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tnf or ma t%on to Support Denison BLMEnuironmentatAssessinent Remand <br />Denison Sunday Mines Group <br />The scientific or regulatory basis for completing a one -mile long soil <br />sampling transect is unclear. Development rock data and risk screening <br />activities completed by Denison (CDM 2009) indicate that the <br />development rock metals concentrations are below BLM risk <br />management criteria (RMC) (BLM 2004) and do not present direct contact <br />risks (incidental ingestion and inhalation) to human health and that <br />potential risks to wildlife are very low. In the event that a small fine <br />fraction of the rock pile were to be dispersed by wind erosion and mixed <br />with natural soils on BLM land at distances up to a mile away from the <br />rock piles, the potential direct contact risks to human health and wildlife <br />would be expected to be even less than the values assessed directly on the <br />rock piles. <br />Comment 3 This Mrreperm& analysis should rely on the hesl available Bala, nol <br />simply oa the data suhmitted, ifheller data can he readily ohlained. <br />Collection andanalysis ofsuhdump anddump adjacent elala, wish any <br />neededmitigalion and appropriatefirll hondirzgshouldhe madeprior to <br />allowing any expansion ofthese dumps Tire results ofthese �orsimilarJ <br />lesls will indicate the aclualground conditions, andgiw a strong hasisfor <br />firturepredicative conditions Once this data is collected, accrrfale <br />miligalionplans and hondirrg estimates can he accomplishedfor long teem <br />reclamalion al this mine. <br />No expansion ofmme dumps will he allowedlo occur unlilsampling of <br />suhd rmp soils and water; andlranseclsoilsampling is completed, with <br />analysis inchrding hording andmitigalion measures based on lhis dales. <br />Discussion Denison has conducted extensive work characterizing the development <br />rock piles in accordance with State of Colorado mine permitting <br />requirements (CDM 2009). The data collection work plans were reviewed <br />and approved by the Colorado Division of Reclamation and Mine Safety <br />(DBMS) to support assessment of soil and groundwater at the mines. <br />DRMS has extensive expertise and experience with mine environmental <br />assessment, management, and regulation. It is unclear how BLM has <br />determined that the data collected and corresponding assessments <br />regarding potential impacts to soil and groundwater are insufficient to <br />support an evaluation of significant impacts in the EA. BLM should <br />further clarify this comment. <br />The Sunday Mines Complex has operated and will continue to operate <br />under previously approved Plans of Operations. The 2008/2009 data <br />collection program and assessments recently completed for the <br />development rock piles do not indicate that environmental conditions at <br />the mines have changed significantly since BLM approval of these Plans <br />of Operations was granted. Accordingly, it is unclear why development <br />of additional mitigation plans and revised bonding estimates for <br />Final Sunday Mines BLM Remand Letter.doc <br />