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Via email and hardcopy <br />Dear Mr. Means, <br />Energy Minerals Law Center <br />a nonprofit law firm serving communities impacted by energy mining <br />1911 Main Avenue, Suite 238, Durango, Colorado 81301 <br />Phone: (970) 375 9231 Fax: (970) 382 0316 <br />Email: emlc @frontier.nnet <br />WON eiV40.0040,‘‘. <br />G. Russell Means <br />Environmental Protection Specialist <br />Colorado Division of Reclamation Mining and Safety <br />Grand Junction Field Office <br />101 South 3rd, Suite 301 <br />Grand Junction, CO 81501 <br />Re: Public Comment on Sunday Mine Complex Limited Impact 110(d) <br />- Designated. Reclamation Permit/Environmental Protection Plan for <br />Carnation Mine # M- 1977 -416 and St. Jude Mine # M- 1978 - 039 -HR <br />These public comments address the Reclamation Permits and Environmental Protection Plans <br />( "EPP ") for the Denison Sunday Mine Complex in general and the 110 Permits at Denison's <br />Carnation Mine # ( "M- 1977 -416) and St. Jude Mine (# M- 1978 - 039 -HR ") in particular: These <br />comments are submitted on behalf of Sheep Mountain Alliance and Center for Biological <br />Diversity and INFORM. Additional comments will be provided in accordance with the <br />September 27, 2011, deadline for the other mines in the Sunday Mine Complex. <br />These comments update and reassert the issues raised in attached comments provided on August <br />6, 2009, regarding the Sunday Mine Complex. As in 2009, the main areas of concern are water <br />quality issues. The Sunday Mine Complex is proximate to the Dolores River. Both ground and <br />surface water from the Denison mine sites involve the Dolores River Watershed, which is home <br />to threatened and endangered species and provides a prime area for recreation involving direct <br />human contact. In addition to concerns raised in the Sunday Mines permit review regarding the <br />uptake of heavy metals by deer and other ungulates that may enter the food web and the human <br />food supply, recent media reports' indicate the presence of gunterite (Na4(H2V10028)22H2O), <br />rakovanite (Na3 {H3 [V 10028] } • 15H20), and other minerals that pose unique chemical and <br />hydrological issues at the Sunday Mines. <br />As detailed in the attached comments, the permit application is incomplete in several respects. <br />Although more detail has been provided since 2009, the applicant has not met its burden to <br />provide necessary information to demonstrate compliance with the Mined Land Reclamation <br />Act. Further, the current application fails to properly acknowledge the permitting roles of the <br />U.S. Bureau of Land Management, which manages the lands upon which the mine is proposed, <br />l http : / /www.miami.muohi.o.edu'news- and - events /news /2011 /03 /rakovanite.html, <br />http: / /www.uidaho.edu /sci/ geology/ newsandevents /geologynewsigunterite . <br />August 29, 2011 <br />RECEIVED <br />AUG 3 0 2011 <br />GRAND JUNCTION HELD OFFICE <br />DIVISION OF <br />RECLAMATION MINING & SAFETY <br />