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STATE OF COLORADO DIVISION OF MfNERALS AND GEOLOGY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 April 2, 2003 V Terry V. Wetz Director of Project Development International Uranium (USA) Corp. Independence Plaza, Suite 950 1050 Seventeenth Street Denver, CO 80265 RF~~~~~~ APR p 9 Divisional M;nere,a b., -very Re: Carnation Mine, M-1977-416, Revised Map, Site Repor[ and Corrective Actions. Deaz Mr. Wetz, DIVISION O F MINERALS GEOLOGY RECLAMATION MINING•SAFETY Bill Owens Governor Greg E. Walther Executive Dirxior Ronald W. Cottony Acing Division Director S !,s`~~1-lEf2AL ~d ~ s , Thank you for the thorough packet of updated materials for the site named above, which was received here on March 25, 2003. In this letter, I will try to comment on all of the necessary items from your packet. Boundary Chance The cover letter stated that International Uranium (USA) Corporation ("IUC") proposes a change in the boundary of this 110(2) permit. The map showing the proposed changes includes both original and proposed boundaries. It reveals that most of the present disturbance was inside the original boundaries, and that the boundary changes are minimal. The map shows the removal of undisturbed areas with corresponding additional areas to include the expanded dumps which were outside the original boundaries. The intent to configure the eastern boundary to abut the west edge of the Sunday Mine pernnit boundary is a good idea. The changes will keep the total acreage of the site at 9.76 acres, remaining under the limit for Hazd Rock 110(2) permits. I do not view this as a change constituting a formal release of part of the permitted land, nor a formal 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 [o 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 topographic or location 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 the formal release of some permitted land, then formally adding other non- permitted land to the permit. Adding land normally requires an amendment to a permit. But my research of the Hard Rock and Metals Rules reveals that amendments to Hard Rock l LO(2) permits such as this one are not authorized. I had also recently mentioned a type of technical revision involving a "land exchange" to reconfigure the boundary. My research of the Hard Rock and Metals policies reveals that no land exchanges are allowed for Hard Rock permits.