DRC-2011-003869 - 0901a0688021e681

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Thomas Rushing ii - URS Proposal for Review ofthe Revised White Mesa Mill ICTM
From: Thomas Rushing ii
To: Roberts, Harold
Date: 4/7/2011 8:19 AM
Subject: URS Proposal for Review of the Revised White Mesa Mill ICTM
CC: [e-mail]; Hultquist, John; [e-mail]; Lundberg, Rusty; Morton, Loren;
[e-mail]; Rupp, Dave; Tischler, Jo Ann
Attachments: ICTM-URSProposal 110406A.DOC
Harold,
Loren asked me to forwarcJ the attachecd URS proposal which outlines costs and tasks for the URS team to
review the "Revisecd White Mesa Mill Site Infiltration and Contaminant Transport Mocdeling Report (March 2010),"
as well as review of supporting technical (documents and associatecd tasks. This is re\ated to the meeting
amongst DUSA, DRC, MWH and URS on 10/5/10 {regarding the DUSA Reclamation Plan 4.0). If DUSA opts to
approve these costs, I will prepare an MOA for DUSA review and signature.
Let me or Loren know if you want to set up a conference call or meeting to discuss this issue.
Tom
Tom Rushing, P. G.
Utah Division of Radiation Control
[phone]
[phone] fax
trushinq(Q)utah.qov
file://C:\Documents and Settings\Trushing\LocaI Settings\Temp\XPgrpwise\4D9D738CEQDOMAINEQRADI001726274171... 4/7/201
URS PROPOSAL:
REVIEW OF THE REVISED INFILTRATION AND CONTAMINANT TRANSPORT MODEL
(ICTM) REPORT, DATED MARCH 2010, SUBMITTED BY DENISON MINES (USA) CORP.
AND RELATED TECHNICAL REVIEW AND SUPPORT SERVICES
Tasks:
URS will provide the following technical reviews and prepare and submit a set of formal interrogatories
related to the revised Infiltration and Contaminant Transport Model (ICTM) Report dated March 2010.
URS will also review related supporting correspondence and documents listed below.
URS will involve professionals experienced with analytical and performance issues at the White Mesa
facility and with expertise related to the analyses being reviewed. URS will also mobilize subject matter
experts in this review, including both a geochemical modeler and a botanist experienced in plant
succession in the arid/semi-arid westem U.S.
URS's technical support to the ICTM Report review will include performance ofthe following tasks:
1. Review Backgroimd Documents: URS will review the following existing information furnished
by the DRC related to review of the November 2007 ICTM:
• MHW 2007. Infiltration and Contaminant Transport Modeling Report, White Mesa Mill
Site, Blanding, Utah - Denison Mines (USA) Corp. MHW Americas, Inc., November 2007
(285 pp.)
• Utah DEQ 2009. Technical Memorandum dated January 13, 2009: Infiltration and
Contaminant Transport Modeling Report, White Mesa Mill Site, Blanding, UT, Received
November 21, 2007: DRC Review Memo - Memo from Tom Rushing to Loren Morton (51
pp. - 32 pp. narrative plus attachments)
• Utah DEQ, DRC Letter to DUSA dated February 2, 2009: White Mesa Uranium Mill,
Ground Water Discharge Permit No. UGW370004, Infiltration and Contaminant Transport
Model Report: DRC Review Comments, Request for Additional Information (8 pp.).
• Loren Morton e-mail to DUSA dated September 3, 2009: Denison Mines: Further
Thoiight(s) on Meeting Yesterday - Radon Control Issues (1 p.)
• DRC 2009. Letter to DUSA dated November 16, 2009: White Mesa Uranium Mill, Ground
Water Discharge Permit No. UGW370004, Infiltration and Contaminant Transport Model
Report: Confirmatory Action Letter Regarding Deliverables (2 pp.)
• Oliver 2009. Revised [Meeting] Minutes, dated November 18, 2009, for March 31,2009
meeting between Denison Mines, DRC, and MWH concerning White Mesa ICTM - prepared
by Douglas Oliver of MHW Americas (13 pp.)
• MWH Submittal to DRC dated December 1, 2009: Revised Reponses to the Utah DRC's
February 2, 2009 Comments on DUSA November 2007 Infiltration and Contaminant
Transport Report (36 pp.)
2. Review Revised ICTM Report: URS will review the most recent ICTM report (MHW 2010):
Revised Infiltration and Contaminant Transport Modeling Report, White Mesa Mill Site,
Blanding, Utah - Denison Mines (USA) Corp. MHW Americas, Inc., March 2010 (522 ppO
Information to be reviewed in Task 2 will include, but not be limited to the following:
o Input Data/Pathways Review: URS will review data packages and baseline information
assembled to support preparation of the ICTM Report.
4/7/2011, Rev. 1 Page l
URS PROPOSAL:
REVIEW OF THE REVISED INFILTRATION AND CONTAMINANT TRANSPORT MODEL
(ICTM) REPORT, DATED MARCH 2010, SUBMITTED BY DENISON MINES (USA) CORP.
