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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 COLORADO <br /> <br />Phone: (303) 866=3567 SION OF <br />AMATION <br />FAX: (303) 832-8106 MINING <br /> <br /> RFECENFD <br /> SEP 0 9 2009 Bill Ritter, Jr. <br />September 2 <br />2009 Governor <br />, Division of Reclamation, Harris D. Sherman <br /> . Mining and Safety Executive Director <br />Christy Woodward Ronald W. Cattany <br />Denison Mines (USA) Corp. Division Director <br />105017 th Street, Suite 950 Natural Resource Trustee <br />Denver, CO 80265 <br />Re: St. Jude Mine, Permit M-1978-039 HR, Amendment AM-1, Technical Adequacy Comments and <br />Questions Regarding the Environmental Protection Plan, and Decision Date. <br />Dear Ms. Woodward, <br />The Division has reviewed the Environmental Protection Plan (EPP) for the above-named mine, and offers <br />the following comments to be considered and the following questions to be addressed. We appreciate the <br />scope and quality of the information that Denison presented. The EPP was very comprehensive and <br />appeared to cover almost everything required under Hard Rock/Metals Rules 6.4.20 and applicable portions <br />of Rule 7. However there are several items that need to be addressed, as listed below. <br />Toxic-forming materials. In Section 5.0 Denison states that "no acid- or toxic-forming materials or acid <br />mine drainage are present at the Sunday Mines Group. Therefore, additional information regarding handling <br />of these types of materials is not applicable to the Sunday Mines Group." This mine is included in the <br />Sunday Mines Group. <br />DRMS response: Because of the inherent qualities of uranium, it must be regarded as a toxic-forming <br />material because it is both a chemical hazard and a radiation hazard (Toxicological Profile for Uranium; U.S. <br />Dept. of Health and Human Services, 1999). Additionally, an element that has State of Colorado surface <br />water quality standards for both drinking water and aquatic life, and a ground water standard for human <br />health must be considered potentially toxic forming. Thus, Denison has not proven that toxic-forming <br />materials are not present, rather they have shown that the mobility of the substances appears to be limited <br />and pose a reduced threat to people or the environment. <br />This 11 Od permit is currently active, and some mining activity is presently occurring at this mine. <br />Additionally, past mining activity has occurred at the site under this permit, including the stockpiling and/or <br />loading of uranium ore at the staging area pad. The pad itself has not undergone final reclamation nor been <br />checked for adequate removal of trace amounts of ore, and future use of the pad may again include the <br />handling of ore. As such, the current presence of a toxic-forming material on the permitted area justifies the <br />Division's determination that this mine is a DMO. If Denison disputes that uranium is a toxic-forming <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines