GENERAL32758

• Permit No: M1980055HR
• IBM Index Class Name: General Documents
• Doc Date: 4/2/2003
• Doc Name: Site Report and Corrective Actions
• From: DMG
• To: International Uranium ‎(USA)‎ Corp.
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
7313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
April 2, 2003

Terry V. Wetz ,/
Director of Project Development
International Uranium (USA) Corp.
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
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Re: Topaz Mine, M-1980-OSSHR, Site Report and Corrective Actions.
Deaz Mr. Wetz,
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MINING•SA FETY
Bill Owens
Governor
Greg E. Walther
Executive Director
Ronald W. Cottony
Acting Division Director

Thank you for the thorough packet of updated materials for the site named above, which was received here on
Mazch 27, 2003. In this letter, I will try to comment on all of the necessary items from your packet.
Boundary Chanee
The cover letter stated that Intemational Uranium (USA) Corporation ("IUC") proposes a change in the boundary
of this 110(2) permit. No map showing the proposed change was included in your packet, though you referred to
one recently submitted to our Denver office with your annual report. I was able to access a digital color image of
that map on my computer, which allowed me to review this proposal to some extent. (I have a favor to ask you,
which is, would you be so kind as to send me an original of the same map that you sent to our Denver office in
February? It would be very valuable for the field office set of hard copy files.)
Your proposal is to remove undisturbed areas in the NW and NE corners of the permitted land, creating new
boundaries which roughly correspond to the drainageways which exist there. Since the access road is understood to
be part of the area liable for reclamation, the change will make the total acreage of the site plus road less than ten
acres, the limit for 110(2) permits. I do not view this as a partial release of permitted land, nor addition of new
land, for reasons explained in the paragraphs below.
There have been several ongoing problems with the permit maps, marking of the boundaries, and defining the _
extent of permitted activities which are subject to reclamation liability. Our past discussions regarding the
boundary locations, adequacy of maps, and possible disturbances outside of the perceived boundaries have always
included the point that these possible offsite excursions were due to the actions of the previous permitted
operator(s) of the site and only came to the Division's attention after IUC succeeded as the permittee. In addition,
the maps available to IUC at the time of the permit transfer did not contain sufficient information to definitively tie
down the exact boundary location.
In light of these facts, and given IUC's willingness to perform the necessary mapping and inventorying of the site
to bring the permit into compliance, I will propose this idea for accomplishing a boundary change to you.
Typically, a boundary change involves release of some permitted land, then adding other non-permitted land to the
permit. Adding land normally requires an amendment to a permit. I had also recently mentioned a type of
technical revision involving a "land exchange" to reconfigure the boundary. But my research of the Hard Rock and