AND RELATED TECHNICAL REVIEW AND SUPPORT SERVICES
o Model Development Review: URS will review the conceptual site model to ensure that it
adequately represents the range of processes expected to occur at the site. The review will
focus on interactions among the various sub-models and determine the appropriateness ofthe
mathematical representations of physical and chemical processes related to radionuclide
release, and transport in the subsurface and surface environment (e.g., groundwater
contamination, radon emissions, etc.).
o Modeling Analyses Review: URS will review the methods and computer models used to
implement the conceptual model of the tailings management cells area closure design and
site. URS will evaluate the computer models/component models used in the ICTM process
and the assumptions used for modeling radionuclide releases from the waste and transport
through environmental pathways, such as air and groundwater. URS will evaluate time -
dependent parameters and how site and waste characteristics may evolve through time.
o Background and Data Review: URS will review and provide input on the appropriateness and
completeness of the background data and input documentation provided to support the ICTM.
o Analysis of Model Predictions: URS will review and assess the completeness of the
documentation provided for demonstrating analysis of performance and regulatory
compliance.
3. Attend Meeting and Prepare and Submit Meeting Minutes: Following its review of the ICTM and
all related documents, URS personnel (2) will attend one meeting in person with UDRC and
DUSA representatives, and a third URS person will participate in the meeting via
teleconferencing. Following the meeting, URS will prepare and submit to UDRC meeting notes,
in the form of a Draft Memorandum of Meeting Minutes to sunmmarize items discussed,
agreements reached, and issues resolved, together with action items.and agreed schedules.
4. Prepare and Submit Draft and Final Interrogatories: Following review ofthe Revised ICTM
Report and related correspondence and documents, URS will prepare and submit to UDRC Draft
Interrogatories on the Revised ICTM Report to document the review findings, identify technical,
issues requiring resolution, and to request additional information from DUSA to further support
the modeling approaches and results and the proposed altemati ve closure cover design. URS will
then address UDRC's comments on the Draft Interrogatories and will finalize the interrogatories
and submit them to UDRC for transmittal to DUSA.
5. Review Responses to Round 1 Interrogatories: Upon receipt of DUSA's responses to the
submitted Round 1 Interrogatories, URS will review the responses to determine whether all issues
addressed in the interrogatories have been adequately resolved so that they can be accepted.
6. Prepare Closeout Technical Memorandum: On the assumption that all issues are satisfactorily
resolved by DUSA's Round 1 responses, URS will prepare a closeout Technical Memorandum to
document relevant activities, analyses, results, conclusions, and justifications for the
administrative record.
4/7/2011, Rev. I Page 2
URS PROPOSAL:
REVIEW OF THE REVISED INFILTRATION AND CONTAMINANT TRANSPORT MODEL
(ICTM) REPORT, DATED MARCH 2010, SUBMITTED BY DENISON MINES (USA) CORP.
AND RELATED TECHNICAL REVIEW AND SUPPORT SERVICES
Deliverables and Schedule:
1. Draft and Final Interrogatories - URS will prepare and submit Draft Round 1 Interrogatories to
UDRC within 20 working days of receipt of authorization from UDRC to proceed with the
review effort. Within 5 working days of receiving UDRC's comments on Draft Round 1
Interrogatories, URS will submit Final Round 1 Interrogatories to UDRC.
2. Meeting Minutes - URS will prepare and submit to UDRC Draft Meeting Minutes no later than
two days following the meeting with UDRC and DUSA personnel. URS will finalize and submit
Final Meeting Minutes that address UDRC's, and, if requested by UDRC, DUSA's comments on
the Draft Meeting Minutes.
3. Review of Round 1 Responses - URS will confirm a schedule for completing review of the
Round 1 Responses and preparing and submitting a Closeout Technical Memorandum once the
magnitude and complexity of the information to be reviewed is known. For purposes of this
Scope of Work and cost estimate, it has been assumed that URS would be able to complete its
review within 10 working days of receiving the Round 1 Responses.
4. Closeout Technical Memorandum - Subsequent to completing the response review, URS will
prepare a Closeout Technical Memorandum documenting activities, analyses, results,
conclusions, and justifications relating to URS' review of the March 2010 ICTM report for the
administrative record. URS will confirm a schedule for preparing the Memorandum once the
magnitude and complexity of the information to be reviewed is known. For purposes of this
Scope of Work and cost estimate, it has been assumed that URS would be able to complete the
Memorandum within 5 working days of completion of its review of the Round 1 responses.
Travel:
No travel by URS personnel outside the Salt Lake City area is required in conjunction with performance
of this scope of services.
Additional Comments:
1. It is assumed that DUSA's responses to Round 1 Interrogatories will adequately and satisfactorily
address all issues raised in Round 1 Interrogatories and that no additional rounds of
interrogatories will be necessary.
2. It is expected that it will be necessary to revise or modify the Radioactive Materials License
and/or Groundwater Permit as a result of this review. Although no allowance has been made in
this proposal for costs associated with this process, related activities would include preparation of
a Statement of Basis; revisions to the Radioactive Materials License and/or Groundwater Permit;
and receiving and responding to public comments. When the exact extent of such revisions has
been determined, URS will, at UDRC's request, submit a proposal to complete activities related
to the amendment process.
3. The relative levels of effort committed by Messrs. Merrell and Luellen will be determined as the
work is conducted, and depending on the needs of the topics being evaluated. Their hourly rates
are identical and any shift in relative effort will have no effect on estimated cost.
Estimated Effort and Cost:
Based on the Scope of Work described above, URS identified those professional individuals who can best
contribute to this effort and has estimated levels of effort and costs associated with this review and
preparation of inteiTogatories. These estimates are summarized in Table 1.
4/7/2011, Rev. 1 Page 3
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