DRC-2009-007025 - 0901a06880156923

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISIQN OF RADIATION CONTROL
Dane L. Finerfrock
Director
^'tO',;LLxn-0d-i0r2S
December 28, 2009
David C. Frydenlund
Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) Corp.
1050 17'^ Street, Suite 950
Denver, Colorado 80265
RE: Renewal Application for Radioactive Material License (RML) No. UT1900479
Dear Mr. Frydenlund:
On February 28, 2007, Denison Mines Corp. (DUSA) submitted an application to renew the State
of Utah RML No. UT1900479 for the White Mesa Uranium Mill located near Blanding Utah.
The Division of Radiation Control (DRC) has reviewed the documentation that you provided
according to NUREG 1556. On November 24, 2008, additional information was requested by the
DRC and was later provided by DUSA. On June 29, 2009 another round of interrogatories
containing two sections was sent to DUSA, one section containing the 2"^ round of Health Physics
Interrogatories and the other section containing the 1^^ round of Engineering Interrogatories.
DUSA responded to these interrogatories in a documented dated August 14, 2009. DUSA stated
in that document that the Reclamation Plan Revision 4.0 would be forthcoming. Revision 4.0 of
the plan was sent by DUSA by letter dated November 24, 2009. After reviewing the additional
information provided, it has been determined that additional information is still required before
the renewal of your RML (UTl900479) can proceed.
Only one remaining item remains with the Health Physics Interrogatories. Nearly half of the items in the
Round 1 Engineering Interrogatories have been satisfied by DUSA responses. Some other items
require minor adjustments to be made such as changes to appendix indexes, new tabs for
submitted items, and small changes to drawings or texts. InteiTogatory items IC, ID, and IE will
need some engineering design effort in order to be completed. These are discussed further below:
Pertaining to the discharge channel from Cell 1, inten'ogatory item IC provides justification and
requests an entry apron design for this channel. Plans and specifications for the rip-rap for that
apron will need to be provided. We are also requesting a drawing, correcting the width of the Cell
1 discharge channel. Further details are given in the inteiTOgatory.
We are also requesting design, plans and specifications for the east and west side rock aprons for
168 North 1950 West • Salt Lake City, I IT
Mailing Aclciress: P.O. Box 144850 • Salt Lake City. UT 841 14-4850
Telephone [phone]* Fax [phone] 'T.D.D. [phone]
iiiiM.rleq.uiah.fiov
Primed on lOO'/r recycled paper
Page 2
the tailing cells dike outslope in interrogatory ID. We believe this item will be further refined by
DUSA in the ICTM study. We have determined that this issue must be addressed and resolved
now as a part of the License Renewal Application. Further details are given in the interrogatory.
Similar to the above, we are requesting cuiTent design, plans and specifications for filter blanket
material for the rip-rap cover involved in the project. This item is discussed in interrogatory IE.
Per our telephone conversation with you and Mr. Harold Roberts on December 22, 2009, DUSA
agreed to respond fully to the above items on or before 60-days after receipt of this letter.
Attached you will find a list of Interrogatory Statements outlining the information requiring
further explanation. This list is divided into two sections. The first section is the '7'^ round of
Health Physics Interrogatories and the second section is the 2"*^ Engineering Interrogatories.
Environmental issues regarding this RML renewal were addressed during the last Groundwater
Quality Discharge Permit Amendment of March 17, 2008. The DRC requests a response to these
Interrogatory Statements by February 28, 2010. Please contact Ryan Johnson (Health Physics) or
Dave Rupp (Engineering) at [phone] if you have any questions or concerns.
UTAH RADIATION CONTROL BOARD
Dane Finerfrcfek, Executive Secretary
Cc: David Turk, Radiation Safety Officer (w/enclosure)
Harold Roberts, Executive Vice President, U.S. Operations (w/enclosure)
enclosure
DLF/RJ/rj
SECTION 1
UTAH DIVISION OF RADIATION CONTROL
DENISON MINES (USA) CORPORATION
WHITE MESA URANIUM MILL
BLANDING, UTAH
HEALTH PHYSICS INTERROGATORIES - ROUND 3
DECEMBER 28,2009
TABLE OF CONTENTS
SectionPage
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT- ALTERNATE FEED: 3
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-RELEASE SURVEYS:
; 3
HEALTH PHYSICS ROUND 3 INTERROGATORY STATEMENT-RELEASE SURVEYS:
3
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-ALARA: 4
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT- EMPLOYEE
TRAINING: 4
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-REVISIONS AND
UPDATES: 4
ACRONYMS AND ABBREVIATIONS
ALARA
CFR
DOT
NRC
OSL
RML
RPP
RSO
RWP
SOP
URCR
As Low As Reasonably Achievable
Code of Federal Regulations
US Department of Transportation
Nuclear Regulatory Commission
Optically Stimulated Luminesence
Radioactive Materials License
Respiratory Protection Program
Radiation Safety Officer
Radiation Work Permit
Standai-d Operating Procedures
Utah Radiation Control Rules
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-
ALTERNATE FEED:
Round One Interrogatory Statements 1 through 3 were answered appropriately and to the
satisfaction of the DRC.
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-RELEASE
SURVEYS:
Round One Interrogatory Statements 4, 5, 6 and 7 were answered appropriately and to the
satisfaction of the DRC.
HEALTH PHYSICS ROUND 3 INTERROGATORY STATEMENT-RELEASE
SURVEYS:
1. Round One Interrogatory statements 14-17 "Explain how the survey techniques, the
release standards used and documentation of surveys of Equipment are sufficient to
demonstrate regulatory compliance and maintain public health and safety. Explain
why surveying techniques such as the use of Large Area Wipes and swipes to look for
removable contamination are not being used on all items being surveyed for release"
Round Two InteiTogatory statement 8 "In response to the method outlined in 49 CFR
173.443(a)(1) Denison Mines states "Using portable alpha detection equipment that
measures the combined fixed and removable contamination is therefore "another
method" contemplated by paragraph 2. (49CFR 173.443(a)(2) "equal or greater
efficiency"), because the Mill applies the removable contamination standard to a
combined reading of fixed and removable contamination." Provide efficiency
calculations to determine the efficiency of this method. Include the survey procedure
used, the efficiency of the meters and probes used in relation to U-238. Show that the
meters and probes that are/will be used has the appropriate sensitivity to provide a
small enough reading to measure the required release limits."
