2009-09-02_REVISION - M1977416

• Permit No: M1977416
• IBM Index Class Name: REVISION
• Doc Date: 9/2/2009
• Doc Name: Technical adequacy comments
• From: DRMS
• To: Denison Mines ‎(USA)‎ Corp.
• Type & Sequence: AM1
• Email Name: RCO
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
O L O PL
O
Denver, Colorado 80203 D
F
N O
Phone: [phone] RECLAMATION
FAX: [phone] MINING
(?© SAFETY
SEp 9 2009 Bill Ritter, Jr.
September 2
2009 f Reciam2fi0n, Governor
, ptVtsjen o
Safety Harris D. Sherman
and
Mining Executive Director
Christy Woodward Ronald W. Cattany
Denison Mmes (USA) Corp. Division Director
1050 17"' Street, Suite 950 Natural Resource Trustee
Denver, CO 80265
Re: Carnation Mine, Permit M-1977-416, 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 included 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.
This 110d permit is currently active, though mining activity is not presently occurring at this mine.
However, mining activity has occurred at the site under this permit, including the stockpiling and/or loading
of uranium ore at the staging area pad. The pad itself has not undergone final reclamation nor been checked
for adequate removal of trace amounts of ore, and future use of the pad may again include the handling of
ore. As such, the current 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 or that
uranium is not present in the permitted area please provide the rationale explaining that position.
Office of Office of
Mined Land Reclamation Denver Grand Junction • Durango Active and Inactive Mines