular monthly agenda
Information
Network
for
Responsible
Mining
Although the language of Rule 7.2.2 plainly requires notification in the
monthly agenda of any pending DMO consideration as well as notice that such a
determination has been made, it does not appeaz that this regulation has been
consistently adhered to in the past. For instance, in the case of the Robin
Redbreast Mine (Pemmit No. M-2005-058), the Division's records indicate that a
determination as to DMO status was made, but a review of past monthly 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 taste for the
Special Sessions Mine (Pemvt No. M-1984-176), which also underwent some
DMO consideration, yet does not appeaz 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-1977-310), JD-8 (Permit No. M-1984-014), JD-9 (Permit No. M-1977-
306), and SM-18 (Permit No. M-1978-116), no formal notice appeazs to have
been previously given that the Division was considering these mines for DMO
status.
As you know, the determination 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 monitor, track, and assess the impacts associated
with proposed mining operations. As such, eazly 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 status
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.
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INFORM