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Denison Mines (USA) <br />Corp. <br />Van 4 Shaft 11/3/1999; <br />M1997032 C <br />110d 9 <br />/SW /NE <br />Return <br />3 <br />Christy Woodward <br />1050 17th Street, Suite <br />50 <br />Denver CO 80265 -0000 <br />(303) 628 -7798 <br />Montrose? <br />8.40! <br />UG; <br />$518'.00j <br />$61,691.00# <br />• <br />Severing the consideration of the Sunday Mine Complex into five separate permit proceedings <br />requires expenditure of unnecessary public resources by the DRMS. It also prevents the careful <br />analysis and comment by the public, who is faced with multiple applications, inconsistent <br />deadlines, and an incomplete picture of the full impact of the mining operation until the last set <br />of application materials are filed. <br />It is better policy and consistent with the MLRB to consider the Sunday Mine Complex under a <br />single 112 Permit and EPP to ensure a full analysis and efficient use of public resources. <br />Second, DRMS should not consider these applications without the information that will be <br />provided by the federal land management agencies. It is these organizations' understanding that <br />the federal agencies will address the entire Sunday Mine Complex in the near future. It is our <br />understanding that the BLM has begun initial steps toward compliance with public disclosure <br />and environmental analysis requirements of the National Environmental Act, Endangered <br />Species Act, and National Historic Preservation Act for the Sunday Mine Complex. It is our <br />view that the federal process will involve an Environmental Impact Statement, consultation with <br />Fish and Wildlife Service, and consultation with various government entities regarding historic <br />preservation due to the significant impacts involved with these mines, especially the unique <br />setting, hydrologic issues, and minerals present at the Sunday Mine Complex. <br />Third, there is no indication that worker protections have been/will be effectively followed at <br />these mines. Review of the publicly available documents of the Mine Safety and Health <br />Administration ( "MSHA ") indicate that these mines are considered "abandoned," and therefore <br />not subject to ongoing MSHA oversight and inspections designed to ensure worker safety. <br />Although uranium mining involves unique impacts, the mine file does not identify the necessary <br />EPA review and approval of radon venting and exposure requirements during ongoing activities <br />at these mines. For purposes of the EPA's radon regulations, "an active mine is an underground <br />uranium mine which is being ventilated to allow workers to enter the mine for any purpose." 40 <br />CFR § 61.21(a). Until such time as all necessary EPA reviews and approvals are obtained and <br />MSHA oversight is demonstrated, DRMS staff should take affirmative steps to address <br />radionuclide exposure of any person who enters these mine sites, including DRMS staff. <br />Fourth, these permits should not be analyzed as revisions or amendments as these permits have <br />been on temporary cessation status since at least 1999, a period of 12 years. Instead, the existing <br />permits should be declared invalid as a matter of law, new permit applications should be <br />required, and the DRMS should shift resources toward ensuring present compliance /reclamation <br />before considering Denison's prospective permitting requests. See C.R.S. § 34-32 - <br />103(6)(a)(III)("in no case shall temporary cessation of production be continued for more than ten <br />