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Information to Support Denison BLMEnulronmenta/Assessment Remand <br />Denison Sunday Mines Group <br />Most of the geohydrologic model is based on interpretation of the geology as <br />mapped at the surface, some observations of water levels in the underground <br />mines. It is noted that faulting is common under or near portions of the <br />mining operations. In the event that mining operations may affect ground <br />water quality, studies should be conducted to determine if any fail is are <br />capable of transporting leachates towards surface waters. <br />Discussion See discussion regarding the BLM Colorado State Director's remand <br />decision comments. <br />Specific Comments <br />Comment 1 ffeleoric Walerflob il(lvProcedrlreflrzalYsis /fflAfP). 2.2.3 This section <br />addresses the potential of certain rocks to cause elevated levels of certain <br />contaminants, even though the water may not be acidic. In the description of the <br />procedure, it states that de- ionized or distilled water is used as the extraction <br />fluid. <br />Comment: We would like to discuss the applicability of the MWMP method <br />compared to other methods such as the Synthetic Precipitation Leaching <br />Procedure (SPLP) test, which uses an extraction fluid which more closely <br />resembles meteoric water than does de- ionized or distilled water. Additionally, <br />we would like further discussion of the fate and transport of any leachate waters <br />likely to be generated. <br />Discussion Both DRMS and the Dolores Public Lands Office (BLM) were provided <br />copies of the Draft Development Rock, Ore, and Soil Characterization Data <br />Collection Work Plan dated June 27, 2008 for review and comment <br />(Denison 2008). Denison received DRMS' approval of the work plan (via <br />telephone conversation) including use of the MWMP for assessing the <br />potential for dissolution and mobility of metals from mine rock at the <br />Sunday Mines Complex. Denison specifically developed the data <br />collection work plan based on a written comment from DRMS that stated, <br />"for any and all leach tests, such as the Meteoric Water Mobility Test <br />(MWMT) and the soil geochemical adsorption potential, the list of <br />analytes should include all regulated parameters in Tables 1 -4 in <br />Regulation 41 for ground water or Tables I -III in Regulation 31 for surface <br />water, at the appropriate detection limits" (DRMS 2008). However, <br />Denison did not receive any comments from BLM on the draft or final <br />data collection work plans. Denison requests clarification from the BLM <br />regarding their review of the work plan, issues regarding analytical <br />procedures used to assess rock geochemistry would have been more <br />appropriately identified during the work plan development process. <br />The Meteoric Water Mobility Procedure (MWMP) was developed in the <br />State of Nevada during the 1980's as part of their mine waste <br />characterization programs. During the 1990's the Nevada Mining <br />Final Sunday Mines BLM Remand Letter.doc 12 <br />