DRC-2011-007806 - 0901a068802a76f5

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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
December 22, 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: July 11, 2011 DUSA Letter, Transmittal of Revised Discharge Minimization Technology
(DMT) and Cell 4A and 4B Best Available Technology (BAT O&M) Plans; July 14, 2011
DUSA Ground Water Discharge Permit UGW370004; June 23, 2011 DUSA Letter,
Transmitting a Proposed DMT Plan; December 14, 2011 DRC Request for Information on
a Confirmatory Action Letter; Combined Comments on Proposed DMT Plan Versions
This letter provides combined comments by the Division of Radiation Control (DRC) on two separately
proposed White Mesa Mill Tailings Management System and Discharge Minimization Technology (DMT)
Monitoring Plan (DMT Plan) versions submitted by DUSA. The two separate DMT Plans proposed are
referenced below:
A. White Mesa Mill Tailings Management System and Discharge Minimization Technology (DMT)
Monitoring Plan (DMT Plan), version 06/11 Revision: Denison 11.2, transmitted by a DUSA June
23,2011 letter.
B. DMT Plan, version 07/11 Revision: Denison 11.3, transmitted by a DUSA July 11, 2011 letter.
Reference (A) was provided, but DRC review was defened by DRC letter dated October 17, 2011. An
earlier DRC comment letter of June 13, 2011 requested additions to the DMT Plan monthly inspection
form for the specific inspection of the movement monitors. After review, it appears the proposed changes
to the monthly movement monitor inspection form are adequate.
Reference (B) was provided in response to Part I.H.7 of DUSA's July 14, 2011 Ground Water Discharge
Permit. The Permit required modifications to the DMT Plan and the Cell 4A and Cell 4B BAT O&M Plan
(BAT O&M Plan) be submitted for Executive Secretary approval. A separate letter from DRC addresses
the proposed BAT O&M Plan changes.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Ms. Jo Ann Tischler
Page 3
DUSA is concurrently preparing to submit a new DMT Plan in response to a separate DRC Letter dated
December 14, 2011. DUSA's response to the DRC December 14, 2011 letter also requires other
information and commitments from DUSA, separate from the DMT Plan.
We request that DUSA review and respond in writing to the above,, including in that response a full
response to the DRC letter of December 14, 2011. This response must include all appropriate adjustments
in a new version of the DMT Plan, with a unique version number.
In your telephone conversation with Mr. Rupp on December 21, 2011 on this subject, you agreed that
DUSA will fully respond to this letter on or before January 30, 2012. The original deadline for DUSA's
response to the DRC December 14, 2011 letter is also hereby extended to that date.
If you have any questions on the above, please contact Mr. Rupp.
UTAH RADIATION CONTROL BOARD
Rusty Lundberg, Executive Secretary ^
RL/DAR
Cc: Harold R. Roberts, DUSA
Russell Topham, DRC
F:\DUSA\GWDPermit\DMT Plan History\DMT Plan Progress on RevisCmtsl2-20n.docx
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RE: 12/22/il ; combined comments /fiAR^^^
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
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