2012-02-29_REVISION - M1977285 (3)

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1. Introduction 2. Objections 3. Issues Raised by the Objectors Page 3 of 9 Recommendation for Approval Over Objections Hard Rock/Metal 112d -2 Permit, Amendment AM -3 Denison Mines (USA) Corp. Sunday Mine Permit No. M- 1977 -285 February 27, 2012 The purpose of this document is to outline the basis for the Division of Reclamation Mining and Safety ( "Division ")'s recommendation for approval of the Hard Rock/Metal 112d -2 Permit Amendment (AM -3) ( "Amendment "), submitted by Denison Mines (USA) Corp. (the "Operator "), for the Sunday Mine, Permit No. M- 1977 -285, over objections raised by the Sheep Mountain Alliance, Center for Biological Diversity, and the Information Network for Responsible Mining ( "INFORM ") (collectively the "Objectors "). The Sunday Mine is one of five mines collectively referred to as the Sunday Group or Complex, located in the Big Gypsum Valley, on land managed by the U.S. Bureau of Land Management ("BLM") in western San Miguel County. It was permitted in 1977, and currently contains 60.00 permitted acres. Its approved post - mining land use is Rangeland. The Sunday Mine is an underground mine that produces uranium and vanadium. Pursuant to House Bill 08 -1161, all uranium mines are considered designated mining operations ( "DMOs "). See C.R.S. § 34-32 - 103(3.5)(a)(III). The Reclamation Permit for every DMO must include an adequate Environmental Protection Plan ( "EPP "). The Operator submitted the application for this Amendment in order to develop and incorporate an EPP into its Permit in accordance with Rules 6.4.21 and 7.1.4. In the interest of clarity and administrative efficiency, the Division has scheduled Board hearings for consideration of each of the Sunday Mine Complex EPP Amendments on March 14 -15, 2012. The Division will present recommendations for Board approval of each EPP Amendment at those hearings. The Division received the following timely objection letters during two public comment periods: • September 27, 2011 letter from Sheep Mountain Alliance, Center for Biological Diversity, and INFORM ( "September 2011 Letter "). • August 29, 2011 letter from Sheep Mountain Alliance, Center for Biological Diversity, and INFORM ( "August 2011 Letter "). • August 6, 2009 letter from Sheep Mountain Alliance and INFORM ( "August 2009 Letter ").