DRC-2010-005963 - 0901a068801dc535

C-2010-00 596
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November 12, 2010
VIA E-MAIL AND OVERNIGHT DELIVERY
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Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax : [phone]
z www.denisohmines.com
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Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Re: State of Utah Ground Water Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Documents Addressing White Mesa Uranium Mill New Cell 4B and Response
to Division of Radiation Control ("DRC") Letter of October 11, 2010 Regarding Comprehensive
Comments on Proposed Revised Plans
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Tailings Management System and
Discharge Minimization Technology Monitoring ("DMT") Plan, the Best Available Technology Operations and
Maintenance ("BAT O&M") Plan, and the Contingency Plan for White Mesa Mill which are currently pending
UDEQ approval. This letter also responds to DRC's letter of October 11, 2010 requesting additional changes to
previously submitted versions of these documents.
Based on the need to address newly-constructed Cell 48, and on the comments provided in DRC's October 11,
2010 letter, Denison has prepared:
• DMT Plan Revision 11,
• BAT O&M Plan Revision 2.0, and
• Contingency Plan Revision 4.0
which are provided, respectively, as Attachments 1, 2, and 3 to this letter. These revisions incorporate:
• all the changes provided in the August 4, 2010 submittal of the DMT Plan Revision 10 (provided in
redline format),
• all the changes requested in DRC's request for information regarding the New Decontamination Pad
and previously submitted in Denison's letter of September 2, 2010 (provided in redline format),
• all the changes requested in DRC's October 11, 2010 letter (provided in redline format), and
• additional changes necessary to address management of Cell 4B (provided in redline format).
All red-lined changes in the attachments to this letter are linked to the approved versions of each document,
specifically, the changes have been applied to:
N:\Cell 4B\November Submittals and Revisions for Cell 4B\11.10.10 Transmittal to DRC Plan Revisions for Cell4B.doc
Letter to Mr. Rusty Lundberg
November 12, 2010
Page 2
• Approved Version 3 of the DMT Plan
• Approved Version 1.4 of the BAT O&M Plan, and
• Approved Version 2.0 of the Contingency Plan.
Each of the revised documents has also been provided as a clean file version with all changes accepted.
Denison requests that UDEQ review and approve the versions attached to this letter, which consolidate into one
set of documents all changes submitted by Denison since September 2008, for which Denison is awaiting DRC
approval.
In an attempt to consolidate all required changes into one set of revisions which capture all required changes
Denison has not provided a stand-alone submittal solely in response to the October 11, 2010 RFI, however, we
have provided, below, specific responses to each request in that RFI. The sections and numbering of the
remainder of this letter follow that of the RFI. Each UDEQ request is shown in italics, below, followed by
Denison's response.
DEQ Comments and Responses
Continqency Plan (Revision 3):
In the subject September 2, 2010 letter, DUSA provided a proposed Revision 3 of the Contingency
Plan. This was provided in response to our subject comment letter of May 10, 2010. However, our
response regarding the Contingency Plan will not be addressed in this letter, but will be addressed
under separate cover Review of that plan will proceed independently, and will not be tied to the use of
the NDP. For reference, the third paragraph and Section 2.a.1 ofthe subject September 2, 2010 DUSA
letter specifically address the contingency plan comments in our May 10, 2010 letter
Denison Response: No response required. Denison requests that DRC review and approve the attached
Contingency Plan revision 4.0, which addresses Cell 4B.
Comments on the Proposed DMT Plan (Revision 10.1. refer to the black-line copy):
1. Paragraph 3. I.e. i. D. The end of the third sentence should be changed to read, " standing water
shall not be less than 6.2 feet."
Denison Response: This change has been made in the attached DMT Plan Revision 11.
2. On page 28 of 48 in Appendix A, entries:
a. Item numbered as one on that page should state Pond and Beach elevations (as per approved DMT
Plan 3/10 Revision: Denison-7).
Denison Response: The weekly inspection data form in DMT approved 3/10 Revision 7 does not say "Pond
and Beach" as your comment states, but states only "Pond.". Moreover, we do not measure beach elevations
in the tailings cells. This change has not been made.
b. For Cell 3 should be deleted (as per approved DMT Plan 3/10 Revision: Denison-7).
Denison Response: This change has been made in the attached DMT Plan Revision 11
c. For Cell 4A an item (d) should be added (per the foregoing reference).
DENISO
MINES
Letter to Mr. Rusty Lundberg
November 12, 2010
Page 3
Denison Response: The DMT Plan 3/10 Revision: Denison-7 Appendix A tailings Weekly Data does not
contain any item d. We do not understand the wording of this comment or the meaning of "foregoing
reference." This change has not been made because we do not understand the request.
3. Per our letter dated April 29, 2010, comment two, where we previously requested that in Appendix
A ofthe DMT Plan, Table II. Operational Systems, that a line be added in the table for any
observable FML liner damage at any disposal cell. Please add this line.
Denison Response: This line has been added to Appendix A, Daily Inspection Data, Table II, in the attached
revision to the DMT Plan.
4. For reference, on page 34 of 48 the bottom two new paragraphs of the black-line copy regard storm
water The record of these storm water related inspection Items will need to be available for the
annual storm water inspections held at the mill.
Denison Response: Agreed.
Comments on the Proposed Cell 4A O&M Plan (Revision 1.6):
A. The list of Attachments on the last page of this plan needs to be revised. It does not include the
revisions for this page, which were proposed in the versions submitted in the DUSA letters of December
11, 2008 and May 26, 2009. Please update and complete.
Denison Response: The list of Attachments has been revised in the version attached to this letter. The
document has undergone multiple revisions since the letters of December 11, 2008 and May 26, 2009 cited in
DRC's comment. The list of Attachments has been updated to be consistent with the Attachments in the
current version of the document.
B. The actual attachments need to be included with the proposed plan. This would be a change to the
attachments included with the current approved version. Cell 4A O&M Plan 3110 Revision Denison 1.4.
Please submit.
Denison Response: The attachments have been provided in the version attached to this letter.
Please also note that by this letter, Denison is providing 10 day notification to UDEQ of a 48 hour hydrostatic
test of the steel tank containment of the EDP (Beginning November 24, 2010).
Please contact the undersigned if you have any questions or require any further information.
Yours very truly.
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
OENISO
MINES
Letter to Mr. Rusty Lundberg
November 12, 2010
Page 4
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISO
MINES