Based on manufacturer calibration sheets and information provided by the site RSO,
Cs-137 is used to calibrate the Ludlum Model-3 meters with the 44-9 GM pancake
probes, thus they are not calibrated for Alpha radiation. Also Sr-90 is used to perform
a function check on the Model-3 meters with 44-9 GM pancake probes. Both Cs-137
and Sr-90 are high energy Beta emitters and will produce a higher efficiency than U-
238, thus they are inappropriate to use for calibration or function tests. Re-evaluate
the efficiency for the Ludlum Model-3 survey meters with the 44-9 GM pancake
probe using U-238 or equivalent alpha source.
BASIS FOR INTERROGATORY:
During the review of the calculations provided by Denison Mines, the reviewer requested
additional information from the Site RSO. The reviewer requested copies of the
calibration information and what sources were used when performing function checks on
survey instruments. In addition the reviewer contacted Ludlum to find out what the
typical efficiency for U-238 for Ludlum Model-3 survey meters with the 44-9 GM
pancake probe. Ludlums response was 15%. Using 15% in the same calculations that
Denison Mines used in their response, the Ludlum Model-3 survey meters with the 44-9
GM pancake probe is not sensitive enough to detect U-238 at the applicable regulatory
levels. A different meter and/or probe may need to be used to do release surveys for ore
trucks. (See attached emails)
Example: Using 15% efficiency and background used in Denison example.
MDC= 3 + 4.65 X -N/TSQ = 2906 dpm/lOOcm^ Alpha
(1)(0.15)(0.15)
APPLICALBE RULE(S) OR REGULATION(S):
R313-24-l(3). Purpose and Authority
R313-15-101. Radiation Protection Programs
R313-15-501(l). Survey and Monitoring-General
REFERENCES:
Radioactive Materials License Renewal Application for RML UT1900479: Appendix E:
Radiation Protection Manual Section 2.6 Equipment Release Surveys.
U.S. Nuclear Regulatory Commission Regulatory Guide 1.86: Decontamination of
Facilities and Equipment Prior to Release for Unrestricted Use.
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-ALARA:
Round One Interrogatory Statement 9 was answered appropriately and to the satisfaction
of the DRC.
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT- EMPLOYEE
TRAINING:
Round One Interrogatory Statements 10 and 11 were answered appropriately and to the
satisfaction of the DRC.
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT- STANDARD
OPERATING PROCEDURES:
Round One Intenogatory Statement 12 was answered appropriately and to the
satisfaction of the DRC.
HEALTH PHYSICS ROUND 2 INTERROGATORY STATEMENT-REVISIONS
AND UPDATES:
Round One InteiTogatory Statement 13 was answered appropriately and to the
satisfaction of the DRC.
(8/25/2009) Ryan Johnson - Re: Question on the efficiency of a Model 3 Page 1
From:
To:
Date:
Subject:
Howdy Ryan,
Kent Boatright <[e-mail]>
Ryan Johnson <[e-mail]>, Rhonda Harris <[e-mail]>
8/21/2009 7:45 AM
Re: Question on the efficiency of a Model 3
I am forwarding your email to Rhonda Harris, our RSO. She has the info
you need. She will email you back today. Tell Kevin hey.
Thanks,
Kent Boatright, Manager
Ludlum Measurements, Inc.
Repair/Calibration Department
325/235-5494 ext 3396 tel
325/235-4672 fax
[e-mail]
Ryan Johnson wrote:
> Kent,
>
> A colleague (Kevin Carney) gave me your name an email address. I have a licensee who uses a Model 3 meter with a Model
44-9 probe to survey for U-238. What is the typical efficiency for U-238 for that meter and probe type. By the way Kevin says Hi.
>
> Thanks for your help
>
> Ryan Johnson
> Environmental Scientist
> Utah Division of Radiation Control
(M^*2009rR^rrjohrTSon'-^^
From: Rhonda Harris <[e-mail]>
To: Ryan Johnson <[e-mail]>
Date: 8/21/2009 10:45 PM
Subject: Model 3 eff
Hello Ryan, the efficiency should be around 15% 4Pi. That is for alpha
emmission only. We do not have a source that we could run an eff for the
gammas although it would be less than 1%. Any gamma will always have
less than 1 % eff with a pancake detector.
If you have any questiuons please let me know.
Thanks
Rhonda
rage i OT i
Mr. Johnson,
Attached are the Ludlum Measurements semi-annual calibration sheets for the Model 177 w/43-1 probe
and the Model 3 w/44-9 pancake probe. At the White Mesa Mill the instruments are checked daily
before use utilizing a Th-230 source (33,000 dpm) for alpha instruments and a Sr/Y-90 source (39,300
dpm) for beta instruments. That information is recorded on the various scan sheets that pertain to their
usage.
David
David Turk
Radiation Safety Officer
t: 435-678-2221 x113 | f: 435-678-2224
6425 S. Highway 191, PO Box 809, Blanding, UT 84511
DENISON MINES (USA) CORP
vtfwvtf.denisonmines.com
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may contain
privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use, distribute print or
copy this message if you are not the intended recipient(s).
From: Ryan Johnson [mailto:Rmjohnson(autah.gov]
Sent: Wednesday, August 19, 2009 5:24 PM
To: David Frydenlund; David Turk; John Hultquist
Subject: Denison's Response to question #8 2nd round of interrogatories
David,
What model of pancake probe do you use?
What type of Calibration sources are used?
Can you ennail me copies of the calibration paper work? Just one from each type of meter(Model 3 with pancake
probe and l^odel 177 with the 43-1 alpha detection probe)
Thanks,
Ryan Johnson
fi lo-//r^AT^r^r-i tmisnlc '.inrl Qotti n rrc\ D m »r»Wr>cr>n\T r»n'.i1 ^^ttiri rrc\T<amr\\ YPm-rwi/i cp>\/l A RT^f^'TO 19/91 /^noQ
Designer and Manufacturer
of
Scientific and Industrial
Instmments GERTIFICATE OF CALIBRATION
CUSTOMER DENISON MINES CORPORATION
Mfg. Ludlum Measurements. Inc.
Mfg. Ludlum Measurements. Inc.
LUDLUM MEASUREMENTS, INC.
POST OFFICE BOX 810 PH. 325-235-5494
501 OAK STREET FAX NO. 325-235-4672
SWEETWATER. TEXAS 79556. U.S.A.
