DRC-2011-002863 - 0901a068802120ed

State ofUtah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADJATION CONTROL
Rusty Lundberg
Director
March 17, 2011
CERTIFIED MAIL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
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RE: 3/17/11; 11 /15/11 annual technical evalu
comments and RFI / DAR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST. STE 950
Denver, Co 80265
'PS(Form;3800: AugLJS!;2b05 See Reverse for Instructions..
SUBJECT: November 15, 2010 Annual Technical Evaluation ofthe White Mesa Mill Tailings
Management System [The Annual Technical Evaluation Report (ATER)];
Comments and Request for Information
We received the latest subject report dated November 15, 2010. This annual technical evaluation report
(ATER) is submitted in accordance with the requirements of the DUSA Radioactive Materials License and
the White Mesa MiU Tailings Management System and Discharge Minimization Technology (DMT)
Monitoring Plan.
License Condition 12.3 states that, "...the licensee shall submit an ATER for Executive Secretary approval
no later than November 15, of each year, to coincide with the annual freeboard calculation date of
November 1st of each year when using the new Freeboard Calculation Method.. .Each ATER shall
incorporate all documents and attachments, including applicable updates to previously submitted
documents with attachments that support information presented in the ATER, including, but not limited to
maps, drawings, tables, and figures. The licensee shall include, as part of the ATER, results of tailings cell
temporary cover settlement and dike displacement monitoring activities. The content ofthe tailings cell
temporary cover settlement and displacement monitoring program related information shall include those
records required under the Settlement Monitoring and Movement Monitoring SOPs (License Conditions
11.7 and 11.8), as approved by the Executive Secretary."
Although the new calculation method to determine freeboard is discussed in License Condition
12.3 above, the new method for this calculation was not approved until the most recent DMT Plan
approval, which was by a DRC letter dated January 20, 2011. Hence, the November 15, 2010
DUSA ATER did not include the new calculation method. However, we expect that the new
method will be included in the November 2011 ATER.
Similarly, although new SOPs for Settlement and Movement Monitors are discussed in the License
Conditions mentioned above, the proposed procedures (SOPs) for such were somewhat recently
submitted for DRC review via DUSA letter dated December 1, 2010. We anticipate that these
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Page 2
SOPs will be reviewed in the near future, and after approval will be incorporated in the upcoming
November 2011 ATER.
The subject November 15, 2010 ATER has been reviewed, and we have the following comments:
1. Regarding movement monitors, on page 8 of the ATER, the last sentence of the first
paragraph states that, "Upon completion of the south Cell 4B dike it will become the new
boundary and will have movement monuments installed." Our follow-up question to this
statement is when will the installation of-these be complete, and the initial survey
measurements made?
2. Under the Site Photographs tab of the ATER, photo 16 shows tree-like plants growing on
the interim cover of Cell 2. These tree-like plants must be removed and any associated
damage to the interim cover on Cell 2 repaired. Please provide a deadline for completion
of this removal and repair work.
3. Photo No. 28 shows soil on the south embankment of the Cell 4B dike that appears to be
not compacted. Please justify why this soil is not compacted, or alternatively provide a
schedule for completion of grading and compaction of such.
4. Under the tab in the subject ATER for Inspection Reports, we note that during a period of
no pumping, there were negative changes in the Cell 4A LDS sump depths (by a few
inches) reported during December 2009. The same is noted on the monthly summary tab
for December 26, 2009. Does this behavior continue to be observed? Please explain and
justify the root cause of this phenomenon of negative changes in the levels in Cell 4A LDS
sump during periods of non-pumping.
5. A map, showing the 17 proposed Settlement Monitors, was provided to DRC earlier by
DUSA letter dated April 23, 2010. In this same letter it states that, "Subsequent to the
2009 ATER, Settlement Monitor 2W5-S has been installed. The Settlement Monitor map
will be updated for the 2010 ATER and the monitoring data will be included in the report."
Under the tab for Settlement Monitors, review of the November 15, 2011 ATER shows
that the Cell 2 settlement stand 2W5-S was installed, and that survey data for this stand
was reported, commencing on April 30, 2010. Unfortunately, the map on the last page
under this tab has not been updated, and shows Settlement Monitor 2W5-S as "proposed."
Please update the Settlement Monitor map with all new Settlement Monitors which have
been installed to date and submit a current and representative version for Executive
Secretary review and approval. Please be advised that License Condition 12.3 requires
DUSA to submit supporting information that is current and up to date.
In order to ensure future compliance with this requirement, please make certain that all
supporting information, figures, maps, tables, and figures, etc. are complete and current in
all upcoming ATER submittals.
*Effective June 17, 2010 License Condition 12.3 states that, ". ..Each ATER shall incorporate all documents and
attachments, including applicable updates to previously submitted documents with attachments that support
information presented in the ATER, including, but not iimited to maps, drawings, tables, and figures."
Page 3
6. For reference, we note the following:
a. The slimes drain pump breaker tripping-off is noted often in weekly summaries.
b. Exposure of Cell 1 liner is noted often in the January-March 2010 weekly
reports.
c. On 02-08-10 the SX slurry blew an end cap at the SE comer of Cell 1.
d. The June 2010 monthly summary logs the volume of pumping from the Cell 1
leakage.
Please review the above notes and comments and respond in writing, furnishing the applicable information
requested as an amendment to the subject ATER. In an email sent from you on March 16, 2011, you
agreed to respond fully to this letter within 30 days of receipt. Please contact me if you have any
questions.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR: dr
FAATER\20I0\Cmtl.doc