DRC-2010-002776 - 0901a0688017a6a5

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Ueulenant Govenwr
Department of
Environmental Quality
Amanda Jbmilh
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerlrnck
Director
DRC-201C-GC2776
U.S. Postal Service-.'
CERTIFIED MAIL.' RECEIPT
(Domestic fi/tail Only; No Insurance Coverage Provided)
For delivery information visit our website at www.-usps.com
April 8. 2010
CERTIFIED MAIL
RETURNED RECEIPT REOUESTED
Mr. David C. Frydenlund
Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) Corp. (DUSA)
Independence Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
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RE: APR(L,2009 DUDA OP AND MAINTNCE- CONDITIONA APPRV LTR
DATE: APRIL 8, 2010/DH.
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MR DAVID C FRYDENLUND
VICE PRESIDENT AND GENERAL COUNSEL
DENISON MINES (USA( CORP (DUSA)
1050 17TH STREET STE 950
DENVER CO 80265
SUBJECT; April, 2009 DUDA Operations and Maintenance Plan Chloroform Pumping Syslem,
Chlorofonn Contamination Investigation, White Mesa Uranium Mill, - Conditional
Approval Letter
Dear Mr. Landau:
The Division OfRadiation Control (hereafter 'DRC") has reviewed the April 2009 Operations and
Maintenance Plan Chloroform Pumping System at the White Mesa Uranium Mill that was submitted to
DRC by DUSA May 4, 2009 (hereafter *'Plan"). The submitted Plan is in response to a ConFirmatory
Action Letter issued by DRC dated April 14, 2009. Based on our review the Plan is conditionally
approved with the following modifications:
1. Item 4 in the Winterization For Long-Term Operations section ofthe Plan needs to be
modified with the following wording changes (modifications are underlined and delefions are
strikelhrough):
'The proiective features, discharge line placement and winter inspections described in items
1), 2) and 3) above will apply to not only lhef4) {5} pumping wells currently in operation, but
will apply also to any future pumping wells associated with the chloroform pumping system."
2. The following parts ofthe Operations section of the Plan need tobe removed:
• The 3'^ paragraph in the Operations section.
• Item 1 "Background'", in the Operations section.
• Item 2 "Quaiterly Water Levels", in the Operaiions section.
• Item 3 "Proposed Water Level Targets" in the Operations section.
Instead, the definitions and performance standards for overall function ofthe chloroform pump
and treat sy.stem to hydraulically contain and control the groundwater contaminant plume
IfiS North l')50 West • Salt Uke Ciiv, UT
Mailing Addrcis: P.O. Box I44S50 • Sair Lake Cify. UT K4 ? I4-IS50
Telephone [phone] • Fax (HIH) 5:ii-40q7 -TDD. (801) 5.16 4414
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Printed on IOO* reLvrled |>;iper
Page 2
needs to be left lo the final Corrective Action Plan (CAP). The DRC recognizes your August
21, 2007 submittal ofa preliminary CAP, which is currently under review. DRC comments on
that document will be forthcoming shortly.
3. The Maintenance section ofthe Plan (modificalions are underlined and deletions are
strikethrough):
When a system failure occurs and is not repaired and fullv made operational within 24 hours of
discovery DUSA shall call the Executive Secretarv to verballv report the svstem failure AU
nystcm ropairs will bo completed within 2A hours of said discovory and will be reported to the
Executive Secretary in a written report within 5 days ofthe failure. Said written failure report
shall contain the following information:
a) A description of the pumping system failure(s) and their root causefs)
b) The period of lime that the pumping system was not or will not be in operation
c) The date by which the pumping svstem will be repaired and fully operational
d) Steps taken or lhat will be taken to repair and make the pumping system fully operational
e) Steps taken or that will betaken to eliminate, and ef prevent reoccurrence of pumping
system failure(s)
f) Each system failure and corrective actions, listed above, will be summarized in the
corresponding quarterly chloroform groundwater moniloring reports
In addition, all system failures will be reported in the followine quarterly chloroform
groundwater monitoring report.
4. At the end ofthe Introduction section ofthe Plan the following wording needs to be added;
"This operations and maintenance plan is required for all pumping wells approved by lhe
Executive Sectary associated with the chloroform pumping system."
In our conference call on April 7, 2010 it was agreed that within 30 days of the receipt of this
letter DUSA would provide, in electronic PDF format, both a final copy of the Plan and a copy of
the Plan in redline strikeout format showing the above modificafions requested. If this was not
your understanding please respond in writing with in three (3) calendar days of receiving this
letter. Thank you for your cooperation in this matter. If you have any quesfions call Dean
Henderson at 1-801-536-0046.
UTAH WATER QUALITY BOARD
DaneLFineiffrock
Co-Executive Secretary
DCH:dh