DRC-2009-007024 - 0901a068801568ad

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VIA FEDERAL EXPRESS
December 23, 2009
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[si DEC 2009
'^^ Division c?^ ^^ Radiation Controi \,
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
wwvv.denisonmi nes.com
Mr. Dane Fineifrock, Execulive 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 Reviev^' of License
Amendment Request and Environmental Reporl For Cell 4B
This letter is in 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 R3J3-24 and UAC RSJ7-6, Interrogatories -
Round /, dated October 29, 2009, prepared by URS Corporation ("URS") on behalf of the State
of Utah Department of Environmental Quality ('TJDEQ"), Division of Radiation Control
C'DRC") (the "Interrogatories").
1. INTRODUCTION
1,1 Background
Denison Mines (USA) Coip. ("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. UTI900479 (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 of the Slate of Utah Radiation Control Board (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.UTJ900479,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 RepOlt");
•the Revised Addendum:--Evaluation of Available Pre-Operational 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 RepOlt");
•the Revised Addendum:--Background Groundwater Quality Report:New Wells For
Denison Mines (USA)Corp.'s White Mesa Mill Site,San Juan County,Utah,April
30,2008,prepared by INTERA,Inc.(the "New Well Background RepOlt",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");
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l:_
•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.UT1900479,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.In order to allow for better tracking of the responses to the
interrogatories,those interrogatories that pose several questions have been subdivided and each
question has been numbered with a separate subparagraph number.Tables are inserted into the
body of this letter.Figures follow the letter under separate tabs.
As a general comment,it is important to keep in mind that,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 Hand
I of the 1978 ER).These are evaporation pond Cell I-I (now referred to as Cell 1),a second
evaporation pond (Cell I-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.
The Amendment Request is not an application for the License or renewal of the License as a
whole,which are addressed in the 2007 License Renewal Application and the 2007 ER,nor is it
an application for approval of the siting and use of Cell 4B,which have already been evaluated
and approved and are included in the License as part of the original approval of the tailings
management system for the Mill,nor is it an application for the GWDP or renewal of the GWDP
which are addressed in the 2009 GWDP Renewal Application.Rather,the Amendment Request
applies to the more detailed amendments to the License and GWDP required in connection with
the actual construction and operation of Cell 4B.
However,a number of the Interrogatories would appear to be more appropriate for an application
for the initial siting and licensing of a uranium mill de novo,rather than for an application to
amend the existing license of an existing facility.For example,information is requested about
design features,effluent control equipment and performance that relate to the Mill as a whole,
and not specifically to Cell 4B.Also,a number of the Interrogatories request modeling
information to predict effluent releases and doses,whereas the Mill has approximately 30 years
of actual data to draw from,which would not be available for a new site.The objective of the
Interrogatories should not be to re-evaluate aspects of the site that have already been evaluated
OENISOJ)~~
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and approved and are not impacted by the addition of Cell 4B.As a result,the responses in this
letter incorporate by reference and refer the reader to previous evaluations and approvals where
applicable.
Because previous environmental analyses provided current environmental information and
assessments,the scope of the Amendment Request has been limited to focus on pathways and
assessments directly related to the construction and operation of the new tailings cell.These
pathways are potential airborne releases from the Cell,and the groundwater considerations
typically associated with the design of a tailing cell.These are the only two significant pathways
that could be impacted by Cell 4B installation and operation.In addition,an archaeological
study is being performed on the surface area that will be impacted by construction of Cell 4B,as
required by License condition 9.7.That study will be provided to the Executive Secretary in a
separate report.
It is important to keep in mind that the Executive Secretary has previously approved the design
and construction of directly adjacent Cell 4A.The liner design and underlying ground
conditions for Cell 4B are identical to those for Cell 4A.
2.1 'INTERROGATORY WHITE MESA CELL 4B UAC R313-24-3-01A/Ol:
ENVIRONMENTALANALYSIS -RADIOLOGICAL AND NONRADIOLOGICAL IMPACTS
INTERROGATORY STATEMENT:
2.1.1 Tabulate,analyze,summarize,and report changes of observed meteorological
conditions that have occurred since they were last updated.
Denison Response
There have been no significant changes of observed meteorological conditions at the site that have
occurred since the 1978 ER and the FES.Meteorological infonnation for the site was updated in
Section 1.1 of the Reclamation Plan,Rev.4.0,as described below.
a)Regional
The climate of southeastern Utah is classified as dry to arid continental.Although varying
somewhat with elevation and terrain,the climate in the vicinity of the Mill can be considered as
semi-arid with normal annual precipitation of about 13.32 inches.See Table 2.1.1-1.Most
precipitation is in the form of rain with snowfall accounting for about 29%of the annual total
precipitation.There are two separate rainfall seasons in the region,the first in late summer and
early autumn (August to October)and the second during the winter months (December to
March).The mean annual relative humidity is about 44 percent and is normally highest in
January and lowest in July.The average annual Class A pan evaporation rate is 68 inches
(National Oceanic and Atmospheric Administration and U.S.Department of Commerce,1977),
with the largest evaporation rate typically occurring in July.This evaporation rate is not
appropriate for determining water balance requirements for the tailings management system and
must be reduced by the Class A pan coefficient to determine the latter evaporation rate.Values
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of pan coefficients range from 60%to 81 %.Denison assumes for water balance calculations an
average value of 70%to obtain an annual lake evaporation rate for the Mill area of 47.6 inches.
Given the arumal average precipitation rate of 13.32 inches,the net evaporation rate is 34.28
inches per year.
The weather in the Blanding area is typified by WaIm summers and cold winters.The National
Weather Service Station in Blanding,Utah is located about 6.25 miles north of the Mill.Data
from the station is considered representative of the local weather conditions (1978 ER,Section
2.7.2).The mean annual temperature in Blanding was 50.3°F,based on the current Period of
Record Summary (1904 -2006).January is usually the coldest month and July is usually the
warmest month.See Table 2.1.1-2
Table 2.1.1-1
Period of Record General Climate Summary -Precipitation
~I-------,------,-----
Station:(420738)BLANDING
From Year=1904 To Year=2006
I1---------
,----[---------'-------Preci'pitati;-n -----,-Total Snowfall --
I---Mean r::~ea~low ~ear I-I~ay Max.-~;I -f~o -r-~;o--~~;O-~:a~I~:g:I~earI IfilE r I~I In.In.In.In.I
~======I r~--~n -r-T:--I--I;n ry:::t::#O,y:my~:O,y:#O'ys r-in r-;~-I-
Ihn~ry -,1.39,5.3111993ro:OO~9720.49[15IJ97'81 -61 4r 1[--or IO.8f 46~91 1979.-
~b~'y-f T2iTj,87[1913Io-:-00[190-iJji.5-0['03/1908r '6r-31-I r --6r--7.31-39.il--1913
lM~rch fl.05[3.72 fl906 10·00 119:32 [1.13 r 01119701 -'6'1'31 T[-0,4.4117.91 -1970
IAP~I 0.871 4.35 fl9261o.00 f!908!133 1 04IJ987 I 51-21 01-oI1:91l5~2T"195'7
May ro:nf2.621t926fQ.OOrI910 'I ~26f -2511994"-'4r--21-0r-'-O I Q2 1 4--.o 1 1978
June I 0.451 2.8411948 ['O:OOrI906'1.40 r-2gii938 131-110,-of -0.0 1 0'.0 r 1905
F-===Ju=IY==II·i5f3.5511914 [M0f1920 [1.74 1 21/19851 61-3,11 -of o~r-2.5 r 1906
r
ISeptember rl28 [-4.80 li927rO~00 1191211.85 r 29/1905 r--5 1 3 11'--0 f-o~o r i5 r -1905
ICktober ,1.45 r 7.011191610·00[191'5 fl·oo 1 19/190815131-'11 '0r 0.3 r-6:0 r 1984.
INovember fl.05I4~i'711905 ro~O [1929 [2.79,-2711919141 31 1l-or~3T19.0 11931.I December [l331 6.84 rl'909 fQ.OO!I917 [3.50 r--23/1909 "-5 ,31'-1r-of~f55.0r'1909,
~__-_~_r_...----r-r--
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[Spring r2.6317.7711926-[0.lOfI972[J.33[19870404 1 lsi 8[
:---------
[S~~I~er "I 2.98!6.90 r198-i[0.1-2 [1960 r4.481 196'80Soi I'-161'g['
...---r FaJl·-l3~7818.70[197iro:SOrI9)7[2.79[1919027[--'141--91'
1 r 0 I 6.5 [28.7 r J970 I
21 0 [0.0 ,-2~['-1906
-21--'-1r-3.7 II'9.SI"-1908
Table updated on Jul 28,2006
For monthly and annual means,thresholds,and sums:
Months with S or more missing days are not considered
Years with 1 or more missing months are not considered
Seasons are climatological not calendar seasons
Winter =Dec.,Jan.,and Feb.Spring =Mar.,Apr.,and May
Summer =Jun.,Jul.,and Aug.Fall =Sep.,Oct.,and Nov.
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Table 2.1.1-2
Period of Record General Climate Summary.Temperature
Station:(420738)BLANDING---_.-,-,-----
From Year=1904 To Year=2006
~:iIY Extremes---[-~~~t~~~~~em~s---I;::~.-rMin~-~em;
-;a~e-~ow r-Date-IHJ:a~t ~ear IL~::~tlYea;~~~~~=F ~~=;r';~
,--
1 --r-r --r --r dd/y-yyy r [dd/Y-YYY [F F F F or F or
Iyyyymmdd yyyymmdd
,---I January i39.lrI7·2"r l8."2 163 [3'i/io03l---=2oj 12/19631
~IFebruary I44.9[22.3r33.6[-n[--28119061-23f"08/1933 44.21199SI-I"8:81193310.0l2.Or26."1-[-0.7,
I March [52."7[27.81-40.31 861 31/1906[~r 281197'~q 51.012004 r-33~0 IJ9481-0.-0 [-0~3 [23.4[0.0
I April [62.21343148.2[-is[19/190Sr IO[24/1913 [56.9f!9921 39.4 [1928r 0.01 0:0112.41 0.0
,----
1 May [TI.3 [42.1-1 5i.-2 [-98r---3Iii002T-15[16719101-65."0~000f 5().1-[19I7[<l.4 [-0:-0 [-2.i[0.0
r=-=J=un=e=f83.3[SO.7[67.ofll0[-22i190S1-281 0311908 75.3 [200216T.2!1907 1"6.3-IOJi[O.l[0.0
r-----~---I July [S8.7IS7.9r7"i'3 I io9 [19/19051 36f 15/1934[81.112003j66.3[191611S.iT <l.O'·O.Or 0.0,
!August [86.2[56.21 ii.iTio61 --18119051 38[-2311968r77.2[1926I6S.6[19681 9.0r-0.-O[-O.Or--()~0,
ISeptember 178.2 f483[63.3 flOOr 01/1905 rwl 26M081 70.21200IT-5"6.6r1922 113\D.O[o:3T 0.0
.----------ro~t;be~[66.0f38~of52~Or 991 08/19051 iOl 30/1971 I sg:-6-12003144~1969/o:T[O:"016.61 0.0
,----
INovember [51.4 r26.7[39.11741 04/1905 [---=7125/1931 I 47.311999 r-32.4 f19s2TO:oT 0.41 23.610-1,
,
1 Winter f4T7119.S f30.7171r 190602281=231 193302081 37.5 119071 19.311933 ro.o112.7 [86.4fi3
r-------I Spring 162.4 r34.714S'.61§8 120020531 1--=3 [19750328 r~12004143.6[1909[0:"4r 0.31385 r-O~O,I Summer [86.0"[54.9[70.5 n10[i 9050622 r -2sr 19080603T 76·4"12002 r 67.4 [1941 f30A I 0.01 O-lT 0.0
1 Fall [65.2[37.7rsl.4rI00[190S090·1"1 -iI19311125r S8.311926r--rufl912r 1.4[M[30.Sr 0.1,
Table updated on Jul 28,2006
For monthly and annual means,thresholds,and sums:
Months with 5 or more missing days are not considered
Years with 1 or more missing months are not considered
Seasons are climatological not calendar seasons
Winter =Dec.,Jan.,and Feb.Spring =Mar.,Apr.,and May
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Summer =Jun.,Jul.,and Aug.Fall =Sep.,Oct.,and Nov.
Winds are usually light to moderate in the area during all seasons,although occasional stronger
winds may occur in the late winter and spring.The predominant winds are from the north
through north-east (approximately 30 percent of the time)and from the south through south-west
(about 25 percent of the time).Winds are generally less than 15 mph,with wind speeds faster
than 25 mph occurring less than one percent of the time (1978 ER,Section 2.7.2).As an element
of the pre-construction baseline study and ongoing monitoring programs,the Mill operates an
onsite meteorological station,described in greater detail below.Further details about weather
and climate conditions are provided in the 1978 ER (Section 2.7)and in the FES (Section 2.1).
b)Storms (PES Section 2.1.4,updated)
Thunderstorms are frequent during the summer and early fall when moist air moves into the area
from the Gulf of Mexico.Related precipitation is usually light,but a heavy local storm can
produce over an inch of rain in one day.The maximum 24-hour precipitation reported to have
fallen during period 1904-2006 at Blanding was 4.48 inches (11.36 cm).Hailstorms are
uncommon in this area.Although winter storms may occasionally deposit comparable amounts
of moisture,maximum short-term precipitation is usually associated with summer thunderstorms.
Tornadoes have been observed in the general region,but they occur infrequently.Strong winds
can occur in the area along with thunderstorm activity in the spring and summer.The Mill area
is susceptible to occasional dust storms,which vary greatly in intensity,duration,and time of
occurrence.The basic conditions for blowing dust in the region are created by wide areas of
exposed dry topsoil and strong,turbulent winds.Dust storms usually occur following frontal
passages during the warmer months and are occasionally associated with thunderstorm activities.
c)On Site
On-site meteorological monitoring at the Mill was initiated in early 1977 and continues today.
The original purpose of the meteorological monitoring program was to document the regional
atmospheric baseline and to provide data to assist in assessing potential air quality and
radiological impacts arising from operation of the Mill.
