2009-09-04_REVISION - M1997032

• Permit No: M1997032
• IBM Index Class Name: REVISION
• Doc Date: 9/4/2009
• 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
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
September 4, 2009
Christy Woodward
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
RgCp1D
SEP 0 9 2004,
Division of Reclarnation,
Mining and Safety
COLORADO
DIVISION OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
Re: Van 4 Mine, Permit M-1997-032, 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.
Permit number. On the cover page and in Paragraph 1.2 the permit number appears to be incorrect. It should
be "M-1997-032." This is not considered to be an item that needs to be corrected or resubmitted, but is
simply called to the operator's attention. The permit number elsewhere in the EPP documents is correct.
Toxic-forming materials. In Section 5.0 Denison states that "no acid- or toxic-forming materials or acid
mine drainage are present at the Van 4 Mine. Therefore, additional information regarding handling of these
types of materials is not applicable."
DRMS response: This office agrees with Denison that the geologic characteristics preclude acid-forming
rock, and that there is no acid mine drainage in the permitted area (per discussion in Section 2 and Section
13). But 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 1 l Od permit is currently active, though mining activity is not presently occurring at this mine.
However, mining activity has occurred at the site in the past, including the stockpiling and/or loading of
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