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Response to DRMS Comments <br />Environmental Protection Plan, <br />Denison Sunday Mines Group <br />Response to Technical Adequacy Comments <br />Sunday Mines Group Environmental <br />Protection Plan <br />This document provides response to technical adequacy comments received from the <br />Colorado Division of Reclamation and Mine Safety (DBMS) on the Environmental <br />Protection Plan (EPP) for the Denison USA Corp. (Denison) Sunday Mines Group, West <br />Sunday (M-1981-021, amendment A-1), Topaz Mine (M-1980-055 HR, Amendment <br />AM-1), Sunday Mine (M-1977-285, Amendment AM-3), Carnation Mine (Permit M-1977- <br />416 HR, Amendment AM-1), and the St Jude Mine (M-1978-039 HR, Amendment AM-1), <br />dated May 29, 2009. These mines are located in San Miguel County, Colorado and are <br />collectively referred to as the Sunday Mines Group. Comments provided by DRMS <br />have been reproduced and presented in italic print. CDM's responses are provided in <br />standard font. <br />Comments provided by Mr. Bob Oswald, DBMS, dated <br />August 28, 2009 <br />General Comments <br />Comment 1 Toxic-forming materials. In Section 5.0 Denison states that "no acid- or toxic- <br />forming materials or acid mine drainage are present at the Sunday Mines Group. <br />Therefore, additional information regarding handling of these types of materials <br />is not applicable to the Sunday Mines Group. " <br />DRMS response: Because of the inherent qualities of uranium, it must be <br />regarded as a toxic forming material because it is both a chemical hazard and a <br />radiation hazard (Toxicological Profile for Uranium; U.S. Dept. of Health and <br />Human Services, 1999). Additionally, an element that has State of Colorado <br />surface water quality standards for both drinking water and aquatic life, and a <br />ground water standard for human health must be considered potentially toxic <br />forming. Thus, Denison has not proven that toxic forming materials are not <br />present, rather they have shown that the mobility of the substances appears to be <br />limited and pose a reduced threat to people or the environment. <br />There is currently mining activity occurring at this mine, including the <br />stockpiling of uranium ore on the staging area pad. As such, the presence of a <br />toxic forming material on the permitted area justifies the Division's <br />determination that this mine is a DMO. If Denison disputes that uranium is a <br />toxic forming material please provide the rationale explaining that position. <br />Response Denison does not intend to challenge DRMS's determination that the <br />Sunday Mines Group mine facilities are designated mining operations <br />(DMO) as defined in the Colorado Mined Land Reclamation Act <br />(Colorado Revised Statutes Title 34, Article 32 (CRS §34-32) and amended <br />Final RTC Sunday Mines EPP.doc