After the Mill construction was completed,the monitoring programs were modified to facilitate
the assessment of Mill operations.The current meteorological monitoring program includes data
collection for wind speed,wind direction,atmospheric stability according to the standard
Pasquill scheme (via measurements of deviations in wind direction,referred to as sigma-theta),
and precipitation as either rain or snow.The recorded on-site meteorological conditions are
reported to Denison on a semi-annual basis and are described in semi-annual reports prepared for
Denison and maintained at the Mill.
Figures 2.1-1 through 2.1-5 show the annual windrose for the site for each of 2004-2008.It is
evident from those windroses that there have not been any significant changes in wind
characteristics at the site during that period.The MILDOS-AREA evaluation performed for the
site by SENES Consultants Ltd.in April 2008 in support of the Amendment Request (the 2008
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MILDOS Evaluation")(see Appendix B of the 2008 ER)uses the average wind speed and
direction recorded at the Mill site for 2004 through 2006.
2.1.2 Incorporate changes of observed meteorological conditions into projections of
radiation doses to the general public (refer to Interrogatory White Mesa Cell 4B 1OCFR40.65(aJ(1)-
07/01).Alternatively,demonstrate that the impacts of such changes on projected radiation doses to
persons potentially exposed to releases from the proposed Cell 4B are inconsequential.
Denison Response
Projections of radiation doses to the general public are set out in the 2008 MILDOS Evaluation.The
2008 MILDOS Evaluation considers airborne releases of radioactive materials.Potential releases to
sUlface water and groundwater are not addressed.However,in the case of the Mill,there are no
releases to surface water or groundwater.Any potential releases to surface water or groundwater
would be controlled and remediated and would not factor into doses to the public.
Since the 2008 MILDOS Evaluation is based on CUlTent windrose data,there are no changes to
meteorological conditions that would impact or change the dose calculations set out in the 2008
MILDOS Evaluation.
2.1.3 Estimate the maximum annual external dose (millirems)that would be received by an
individual at the nearest site boundary from direct radiation during operations andfollowing closure
ofproposed Cell 4B.Provide an appendix describing the models,assumptions,and inputs used in
these calculations.
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Denison Response
The 2008 MILDOS Evaluation provides an estimate of the maximum total effective dose equivalent
("TEDE")for a number of receptors,including the nearest potential residence.The nearest potential
residence is at the nOlthem boundary of the Mill property,close to air particulate monitoring station
BHV-1,which is the closest private propelty that could be inhabited full time by a member of the
public.That location,BHV-1,is also in one of the predominant wind directions.All other site
boundaries abut United States Bureau of Land Management ("BLM")land,which could not be
inhabited full time by a resident.Therefore the person likely to receive the highest dose from the
licensed operation,as contemplated by Utah Administrative Code ("UAC")R313-15-301 and 302,
would be a person at the nearest potential residence.It should be noted that BHV-1,the location of
the nearest potential residence is approximately 1.2-miles north of the Mill site itself.The current
nearest actual residence is approximately 1.6 miles north of the Mill site.Therefore the 2008
MILDOS Evaluation is conservative in this regard.
For processing of Colorado Plateau Ore,the maximum TEDE was calculated in the 2008 MILDOS
Evaluation to be 1.4 mrem/yr for an infant at the nearest potential residence,BHV-1,which is about
1.4%of the R313-15-301(l)(a)limit of 100 mrem/yr to an individual member of the public during
Mill operations.For processing higher grade Arizona Strip ores,the TEDE was calculated to be a
maximum of 3.1 mrem/yr for an infant at the nearest potential residence,which is about 3.1 %of the
100 rnrem/yr limit.The annual extemal dose would be a fraction of the TEDE and would therefore be
less than 3.1 mrem/yr,assuming full operations processing high grade Arizona Strip ores.
Following closure of proposed Ce1l4B,the TEDEs for all receptors would be less than the modeled
results due to the fact that all contaminated materials at the site will be disposed of into the tailings
cells and covered with an engineered tailings cover designed to maintain radon releases to within
regulatory standards.Site surface clean-up standards are described in Section 3.3 of Attachment A to
the Reclamation Plan,Rev.4.0,and the tailings radon flux standards are described in Section 3.3.2 of
the Reclamation Plan,Rev.4.0.Total emissions from the site will therefore be reduced at closure,and
the TEDE to the member ofthe public likely to receive the highest dose from licensed operations will
be lower than during Mill operations.See also Section 2.1.11 below.
2.1.4 Identify and assess hazards and risks to human health and the environment created by
all potential constituents ofconcern at a site.
Denison Response
The constmction and operation ofCe1l4B will not add any new hazards or risks to human health and
the environment created by potential constituents of concem over and above existing licensed
facilities at the Mill.The physical,chemical and radiological make up of the tailings is not expected
to be significantly different from that of existing tailings or from the assumptions in the 2008
MILDOS Evaluation.The tailings cell cover design will be the same as for the existing tailings cells,
including Cell 4A;therefore,radon emanations are not expected to be any different than emanations
from Cell 4A.Cell 4B will have a similar double liner/leak detection/slimes drain system as Cell 4A,
which is designed not to release tailings solutions to the environment.Arty potential releases would
OENISONI)~~
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be detected by the Mill's groundwater monitoring program and remediated before there could be any
impact to the public.See Appendix B to the 2008 ER for Denison's proposed additions to the site's
groundwater monitoring program to accommodate CeIl4B.
The hazards and risks to human health and the environment created by all potential constituents of
concem at the Mill site was assessed in detail by Dames and Moore in the 1978 ER and by the NRC
in the FES.See Section 5.0 of the 1978 ER and Section 4.0 ofthe FES.
2.1.5 Characterize the source term for all constituents ofconcern and identify any potential
orfuture groundwater contamination.
Denison Response
The constlUction and operation of Cell 4B will not add any new constituents of concem over and
above existing licensed facilities at the Mill.The physical,chemical and radiological make up of the
tailings to be disposed of in Cell 4B is not expected to be significantly different from that of existing
tailings or from the assumptions in the 2008 MILDOS Evaluation.
The hazards and risks to human health and the environment created by all potential constituents of
concem at the Mill site was assessed in detail by Dames and Moore in the 1978 ER and by NRC in
the FES.See Section 5.0 of the 1978 ER and Section 4.0 ofthe FES.
2.1.6 Identify the pathways the constituents ofconcern will likely follow including ingestion
ofcontaminated water and ingestion ofcontaminatedfoods.Identify points ofexposure.
Denison Response
The pathways for constituents of concem for Cell4B will be the same as the pathways for constituents
of concem applicable to the Mill site as a whole.Those pathways are discussed in detail in Sections
5.1,5.2,5.3 and 5.4 of the 1978 ER and Section 4.7.2 ofthe FES.
Because previous environmental analyses provided current environmental information and
assessments,the scope of the Amendment Request has been limited to focus on pathways and
assessments directly related to the constlUction and operation of Cell 4B.Those pathways are
potential airbome releases from the Cell and the groundwater considerations typically associated with
the design of a tailings cell.Those are the only two significant pathways that could be impacted by
Cell 4B installation and operation.In addition,an archaeological study is being performed on the
surface area that will be impacted by constmction of Cell 4B,as required by License condition 9.7.
The results of that study will be provided to the Executive Secretary in a separate report.
2.1.7 Estimate the concentrations or doses those constituents will likely produce at the
location where humans or environmental populations could be reasonably exposed.
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Denison Response
The concentrations of air pmticulate radionuclides and gamma concentrations at various receptor
locations,including at the nearest potential residence (BHV-1)are repOlted in the Mill's Semi Annual
Effluent Reports that are submitted to the Executive Secretary.Therefore,since years of historic data
are available,estimations ofthe concentrations of those constituents and doses are not necessmy
Doses (TEDEs)at the locations where humans or environmental populations could be reasonably
exposed are estimated in the 2008 Mll..,DOS Evaluation.See Section 2.1.3 above.
2.1.8 Define the spatial distributions of the various constituents of concern of existing
contaminant plumes.
Denison Response
There are three circumstances where applicable groundwater standards have been exceeded at
the site that are not associated with natural background:chloroform contamination,
tetrahydrofuran (HTHF")contamination and nitrate contamination.As discussed below,none of
these circumstances appear to be related to discharges from milling activities.The following
paragraphs are excerpted from Section 2.16 of the 2009 GWDP Renewal Application.
a)Chloroform Investigation
In May,1999,excess chloroform concentrations were discovered in monitoring well MW-4,in
the shallow perched aquifer along the eastern margin of the Mill site.Because these
concentrations were above the State of Utah Ground Water Quality Standards (HGWQSS")for
chloroform,the Executive Secretary of the Utah Water Quality Board initiated enforcement
action against the Mill on August 23,1999 through the issuance of a Groundwater Corrective
Action Order (UDEQ Docket No.UGO-20-01),which required completion of:1)a contaminant
investigation report to define and bound the contaminant plume,and 2)a groundwater corrective
action plan to clean it up.Repeated groundwater sampling by both the Mill and DRC have
confirmed the presence of chloroform in concentrations that exceed the GWQS along the eastern
margin of the site in wells that are upgradient or cross gradient from the tailings cells.Other
volatile organic compound (HVOC")contaminants have also been detected in those samples.
After installation of 25 new monitoring wells at the site,groundwater studies appear to have
defined the boundaries of the chloroform plume.
Based on the location of the plume and characterization studies completed to date,the
contamination has been attributed to the operation of temporary laboratory facilities that were
located at the site prior to and during construction of the Mill facility,and septic drainfields that
were used for laboratory and sanitary wastes prior to construction of the Mill's tailings cells.
Interim measures have been instituted in order to contain the contamination and to pump
contaminated groundwater into the Mill's tailings cells.To that end,the Mill has equipped 4 of
the wells (MW-4,MW-26 (previously named TW4-15),TW4-19 and TW4-20)with pumps to
recover water impacted by chloroform and to dispose of such water in the Mill's tailings cells.
"ENISOJ)~
MINES
12
On page 3 of the 2004 Statement of Basis,DRC noted that,while the contaminant investigation
and groundwater remediation plan are not yet complete,the DRC believes that additional time is
available to resolve these requirements based on the following factors:1)hydraulic isolation
found between the shallow perched aquifer in which the contamination has been detected and the
deep confined aquifers which are a source of drinking water in the area,2)the large horizontal
distance and the long groundwater travel times between the existing groundwater contamination
on site and the seeps and springs where the shallow aquifer discharges at the edge of White
Mesa,and 3)lack of human exposure for these shallow aquifer contaminants along this travel
path.
Denison submitted a Preliminary Corrective Action Plan,White Mesa Mill Near Blanding,Utah,
August 20,2007,prepared by Hydro Geo Chern,Inc.,on August 21,2007,and a Preliminary
Contamination Investigation Report,White Mesa Mill Near Blanding,Utah,November 20,2007,
prepared by Hydro Geo Chern,Inc.,on December 21,2007.Those documents are currently
under review by the Executive Secretary.
b)THF Study
Detectable concentrations ofTHF have been found in four wells at the Mill,including upgradient
well MW-l,and far downgradient well MW-3,as well as wells MW-2 and MW-12 which are
close to the Mill's tailings cells.Two of those wells,upgradient well MW-l and far
downgradient well MW-3 have had THF concentrations that exceeded the GWQS.The two
other wells,MW-2 and MW-12,that are closest to the tailings cells exhibited detectable THF
concentrations that did not exceed the GWQS.Based on Denison's analysis,and on INTERA,
Inc.'s analysis in the Background Reports,Denison has concluded that the THF was most likely
derived from PVC glues and solvents used during installation of the PVC well casings found in
several monitoring wells at the facility,including each of the four wells described above.This
position is consistent with the occunence of THF in both upgradient and far downgradient wells
at the site.
Part LH.18 of the original GWDP required Denison to develop a plan and complete a study to
explain the occurrence of THF in those wells.To that end,Denison submitted plans dated April
7 and December 15,2005 for Executive Secretary review.The plans set out to demonstrate that
the THF contamination was caused by PVC solvents and glues used in the original well
construction.After completion of the study,which included a series of THF sampling and
analysis at well MW-2,the June 26,2007 Denison report concluded that the sample results were
inconclusive,because no THF was found in MW-2 and the basis for the study in that well was
not satisfied.In a letter dated December12,2007,the Executive Secretary agreed with Denison
and advised Denison that,in the absence of meaningful study results,routine compliance
monitoring for THF would be required for the foreseeable future at all point of compliance wells
at the facility.Later,the Executive Secretary removed the Part LH.18 study requirement from
theGWDP.
()ENISOJ)~~
MINES
13
However,recent sample results for all monitoring wells at the site,including MW-1 and MW-3,
indicate that THF concentrations are now less than the GWQS for THF.There have been no
exceedances of the State GWQS in any monitoring well over the last two years.
c)Nitrate Investigation
During review of the New Well Background Report and other reports,a Nitrate contaminant
plume was identified by DRC staff in five monitoring wells in the Mill site area,including wells
MW-30,MW-31,TW4-22, TW4-24,and TW4-25.TW4-25 is located upgradient of the Mill's
tailings cells.Elevated concentrations of chloride also appear to be associated with the nitrate
plume.
On September 30,2008,the Executive Secretary issued a request for a voluntary plan and
schedule for Denison to investigate and remediate this Nitrate contamination.On November 19,
2008 Denison submitted a plan and schedule prepared by INTERA,Inc.,which identified a
number of potential sources for the contamination,including several potential historic and offsite
sources.On January 27,2009,the Executive Secretary and Denison signed a Stipulated Consent
Agreement by which Denison agreed to conduct an investigation of the Nitrate contamination,
determine the sources of pollution,and submit a report by January 4,2010.On December 1,
2009 the Executive Secretary recommended that the elevated concentrations of chloride
associated with the nitrate plume also be addressed in the nitrate investigation.After review and
approval of the Contaminant Investigation Report,the Executive Secretary will determine if a
groundwater conective action plan is required.Denison is cunently in the process of conducting
the investigation.
2.1.9 Provide a reasonably conservative or best estimate and sensitivity of the potential
health effects caused by human exposure to potential constituents ofconcern.
Denison Response
See Sections 2.1.3,2.1.4,2.1.5,2.1.6 and 2.1.7 above.
2.1.10 Identify and evaluate the risks posed by the potential constituents of concern to
environmental populations.Estimate the likelihood ofhuman and environmental exposure.
Denison Response
See Sections 2.1.3,2.1.5 and 2.1.6 above.
