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Christy Woodward <br />July 31, 2008 <br />Page 12 <br />Total Metals Analyses <br />Total metals analyses measure the total concentration of particular metals or metalloids in a <br />rock. Total metals data do not provide specific information regarding the potential mobility of <br />the particular metal or metalloid, but they are useful in conducting general evaluations of the <br />potential for mine rock to cause adverse impacts to human health or the environment. The <br />mechanisms of human or environmental exposure may include leaching, dispersion as dust, <br />incidental ingestion though recreation activities or other mechanisms. In the event that <br />constituents occur in problematic concentrations in the mine rock, knowledge of total metals <br />concentrations facilitates development of appropriate engineering mitigations to interrupt <br />potential mechanisms during mine development or reclamation, and mitigate associated <br />environmental liabilities. <br />Total metals data collected in this investigation will be compared to background <br />concentrations and screening levels, such as the risk management criteria for mining sites <br />published by the U.S. Department of Interior, Bureau of Land Management (BLM 2004), to <br />determine if a potential hazard exists. Concentrations that exceed screening levels are not <br />necessarily problematic, but this risk screening approach will provide Denison with <br />information to :further evaluate if additional data collection should be considered. <br />0 <br />References • <br />ASTM International, Inc. 2007. Standard Test Method for Column Percolation Extraction of Mine <br />Rock by the Meteoric Water Mobility Procedure, ASTM E2242-07. June. <br />ASTM International, Inc. 2004. Standard Test Method for 24-h Batch-Type Measurement of <br />Contaminant Sorption by Soils and Sediments, ASTM D4646-03. January. <br />Colorado Division of Reclamation Mining and Safety (DRMS). 2008a. Notices of Determination <br />of Designation Mining Operation (DMO). February 8. <br />Colorado Department of Public Health and Environment, 1997, Proposed Soil Remediation <br />Objectives Policy, Attachment 4, Guidelines for Determining Background <br />Concentrations. December 31. <br />DRMS. 2008b. Division Response to Operator's Memo (Draft dated' March 31, 2,008) Concerning a <br />Proposed Program for Designated Mining Operation (DMO) Environmental <br />Analysis, at the Sunday Mine Complex and Ilan 4 Mine. May 9. <br />DRMS. 2008c. New Requirements - Designated Mining Operations (DMO) Status - <br />Implementation of HB 1161. June 6. <br />Denison Mines (USA) Corp. (Denison). 2008. Memorandum in Response to Notice of <br />Determination of Designated Mining Operation (DMO, DRMS File Numbers <br /> <br />0:164986 - DenisonlTask Order 3 - DMO Sampling and Analysis Plan%Task 3.1 - Sal Ore Rock Data Collection Plan\Final Denison Sunday Mines Group Soil Ore Rode Data <br />Collection Work Plan.doc