2009-05-19_REVISION - M1977285 (29)

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i Response: As stated in Section 8.2.1.7 of the EA, "An independent hauling contractor would transport the ore, and hauling would be performed under U.S. Department of Transportation (DOT) regulations found at CFR Title 49, Transportation, and in accordance with the Operator's °Transportation Policy for Shipments of Colorado Plateau Uranium Ores to the White Mesa Uranium Mill." Section 8.2.1.7 of the EA also states that: "The Operator is responsible for ensuring that radiation levels from hauling operations fall within applicable DOT limits as specified in 49 CFR 173.427(a)(1). These requirements state that the external dose rate may not exceed a radiation level of 1,000 mrem/hr at 3 meters from the unshielded material. Based on the grade of the uranium ore from the Sunday Mines, the exposure rate would be less than 1 millirem per hour (mrem/hr) to recipients standing outside of the truck. As a result, the requirements at 49 CFR 173.427(a)(1) are expected to be satisfied." The EA summarizes the Operators Emergency Response Plan including a discussion of exposure potential, personal protective equipment, and cleanup requirements. Comment: Region 5 of the Colorado Department of Transportation (CDOT) has reviewed the Environmental Assessment (EA) for the proposed expansion of Denison Mines (USA) Corp., Sunday Mine Complex (CO-800-2007-104EA). The EA was prepared for the U.S. Department of Interior, Bureau of Land Management, Dolores Public Lands Office by Tetra Tech. CDOT finds that the EA fails to describe specific is impacts to the highway system from the proposed action and other alternatives. The specific impacts to both the San Miguel County roads and Colorado State highways needs to be disclosed in the EA as both direct and indirect impacts, with mitigation measures included. Under the Council on Environmental Quality (CEQ) regulations, direct impacts are "those that are caused by the action and occur at the same time and place", and indirect impacts are "those that are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable" (40 CFR Part 1508.8). The EA needs to disclose all effects from mining related traffic entering and leaving the highway system from the study site. These impacts will be direct to County Road 20R, and indirect to State Highway 141 and State Highway 491. CDOT feels that the EA is deficient as it does not disclose these impacts to the highway system, nor address mitigation for these impacts. The State of Colorado State Highway Access Code (pursuant to § 43-2-147(4), C.R.S., and in accordance with § 24-4-103, C.R.S., Effective 8/31/98) states that any change of land use or proposed vehicle volume increase to a site by 20 percent or more constitutes a major modification, which typically requires permitting. Under these requirements, CDOT requests that a Traffic Impact Study be prepared by the project proponent in order to CDOT and San Miguel County to accurately assess project-related impacts. The Traffic Impact Study will provide CDOT with the information required to determine whether the State Access Permits and access improvements are warranted. According to the State Access Code, one haul truck is equivalent to three passenger vehicles, and traffic volume increases stated within the document do not reflect this ratio. Decision Record 11 Sunday Mines Complex Expansion Dolores Public Lands Office January 2009