2.1.11 Project impacts at the point ofexposure over a 1,000-year time frame.
Denison Response
During Mill operations,the doses to the member of the public most likely to be exposed are expected
to continue to be approximately the same as they have been to date.See Section 2.1.3 above.
OENISONr)~~
MINES
14
Upon site closure,all Mill buildings and contaminated areas,including area wind-blown
contamination will be placed into one of the tailings cells.The clean up standard for all non-tailings
areas and sUlTounding areas is set out in 10 federal Code of Regulations ("CFR")PaIt 40 Appendix A,
Criterion 6(6)(incorporated by reference into UAC R313-24-4)and Section 3.3 of Attachment A to
the Reclamation Plan,Rev.4.0.
After all non-tailings areas are cleaned up and contaminated materials are placed into one ofthe Mill's
tailings cells,the tailings cells will be capped in place.The tailings cell cap must be designed to
ensure that radon emanations do not exceed 20 pCi/m2 per second,as required by 10 CFR 40,
Appendix A,Criterion 6 and Section 3.3.2 of the Reclamation Plan,Rev.4.0,for 1,000 years to the
extent reasonable practicable,and in any event for 200 years.
Upon license te1Tl1ination,the tailings cells will be traIlSfelTed to the United States Department of
Energy ("DOE")for perpetual care and maintenance.
The doses to members of the public will therefore be minimal and within regulatory standards over a
1,000 year time frame.Upon transfer to DOE,it will be DOE's responsibility to ensure that the
tailings cells maintain their integrity such that these standards will continue to be met in perpetuity.
2.1.12 Establish a spectrum ofpotential accidents involving the proposed Cell 4B by classes
ofoccurrence and appropriately evaluate each class ofaccidents.Discuss measures that DUSA has
implemented or will implement to prevent accidents and demonstrate that such measures are
adequate.Describe emergency plans and trainingfor responding to accidents.
Denison Response
The following is a description of each type of radioactive materials and other accident involving
proposed Cell 4B,that could potentially occur at the Mill site that could require an emergency
response.The following paragraphs are excerpted from the Mill's draft Emergency Response Plan
Revision 2,dated April 20,2009 (the "Emergency Response Plan"),a copy of which has been
provided to the Executive SecretaIy
a)Tornado
Although this is highly unlikely,a tornado could occur at the Mill.A severe tornado could cause
buildings and other structures to collapse,chemical or gas releases,major fires as well as general
panic.The environmental impacts from a tornado could be the transport of tailings solids and
liquids,ores or product from the Mill area into the environment.This dispersed material would
contain some uranium,radium,and thorium.An increase in background radiation could result,
and,if sufficient quantities are detected and isolated,they would be cleaned up.However,NRC
staff have concluded in A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and
Other Radioactive Materials Licensees,S.A.McGuire,January 1988 ("NUREG-1140")that
while tornadoes could release a large amount of radioactive material,they spread the material so
greatly that resulting doses are very small.As a result,tornadoes are not discussed further in
NUREG-1140 and are not considered to be a significant radiological risk at uranium mills.
OENISOJ)JJ
MINES
15
However,to the extent that a tornado has caused or is likely to result in an ammonia leak or
propane release,an SX building fire or a breach of the Mill's tailings cells,it would be classified
as a Site Area Emergency or Alert,as defined in the Emergency Response Plan,depending on
which one of those other accidents resulted from the tornado.All other tornadoes would be
classified as On-Site Emergencies,as defined in the Emergency Response Plan.See Section 3 of
the Emergency Response Plan for the significance of these classifications.
In the event of a major tornado,the procedures outlined in Appendix G to the Emergency
Response Plan would be followed.
b)Major Earthquake
Although this is highly unlikely,an earthquake could occur at the Mill.A severe earthquake
could cause buildings and other structures to collapse,chemical and/or gas releases,major fires
as well as general panic.NRC staff concluded in NUREG-1140 that emthquakes were not
identified as leading to significant releases of radionuclides unless they were followed by a fire.
To the extent that an earthquake has caused or is likely to result in an ammonia leak or propane
release,an SX building fire or a breach of the Mill's tailings cells,it would be classified as a Site
Area Emergency or Alert,as defined in the Emergency Response Plan,depending on which one
of those accidents resulted from the earthquake.All other major earthquakes would be classified
as On-Site Emergencies,as defined in the Emergency Response Plan.See Section 3 of the
Emergency Response Plan,for the significance of those classifications.
In the event of a major earthquake the procedures outlined in Appendix G to the Emergency
Response Plan would be followed.
c)Tailings Accidents
(i)Flood Water Breaching of Retention System
In general,flood water breaching of tailings embankments presents one of the greatest dangers
for the sudden release of tailings solids and impounded water.The tailings cells are designed
with sufficient freeboard (at least three feet)to withstand back-to-back lOa-year storm events or
40%of the probable maximum flood (PMF)followed by the lOa-year storm event.The flood
design is equivalent to 15 inches of rainfall.In addition,the tailings dikes were designed in
accordance with NRC regulations and allow a sufficient margin of safety even in the event of an
earthquake.
The possibility of floods in Westwater Creek,Corral Creek,or Cottonwood Wash causing
damage to the tailings retention facility is extremely remote.This is due to the approximately
200 foot elevation difference between the streambeds of the creeks and the toe of the tailings
dikes.
Flood water breaching a tailings embankment is classified as an On-Site Emergency,as defined
in the Emergency Response Plan,because it is unlikely that any releases to the environment
OENISOJ)J
MINES
16
I:
would leave the Mill property,and in the event that any contamination were to leave the
property,it is unlikely that the release would be expected to require a response by an offsite
response organization to protect persons offsite.See Section 3 of the Emergency Response Plan
for the significance of that classification.
In the event of a Flood Water Breach of the tailings retention system,the procedures 111
Appendix H of the Emergency Response Plan would be followed.
(ii)Structural Failure ofTailings Dikes
All tailings dikes have been designed with an ample margin of safety as per NRC regulations.
This has included design calculations showing dike stability even when the dike is saturated with
moisture during a seismic event,the most severe failure mode.In addition,the tailings discharge
system is checked at least once per shift during operation,or once per day during Mill standby.
NRC staff concluded in NUREG-1140 that tailings pond failures also release a large quantity of
material.However,NRC staff concluded that rapid emergency response is not needed to avoid
doses exceeding protection action guides because dose rates at a spill site are very low.NRC
staff concluded that an appropriate response would be to monitor drinking water,especially for
radium-226,to be sure that drinking water standards are met.Gamma monitoring of the ground
would also be appropriate to determine where the tailings have been deposited.However,NRC
staff concluded that ground contamination would present little immediate hazard to the public
because the gamma dose rates would be low.Gamma dose rates in contact with tailings should
be less than 0.1 mR/hr.A clean-up of the spilled tailings would be expected,but this could be
done effectively without pre-existing emergency preparedness.
Although the discharge from a dike failure would soon cross the restricted area boundary,the
flow path would be over three miles in length before leaving the Mill propelty.In the event of a
dam failure,large operating equipment would be mobilized to construct temporary earthen dikes
or berms downgradient of the failed dike.In addition,the Executive Secretary,MSHA,and the
State of Utah,Department of Natural Resources,Division ofDam Safety would be notified.The
contamination from such an event would be cleaned up and returned to the tailings area.
A tailings dam failure is classified as an On-Site Emergency,as defined in the Emergency
Response Plan,because it would be unlikely that any releases to the environment would leave
the Mill property,and in the event that any contamination were to leave the property,it would be
unlikely that the release would be expected to require a response by an offsite response
organization to protect persons offsite.See Section 3 of the Emergency Response Plan,for the
significance of that classification.
In the event of a tailings dam failure the procedures outlined in Appendix H of the Emergency
Response Plan would be followed.
(iii)Seismic Damage to TranspOlt System
In the event of a seismic rupture of a tailings slurry pipeline,the released sluny would be
OENISOJ)JJ
MINES
17
contained in the tailings cells regardless of the quantity released.The tailings retention system
pipe is in the same drainage basin as the retention system.Any tailings slurry released by a pipe
rupture,no matter what the cause,would flow downhill where it would be impounded inside a
tailings cell.
If a break occurred,the pumping system would be shut off,personnel removed from the
immediate area,and the Executive Secretary notified.The break would be repaired and the
affected area cleaned up in the safest and most expeditious manner.The advice and direction of
the Executive Secretary would be sought and heeded throughout the episode.
A seismic rupture in the tailings slurry pipeline would be classified as an On-Site Emergency,as
defined in the Emergency Response Plan.See Section 3 of the Emergency Response Plan for the
significance of that classification.
In the event of a rupture in the tailings slurry pipeline the procedures outlined in Appendix H of
the Emergency Response Plan would be followed.
d)Tenorist/Bomb Threat
In the event that any person should receive a threat of a bomb,the procedure set out in Appendix
I of the Emergency Response Plan would be followed.
Because of the unknown nature of the risk,a tenoristlbomb threat would be classified as an
Alert,as defined in the Emergency Response Plan.See Section 3 of the Emergency Response
Plan for the significance of that classification.
In the event of a terroristlbomb threat,the procedures in Appendix I of the Emergency Response
Plan would be followed.
2.2 INTERROGATORY WHITE MESA CELL 4B UAC R313-24-3-01B/Ol:
ENVIRONMENTAL ANALYSIS -IMPACT ON WATERWAYS AND GROUNDWATER
INTERROGATORY STATEMENT:
2.2.1 Provide updated information on use and characteristics of groundwater and surface
water resources,including aquifer horizontal and vertical permeabilities and other
physicallhydraulic properties,well drawdown characteristics for existing wells.
Denison Response
A detailed description of aquifer horizontal and vertical permeabilities and other
physical/hydraulic properties,and well drawdown characteristics for existing wells is set out in
Sections 6.3,7.1,7.2 and 7.3 of the 2008 ER.That information has been updated from January
8,2008 to August 27,2009 and is set out in Section 2.5 of the 2009 GWDP Renewal
Application.
OENISONI)JJ
MINES
18
2.2.2 Provide updated information on present and projected future uses of groundwater and
suiface water in the area surrounding the mill site within a minimum 10-mile radius.
Denison Response
a)Surface Water
Updated information on present uses of surface water in the area sUlTounding the Mill is set out
in Section 1.4.1 of the Reclamation Plan,Rev.4.0.Surface water use in the area is not expected
to change significantly in the foreseeable future.
b)Ground Water Use
The following discussion is excerpted from Section 1.5.6 of the Reclamation Plan,Rev.4.0.
Two hundred sixty one groundwater appropriation applications,within a five-mile radius of the
Mill site,are on file with the Utah State Engineer's office.A summary of the applications is
presented in Table 2.2.1-1 and shown on Figure 2.2.1-1.The majority of the applications are by
private individuals and for wells drawing small,intermittent quantities of water,less than eight
gallons per minute (gpm),from the BUlTO Canyon formation.For the most part,these wells are
located upgradient (north)of the Mill site.Domestic water,stock watering,and irrigation are
listed as primary uses of the majority of the wells.It is important to note that no wells completed
in the perched groundwater of the Buno Canyon formation exist directly downgradient of the
site within the five-mile radius.Two water wells,which available data indicate are completed in
the Entrada/Navajo sandstone (Clow,1997),exist approximately 4.5 miles southeast of the site
on the Ute Mountain Ute Reservation.These wells supply domestic water for the Ute Mountain
Ute White Mesa Community,situated on the mesa along Highway 191 (see Figure 2.2.1-1).
Data supplied by the Tribal Environmental Programs Office indicate that both wells are
completed in the Entrada/Navajo sandstone,which is approximately 1,200 feet below the ground
surface.Insufficient data are available to define the groundwater flow direction in the
Entrada/Navajo sandstone in the vicinity of the Mill.
The well yield from wells completed in the Burro Canyon formation within the White Mesa site
is generally lower than that obtained from wells in this formation upgradient of the site.For the
most part,the documented pumping rates from on-site wells completed in the Burro Canyon
formation are less than 0.7 cubic feet per second (cfs).Even at that low rate,the on-site wells
completed in the BUlTO Canyon formation are typically pumped dry within a couple of hours.
This low productivity suggests that the Mill is located over a peripheral fringe of perched water;
with saturated thickness in the perched zone discontinuous and generally decreasing beneath the
site,and with conductivity of the formation being very low.These observations have been
verified by studies performed for the DOE's disposal site at Slick Rock,which noted that the
Dakota Sandstone,BUlTO Canyon Formation,and upper claystone of the Brushy Basin Member
are not considered aquifers due to the low permeability,discontinuous nature,and limited
thickness of these units (DOE,1993).
OENISONI)~
MINES
19
Table 2.2.1-1
Water Rights
IN::erl Diversion Ii:~IIStatusljPriOrity II Uses II CFS II AC~II OwnerName ITypeILocation
109-10061lUnderground II IIU 11197711101~lo.500110.ooo IIDOROTHY PERKINS I
DS30W20E40237S DDDDDDNORTHRESERVOIR22ESL..ROAD (37-1).
109-1008 IIUnderground II liT 11197711101~lo.50ollb.{)OO IIARDEN NIELSON I
D
S460 Ell7 W4 01 DDDDDDlpoOoBOX1I378 I37S22ESL
109-1009 IIUnderground IDEJI1977111OIDlo.500110.0001 BARM.K.RANCHESINCORPORATED
D
N1200E990W414 DDDDDDroOoBOX576 I37S22ESL
109-1009 Ilunderground IDEJI19771110IDlo.500110.000 IBAR M.K.RANCHESINCORPORATED
D
oW990 N414 37S DDDDDDIp.OoBOX576 I22ESL
109-1009l1underground IDEJI1977III01D10.5001roOOO I~~~~1ffiS
D~ii~~9i~S411 DDDDDD~oOoBOX576 I
~JIundergroUDd II:~IDII94507021flS Irooo+ooo IF Mo BROWN I
DN1275E2708 SWOl DDDDDDFLANDINGUT 84535 I.37S 22ESL ....
109-1013 IIUnderground II lip 11197712071~lo.0151Io.ooo IILEWIS A.BLACK I
D~:~1iS434 DDDDDDr'ooBOX #403 I
109-10161Iundergrowid IDDII97801031IDIS 110.5001100000.J=ill>.I
DN5590S43436S DDDDDD60NORTH 100 WEST..22E SL .(16.:5)
109-1017.IIUndergtound II IIp Ili97801051~10.0151Io.0001IJ0l1NBRAKE I
D~ii~~~lS434 DDDDDDh-BOX #173 I
09-1018 Underground T 19780104 DIS 0.015 0.000 .MARGARET E.THOMPSON
DS2620W840NE36 DDDDDDlpo BOX#231 I36S22ESL..
