DRC-2009-004309 - 0901a06880143175

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Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
September 22, 2009
CERTIFIED MAIL
(Retum Receipt Requested)
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Mr. Landau:
SUBJECT: June 26, 2009 DUSA Email: June 25, 2009 DUSA Memorandum of Cell 1 Liner
Repairs; Request for Revision to the Liner Maintenance Provisions - Cells 1,2,3
and Roberts Pond (LMP)
We received your email dated June 26, 2009, subject as above, and reviewed the information
submitted. We appreciate receiving this submittal. During our review of the information, some
items needing improvement in the current DUSA LMP became apparent. Please revise the LMP
to address the items below.
To conform more closely to ASTM 5641, we note the following items for improvement on future
liner repairs. These were observed from photographs and testing records supplied in the DUSA
June 25, 2009 Memorandum of Cell 1 Liner Repairs:
1. The vacuum box gage pressure varied between 2 to 5-inches of mercury. Such
corresponds to 1 to 2.5 psi. According to ASTM D5641 paragraph 7.6, "For most cases a
minimum vacuum of 4 to 8 psi as registered on the vacuum gage should be appropriate."
We recommend that on future vacuum box tests conducted, a vacuum be applied within
the 4-8 psi range. Please revise the LMP accordingly.
2. All new seams in the liner repair efforts were tested and found to be good, by many
vacuum tests. However, in accordance with ASTM D5641 paragraph 7.10, adjacent
vacuum box test areas are to be tested by "overlapping the previously tested areas by a
distance no less than 10% of the minimum chamber length or at least 2-inches, whichever
is the greater and repeat the procedure until the entire seam has been tested." The photos
depict that tested areas were usually butted adjacently, instead of using the lapping
168 North 1950 West • Salt Lake City, UT
Mailing Addressi P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone]-Fax [phone]-T.D.D. [phone]
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Printed on 100% recycled paper
Mr. Steven Landau
September 22, 2009
Page 2
described above. We recommend that on future vacuum box tests conducted, the vacuum
box test areas overlap the previously tested areas by a distance no less than 10% of the
minimum chamber length or at least 2-inches, whichever is the greater. Please revise the
LMP accordingly.
Due to the above, we request that
A. ASTM D5641 be referenced in the DUSA document titled Liner Maintenance
Provisions - Cells 1,2,3 and Roberts Pond.
B. Comments 1 and 2 above, be incorporated into that document.
C. The revised document be given a revision number, and submitted for approval.
In a telephone conversation with me on July 16, 2009, you agreed to fully respond to the above
45-days after receipt of this letter. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
cc: Harold R. Roberts, DUSA
F:\GWDPermil Related Items\RevidRedaled&senlO9-22-091tr for unsent 7-20-091tr
File: DUSA Liner Repairs