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Memorandum in Response to Notice of Determination of Designation Mining Operation (DMO); DRNIS 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 />None of the Carnation, St. Jude or Van 4 mines uses or stores any designated chemicals, <br />so our focus will be on demonstrating that none of those mines has the potential to <br />produce acid mine drainage in quantities sufficient to adversely affect any person, <br />property or the environment. <br />In order to make this demonstration, Denison provides the following information and <br />proposes the following sample collection for each of these three mines: <br />The rock hosting the ore body for each mine is the Salt Wash Member of the <br />Morrison Formation, which is sandstone and shale and has very low sulfide content <br />and is therefore not likely to produce acid-forming materials. 'The sandstone waste <br />produced in the mines ranges in size from fine-grained sand to rock about two feet in <br />diameter. The material on the traveled surface of the waste rock area tends to be finer <br />grained as the rock readily breaks down under mine vehicle traffic. Based on field <br />observations of the reclaimed waste rock areas at the GMG mine ,(located adjacent to <br />the Sunday Mine), vegetation has been observed to grow on the waste rock from this <br />area. Based on these field observations and the fact that the waste rock originates <br />from sandstone, it is not anticipated that the waste rock will prove to be acid <br />generating. ' <br />Because the waste rock at the three - .110 Mine sites is all. generated from the same <br />geologic member, Denison proposes to take three representative samples each from <br />the surface of the St. Jude, Carnation and Van 4-waste rock areas (nine samples total) <br />and a composite ore sample and perform an Acid Base Accounting (ABA) Test (from <br />a certified lab) to demonstrate that the waste rock from`this member is not acid <br />producing. Sample'collectio~ will occur once this procedure has been agreed upon by <br />the Division. Results of these tests will be provided to the Division within one month <br />of their collection. ` <br />If the results of.thesetests demonstrate that the waste rock does not have a potential to <br />produce acid mine drainage, then there can be no adverse effect on any person, property <br />or the environment from acid mine drainage. If the tests indicate that there is a potential <br />for acid mine drainage, then' Denison will propose further tests to determine if any such <br />potential acid`mine drainage,could adversely affect any person, property or the <br />environment. <br />112 PERMITS <br />The remaining three mines, the Sunday, West Sunday and Topaz mines, are currently <br />permitted as Regular Operations (112 permits) and are not subject to the exemption in <br />Rule 1.1(14)(e) that is applicable to the 110 permit mines. However, there is the potential <br />that one or more of the Sunday, West Sunday or Topaz mines could satisfy the exemption <br />in Rule 7.2.6(1). Rule 7.2.6(1) provides that if an operator demonstrates to the <br />satisfaction of the Division that designated chemicals will not be stored or used on-site <br />for extractive metallurgical processing; toxic or acid-forming materials will not be <br />exposed or disturbed in quantities, sufficient to adversely affect human health, property <br />2 <br />