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STATE OF COLORADO <br /> <br />DIVISION OF RECLAMATION, MINING AND SAFETY. <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />,/ <br />August 28, 2009 <br />p,UG 312009 <br />phfits?? 0t ReC$ ? F'j, <br />tNlv+jng and <br />COLORADO <br />D I V I S ION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Harris D. Sherman <br />Executive Director <br />Christy Woodward Ronald W. Cattany <br />T? Denison Mines (USA) Corp. Division Director <br />1050 17th Street, Suite 950 Natural Resource Trustee <br />Denver, CO 80265 <br />Re: Sunday Mine, Permit M-1977-285, Amendment AM-3, Technical Adequacy Comments and <br />Questions Regarding the Environmental Protection Plan, and Decision Date. <br />Dear Ms. Woodward, <br />The Division has reviewed the Environmental Protection Plan (EPP) for the above-named mine, and offers <br />the following comments to be considered and the following questions to be addressed. We appreciate the <br />scope and quality of the information that Denison presented. The EPP was very comprehensive and <br />appeared to cover almost everything required under Hard Rock/Metals Rules 6.4.20 and applicable portions <br />of Rule 7. However there are several items that need to be addressed, as listed below. <br />Toxic-forming materials. In Section 5.0 Denison states that "no acid- or toxic-forming materials or acid <br />mine drainage are present at the Sunday Mines Group. Therefore, additional information regarding handling <br />of these types of materials is not applicable to the Sunday Mines Group." <br />DRMS response: Because of the inherent qualities of uranium, it must be regarded as a toxic-forming <br />material because it is both a chemical hazard and a radiation hazard (Toxicological Profile for Uranium; U.S. <br />Dept. of Health and Human Services, 1999). Additionally, an element that has State of Colorado surface <br />water quality standards for both drinking water and aquatic life, and a ground water standard for human <br />health must be considered potentially toxic forming. Thus, Denison has not proven that toxic-forming <br />materials are not present, rather they have shown that the mobility of the substances appears to be limited <br />and pose a reduced threat to people or the environment. <br />There is currently mining activity occurring at this mine, including the stockpiling of uranium ore on the <br />staging area pad. As such, the presence of a toxic-forming material on the permitted area justifies the <br />Division's determination that this mine is a DMO. If Denison disputes that uranium is a toxic-forming <br />material please provide the rationale explaining that position. <br />Environmental Protection Facilities (EPFs). In Section 6.0 Denison states, "...future EPFs are not planned to <br />be constructed, because neither designated chemicals, nor toxic- or acid-forming materials or acid rock <br />drainage are present at the Sunday Group Mines." <br />PCI <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines