DRC-2011-005590 - 0901a0688022e592

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director C-2011-005590
May 10, 2011
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. David C. Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth St. Suite 950
Denver, Colorado, 80265
Subject: September 22, 2010 Conditional Approval and Confirmatory Action Letter for the
Denison Mines (USA) [DUSA] White Mesa Uranium Mill - Plan and Schedule for Cell
1 Inspection and Repairs - Revised Confirmatory Action Letter
Dear Mr. Frydenlund:
The September 22, 2010 Confirmatory Action Letter required DUSA to perform a video log ofthe
Tailings Cell 1 Leak Detection System (LDS). If any debris was observed within the standpipe, it
was to be removed and a confirmation video log would be performed to show the debris had been
removed from the standpipe. DUSA submitted video logs of both the Cell 1 and 3 standpipes on
December 27, 2010. The DRC reviewed both video logs requested a meeting by e-mail on March
31, 2011 to discuss its findings. The DRC discussed its findings with DUSA in an April 28, 2011
conference call. The DRC findings were as follows:
1. On August 10, 2010 DUSA added a 6-foot extension to the Cell 1 LDS standpipe. This
extension raised the standpipe off the ground surface, which should prevent stormwater
and debris from falling into the standpipe in the future. An extension must also be added
to the Cell 3 standpipe to prevent stormwater and debris entry. This extension does
not need to be 6 feet long, per say, but it does need to be sufficiently above the
ground surface to prevent entry of stormwater and debris.
2. Both the Cells 1 and 3 standpipes must also have an attached cap/cover to the standpipes,
which will also prevent debris from falling into the standpipe and will provide security.
3. It is critical that the LDS monitoring equipment/practice be able to physically reach the
bottom of the standpipe for the detection of fluid. The outcome of the video logs at the
Cells 1 and 3 LDS demonstrates the historic equipment and practice (blowpipe rnethod to
195 North 1950 West • Salt Uke City, UT
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measure depth of fluid level) are unacceptable, and have not generated reliable and
representative monitoring information.
4. Because the blowpipe method is not a reliable and representative detection method. This
method needs to be replaced with a more modem, reliable technique and equipment.
DUSA claimed in the April 28, 2011 conference call that they had added an extension to the
Tailings Cell 3 standpipe and that both the Cell 1 and Cell 3 standpipes have an attached cover.
The DRC asked that DUSA provide pictures that documents the new standpipe extension and
covers.
DUSA also proposed a new monitoring equipment and technique for the Cell 1 and Cell 3 LDS.
DUSA committed to provide a plan and schedule for this new monitoring equipment to the
Executive Secretary on or before June 1, 2011.
Confirmatory Action
During the April 28, 2011 conference call, DUSA committed to doing the following on or before
June 1,2011:
1. Submit pictures of the Tailings Cell 3 standpipe extension and the Cells 1 and 3 standpipe
covers.
2. Provide a plan and schedule to replace the current leak detection method and equipment at
the Cells 1 and 3 LDS standpipes.
This CAL does not replace the September 22,2010 CAL. Please respond in writing within three
calendar days of receipt of this letter if you disagree with the above agreed upon resolution or
compliance schedule.
Thank you for your continued cooperation.
UTAH WATER QUALITY BOARD
Rusty LundbVrg (J
Co-Executive Secretary
RL/PRG:prg