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BLM has stipulated very extensive and specific sampling activities in the September 19, 2009 remand and the <br />November 3, 2009 correspondence. For example, in the remand decision, BLM has stipulated numerous <br />additional data collection activities such as installing monitoring wells /lysimeters in the development rock piles <br />and completing one -mile long soil sample transects. However, BLM does not fully describe the issues that are <br />driving the stipulated data collection activities. This is a critical facet of the NEPA process as set forth in the <br />NEPA regulations. Therefore, Denison is requesting discussions with BLM to completely define these issues <br />prior to conducting further data collection activities. In addition, as with any data collection activity, data <br />quality objectives (DQO) should be further defined including identification of criteria for evaluating the data. <br />For example, it is currently unclear how the development rock data and fate and transport assessments presented <br />in the EPP are not sufficient and how additional data collected from well/lysimeter(s) within the development <br />rock would be utilized to further characterize the potential for dissolution and mobility of metals from mine <br />rock at the Sunday Mines Group. Furthermore, the scientific or regulatory basis for several of the requests, <br />such as the need to complete soil sampling along a one -mile long transect to further define potential impacts <br />from mine surface disturbance areas (e.g., development rock areas), are unclear. <br />In addition, significant data collection and assessment activities were conducted in 2008 and 2009 to address the <br />mine permitting requirements of the Colorado Division of Reclamation, Mining and Safety (DRMS) regarding <br />DRMS' regulatory juri sdiction of the mine surface disturbance areas and protection of waters of the state <br />(groundwater) in the area of the underground mines. Denison is requesting that BLM provide further <br />clarification regarding why data collection activities and assessments conducted to evaluate potential impacts to <br />soil and groundwater and support the DRMS mine permitting process are insufficient to identify and evaluate <br />significant issues in the EA. <br />Given that the EA has been remanded, Denison understands that it has the potential options of either appealing <br />the decision to the Interior Board of Land Appeals (IBLA) or moving forward with BLM with the preparation <br />of a revised EA. Denison is requesting a meeting with the BLM state director's office and other parties (e.g., <br />U.S. Geologic Survey) that supported the remand decision to discuss the decision and clarify the need for <br />further data collection activities. The attached information is provided to support BLM and other stakeholders <br />in our future coordination. <br />If you have any questions or comments regarding this submittal of this response to BLM comments, please feel <br />free to call me at 303 - 389 -4136. <br />Yours very truly, <br />Christy Woodward, PE <br />Environmental Coordinator <br />Attachments <br />cc: CDM, Inc. File <br />Denison Mines, File <br />Bob Oswald, Colorado Division of Reclamation, Mining and Safety <br />Ron Hochstein, Dave Frydenlund, Philip Buck, Terry Wetz, Denison Mines (USA) Corp. <br />0ENIS0N0 <br />MINES <br />