DRC-2010-001424 - 0901a06880161443

DENISON
MINES
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Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tei: 303 628-7798
Fax:[phone]
www.denisonmtnes.com
VIA PDF AND FEDERAL EXPRESS
January 22,2010
Mr. Dane Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Dear Mr. Finerfrock:
Re: White Mesa Uranium Mill - First Round of Interrogatories From Review of License
Amendment Request and Environmental Report For Cell 4B - Supplemental Response
This letter is a supplemental response to the document entitled Utah Division of Radiation
Control, Denison Mines (USA) Corp, Interrogatories From Review of License Amendment
Request and Environmental Report for Cell 4B, Under UAC RSI3-24 and UAC RSI 7-6,
Interrogatories - Round 1, dated October 29, 2009, prepared by URS Corporation ("URS") on
behalf of the State of Utah Department of Environmental Quality ("UDEQ"), Division of
Radiation Control ("DRC") (the "Interrogatories"). Denison Mines (USA) Corp. ("Denison")
provided its initial response to the Interrogatories by a letter dated December 23, 2009 (the
"December 23, 2009 Response Letter) to the Executive Secretary (the "Executive Secretary") of
the State of Utah Radiation Control Board.
A number of Interrogatories in the October 29, 2009 UDEQ letter were not posed as questions or
requests for information, but were labeled as "To be Determined." In the December 23, 2009
Response Letter, Denison addressed each of these "To be Determined" Interrogatories" with the
comment "No Comment at this time" because a response was not requested. Upon subsequent
discussions between UDEQ staff, URS and Denison, it was determined that, for the sake of
making a complete record, Denison would provide responses to these "To be Determined"
Interrogatories.
1. INTRODUCTION
1.1 Background
Denison operates the White Mesa Uranium Mill (the "Mill"), located approximately 6 miles
south of Blanding Utah, under State of Utah Radioactive Materials License No. UT1900479 (the
"License"), State of Utah Ground Water Discharge Permit No. UGW370004 (the "GWDP") and
State of Utah Air Quality Approval Order DAQE-AN1205005-06 (the "Air Approval Order").
By letters to the Executive Secretary dated June 11, 2008 (the "License Amendment Request")
and June 16, 2008 (the "GWDP Amendment Request" and together with the License
Amendment Request, the "Amendment Request"), Denison requested amendments to the
License and GWDP, respectively, to construct, operate and (when operations are complete)
reclaim a proposed new tailings Cell 4B for the Mill.
In support of the Amendment Request, Denison had also previously submitted to the Executive
Secretary a report entitled Cell 4B Design Report, White Mesa Mill Blanding Utah, prepared by
Geosyntec Consultants (the "Design Report") on December 8, 2007, which sets out the proposed
design specifications for Cell 4B, and an Environmental Report In Support of Construction of
Cell 4B, White Mesa Uranium Mill Blanding Utah (the "Original 2008 Environmental Report")
on April 30, 2008.
The Original 2008 Environmental Report was replaced with a revised version (the "2008 ER")
on September 11,2009.
1.2 Documents Incorporated by Reference
This letter incorporates by reference information previously submitted in previous environmental
analyses performed at the Mill, as described below.
• the Final Environmental Statement Related to Operation of White Mesa Uranium
Project, Energy Fuels Nuclear, Inc., May, 1979, Docket No. 40-8681 (the "FES"),
prepared by the United States Nuclear Regulatory Commission ("NRC") for the
original License application in May 1979;
• The Environmental Report, White Mesa Uranium Project San Juan County, Utah,
dated January 1978, prepared by Dames & Moore (the "1978 ER"), which formed the
basis for the FES;
• the Statement of Basis that was prepared in December 2004 by DRC in connection
with the issuance of the GWDP (the "2004 Statement of Basis");
• the White Mesa Uranium Mill, License Renewal Application, State of Utah
Radioactive Materials License No. UTI900479, February 28, 2007 (the "2007
License Renewal Application");
• the Environmental Report In Support of the License Renewal Application, State of
Utah Radioactive Materials License No. UT1900479, February 28, 2007 (the "2007
ER");
• the Revised Background Groundwater Quality Report: Existing Wells For Denison
Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, October 2007,
prepared by INTERA, Inc. (the "Existing Well Background Report");
• the Revised Addendum: — Evaluation of Available Pre-Operatlonal and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah,
November 16, 2007, prepared by INTERA, Inc. (the "Regional Background Report");
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• the Revised Addendum: — Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Jucm County, Utah, April
30, 2008, prepared by INTERA, Inc. (the "New Well Background Report", and
together with the Existing Well Background Report and the Regional Background
Report, the "Background Reports");
• White Mesa Uranium Mill, Renewal Application, State of Utah Ground Water
Discharge Permit No. UGW370004, September 1, 2009, prepared by Denison (the
"2009 GWDP Renewal Application");
• the Statement of Basis for a Uranium Milling Facility South of Blanding, Utah,
Owned and Operated by Denison Mines (USA) Corp., dated September 2009,
prepared by DRC in support of proposed modifications to the GWDP (the "2009
Statement of Basis"); and
• the Reclamation Plan, White Mesa Mill Blanding Utah, Radioactive Materials
License No. UTI900479, Revision 4.0, November 2009 (the "Reclamation Plan, Rev.
4.0").
2. RESPONSES TO INTERROGATORIES
Each Interrogatory is shown in italics below, followed by Denison's response to the question
and/or request for information. The Interrogatories below are referred to by the same numbers
they were referred to in the December 23, 2009 Response Letter.
Reference is made to the general comments set out in Section 2 of the December 23, 2009
Response Letter, which apply to all Interrogatories, including those addressed in this letter.
2.5 INTERROGATORY WHITE MESA CELL 4B 10CFR40.26(C)(2)-02/01: GENERAL
UCENSE
REGULATORY BASIS:
UAC RSIS-24-4 Invokes the following reauirement from I0CFR40.26(c)(2): The general license In
paragraph (a) ofthis section Is subject to the documentation of dally Inspections of tailings or waste
retention systems and the Immediate notification ofthe Executive Secretary, of any failure In a tailings
or waste retention system that results In a release of tailings or waste Into unrestricted areas, or of
any unusual conditions (conditions not contemplated In the design ofthe retention system) that If not
corrected could lead to failure of the system and result In a release of tailings or waste Into
unrestricted areas; and any additional requirements the Executive Secretary may by order deem
necessary. The licensee shall retain this documentation of each dally Inspection as a record for three
years after each Inspection Is documented.
INTERROGATORY STATEMENT:
To Be Determined.
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Denison Response
The Mill currently has an extensive monitoring and reporting system, including the requirement to
conduct and document daily inspections of tailings and waste retention systems and the immediate
notification of the Executive Secretary of any failure in a tailings or waste retention system that results
in a release of tailings or waste into unrestricted areas. See Section 2.3 of the Reclamation Plan Rev.
4.0 for a summary of these requirements. See also Part I.G.3 of the GWDP and the Mill's Emergency
Response Plan. Documentation of each daily inspection is retained as a record for at least three years
after each inspection is documented.
These monitoring, inspection and record keeping requirements will apply to Cell 4B upon
construction and operation.
2.6 INTERROGATORY WHITE MESA CELL 43 I0CFR40.31(H)-03/0I: APPUCATION
FOR SPECIFIC UCENSES
REGULATORY BASIS:
UAC RSlS-24-4 Invokes the following requirement from I0CFR40.Sl(h): An application for a
license to receive, possess, and use source materiai for uranium or thorium milling or byproduct
material, as defined in 10CFR40, at sites formerly associated with such miUing shall contain
proposed written specifications relating to milling operations and the disposition of the
byproduct materiai to achieve the requirements and objectives set forth in Appendix A of
10CFR40. Each application must clearly demonstrate how the requirements and objectives set
forth In Appendix A of 10CFR40 have been addressed. Failure to clearly demonstrate how the
requirements and objectives In Appendix A have been addressed shall be grounds for refusing to
accept an application.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The original application for the License and each renewal, including the 2007 License Renewal
Application, contain written specifications relating to milling operations and the disposition of the
resulting byproduct material to achieve the requirements and objectives set forth in Appendix A of 10
CFR Part 40. Each such application clearly demonstrates how the requirements and objectives set
forth in Appendix A of 10 CFR Part 40 have been addressed. Issuance of the License in 1980 and
renewals m 1985 and 1997 by NRC attest to the fact that such requirements have been satisfied.
2.7 INTERROGATORY WHITE MESA CEU 4810CFR40.61-06/01: RECORDS
REGULATORY BASIS:
UAC RSlS-24-4 Invokes the following requirement from 10CFR40.61:
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(a) Each person who receives source or byproduct material pursuant to a license issued
pursuant to the regulations in 10CFR40 shall keep records showing the receipt, transfer, and
disposal ofthis source or byproduct materiai as follows:
(1) The licensee shall retain each record of receipt of source or byproduct materiai as long as
the material is possessed and for three years following transfer or disposition of the source or
byproduct material.
(2) The licensee who transferred the materiai shall retain each record of transfer of source or
byproduct materiai until the Executive Secretary terminates each license that authorizes the
activity that Is subject to the recordkeeping requirement.
(3) The licensee shall retain each record of disposal of source or byproduct material until the
Executive Secretary terminates each license that authorizes the activity that Is subject to the
recordkeeping requirement.
(4) If source or byproduct material is combined or mixed with other licensed materiai and
subsequently treated In a manner that makes direct correlation of a receipt record with a
transfer, export, or disposition record Impossible, the licensee may use evaluative techniques
(such as flrst-ln-flrst-out), to make the records that are required by 10CFR40 account for IOO
percent ofthe materiai received.:
(b) The licensee shall retain each record that Is required by the regulations In 10CFR40 or by
license condition for the period specified by the appropriate regulation or license condition. Ifa
retention period Is not otherwise specified by regulation or license condition, each record must
be maintained until the Executive Secretary terminates the license that authorizes the activity
that Is subject to the recordkeeping requirement.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The Mill has been operating since 1980 subject to and in compliance with the requirements of 10 CFR
40.61. The construction and operation of Cell 4B will not affect the application of these requirements
to the Mill, which requirements will continue to be met.
2.9 INTERROGATORY WHITE MESA CEU 43 10CFR40. INTRODUCTION-08/01:
CAPACITY OF TAIUNGS OR WASTE SYSTEMS OVER THE UFETIME OF MILL
OPERATIONS
REGULA TORY BASIS:
UAC RSIS-24-4 Invokes the following requirement from I0CFR40. Appendix A, Introduction: The
specifications must be developed considering the expected full capacity of tailings or waste systems
and the lifetime of mill operations. Where later expansions of systems or operations may be likely (for
example, where large quantities of ore now marginally uneconomical nmy be stockpiled), the
amenability ofthe disposal system to accommodate Increased capacities without degradation In long-
term stability and other performance factors must be evaluated.
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INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
While proposed Cell 4B has not yet been constructed, it was contemplated, described and assessed
previously, being a critical component of the initial FES and original licensing of the facility. These
initial environmental analyses and the License contemplated six tailings cells that would contain
approximately 11 million tons of tailings solids, which would be the tailings resulting from 15 years of
Mill operations at full capacity (see Section 3.2.4.7 of the FES and Section 3.4 and Appendices H and
I of the 1978 ER). These are evaporation pond Cell l-I (now referred to as Cell 1), a second
evaporation pond (Cell 1-E), which has not been constructed, and a series of 80-acre cells, of which
Cells 2 and 3 and half of Cell 4 (Cell 4A) have been constructed to date. 80-acre Cells 4 and 5 have
been specifically contemplated and included in the License (see Figure 3.4 of the FES). With the
construction of Cell 4A (40 acres). Cell 4B will consume the second 40 acres of the previously
authorized 80 acre Cell 4.
2.10 INTERROGATORY WHITE MESA CELL 4B 10CFR40 APPENDIX A,
INTRODUCTION-09/01: ALTERNATIVE REQUIREMENTS
REGULATORY BASIS:
UAC RSIS-24-4 Invokes the following requirement from I0CFR40. Appendix A, Introduction: ...
