2009-12-23_GENERAL DOCUMENTS - M1977285

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/nfolmalion 10 Sappol Denison ELM EnVi ronmenlafASSessmenlRemand Denison SundayMineS Group e ce ° Comments provided by Ms. J amie Seller -Baker B V ed dated November 3, 2009 2 32 00 9 General Comments � afl ii ,2 Comment 1 The Colorado State Director has remanded the decision to authorize the Plan Amendment (COC 52049 07 -1A) for the Topaz and Sunday Complex on September 17, 2009. The State Director determined that adequate baseline data for the Project Area must be established prior to implementation of any additional activities. As such, Denison Mines may only conduct operations as authorized under the original Sunday and West Sunday Plans of Operations at this time. No fiirther operations, as described in the proposed Plan Amendment, may occur until sampling of soils and water, and transect soil sampling is completed, the NEPA analysis has been completed, mitigation measures have been identified, and adequate bonding is in place. The Dolores Public Lands Office (BLM) has previously required that Denison Mines prepare a geochemical analysis of waste rock materials located on the Sunday Mines (COC 52049) as part of the Conditions of Approval for the Plan Amendment. Denison Mines prepared an Environmental Protection Plan (EPP) as part of the requirements under State regulations for mining and BLM's requirements under the original decision. The BLM received a copy of the Environmental Protection Plan (EPP) for the Sunday Complex on June 5, 2009. The Plan includes: a finalized report on geochemical characteristics of ore, proto- ore, and waste materials, and a hydrogeologic model. The reports include initial data on water depths and water quality in the area of the underground mines. Data presented is form mined areas. It is recognized that Denison intends to continue monitoring at these sites. Per the State Director's decision, baseline information must be provided for the following items: • Denison must provide direct baseline data to verifi/ whether the existing dumps are /are not producing leachates and the water quality of any leachates. Background levels for soils were presented in the original EA. Denison must provide sampling data to demonstrate hozv any wind -blown material from the dumps may have affected soil quality within a one -mile area of the dumps. Data should be presented to demonstrate hozv underground mining may affect groundwater (e.g., introduction of oxygen into the ground water). Additional data is needed to demonstrate if the Salt Wash consists of one large aquifer or a series of aquifers controlled by faulting, and if water quality in the Salt Wash aquifer(s) is homogenous or is locally affected by mineralized zones. Final Sunday Mines BLM Remand Letter.doc 11