DRC-2011-001049 - 0901a068801f2d4c

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Govenior
January 12, 2011
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2011-001049
GERTIFIEDMAIL
(Retum Receipt Requested) I
'(
: .• I. •;
Ms. Jo Ann Tischler •
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA) |
1050 17* Street, Ste. 950 i
Denver, CO 80225
Dear Ms. Tischler:
SUBJECT: December 20, 2010 DUSA Response to Request for Information regarding Reclamation
Plan, Submittal of Reclamation Plan Revision 3.2A; November 30, 2010 DRC Comment
Letter; Request for Information
We received a DUSA letter dated December 20, 2010 on the subject, which submits the White Mesa Mill
Reclamation Plan Revision 3.2A. It appears the majority of Rev. 3.2A was also transmitted by two emails
from DUSA dated December 20, 2010. The subject DUSA letter was sent in response to our comment
letter of November 30, 2010.
We have reviewed the subject DUSA submittal and have the following comments and requests:
1. Our letter of November 30, 2010, paragraph 3, stated that, "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..."
Recap:
The referenced Figure A-5.1-2 in Reclamation Plan Rev. 3.1 (labeled on the figure to
include drawings through Rev. No. 4 dated July 9, 2008), provides Section A-A' and
Details 1 through 3. The figure is titled, "...Reclamation Cover Details and Cross
Section."
In contrast, Reclamation Plan Rev. 3.2 provided a Figure A-5.1-2 titled, "Reclamation
Cover and Cross Sections..." This figure provided Sections B-B', C-C, and D-D'. Not
the same sections or details as Rev. 3.1. As stated in DUSA's letter of June 29, 2010, it
appeared that this figure was provided as a "replacements for" the figure of the same figure
number. However, the latter Figure A-5.1-2 (Rev. 3.2) does not contain any of the
drawings provided in the earlier Rev. 3.1 figure of the same name. Therefore, to keep the
195 North 1950 West-Salt Uke City, UT [
Mailing Address: P.O. Box 144850 • Salt Lalce City, UT 84114-4850
Telephone [phone] • Fax [phone] -T.D.D. [phone]
www.deij.uinh.f^ov . .
Pnnted on 100% recycled paper
Page 2
original drawing concepts provided on Figure A-5.1-2 (Rev. 3.1), DRC requested that the,
"existing Figure A-5.1-2 must somehow be retained and not replaced by the Addendum..."
Comment:
After receipt of the subject letter of December 20, 2010, we have compared the submitted
figures in Rev. 3.2A with the corresponding previous figures in Rev. 3.1. It appears that
proposed Figures A-5.1-2 and A-5.1-3 are not the same as the Rev. 3.1 figures ofthe same
number. Also, some correction to the drawings is needed.
In as much as these figures are to replace the corresponding figures of the same number as
part of a formal addendum, we request you please correct the following:
a. Correct a transposition of figure numbers by changing the figure numbers
proposed as Figures A-5.1-2 and A-5.1-3 in Rev. 3.2A to correspond to the figures
of the same number from Rev. 3.1.
b. Section D-D' needs to be revised to include the addition of Cell 4B.
2. In Rev. 3.2A, Appendix G, a technical memorandum from MWH dated January 29, 2010 is
provided. This gives the design justification for the 6-inch thick filter blanket on cell outside
slopes of the cells. This memo was not provided in the subject Emails sent. This item must be
provided in electronic format as well as the paper copy ofthe Reclamation Plan.
3. In our letter of November 30, 2010, we requested 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." However, the subject DUSA December 20, 2010 letter
describes Rev. 3.2A is an addendum to proposed Rev. 3.2. This designation will lead to
confusion, which must be avoided. Please revise the plan's cover, text and transmittal letter to
show that the next version, e.g. Rev. 3.2B, is an addendum to Rev. 3.0 and Rev.. 3.1 (which
have already been approved by the DRC). Rev. 3.2B needs to be complete, and not rely on the
previous Rev. 3.2 or 3.2A addendums.
a. In response to our letter mentioned above, the DUSA letter of December 20, 2010 provides
a replacement cover, which states, "Addendum/Changed Pages for the White Mesa Mill
and Tailings Management System." However, the Reclamation Plan addendum cover
needs to be edited to be explicit and accurate as to what the addendum applies to in
accordance with the above paragraph.
b. Also, the text of the Reclamation Plan addendum (Rev. 3.2A) does not address this point,
as requested in the mentioned DRC letter. A separate preface page in the addendum may
be an appropriate method to address our request.
c. Please assure that Rev. 3.2B is complete, and does not rely on the previous Rev. 3.2 or
3.2A addendums.
4. The upcoming revised edition of the Reclamation Plan Revision 3.2 (i.e. a revision ofthe
Addendum) will need to be identified by a unique edition name, but still retain the
Reclamation Plan Revision 3.2 label, e.g. "Edition B," or other method for identifying the
unique edition.
5. We recognize that in the process of DRC review and DUSA response that identification needs
will require designation of editions or versions such as B, C, etc. However, we request that
when the final revision is ready for approval that DUSA submit a final document labeled as
Rev. 3.2-final.
Page 3
Please review the above comments, and respond in writing including an electronic copy, by submitting|a
unique revised edition of Reclamation Plan Revision 3.2 for approval. Please assure that the electronic^ and
paper copies agree in content. DUSA's response time on this letter is left to DUSA's discretion, in as '
much as the approval of Reclamation Plan Rev. 3.2 is a License Condition for DRC authorization fpr use
of Cell 4B. If you have any questions on the above, please contact me.
Sincerely,
Davirt t-David A. Rupp, P.E.
Geotechnical Services Section
LBM:DAR:dr
Cc: Harold R. Roberts, V.P. US Operations
F:\drupp\DUSA\RP3.2AJan-2011.doc