DRC-2011-001233 - 0901a068801f7022

Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
January 21,2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp (DUSA)
1050 17* Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: January 10, 2011 DUSA Letter, Transmits Revised DMT and BAT O&M Plans, which
addresses White Mesa Uranium Mill Tailings Cell 4B, etc.; January 6, 2011 DRC Letter,
Review of DMT and BAT O&M Plans; Cell 4A and 4B BAT Monitoring, Operafions and
Maintenance Plan (O&M Plan): Request for Information
We have reviewed the subject letter from DUSA dated January 10, 2011, which is a response to the subject
DRC comment letter of January 6, 2011. The DUSA letter proposes the two subject documents, noted
above. However, this letter only addresses the proposed O&M Plan, as revised, known as The Cell 4A and
Cell 4B BAT Monitoring, Operations and Maintenance Plan, 01/2011 Revision Denison 2.1.
After review of this plan, we have the following comments with reference to the submitted redline copy:
1. On page 14, there is a proposed redlined phrase in the sentence beginning with, "Each pump is
equipped with a pressure sensing transducer...," in redline it states, "for Cell 4A and 3 inches for
Ceil 4B)." The "3 inches" must be changed to "2-1/4 inches (0.19 feet)," or other acceptable
measurement.
2. We earlier provided this request as comment VII of our January 6, 2011 letter, regarding freeboard
calculations. DUSA has chosen to propose this O&M Plan, as if Cell 4B was approved for use.
a. Therefore, the secfion beginning on page 15, titled "Cell 4A Solufion Freeboard Calculafion,"
needs to be re-titled to "Solution Freeboard Calculations," (as this section provides freeboard
calculafions for Cell 1 and 4B) or another acceptable fitle.
b. The last sentence of this secfion, on page 17 needs to delete the reference to Cell 4A.
3. On page 5, paragraph d.2, there is a proposed redline change. The 18-inch diameter (proposed to
be deleted) is correct in accordance with the CQA Report record drawings, and must be retained.
The redline change proposed, i.e. a 2-foot inside diameter pipe is incorrect, and should be
removed.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O.Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone]-Fax [phone]'T.D.D. [phone]
www. deq. utah.gov
Printed on J 00% recycled paper
Ms. Jo Ann Tischler
Page 2
Please review the above comments, and respond in writing, submitfing corresponding complete revised
copies of the subject O&M Plan, given a new and unique version number. DUSA's response time on these
types of letters is left to DUSA's discrefion, in as much as the approval of the O&M Plan is a requirement
for a DRC authorization for use of Cell 4B. If you have any quesfions on the above, please contact me.
Sincerely,
/CAV ^''^XTf '
David A. Rupp, P.E/*^
Geotechnical Services Section
DAR:dr
Cc: Mr. Harold Roberts, DUSA
F:\0&M Plan History\RFI 01-21-2011.doc