Licensees or applicants may propose alternatives to the specific requirements In this appendix. The
alternative proposals may take Into account local or regional conditions, including geology,
topography, hydrology, and meteorology. Jhe Executive Secretary may find that the proposed
alternatives meet the Executive Secretary's requirements If the alternatives will achieve a level of
stabilization and containment ofthe sites concemed, and a level of protection for public health, safety,
and the environment from radiological and nonradlological hazards associated with the sites, which
Is equivalent to, to the extent practicable, or more stringent than the level which would be achieved by
the requirements of this Appendix and the standards promulgated by the Utah Administrative Code,
Rule RSI7-6, Ground Water Quality Protection.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Proposed Cell 4B has been designed and will be constructed and operated in accordance with all
applicable regulations, permits and licenses. No altematives to the specific requirements in 10 CFR
Part 40, Appendix A have been proposed by Denison in the design, construction or operation of Cell
4B other than as required by more specific regulations and permit or license conditions imposed by
the State of Utah.
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2.12 INTERROGA TORY WHITE MESA CELL 4B 10CFR40, APPENDIX A, CRITERION 2-
11/01: PROUFERATION
REGULATORY BASIS:
UAC RSIS-24-4 Invokes the following requirement from 10CFR40 Appendix A. Criterion 2: To
avoid proliferation of small waste disposal sites and thereby reduce perpetual surveillance
obligations, byproduct material from In situ extraction operations, such as residues from solution
evaporation or contaminated control processes, and wastes from small remote above ground
extraction operations must be disposed of at existing large mill tailings disposal sites; unless,
considering the nature of the wastes, such as their volume and specific activity, and the costs and
environmental Impacts of transporting the wastes to a large disposal site, such ofi'slte disposal Is
demonstrated to be Impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The Mill's tailings system has been designed as a large permanent waste disposal site, which can help
to reduce proliferation of small sites and thereby reduce perpetual surveillance obligations by
accepting for permanent disposal byproduct material from in situ extraction operations. License
condition 10.5 permits the Mill to dispose of byproduct material generated at licensed in situ leach
facilities, subject to specified conditions. The Mill has historically and currently disposes of such
byproduct material in accordance with License condition 10.5.
2.13 INTERROGATORY WHITE MESA CELL 4B 10CFR40, APPENDIX A, CRITERION 3-
12/01: PLACEMENT BEWW GRADE
REGULATORY BASIS:
UAC RSIS-24-4 invokes the following requirement from I0CFR40, Appendix A, Criterion 3: The
"prime option" for disposal of tailings Is placement below grade, either In mines or specially
excavated pits (that Is, where the need for any specially constructed retention structure Is eliminated).
The evaluation of altemative sites and disposal methods performed by mill operators In support of
their proposed tailings disposal program (provided In applicants' environmental reports) must reflect
serious consideration ofthis disposal mode. In some Instances, below grade disposal may not be the
most environmentally sound approach, such as might be the case If a ground-water formation Is
relatively close to the surface or not very well isolated by overlying soils and rock Also, geologic and
topographic conditions might make full below grade burial Impracticable: For example, bedrock may
be sufficiently near tlie surface that blasting would be required to excavate a disposal pit at excessive
cost, and more suitable alternative sites are not available. Where full below grade burial Is not
practicable, the size of retention structures, arui size and steepness of slopes associated exposed
embankments must be minimized by excavation to the maximum extent reasonably achievable or
appropriate given the geologic and hydrologic conditions at a site. In these cases, It must be
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demonstrated that an above grade disposal program will provide reasonably equivalent Isolation of
the tailings from natural erosional forces.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Cell 4B will be excavated and constructed in a similar manner as existing Cells 1, 2, 3 and 4A, which
are mainly below grade, as dictated by the topography and bedrock conditions at the site. All tailings
cells at the site are situated in a natural swale, and are excavated to and partially within bedrock. This
results in the north and east dikes of the cells being at surface grade. The southem dike of the
southern-most cell has an above-grade dike. Similarly, the westem dike of Cell 4B will be partially
above grade. Geologic and topographic conditions make full below grade burial impracticable for two
reasons. First, bedrock is sufficiently near the surface that blasting would be required to fully excavate
a cell at excessive cost. Second, because of the natural topography, surface grade burial at the
southwest comers of the cells would require sub-grade burial at the northeast comers. More suitable
altemative sites are not available. However, the size and steepness of the slopes associated with the
exposed embankments of existing cells are, and Cell 4B will be, minimized by excavation to the
maximum extent reasonably achievable or appropriate depth given the geologic and hydrologic
conditions at the site. As required by 10 CFR Part 40, Appendix A, Criterion 6, the cells, including
Cell 4B have been designed to provide reasonable assurance of control of radiological hazards to be
effective for 1,000 years, to the extent reasonably achievable, and, in any case, for at least 200 years.
2.15 INTERROGATORY WHITE MESA CELL 4B 10CFR40, APPENDIX A, CRITERION
5A(1)-14/01: GROUND-WATER PROTECTION STANDARDS
REGULATORY BASIS:
UAC RSIS-24-4 Invokes the following requirement from I0CFR40, Appendix A, Criterion 5A(I):
The primary ground-water protection standard Is a design standard for surface Impoundments
used to manage uranium and thorium byproduct materiai Unless exempted under paragraph
5A(S) of this criterion, surface Impoundments (except for an existing portion) must have a liner
that Is designed, constructed, and Installed to prevent any migration of wastes out of the
Impoundment to the adjacent subsurface soil, ground water, or surface water at any time during
the active life (Including the closure period) ofthe Impoundment. The liner may be constructed of
materials that may allow wastes to migrate Into the liner (but not Into the adjacent subsurface
soil, ground water, or surface water) during the active life of the facility, provided that
Impoundment closure Includes removal or decontamination of all waste residues, contaminated
containment system components (liners, etc.), contaminated subsoils, and structures and
equipment contaminated with waste and leachate. For Impoundments that will be closed with the
liner materiai left In place, the liner must be constructed of materials that can prevent wastes
from migrating into the liner during the active life of the facility.