ORDER NO. 20132422/337160
Model
Model
M2. Serial No. J772AL
43-1
Cal. Dote 23-ADr-09 Cal Due Date 23-Oct-09
Serial No. ^7^o(?t^3
Col. Interval 6 Months Meterface 202-020
79 °F RH 2Z_ % Alt 697.8 mm Hg Check mark (^applies to applicable Instr. and/or detector lAW mfg. spec. T. _
• New Instrument Instrument Received ^Within Toler.+-10% •10-20% Q Out of ToL •Requiring Repair • Other-See comments
• Mechanical ck. 0' Meter Zeroed • Background Subtract • Input Sens. Linearity
0' F/S Resp. ck 0' Reset ck. • Window Operation EZ Geotropism
0'Audio ck. H' Alarm Setting ck. 0 Batt. ck. (Min. Volt) 5.97 VDC
0 Calibrated in accordance with LMI SOP 14.8 rev 12/05/89. • Calibrated in accordance with LMI SOP 14.9 rev 02/07/97.
Instrument Volt Set 650 V Input Sens. 35 mV Det. Oper. 650 V at 35,
• HV Readout (2 points) Ref./lnst. JQQ_
Threshold mV Dial Ratio mV
V Ref./lnst.. 1000
COMMENTS:
Calibrated with Subtract in "OFF" position.
AUrt^ cWcV^ti. U^V p»o\ SK^.
Gamma Calibralibn: GM datectors posftioned papendicular to source except for M 44-9 tn which the front of prota faces source.
RANGE/MULTIPLIER
X1K
X1K
XIOO
XI OQ
REFERENCE
CAL POINT
400kcpnn
lOOkcpnn
INSTRUMENT RECD
"AS FOUND READING"
40kcpm f/u>
INSTRUMENT
METER READING*
Vc^«
lOkcpm /a>
im. 4kcpnn lfiX>
JlJSL
VtjO
HQ.
IL
Ikcpm /vO 7u»
400cpm ^60 ^(j>
IL lOOCpJTI M /tJO
•Uncertainty within ±10% CF. within ± 20% AH. Range(s) Calibrated Electronically
REFERENCE
CAL. POINT
INSTRUMENT
RECEIVED
INSTRUMENT
METER READING*
Digital Readout
REFERENCE
CAL. POINT
INSTRUMENT
RECEIVED
INSTRUMENT
METER READING*
Log
Scale
.udlvjm Measurements, Inc. certifies fhol the obove Instrument has been calibrated by standords traceable to ttie National Inslilote of Standards ond Tectinology, or to the colibrofion faciRlles of
Dttier Inlemallonol Slondords Orgonizalion members, or hiave been derived from accepted volues of nolurol pfiyslcol constants or have been derived by Ihe ratio type of collbration fechnlques.
the colibrolion system contorms to the requirements of ANSI/NCSL Z540-I-I994 ond ANSI N323-t978 State of Texas Colibrotion License No. LO-1963
Reference Instruments and/or Sources: Os-394/1122 •1131 D78i Dos? 0280 060646
Cs-137 Gamma S/N •1162 •0112 •M565 DsiOS •TIOOBQTB?? nE552 DESSI 0720 ^734 01616 • Neutron Am-241 Be S/NT-304
H* Alpha S/N
Q' m 500 S/N
Calibrated By>o5.vfAH
Pu239 2928-01 • Beta S/N • Other
63893 • Oscilloscope S/N_ H' Multimeter S/N_ 93870637
TK<5r^^ b.^ar^ 1-
Reviewed By: ">VA>.;^^ A-A,,^..
Dote '^^'P\^^-0^
This certificate shall not be reproduced except in lull, without the written opprovol of Ludlum Measurements, Inc.
FORMC22A 10/15/2008
Date ^'^>^^A 01
AC Inst. O-^ssed Dielectric (Hi-Pot) and Continuity Test
Q"'y • Failed:
Designer and Manufacturer
of
Scientific and Industrial
Instruments
CUSTOMER DENISON MINES
Mfg. Ludlum Measurements. Inc.
Mfg. Ludlum Measurements. Inc.
7k RTJFICATE OF CALIBRATION
^LUDLUM MEASUREMENTS, INC.
( •: i)ST OFFICE BOX 810 PH. 325-235-5494
'501 OAK STREET FAX NO. 325-235-4672
SWEETWATER, TEXAS 79556, U,S.A.
ORDER NO. 20136685/339746
Model
Model 44-9
Cal. Date 6-Aug-09 Cal Due Date 6-Aug-10
74
Serial No. \ 5A S&^
Serial No. Pfll^^?^ 67&
Cal. Interval 1 Year Meterface 202-608
47 % Alt RH 698.2 mmHg Check mark j^pplies to applicable instr. and/or detector lAW mfg. spec. T._
• New Instrument Instrument Received g-WlthinToler.+-10% •10-20% •OutofTol. • Requiring Repair • Other-See comments
J^ Mechanical ck. 0' Meter Zeroed
^ F/S Resp. ck (2' Reset ck.
0' Audio ck. • Alarm Setting ck.
• Calibrated in accordance with LMI SOP 14.8 rev 12/05/89.
Instrument Volt Set 900 V Input Sens. 3 3
• Background Subtract
• Window Operation
0- Bait. ck. (Min. Volt)
• Input Sens. Linearity
(3' Geotropism
2.2 VDC
[3*eSfHbrated In accordance with LMI SOP 14.9 rev 02/07/97.
3 *5 Threshold
O mV Dial Ratio
• HV Readout (2 points) Ref./lnst.. V Ref./lnsL
mV
COMMENTS:
Gamma Calibration: GM detectors positioned perpendicular to source except for M 44-9 in which the front of probe faces source.
RANGE/MULTIPLIER
X100
X100
X10
X10
X1
XI
X0.1
X0.1
REFERENCE
CAL. POINT
150mR/hr
50 mR/hr
15mR/hr
5 mR/hr
1.5 mR/hr =5
1.0 mR/hr
iDCl^ji
INSTRUMENT RECD
"AS FOUND READING"
INSTRUMENT
METER READING*
O.S
i±k. _U5_ i^
5 (<0 cpm
11 (O cpm
JL^
l.S
0-5 g.S
'Uncertainty within ± 10% CF. within ± 20% X0.1 Range(5) Calibrated Electronically
REFERENCE
CAL. POINT
INSTRUMENT
RECEIVED
INSTRUMENT
METER READING*
Digital
Readout
REFERENCE
CAL. POINT
INSTRUMENT
RECEIVED
INSTRUMENT
METER READING*
Log
Scale
Ludlum Measurements. Inc. certifies (tial Ihe above Ir^trument fias been calibrated by standards traceable to tfie National Institute of Standards and Technology, or to the calibration facltlfles of
other Intemslional Standards Organization members, or have been derived from accepted values of natunat physical constants or have been derived by the ratio type of calibration techniques.
