GENERAL34242

• Permit No: M1977416
• 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

09-25-06
11:44AM FROM-DMG GRAND JUNCTION FIELD OFFICE 970 241 1516 T-200 P.002/003 F-037
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 detemvnation has been made as
required by DRMS regulation. Bard Rock/Metal Mining Rule 7.2.2(1) explicitly
states:
tiny time after the effective date ofthis Subsection 7.2.2, the Office
may nok; fy an Operator of the Office's determination that an
existing or proposed mining operation is, or has a reasonable
potential to be, a Designated marring Operation. The monthly
Agenda shall Notice chose operations for which the O,ffrce may
have anypending Designated Mining Operation considerations,
and upon a determination that an operation so considered, is ar is
not a Designated Mining Operation, the Office shall provide
Notice in the next regular monthly agenda.
IN1=0RM
Information
Network
for
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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 appear that this 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 monthly agendas
does not reveal any notification that DMO status was ever under consideration,
nor that such a detemunation was made. The same appears to hold txue for the
Special Sessions Mine (Permit 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-1977-310}, 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 appears to have
been previously given that the Division was considering these mines for DMO
status.
As you know, the determinaton as to DMO status formed a central aspect
of the post-Summitville revisions to the state reclamation laws and has signif~catrt
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
tv the Division's consideration of DMO status for a particulaz 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 Jntetnational Uranium Corp.'s Notice of Intent to resume
uranium mining in San Miguel Coursty and that you provide the required notice in
the monthly agenda, so that the public may be fitlly informed, as contemplated by
Rule 7.2.2. Thank you for your time and consideration ofthis letter. We would
appreciate a response to this inquiry.
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