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2011-09-29_GENERAL DOCUMENTS - M1977285
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2011-09-29_GENERAL DOCUMENTS - M1977285
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Last modified
8/24/2016 4:43:29 PM
Creation date
10/4/2011 1:25:48 PM
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DRMS Permit Index
Permit No
M1977285
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
9/29/2011
Doc Name
Public Comments
From
Energy Minerals Law Center
To
DRMS
Email Name
RCO
Media Type
D
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No
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Energy on mining in this region. Coordination in permitting between the State and Federal <br />processes ensures that both agencies act only after all relevant impact reviews have been <br />accomplished. <br />Likewise, the DRMS review should be conducted in coordination with agencies that regulate <br />release of pollution from these mines, such as Environmental Protection Agency (EPA) and <br />Colorado's Water Quality Control Division. Because one of the deadliest legacies of uranium <br />mining is the exposure of the public, workers, and public employees to radionuclide emissions, <br />current compliance with radon emission regulations under the Clean Air Act (40 CFR Part 61) <br />must be accomplished and demonstrated before any person is allowed "to enter the mines for any <br />purpose." 40 CFR § 62.21(a). <br />Also of continuing concern is the apparent non - compliance with the Mined Land Reclamation <br />Act's (MLRA) unequivocal requirement that "in no case shall temporary cessation of production <br />be continued for more than ten years without terminating the operation and fully complying with <br />the reclamation standards of this article." C.R.S. § 34- 32- 103(6)(a)(III). As discussed in the <br />attached comments, this provision appears to apply to the Sunday Mines, as they have exceeded <br />the allowed period of nonproduction. At minimum, the length of time since permitting should <br />trigger a full review of the mine permit and reclamation requirements, not constrained by any <br />limitations of an EPP, and encompassing all components of the mining operations. In other <br />words, these circumstances require the applicant to affirmatively demonstrate that the underlying <br />mine permit and mining operation are in current compliance with all MLRA provisions and <br />regulations applicable to a new mine permit before an amendment can issue. <br />Lastly, and as stated previously, it is better policy and consistent with the MLRA to collapse all <br />five Sunday Mine Complex permits into a single 112d Permit and EPP to ensure a full analysis <br />and efficient use of public resources. <br />Thank you for your careful attention to this matter. The resurgence of the uranium mining <br />industry continues to present difficult and unique questions. <br />Sincerely, <br />%s'57/ <br />Managing Attorney <br />Energy Minerals Law Center <br />enclosures <br />2 <br />
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