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Response to DRMS Comments <br />Environmental Protection Plan, <br />Denison Van 4 Mine <br />Response to Technical Adequacy Comments <br />Van 4 Mine Environmental 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) Van 4 Mine (Permit M-1977- <br />032), dated May 29, 2009. This mine is located in Montrose County. Comments <br />provided by DRMS have been reproduced and presented in italic print. CDM's <br />responses are provided in standard font. <br />Comments provided by Mr. Bob Oswald, DBMS, dated <br />September 4, 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 Van 4 Mine. <br />Therefore, additional information regarding handling of these types of materials <br />is not applicable. " <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 />This 110d permit is currently active, though mining activity is not presently <br />occurring at this mine. However, mining activity has occurred at the site in the <br />past, including the stockpiling and/or loading of uranium ore, affecting the <br />staging area and structures near the shaft. The surface of this area has not <br />undergone final reclamation nor been checked for adequate removal of traces of <br />ore, and future use of the site may again include the handling of ore. As such, <br />the presence of a toxic forming material on the permitted area justifies the <br />Division's determination that this mine is a DMO. If Denison disputes that <br />uranium is a toxic forming material please provide the rationale explaining that <br />position. <br />Response Denison does not intend to challenge DBMS' determination that the Van <br />4 Mine facility is a designated mining operations (DMO) as defined in the <br />Colorado Mined Land Reclamation Act (Colorado Revised Statutes Title <br />34, Article 32 (CRS §34-32) and amended via Colorado House Bill (HB) <br />1161 as signed into law by the governor on May 20, 2008. <br />DRMS RTC Van4 Mine EPP.doc