109-1023 IIUnderground IIIDI1978012611DIS 111.000110.000 I!CALVIN BLACK I
D
S10 W4000 NE 16 DDDDDDr·O.BOX #885 I37S22ESL
109-1023 IIUnderground II liT 11197801261lDIS 111.000110.000 IICALVIN BLACK I
D
S600 W1320 NE 16 DDDDDDr·O.BOX #885 I37S22ESL
109-103 lIunderground II:~101194507JOIDI0.003lr·000 1=M.1D~~~92~~i5 NW02 DDDDDDrLANDING liT 845351
~[1~0~EJ88COLIEGEOF09-1031 Underground info P 19830425 SX 0.136 0.000 EASTERN UTAH
D~I~~O SW23 38S DDDDDDI451EAST 400 NORTH I
109-1032 IIUnderground II liT 1I1978030911DIS 110.015110.000 IIBLANDING CITY I
D~~2~8~~NE 15 DDDDDDIBLANDING liT 84511 I
109-1033 Ilunderground II:~101197803091FIS IIO.oI511o.000 I~~~~EY
DNJ050WI 195 SE 10 DDDDDD191 BUITERNUT37S22ESL.OC>RIVE NORTH
109-1042 Ilundergroundll:~IDI19780505IEJI0.oI511J.450 I~OE G.BROWN I
D~i;~~i~90 SEOI DDDDDDrLANDINGUT84511 I
\09-1043 IIUnderground II liT 1119780SosIIQDI0.01SII0.000 IIARVID K.BLACK I
D~~~~2~~~NWOI DDDDDDIBOX339 I
109-1044 IIUnderground II IIp 111978042911QD!0.01SI10.000 IlpETE M.BLACK I
D~~~02:~~W436 DDDDDDIBOX386 I
109-1045 Ilunderground II:~101197805041FIS 1I0.oI51Io.000 I[KENNETH BROWN I
D~ig~~i~oSEOl DDDDDDlp·O.BOX#637 I
109-1047 lIunderground II:~101197805111FIS 11°.015111.586 IIIVAN Q.JONES I
I IIN105 WIIIO E4 02 II II II 1001 \I881EASTBROWNS I
I 1137s 22ESL II .II II 1001 IICANYON ROAD I
109-1048 [[underground II:~10119780511ljnlS If.oJ51100000 IlDORIS GUYMON I
D N105 WlllO E402 DDDDDDroOoBOX#117 137S22ESL
109-10S7 lIunderground II:~[0[197806231IDIS [lo.01S[[O.ooo IEUGENE &DORTHEA GUYMON
D S100 W1400 NE 02 DDDDDDIBOX1l7 I37S22ESL
1°9-1058 IFnderground IDDBDBEJ
EUGENE &DOROTHEAGUYMON
D N400 W400 E4 02 DDDDDD[BOX117 137S22ESL
1°9-1059
1 I:~IDI19780623IFIS 11°010°1100000 I
EUGENE &Underground DOROTHEAGUYMON
D SIOO W1400 NE 02 DDDDDD[BOX117 I37S22ESL
[09-1063 Ilunderground [DO[197808021IDO 1[0.015110.000 II~~N~TRUCTION 1
D N900 W660 SE 34 DDDDDDlp·O.BOX41S [36S 22ESL109-1071 IIUnderground II liT 11197808241010.01sII0.000 IIJAMES J.HARRIS ID8600W1280E436DDDDDDIBOX392I36822ESL
109-1090 Ilunde.rgrOlllld It[]O~EJBEJGUYDENTON AND•info P 19790S21 DI 0.015 0.000 PEGGY DENTON
DN1090W20 S4 02 DDDDDD632EAST BROWNS37822ESLCANYONROAD
f9-11°IIUnderground II:~10119460415IjnlS 1I00wolfooOO I~NRY Mo LYMAN I
D~i:~i:~~23 B403 DDDDDDIBLANDING ur 845111
109-1100 lIUnderground.II IIA.1119790904!1Q010.OlsII0.000 !lLOYD ROPER I
D~~:;~:;~S434 DDDDDDroOoBOX469 1
109-1110 Ilunderground I~~~10II9830304IEJI°.oJ5[IOoooo [=~~r I
I IIN1l70WlOOOSE0111 I'II 1001 IIp·o.BOX1090 I
I 1137s 22ESL II II II 1001 II .I
109-1124 IIUnderground IDDI1986081811![]10.0151Io.000·IIJOHN BRAKE I
D N31()E280 S4 34 DDDDDDII300So 300Wo (60-9)136S22ESL
109-1128 IIUnderground II IDI198003101IDIS 110.015110.000 IIJAMES A.LAWS I
D S1610 E560 N4 02 DDDDDDlpoOoBOX121O I37S22ESL
1°9-1144 Ilunderground ID011980063011015 IIOo0151roOoo II~n~N SMITHDN1272E149S434DDDDDDlpoOoBOX116936S22ESL
109-1145 IIUnderground IDOl1980063011015 11000151100000 II~~~NN SMITH
D N1272 E149 S4 34 DDDDDDlp.O.BOX116936S22ESL
109-1146 IIUndergrOUnd IDOl198006301lDIS 110.015110.000 II~~NN SMITH
D N1272 E149 S4 34 DDDDDDlpoOoBOX1l69 136S22ESL
109-1147 IIUnderground IDOl198006301lDIS 110.01511°.000 II~~~NN SMITH 1
D N1272 E149 S4 34 DDDDDDroOoBOX1169 136S22ESL
1°9-1153 Ilunderground IDOI19800825IEJI0.D151100000 1~~Vo&REVA 1DDDODDOPARLEYANDREVAN1350E1l50SW34REDDFAMlLY
36S 22E SL LIVING TRUST(1981)
109-1156 Ilunderground II:~iD1198oo909!rm 11°0015110000°1
AL B.CLARKE ANDSHIRLEYW.CLARKE
D N2580 W921 S4 01
DDDDDD
1555 BROWN'S
37S 22ESL CANYON ROAD
f9-1157I1underground IDDI198009121§J10070011511.5401~WHITE MESA 1
D N1200 E280 SW 21
DDDDDD
1050 17TH STREET,
37S 22ESL SUITE 950
109-]]57 IIUnderground 1 D1198009121EJlo.7001151 1.5401IUCWHITE MESALLC
D N200 W200 SE 28 DDDDDD105017THSTREET,37S 22ESL SUITE 950
109-1157 Ilunderground IDDI1980091~EJlo.700IISII.S40I~WHITE MESA I
D N1200 W200 SE 33 DDDDDDIOSOI7TI1STREET,37S 22E SL SUITE 950
109-1157 IIUndergrOUnd IDDI19800912IEJI0.70011511.54011~~WHITE MESA 1
D N12000 SE 21 37S DDDDDD1050 17TH STREET,22ESL SUITE 950
~IUnderground IDOII9460903IDlo.ooslr.ooo II~~:ILTON 1
D S150 W925 E4 35 DDDDDD747 NORTH 30036S22ESLWEST(34-2)109-1167 IIUnderground II IDI1980120911DIS 110.012110.000 IILYNDA HARRELSONIDS1430W270N402DDDDDDI~~~I00 137S22ESL
109-1173 Ilunderground IODI198102021010.000111.000 I~~i:~IONINCORPORATED
Di~~5~:~~00 NE32 DDDDDDICIOK &AIHELTON I
109-1176 IIUnderground IDOI19800912IEJlo.600110.000 II~~EMESA IDN1400W3000SE28DDDDDD10S017THSTREET,37S 22E SL SUITE 950
109-1176 Ilunderground II~~10119800912IEJI0.600110.000 II~~~ITE MESA I
D N1300 W2400 SE 28 DDDDDD1050 17TH STREET,
37S 22E SL SUITE 950
109-1176 Irnderground II:~10119800912IEJlo.60+000 II~~MESA IDN2I00W2200SE28DDDDDDIOS017THSTREET,375 22E 5L ·5UITE950
109-1176 Ilunderground IDOI19800912IEJlo.600110.00011:Y~~ITE MESA IDNI290WI70SE33DDDDDDIOS017THSTREET,375 22E SL SUITE 950
109-1176 Ilunderground IDOI19800912IEJlo.600110.0001~.WHITE MESA I
DN1000E650 SW22 DDDDDD1050 17TH STREET,
37S 22E SL SUITE 950
109,1198 IIUnd~grOUDd IDDI19810406IID1S Ilo.m5Ir·oDO l~i~ALMER IDS585E1460W401DDDDDD12EAST5THSOUTH37S22ESL107-5
109-1199 IIUnderground II lIT 11198104031010.052110.000 IIIVAN R.WATKINS I
D S2722 E310 NW 01 DDDDDDr.o.BOX 372 I37S22ESL
109-1201 IIUnderground 1/lip 1!1981041611DIS 110.015110.000 IIKAREN c.KNIGHT I
D~J~~~;~W436 DDDDDD~I64BLUFFROAD I
109.1221 l~lld~groUDd IDEJI198107211~lli Ilwmlr'OOO l~i~:ND
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109-1225 IIUnderground II liT 1I1981070811DIS 110.100110.000 IIDENNIS E.GUYMON I
D~i~;~I;ioE402 DDDDDDIBOX657 I
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D N760 E1532 W4 02 DDDDDD1307 SOUTH MAIN
37S 22ESL (79-9)
109.123 Iflld~gronnd II:~IDII9470822IDlo.01511°·ooo IIGEORGE F.LYMAN I
D~i~~~SW 15 DDDDDDIBLANDINGUT84511 I
109-1230 IIUnderground IOIT 1I1981092111DIS 110.015110.000 I!RICHARD ARTHUR I
D~i~~~W402 DDDDDD~;~UTH100 I
109-1233 IIUnderground II lip 111981100711DIS 110.000113.266 IIKIRK BLACK I
DN306E51 W401 DDDDDD~~~~37S 22E SL WORLD 103-23
109.1236 IIUlldergrOUDd II:~IDI1981110211D1S Ir'015Ir,oool JAMESR.AND
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BRANDT
I IIS910 E2020 W401 II II II 1001 1139 SOUTH 100
I 1137s 22ESL II II II 1001 IIWEST (68-2)Ir9-1238 /lunderground II:~IDI19811223IEJI°.oJ511°·000 IIALYCE M.RENTZ I
0 N1300 E50 S4 01 DDDDDDBROWNCANYON37S22ESLROAD103-8109-1248 llUnderground IDlp 11198202091~10.0151Io.000 IIREED HURST I
0 S1470 E125 N402 DDDDDDI354S.300W.#56 I37S22ESL
109-1262 IIUnderground II:~IDI19820811IEJI°.Q151Io·000 IIGERALD B.HElNER I
0 N132 E2244 W4 02 DDDDDDh·BOX1127 I37S22ESL
1°9-1287 Ilunderground II:~ID119830207IF1S 11°.01511°.000 IIALVlN H.KAER I
0 N476 E2256 W402 DDDDDD~·O.BOX 1133 I37S22ESL
109-1290 IIUnderground IDDI19830323IEJr·0I51Io·000 II~~E~=RES I
0 S932 W363 N4 03 DDDDDDI:u'i:T1600 I37S22ESL
109-1346 Ilunderground IDDI19840305IDI0.0151Io.000 1~.~~~~iVA L.