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INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Cell 4B has been designed witii a multiple syntiietic and geosynthetic clay liner system, using Best
Available Technology ("BAT"), that will prevent any migration of wastes out of Cell 4B to the
adjacent subsurface soil, ground water, or surface water at any time during fhe active life (including
closure period) of the cell. Cell 4B has been designed to be closed with the liner system left in place.
As a result, the liner system will be constmcted of materials tiiat can prevent wastes from migrating
into the liner during the active life of the facility. See the Design Report for Cell 4B design criteria.
2.16 INTERROGATORY WHITE MESA CELL 4B 10CFR40, APPENDIX A, CRITERION
5A(2)-15/01: UNER
REGULATORY BASIS:
UAC RSI3-24-4 invokes the followmg requirement from 10CFR40, Appendix A, Criterion 5A(2):
The liner required by paragraph 5A(I) above must be:
(a) Constructed of materials that have appropriate chemical properties and sufficient strength
and thickness to prevent failure due to pressure gradients (Including static head and external
hydrogeologic forces), physical contact with the waste or leachate to which they are exposed,
climatic conditions, the stress of installation, and the stress of dally operation;
(b) Placed upon a foundation or base capable of providing support to the liner and resistance to
pressure gradients above and below the liner to prevent failure ofthe liner due to settlement,
compression, or uplift; and
(c) Installed to cover all surrounding earth likely to be In contact with the wastes or leachate.
INTERROGA TORY STATEMENT:
To Be Determined.
Denison Response
Cell 4B has been designed to utilize BAT, as approved by tiie Executive Secretary. This means that
Cell 4B will be constmcted of materials that have appropriate chemical properties and sufficient
strength and thickness to prevent failure due to pressure gradients (including static head and extemal
hydrogeologic forces), physical contact with the waste or leachate to which they are exposed, climatic
conditions, the stress of installation, and the stress of daily operation.
Furtiier, the Cell 4B liner system will be placed upon a foundation or base capable of providing
support to the liner and resistance to pressure gradients above and below the liner to prevent failtire of
the liner due to settiement, compression or uplift.
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Finally, the Cell 4B liner system will cover all surrounding earth likely to be in contact with the wastes
or leachate.
The Cell 4B liner system will be virtually identical to tiie Cell 4A liner system, which has previously
been reviewed and approved by the Executive Secretary. The physical, chemical and radiological
nature of tiie tailings to be disposed of in Cell 4B will not be significantly different from tiie tailings to
be disposed of in Cell 4A.
See the Design Report for Cell 4B design criteria.
2.17 INTERROGATORY WHITE MESA CEU 4B 10CFR40, APPENDIX A, CRITERION
5A(4)-17/01: PREVENT OVERTOPPING
REGULATORY BASIS:
UAC RSIS-24-4 Invokes the following requirement from I0CFR40, Appendix A, Criterion 5A(4): A
surface Impoundment must be designed, constructed, maintained, and operated to prevent
overtopping resulting from normal or abnormal operations, overfilling, wind and wave actions,
rainfall, or run-on; from malfunctions of level controllers, alarms, and other equipment; and
from human error.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Parts I.D.2 and I.D.6 of tiie GWDP provide that under no circumstances shall tiie freeboard be less
than 3 feet in tailings cells 1, 3 and 4A. Cell 2 is filled with tailings solids, has an interim cover and
does not contain a pool area. In addition, freeboard limits, which have been calculated with an
adequate level of protection against overtopping resulting from normal or abnormal operations,
overfilling, wind and wave actions, rainfall, or run-on, and from malfunctions of level controllers,
alarms, and otiier equipment and fi'om human error are set out in License condition 10.3 and in the
Cell 4A BAT Operations and Maintenance Plan. Further, License Condition Part I.D.3 (c) of the
GWDP provides tiiat upon closure of any tailings cell, tiie Permittee shall ensure that the maximum
elevation of the tailings waste solids does not exceed the top of the flexible membrane liner in the cell.
See also tiie letter dated September 11, 2009 from Denison to UDEQ, which addresses questions
relating to the Design Report and the freeboard calculations for Cell 4B.
2.18 INTERROGATORY WHITE MESA CELL 4B 10CFR40, APPENDIX A, CRITERION
5A(5)-18/01: DIKES
REGULATORY BASIS:
UAC R3IS-24-4 Invokes the following requirement from I0CFR40, Appendix A, Criterion 5A(5):
When dikes are used to form the surface Impoundment, the dikes must be designed, constructed,
and maintained with sufficient structural integrity to prevent massive failure of the dikes. In
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ensuring structural integrity. It musl not be presumed that the liner system will function without
leakage during the active life ofthe Impoundment.
INTERROGA TORY STA TEMENT:
To Be Determined.
Denison Response
All dikes used to fomi Cell 4B have been designed and will be constmcted and maintained with
sufficient stmctural integrity to prevent massive failure of the dikes, even assuming liner failure. See
the Design Report.
2.20 INTERROGATORY WHITE MESA CEU 4B 10CFR40, APPENDIX A, CRITERION
6(2)-20/01: VERIFY EFFECTIVENESS OF FINAL RADON BARRIER
REGULA TORY BASIS:
UAC RSI3-24-4 Invokes the following requirement from I0CFR40, Appendix A, Criterion 6(2): As
soon as reasonably achievable after emplacement of the ftnal cover to limit releases of radon-222
from uranium byproduct material and prior to placement of erosion protection barriers or other
features necessary for long-term control ofthe tailings, the licensee shall verify through appropriate
testing and analysis that the design and constmction of the final radon barrier is effective In limiting
releases of radon-222 to a level not exceeding 20 pCi/m s averaged over the entire pile or
impoundment using the procedures described In 40 CFR part 61, appendix B, Method 115, or another
method of verification approved by the Executive Secretary as being at least as effective in
demonstrating the effectiveness of the final radon barrier.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
As discussed in Section 2.4.1 ofthe December 23, 2009 Response Letter, the Reclamation Plan, Rev.
