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address the requirements under HB1161. Under these regulations, the Operator • <br />is required and has committed to complete studies to identify environmental <br />concerns that may be associated with the Sunday Mines. The Operator is <br />required to collect the 5 quarters of water quality monitoring data during <br />operation at the Sunday Mines. The Operator is in the process of collecting its 5 <br />quarters of water quality data. To comply with the amended regulations, the <br />Operator is also characterizing mine rock at the Sunday Mines. In compliance <br />with the amended regulations and as stated in EA Section 8.2.7, Ground Water, <br />page 27, <br />"in the event that mine rock characterization tests indicate there is a potential <br />for leachate that exceeds background water quality to develop, piezometers <br />and/or monitoring wells would be installed below the toe of the WRA to <br />monitor any groundwater quality. <br />In the event that it is shown that groundwater quality is being affected by the <br />WRA, the waste rock material would be managed in such a manner to reduce <br />water from entering the WRA and/or containing any leachate from exiting the <br />material. Examples of mitigations include capillary barriers or other covers to <br />prevent or minimize water infiltration, liners under the WRA to prevent fluids <br />from entering the groundwater system, and treatment to improve leachate <br />quality to a degree that it would not affect groundwater." <br />Potential impacts from the Proposed Action have been identified (i.e. potential <br />leaching into ground water and surface water) and considered in the EA. • <br />Effective mitigation measures have also been identified. Mitigation of any actual <br />impacts is required and would be applied as necessary. <br />Comment 10: The concern I would like to voice my opinion about, is in reading the <br />documentation regarding the ore hauling section of the operation, it is particularly 'lax' in <br />my opinion, on specifications and remedial actions in an emergency for the potentially <br />third party contractor. Who oversees that the trucks are following the MSHA protocols <br />and how often is that regulated to ensure the public's safety as well as that of the drivers? <br />How does Denison control the hauling section of their operations to have a responsible <br />interest in assuring this part of the system is carried out with the utmost care for the <br />surrounding population land and wildlife? I would like to see the mining operation have a <br />direct connection to the hauling contract in terms of responsibility of their actions. Also <br />having a place in Moab UT, we have been following the regulations on how the trucks <br />that will be transporting the Atlas tailings from the site to the train car and then from <br />Moab to Crescent Junction, noting that they are well encapsulated, not just with a'tarp' on <br />top. That is just for tailings, not hot ore heading to a processing plant. As you are no <br />doubt aware, the haul route takes the potential fugitive particles on a ride through a <br />seriously windy part of the country! Can you mandate more stringent levels of control on <br />the ore for the trucking section to protect the public from a major exposure. I saw no <br />mention of particulate masks as a precaution for both drivers and our emergency response <br />personnel. <br />0 <br />Decision Record 10 Sunday Mines Complex Expansion <br />Dolores Public Lands Office January 2009