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As the Site is an existing mining operation under an existing permit, and as the permit was granted prior to the <br />promulgation of the Rules applicable to DMOs, the existing permit and permit application for the operation of the <br />Site does not contain all of the necessary elements of an Environmental Protection Plan. As a result, please <br />take notice that Denison does not intend to file any demonstrations under Rule 7.2.3(2)(a) of the Regulations <br />that the existing permit application for the operation of the Site contains all of the necessary elements of an <br />Environmental Protection Plan. <br />As a result of the Division's determination that the Site is a DMO, Denison is required to prepare an <br />Environmental Protection Plan for the Site. Denison does not believe it is possible to complete the <br />Environmental Protection Plan within the 180 days required by Rule 7.2.3(2)(b) of the Regulations. Additional <br />time is needed to prepare the Environmental Protection Plan, for the following reasons: <br />• The Site is an existing permitted mining operation and is not currently the subject of an initial application <br />for a new mine permit. As a result, not all of the current data required to support a new application are <br />available to Denison for the Site at this time. Time will be needed to determine what existing <br />information is available for the Site that would be relevant to the Environmental Protection Plan and to <br />develop plans and programs to assemble missing information. <br />• Once the gaps in available information are identified, it will be necessary to obtain Division concurrence <br />on the manner of collecting the information. For example, sample collection and analysis and other <br />test-work programs will require Division approval prior to implementation. <br />• Because Denison is in the process of an environmental review of the Site by the Bureau of Land <br />Management ("BLM") under the National Environmental Policy Act, concurrence of BLM in some <br />circumstances will also be required. <br />• Sampling and analysis programs will have to be implemented in the field. <br />• Results of sampling and analyses will be required to be analyzed, which could lead to the need to <br />obtain more data from further sampling and analysis. <br />• Studies and reports will be required to be completed. <br />• The results of field analyses and studies will be required to be incorporated into the Environmental <br />Protection Plan. <br />• The foregoing requirements apply to the simultaneous preparation and submittal of Environmental <br />Protection Plans for six different Sites (the West Sunday, Sunday, Topaz, Carnation, St. Jude and Van <br />4 mines). <br />As a result, Denison hereby requests, pursuant to Rule 7.2.3(2)(c) of the Regulations, a period of one year to <br />file the Environmental Protection Plan for the Site. The Site is an existing permitted mine, and Denison will <br />continue to operate and mine the Site while the Environmental Protection Plan is being prepared in a similar <br />manner as it has been operated and mined in the past, without changing in any significant way the manner in <br />which ore and waste rock generated from the mine are managed. There will therefore be no incremental harm <br />that could occur to human health, property or the environment if the additional time were granted. <br />Denison believes that: <br />• The Site does not use toxic or acidic chemicals in processing for purposes of extractive metallurgy; <br />• Acid mine drainage, as defined by Rule 1 of the Regulations, will not occur or have the potential to <br />occur as a result of mining or reclamation activities or operations at the Site; and <br />• Toxic oracid-forming materials will not be exposed or disturbed at the Site in quantities sufficient to <br />adversely affect human health, property or the environment. <br />Therefore, even under the Division's interpretation of the legislation and regulations, Denison believes that it will <br />be able to demonstrate that the Site should be considered to be exempt from the requirements of Rule 7 of the <br />Regulations, under Rule 7.2.6(1). In the course of preparing the Environmental Protection Plan for the Site, <br />Denison will determine if it has sufficient information to support an exemption under Rule 7.2.6(1) and, if and <br />when sufficient information is available, will consider making further submissions to the Division in support of an <br />exemption from DMO status under that Rule. <br />dENISO~II <br />MINES <br />2 <br />