4.0 presents the plan for reclamation of tiie site as it exists today, prior to the constmction of Cell 4B.
The Reclamation Plan will be further revised to incorporate the addition of Cell 4B prior to acceptance
and authorization for use by DRC. As one of several conditions in the GWDP, an infiltration analysis
(the "Infiltration Analysis") of tiie tailings cover and re-design of tiie cover for better performance is in
progress.
The current tailings cover design, included as Appendix D to the Reclamation Plan, Rev. 4.0, includes
an analysis of radon attenuation characteristics of the currently approved cover, which has been
designed to satisfy all radon emission standards. See Section 3.3.2.1 of tiie Reclamation Plan, Rev.
4.0, which describes the modeling tiiat was performed to demonstrate that the current tailings cover
design will meet these regulatory criteria. The re-designed cover, to be approved by the Executive
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Secretary as part of tiie Infiltration Analysis, will also be designed to satisfy all radon emission
standards, and will include an updated analysis of radon attenuation characteristics.
As required by UAC R313-24-4 (10 CFR Part 40, Appendix A, Criterion 6(2)), as soon as
reasonably achievable after emplacement of the final cover over Cell 4B, and prior to placement of
erosion protection barriers or other features necessary for long-term control of the tailings, the Mill
will verify through appropriate testing and analysis that the design and constrtiction of the final radon
barrier is effective in limiting releases of radon-222 to a level not exceeding 20 pCi/m"s averaged over
the entire pile or impoundment using the procedures described in 40 CFR Part 61, appendix B,
Metiiod 115, or another method of verification approved by tiie Executive Secretary as being at least
as effective in demonstrating the effectiveness of the final radon barrier.
2.22 INTERROGATORY WHITE MESA CELL 43 10CFR40, APPENDIX A, CRITERION
6(4)-22/01: REPORT RADON BARRIER EFFECTIVENESS
REGULATORY BASIS:
UAC RSI3-24-4 Invokes the following requirement from 10CFR40, Appendix A, Criterion 6(4):
Within ninety days ofthe completion of all testing and analysis relevant to the required verification In
paragraphs (2) and (3) of I0CFR40, Appendix A, Criterion 6, the uranium mill licensee shall report
to the Executive Secretary the results detailing the actions taken to verify that levels of release of
radon-222 do not exceed 20 pCl/m s when averaged over the entire pile or impoundment. The
licensee shall maintain records until termination of the license documenting the source of Input
parameters including the results of all measurements on which they are based, the calculations and/or
analytical methods used to derive values for Input parameters, and the procedure used to determine
compliance. These records shall be kept In a form suitable for transfer to the custodial agency at the
time of transfer ofthe site to DOE or a State for long-term care if requested
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
As required by UAC R313-24-4 (10 CFR Part 40, Appendix A, Criterion 6(4)), witiiin ninety days
of the completion of all testing and analysis relevant to the required verification in paragraphs (2) and
(3) of 10 CFR Part 40, Appendix A, Criterion 6, Denison will report to the Executive Secretary tiie
results detailing the actions taken to verify that levels of release of radon-222 do not exceed 20
pCi/m^s when averaged over the entire pile or impoundment. Denison will maintain records until
termination of the License documenting the source of input parameters including the results of all
measurements on which they are based, the calculations and/or analytical methods used to derive
values for input parameters, and the procedure used to determine compliance. These records will be
kept tn a form suitable for transfer to the custodial agency at the time of transfer of the site to the
United States Department of Energy ("DOE") or a State for long-term care, if requested.
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2.24 INTERROGATORY WHITE MESA CEU 4B 10CFR40, APPENDIX A, CRITERION
6(6)-24/01: CONCENTRATIONS OF RADIONUCUDES OTHER THAN RADIUM IN SOIL
REGULA TORY BASIS:
UAC RSI3-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(6): The
design requirements In this criterion for longevity and control of radon releases apply to any
portion of a licensed and/or disposal site unless such portion contains a concentration of radium
in land, averaged over areas of 100 square meters, which, as a result of byproduct material,
does not exceed the background level by more than: (I) 5 picocuries per gram (pCl/g) of radium-
226, or, in the case of thorium byproduct material, radium-228, averaged over the first 15
centimeters (cm) below the surface, and (ii) 15 pCi/g of radium-226, or, in the case of thorium
byproduct material, radium-228, averaged over I5-cm thick layers more than 15 cm below the
surface.
Byproduct material containing concentrations of radionuclides other than radium In soil, and
surface activity on remaining structures, must not result In a total effective dose equivalent
(TEDE) exceeding the dose from cleanup of radium contaminated soil to the above standard
(benchmark dose), and must be at levels which are as low as Is reasonably achievable. If more
than one residual radionuclide is present in the same 100-square-meter area, the sum of the
ratios for each radionuclide of concentration present to the concentration limit will not exceed
"1" (unity). A calculation of the potential peak annual TEDE within IOOO years to the average
member ofthe critical group that would result from applying the radium standard (not Including
radon) on the site must be submitted for approval. The use of decommissioning plans with
benchmark doses which exceed IOO mrem/yr, before application of ALARA, requires the
approval ofthe Executive Secretary after consideration ofthe recommendation ofthe staff of the
Executive Secretary. This requirement for dose criteria does not apply to sites that have
decommissioning plans for soil and structures approved before June 11, 1999.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Section 3.3.3 of Attachment A to the Reclamation Plan, Rev. 4.0 requires tiiat all areas contaminated
through process activities or windblown contamination from the tailings areas must be remediated to
meet applicable cleanup criteria for Ra-226, Th-230 and natural uranium. Section 3.3.3 fiirther
provides that contaminated areas will be remediated such that tiie residual radionuclides remaining on
the site, that are distinguishable from background, will not result in a dose that is greater than that
which would result from tiie radium soil standard, as required by UAC R313-24-4 (10 CFR Part 40,
Appendix A, Criterion 6(6)). The procedures to be followed in taking the required surveys,
including final surveys witiiin specific 10 meter by 10 meter grids, are set out in Sections 3.3.3,
3.3.4 and 3.3.5 of Attachment A to the Reclamation Plan, Rev. 4.0.