OS1321WI980E415 DDDDDD578S0UTH20037S22ESL.WEST 61-1
109-138 IIUnderground IDDI19500525IDlo.0I5Ir·000 I~~;o 1OS1326W1205E402DDDDDD1166SOUTH10037S22ESLEAST
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OS2722 EIO NW01 DDDDDD1020 15TH STREET,378 22E SL SUITE 122EEJDDBEJBEJGOPERWTCO09-1402 Underground T 19841113 0 0.000 6.000 •~~SHALLOILCORPORATION
OS2722EIONW01 DDDDDD1020 15TH STREET,378 22E SL SUITE 22E
109-14J IFnderground II:~IDI19500918IDlo.0I51Io.0001=M.1
109-1548 Ilunder~OOd IDDI19871202IEJIo.000I180000 1~~~~:~g~UM
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109-1664 l~nder~OOd IDD119890913II01S 1~.Q151100000 11~1i:gHAM I
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109-1457Iund~~OOd DDI198601031~loooooI130000 I~;:::
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D S570E1458 W401 DDDDDDBROWN.CANYON
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109-1477 IIUnd~grOOOd II;;~IDI199311081§]00l51100000 IIJOANN WATKINS I
D N750W2180SE01 OODDDD~~~:O~10337S22ESL14-
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37S 22ESL QUINTANA
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109-1785 IIUnderground II IIA 111991103111DIS 110.100110.000 IIBERTHA SNYDER I
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109-1794 Ilunderground II:~IDI19920313IEJlo.1001~·000 I:=IJAME==S=D=.=R=ED=D=~II
O N1115 E2320 SW02 DDDDDDISANTAFEHEIGHTS I37S22ESL104-9
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8)
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0 N1480 W1905 SE 11 DDDDDDIBOX864 137522ESL
109-Z001 lIunderground II:~1011998100z1101S 110.000111.480 IIANNA M.RAFFERTY I
0 S860 E315 NW 22 DDDDDDlp.O.BOX 553 I37S22ESL
109-2006 IlUnderground II liT 1l1999011211DIS 110.000114.730 IIMARTHA LYMAN I
0 S660 W700 NE 21 DDDDDDlp·O.BOX96 I37S22ESL
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0 N2430 E2540 SW 36
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109-2021 1[underground II:~101199908101IDIS l[o.oooIEJISHELLY BLAKE 1
0 S275 E561 W4 35
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36S 22ESL (95-23)
109-Z033 Ilunderground IDDBBBEJ
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109-Z035 I~nderground II:~IDI20000504IEJlo.00oI14.730 IIALANSHUMWAY I
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109-2068 Ilunderground II:~IDI2007050211D1S 110.000112.904 IIBRUCE E.STEVENS 1
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109-2075 IIUnderground II liT 1120020603110x 110;0001116.140 IluSA CORPORATION I
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109-2290 IIUnderground lOlA 1120080221 1lDIS 110.000114.730 IILOIS SHUMWAY I
0 S284 W423 NE 03 DDDDDDrOBOX447 I37S22ESL
109-2296 IIUnderground IDOI200805051101S 110.0001[4.730 lj;;yNDELL &EUZA 10S1255W814E402DDDDDDr.o.BOX 555 I37S22ESL
109-2297 IIUnderground ID01200805161[OIS Ilo.ooolr·728 1NELLADEE ANDJACKL.STREET
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0 S955 E192 NW 01 DODDDCI141 EAST 300 SOUTH I37S22ESL
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0 S50 W990 NE 21 DODDDDIpOBOX106 I37S22ESL
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109-365 IIUnderground "lip II 19641013IDI0.01511o.000 IIEUGENE GUYMON I
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109-385 IIUnderground II liT 11196507151010.500110.000 IIHARRIS SHUMWAY I
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109-423 IIUnderground II lip 1I1935052211DIS 110.022115.580 IIFRED S.LYMAN I
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109-466 IIUnderground II IIp 1119680308IDIO.00711o.000 IILORENZO HAWKINS I
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109-544 lIUnderground II liT 11197209221010.015110.000 .IIROBERT E.HOSLER I
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109-581 lIUnderground II lip 11197405021010.300110.000 IIDELORES HURST I
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109-581 IIUnderground II lip 11197405021010.300110.000 IIDELORES HURST I
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109.582 jlunderground IDDI197405021010.750110.000 11~~TMlLTON 1
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I II I~
"
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109-597 "Underground 11 lip 1119740829IDI0.015I1o.000 IlnOROTHY PERKINS I
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109-606 IIUnderground II liT 111974112711015 110.100110.000 IIJESS M.GROVER I
D
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109-619 IIUnderground II liT 111975061911015 110.015110.000 IIBOYDLAWS I
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N747 W932 E4 02
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N400 W350 E4 02
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D
N275 W150 E4 02
DDDDDDr·O.BOX #117 I37S22ESL
109-634 lIunderground II:~10119751129IDI0.0151Io·000 ILORRAINE ROSE
AND VERL J.ROSE
DS1326W1205E402 DDDDDD1166 SOUTH 100
37S 22E SL EAST
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D S2722 EI0 NW 01 DDDDDDEASTBROWN37S22ESL.~~YON ROAD 103-
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109-666 lIunderground IDDI19761021IEJI1.000110.000 I
HEMlWEST
PROPERTIES
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37S 21E SL EAST~======!\
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D N640W1650SE28 DDDDDDb~~:r:o~TREE.T,
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C]N1400 W300a SE28 DDDDDD1050 17TH STREET
37S 22E SL SUITE 950
109-689 l/underground II:~IDI197703071IMOSIIl.ll01[803.6001~[~=L~==WH==IT=E=ME=S=A==:I'
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37S 22E SL SUITE 950
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109-713 [[undergronnd II:~IDI19770407IIDIS 11°.01511°.000 ]\==ID=EAN==W=.G=U=Y=M=O=N===;I'
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1:=109=-7=40=IIUnderground Ilwell IlpII19770419ID~10.ooo II~w=IN=ST=O=N=A=ND===!11
01 IEJDDDDD
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BAYLISS .
0
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109-743 IIUnderground II liT \l19851016!1!2[]0.0151!0.000 110.FROST BLACK I
0
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DDDDDD
208 SOUTH 200
36S 22ESL WEST (65-5)
109-771 lIunderground IDDI197704271010.0151Io·000 1
ELIZABETH ANN
HURST PHILLIPS
0
N670 E950 S4 34
DDDDDDlp·0.BOX#389 136S22ESL
109-778 \lUnderground II liT 11197705041~IO.0151Io.000 IlREX D.ANDERSON I
0
S310 E1240 W4 15
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109-792 lIunderground II:~ID11977050911DIS 11°.015110.000 II~~~LYDE 1
D S80 E220 W4 01 37S DDDDDD 1000 EAST BROWNS
22ESL CANYON ROAD 103-
14
109-805 lIunderground IDD11977051011DIS 110.015110.000 1
BAR M.K.RANCHES
INCORPORATED
0
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INCORPORATED
0
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109-808 Ilunderground IDDI197705101IDIS 110.015110.000 1
BAR M.K.RANCHES
INCORPORATED
0
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DDDDDDIBOX576 137S22ESL
109-826 IIUnderground II IIU 111977052311DIS 110.500110.000 IICLISBEE LYMAN IoN665W1015S410DDDDDD435SOUTH20037522ESLWEST63-2
109-826 IIUnderground II Ilu 1l197705231lDIS 110.500110.000 IlcLISBEE LYMAN IoN70W790S41037SDDDDDD435SOUTH20022ESLWEST63-2
109-826 IIUnderground II Ilu 11197705231lDIS 110.500110.000 IICLISBEE LYMAN I
ON340W750 S410 DDDDDD435SOUTH 20037S22ESLWEST63-2
109-826 IIUnderground II liD 111977052311DIS 110.500110.000 IlcLISBEELYMAN I
D N315W450S41O DDDDDD435SOUTH 200
37S 22E SL WEST 63-2
1;=109=-8=3=1=IIUnderground II liT 111980051611DIS 110.015110.000 IIJ·KEITH ROGERS I
D~~~~~SW35 DDDDDD~~~OTHILL
109-832 "Underground II liT 11198005 1611DIS 110.015110.000 IIJ·KEITH ROGERS I
D~;;;~~~SW35 DDDDDD~~~OOTHILL
109-833 IlUnderground II lip 11198005161010.015110.000 IIJ·KEITH ROGERS I
D N1265W250 SE34 DDDDDD3488 NORTH
36S 22E SL FOOTHILL DRIVE
j=09=-8=34=llunderground II liT 111980051611DIS 110.015110.000 IIJ·KEITH ROGERS I
D N2208 E2252 S4 34 DDDDDD3488FOOTHILL
36S 22E SL DRIVE
109-843 lIunderground IDOI19900308IEJlo.015110.000 IP==I~~=~=K=~=S==S=AND=RA~II
D N2220 E1930 S4 34 DDDDDD864NORTH
36S 22E SL DAYBREAK DRIVE
109-860 Ilundergronnd II:~101197706zoIEJlo.0151Io·000 11=~u I
Di~~~~~7:W401 DDDDDDlp·O.BOX#822 I
109-871 IIUnderground II lip 11197706061010.015110.000 IIJESS M.GROVER I
D~:;~;i;~W4 36 DDDDDDIBLANDINGUT 845111
109-872 1!underground II:~10119770606IDlo.01511°·000 IIJESS M.GROVER I
Dij~Oz~::~W401 DDDDDDIBLANDING UT 845111
109-875 1!underground I~~10119770630IEJlo.0151Iz.5IZ IIAROE G.BROWN I
D~i;~~:i~o SEOI DDDDDDIBOXZ13 I
1°9-876 1Fndffground II:~IDI19770631EJlo.01+.400 I:!:s
D N1l50 W1900SEOl DDDDDD1527LINCOLN
37S 22E SL STREET APT.#4
1=09=-S=79=IIUnderground II lip 111977070610~10.000IiJAMES DEWEY AND I
01 IDDDDDDSHIRLEY LOU B.
BRADFORD
0 N570 W700 SE 36 DDDDDDI149 SOUTH 800 EASTI36S22ESL
109-885 Ilunder~und IDDI19770711IDr.D151Io·000 jl~~~~:n I
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[09-888 IFnder~und II:~ICII19770711IEJlo.01511°·ooo IF E.HALLIDAY 1
O~~~l~~;iNWll DDDDDDIBOX335 I
109-895 IIUnderground II liT 11198009251~]o.0151Io.000 IINELDON E.HOLT I
0~~~~zili~ON421 DDDDDD~OX394 I
109-896 Ilunder~und II:~ICI119770713IDlo.00711°·ooo IINELDON E.HOLT 1
0~ig~;:~~SW15 DDDDDDIBOX394 I
/09-906 IIUnderground II liT 1I1977071911DIS 110.015110.000 IIREED E.BAYLES I
0~~i~:~~S435 DDDDDD[p·O.BOX#203 1
109-914 IIUnderground II lip 11197707261[![]10.0151Io.000 IlEUGENE GUYMON I
0~i;~~li~FA02 DDDDDDlp·O.BOX#117 I
109-915 IIUnderground II Ilu 11197707261[![]!0.100Ijo.000 IIEUGENE GUYMON I
0~ig~~1~~FA02 DDDDDDr·O.BOX #117 I
109-925 lIunderground II::ID1197707281101S I[omsllo.ooo IrOROTHY PERKINS I
O;ii~cs FA0237S DDDDDD20SEAST 700 SOUTH
~Fnder~nnd IDDI19440929IDlo.013lr·oool~~~~~Y
0 N644 W855 SE 10 DDDDDD191 BUTTERNUT
37S 22ESL DRIVE NORTH
109-949 IIUnderground II liT 1I1977081611DIS 110.015110.000 "BERTHA SNYDER ,o S200 ESOO W401 DDDDDDlp.O.BOX 1318 I37S22ESL
109-954 IIUnderground 1\lip 1119770907l1DIS 110.015110;000 IlpHYLLIS·B.JONES I
D~i~~I;~O SE36 DDDDDDlpoOo BOX #472 1109-955 IIUnderground II lip 11197709071010.015110.000 110.FROST BLACK I
D
S175 E50 W4 36 36S DDDDDDlpoOBOX#71 122ESL
109-958 Ilunderground IDDI19770915IEJI0.0151Io·000 IRICHARD &NORMAN NIELSON
D
S2640 W400 NE 14 DDDDDDroOoBOX#245 I37S22ESL
1°90959 Ilunderground IDDBBBEJ NORMAN ANDRICHARDC.NIELSON
D
N1700 WIlOO SE 11
DDDDDD
63 NORTH 100 WEST37S22ESL(17-2)109-960 I!underground IDDI198806221EJIOo015110oooo I~~=~ON I
DS585E40W401 37S DDDDDD63NORlB lOOWEST22ESL(17-2)
109-977 1[underground IDDI1977100511DIS 110.015110.000 II~~J~1
D
N559 054 34 365
DDDDDD
60 NORTH 100 WEST22E5L(16-5)
1°9-983 I DDBEJBEJ PETERD.ANDUndergroundGEORGIAR.KARAME5INE5
D
N1270 W1980 SE 01
DDDDDD
1527 LINCOLN37522E5LSTREETAPT.#4
109-984 Ilunderground II:~IDI19771013IIDIO 110.015110.000 II=tLA 1DS545W505E403DDDDDDP.O.BOX #643,
37522ESL HIGHWAY 163NORTH
109-988 ljunderground IDD1198111171EJI°.oJ5110oo00 11~~~~Rn [
D
N700 W270 5E 36 DDDDDDlpoOoBOX#1357 136S22ESL
109-989 IIUnderground II liT 111977103111DO 110.015110.000 IIREX D.ANDERSON I
D~ig;~~~W415 DDDDDDroOoBOX569 I
109-990 Ilunderground II:~ID119771 lOIIEJI°.oJ511J.280 I~UGENE GUYMON I
D~isoo22~3g2FA02 DDDDDDr·O.BOX #117 I
109-993 IIUnderground II lip 111977102711Q[]0.0l51Io.000 IIBERNAL BRADFORDI
D~:;~~;20SE36 DDDDDDr·o.BOX #594 I
109.994 lunder~O~d 001197711081DI0.0151Io·000 ITh~fEtAND
D S660W660 l\TE32 DDDDDD675EAST 50038S22ESLSOUTH,5TH FLOOR
['12177 [Iundergro~d IDDI198202231f1S 1[°.01511°.000 II~i~~ALMER I
D S551 E1540 W4 01 DDDDDD12 EAST 5TH SOUTH37S22ESL107-5
1.13054 Ilundergro~d IDOI19831205IEJI°.Q15Ir·000 I:==~==~R=~==~=IE=L=S=ON~I
D;~~5S~0 W4 0137S DDDDDDlp.o.BOX #245 [
la20266 IIUnderground II liT 11197703151~12.0001l0.000 IIBLANDING CITY I
D~~:~~45NE35 DDDDDDI50WESTlooSOUTH I
la20266 IIUnderground II liT 11197703151~12.000110.00o IIBLANDING CITY I
D~~~:~~o NE35 DDDDDDI50WEST100 SOUTH I
['21545 Ilundergro~d II:~10119970915IEJlo.0(+730 I~~=Y 1
D N3055W1059 SE01 DDDDDD468NORTH 50037S22ESLWEST
1.24139 Ilunder~o~d II:~101200002011101S 110.000111.480 I~IANN==A=M=.RAFFE==R=T:=:;\TIi
D~~~02;~IS~NW22 DDDDDDr·O.BOX553 I
la35842.IIUnderground II Ilu .11200908191~12.000110.ooo IIBLANDING CITY I
D~i:~:i~~W401 DDDDDDI50WEST 100 SOUTH 1
la35842 IIUnderground II IIU 11200908191~12.0001l0.000 IIBLANDING CITY I
D~~:52;~3it412 DDDDDDI50WEST lOOSOUTH I
la35896 IIUnderground II IIU 11200909081~[QQQl14.730 I!MITCHELL H.&I
I II II II II 1001 IIJANA L.BAILEY I
D N256 W943 SE 16 DDDDDDI~~~·SHffi1TAIL I37S22ESL
!t89-09-01 IIUnderground II liT 11198901181~10.0001l5.000 IIlvAN R.WATKINS I
D S2722 ElO NW 01 DDDDDDIBOX938 I37S22ESL
/t89-09-021IUnderground II liT 11198905041~10.000115.000 IIIVAN R.WATKINS I
D S2722 ElO NW 01 DDDDDDfOX938 I37S22ESL
Groundwater use in the area is not expected to change significantly in the foreseeable future.
2.2.3 Provide updated il1formation on surface water and groundwater quality for potentially
impacted surface waters and groundwater out to at least a i-mile radius from the site.
Denison Response
a)Surface Water Quality
Updated information on surface water quality for potentially impacted surface waters out to at
least a I-mile radius from the site is set out in Sections 1.4.2 and 1.4.3 of the Reclamation Plan,
Rev.4.0.
b)Ground Water Quality
Updated information on groundwater quality for potentially impacted groundwater out to at least
a I-mile radius from the site is set out in Sections 1.5.2,1.5.3,1.5.4 and 1.5.5 of the Reclamation
Plan,Rev.4.0.
