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Memorandum in Response to Notice of Determination of Designation Mining Operation (DMO); DRMS File Numbers <br />M-1977-416, M-1978-039 HR, M-1977-285, M-1980-055 HR, M-1981-021 and M-1977-032. <br />Phase 1 to come to an agreement on the contents of the EPP, if required, prior to the start <br />of Phase 2. <br />As required under Rule 7.2.3(2), the EPP will be submitted within one year from the date <br />of the Notices received by Denison on February 8, 2008. However, if monitoring of <br />surface and groundwater is determined to be necessary, the five quarters of sampling will <br />have to begin at the six month juncture between Phase 1 and 2 and will then travel <br />beyond the one year period, lasting a total of twenty one months until final information <br />will be obtained. As a result, the EPP will be submitted without the benefit of the full <br />five quarters of data. <br />Deliverables <br />The Sunday, West Sunday, Carnation and Topaz mines are all located within 2 miles of <br />each other. Therefore, the site specific information for these mines will be similar in <br />nature. In addition, documentation for this process will likely be onerous and reviews <br />may be time intensive. Based on this information, Denison proposes to provide;the EPP <br />documentation for the Sunday, West Sunday and.Topaz mines in one report format for all <br />deliverables. <br />CONCLUSIONS <br />For the three limited impact mines operated by Denison, the Carnation, St. Jude and Van <br />4 mines, representative samples (three each) from each-site (nine samples total) will be <br />taken and an Acid Base Accounting test (from a certified laboratory) will be prepared to <br />access the acid-forming. potential of the waste rock at these sites. Denison believes that <br />based on these sample results, these three facilities will be exempt from DMO <br />designation under Rule 1.1(14)(e). If the cntena~for the exemption can not be <br />demonstrated, Denison}willcontinne with the completion of EPPs for those mines. <br />The remaining three facilities; the .Sunday, West Sunday and Topaz mines are Regular <br />Operation Mines. Therefore, Denison~will commence preparation of an EPP for those <br />mines as required by the current designation. Denison proposes to prepare the EPP in <br />two general phases. These phases will generally follow the requirements of an EPP as <br />established in Rule 6.4.20. '-Phase 1 will consist of data collection required to adequately <br />characterize the waste rock: and ore and assess the regional geology and hydrogeology at <br />these sites specifically;- Phase 2 will be the finalization of the preparation of the EPP <br />based on the site specific information obtained in Phase 1. Denison will evaluate the <br />information collected in Phase 1 to determine if there is enough information to <br />demonstrate that the exemption in Rule 7.2.6(1) should apply. <br />In Phase 1, Denison proposes the following steps to generate data for the preparation of <br />an EPP for the Sunday, the West Sunday and the Topaz Mines currently being <br />designated: <br />• Acid Base Accounting on representative waste rock samples (three from each <br />mine) to evaluate acid-forming potential. <br />9 <br />