2011-08-30_REVISION - M1978039HR

• Permit No: M1978039HR
• IBM Index Class Name: Revision
• Doc Date: 8/30/2011
• Doc Name: Public Comment
• From: Energy Minerals Law Center
• To: DRMS
• Type & Sequence: AM1
• Email Name: RCO
• Email Name: SSS
• Media Type: D
• Archive: No

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