DRC-2010-005242 - 0901a068801c6d8a

State of Utah
GARY R. HERBERT
Governor
GREG BELL
LieuienanI Governor
Department of
Environmental Quality
Amanda Smith
E.xecuiive Direcior
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2010-Q052AE
September 23,2010
CERTIFIED MAIL
(Retum Receipt Requested)
I
•
Ms. Jo Ann Tischler ;
Director, Compliance and Permitting
Denison Mines (USA) Coip. (DUSA)
1050 17'^ Street, Ste. 950
Denver, CO 80225
Dear Ms. Tischler:
SUBJECT: August 19, 2010 DUSA Response Letter to June 16, 2010 DRC Request for
Information; June 29, 2010 Submittal Reclamation Plan 3.2 and Updated Surety;
March 3, 2010 DUSA Letter, 2010 Surety Update; Request for Information
We received the subject letter from DUSA dated August 19, 2010 regarding the surety update.
We have reviewed this information and have the comments, listed below. These comments follow
the same numerical foiTnat as the most recent letter:
1. Equipment Maintenance Hourly Rate. The fixed monthly equipment maintenance cost
of $65,430 provided by North Central Rental and Leasing (NCRL) is exclusively for
the machinery rented from NCRL. Other equipment sources, such as Honnen
Equipment or WWR Rental are not covered by this monthly fixed cost. This was
confirmed in a telephone conversation between Messrs. Oscar Swenson of NCRL and
David Rupp of DRC on September 14, 2010.
Therefore, it is appropriate to divide the NCRL monthly fee only by the total hours of
NCRL monthly equipment operation to derive an hourly maintenance rate for the
NCRL equipment. For the maintenance costs from the other equipment sources, we
would be willing to accept the foregoing derived rate for NCRL maintenance extended
to that equipment. DUSA may also propose other additional documented equipment
maintenance rates for the other equipment sources. Please adjust the estimate to
include this change in costs for equipment maintenance.
2. No comment.
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]
H'iviv.fieq.utah.^oy
Printed on 100% recycled paper
Page 2
3. Automobile and General Liability Insurance. The DUSA response generally satisfies
our comment. Additionally, we request that on the cost summary sheet the related line
item be shown as "Motor Vehicles and General Liability Insurance" or similar
wording.
4. Reclamation Costs for the New Reagent Storage Building (NRSB). The DUSA
response indicates the NRSB has been added to the table for Altemate Feed Circuit
Costs. This table has been provided, but there are some inconsistencies needing
coirection:
a. The Haul Truck hours remained the same, but it appears they should be increased,
as the loader and truck driver hours, as well as the area of concrete to be removed
were increased.
b. The increased hours for loader and truck driver were only for 2-hours each. Please
correct or justify this as appropriate for the complete NRSB inventory, structure
and concrete removal work.
c. The Equipment Maintenance unit cost per hour in the costs in the table provided
appears erroneous, and needs to be corrected along with the above items.
5. No further comment.
6. No comment.
7. This is a new item. Updated surety estimates were submitted by DUSA letters dated
June 29, 2010 and August 19, 2010. We have a question on the Cell 4A full surface
area used in the fill calculations presented by these submittals. In the July 2009 and
March 3, 2010 DUSA surety estimates, the full surface area for Cell 4A has been
presented as 1,829,520 square feet. In the latest estimates mentioned above, that ai^ea
is presented as 1,785,960 square feet. Please justify the lower figure or provide
coiTesponding corrections to the estimate.
Please review the above comments, and submit the requested information, including a final
summary of the adjusted costs. Per your email on September 20, 2010, you committed that
DUSA would fully respond to the above within 30-days of receipt. If you have any questions on
the above, please contact me.
Sincerely,
•• •' / ' A-
David A. Rupp, P.E. I
Geotechnical Services Section
DAR:dr
F:\drupp\wp\ 1UC\ Surety\2010\RF12 09-2010.doc