The calibration system confornre lo the requirements of ANSI/NCSL 2540-1-1994 and ANSI N323.197a State of Texas Calibration License No. LO-1963
Reference Instruments and/or Sources: ns-394/1122 Qnai 0781 Qosg 0280 •60646
Cs-137 Gamma S/N •l162 0'G112 • M565 QsiOS •T1008nT879 0^552 52iE551 0720 0734 •16I6 • Neutron Am-241 Be S/N T-304
• Alpha S/N
Q' m 500 S/N
Calibrated By;
• Beta S/N • Other
Reviewed By:
73648 • Oscilloscope S/N Q^ Multimeter S/N
Dale ^'(\OC\ - 09.
89880241
"Vo^j^^J.^ \r\ c^ >»• Date UK 5
^ 03_
This certificate shall not be reproduced except In futl, without the written approval of Ludlum Measurements, Inc.
FORMC22A 10/15/2008
AC Inst. • Passed Dielectric (Hi-Pot) and Continuity Test
Only • Failed;
SECTION 2
UTAH DIVISION OF RADIATION CONTROL
DENISON MINES (USA) CORPORATION
WHITE MESA URANIUM MILL
BLANDING, UTAH
ENGINEERING COMMENT INTERROGATORIES
ROUND 2
DECEMBER 28,2009
TABLE OF CONTENTS
Section/Page
INTERROGATORY STATEMENTS ON THE RECLAMATION PLAN 3
Plan Revision Numbers, Statement I-A 3
Plan to be included in License Renewal Application, Statement LB 4
Discharge Channel from Cell 1, Statement LC 5
Rock Apron at Base of Outslope of Tailings Cells, Statement LD 7
Filter Blanket below Rip-Rap of Tailings Cells, Statement LE 8
Map showing Mill Buildings and Tankage, Statement LF 10
Illegible copy of a Rainfall Duration Curve, Statement LG 11
References of NRC to DRC, Statement LH 12
Changes to Final Construction Report, Statement LI 13
Outdated Reclamation Plan Table of Contents, Statement LJ 14
Addition of Provisions for Cell 4A to the Plan, Statement LK 15
Amend Plan to Conform to Final Approved ICTM, Statement LL 16
INTERROGATORY STATEMENT II-A: LICENSE VIOLATIONS: 17
INTERROGATORY STATEMENT II-B: CORRECT MODELING INFERENCES: 18
INTERROGATORY STATEMENT II-C: CORRECT VERSION OF DOCUMENTS: 19
INTERROGATORY STATEMENT ILD: OMISSION OF DMT DOCUMENT 20
INTERROGATORY STATEMENT II-E: OMISSION OF O&M DOCUMENT 21
ACRONYMS AND ABBREVIATIONS
ALARA As Low As Reasonably Achievable
CFR Code of Federal Regulations
DRC Utah Division of Radiation Control
DUSA Denison Mines (USA) Corp.
NRC Nuclear Regulatory Commission
NUREG-XXXX Reports and Books Prepared by the NRC
NUREG/CR-XXXX Reports and Books Prepared by NRC Contractors
PMF Probable Maximum Flood
RWP Radiation Work PeiTnit
UAC R313 Utah Administrative Code, Rule 313
MILDOS MILDOS Computer Code
Preface to Engineering Comment Interrogatories Round 2;
Original Interrogatories Round 1 are given in italics. However, often not the entire
original interrogatory, i.e. the Basis for Interrogatory, Regulatory Basis, and References
are given in the following interrogatories.
If paits of the original interrogatory have been omitted from the Round 1 version, a
dotted line trailer (...) has been inserted, to alert the reader to this fact. If further
information is required please review Engineering Comment Interrogatories Round 1.
INTERROGATORY STATEMENT- The Reclamation Plan:
I-A DRC Round 1 dated July 2, 2009:
The currently approved, latest Reclamation Plan needs to receive a unique identifying number the
as to the version of the plan it is. We request that DUSA assign a version number (e.g. 4.0) to the
currently approved reclamation plan. If there are iterative changes necessary to the plan as a
result of these License Renewal Application comments, each DUSA proposed revision to the plan
must be identified by a unique reference number, e.g. a suffix to the number, such as proposed
Revision 4.1, 4.2, etc.
The updates to the Reclamation Plan conveyed by DUSA letter dated July 25, 2008 were not
included in the License Renewal Application. They need to be included...
DUSA Responded by Submitting a Letter dated August 14, 2009, stating Revision 4.0 of the
Reclamation Plan would be forthcoming. Revision 4.0 of the plan was sent by DUSA by letter
dated November 24, 2009: This update to the Reclamation Plan is now included as part of the
License Renewal Application.
DRC Response:
The newly submitted Reclamation Plan Revision 4.0 renumbering and updates to include
information from the DUSA letter of July 25, 2008 has been reviewed, and is acceptable. This
matter is closed.
For additional DRC comments on the November, 2009 DUSA Reclamation Plan, see below.
INTERROGATORY STATEMENT - The Reclamation Plan:
I-B DRC Round 1 dated July 2, 2009:
Please update and complete the Section 8 of the License Renewal Application, regarding the
Reclamation Plan. Please include the current approved version of the Reclamation Plan as an
Appendix to the License Renewal Application.
DUSA Responded by Submitting a Letter dated August 14, 2009, stating Revision 4.0 of the
Reclamation Plan would be forthcoming. Revision 4.0 of the plan was sent by DUSA by letter
dated November 24, 2009:
The DUSA letter of November 24, 2009 supplied a revised Section 8 to the License Renewal
Application as replacement pages. This letter states the Reclamation Plan is submitted as a new
Appendix P to the original License Renewal Application.
DRC Response;
The replacement pages to Section 8 of the License Renewal Application are acceptable, and have
been incorporated into the License Renewal Application.
The DUSA letter of November 24, 2009 states, "Denison is hereby submitting the enclosed
Revision 4.0 as a new Appendix P to the February 28, 2007 renewal application..."
However, the Index to Appendices in the February 28, 2007 License Renewal Application (i.e.
page vi) needs to be revised to add Appendix P. Also, a tab sheet and a place holder sheet, stating
the location of the new Appendix P, should be submitted to place in the License Renewal
Application appendices volume.
For additional DRC comments on the November, 2009 DUSA Reclamation Plan, see the
additional interrogatories below.
INTERROGATORY STATEMENT- The Reclamation Plan:
I-C DRC Round 1 dated July 2, 2009:
Re sardine the Cell 1 Discharge Channel, on Figure A-2,2,4-1 Sedimentation Basin Detail:
J. The potential need for or absence of rip-rap protection for the Cell I discharge channel,
entry and exit platform aprons must be explained and justified. An adequate
demonstration will include, but is not limited to analysis according to NUREG-1623.
2. The need to join or not join (the existing configuration) the discharge channel to the toe
of the new south dike of Cell 1 must be explained and justified.