2.2.4 Please define the chemical characteristics ofexisting groundwater and surface water and
identify methods utilizedfor completing monitoring groundwater and surface water quality.
Denison Response
a)Chemical Characteristics
The chemical characteristics of the groundwater and smface water at the Mill site are included in the
discussions of groundwater and surface water quality in the Reclamation Plan,Rev.4.0,refened to in
Section 2.2.3 above.
b)Surface Water Monitoring
The following discussion is excerpted from Section 2.3 of the Reclamation Plan,Rev.4.0.
Surface water monitoring is conducted at two locations adjacent to the Mill facility known as
Westwater Creek and Cottonwood Creek.Samples are obtained annually from Westwater Creek
and quarterly from Cottonwood Creek using grab sampling.For Westwater Creek,samples are
of sediments if a water sample is not available.Field monitored parameters and laboratory
monitored parameters are listed in Table 2.2.3-1 below.For further procedural information see
Section 2.1 of the Mill's Environmental Protection Manual included as Appendix A to the 2007
License Renewal Application.See Section 1.4.3 of the Reclamation Plan,Rev.4.0 for a
summary of the historic results for surface water monitoring.
DENISON')~
MINES
21
Table 2.2.3-1
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater Creek and Cottonwood Creek
Field Requirements
1.temperature C;
2.Specific Conductivity umhos at 25 C;
3.pRat25C;
4.Sample date;
5.Sample ID Code;
Vendor Laboratory Requirements
*Semlannual sample must be taken a mlllimum of four months apart.
**Annual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuclides and LLDs reported in fJ Ci/ml
Semiannual*Quarterly
One gallon Unfiltered and Raw One gallon Unfiltered and Raw
One gallon Unfiltered,Raw and preserved to One gallon Unfiltered,Raw and Preserved to
pH <2 with RN03 pH <2 with HN03
Total Dissolved Solids Total Dissolved Solids
Total Suspended Solids Total Suspended Solids
Gross Alpha
Suspended Unat
Dissolved Unat
Suspended Ra-226
Dissolved Ra-226
Suspended Th-230
Dissolved Th-230 ..
c)Groundwater Monitoring
The following discussion is excerpted from Section 2.3 of the Reclamation Plan,Rev.4.0.
At the time of renewal of the License by NRC in March,1997 and up until issuance of the
GWDP in March 2005,the Mill implemented a groundwater detection monitoring program to
ensure compliance with 10 CFR Part 40,Appendix A,in accordance with the provisions of the
License.The detection monitoring program was in accordance with the report entitled,Points of
Compliance,White Mesa Uranium Mill,prepared by Titan Environmental Corporation,
submitted by letter to the NRC dated October 5,1994 (Titan,1994b).Under that program,the
Mill sampled monitoring wells MW-5,MW-ll,MW-12,MW-14,MW-15 and MW-17,on a
OENISONf)~~
MINES
22
quarterly basis.Samples were analyzed for chloride,potassium,nickel and uranium,and the
results of such sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports
that were filed with the NRC up until August 2004 and with the DRC subsequent thereto.
Between 1979 and 1997,the Mill monitored up to 20 constituents in up to 13 wells.That
program was changed to the Points of Compliance Program in 1997 because NRC had concluded
that:
•The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer;and
•The most dependable indicators of water quality and potential cell failure were
considered to be chloride,nickel,potassium and natural uranium.
(i)Issuance of the GWDP
On March 8,2005,the Executive Secretary issued the GWDP,which includes a groundwater
monitoring program that supersedes and replaces the groundwater monitoring requirements set
out in the License.Groundwater monitoring under the GWDP commenced in March 2005,the
results of which are included in the Mill's Quarterly Groundwater Monitoring Reports that are
filed with the Executive Secretary.
(ii)CUlTent Ground Water Monitoring Program at the Mill Under the GWDP
The CUlTent groundwater monitoring program at the Mill under the GWDP consists of
monitoring at 22 point of compliance monitoring wells:MW-1,MW-2,MW-3,MW-3A,MW-
5,MW-ll,MW-12,MW-14,MW-15,MW-17,MW-18,MW-19,MW-23,MW-24,MW-25,
MW-26,MW-27,MW-28,MW-29,MW-30,MW-31 and MW-32.The locations of these wells
<:\re indicated on Figure 2.2.3-1.
Part I.E.I.(c)of the GWDP requires that each point of compliance well must be sampled for the
following constituents:
Table 2.2.3-2
Groundwater Monitoring Constituents Listed in Table 2 of the GWDP
Nutrients:
Ammonia (as N)
Nitrate &Nitrite (as N)
Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
OENISONI)~~
MINES
23
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc
Radiologies:
Gross Alpha
Volatile Organie Compounds:
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)
Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
TDS
Further,Part 1.E.1.(c)of the GWDP,reqUIres that,111 addition to pH,the following field
parameters must also be monitored:
•Depth to groundwater
•Temperature
•Specific conductance,
OENISONI)~~
MINES
24
and that,in addition to chloride and sulfate,the following general orgamcs must also be
monitored:
•Carbonate,bicarbonate,sodium,potassium,magnesium,calcium,and total anions and
cations.
Sample frequency depends on the speed of ground water flow in the vicinity of each well.Parts
I.E.1(a)and (b)of the GWDP provide that quarterly monitoring is required for all wells where
local groundwater average linear velocity has been found by the Executive Secretary to be equal
to or greater than 10 feet/year,and semi-annual monitoring is required where the local
groundwater average linear velocity has been found by the Executive Secretary to be less than 10
feet/year.
Based on these criteria,quarterly monitoring is required at MW-ll,MW-14,MW-25,MW-26,
MW-30 and MW-31,and semi-mIDual monitoring is required at MW-1,MW-2,MW-3,MW-3A,
MW-5,MW-12,MW-15,MW-17,MW-18,MW-19,MW-23,MW-24,MW-27,MW-28,MW-
29 and MW-32.
(iii)Deep Aquifer
The Mill's culinary well (one of the Mill's supply wells)is completed in the Navajo aquifer,at a
depth of approximately 1,800 feet below the ground surface.Due to the fact that the deep
confined aquifer at the site is hydraulically isolated from the shallow perched aquifer (see the
discussion in Sections 1.5.1.1 and 1.5.1.2 of the Reclamation Plan,Rev.4.0)no monitoring of
the deep aquifer is required under the GWDP.
d)Seeps and Springs Monitoring
Pursuant to Part l.H.8 of the GWDP,Denison has a Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill,Revision:0,March 17,2009 (the "SSSP")that
requires the Mill to perform groundwater sampling and analysis of all seeps and springs found
downgradient or lateral gradient from the tailings cells.
Under the SSSP,seeps and springs sampling is conducted on an annual basis between May 1 and
July 15 of each year,to the extent sufficient water is available for sampling,at five identified
seeps and springs near the Mill.The sampling locations were selected to correspond with those
seeps and springs sampled for the initial Mill site characterization performed in the 1978 ER,
plus additional sites located by Denison,the BLM and Ute Mountain Ute Indian Tribe
representatives.
Samples are analyzed for all ground water monitoring parameters found in Table 2.2.3-2 above.
The laboratory procedures utilized to conduct the analyses of the sampled parameters are those
utilized for groundwater sampling.In addition to those laboratory parameters,the pH,
temperature and conductivity of each sample is measured and recorded in the field.Laboratories
selected by Denison to perform analyses of seeps and springs samples are required to be certified
by the State of Utah in accordance with UAC R317-6-6.12.A.
OENISONI)J
MINES
25
The seeps and springs sampling events are subject to the White Mesa Uranium Mill Ground
Water Monitoring Quality Assurance Plan (QAP)(the "QAP"),unless otherwise specifically
modified by the SSSP to meet the specific needs of this type of sampling.
2.3 INTERROGATORY WHITE MESA CELL 4B VAC R313-24-3-01C/Ol:
ENVIRONMENTALANALYSIS -ALTERNATIVES
INTERROGATORY STATEMENT:
2.3.1 Add a section to the ER that discusses the second alternative identified in the introduction to
Chapter 11,namely,"Amend the license to include the construction ofCell4B with such additional
conditions as are considered necessary or appropriate to protect public health,safety,and the
environment...."
Denison Response
Denison believes that the Amendment Request is complete and that the proposed design of Cell
4B and the additional monitoring proposed in Section 10.2 of the 2008 ER are adequate to
protect public health,safety,and the environment,without the need to add any additional
conditions to the License.Of course,in reviewing the application,the Executive Secretary will
have to make his own determination as to whether or not any additional conditions are necessary.
Denison does not believe that a Section to that effect needs to be added to the 2008 ER.
2.3.2 Estimate the increase in operating and closure costs that has occurred since the costs were
estimatedfor the last license renewal.
Denison Response
Closure costs are estimated annually as required by License condition 9.5 and submitted to the
Executive Secretary for approval.The most recent update in closure costs is set out in Attachment
C to the Reclamation Plan,Rev.4.0.
The operating costs ofthe facility are proprietary and not relevant to the Amendment Request.
Denison and the Executive Secretary will estimate the additional closure costs associated with Cell
4B after the design of Cell4B is approved and prior to commencement of operation of Cell4B.The
Mill's surety will be updated at that time to reflect those additional costs.
2.3.3 Justify the statement that the "...costs associated with the operation ofthe Mill have not
changed significantly but the benefits have become more evident over time as the number of
uranium mills has dwindled and the demandfor uranium milling services from local miners and the
industry as whole has increased."
OENISOJ)~~
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Denison Response
Costs associated with the operation of the Mill have increased roughly with the rate of inflation
since the Mill was first constructed.There have also been other increases in operational costs
associated with changes in regulatory requirements.Those increases in costs are not unlike the
increases in costs for uranium mines and for similar facilities in other industries.
However,at the time the Mill was originally constructed there were a number of other operating
uranium mills in the United States that were able to provide toll milling services to nearby uranium
mines.The Mill is now the only operating uranium mill in the United States.The cost and time
associated with permitting and constructing a new uranium mill or in re-pelmitting for operation
one of the three other existing non-operational uranium mills in the United States would be
significant.As a result,over the next several years,the Mill ill be the only alternative for all of the
conventional uranium mines in the United States.The increases in the benefits of keeping the Mill
in production at this time are therefore evident.
It should be kept in mind,however,that the Amendment Request is not an application for the
License or for renewal of the License as a whole,which are addressed in the 2007 License
Renewal Application and in the 2007 ER,nor is it an application for approval of the siting and
use of Cell 4B,which have already been evaluated and approved and are included in the License
as part of the original approval of the tailings management system for the Mill.Rather,the
Amendment Request is for the more detailed amendments to the License required in connection
with the actual construction and operation of Cell 4B.It is therefore not appropriate to re-
analyze the costs and benefits of the Mill as a whole or the costs and benefits of the construction
of Cell 4B.Cell 4B will basically be the same design as existing Cell 4A,the construction and
operation of which have been approved by the Executive Secretary,and which is located
immediately adjacent to proposed CeIl4B.
2.3.4 Present and justify the criteria used for assessing and comparing benefits and costs where
these are expressed in nonmonetary or qualitative terms.
Denison Response
The Amendment Request is not an application for the License or for renewal of the License as a
whole,which are addressed in the 2007 License Renewal Application and in the 2007 ER,nor is
it an application for approval of the siting and use of Cell 4B,which have already been evaluated
and approved and are included in the License as part of the original approval of the tailings
management system for the Mill.Rather,the Amendment Request is for the more detailed
amendments to the License required in connection with the actual construction and operation of
Cell 4B.It is therefore not appropriate to re-analyze the costs and benefits of the Mill as a whole
or the costs and benefits of the construction of Cell 4B.Cell 4B will basically be the same
design as existing Cell 4A,the construction and operation of which have been approved by the
Executive Secretary,and which is located immediately adjacent to proposed Cell 4B.The costs
and benefits associated with Cell 4B will therefore not be significantly different from the costs
and benefits associated with the previously approved Cell 4A.
OENISOJ)J
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2.3.5 Summarize and update estimated costs and benefits that were earlier estimated and reported
(namely Tables 11.0-1 and 11.0-2 originally presented in D&M 1978).
Denison Response
See Section 2.3.4 above.
2.3.6 Provide additional support using current information for the statement at page 34 of the
Cell 4B ER that "There have been no significant changes to the costs [and benefitsJ associated with
the Mill since the last license renewal in 1997 ...."Provide a benefit-cost evaluation in the form
ofa narrative accompanied by tables and charts.
Denison Response
See Section 2.3.4 above.
2.3.7 Present or cite and summarize (including concise citations)objective evidence that supports
the Cell 4B ER statement on page 31 that "The Mill has demonstrated that it is capable of
continuing to operate in a manner that satisfies all regulatory standards and ALARA goals ...."
Explain how the Notice and Violation and Groundwater Corrective Action Order issued by the
Utah Department ofEnvironmental Quality in 1999 affects confidence that amending the license to
allow construction ofCell 4B will be successfully accomplished and properly operated.Explain why
the necessity for this Notice and Violation and Groundwater Corrective Action Order and DUSA 's
responses do not affect the Division's confidence that the Mill will continue "...operate in a
manner that satisfies all regulatory standards ...."
Denison Response
The Mill has been operating since 1980 and has been inspected by NRC up until August 2004 and by
DRC since that time.The License was renewed in 1985 for five years and in 1997 for ten years,all of
which demonstrates that the Mill is capable of operating in a manner that satisfies all regulatory
standards and as low as reasonably achievable ("ALARA")goals.Further,the periodic reports filed
with the Executive Secretary all demonstrate that the Mill is operating in compliance with all
regulatory standards and ALARA goals.Those Reports are inspected by DRC.
The Amendment Request is not an application for the License or renewal ofthe License as a whole,
which are addressed in the 2007 License Renewal Application and the 2007 ER.