At the time of site closure, a calculation of the potential peak annual total effective dose equivalent
("TEDE") within 1,000 years to the average member of the critical group that would result from
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applying the radium standard (not including radon) on the site will be submitted to the Executive
Secretary for approval, as required by UAC R313-24-4 (10 CFR Part 40, Appendix A, Criterion
6(6)).
These final site closure standards and procedures do not apply directly to any of the tailings cells,
including proposed Cell 4B, because they will be capped in place. However, these standards and
procedures apply to all areas impacted by the tailings cells, including Cell 4B.
2.25 INTERROGATORY WHITE MESA CELL 43 10CFR40, APPENDIX A, CRITERION
6(7)-25/01: NONRADIOLOGICAL HAZARDS
REGULA TORY BASIS:
UAC RSI3-24-4 invokes the following requirement from I0CFR40, Appendix A, Criterion 6(7): The
licensee shall also address the nonradlological hazards associated with fhe wastes in planning
and implementing closure. The licensee shall ensure that disposal areas are closed in a manner
that minimizes the need for further maintenance. To the extent necessary to prevent threats to
human health and the environment, the licensee shall control, minimize, or eliminate post-
closure escape of nonradlological hazardous constituents, leachate, contaminated rainwater, or
waste decomposition products to the ground or surface waters or to the atmosphere.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The liner system for proposed Cell 4B is virtually identical to the liner system for Cell 4A, which has
previously been approved by the Executive Secretary, and which has been designed to hold all
tailings, including all nonradlological constituents. In the event of failure in the liner system, the
GWDP addresses tiie radiological and nonradlological hazards associated with tiie Mill tailings to be
disposed of in the tailings cells, including proposed Cell 4B.
There are no nonradlological emissions of any significance from the tailings cells when in operation.
Therefore, there will be no nonradlological emissions of any significance after placement of the final
cover on the tailings cells.
2.27 INTERROGA TORY WHITE MESA CEU 4310CFR40, APPENDIX A, CRITERION 7-
29/01: PREOPERATIONAL AND OPERATIONAL MONITORING PROGRAMS
REGULATORY BASIS:
UAC RSI3-24-4 Invokes the following requirement from 10CFR40, Appendix A, Criterion 7: At
least one full year prior to any major site construction, a preoperational monitoring program
must be conducted to provide complete baseline data on a milling site and its environs.
Throughout the construction and operating phases ofthe mill, an operational monitoring
program must be conducted to measure or evaluate compliance with applicable standards and
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regulations; to evaluate performance of control systems and procedures; to evaluate
environmental impacts of operation; and to detect potential long-term effects.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
An extensive preoperational monitoring program was performed at the Mill site prior to initial
constmction and licensing of the Mill, in order to provide complete baseline data on the Mill site and
its environs, as required by 10 CFR Part 40, Appendix A, Criterion 7. The results of this
preoperational monitoring program are described in detail in tiie 1978 ER and the FES.
Operational monitoring programs have been conducted at the Mill throughout tiie constmction and
operating phases of the Mill, to measure or evaluate compliance with applicable standards and
regulations; to evaluate performance of control systems and procedures; to evaluate environmental
impacts of operation; and to detect potential long-term effects. The Mill's operational monitoring
programs are described in Section 2.3 of tiie Reclamation Plan, Rev. 4.0. Monitoring results are
reported in the Mill's Semi Annual Effluent Reports and Quarterly Groundwater Monitoring Reports
and other reports filed witii the Executive Secretary.
Baseline data for any new groundwater monitoring wells installed in connection with the constmction
of Cell 4B will be obtained over the first eight quarters after installation of the wells. Because any
such monitoring wells will likely be installed in one or more of the Cell 4B dikes, being tiie
downgradient locations closest to the cell, it will not be possible to install and monitor such wells prior
to constmction of Cell 4B. However, Cell 4B will have a state of the art leak detection system that
will be monitored regularly upon commencement of operations of the cell. As a result, there will be
adequate assurance that the groundwater at any newly installed wells will not have been impacted by
Cell 4B operations during the eight-quarter baseline sampling period.
2.29 INTERROGATORY WHITE MESA CEU 43 10CFR40, APPENDIX A, CRITERION
8A-31/01: DAILY INSPECTIONS
REGULATORY BASIS:
UAC RS13-24-4 invokes the following requirement from 10CFR40, Appendix A. Criterion 8A:
Daily Inspections of tailings or waste retention systems must be conducted by a qualified engineer or
scientist and documented. The licensee shall retain the documentation for each dally Inspection as a
record for three years afier the documentation is made. The Executive Secretary must be immediately
notified of any failure In a tailings or waste retention system that results In a release of tailings or
waste Into unrestricted areas, or ofany unusual conditions (conditions not contemplated In the design
of the retention system) that Is not corrected could Iruilcate the potentiai or lead to failure of the
system and result in a release of tailings or waste Into unrestricted areas.
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INTERROGA TORY STATEMENT:
To Be Determined.
Denison Response
See the response to Interrogatory 2.5 above.
