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Information to Support Denison's Response <br />to the Environmental Assessment Remand, ® 'Veor <br />Sunda Mines Co San Migue Fc23 <br />Y p � 9 <br />County, Colorado <br />Ce <br />This document provides information to support Denison Mines (USA) Corp (Denison) S� c on <br />with their response to the U.S. Bureau of Land Management (BLM) decision to remand r <br />the Environmental Assessment (EA), Finding of No Significant Impact ( FONSI), Record <br />of Decision (RD) and Plan of Operations (PO) for the proposed expansion of the Sunday <br />Mines Complex which includes five mines: the Sunday Mine, Carnation Mine, St. Jude <br />Mine, West Sunday Mine, and the Topaz Mine. Denison has received the following two <br />correspondences from BLM regarding the remand: <br />The remand decision from the State Director's Review (SDR) (BLM 2009a), which <br />was received on October 1, 2009; and <br />■ A letter received from Ms. Jamie Seller- Baker, Associate Field Manager of the <br />Dolores Public Land Office on November 3, 2009 (BLM 2009b). <br />Comments provided by BLM have been reproduced and presented in italic print. <br />Information developed by CDM is provided in standard font. <br />Comments in Remand Letter provided by Ms. Lynn Rust, <br />BLM, dated October 1, 2009 <br />General Comments <br />Comment 1 The RZffColorado State Ofce notes the adaptive mitigation as adopted <br />in this E4 anddecisioa is not only reasonable, it is infactrequiredizz the <br />regulations zpon a sign fcan1 change in mining cond.0orrs during the life <br />of1lepeimitandmiae flowevez; when thesubmilledhaseline "best <br />available data" is inadequate or lacking, and is insufcientfor <br />identification ofimpacts, permitting cannot occur f Iaallocali y- specific <br />baseline data must he a vailahleforpermitling under "best available <br />data ". In this case, thepreserzce oferisting mines and dumps without <br />data or analysis appear to make the continued and expandedmining <br />benign. lVewstzzdles consistent with the adaptive management concept <br />have indentifiedpossible issz <es withpotelztialdump rockmaterial, and <br />with mine anddump water The results ofthe newstzza'ies shouldhe <br />incorporatedinto the E4 [Environmental Assessment], FONSI [Finding of <br />No Significant Impact], and Decision. <br />Discussion Denison is committed to protection of the environment and compliance <br />will applicable regulatory requirements. In accordance with this <br />Final Sunday Mines BLM Remand Letter.doc <br />