The Notice and Violation and Groundwater Corrective Action Order issued by the Utah
Department of Environmental Quality in 1999 relates to chlorofOlm contamination that predates
Mill operations and has nothing to do with the Mill's ability to continue to operate in a manner that
satisfies all regulatory standards and ALARA goals.The chlorofOlm contamination at the Mill site
has been attributed to the operation of a temporary laboratory facility that was located at the site prior
to and during the construction of the Mill facility,and from septic drain fields that were used for
laboratory and sanitary wastes prior to construction ofthe Mill's tailings cells.In April 2003,Denison
OENISOJ)JJ
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commenced an interim remedial program of pumping the chloroform contaminated water from the
groundwater to the Mill's tailings cells.This will enable Denison to begin clean up of the
contaminated areas and to take a further step towards resolution of this outstanding issue.Pumping
from the wells continues at this time.Denison is continuing to work with the State of Utah to develop
a long-tenll conective action plan.A draft of an action plan was submitted and is cWTentIy being
reviewed by the State.See Section 2.1.8 above.
2.4 INTERROGATORY WHITE MESA CELL 4B UAC R313-24-3-0ID/OI:
ENVIRONMENTAL ANALYSIS-LONG-TERM IMPACTS
INTERROGATORY STATEMENT:
2.4.1 Please provide an updated Reclamation Plan that considers the current concept of
fully utilizing Cells 4A and 4B for tailings management,including the long term stabilization and
disposal of tailings.The updated Reclamation Plan must account for the use of these two cells for
disposal,which will·directly impact the length of slopes,precipitation runoff rates and volumes,
design ofthe top cap,and design ofthe cap side slopes including rock sizing andfill depth.
Denison Response
The Reclamation Plan,Rev.4.0,was submitted to DRC on November 23,2009.The Reclamation
Plan,Rev.4.0 presents the plan for reclamation of the site as it exists today,prior to the constlUction
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.Figure 2.4.1-1 presents the concept for final
reclamation of Cell 4B.As one of several conditions to the GWDP,an infiltration analysis of the
tailings cover and re-design of the cover for better perfollllance is in progress.The final revised cover
design will address swface water management issues associated with the addition ofCell 4B.
2.4.2 Assess and report the geotechnical stability of the tailings impoundment,including
slope stability,liquefaction,and settlement.
Denison Response
The geotechnical stability of the tailings impoundment,slope stability,liquefaction potential and
settlement were addressed in Appendix D ofthe Reclamation Plan,Rev.4.0.
2.4.3 Prepare and submit the updated Reclamation Plan,and,in particular,discuss the
final cover and long-term stabilization design for the facility,including Cell 4B (and Cell 4A),
according to requirements ofNUREG-1620 and in accordance with 10CFR40 -Appendix A,Criteria
6(3)and 6A(1).
Denison Response
See Section 2.4.1 above.
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2.4.4 Address slope stability,liquefaction,and settlement in accordance with NUREG-1620.
Address the hydrologic characteristics ofthe site,including flooding potential,and erosion protection
features ofthe tailings impoundment.
Denison Response
See to 2.4.2 above.
2.4.5 Address the radiation protection design of the tailings disposal impoundment cover
for radon and gamma attenuation.
Denison Response
The CUlTent tailings cover design,included as Appendix D to the Reclamation Plan,Rev.4.0 includes
an analysis of radon and gamma attenuation characteristics of the proposed cover.The re-designed
cover,discussed in Section 2.4.1 above,will include an updated analysis of radon and gamma
attenuation characteristics of the re-designed cover.
2.4.6 Evaluate the potential for settlement ofthe tailings impoundment and cracking ofthe
radon barrier that might result.
Denison Response
See the response to Section 2.4.2 above.Settlement monitors are installed over areas of tailings that
have reached the final design grade for the disposal cell.The vertical movement of those monitors is
evaluated during the placement ofthe initial platform fill and the dewatering of the disposal cell.Final
cover placement will take place after most of the settlement has occulTed,reducing the potential for
differential settlement and cracking ofthe radon barrier.
2.4.7 Address plans for reclaiming and restoring lands disturbed by mining and milling
activities.
Denison Response
A description of the complete site reclamation activities is included in Section 3 and Attachment
A of the Reclamation Plan,Rev.4.0.
2.4.8 Estimate costs to implement the Reclamation Plan activities and state the financial
Arrangements necessary to provide requiredfinancial assurances.
Denison Response
Cost estimates for implementation of the current Reclamation Plan are included in Attachment C
to the Reclamation Plan,Rev.4.0.Estimated costs are guaranteed by surety bond from National
Union Fire Insurance Company of Pittsburgh,PA,held by the Executive Secretary.
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2.4.9 Assess and describe the long-term environmental impacts resulting from all proposed
reclamation activities.
Denison Response
The Mill buildings and non-tailings areas of the Mill facility will be cleaned up and deposited into the
Mill's tailings cells.Impacted soils in the vicinity of the Mill will be cleaned up and placed into the
Mill's tailings cells.The Mill's tailings cells will be capped in place and transfened to DOE for
perpetual care and maintenance.
The long-term environmental impacts resulting from all proposed reclamation activities will therefore
be within regulatory standards,will be subject to perpetual institutional care and maintenance and,as a
result will be minimal.See also Section 2.1.11 above.
2.4.10 Estimate decontamination criteria derived concentration guidelines (DCGLs)for
primary radionuclides.State data quality objectives (DQOs)for radiological surveys and sampling.
Provide final verification (status survey)plans and procedures.
Denison Response
Assessment and cleanup verification of radiological site contamination is described in Sections 3.2
and 3.3 of Attachment A to the Reclamation Plan,Rev.4.0.See also Section 2.1.11 above.
2.5 INTERROGATORY WHITE MESA CELL 4B lOCFR40.26(C)(2)-02/01:GENERAL
UCENSE
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.6 INTERROGATORY WHITE MESA CELL 4B lOCFR40.31(H)-03/01:APPUCATION
FOR SPECIFIC UCENSES
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
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2.7 INTERROGATORY WHITE MESA CELL4B lOCFR40.61-06101:RECORDS
INTERROGATORYSTATEMENT:
To Be Detennined.
Denison Response
No comment at this time.
2.8 INTERROGATORY WHITE MESA CELL 4B lOCFR40.65(A)(l)-0710l:EFFLUENT
MONITORING REPORTING REQUIREMENTS.
INTERROGATORY STATEMENT:
Assess the extent to which meteorological characteristics in the vicinity of the facility have changed
since the Environmental Report was revised to account for such changes.Present revised
meteorological characteristics.
Denison Response
See Section 2.1.1 above.
2.9 INTERROGATORY WHITE MESA CELL 4B lOCFR40.INTRODUCTION-OSIOl:
CAPACITY OF TAIliNGS OR WASTE SYSTEMS OVER THE liFETIME OF MILL
OPERATIONS
INTERROGATORY STATEMENT:
To Be Detennined.
Denison Response
No comment at this time.
2.10 INTERROGATORY WHITE MESA CELL 4B lOCFR40 APPENDIX A,
INTRODUCTION-0910l:ALTERNATIVE REQUIREMENTS
INTERROGATORYSTATEMENT:
To Be Detennined.
Denison Response
No comment at this time.
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2.11 INTERROGATORY WHITE MESA CELL 4B 10CFR40 APPENDIX A,CRITERION 1-
10/01:PERMANENTISOLATION WITHOUT ONGOING MAINTENANCE
INTERROGATORYSTATEMENT:
2.11.1 Refer to Section 14.0 of the Environmental Report and the Reclamation Plan,White
Mesa Mill,Blanding,Utah (IVC 2000):
Please demonstrate that previously submitted analyses ofslope stability,settlement,and liquefaction
are applicable to the design of Cell 4B and that confidence exists that Cell 4B will remain stable
following closure,reclamation,and stabilization.
Denison Response
The geotechnical stability of the tailings impoundment,slope stability,liquefaction potential and
settlement were addressed in Appendix D of the Reclamation Plan,Rev.4.0.The liquefaction
potential ofthe tailings solids was evaluated in Attachment E to the Reclamation Plan,Rev.4.0.
2.11.2 Please provide information,analyses,and discussion to demonstrate that tailings will
be disposed ofin a manner that requires no active maintenance to preserve conditions ofthe site or to
protect human health and the environment from hazards the tailings might otherwise present.To the
extent that such information,analyses,and discussion have been presented previously,please
summarize pertinent information,including concise citations to previously submitted documents,and
justify their applicability to the Cell 4B closure design.
Denison Response
Denison is cunently operating Cell 4A under the DRC-approved Cell 4A BATMonitoring,Operations
and Maintenance Plan.The Plan describes the acceptable methods for discharge into the cell of
tailing solids and solution from pre-determined locations around the perimeter of the cell.Tailings
will continue to be discharged up to the top of the flexible membrane liner (FML),at which time the
tailings solids will be contoured to final grades and the dewatering process will begin concunently
with placement of the initial platform fill.A similar BAT Monitoring,Operations and Maintenance
Plan will be proposed prior to final approval of CeIl4B.Installation of the final reclamation cap will
be in accordance with the Reclamation Plan approved at the time of cell closure.The Reclamation
Plan is intended to allow for transfer of the reclaimed site to DOE for perpetual care and maintenance,
funded by the site licensee's Long Term Care fund.
2.12 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIXA,CRITERION
2-11/01:PROliFERATION
INTERROGATORY STATEMENT:
To Be Determined.
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Denison Response
No comment at this time.
2.13 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIXA,CRITERION 3-
12/01:PLACEMENTBELOW GRADE
INTERROGATORY STATEMENT:
To Be Detennined.
Denison Response
No comment at this time.
2.14 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIXA,CRITERION 4-
13/01:LOCATIONAND DESIGN REQUIREMENTS
INTERROGATORY STATEMENT:
2.14.1 Indicate,out to 8-km (5-mi)radius,the nature and extent ofpresent and projected
land use (e.g.,agriculture,livestock raising,dairies,pasturelands,residences,wildlife preserves,
sanctuaries,hunting areas,industries,recreation,transportation)and any recent trends such as
major orunexpected changes in population or industrial land use patterns.
Denison Response
See Section 3.10 of the 2007 ER and Section 2.5 of the FES.Land use has not changed significantly
in the area of the Mill since the FES,with the exception that the nearest residence is now
approximately 1.6 miles from the Mill,whereas the nearest residence at the time of the FES was
approximately 4.8 miles from the Mill.However,the Mill's 2008 MILDOS Evaluation modeled the
nearest potential residence,which is at the northem boundary of the Mill property,approximately 1.2
miles from the Mill and some 0040 miles closer to the Mill than the cunent actual nearest residence.
See Section 2.1.3 above.
Populations within a 50-mile radius ofthe Mill have also been updated since the FES and are included
in Section 4.0 of the 2008 ER and Section 3.9 of the 2007 ER.These updated demographics are
incorporated into the 2008 MILDOS Evaluation.
No significant trends are expected in population or industrial use patterns in the foreseeable future.
2.14.2 Identify the location,nature,and amounts ofpresent and projected ground-water use
(e.g.,water supplies,irrigation,reservoirs,recreation,and transportation)within 16 km (10 mi)ofthe
site and the present and projected population (during the active life ofthe mill)associated with each
use point.Infonnation providedfor each use point should include:
OENISONI)~~
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•Location
•Distance from mill
•Withdrawal rate
•Return rates
•Type ofwater use
•Depth ofwells
•Groundwater elevation
•Drawdown rates
•Source and projection ofwater-use estimates
Denison Response
There have been no significant changes to the locations,distances from the Mill,withdrawal rates,
return rates,type of water use,depth of wells,groundwater elevation,drawdown rates or source of
projection of water use estimates downgradient of the proposed Cell 4B,since the FES,other than as
described in Section 2.2.2 above.
As the Amendment Request is not an application for licensing of the Mill as a whole,Denison does
not believe that the other information requested above is relevant to the Amendment Request.
2.14.3 Provide descriptive information to give recent changes in the locations and
populations ofneighboring schools;facilities;hospitals;and residential areas within 8 km (5 mi).
Denison Response
See the discussion in Section 2.14.1 above.There have not been any significant changes in the
locations and populations of neighboring schools,facilities;hospitals;and residential areas within 5
miles from the Mill.The 2008 M~DOS Evaluation takes into account recent demographic
infOlmation within a 50-mile radius of the Mill,and calculates the dose to the nearest potential
residence,which is at the northern boundary of the Mill.Therefore the potential radiological impacts
from the addition ofCell4B on populations and neighboring residences has been taken into account in
that modeling.
2.14.4 Demonstrate that soils in the area where Cell 4B will be constructed are not unstable
because oftheir physical or chemical properties,locations,and dimensions.Address compressibility;
rate of consolidation;shear strength (including,for sensitive soils,possible loss of shear strength
resulting from strain-softening);liquefaction potential;permeability;dispersion characteristics;
swelling and shrinkage;long-term moisture content for radon barrier material;and cover cracking.
Denison Response
Site characteristics and physical properties of the construction materials and the final stability of
the Cell 4B impoundment are presented in the Design RepOlt.Cover material characteristics and
cover performance are described in Appendix D ofthe Reclamation Plan,Rev.4.0.Liquefaction
potential of the tailings material is discussed in Attachment D to the Reclamation Plan,Rev.4.0.
OENISONI)~~
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2.14.5 Update records ofhistorical ground-water-level fluctuations at the site.
Denison Response
Figures 2-5 of the Rep0l1 entitled Site Hydrogeology and Estimation ofGroundwater Travel Times in
the Perched Zone,White Mesa Uranium Mill Site Near Blanding,Utah,dated August 27,2009,
prepared by Hydro Geo Chern,Inc.,included as Appendix A to the 2009 GWDP Renewal
Application,are perched groundwater contour elevation maps for the years 1990, 1994,2002 and
2009 respectively.Those Figures identify the mounding in the perched zone at the locations of the
three wildlife ponds and the impacts of such mounding on perched zone water levels at the site,due to
the periodic recharge ofthose ponds with water from Recapture Reservoir commencing around 1994.
See also:(1)Figure 7 of the Existing Well Background Rep0l1,which contains hydrographs of Mill
site monitoring wells showing groundwater elevation trends over time in monitoring wells at the site;
(2)Figure 8 of the Existing Well Background Rep0l1,which shows the spatial distribution of water
level changes from 1994 to 2001;and (3)the discussion in Section 8.3 ofthat Report
2.14.6 Please state the proposed maximum slope ofthe stabilized tailings impoundment that
includes the Cell 4B area.Justify any slope steeper than 5h.·1v and explain why gentler slopes are
impracticable.Identify and justify any design enhancements incorporated to provide assurance that
the stabilized impoundment will remain stable without reliance on active measuresfollowing closure.
