2010-01-04_REVISION - M1977285 (7)

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Response to DRMS Comments Environmental Protection Plan, Denison Sunday Mines Group help in determining possible impacts from groundwater migration, but if sampling of the "well nest" reveals degradation from toxic forming materials of the more nearby strata, the underground sumps will have to be considered as EPFs and a different approach to long-term groundwater management and reclamation will have to be considered. Please be reminded that if such offsite impacts from toxic forming materials do occur, the mine pool may by definition be considered an EPF and subject to management and containment. If further discussion or studies indicate that additional sampling or other activity must be performed, it may be required under a separate revision to the permit. At this time, recognizing the complexity that this issue presents and the need for additional time to examine and discuss it, and possibly include it in the current amendment, the Division is extending the review period by 60 days (pursuant to Hard Rock/Metals Rule 1.4.1(7)). Response Additional information has been prepared to address this comment. An addendum to the Hydrogeological Evaluation of the Sunday Mines Group (Attachment O of the EPP) has been developed; see attached addendum for review. Comment 10 Post-mining use of the site. Denison defines future use of the site as "non- motorized recreation. " It is unclear if this is a BLM land use designation or if this name stated herein is provided in a framework for the reclamation plan under the DRMS permit. Non-motorized use, however, seems questionable to this office because old mine sites are very popular with ATV users. Will there be an attempt made to restrict access to ATV and other motorized recreationists in the post-mining condition? Is this future use in conformance with the plan approved by BLM? Response The post-mining land uses at the Sunday Mines Group are established in the U.S. Bureau of Land Management (BLM) Management Plan for the area (San Juan Public Lands Draft Management Plan (BLM 2008)). The affected areas of the Sunday Mines Group are included within the Management Area 3 (MA 3): Natural Landscape within Limited Management. As discussed in the management plan (BLM 2008, p. 76), MA 3s emphasize non-motorized recreation opportunities, but motorized travel occurs in some areas on existing roads and some trails. However, most roads would be closed upon project completion. Other than road closures implemented by BLM, Denison does not anticipate conducting additional activities to restrict access to motorized vehicles to the post- mining area. This is the formal post-mining land use of the site. Although the state may be uncertain whether it will be enforced or changed in the future, it is beyond Denison s authority to change the post mining land use or to limit the BLM's authority to choose the post-mining land use. Comment 11 Division's decision date. The decision date that was set upon the Division's finding that the amendment application was complete was Final RTC Sunday Mines EPP.doc