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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 />or the environment; and acid mine drainage will not occur as a result of mining <br />operations, then it will be exempt from the requirement to prepare an EPP. <br />Denison believes there is a strong likelihood it will be able to demonstrate to the Division <br />that it satisfies these criteria for the Sunday, West Sunday and Topaz mines. <br />As a result, Denison proposes to prepare the Environmental Protection Plans (EPP) as <br />required by the current designation in two general phases. These phases will generally <br />follow the requirements of an EPP as established in Rule 6.4.20. Phase 1 will consist of <br />data collection required to adequately characterize the waste rock at the mines and to <br />assess the regional geology and hydrogeology at these sites specifically. The mines do <br />not store or use designated chemicals on-site for extractive metallurgical processing. <br />Denison and the Division will then be able to make a determination, based on the data <br />collected in Phase 1 if enough information is available to demonstrate that the <br />requirements for the exemption in Rule 7.2.6(1) have~been satisfied for any of the 112 <br />mines. Phase 2 will be the finalization of the preparation' of the EPP based on the site <br />specific information obtained in Phase 1. <br />The following is a discussion of Phase 1 data collection and Phase 2 EPP preparation: <br />Phase 1 Data Collection <br />Phase 1 will consist of three general categories of data collection, waste rock and ore <br />characterization and environmental pathway analysis. These three categories are <br />described in detail as follows: <br />Data Collection <br />Groundwater encountered at hese,mines is minimal. Some groundwater is used in <br />undergrouridoperations for drilling and dust suppression, and the remainder of the <br />groundwater that seeps into the underground workings is routed to sumps within the <br />underground mine workings. No,.groundwater is brought to the surface; therefore, <br />these mines are all zero discharge facilities. <br />A records review of existing geologic drill logs and groundwater information will be <br />completed inan.effort to'determine the depth to groundwater beneath the waste rock <br />areas at the mines. _ Based on this information, a hydrogeologic report will be <br />provided to the Division to assess the potential of the waste rock areas to impact <br />groundwater in the area. Soils information as discussed in the following will also be <br />provided to assess the potential for soil and groundwater contamination from waste <br />rock areas. <br />Waste Rock and Ore Characterization <br />Three of the designated mines outlined by the Division are located within <br />approximately 2 miles of each other. In some instances, these mines share <br />underground workings and in all instances the same ore body is mined. As discussed <br />3 <br />