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Christy Woodward <br />July 31, 2008 • <br />Page 2 <br />associated regulations. In addition, this work plan incorporates information and data <br />collection/ assessment approaches discussed with Denison in a June 13, 2008 project meeting. <br />As described in Deidson's lever to DRUB, data collection will be completed for the Sunday <br />Mines Group and Van 4 Mine to evaluate if the potential for formation of toxic materials or <br />acid mine drainage is sufficient to adversely affect any person, property, or the environment; <br />thereby evaluating the potential DMO status of the Sunday Mines Group and Van 4 Mine. <br />Introduction <br />This data collection work plan describes the sampling, analyses„ and data evaluation activities <br />for development rock, ore, and soil for use in addressing the Sunday Mines Group and Van 4 <br />Mine DMO status. Sampling procedures and analyses presented in this data collection work <br />plan are consistent with the Phase 1 data collection activities described in DiiniSon's <br />memorandum to DRMS (Denison 2008) and DRMS' May 9, 2008 response letter (DRMS <br />2008b) to Denison approving (with comment) the proposed program for environmental <br />analysis at the Sunday Mines Group and Van 4 Mine. <br />During development of this work plan, the Colorado Mined Land Reclamation Act (Colorado <br />Revised Statutes Title 34, Article 32 [CRS §34-32]) was amended via Colorado House Bill (HB) • <br />1161 as signed into law by the Governor on May 20, 2008. The revised statutes changed the <br />definition of a 13MO to include all uranium mine operations including conventional <br />underground uranium mines such as the Sunday Mines Group and Van 4 Mine. Revised <br />regulations have not yet been adopted by the Colorado Mined Land Reclamation Board to <br />address CRS §34-32-103. This data collection work plan has been developed to address this <br />change in the DMO definition and is consistent with information provided by DRMS, to <br />Denison in a June 6, 2008 letter (DRMS 2008c). <br />Current regulations at Hard Rock/Metal Mining Rule (HRMMFC) § 1.1(14)(e), provide a <br />distinction regarding potential DMO status between limited impact operations (CRS §34-32- <br />110 permits) and regular operations (CRS §34-32-112 permits). This distinction can potentially <br />exempt mines permitted under CRS §34-32-110 from DMO status if they do not use or store <br />designated chemicals or have the potential to cause acid mine drainage. Regular operations <br />require consideration of designated chemicals, potential for acid mine drainage, and the <br />potential for the mine to produce toxic substances. With the recent revision to CRS §3432-103, <br />it is unknown if the DMO designation distinction provided at HRMMR § 1.1(14)(e) will <br />remain in effect for existing uranium mines currently permitted as limited impact operations. <br />Three of the mines (the Carnation, St. Jude, and Van 4 mines) described in this data collection <br />work plan are currently permitted as limited impact operations (CRS §3432-110 permits). The <br />remaining three mines (the Sunday, Topaz, and West Sunday mines) are currently permitted <br />as regular operations (CRS §34-32-112 permits). Based on discussions between Denison and <br />DRMS and the uncertainty regarding changes in the regulations; that will be made in the <br /> <br />0:164986 - Denison%Task Order 3 - DMO Sampling and Analysis PlanlTask 3.1 - Sal Ore Rock Data Collection Plan'Final Denison Sunday Mines Group Sal Ore Rode Data <br />Collection Work Plan.doc