DRC-2010-002081 - 0901a0688016e025

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lietitenanr Governor
Department of
Environmental Quality
Amanda Smith
E.ferutive Direr tnr
D[\1SI0N OF RADIATION CONTROL
Dane L. Finerfrock
Diri-fior
DRC-201C-0C2081 February 25. 2009
CERTIFIED MAIL
(Return Receipl Requested)
David C. Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Slreet. Suite 950
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: September 30, 2009 Annual Technical Evaluation of rhe Wliite Mesa MiU Tailings
Management System for the period of August 2008 tiirough July 2009; Utah Radioactive
Materials License No. UT190O479. Amendment 3, (under timely renewal); April 23, 2009,
DRC Closeout Letter with DRC Findings and Request for Improvements to the 2009
ATER Report; October 2L 2008 DRC Comment Letter: Comments and Requesl for
Additional Information
We received the subject report dated September 30, 2009. This annual technical evaluation report (ATER)
is subniitted in accordance with the requirements ofthe subject radioactive materials license. Tiie license
condition 10.3 requires that the "report shall be submitted fur Executive Secretary approval no later than
September L of each year." The date for submittal ofthis ATER was extended to October 1, 2009 by a
DRC Letter dated August 27. 2009.
The U7i;re Mesa Mill Tailings Management Syslem and Discharge Minimization Technology (DMT)
Monitoring Plan as approved by DRC on May 9. 2007 discusses the required contents ofthe ATER report.
According to the Evahiaiion Procedure section in the report, tbe repoit is prepared in accordance with the
White Mesa .Mill (WMM) Environmental Protection Manual.
We have reviewed the suliject ATER, and have the following comments:
1. Settlement Monitoring.
A. In a DUSA letter dated December 30, 2008 regarding the 2007-2008 ATER, DUSA stated,
'The ATER recommended the new settlement monitors to the MilPs management and they
have committed that the new monitors, where needed, will be installed and surveyed as to
locaiion by no later than June 30, 2009." Lt appears the new monitors correspond to the
proposed settlement monitor 2W5-S for Cell 2, and other additional new monitors for the
areas recently covered in Ceil 3.
168 North 1<)50 Wesi-SaliLnkcCiry, HT
Mailing Address: PO. BOK 1448^^0'Salt Lake Ciiiy, HT 84114-4850
Telephone (801).'i?6-425(}'r;iK [phone]-TDD {801)536-4414
M Vv r..ilrij.\iliih.jiiiy
Printed on 100^ recycled p.-iper
David C. Frydenlund
February 25, 2010
Page 2
In this regard, the DRC closeout letter for the 2007-2008 ATER dated April 23, 2009
states, ^'Confirmation of this work must be documented in the 2(K)9 ATER Report. The
designated names of the new settlement monitors locations will need to be unique,
coordinated and updated to be in agreement on various maps and forms, in future Annual
Technical Evaluation Reports (ATERs) as well as the DMT Monitoring Plan. Please
revise these documents as appropriate for submittal in ihe 2009 ATER Report."
Confirmation of this work was not submilted in the subject September 30. 2009 ATER.
Please submit the required confinnation of the new settlement monitor installation work
with corresponding settlement survey tables and graphs.
B. Tn the subject DRC approval letter dated April 23, 2009 we state, "Our previous comment
letters . . . have requested that DUSA carr>' forward all applicable comments into future
ATER Repon subniittals. Please assure that the applicable items above are carried forward
into all future ATER Reports as well."
There is no map of the settlement stands provided. Please provide an updated map of (he
settlement stand system, incorporating all corresponding adjustments from above.
With respect to settlement monitoring, provisions in the license will be added to include
requirements for such monitors to be placed, surveyed, mapped, maintained, analyzed and reported
on. Reporting of such activities will be in the Annual Technical Evaluation Reports (ATERs).
2. Liner Maintenance.
In 2009 a liner damage accident, occurring on May 14. 2009, was reported to DRC by a DUSA
notification letter dated May 19, 2009. Necessary repairs to the liner were documented to DRC by
DUSA email dated June 26. 2009.
In the subject September 30. 2009 ATER, under the monthly summary tab, some of the monthly
inspection tables have entries which indicate liner damage, as follows:
A. For April 6-7. 2009, the monthly inspection summary table notes smidl puncture(s) in the
southwest comer of Cell 4A. The Cell 4A BAT Monitonng, Operations and Maintenance
Plan provides a repair method for damaged liner in Cell 4A.
