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HomeMy WebLinkAboutDRC-2011-007118 - 0901a06880257a5cOEMiSON MIMES August 1,2011 Denison Mines (USA) Corp. 1050 17th Street, Suite 950 Denver, CO 80265 USA Tel: 303 628-7798 Fax:303 389-4125 www.denisonmines.com VIA PDF AND FEDERAL EXPRESS Mr. Rusty Lundberg Executive Secretary Utah Division of Radiation Control Utah Department of Environmental Quality 195 North 1950 West Salt Lake City, UT 84116-3097 Re: White Mesa Mill Cell 2 Slimes Drain Compliance - Confirmation of Completed Steps from June 17, 2011 Plan Letter This letter provides confirmation of the actions committed to during discussions in Denison Mines (USA) Corp.'s ("Denison's") conference call with Utah Division of Radiation Control ("DRC") on May 25, 2011 and in a in June 17, 2011 Status Update letter regarding Cell 2 Annual Slimes Drain Compliance (the "June Status Update" or the "Status Update Letter") at White Mesa Mill. The actions are addressed in this letter in the same order as they were discussed in the Status Update Letter. Re-grading of Interim Fill on Cell 2 The Status Update Letter committed that Denison would re-grade the interim fill on Cell 2 on or before August 1, 2011 in order to reduce the potential for the accumulation of stormwater on the surface of Cell 2, which can potentially infiltrate into Cell 2. Denison believes that the reduction of infiltration by removal of low areas and filling of potential pooling spots will have a positive effect on the slimes drain level. Denison completed filling and regrading of Cell 2 on July 30, 2011. The regrade required 62,000 cubic yards of cut and fill, consisting of alluvial material and/or rock. Drawings of the cell regrading plan are provided in Attachment 1. Photographs of the completed regrading are provided in Attachment 2. N:\Cell 2\08.01.11 Itrto R lundberg Cell 2 completion\08.01.11 Itrto R Lundberg Cell 2 modifications.docx Letter to Mr. Rusty Lundberg August 1,2011 Page 2 Installation of Piezometers As discussed in the Status Update Letter Denison has performed an engineering evaluation of issues related to the feasibility of installation and use of piezometers in Cell 2 for the above purpose. Based upon this further evaluation, Denison does not believe that it is feasible to install and operate peizometers that would provide representative and dependable measure of the slimes drain level for the following reasons. For the reasons stated in the letter, including 1. The likelihood that artesian effects will create piezometer levels inconsistent with slimes drain levels; 2. The fact that no piezometer or collection of piezometers could represent cell-wide conditions; and 3. The high risk of continual plugging Denison has determined that piezometer installation is not feasible in Cell 2 and, as stated in the Status Update Letter, has not installed piezometers. Engineering Evaluation of Pump in Cell 2 Denison performed an engineering evaluation of the current pump in the Cell 2 access pipe to determine if any changes can be made to improve its efficiency and output and has made mechanical changes to the pump configuration and adjustments to the pump operational cycle as discussed below. As discussed in the June Status Letter, the sensor settings (which trigger pump startup) were adjusted from the former 0 feet to 4 feet setting to the current setting of 0 feet to 2 feet. As a result, the pump rate has been slowed sufficiently to allow the pump to cycle on more frequently for a longer time at a narrower range of solution levels, in effect, performing like a smaller pump, as suggested by DRC. This mode of operation has been maintaining as lower slimes drain level based on the increased frequency of pumping. Amendment of the Groundwater Discharge Permit for Reduced Monitoring Frequency Denison has received DRC's June 30, 2011 Draft Statement of Basis Memorandum and Draft amended Groundwater Discharge permit. As agreed upon in a telephone conversation between Denison and DRC during the week of July 25, 2011, Denison will provide comments or proposed markups to the draft documents by August 17, 2011. Please contact me if you have any questions or require any further information. DENISO MINES Letter to Mr. Rusty Lundberg August 1,2011 Page 3 Yours very truly, DENISON MINES (USA) CORP. (^JX/^ ^^^^^^^^^^ Jo Ann Tischler Director, Compliance and Permitting cc: David C. Frydenlund Ron F. Hochstein Harold R. Roberts David E. Turk Kathy A. Weinel DENISOrAi MINES Letter to Mr. Rusty Lundberg August 1,2011 Page 4 ATTACHMENT 1 DENISO MINES I pi 3 a. e s 3 (J OO u T — m <M : . 31 o S iir OOUJ-? a, K 2 ^ lo — J] c |ii •I _ D S 5 I o o IR o 8 S 8 8 o 8 o 5 o 8 CD 8 Ef a V o 9 5 o - o 8 s o G. e 3 8 K: 3 8 ?/ S o X 9 PI 5 1.-, 8 S- ^ J 17 ^1' S = is 5i Ul ii S S S iS S 8 8 lO d 6 o> pi b d o o 5 8 8 5 8 8 S o o '• -- d 1-1 3^ CIS S5 888 d d o a § ^ 3 K M in uS d - o I ff f5 r 88 d d (0 *^ •— Oh d s Ol Q IO •Si o 5 (0 r~ eo o gg d d 88 d d n n n 9 in a. in to d> <\i f^^ S n UJ S 8 1 i I a C 1 Letter to Mr. Rusty Lundberg Auuust 1.2011 Pages AIIACHMI^M: DENISO MINES Cell 2 - Looking Northeast Cell 2 - Looking East »2 Cell 2-Looking East ai Cell 2 - Looking Southeast ffl