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fnformafion fo Suopon Denison BL MEnuironmenfafAssessment Remand <br />Denison Sunday Mines Group <br />corporate philosophy, Denison is actively working to update existing <br />permits associated with the entire Sunday Mines Complex, which <br />includes the Topaz and Sunday Mines. The Sunday Mines Complex <br />includes five mines: the Sunday Mine, Carnation Mine, St. Jude Mine, <br />West Sunday Mine, and the Topaz Mine. Four of these five mines were <br />present prior to initiation of mine regulatory programs by the state and <br />BLM in the late 1970's and early 1980's. There are no data whatsoever to <br />support BLMs assertion that mining conditions have changed at these <br />sites. The minin regulatory environment at both the state and BLM <br />levels has changed markedly since the late 1970's, and the public and <br />regulatory agency perspective on mining has changed, but conditions at <br />the mines have not. Denison holds valid approved BLM Plans of <br />Operations and State mine permits that are valid for the life of the mine <br />for each mine in the Sunday Mines Complex including the Topaz and <br />Sunday mines. <br />Denison has expended very significant efforts to complete site - specific <br />sampling, laboratory analysis, and data evaluation to understand <br />potential environmental issues associated with the uranium mines and to <br />comply with new statutes and regulations promulgated by the State of <br />Colorado (e.g., Colorado Mined Land Reclamation Act (Colorado Revised <br />Statutes (CRS) Title 34, Article 32 [CRS §34 -32]) as amended via Colorado <br />House Bill (HB) 1161. As a result of this work, the hydrological and <br />geochemical conditions of the development rock piles are well <br />understood. Denison provided this information to BLM in the spring of <br />2009 in accordance with an approval condition of the PO (since <br />remanded). Therefore, BLMs assertion that the Sunday Mines Complex <br />are existing mines and dumps without data or analysis is without basis. <br />CDM recognizes that this environmental characterization data was not <br />included in the remanded EA, and therefore the existing data were not <br />evaluated in the associated FONSI or RD. The lack of the environmental <br />characterization data in the EA is a result of limited time to complete the <br />characterization activities to support the federal and state mine <br />permitting activities. CDM concurs with BLM that evaluation of these <br />issues is pertinent for inclusion in a revised EA for the project. However, <br />CDM does not concur that entirely new studies are warranted because <br />the assessment activities conducted to support the requirements of the <br />state mine permitting process (e.g., environmental protection plan) have <br />already addressed many of the issues raised in the BLM remand. The <br />Colorado Division of Reclamation and Mine Safety (DRMS) has extensive <br />experience in mine regulation, and a well defined regulatory framework <br />to address mining, surface water quality, and groundwater quality at the <br />mines. Characterization work completed to address state permitting <br />requirements was implemented in accordance with a data collection <br />workplan that was reviewed and approved by DRMS. This work plan <br />Final Sunday Mines BLM Remand Letler.doc <br />