DRC-2010-006141 - 0901a068801e3cdd

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Department of
Environmental Quality Amanda Smiih
E.\c'ctin\'c' Dirt'ctor
DIVISION OF RADIATION CONTROL
Rusty Lundhcrg
Dirciior
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State of Utah
GARY R. HERBERT
Govenior
GREG BELL
Lifiileiinni Govenuir
November 30, 2010
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischier
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 17"" Street, Ste. 950
Denver, CO 80225
Dear Ms. Tischier:
SUBJECT: June 29, 2010 DUSA Submittal of Revision 3.2 of White Mesa Mill Reclamation Plan,
Submitted in the form of an Addendum to Approved Reclamation Plan Revision 3.1;
Utah RAM License No. UTI900479, Condition 9.11; Request for Information
We received the subject proposed Revision 3.2 of the Reclamation Plan (the Plan) via your cover letter
dated June 29, 2010. As described in the letter, this revision was submitted in the form of an Addendum to
existing approved Reclamation Plan 3.1. The purpose of Revision 3.2 was to provide closure design for
the facility, including Tailings Cell 4B. We have reviewed subject Reclamation Plan Revision 3.2, and
have the following comments:
1. The Table of Contents for the Plan needs to be adjusted as a consequence of the subject
Addendum to the existing Reclamation Plan.
2. On page 1-1 of the redline copy, please retain the last sentence of the second full paragraph
and the list of the facilities to be decommissioned on pages 1-1 through 1-2.
3. Existing Figure A-5.1-2 in approved Revision 3.1 appears to contain cross sections and details
which are essential to be retained in the Reclamation Plan.
a. Therefore, existing Figure A-5.1 -2 must somehow be retained and not replaced by the
Addendum.
b. In other elements of the Plan, the existing Figure A-5.1-2, and Figure A-5.1-4 in the
existing plan need to include, as appropriate, the design as well as the associated drawings
for a sub rip-rap tailings filter blanket.
4. In accordance with the subject License Condition 9.11, the Plan needs to describe the use of
new permanent fixtures or facilities that have been installed or are contemplated to be
constructed in conjunction with the reclamation of Cells 4A and 48. We suggest this be
accomplished by referencing the specific as-built drawings, DMT, and BAT O&M Plans for
these facilities.
195 North 1950 West • .Salt Lake Cily. UT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fa.x [phone] • T.D.D. [phone]
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Ms. Jo Ann Tischier
Page 2
5. Existing Figure 3.2.3-1 is contained in Reclamation Plan 3.1. This figure is a site map ofthe
mill and ore pad. However, the figure does not reference the distinct boundaries of the ore
storage pad as provided by a map in the DMT Plan, and as defined by coordinates in Part
I.D.3.f of the Ground Water Discharge Permit. Please incorporate these references in the Plan,
or adjust the figure appropriately to include these boundaries.
6. We request that the cover and the text of Reclamation Plan be revised to state that Reclamation
Plan Revision 3.2 is in the form of an Addendum to Reclamation Plan 3.0 and 3.1.
7. Attachment C to the subject Plan included a revised surety estimate that is out-dated. We
acknowledge more recent surety cost estimates provided by DUSA on March 3, August 19,
and October 15, 2010. We have also most recently asked DUSA to modify its 2010 surety
estimate in a November 16, 2010 Request for Information letter. Therefore, please be advised
that any future DRC approval of Revision 3.2 will not include any approval ofthe existing
Attachment C.
8. The revised Plan edition of Reclamation Plan Revision 3.2 (i.e. the Addendum) will need to be
identified by a unique edition name, but still retain the Reclamation Plan Revision 3.2 label,
e.g. "Edition A," or other method for identifying the unique edition.
Please review the above comments, and respond in writing submitting a unique revised edition of
Reclamation Plan Revision 3.2 for approval. Per my telephone conversation with Mr. Harold Roberts of
DUSA on November 30, 2010, he committed that DUSA will fully respond to the above within 15
calendar-days of receipt of this letter. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
F:\drupp\DUSA\RP3.2RFM ll-2010.doc