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water treatment will be necessary, we request that Denison create a fund now to pay for <br />future treatment. Without such a fund it is inevitable that tax payer will once again "foot <br />the bill" for someone else's mess. <br />As Denison's EPP (page 8-1) states, "Mining processes ... may affect the concentration <br />of metals in groundwater;" it goes on to state, "These activities are inherent parts of the <br />mining process and ... are unavoidable in close vicinity of the underground workings." <br />However, this neither limits nor mitigates Denison's accountability in maintaining water <br />quality. The water quality issues are of extreme importance because all water from the <br />Denison mine sites inevitably flows into the Dolores River and as we are sure the DRMS <br />knows, the Dolores River is a prime recreational site for fishing and boating and is home <br />to several threatened and endangered fish (including Colorado pike minnow, razorback <br />chub, humpback chub, bonytail chub) and three sensitive species (roundtail chub, <br />flannelmouth sucker and bluemouth sucker). Therefore, we strongly suggest that DRMS <br />take a very wary approach to water flow modeling and leachate potential and testing, and <br />design mitigation procedures that will prevent a worst case scenario. As part of this <br />cautious approach, the Division should also require additional information regarding all <br />potential effects on water quantity and on existing water uses. <br />Additionally, when discussing best management practices, the Denison EPP states, <br />"Where BMPs have failed... they will be addressed as soon as possible... to minimize <br />the discharge of pollutants" (Storm Water Management Plan page 26). The concern is <br />that "as soon as possible" is vague- "possible" can be interpreted in many different ways <br />(e.g. `when I get around to it'). The phrase ought to be changed to read, "as soon as it is <br />safe." This would limit the discharge of contaminants and ensure worker safety. <br />Additionally, in Energy Laboratory's analysis of radon detectors, they state, "desired <br />exposure time is 48 hours" and the canister should be returned to the laboratory quickly <br />"to avoid excessive decay. Maximum recommended delay ... should not exceed 8 days" <br />(Denison EPP attachment 3 un-numbered page). An explanation of how the 3.8 day half- <br />life (approximate) of radon will influence the decay count should be included. Because <br />of the complexity and detail of the EPP these slight changes appear to be necessary. <br />Denison states: <br />It should be noted that risks to miners were not evaluated as part of this <br />assessment because mine safety including exposure to mine rock and minerals is <br />regulated by the Mine Safety and Health Administration MSHA in accordance <br />with the federal Maine Safety and Health Act of 1977 as amended and other <br />federal laws and regulations Dsenisori mining operations comply with these <br />regulations. <br />Appendix A at 4-8. While we recognize that MSHA regulation applies, the DRMS <br />regulations require any EPP to discuss and analyze potential impacts to human health as a <br />result of the mining operation. These requirements cannot be circumvented simply <br />because another agency may also have jurisdiction. As such, the Division should require <br />Denison to provide full information as to how the health of mine workers will be <br />protected as part of the EPP.