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2009-05-19_REVISION - M1981021 (36)
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2009-05-19_REVISION - M1981021 (36)
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Last modified
6/15/2021 2:18:37 PM
Creation date
5/27/2009 9:22:57 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1981021
IBM Index Class Name
REVISION
Doc Date
5/19/2009
Doc Name
EPP amendment (AM-01) submittal (part 1)
From
Denison Mines
To
DRMS
Type & Sequence
AM1
Email Name
RCO
Media Type
D
Archive
No
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Section 13 <br />Geochemical Data and Analysis <br />Potential for Direct Contact Risks <br />A number of inorganic constituents of development rock were measured from <br />samples collected from waste piles at the Sunday Mines Group. Generally, <br />concentrations observed in these samples were higher than background <br />concentrations measured in surrounding soils, indicating that development rock does <br />reflect the mineralization that justified development of the mine. These concentrations <br />were compared to screening criteria developed by BLM for metals in soils in Risk <br />Based Criteria for Metals at BLM Mining Sites (BLM 2004). With the exception of arsenic, <br />maximum concentrations of 11 metals/ metalloids addressed by BLM were below risk <br />management criteria (RMCs) for direct contact with soils. Further evaluation of <br />arsenic, using site-specific exposure considerations and measured bioavailability of <br />arsenic in development rock, indicate that an appropriate site-specific RMC is greater <br />than maximum arsenic concentrations. <br />Additional evaluation of metals other than the 11 constituents for which BLM RMCs <br />are available was performed using conservative regional screening levels (RSLs) from <br />EPA. This evaluation did not identify any constituents in development rock at <br />concentrations exceeding their respective RSLs. Notably, concentrations of uranium <br />and vanadium, target metals for mining operations, were less than appropriate <br />screening criteria. <br />Media besides soil are either not present within the affected areas of the Sunday <br />Mines Group (sediment, surface water) or are not accessible (groundwater). Thus, <br />RMCs based on direct contact with soils are appropriate for evaluating possible toxic- <br />forming materials. In addition, the most restrictive (i.e., lowest) RMC for arsenic is <br />based on a worker that might visit the site to perform such activities as control of <br />invasive species and abatement of fire hazards. If this worker is protected, other <br />visitors to the site - campers, ATV riders, surveyors - will also be protected. Based on <br />the BLM land management plan for this area, future land use for the site is assumed <br />to be non-motorized recreation, and thus future residents were not evaluated. Based <br />on the above results, the following conclusions are justified: <br />• A worker scenario is the most restrictive of applicable exposure scenarios for <br />the Sunday Mines Group, and conclusions concerning toxic-forming potential <br />are appropriately based on this receptor <br />• Groundwater at the site is present only at a depth that precludes contact for <br />visitors to the site, including campers, ATV riders, surveyors and workers. <br />Thus, RMCs based on direct contact with soil are appropriate for evaluating <br />toxic-forming potential <br />• Metals concentrations in development rock are higher than regional <br />background and screening against health-protective criteria is appropriate for <br />evaluation of toxic-forming potential <br />• Screening using BLM RMCs and USEPA RSLs indicates that no constituents <br />are present at concentrations that suggest toxic-forming potential (arsenic is <br />addressed separately below) <br />13-3 <br />T:164986-Denison MinesUask Order 4 - EPP Sunday Mines GroupTINAL EPPT-INAL - Environmental Protection Plan Sunday Mines.doc
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