DRC-2010-006101 - 0901a068801e13d9

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State of Utah
GARY R. HERBERT
GREG BELL
Lieitrendiil Guvcnior
Department of
Environmental Quality
Amiindii Smith
K.xcu lUiic Dircrltfr
DIVISION OF RADIATION CONTROL
Ru.sly Liindherg
Dircciiir
DRC-2010-006101
November 24, 2010
Certified Mail
(Return Receipt Requested)
Mr. Harold R. Roberts
Vice President, US Operations
Denison Mines (USA) Corp (DUSA)
1050 17"'Street, Suite 950
Denver, CO 80265
Dear Mr. Roberts:
SUBJECT: Denison Mines (USA) Corporation (DUSA) While Mesa Mill Facility
DRC Cell 4B Construction Inspection November 22-23, 2010
Observations and Discussions
On November 22 and 23, 2010 I visited the subject construction site and had several observations and
discussions, as noted below. In general the work appears to be nearly complete. It appeared that the
majority of the physical work remaining is the placement of slimes strip-drains as herring bones to the
slimes drain header, and the covering of such with suitable sand bags in an acceptable manner.
Persons Contacted During the Inspection: Steve Snyder, Ryan Palmer, David Turk, and Rich Bartlett of
DUSA; Mike Beeman, a superintendent with AEGL Construction, and his foremen Reuben and Vince;
Mike Carlson and Victor Heredia of GeoSyntec.
1. Strip Drain Sandbags in Cell 4B. I observed the work of placing newly filled sand bags on the
strip drains. It appears now, i.e. for about 80% of the total strip-drain area, that new larger sand
bags are planned to be used to cover the strip drains. At the time of the inspection, unacceptably
low sand volume bags were being emptied and the sand put into the new larger bags to cover the
strip drains. In addition it was agreed that some existing sand bags with adequate volume to
conform to the plans and specifications will be reshaped and re-placed on the strip drains. It
appeared the strip-drains and sandbag installation and re-placement work, in total, is roughly 60%
complete. Some of the AEGL workers are still learning how to butt the sand bags side to side
without gapping or overlapping them. It was apparent that the foremen and the GeoSyntec
inspectors are making progress teaching them this.
During the inspection, Mr. Carlson of GeoSyntec stated that each individual line of strip-drain and
sandbag cover will be reviewed, corrected as needed, and separately documented. An individual
record for each strip-drain will be made. DRC staff will look for these records during review of
the upcoming As-Built Report.
IQS North 1950 West • Salt Lake {^ity. UT
Mailing .Address: P.O. Box 144850 • .Sail Uke ('ity. UT 84114-4850
Telephone (80)) 5.16-4250 • F;ix (801) 5.Vi-4007 • T.D D. (801) 5-'''6-4414
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Page 2
2. The Slimes Drain Windrow Header. In a few locations, it was observed that the wind and water
have displaced the woven geotextile material on the slimes drain windrow header. These areas
need to be repaired before any final DRC construction inspection. Additional sand bags on the
side flaps of the geotextile windrow, i.e. more than the specified 1 bag per 10-feet. appear to be
needed to stabilize the header cover material. I was assured by the contractor and GeoSyntec that
this would be done shortly.
3. Project Certification. Mike Carlson of GeoSyntec mentioned that a certification of the
construction project will be provided to DRC to affirm that it confoms to the approved plans and
specifications. He mentioned that the certification may have stipulations, regarding the
uncompleted sand bag and strip-drain work. DRC will consider any impact these stipulations may
have during DRC review of the final As-Built Report.
4. Project Completion Report Photographs. Mike Carlson also mentioned that the as-built or project
completion report will include photos of the construction work. I requested the photos in the report
include photos of the sand bag work and the slimes drain windrow header repairs mentioned
above. These photos should include some photos of the entire header, some header segments, and
at least 2 photos per strip-drain Hne that demonstrate the depth measurement of the sand bags.
Individual photographs will need, to be labeled with date stamps and descriptions on all photos.
On an earlier visit, Mr. Turk of DUSA and I discussed that the original drawings, sheet 2, called
for 4 feet of excavated soils from Cell 4B to be placed on the east side of tailings Cell 3. At the
time of the inspection, Mr. Turk noted that this was not done. However, some excavated soils
were placed on the west side of Cell 3. It is recommended that this change from the original plans
will need to be included on the as-built drawings.
5. Cell 4B BAT O&M Plan. In addition to the above, the Utah Division of Radiation Control will
need to approve a Cell 4B BAT O&M Plan before authorizing use of Cell 4B. I suggested that to
avoid unforeseen delays that the Radioactive Materials License and the Ground Water Discharge
Permit should also be reviewed, to assure that all requirements for Cell 4B use are fulfilled prior to
the time needed.
If you have any questions on the above, please contact me.
/ /
Sinci^rely,
David A. Rupp, P.E.
Geotechnical Services S"ec
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F:\ren 4B\Constr\Obsrvns &L Discussions 11-22-2,^. 20IO.doc