3. Drawing details are needed to show the outcome of the above analyses to describe the
sections of the discharge channel, its lining, appurtenant entry, exit apron zones, dike
alignment and lining.
Basis for the Interrogatory:
1. The need for using rip-rap protection for the Cell 1 discharge channel, entry and exit
aprons need to be analyzed under Potential Maxinium Precipitation and Flood.
2. It appears advantageous to connect the discharge channel to the toe of the new south
dike of Cell 1 to ensure entry flow path longevity, and to possibly eliminate need for rip-
rap armor south of the discharge channel on the west dike of Cell 1.
3. The construction requirements for the discharge channel, its lining, appurtenant entry,
exit apron zones, dike alignment and lining need to be specified....
References:
Reclamation Plan, Revision 3.0, Figure A-2.2.4-1 Sedimentation Basin Detail
NUREG-1623, Design of Erosion Protection for Long-Term Stabilization
Chow, V.T. 1959, Design of Channels for Uniform Flow, Open Channel Hydraulics, McGraw-
Hill Book Company, p. 164-179.
DUSA Response dated August 14, 2009:
"The Cell Discharge Channel is intended to divert the water accumulated from the PMP storm
event from a 143 acre area, which includes the sedimentation basin created from the Cell area,
the reclaimed Mill area, and the area to the north of the Cell area but south of the existing
diversion ditches. The channel is created by excavation of the undisturbed ground to the west of
Cell 1 to maximum depth of approximately 17 feet. The lower 10 feet of the channel is
excavated in Dakota Sandstone to an elevation matching the lowest point on the west end of the
Cell 1 sedimentation basin. The channel will be excavated at slope of 1% and will daylight in
the Dakota Sandstone cliffs in Westwater Canyon. A cross section of the area to be excavated is
included in Appendix P to this letter."
"The maximum discharge volume through the channel will be 1344 cubic feet per second
resulting in flow velocity of 7.45 feet per second assuming bottom channel width of 120 feet
The channel design proposed in the reclamation plan is actually 150 feet wide at the bottom,
which will further reduce the flow velocity. The allowable flow velocity for bedrock channel
is 8-10 feet per second; therefore no riprap is required in the channel bottom. The entrance to
the channel will match the bottom elevadon of the sedimentation basin; so no riprap will be
necessary at that point. The channel discharge will be on to the cliffs of Westwater Canyon;
therefore no riprap will be necessary at that point. The discharge calculations are included in
Attachment G to the Reclamation Plan, and also included in Appendix P to this letter.
"We do not believe that the discharge channel should be joined with the toe of the new fill area
on the north slope of the Cell 1 dike. The flows off the dike slope will be very small and the rip
rap toe will easily protect the slope and the reclamation cover. The flow velocities at the entrance
to the discharge channel could possibly impact the rip rap loe. or require additional rip rap, and
should therefore be avoided. Water potentially backing up from the entrance to the discharge
channel would be very low velocity in the area near the toe of the Cell 1 north slope and would
not impact the stability of the slope."
DRC Response:
Interrogatory 1C Item 1:
It appears the approach velocity at entry to the channel inay exceed the scouring resistance of the
existing Cell 1 soil upstream of the channel, creating erosion prior to flow on the in-situ rock
lined channel bed.
To support your claim that this is not a problem for the Cell 1 floor:
Please analyze the dimensions, area of extent, and anticipated channel entry scour
velocities in accordance with methods outlined in NUREG-1623, and submit quantitadve
calculations for DRC review.
If said calculations indicate soil scour will occur, please submit design for an appropriate channel
entryway rip-rap apron, to accommodate the area of scouring velocities, for revision to the current
Reclamation Plan Version 4.0. This calculation and/or the design change, plans and
specifications will need to be included as part of this License Renewal Application.
Interrogatory IC Item 2:
The response from DUSA is satisfactory and that matter closed.
Interrogatory IC Item 3:
The dimensions shown on the Reclamation Plan drawings for the Cell 1 outlet channel need to be
corrected to indicate the dimensions discussed by DUSA above. The Reclamation Plan drawings
currently show a 200-foot wide channel bottom. In contrast, your August 14, 2009 response said
it would be 150-feet wide.
Please submit revised calculadons (above) and corrected drawings of the channel dimensions
with plans and specifications for the rip-rap entry apron provision mentioned above for revision
to the current Reclamation Plan Version 4.0. This change will need to be included as part of this
License Renewal Application.
INTERROGATORY STATEMENT- The Reclamation Plan:
I-D DRC Round 1 dated July 2, 2009:
This interrogatory is being provided for DUSA's information only. This item will be pursued
concurrent with DRC review of the Infiltration and Contaminant Transport Modeling Report,
White Mesa Mill Site, Blanding Utah (ICTM) prepared by DUSA. Last correspondence on the
report was furnished by DUSA on April 30, 2009.
Is installation of a rock apron at the base of all the final covered tailings cell outslope intended
for the entire perimeter of the final covered tailings cell system? If so, please clarify by
specifying on the drawings that such is required. If not, please demonstrate that the absence of
such will be adequate for the 1,000-year design period or at minimum a 200-year period.
Basis for the Interroj^atory:
The reclamation plan drawings only distinctly specify rock aprons on the south outslope of Cell
4A, It is unclear if installation of a rock apron at the base or toe of all dike outside side slopes is
intended. That is, are rock aprons to be installed for the entire perimeter of the tailings cell
system? Reclamation Plan figures A-5.1-1, -2, -3 and -4 show a plan view and cross-sections of
the tailings cells. The section A-A' on Figure A-5.1-2 on the left side refers to Fig. A-5.1-4,
which is a drawing of the "Rock Apron at Base of the Toe of the Cell Outslope. " None of these
plan views or cross-sections specifically shows rock aprons, other than the south side of Cells
4A...
References:
Reclamation Plan, Revision 3.0, Figures A-5.1-1, -2, -3 and -4.
Reclamation Plan, Revision 3.0, Figure A-2.2.4-1 Sedimentadon Basin Detail
NUREG-1623, Design of Erosion Protection for Long-Term Stabilization
Chow, V.T. 1959, Design of Channels for Uniform Flow, Open Channel Hydraulics, McGraw-
Hill Book Company, p. 164-179.
DUSA Response dated August 14, 2009:
"The questions raised in Interrogatory Statement I-D will be addressed in the re-design of the
tailings cover system in accordance with the approved ICTM."
DRC Response:
We agree that the need for rock aprons discussed above will be addressed by DUSA in the ICTM
study. However, we have determined that this issued must be addressed and resolved now as a
part of the License Renewal Application.