2.30 INTERROGATORY WHITE MESA CELL 4310CFR40, APPENDIX A, CRITERION 9-
32/01: FINANCIAL SURETY ARRANGEMENTS
REGULATORY BASIS:
UAC RS13-24-4 Invokes the following requirement from 10CFR40, Appendix A, Criterion 9:
Financial surety arrangements must be established by each mill operator prior to the
commencement of operations to assure that sufficient funds will be available to carry out the
decontamination and decommissioning of the mill and site and for the reclamation of any
tailings or waste disposal areas. The amount of funds to be ensured by such surety arrangements
must be based on Executive Secretary-approved cost estimates in a Executive Secretary-
approved plan for (1) decontamination and decommissioning of mill buildings and the milling
site to levels which allow unrestricted use of these areas upon decommissioning, and (2) the
reclamation of tailings and/or waste areas In accordance with technical criteria delineated In
Section I of this Appendix. The licensee shall submit this plan In conjunction with an
environmental report that addresses the expected environmental Impacts of the milling
operation, decommissioning and tailings reclamation, and evaluates alternatives for mitigating
these Impacts. The surety must also cover the payment of the charge for long-term surveillance
and control required by Criterion 10. In establishing specific surety arrangements, the licensee's
cost estimates must take into account total costs that would be Incurred If an Independent
contractor were hired to perform the decommissioning and reclamation work. In order to avoid
unnecessary duplication and expense, the Executive Secretary may accept financial sureties that
have been consolidated with financial or surety arrangements established to meet requirements
of other Federal or state agencies and/or local goveming bodies for such decommissioning,
decontamination, reclamation, and long-term site surveillance and control, provided such
arrangements are considered adequate to satisfy these requirements and that the portion of the
surety which covers the decommissioning and reclamation of the mill, mill tailings site and
associated areas, and the long-term funding charge Is clearly Identified and committed for use In
accomplishing these activities. The licensee's surety mechanism will be reviewed annually by the
Executive Secretary to assure, that sufficient funds would be available for completion of the
reclamation plan if the work had to be performed by an Independent contractor. The amount of
surety liability should be adjusted to recognize any Increases or decreases resulting from
Inflation, changes In engineering plans, activities performed, and any other conditions affecting
costs. Regardless of whether reclamation Is phased through the life of the operation or takes
place at the end of operations, an appropriate portion of surety liability must be retained until
final compliance with the reclamation plan Is determined.
This will yield a surety that is at least sufficient at all times to cover the costs of
decommissioning and reclamation of the areas that are expected to be disturbed before the next
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llcen.se renewal. The term of the surety' mechanism must be open ended, unless It can be
demonstrated that another arrangement would provide an equivalent level of assurance. This
assurance would be provided with a surety instrument which is written for a specified period of
time (e.g., 5 years) yet which mu.st be automatically renewed unless the surety notifies the
beneficiary (the Executive Secretary) and the principal (the licensee) some reasonable time (e.g.,
90 days) prior to the renewal date of their Intention not to renew. In such a situation the surety
requirement still exists and the licensee would be required to submit an acceptable replacement
surety within a brief period of time to allow at least 60 days for the regulatory agency to collect.
Proof of forfeiture must not be necessary to collect the surety so that In the event that the
licensee could not provide an acceptable replacement surety within the required time, the surety
shall be automatically collected prior to its expiration. The conditions described above would
have lo be clearly stated on any suret}' Instrument which Is not open-ended, and must be agreed
lo by all parties. Financial surety arrangements generally acceptable to the Executive Secretary
are:
(a) Surety bonds;
(b) Cash deposits;
(c) Certificates of deposits;
(d) Deposits of government securities;
(e) Irrevocable letters or lines of credit; and
(f) Combinations of the above or such other types of arrangements as may be approved by the
Executive Secretary. However, .self insurance, or any arrangement which essentially constitutes self
Insurance (e.g., a contract with a Stale or Federal agency), will not satisfy the surety requirement
since this provides no additional assurance other than that which already exists through license
requirements.
INTERROGATORY STA TEMENT:
To Be Determined.
Denison Response
As required by License condition 9.5, the Mill has deposited a surety bond with the Executive
Secretary, consistent witii UAC R313-24-4 (10 CFR Part 40, Appendix A, Criteria 9 and 10),
adequate to cover the estimated costs, accomplished by a third party, for decommissioning and
decontamination of the Mill and Mill site, reclamation of the Mill's tailings or waste disposal areas,
ground-water restoration as warranted and the long-term surveillance fee.
The amount of the stirety bond is currently $15,807,429. Annual updates to the surety amount,
required by UAC R313-24-4 (10 CFR Part 40, Appendix A, Criteria 9 and 10) are submitted for
Executive Secretary for approval by March 4 of each year.
Prior to operation of Cell 4B, the reclamation cost estimate will be updated to reflect tiie eventual
closure of Cell 4B, and the surety bond will be updated accordingly. The amended License and
GWDP will contain conditions to that effect. If the Infiltration Analysis has been completed and a re-
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designed cover system has been approved by the Executive Secretary at that time, tiien the revised
reclamation cost estimate and surety will be based on the re-designed cover system. OtheiAvise, the
revised reclamation cost estimate and surety will be based on tiie application of the currently approved
cover design to Cell 4B, and will be updated subsequently to reflect the re-designed cover once it has
been approved by the Executive Secretary.
2.35 INTERROGATORY WHITE MESA CELL 43 UAC R317-6-6.10-38/01: BACKGROUND
WATER QUAUTY DETERMINATION
REGULATORY BASIS:
UAC RSI 3-24-4 Invokes UAC RSI 7-6-6.10 In lieu of comparable requirements in 10CFR40:
A. Background water quality contaminant concentrations shall be determined and specified In the
ground water discharge permit. The determination of background concentration shall take Into
account any degradation.
B. Background water quality contaminant concentrations may be determined from existing
Information or from data collecled by the permit applicant. Existing Information shall be used. If the
permit applicant demonstrates that the quality of the information and its means of collection are
adequate to determine background water quality. If existing information Is not adequate to
determine background water quality, the permit applicant shall submit a plan to determine
background water quality to the Executive Secretary for approval prior to data collection. One or
more up-gradlenl, lateral hydraulically equivalent point, or other monitoring wells as approved by
the Executive Secretary may be required for each potential discharge site.
C. After a permit has been issued, permittee shall continue to monitor background water quality
contaminant concentrations In order to determine natural fiuctuatlons In concentrations. Applicable
up-gradient, and on-site ground water monitoring data shall be Included in the ground water
quality permit monitoring report.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Background ground water quality at the site has been determined by the Executive Secretary, based on
a review of the Background Reports and otiier analyses, and is set out in the 2009 Statement of Basis.
Such background ground water quality is currently in the process of being incorporated into a revised
GWDP.
Under the GWDP, water quality at the site is monitored on a continued basis.
