2008-05-09_GENERAL DOCUMENTS - M1980055HR

• Permit No: M1980055HR
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 5/9/2008
• Doc Name: Division's Response to Operator's Memo
• From: DRMS
• To: Denison Mines
• Permit Index Doc Type: Gen. Correspondence
• Email Name: RCO
• Media Type: D
• Archive: No

STATE OF COLORADO
~~, DIVISION OF RECLAMATION, MINING AND SAFETY
/Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
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COLORADO ~~-
D 1 V I S I O N O F
RECLAMATION
MINING
-&-
SAFETY
~ MAY l d 'Z008 Bill Ritter, Jr.
May 9, 2008 Governor
. Uivesior' oa ~teciumation,
i~/iiP3if1 Harris D. Sherman
Ms. Christy Woodward 9 and Safety Executive Director
-(ts/Denison Mines (USA) Corp. Ronald w. cattanY
1050 Seventeenth Street, Suite 950 Division Director
Natural Resource Trustee
Denver, CO 80265
Re: Division Response to Operator's Memo (Draft dated March 31, 2008) Concerning a Proposed Program
for Designated Mining Operation (DMO- ) E onmental Analysis, at the Sunday Mine Complex and Van 4
Mine. Pertaining to:
Sunday Mine, Permit M-1977-285; Carnation Mine, Permit M-1977-41.6;
St. 7ude Mine, Permit M-1978-039 HR; Topaz Mine, Permit M-1980-055 I~ '~
West Sunday Mine, Permit M-1981-021; and Van 4 Mine, Permit M-1997-032.
Dear Ms. Woodward,
This office has reviewed the above-named Memo,-which was submitted as a response to the Notices of
Determination of DMO that the Division delivered to Denison Mines, for the six permitted uranium mines
captioned above. The Memo discusses benison's proposed plan for commencing the testing and background
analyses at the sites for eventual classification of each mine as a DMO or non-DMO. I wish to point out one
small item that appears erroneously throughout benison's Memo, but which should be corrected: the permit
number of the Van 4 Mine is actually M-1997-032.
The proposed sampling at the three 110(2) permits, for which three representative samples of waste rock from
each site will be taken, as well as one composite ore sample, is acceptable. Likewise, this same proposed
sampling regime at the three 112 permits is acceptable.
Regarding the water quality and geochemical testing, the Division's staff geochemist reviewed the Memo, and
found the overall regime acceptable, but made the following recommendations:
1) For the early rounds of groundwater sampling (i.e., quarterly for approximately the first year), the list of
proposed water quality analytes on page 4 should be expanded to include all parameters listed on Table
1 through 4 in CDPHE Regulation 41 -Basic Standards for Ground Water. Parameters that repeatedly
show concentrations below detection limits may be dropped from the program in future, but not in the
early stages. Denison and the Division should discuss the issue of dropping parameters before doing so.
The following parameters may be omitted altogether: Total Coliforms, Asbestos, Free Cyanide,
Chlorophenol, Color, Corrosivity, Foaming Agents, Odor, and Phenol. The link for Regulation 41 is:
http://www.cdphe.state.co.us/regulations/wgcereps/100241basicstandardsfor~roundwater pdf.
2) The analytes for surface water samples should be equally comprehensive, to include all parameters on
Tables I through III in CDPHE Regulation 31 -Basic Standards and Methodologies for Surface Water.
As stated above, parameters maybe dropped~from later sampling if they continue to return below
Office of Office of
MinPrl I and Ra~lamatirni Denver Grand Junction • Duran>;o Active and Inactive Mines