Due to the uncertain timeline for the ICTM study compledon on this item, DUSA must submit
design analysis, plans and specifications for rock aprons for the tailings cells perimeter outslope
as discussed above.
The design for the rock aprons, as appropriate, will need to be included as part of this License
Renewal Application, and must comply with the engineering guidelines found in NRC NUREG
1623.
However, we realize the final design of appurtenant rock aprons for the outslope of the tailings
cells may be in accordance with an approved ICTM design, and will need to be included in the
future revision to the White Mesa Mill Reclamation Plan to be submitted for approval after
completion and approval of the ICTM study.
INTERROGATORY STATEMENT- The Reclamation Plan:
LE DRC Round 1 dated July 2, 2009:
Please deinonstrate that for final reclamation of the tailings cells a filter blanket is necessary or
unnecessary to be installed below the riprap cover, for the top, side slopes, and rock aprons of
the tailings cells.
Basis for the Interrogatory:
There is no filter blanket shown or specified in the Reclamation Plan. A demonstration of layer
stability is needed to justify the omission of a filter blanket in the cover design.
Also, we recognize that different engineering design has been proposed by DUSA in the
November 21, 2007 Infiltration and Contaminant Transport Modeling Report, White Mesa Site,
Blanding, Utah, prepared by MWH Americas Inc. Erosion stability issues and radon controls
must considered in the final reclamation plan and must be closely coordinated with ICTM report
that may be approved later.
Regulatory Basis:
1. R313-24-4. Uranium Mills and Source Material Mill Tailings Disposal Facility
Requirements -Clarifications or Exceptions incorporate 10CFR40 Appendix A with some
exceptions and substitutions.
2, 10CFR40, Appendix A, Criterion 9 requires an Executive Secretary approved
reclamation plan for the White Mesa Mill.
References:
1. 2002, TL. Johnson, NUREG-1623, Design of Erosion Protection for Long-Term
Stabilization, Appendix D, Designing Riprap Erosion Protection, Paragraph 2.1.1, Filter
Requirements: "It is generally recommended that a filter or bedding layer comprised of
well-graded rock material be placed on the cover or in locations where rock riprap is to
be placed for erosion protection. Locations recommended for filter placement include
impoundment side slopes, toes of slopes, transition areas, diversion ditches and channels,
stilling areas, and flow impact areas. The purpose of the filter is to bed the riprap and
prevent stone penetration into the cover and7or radon barrier, prevent soil erosion from
flow at the stone7soil interface, and to prevent the pooling of precipitation and/or
tributary runoff from infiltrating into the cover and waste materials. Filter sizing criteria
are presented in NUREG7CR-4620 (Nelson, 1986). "
2. Same Drawing References, per the interrogatory immediately above this one.
DUSA Response dated August 14, 2009:
"It is not clear why filter blanket was not included in the original cover design. As noted by
DRC, Denison is proposing revised cover design as part of the Infiltration Analysis [ICTM]
which will eliininate the rip rap on the top surface of the reclaimed tailings. The need for a filter
blanket on the embankment side slopes and toe areas will be evaluated at that time."
DRC Response:
We agree that the need for the filter blanket discussed above will be addressed by DUSA in the
ICTM study. However, we have determined that this issued must be addressed and resolved now
as a part of the License Renewal Application.
Due to the uncertain timeline for the ICTM study completion on this item, DUSA must submit
design analysis, and plans and specifications for a filter blanket to be installed below all riprap
cover, including but not limited to the top, side slopes, channel lining aprons and dike outslope
rock aprons of the tailings cells.
The design for the filter blankets will need to be included as part of this License Renewal
Application, and must comply with the engineering guidelines found in NRC NUREG 1623.
However, we realize the final design of the filter blanket for the rip/rap system may be in
accordance with an approved ICTM design, and will need to be included in the future revision to
the White Mesa Mill Reclamation Plan to be submitted for approval after completion and
approval of the ICTM study.
INTERROGATORY STATEMENT- The Reclamation Plan:
I-F DRC Round 1 dated July 2, 2009:
Reclamation Plan Fig, 3.2.3-1, Site Map Showing Locations of Buildings and Tankage needs to
be updated to current conditions....
DUSA Responded by Submitting a Revision 4.0 of the Reclamation Plan on November 24, 2009:
The DUSA letter of November 24, 2009 conveyed a revised Figure 3.2.3-1 in Reclamation Plan
Version 4.0.
DRC Response:
The revised Figure 3.2.3-1 provided has been reviewed. This figure does not provide a current
map of the tanks and the tank solutions that are depicted by the DUSA letter dated July 15, 2009,
subject: Tank Layout and Update. Please revise and update Figure 3.2.3-1 in accordance with
this latest information, to ensure that it is complete and representative of current site conditions.
10
INTERROGATORY STATEMENT- The Reclamation Plan:
I-G DRC Round 1 dated July 2, 2009:
In the DRC copy of the Reclamation Plan, Appendix [Attachment! G, Attachment 9, Rainfall-
Duration Cun'efor One-Hour PMP at White Mesa Mill is illegible. Please provide a readable
copy of the graph....
DUSA Response dated August 14, 2009:
"A readable copy of Reclamation Plan, Appendix [Attachment] G, Attachment 9, Rainfall-
Duration Curve for One-hour PMP at White Mesa Mill is attached as Appendix Q to this letter."
DRC Response:
We note this submittal. The response is acceptable. The subject rainfall duration curve has been
integrated into the submitted Reclamation Plan Version 4.0 as well as the current Reclamation
Plan.
Per Appendix F, Table IC of the Tailings Cover Design White Mesa Mill 1996, by Titan
Environmental Corporation, the minimum D50 for the rip-rap diameter for top portion of the cover
is to be 3.4 inches.
Drawing A-5.1-3 in the Reclamation Plan Rev 4.0 lists the D50 as 0.3 inches. Please correct this
error on the drawing.
11
INTERROGATORY STATEMENT- The Reclamation Plan:
I-H DRC Round I dated July 2, 2009:
Numerous references to the NRC in the Reclamation Plan must be changed to the Utah Division
of Radiation Control (DRC). A general overriding amendment to the Reclamation Plan may best
satisfy this need..,
DUSA Responded by Submitting a Revision 4.0 of the Reclamation Plan on November 24, 2009:
The DUSA letter of November 24, 2009 supplied a revised Section of the License Renewal
Applicadon.
DRC Response:
This information has been reviewed, and checked for coordination within the new Reclamation
Plan Revision 4.0 text, and is acceptable. This matter is closed.
