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Creek. Discharges from the waste rock area berms must be measured for sediment and <br />additional check darns required so as to maintain water quality. <br />Denison states: <br />"Regarding ore material several metals were detected at concentrations exceeding <br />their respective screening levels. Although the ore material could be considered a <br />potentially toxic forming material given this screening evaluation it is a <br />marketable material and is only temporarily stored at the site for brief time <br />periods between production and shipment for processing. Accordingly further <br />considerations regarding ore material are not warranted" (Attachment A page 4- <br />This lack of analysis is not consistent with DRMS regulations requiring operators to <br />minimize impacts. In the past, as well as very recently, several western slope uranium <br />mines have been put on standby status, and ore stockpiles have been left on some sites for <br />years. Given this past experience, Denison should be required to provide complete <br />chemical and leachate data (via SPLP tests or otherwise) on all ore stockpiles, all waste <br />rock, and any protore. Absent such data, Denison cannot demonstrate that it is <br />minimizing all impacts to surface and ground water quality. <br />Fourth, "The affected area of the West Sunday, mine lies on the Brushy Basin Member of <br />the Morrison Formation and the Burro Canyon Formation" (Denison EPP page 7-2). <br />Specifically, the West Sunday Mine's development rock storage area overlies the Burro <br />Canyon Formation. "Where saturated the Burro Canyon Formation is part of the Dakota <br />aquifer and there is potential for groundwater recharge to the Dakota aquifer from the <br />mine affected area" (Denison EPP page 7-5). The Dakota aquifer "has been used as a <br />source of water for more than a century" (quoted from Kansas Geological Survey <br />website). Furthermore, according to the USGS website, approximately 133 millions <br />gallons are extracted daily from the Dakota Aquifer- the water is allocated for <br />agricultural irrigation, public supply and domestic and commercial purposes (Ground <br />Water Atlas of the United States- http://pubs.usgs.gov/ha/ha730/ch d/D-text4.html). <br />Denison must address; 1) how their activities will affect water quality of the Dakota <br />aquifer, and 2) how they will mitigate this disturbance? <br />Fifth, Denison proposes to monitor down gradient wells and "in the event that ambient <br />water quality is exceeded ... additional actions will be developed by Denison in <br />consultation with DRMS" (Denison EPP page 11-2). We respectfully request that <br />Denison and the DRMS develop a plan now. It is easier to develop procedures before <br />they are needed, and having actions/procedures in place will limit additional water <br />quality degradation that would occur while crafting a plan. <br />Our final concern regarding water quality is related to water entering the mines. In <br />section 7 of the Denison EPP it is state that ground water is flowing into all the mines, <br />but because of the ventilation procedures this water is evaporated (Denison EPP pages 7- <br />0 to 7-9). Once mining and thus, ventilation have ceased, what type of water treatment <br />will be necessary and equally important who will pay for it? If after the mines close <br />4