DRC-2012-001563 - 0901a068802e22f6

State of Utah
GARYR HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Srruth
Exccuti\ e Director
DIVISION OF RADLMION CONTROL
Rusty Lundberg
Director
DRC-2042-00156
May 30, 2012
Jo Ann Tiscliler
Director, Compliance and Permitting
Denison Mines (USA) Corp.
1050 Seventeenth St. Suite 950
Denver, Colorado, 80265
Subject: Denison Mines (USA) Corp., May 25, 2012 Response Letter, Including a Revised White
Mesa Uranium Mill Ground Water Quality Assurance Plan, Rev. 7.1: Approval
Dear Ms. Tischler:
The Utah Division of Radiation Control (DRC) has reviewed the Denison Mines (USA) Corp.
(DUSA) May 25, 2012 response letter (Letter); submitted m response to a DRC April 16, 2012
Request for hiformation (RFI) letter.
The Letter included:
1. Notification ofthe DUSA request for a ground water discharge permit modification tinder
separate cover dated May 25, 2012, to formalize issues discussed during an April 5, 2010
DRC/DUSA teleconference, regarding accelerated monitoring and reporting timelines.
2. DUSA response to the DRC issues regarding long laboratory tumaround times (11 week
tumaround) noted in the White Mesa Uranium Mill 4* Quarter 2011 Ground Water
Monitoring Report, ahd the subsequent DRC RFI request to modify the White Mesa
Uranium Mill Groimd Water Quality Assurance Plan (QAP) to include a requirement for a
maximum 30 day tumaround time.
3. Notification that monitoring well MW-11 will be retumed to baseline ground water
monitoring for THF beginning in June 2012, per the DRC Director approval.
4. QAP Revision 7.1, revised per the DRC RFI, for DRC Director review and approval.
DUSA Contract Laboratory Turn Around Time
Per the Letter, it was noted that DUSA does not agree with the RFI request to include a 30 day
turnaround requirement for the DUSA contract laboratory to provide laboratory sample results.
195 North 1950 West • Salt Lake Cify, UT
Mailing Address PO Bo.x 144850 • Sait Lake City, UT 84114-4850
Telephone (SOI) 536-4250 • Fa.x [phone] 'TDD [phone]
twrn deq utali gov
Pnntfid on lOO^.S recycled paper
Jo Ann Tischler
Page 2
Per the Letter this is based on:
1. DUSA should not be penahzed for collecting samples early in the monitoring quarter,
2. DUSA does not self-perform the analytical work and cannot force delivery of data within a
specified time frame.
3. DUSA strives to enforce the contractually specified time frames for data delivery with the
contract laboratory.
Per a DUSA/DRC telephone conference on May 14, 2012, these issues were discussed and it was
agreed that instead of the 30 day laboratory data tumaround requirement:
1. DUSA will provide the Exceedance Notice within 30 days from the receipt of the last data
package and no later than 60 days after the end of the quarter.
2. DUSA will subnnt the Plan and Time Schedule for addressing OOC parameters witiiin 30
days after the Exceedance Notice. ,
DUSA notes in the Letter that these changes have been incorporated into the May 25, 2012
ground water permit modification request.
Based on DRC review, these changes are consistent with the agreements made during the May 14,
2012 conference call.
QAP Rew 7.1 DRC Approval
Based on DRC review ofthe Wliite Mesa Uranium Mill Mill QAP Revision 7.1, dated May 25,
2012, it appears that the DRC comments in the RFI have been incorporated into the QAP Rev. 7.1
as appropriate, with the exception ofthe 30 day laboratory tumaround time as discussed above.
Therefore, QAP Revision 7.1 is approved.
Ifyou have any questions regarding this letter please contact Tom Rushing at [phone].
Sincerely,
Rusty Lundberg, Director
RL.TRitr
F \DUSA\Groundwater Reports\2011 Groundwater ReporLs\201 1 1st, 2nd and 3rd Qtr Re\iew\DUSA Response to NOED\QAP Revision 7 1 DRC
Approval Ltr docx