2.38 INTERROGATORY WHITE MESA CEU 43 UAC RSI7-6-6.13-41/01: REPORTING
OF MECHANICAL PROBLEMS OR DISCHARGE SYSTEM FAILURES
REGULATORY BASIS:
UAC RSI 3-24-4 Invokes UAC RSI 7-6-6.13 In lieu of comparable requirements In I0CFR40:
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The permittee shall notify the Executive Secretary within 24 hours of the discovery qf any
mechanical or discharge syslem failures that could affect the chemical characteristics or volume of
the discharge. A written statement confirming the oral report shall be submitted to the Executive
Secretary within five days of the faihire.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The GWDP requires such notices to be given in tiie event of failure to maintain discharge
minimization teclinology ("DMT") or BAT standards required under tiie GWDP (Part I.G.3) and if
the facility is otherwise out of compliance (Part I.G.4 and Part U.I).
2.39 INTERROGATORY WHITE MESA CEU 43 UAC R317-6-6.10-42/01: CORRECTION
OF ADVERSE EFFECTS
REGULATORY BASIS:
UAC RSI 3-24-4 Invokes UAC RSI 7-6-6.14 in lieu of comparable requirements In 10CFR40:
A. If monitoring or testing Indicates that the permit conditions may be or are being violated by
ground water discharge operations or the facility Is otherwise In an out-of-compllance status, the
permittee shall promptly make corrections to the system to correct all violations of the discharge
permit.
B. The permittee, operalor, or owner may be required to take corrective action as described in
Refer lo Appendix A for relevant NRC regulatory guidance.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
Part I.G.4 of the GWDP specifies the actions that must be taken by Denison in the event of a violation
of a condition of the GWDP.
2.40 INTERROGATORY WHITE MESA CELL 43 UAC R317-6-6.10-43/01: OUT-OF-
COMPUANCE STATUS
REGULA TOR Y BASIS:
UAC RSI 3-24-4 invokes UAC RSI 7-6-6.16 In lieu of comparable requirements In 10CFR40:
A. Accelerated Monitoring for Probable Out-of-Compl lance Status
If the value of a single analysis ofany compliance parameter In any compliance monitoring sample
exceeds an applicable permit limit, thefacility shall:
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1. Notify the Executive Secretary In writing within SO days of receipt of data;
2. Immediately initiate monthly sampling If the value exceeds both the background
concentration of the pollutant by two standard deviations and an applicable permit limit,
unless the Executive Secretary determines that other periodic sampling Is appropriate, for a
period of two months or until the compliance status of the facility can be determined.
B. Violation of Permit Limits
Out-ofcompUance status exists when:
1. The value for two consecutive samples from a compliance monitoring point exceeds:
a. one or more permit limits; and
b. the background concentration for that pollutant by two standard deviations (the
standard deviation and background (mean) being calculated using values for the
ground water pollutant at that compliance monitoring point) unless the existing
permit limit was derived from the background pollutant concentration plus two
standard deviations; or
2. The concentration value of any poUutant In two or more consecutive samples is
statistically significantly higher than the applicable permit limit The statistical significance
shall be determined using the statistical methods described In Statistical Methods for
Evaluating Ground Water Monitoring Data from Hazardous Waste Facilities, VoL 53, No.
196 of the Federal Register, Oct. 11, 1988 and supplemental guidance In Guidance For
Data Quality Assessment (EPA/600/R-96/084 January 1998).
C. Failure to Maintain Best Available Technology Required by Permit
I. Permittee to Provide Information
In the event that the permittee falls to maintain best available technology or otherwise falls
to meet best available technology standards as required by the permit, the permittee shall
submit to the Executive Secretary a notification arui description of the failure according to
RS 17-6-6.13. Notification shall be given orally within 24 hours ofthe permittee's discovery
of the failure of best available technology, and shall be followed up by written notification.
Including the Information necessary to make a determination under RSI7-6-6.16.C.2, within
five days of the permittee's discovery of the failure of best available technology.
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
The determination of when the Mill is in out of compliance status and tiie procedures to be followed
once the facility is determined to be out of compliance are set out in Part G of the GWDP, which
incorporates tiie requirements of UAC R317-6-6.16. See also the response to Interrogatory 2.38
above.
2.41 INTERROGATORY WHITE MESA CEU 43 UAC R317-6-6.10-44/01: PROCEDURE
WHEN A FACIUTY IS OUT-OF-COMPUANCE
REGULATORY BASIS:
UAC R3IS-24-4 Invokes UAC RSI 7-6-6.17 In lieu of comparable requirements In 10CFR40:
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A. If a facility is out qf compliance thefoiiowing is required:
1. The permittee shall notify the Executive Secretary of the out of compilance status within
24 hours after detection of that status, followed by a written notice within 5 days of the
detection.
2. The permittee shall Initiate monthly sampling, unless the Executive Secretary determines
that other periodic sampling Is appropriate, until thefacility is brought into compliance.
3. The pemiittee shall prepare and submit within SO days to the Executive Secretary a plan
and time schedule for assessment of the source, extent and potential dispersion of the
contaminalion, and an evaluation of potentiai remedial action to restore and maintain
ground water quality and Insure that pemiit limits will not be exceeded al the compliance
monitoring point and best available technology will be reestablished.
4. The Executive Secretary may require immediate implementation of the contingency plan
submitted with the original ground water discharge permit in order to regain and maintain
compliance wllh the permit limit standards at the compliance moniloring point or to
reestablish best available technology as defined In the pemiit.
5. Where It is infeasible to re-establish BAT as defined in the permit, the permittee may
propose an alternative BAT for approval by the Executive Secretary.
INTERROGATORY STA TEMENT:
To Be Determined.
Denison Response
The determination of when tiie Mill is in out of compliance status and the procedures to be followed
once the facility is determined to be out of compliance are set out in Part G of the GWDP, which
incorporates the requirements of UAC R317-6-6.17.
If you should have any questions or require additional information, please contact the
undersigned.
Yours very tmly,
DENISON M;NES j^USA) CORP.
By:
DavienZf. rrynenlund
Vice President, Regulatory Affairs and Counsel
cc: Robert D. Baird, URS
Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
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