12
INTERROGATORY STATEMENT- The Reclamation Plan:
I-I DRC Round 1 dated July 2, 2009:
In the Reclamation Plan on pp. B-2 and B-16, the Final Construction Report is referred to. This
report is important to independently document the completion of the reclamation and
decommissioning work. In that regard, please revise the Reclamation Plan to include the
following:
1. Please remove any reference to NRC7DRC field presence in the Reclamation Plan.
2. The report must be submitted to the DRC within 180 calendar days after the apparent
completion of Construction, for Executive Secretary review and approval.
Basis for the Interrogatory:
There is no current distinct requirement in the license for a Final Closure Report. There are
many regulatory and administrative needs for such a report.
Regulatory Basis:
1. R313-24-4. Uranium Mills and Source Material Mill Tailings Disposal Facility
Requirements -Clarifications or Exceptions incorporate 10CFR40 Appendix A with some
exceptions and substitutions.
2. 10CFR40, Appendix A, Criterion 9 requires an Executive Secretary approved
reclamation plan for the White Mesa Mill.
3. R313-24-l(3)
4. R313-22-36(10)
5. R313-22-34(7)
6. R313-22-34(l)
References:
Reclamation Plan, Attachment B, Quality Plan for Construction Activities White Mesa Project
Blanding, Utah.
DUSA Responded by Submitting a Revision 4.0 of the Reclamation Plan on November 24, 2009:
The Reclamation Plan, Revision 4.0 made most of the appropriate changes to the specified
verbiage.
DRC Response:
References to the NRC appear to be removed from the Reclamation Plan, Revision 4.0.
However, the verbiage on the last sentence on page B-2 needs connection. Please correct this
sentence and resubmit this page as a revision to the cunent Reclamation Plan Version 4.0. This
change will need to be included as part of this License Renewal Application.
13
INTERROGATORY STATEMENT- The Reclamation Plan:
I-.T DRC Round 1 dated July 2, 2009:
// appears the current Table of Contents (TOC) in the Reclamation Plan (Revision 3.0) is taken
directly from Revision 2.0, which is now outdated. The actual content and page numbers of the
plan were revised in Revision 3,0. Additional content changes to the plan as a result of review of
the current license renewal application are expected.
Adjustments to the current TOC in the Reclamation Plan are needed to bring the table up to date.
A final adjustment will need to be done at the end of the review iterations for the license renewal
application.
Regulatory Basis:
1. R313-24-4. Uranium Mills and Source Material Mill Tailings Disposal Facility
Requirements -Clarifications or Exceptions incorporate 10CFR40 Appendix A with some
exceptions and substitutions.
2. 10CFR40, Appendix A, Criterion 9 requires an Executive Secretary approved
reclamation plan for the White Mesa Mill.
References:
Reclamation Plan, Table of Contents.
DUSA Responded by Submitting Revision 4.0 of the Reclamation Plan on November 24, 2009:
Revision 4.0 of the Reclamation Plan has a revised Table of Contents.
DRC Response:
This information has been reviewed, and checked for coordination within the new Reclamation
Plan Revision 4.0 text, and is acceptable. This matter is closed.
14
INTERROGATORY STATEMENT- The Reclamation Plan:
LK DRC Round 1 dated July 2, 2009:
The Reclamation Plan refers to work in Tailings Cells 1, 2, 3 and sometimes Cell 4A. However
the plans and specifications for the reclamation of Cell 4A are not always included in the
Reclamation Plan written text and drawings.
Additions to the Reclamation Plan are needed to include provisions, for the reclamation of Cell
4A, into the plans and specifications. Provisions for Cell 4A needs to be incorporated into the
Reclamation Plan Table of Contents (TOC), as well as the plans and specifications.
Basis for the Interrogatory:
Provisions in the existing Reclamation Plan for the tailings cell system do not always include Cell
4A in the written text and drawings, as well as the TOC. Provisions for Cell 4A must be included
in the Reclamation Plan.
Regulatory Basis:
1. R313-24-4. Uranium Mills and Source Material Mill Tailings Disposal Facility
Requirements -Clarifications or Exceptions incorporate 10CFR40 Appendix A with some
exceptions and substitutions.
2. 10CFR40, Appendix A, Criterion 9 requires an Executive Secretary approved
reclamation plan for the White Mesa Mill.
References:
Reclamation Plan, Table of Contents, Sections 2.0, and 3.0, List of Tables, List of
Attachments, etc.
DUSA Responded by Submitting Revision 4.0 of the Reclamation Plan on November 24, 2009:
Revision 4.0 of the Reclamation Plan addresses the reclamation of Cell 4A.
DRC Response:
This information has been reviewed, and checked for coordination of reclamation of Cell 4A
within the new Reclamation Plan Revision 4.0 plans and specifications, TOC and text, and is
acceptable. This matter is closed.
15
INTERROGATORY STATEMENT- The Reclamation Plan:
I-L DRC Round 1 dated July 2, 2009:
"The tailings cell cover design found in the Reclamation Plan provided with the February 28,
2007 License Renewal Application is not the same as that provided in the November 21, 2007
Infiltration and Contaminant Transport Modeling (ICTM) Report, White Mesa Site, Blanding,
Utah, prepared by MWH Americas Inc, It will be DUSA's responsibility to amend the License
Renewal Application and the Reclamation Plan to ensure that the tailings cells cover design,
plans, specifications and construction ultimately authorized conforms to the approved ICTM
Report. "
Basis for the Interrogatory:
Provisions in the existing License Renewal Application and Reclamation Plan will need to be
adjusted to ensure that the tailings cells cover design, plans, specifications and construction
conforms to the approved ICTM...
DUSA Response:
The Reclamation Plan, and to the extent applicable the 2007 License Renewal Application, will
be amended to ensure that the tailings cell cover design, plans, specifications and construction
ultimately authorized conform to the approved ICTM. Denison expects that the resulting
changes to the Reclamation Plan may be significant, and may jusdfy the creation of Revision
5.0 of the Reclamation Plan in order to properly incorporate the changes into the Plan.
DRC Response:
We agree that depending on the approval date for the ICTM Report, DUSA will probably need to
issue a future revision to the Reclamation Plan for approval, incorporating the approved ICTM
plan provisions, rather than incorporate such provisions in the submitted Reclamation Plan
Revision 4.0. So, at a future date, an approved Reclamation Plan incorporating the approved
ICTM study would then need to be included as part of next license amendment after approval of
the current License Renewal Application.
However, it is imperadve that Revision 4.0 of the Reclamation Plan be reviewed and approved by
DRC to reflect the most currendy available design for closure conditions. To this end, it is
important DUSA complete all present issues in this Interrogatory, so that DRC review of the
License Renewal Application can move forward.
