2009-08-28_REVISION - M1980055HR

• Permit No: M1980055HR
• IBM Index Class Name: REVISION
• Doc Date: 8/28/2009
• Doc Name: Technical adequacy comments & questions regarding the EPP & decision date
• From: DRMS
• To: Denison Mines ‎(USA)‎ Corp.
• Type & Sequence: AM1
• Email Name: RCO
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
? Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]

August 28, 2009
Christy Woodward
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
Rv
STATE OF COLORADO
RECE E
AUG 3 1 2009
Division of Reclamation,
Mining and Safety
COLORADO
D I V I S ION OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
? ? ? ?
Re: Topaz Mine, Permit M-1980-055 HR, Amendment AM-1, Technical Adequacy Comments and
Questions Regarding the Environmental Protection Plan, and Decision Date.
Dear Ms. Woodward,
The Division has reviewed the Environmental Protection Plan (EPP) for the above-named mine, and offers
the following comments to be considered and the following questions to be addressed. We appreciate the
scope and quality of the information that Denison presented. The EPP was very comprehensive and
appeared to cover almost everything required under Hard Rock/Metals Rules 6.4.20 and applicable portions
of Rule 7. However there are several items that need to be addressed, as listed below.
Toxic-forming materials. In Section 5.0 Denison states that "no acid- or toxic-forming materials or acid
mine drainage are present at the Sunday Mines Group. Therefore, additional information regarding handling
of these types of materials is not applicable to the Sunday Mines Group." (This mine is one of the mines in
the Sunday Mines Group.)
DRMS response: Because of the inherent qualities of uranium, it must be regarded as a toxic-forming
material because it is both a chemical hazard and a radiation hazard (Toxicological Profile for Uranium; U.S.
Dept. of Health and Human Services, 1999). Additionally, an element that has State of Colorado surface
water quality standards for both drinking water and aquatic life, and a ground water standard for human
health must be considered potentially toxic forming. Thus, Denison has not proven that toxic-forming
materials are not present, rather they have shown that the mobility of the substances appears to be limited
and pose a reduced threat to people or the environment.
There is currently mining activity occurring at this mine, including the stockpiling of uranium ore on the
staging area pad. As such, the presence of a toxic-forming material on the permitted area justifies the
Division's determination that this mine is a DMO. If Denison disputes that uranium is a toxic-forming
material please provide the rationale explaining that position.
Office of Office of
Mined Land Reclamation Denver • Grand Junction Durango Active and Inactive Mines