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inforinafion to Supooil Denison BL MEnuironmenfa /Assessment Remand <br />Denison Sunday Mines Group <br />criterion suitable for protecting groups of species, communities, or <br />ecosystems; however, none have been widely accepted... the median <br />(Table 4) is recommended at the present time." Additional evaluation <br />including consideration of the home ranges of mule deer in relation to the <br />areas of development rock piles should be considered as an issue in the <br />revised EA. <br />Comment 3 Spill Prev ention, Control, and Countermeasures (SPCC) Plan, Pemmalela! <br />Stormwater Structures 4(b) Denison has indicated that temporary erosion and <br />sediment controls will be removed once final stabilization is achieved. Any long- <br />term features will require adequate bonding to ensure proper functioning is <br />maintained. Per CFR 3809.552(c), Denison should identify which features will <br />remain after final stabilization is achieved and establish mechanism to ensure <br />long -term maintenance of these features. As part of this process, Denison must <br />submit an estimate of the maintenance costs for such features for BLM's review. <br />Discussion CDM did not develop the SPCC Plan, we defer to Denison to address this <br />comment. Denison's response to this comment is provided below. <br />Denison Addendum: Standard reclamation practice includes leaving <br />stabilized drainages that route off -site water away from the surface <br />facilities following reclamation. As a certified Engineer in the state of <br />Colorado, it is against my better judgment to remove these stabilized <br />drainages which have been in place for 30 plus years; however, there are <br />no mechanisms in the state of Colorado for long -term bonding, rendering <br />this request impractical and impossible. I strongly advise from a <br />hydrological perspective that the BLM rethink this request in terms of <br />what it means for long -term management of these facilities in that surface <br />water runoff be routed through the reclaimed waste rock piles. I also <br />recommend that BLM evaluate the stability and age of these existing <br />drainages prior to requesting that these be removed as long -term bonding <br />is not a practical or possible reality. In the event that this is not possible, <br />Denison would request that BLM provide a mechanism for this type of <br />bonding if one is available. - Christy Woodward, PE, Denison Mines <br />(USA) Corp. <br />References <br />CDM Inc. (CDM). 2008. Draft Development Rock, Ore, and Soil Characterization Data <br />Collection Work Plan, to Address Designated Mining Operations (DMO) Status Sunday Mines <br />Group and Van 4 Mine, San Miguel County. June 27. <br />CDM, 2009. Environmental Geocliemistnj Investigation of Rock and Soil Material, Sunday <br />Mines Group, San Miguel County, Colorado. May. <br />Colorado Division of Reclamation and Mine Safety (DBMS). 2008. Division Response to <br />Operator's Memo (Draft dated March 31, 2008) Concerning a Proposed Program for Designated <br />Final Sunday Mines BLM Remand Letter.doc 15 <br />