DRC-2009-002327 - 0901a0688011d29e

DBc- ^Cf\-00^391
DENISOI^i
MINES
June 5, 2009
VIA PDF AND FEDERAL EXPRESS
Mr. Loren Morton
State of Utah Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
Re: White l\1esa Uranium IVIiil; Groundwater Discharge Permit No. UGW370004 - New
Decontamination Pad
Dear Mr. Morton:
Reference is made to the meeting at your offices on May 11, 2009, at which you, Phil Goble,
Dan Erskine and 1 discussed the proposed revisions to Groundwater Discharge Permit No.
UGW370004 (the "GWDP") for the Denison Mines (USA) Corp. ("Denison") White Mesa
uranium mill (the "Mill"). During that meeting we discussed certain matters relating to the new
decontamination pad (the "New Decontamination Pad") being constructed at the Mill.
We agreed that the current proposed language in Parts 1.D.12, 1.E.12 and I.F.12 of the GWDP
relating to the Decontamination Pad, which would require the Mill to periodically sample the
wastewater contained in the sediment basins at the Decontamination Pad and maintain the
quality of such wastewater at State Groundwater Quality Standards, would be deleted and
replaced with a prohibition on the use of the Decontamination Pad until certain conditions, to be
proposed by Denison, are satisfied.
Based on our discussions on May 11, 2009, and after having considered this matter further,
Denison, proposes the following conditions that must be satisfied prior to the Mill using the
Decontamination Pad:
(a) the Executive Secretary reviews and approves the as-built drawings for the
Decontamination Pad (other than the liner and leak detection system, which have not yet
been constructed), that have been provided by Denison to the Executive Secretary;
(b) the Executive Secretary reviews and approves the engineering design drawings for the
liner and leak detection system, that have been provided by Denison to the Executive
Secretary;
(c) the Executive Secretary reviews and approves an As Low As Reasonably Achievable
("ALARA") analysis provided by Denison that demonstrates that the re-use and recycling
of wash water as per the design of the Decontamination Pad will result in radiation
exposures to workers and members of the public ALARA;
(d) the Executive Secretary reviews and approves amendments, proposed by Denison, to
the Mill's existing Discharge Minimization Technology ("DMT") Plan to include:
• The manner of monitoring the leak detection system for the Decontamination Pad
to ensure that any leaks in the liner are detected as soon as possible; and
• The manner of inspecting the Decontamination Pad, including the leak detection
system, and setting out a new inspection form or changing an existing inspection
form to document such inspections;
(e) Denison constructs the liner and leak detection system in accordance with the approved
drawings and submits a final as-built report to the Executive Secretary for his review and
approval;
(f) Denison performs a hydrostatic test of the liner and leak detection system, after having
given the Executive Secretary at least 10 days advance notice of the date on which the
test will be conducted, in order to provide the Executive Secretary with the opportunity to
witness the test;
(g) The hydrostatic test demonstrates that the liner and leak detection system perform in
accordance with the approved drawings, and the Executive Secretary approves the
results of such test; and
(h) The Executive Secretary gives his final approval for the Mill to commence use of the
Decontamination Pad, which approval will be given by the Executive Secretary upon
satisfaction of all of the foregoing conditions.
We have provided you with the drawings referred to in paragraphs (a) and (b) above. We will
provide you with the ALARA analysis and proposed revisions to the DMT Plan on or before
June 17,2009.
If you have any questions or require any further information, please contact the undersigned.
David C Frydenlund
Vice President Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
DENISO
MINES
J>i