2010-02-09_REVISION - M1977285

• Permit No: M1977285
• IBM Index Class Name: REVISION
• Doc Date: 2/9/2010
• Doc Name: Review of environmental protection plan
• From: David Bird
• To: Bob Oswald
• Type & Sequence: AM3
• Email Name: RCO
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE: February 9, 2010
TO: Bob Oswald
FROM: David Bird
FEB 16 2010
DOWOn o1 1,,eciamaWn,
Mining and Safety
RE: Review of Environmental Protection Plan for Denison Mines (USA) Corp
Sunday Mines Complex
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
M-14111-2915 AM-D'A M - t4?-y11? AAt-n% IM- nom- onwt - Ar%-O1
M- X980- ow k Ant-oi M- 1q8i -t)-i A,4-01
The Division of Reclamation, Mining, and Safety (DRMS) geochemist has completed a review of the
Response to Technical Adequacy Comments for the Environmental Protection Plan (EPP) for the Denison
Mines (USA) Corp. Sunday Mines Complex. DRMS has the following additional adequacy concerns:
Attachment A, Comment 1
Denison: In the context of questioning whether uranium should be regarded as a toxic-forming material due
to its presence at low concentrations, the Applicant states "Denison selected the BLM risk management
criteria (RMC)(BLM 2004) to be appropriate criteria for the site based on future land use for the mines."
DRMS response: The BLM publication "Risk Management Criteria for Metals at BLM Mining Sites,
Technical Note 390 rev., October 2004," contains no reference information for uranium. If this is the same
document to which the Applicant refers, please elaborate on how the information in this document was
extrapolated to risk management of uranium at the Denison sites.
Final DRMS Report, 11.0, Water Quality Monitoring Plan
Denison (Pg 11-1): "The compliance limit at the groundwater compliance points is proposed to be the 95th
confidence interval of the mean, as defined by the mean ambient water quality from the subsurface
monitoring wells nest samples multiplied by two times the standard deviation of the concentrations."
DRMS comment: How many samples will be collected in order to establish the statistical basis for the plan
described?
Final DRMS Report, 11.0, Water Quality Monitoring Plan
Denison, Exhibit 11-1, Compliance Monitoring Analytical Parameters.
DRMS Comment: The list of analytes must include Radium 226 and Radium 228. Temperature should be
included as a field measurement. Applicant is advised that pH, conductivity, ORP, and DO must also be
measured in the field.
Office of Office of
Mined Land Reclamation Denver - Grand Junction - Durango Active and Inactive Mines