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Response to DRMS Comments <br />Environmental Protection Plan, <br />Denison Sunday Mines Group <br />Although Denison does not agree with the determination of uranium as a <br />toxic forming material for the above mentioned reasons, Denison will <br />comply with all applicable rules and regulations, including DMO status. <br />Comment 2 Environmental Protection Facilities (EPFs). In Section 60 Denison states, <br />"...future EPFs are not planned to be constructed, because neither designated <br />chemicals, nor toxic- or acid-forming materials or acid rock drainage are <br />present at the Sunday Group Mines. <br />DRMS response: Again, it is the Division's position that uranium is a toxic- <br />forming material and that this permit is a DMO. The uranium on the surface <br />may be restricted to its presence in the ore and low-grade ore, that are stored on <br />the pad, and the working surface of the pad. There may be more locations <br />and/or structures within the permitted area which are affected by or come in <br />contact with this material, and should be identified by the operator to <br />demonstrate that they are compliant with the minimum applicable standards of <br />EPFs. Please state whether there are additional EPFs that can be identified at <br />the site, based on the justification given above, that should be considered for <br />inclusion and if applicable, a plan for structural improvement. <br />Response Regarding the DMO status of the Sunday Mines Group and the <br />evaluation of "toxic-forming", please see Response to Comment 1. The <br />state's regulatory mechanism for protection of the environment at DMOs <br />is the identification and management of mine site environmental <br />protection facilities (EPF). The EPP has been revised to designate ore <br />storage pads at the Sunday Mines Group as EPFs in order to implement <br />best management practices. The pads will be designed and constructed <br />using berms and a polyvinyl (PVC) geomembrane liner, or equivalent, to <br />contain storm water in contact with ore material and divert storm water <br />run-on around the pad area. <br />Low-grade ore is currently placed only on the development rock pile at <br />the Sunday Mine sites. As presented in the Environmental Geochemistry <br />Investigation of Rock and Soil Material (Attachment B of the EPP), the <br />low-grade ore geochemical data indicates that it has characteristics <br />similar to the waste rock and, based on evaluation with risk management <br />criteria (RMC) developed by the U.S. Bureau of Land Management (BLM <br />2004), does not suggest significant toxic forming potential. In addition, as <br />part of the Sunday Mine reclamation, Denison has committed to place the <br />low-grade ore back into the underground workings or haul the material <br />to the White Mesa Mill. Denison currently includes removal of low-grade <br />material in the reclamation plans for the Sunday Mine sites. Accordingly, <br />an ore storage pad should not be required for the storage of low-grade <br />ore. <br />Comment 3 Ore storage pad. Denison has provided documentation of the residence time of <br />the ore while stockpiled, which appears to be only a matter of days. The low- <br />grade ore, however, remains exposed on the pad surface for a longer period of <br />Final RTC Sunday Mines EPP.doc 3