B. For April 27-May 1, 2009, the corresponding montlily inspection suinmary tables report
that the east bank of Cell 1 has liner being repaired. Liner repair on Cell 1 is to be
accomplished by use of the cunent Liner Maintenance Provisions. \n an etnail received
from you on February 25, 2010, you slated this rcpair site is the same as that documented
in the above paragraph below Liner Maintenance.
Please provide copies of the documentation for the repair and testing for item 2A above, in
accordance with the applicable procedure.
Regarding liner maintenance, provisions in the Ground Water Discharge Pennit will be added
defining reporting requirements for liner repairs beginning with Cells 4A and newer tailings cells.
3. Movement Monitoring.
A. In the subject April 23, 2009 DRC letter it states, "we request DUSA provide the criteria
used for evalualion of monitor movement in the text of the ATER report. Include the
David C. Frydenlund
February 25, 2010
Page 3
conesponding analysis of the most active single grouping of monuments within the ATER
report. Please submit this infomiation for approval."
In the subject September 30, 2009 ATER. page 9, the first paragraph stales that, "The
majority ofthe Cell 4A poinls were disturbed during the Cell re-lining activities and were
re-set in ihe fall of 2008. For these points there is no meaningful comparison back to
previous points."
The remark above appears to refer only to the disturbance movement monitors located on
the dikes of Cell 4A. However, there are also movement monitors on the soulhem dike of
Cell 3. No evaluation was submitted regarding these movement monitors. Please discuss
the use of these monitors for movement evaluation as mentioned in first paragraph given in
3A above.
B. In our subject letter dated April 23, 2(K)9 with respect to the movement monitors we stated,
"Specifically, DRC is asking for the quantitative criteria DUSA uses to evaluate movement
of these monitors, and for such to be printed in the actual text ofthe ATER report."
Continuing on this subject in the above letter, it states, ". .. we are asking for the
upcoming ATER report text to provide this infomiation. DUSA needs to develop
quantitative criteria to evaluate horizontal monitor movement and include this with
evaluation of the most active group of monitors in the text of the annual ATER reports.
This needs to commence with the 2009 report."
The September 30, 2009 ATER makes some reference to quantitative analysis', but the
specific criteria requested is not printed in the text of this report, as requested. We
therefore requesl that DUSA provide the previously requested criteria DUSA uses to
evaluate movement of monitors, and for such to be printed in the actual text of the ATER
report.
The criteria used for evaluation of monitor movement needs to be put into the cunent
ATER text. The criteria musl stand alone. The criteria may be applied whenever valid
movement monitor data is available.
C. The contains a copy of a drawing titled UMETCO Minerals Corporation, Sut^^ey Control
at Wliite Mesa Mill. Blanding, Utah, dated August 27, 1992. The drawing has many
labeled numeric points which are illegible even with a magnifying glass. Please supply a
clear legible copy of this map.
With respect to movement monitoring, provisions in the license will be added to include
requirements for such monitors to be placed, surveyed, mapped, maintained, analyzed and reported
on. Reporting of such activities will be in the Annual Technical Evaluation Reports (ATERs).
In the subject September 30: 2009 ,^TER, page 9. it i^taies. '"None uf the points along the Celt 3 dike or the (wo (2) Cell4A dikes
show any abnormal movement. There is no Irend in ihe Cell 3 or Cell 4A movemeni monitors."
'Survey data provided by Jones and DeniilJc Eneinecrs . . . was reviewed during the evalualion. The current data was compared
lo Ihe previous iwo (2) years dala. Evaluation of the data indicated only very minor movement may have occurred along the Cell 3
dike and the north soulh Cell 4A dike. All the possible movements were within expected and acceptable limits."
David C. Frydenlund
Febniary 25, 2010
Page 4
4. Drainage map.
We received a map drawing titled. Mill Site Drainage Basins, labeled as Figure 1, referenced as
figure 2_l-6-()9.dwg, original date 2005, with latest revision 1/7/09 initialed by BM. This map
appears to contain all map drainage information previously requested. This figure will be reviewed
by other DRC staff for use in upcoming inspections.
5. Carrying Forward Applicable Documents inlo ATER Submittals.
We continue to request that DUSA carry forward all applicable documents into all future ATER
submittals. These documents include, but are not limited to all maps, drawings, tables and graphs.
These documents need lo be updated for the next ATER period.
Wilh respect to carrying forward applicable documents inlo ATER submittals, provisions in the
license will be added lo include requirements carrying forward documents in the ATERs.
Please review the above notes and comments and respond in writing, furnishing the information requested.
In an email sent from you on February 25, 2010, you agreed to respond fully to this letter within 60 days of
receipl. Please contact me ifyou have any questions.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
LBM:DAR: dr
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