DRC-2011-007453 - 0901a06880278911

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-2011-
Phillip Goble - License Renewal License Condition 9.11
From: Phillip Goble
To: Frydenlund, David
Date: 9/14/2011 4:59 PM
Subject: License Renewal License Condition 9.11
CC: Ford, M. Lindsay; Hultquist, John; Johnson, Ryan; Lockhart, Laura; Lundberg, Rusty; Morton, Loren;
Roberts, Harold; Rupp, Dave; Tischler, Jo Ann
Dave,
During a September 1, 2011 meeting, the DRG presented DUSA with three choices regarding cover design requirements
for the White Mesa Uranium Mill. During our meeting today, DUSA chose Option 2 and proposed a change to what
would be required for the ICTM Model Report, i.e. the Report will be limited to an infiltration analysis only.
The DRC disagreed with a reduced version of the ICTM Module Report for the proposed cover design and the Executive
Secretary decided that Option 2 will stand as originally considered with review of a full ICTM Model Report, including
both infiltration and contaminant transport analysis.
As you requested in our meeting today, here is the concept for Option 2.
Option 2 - No future tailings cells will be considered by the DRC until an appropriate cover design is
approved by the Executive Secretary. If DUSA wants the DRC to continue reviewing the ICTM Model Report, new
Cover Design by DUSA, and new the Reclamation Plan, DUSA shall agree to sign a Memorandum of Agreemerit (MOA) to
fund the DRC consultant to complete the work in a timely matter to meet any agreed upon deadlines between DRC and
DUSA. DRC will move forward to public comment / meeting immediately. The License will contain a new license
condition that limits tailings disposal to only Tailings Cells 2, 3, 4A, and 48
Concept:! No future tailing cells will be considered by the DRC until: 1) An appropriate cover design is approved by the
Executive Secretary, pursuant to License Condition 9.11, and 2) The surety is updated to reflect the design and
construction costs of the approved cover design. Under no circumstance shall the Revised Surety be less than
$18,777,388, which was approved by the Executive Secretary on December 20, 2010. DUSA will submit the Cover
Design and Reclamation Plan Rev. 5,0 on or before September 30, 2011. At the time of the submittal, DUSA will also
submit a revised surety for the design and construction of the proposed cover design for DRC review and approval. The
DRC will review the updated Surety and will accept the Surety without actually the reviewing the design ofthe cover.
DUSA must show good faith by showing actual costs for the design and construction of the proposed cover in the
September 30, 2011 submittal. Once the updated Surety amount is accepted, DUSA shall submit written evidence of
the accepted surety amount within 60 calendar days.
Review of the Cover Design, Reclamation Plan Rev. 5.0, and the March 31, 2010 Revised ICTM will be completed by a
DRC consultant. DRC and DUSA will sign a MOA on or before September 30, 2011 to fund the DRC consultant to
complete the work in a timely matter to meet any agreed upon deadlines between DRC and DUSA. Once the Cover
Design, Reclamation Plan Rev. 5.0, and an ICTM Report is approved, DUSA shall submit a revised Surety for the
approved design and construction of the proposed cover.
This concept will be added to License Condition 9.11 for the DUSA's License Renewal. We expect to go to public
comment within 2 or 3 weeks.
If you have any questions please let me know.
Sincerely,
Phil Goble
LLRW/U-Mill Compliance Section Manager
Utah Division of Radiation Control
[phone]
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