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X( <br />WESTERN MINING ACTION PROJECT <br />Roger Flynn, Esq., <br />Jeffrey C. Parsons, Esq. <br />P.O. Box 349 <br />440 Main Street, Suite 2 <br />Lyons, CO 80540 <br />(303) 823 -5738 <br />Fax(303)823 -5732 <br />�Yn1&2igc _urg <br />via email, hardcopy to follow <br />November 18, 2009 <br />V <br />1 <br />Allen Sorenson <br />Div. of Reclamation, Mining and Safety <br />1313 Shennan Street, Room 215 �- <br />Denver, CO 80203 <br />RE: Powertech (USA) Inc. Baseline Characterization File No. P- 2009 -012; <br />Centennial Uranium Project, Weld County, Colorado <br />Dear Mr. Sorenson: <br />This letter is submitted on behalf of Coloradoans Against Resource Destruction <br />(CARD), Environment Colorado, Clean Water Action, and Information Network for <br />Responsible Mining (INFORM) regarding the Division's consideration of Powertech (USA) <br />Inc.'s proposed Centennial Project Baseline Characterization, File No. P- 2009 -012. These <br />comments are intended to aid in the Division's ongoing technical and legal review of the <br />baseline characterization plan. <br />It is our understanding that the Division is currently in the process of identifying potential <br />third party experts to review and oversee the proposed baseline characterization plan and <br />associated activities in accordance with the Mined Land Reclamation Act (MLRA). Should <br />additional technical information become available, including any additional information <br />submitted by Powertech or the third party expert, commenters reserve the right to update these <br />comments as warranted. <br />Overall, Powertech's proposed baseline plan fails to provide a "thorough" baseline site <br />characterization and monitoring plan as required by the MLRA. In particular, the proposed plan <br />neglects to address the geologic and hydrologic characteristics of the proposed mining area, and <br />lacks a plan for gathering such information. The proposed monitoring plan also does not contain <br />adequate information on long -term groundwater monitoring necessary to ensure the effectiveness <br />of reclamation plans. This is despite the fact that the MLRA requires such information to be <br />included in the baseline review. <br />