16
INTERROGATORY STATEMENT- License Violations:
II-A DRC Round 1 dated July 2, 2009:
The application states that license violations identified during NRC or State of Utah site
inspections are listed. However, not all violations are listed. The application states that license
violations identified during NRC or State of Utah site inspections are listed However, not all
violations are listed. Please include a listing of all violations of your Ground Water Quality
Protection Permit.
Basis for the Interrogatory: The above regulatory basis document states that license violations
identified during NRC or Agreement State site inspections should be listed in License Renewal
Applications. The State Ground Water Quality Protection Rules are incorporated by reference in
the Uranium Mills and Source Material Mill Tailings Disposal Facility Requirements in UAC
R313-24.
Regulatory Basis:
1. NUREG-1569 Appendix A: Guidance for Reviewing Historical Aspects of Site
Performance for License Renewals and Amendments;
2. R313-24-4(1 )(b) - including exclusion of 10 CFR 40, Appendix A, Criterion 5(B)(1) thru
5H, Criterion 7A, and Criterion 13; and replacement with Utah Administrative Code
R317-6 [Ground Water Quality Protection Rules]
3. License Renewal Application paragraph 1.2.6: Listing and Description of Violations,
etc.
References:
1. License Renewal Application, Section 9, Table 9.2-1: NRC and UDEQ Inspections at
White Mesa Mill since March 31, 1997.
2. NUREG-1569 Appendix A: Guidance for Reviewing Historical Aspects of Site
Performance for License Renewals and Amendments ;
DUSA Response dated August 14, 2009:
"Denison disagrees with the foregoing statement. All violadons including violadons under the
Mills State of Utah Groundwater Discharge Permit Air Approval Order and Radioactive
Materials License as of February 28 2007, the date of submittal of the 2007 License Renewal
Application, are listed in Table 9.2-1 of Volume I of the Applicadon. These violadons are also
discussed in Sections 9.2.1, 9.2.2 and 9.2.3 of Volume I of the Application. Specifically,
Secdon 9.2.3, entided "Water Quality Notices of Violadon" addresses the 11 violations issued on
or before February 28 2007 under the Mills Groundwater Discharge Permit."
"There have been number of violadons under the Mills Radioactive Materials License,
Groundwater Discharge Permit and Air Approval Order since February 28, 2007. However,
since the disclosure in the 2007 License Renewal Application is as of February 28 2007, these
have not been addressed here."
DRC Response:
We have reviewed this response and find it acceptable. This matter is closed.
17
INTERROGATORY STATEMENT- Correction of Modeling Inferences
II-B DRC Round 1 dated July 2, 2009:
1. There is no paragraph 3.13.1.6 in the Environmental Report (ER). This reference must
be corrected.
2. License Renewal Application Paragraph 6.5.8 should clearly state that the statement is
based on modeling predictions,
3. License Renewal Application Paragraph 6.5.9 should also clearly state that the statement
in the paragraph is based on modeling predictions.
Basis for the Interrogatory:
1, The above basis paragraph 6.5.8 currently states that, "Section 3.13,1.6 of the ER . . .
concludes that even running at full capacity in high-grade . . . ores the maximum . . .
doses to the public are well within . . . applicable regulatory standards and ALARA
goals."
2. In License Renewal Application, paragraph 6.5.9 it states that, "The MILDOS Area
Modeling confirms that the current design and operation controls at the Mill are
sufficient to result in operations at full capacity processing high-grade ores that are
within the regulatory standards and applicable ALARA goals. "
Regulatory Basis:
1. The Environmental Report (ER), Vol. 4 of the License Renewal Application, paragraph
3.13.1.6. of the ER is referenced in paragraph 6.5.8 of the application.
2. License Renewal Application,
a. Paragraph 6.5.8, MILDOS Area Modeling
b. Paragraph 6.5.9, Summary of Effectiveness of Environmental Controls and
Monitoring.
3. Utah Administrative Code R317-6, Ground Water Quality Protection.
References:
1. License Renewal Application, paragraph 6.5.8, MILDOS Area Modeling
2. Ibid., paragraph 6.5.9, Summary of Effectiveness of Environmental Controls and
Monitoring.
DUSA Response dated August 14, 2009:
"The requested changes have been made to page 65 of the 2007 License Renewal Applicadon. A
revised page 65, marked to indicate the changes, and clean copy, are attached as Appendix R to
this letter."
DRC Response:
We have reviewed this response and find it acceptable. The replacement page has been
incorporated into the License Renewal Applicadon. This matter is closed.
INTERROGATORY STATEMENT- Correct Version of Documents
II-C DRC Round I dated July 2, 2009:
The SWBMPP provided as tab 1 in Appendix C of the License Renewal Application is not the
approved version. Please replace with the June 2008 edition, that was approved by the DRC on
July 1,2008....
DUSA Response dated August 14. 2009:
"Attached as Appendix S is the June 2008 edition of the Storm Water Best Management Practices
Plan that was approved by the DRC on July 1, 2008."
DRC Response:
We have reviewed this response and find it acceptable. The DUSA document dated June 13,
2008 has been incorporated into the License Renewal Applicadon. This matter is closed.
19
INTERROGATORY STATEMENT- Correct Version of Documents
II-D DRC Round 1 dated July 2, 2009:
The edition of the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan (DMT Plan) provided as tab 3.1 of Appendix A of the
License Renewal Application, is not the approved version. Please replace it with the approved
"09708 Revision: Denison-6" version of the plan and attachments...
DUSA Response dated August 14, 2009:
"Attached as Appendix E is the approved 09/08 Revision Denison-6 version of the White
Mesa Mill Tailings Management System and Discharge Minimizadon Technology (DMT)
Monitoring Plan."
DRC Response:
We have reviewed this response, and find the correct document was submitted, and is acceptable.
The currently approved DMT Plan, approved by the DRC on September 17, 2008 has been
incorporated into the License Renewal Application.
20
INTERROGATORY STATEMENT- Omission of Document
II-E DRC Round I dated July 2, 2009:
The License Renewal Application appears to not contain the Cell 4A BAT Monitoring, Operations
and Maintenance Plan (O&M Plan). Please include the latest approved edition in the
application...
DUSA Response dated August 14, 2009:
"Attached as Appendix L is version 09/08 Revision Denison 1.3 of the Cell 4A BAT Monitoring
Operations and Maintenance Plan which is the latest approved edidon of that plan."
DRC Response:
We have reviewed this response and find the document submitted acceptable.
However, the Index to Appendices in the February 28, 2007 License Renewal Application need to
be added for the O&M Plan. A tab sheet should be submitted to place the O&M Plan into the
appropriate License Renewal Application appendix volume.
F:\driipp\DUSA\LRA\Engrg InterrogsRiidlb 12-22-09.doc
21