Denison Response
All slopes on the reclaimed Mill site and tailings are 5h:1v or less (gentler).As one of several
conditions in the GWDP,an infiltration analysis of the tailings cover and re-design of the cover for
better perfOlmance is in progress.The final revised cover design will address surface water
management issues and other design improvements associated with the addition ofCeIl4B.
2.14.7 Describe measures taken to stabilize the final cover system following closure that
includes the Cell4B area.
Denison Response
Cover stability is discussed in the Reclamation Plan,Rev.4.0.The Reclamation Plan will be fulther
revised to incorporate the addition of Cell 4B prior to acceptance and authorization for use by the
Executive Secretary.
2.14.8 Discuss the most recent data on seismic events in the region that are applicable to
the White Mesa site and identify any implications for design criteria applicable to the design ofthe
facility,including the final closure design for Cell 4B,for ensuring long-term stability;and present
andjustify the results ofany design calculations prepared to incorporate any revised design criteria.
OENISOJ)J
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Denison Response
Seismic design information is included in the Design Report,and the Reclamation Plan,Rev.
4.0.
2.14.9 Identify any changes in the nature and extent ofpresent and projected land use (e.g.,
agriculture,livestock raising,dairies,pasturelands,residences,wildlife preserves,sanctuaries,
hunting areas,industries,recreation,transportation)that have occurred since the 1978 ER (D&M
1978)was prepared.Identify any recent trends such as major or unexpected changes in population or
industrial patterns have occurred since the 1978 ER (D&M 1978)was prepared.
Denison Response
There have been no significant changes in the nature and extent ofpresent and projected land use (e.g.,
agriculture,livestock raising,dairies,pasturelands,residences,wildlife preserves,sanctuaries,hunting
areas,industries,recreation,transportation)that have occurred since the 1978 ER was prepared nor
have there been any significant recent trends such as major or unexpected changes in population or
industrial patterns since the 1978 ER,other than the location of the nearest residence.As discussed
above,the nearest actual residence is now approximately 1.6 miles from the Mill,as opposed to the
nearest actual residence at the time of the 1978 ER,which was approximately 4.8 miles from the Mill.
For the purposes of evaluating radiological doses from the addition of Cell 4B,as set out in the 2008
MILDOS Evaluation,the dose at the nearest potential residence,located approximately 1.2 miles
north of the Mill and some 0.40 miles closer to the site than the CUlTent actual nearest residence,has
been calculated as the dose to the person likely to receive the highest dose from Mill operations.
Recent data on populations within a 50 mile radius are also factored into the 2008 MILDOS
Evaluation.Cattle grazing on lands abutting the Mill's restricted area is similar to grazing that
occurred at the time ofthe 1979 ER,and is taken into account in the 2009 MILDOS Evaluation.
2.14.10 Provide in tabular form for each of the 22-1!2-degree sectors,the distances [to a
distance of8 km (5 mi)lfrom the center ofthe site to thefollowing:
•Nearest cattle (or other meat animals)grazing on natural forage,with types and
numbers ofanimals specified.
•Nearest game animals consumed by sportsmen.
•Nearest residence.
•Nearest site boundary.
•Nearest vegetable garden larger than 50 m2 (60 yd2)in area.The type ofcrop and
amounts produced should be noted.
Denison Response
The Mill and Cell 4B are already sited and the Mill is an existing operating facility.Therefore,
Denison does not believe that all of the requested information is relevant to the Amendment Request.
OENISOJ)~~
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The 2008 MILDOS Evaluation estimated the dose to a nwnber of receptors including the nearest
potential residence,located approximately 1.2 miles north of the Mill facility at the northern boundary
ofthe Mill propelty,based on all plausible exposure pathways.
MILDOS-AREA calculates the impacts based on mlliual average air concentrations of radionuclides
considered.The human pathways considered in MILDOS-AREA for individual and population
impacts are:inhalation,external exposure from groW1d concentrations,external exposure from cloud
immersion,ingestion of vegetables,ingestion ofmeat and ingestion ofmilk.
With respect to the ingestion of vegetables,the 2008 MILDOS Evaluation incorporated the default
provisions of the MILDOS-AREA code,which assume that nearby receptors consume specified
percentages of their total vegetable consumption from vegetables grown at their respective receptor
locations.
With respect to ingestion of meat and milk,the m'ea immediately north of the Mill is used only for
grazing of beef cattle.A second location to the east and south of the Mill is also used for the grazing
of beef cattle.Although considered unlikely,the 2008 MILDOS Evaluation contemplated that in one
worst case scenario,it is possible that the beef cattle grazed at these locations would be eaten by the
residents near the Mill.A scenario which SUppOltS dairy cattle grazing at these locations was not
included in the modeling because the prospect of SUppOlting dairy cattle grazing near the Mill is not
credible, given the arid climate and the much lm'ger feed requirements of dairy cattle as opposed to
beef cattle.Fwther,no dairy cattle have been observed near the Mill.The 2008 MILDOS evaluation
assumed,as a worst case scenario,that the inhabitants at the nearest potential residence consumed all
of their beef from the cattle grazing at the locations near to the Mill described above,which,based on
historic grazing practices,were asswned to graze at those locations for two months each yem'.The
2008 MILDOS Evaluation also conservatively assumed that such residents drank all of their milk
from cows that grazed at the location of the nem'est potential residence.
In this worst case scenm'io,the total dose to the person most likely to receive the highest exposure (i.e.,
residents at the nearest potential residence)was calculated to be well below the regulatory limit.See
Section 5.0 ofthe 2008 MILDOS Evaluation.
2.14.11 Provide data on annual production and distribution of meat (kg)and truck farming
produce (kg)within an 80-km (50-mi)radius from the proposed facility.Provide information on
grazing season (months ofyear)andfeeding regimens for cattle.Please provide specific information
on actual consumption ofthe meatfrom cattle and game animals.
Denison Response
See Section 2.14.10 above.
2.14.12 Identify any changes in the locations,natures,and amounts ofpresent and projected
surface and ground-water use (e.g.,water supplies,irrigation,reservoirs,recreation,and
transportation)within 16 km (10 mi)ofthe site.
OENISOJ)~
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Denison Response
See Section 2.2.2 above.There are no expected changes in the locations,natures,and amounts of
present and projected surface and ground-water use within five miles downgI"adient of the site.
2.14.13 Identify any changes in the present and projected population (during the active life of
the mill)associated with each use point,where appropriate.
Denison Response
See Section 2.2.2 above.There are no expected changes in the present and projected population
associated with each use point during the active life of the Mill.
2.14.14 Summarize and tabulate data on changes in both present and projected future water
use;locate users on maps oflegible scale.Tabulations should include:
•Location:Changes in locations ofwater users.
•Distances ofuserfrom mill.
•Withdrawal rate:Changes in present and projected withdrawal rates (in liters per
second or cubic meters per second)for each water use,including seasonal
variability.
•Return rates:Changes in present and projected return rates (in liters per second
or cubic meters per second),ifappropriate,including seasonal variability..
•Type of water use:Changes in types of water use for each location,e.g.,
municipal,industrial,irrigation,stock/game watering.
•In addition,for ground-water use:Indicate changes in depths of wells,
groundwater elevation,and drawdown rates and characterize the use of each
aquifer.
•Source and projection ofwater-use estimates:Where use rates are anticipated to
change over the life ofthe project and beyond,indicate projections and the source
ofthe projection information.
Denison Response
See Section 2.2.2 above.
2.14.15 Provide changes in the projected population by direction and distance from the site
within a 5-mile radius of the mill for the anticipated life ofthe mill.Identify and discuss significant
transient or seasonal population variations,including the basesfor assumptions and projections.
Denison Response
See Section 2.14.1 above.There are no expected significant changes in the projected population by
direction and distance from the site within a 5-mile radius of the Mill for the anticipated life of the
Mill.Further,as discussed in Sections 2.1.3 and 2.14.10 above,the 2008 MlLDOS Evaluation
OENISONf)~~
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models the nearest potential residence and concludes that the expected dose to that receptor is well
within regulatory standards and ALARA goals.
There are no significant transient or seasonal population variations applicable to the area ofthe Mill.
2.14.16 Provide an evaluation ofchanges in prominent meteorological parameters prevailing
at the site that have occurred since the 1978 ER (D&M 1978)was prepared.Summarize site
meteorology based on meteorological measurements taken onsite and at nearby representative
stations,including:
•Quarterly and annual wind rose presentationfor the 16 compass directions.
•Quarterly and annual wind speed,wind direction,and atmospheric stability data
in jointfrequency form at heights representative ofeffluent releases.
•Total precipitation and evaporation by month.
•Diurnal and monthly averages and extremes oftemperature and humidity
•Monthly wind characteristics including speeds and direction,annual joint
frequency ofwindspeed,and direction by stability category
•Data on precipitation
•Frequency of occurrence and effects ofstorms.
Denison Response
See Section 2.1.1 above.
2.14.17 To the extent warranted by changes in site meteorology,Identify andjustify changes in
design features that may resultfrom any changes in design basis events.
Denison Response
See Section 2.1.1 above.There have been no significant changes in site meteorology.
2.14.18 Present and justify background concentrations of radionuclides in groundwater that
has resultedfrom responding to recent Division directives (URS 2008).
Denison Response
The determination of background concentrations of radionuclides and all other constituents of concern
at the Mill site has been the subject of the Background Reports,the Summary ofWork Completed,
Data Results,Interpretations and Recommendations for the July 2007 Sampling Event at the Denison
Mines,USA,White Mesa Uranium Mill Near Blanding Utah,dated May 2008,prepared by T.Grant
Hurst and D.Kip Solomon of the University of Utah,Depmtment of Geophysics,and other analyses.
The background concentrations of radionuclides and all other constituents of concern determined by
DRC,based on the foregoing analyses,and the rationale for that determination are set out in the 2009
Statement ofBasis.
OENISONI)~J
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2.14.19
following:
•
•
•
•
•
•
•
•
Present and justify parameter values used to characterize mill tailings,including the
Compressibility and rate ofconsolidation
Shear strength,including,for sensitive soils,possible loss of shear strength
resulting from strain-softening
Liquefaction potential
Permeability
Dispersion characteristics
Swelling and shrinkage
Long-term moisture content for radon barrier material
Cover cracking.
Denison Response
Material characteristics of tailings material and cover soils are included in the 1978 ER,and the
Reclamation Plan,Rev.4.0,Appendix D.
2.14.20 Provide a detailed description of the applicable field and laboratory investigations
and testing that were completed,and summarize material properties (e.g.,permeability,moisture-
density relationships,gradation,shrinkage and dispersive characteristics,resistance to freeze-thaw
degradation,cracking potential,and chemical compatibility,including any amendment materials).
Denison Response
Material characteristics of tailings material and cover soils are included in the 1978 ER,and the
Reclamation Plan,Rev.4.0,Appendix D.
2.14.21 Present details (including sketches)of the disposal cell cover termination at
boundaries,with any considerationsfor safely accommodating subsuiface waterflows.
Denison Response
Surface water management and erosion protection design is presented in Attachment A and
Attachment G of the Reclamation Plan,Rev.4.0.
2.14.22 Provide a schematic diagram displaying various disposal cell layers and thicknesses.
Establish the particle size gradation ofthe disposal cell bedding layer and the rock layer to ensure
stability against particle migration during the period ofregulatory interest.
Denison Response
Tailings cell cover design and material characteristics are detailed In Attachment A and
Attachment G of the Reclamation Plan,Rev.4.0.
OENISOJ)~~
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41
2.14.23 Demonstrate that the effects ofpossible freeze-and-thaw cycles on soil strength and
radon barrier effectiveness do not compromise their long-term stability or ability to function as
required.Demonstrate that freezing and formation of ice crystals and lenses will not cause heaving.
Demonstrate that soil is not susceptible to frost heave,considering that uniformly graded soils
containing more than 10 percent ofparticles smaller than 0.02 mm and well-graded soils with more
than 3 percent ofparticles smaller than 0.02 mm are susceptible.
Denison Response
Material characteristics of tailings material and cover soils and an analysis of freeze-thaw cycles
on the radon barrier are included in the 1978 ER,and the Reclamation Plan,Rev.4.0,Appendix
D.
2.14.24 Present an analysis ofthe potential for cracks to develop in the disposal cell cover as
a result ofdifferential settlement andshrinkage.
Denison Response
Settlement monitors are installed over areas of tailings that have reached the final design grade
for the disposal cell.The vertical movement of these monitors is evaluated during the placement
of the initial platform fill and the dewatering of the disposal cell.Final cover placement will take
place after most of the settlement has occurred,reducing the potential for differential settlement
and cracking of the radon barrier.Liquefaction of the tailings solids due to seismic events and
the potential impact on the cell cover is discussed in Attachment E to the Reclamation Plan,Rev.
4.0.Additional analysis,if necessary,will be conducted as a part of the cell cover re-design
discussed in response to Section 2.4.1 above.
2.14.25 Demonstrate that any geomembranes included in the final cover(s)are adequate for
the proposed disposal cell cover and describe their major properties (e.g.,physical,mechanical,and
chemical).Discuss methods for membrane installation.Demonstrate that the shear strength of the
interface between compacted clay and geomembranes is appropriately considered in the stability
analyses under both static and dynamic loads is noted.
Denison Response
No geomembranes are planned for use in the final cover.
2.14.26 Demonstrate that information on site characterization,slope stability,settlement,and
liquefaction used in the disposal cell cover design is appropriately reflected in the evaluation,and
therefore,constitutes inputs that would contribute to the demonstration of disposal cell design
compliance with the regulations.
Demonstrate that the design erosion protection covers for the site conform to the suggested
criteria in NUREG-1623 (NRC 2002).Demonstrate that the proposed cover design will meet
longevity requirements without the use ofactive maintenance.
OENISONJ)~
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Denison Response
Tailings cell design and cover design were based on then cUlTent NRC guidance at the time of
approval by NRC in 2000.A review of the current guidance suggests no additional changes need to
be made to the cell or cover design,other than the changes to the cover design discussed in Section
2.4.1 above.
2.15 INTERROGATORY WHITE MESA CELL 4B lOCFR40,APPENDIX A,CRITERION
5A(1)-14/01:GROUND-WATER PROTECTION STANDARDS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.16 INTERROGATORY WHITE MESA CELL 4B lOCFR40,APPENDIX A,CRITERION
5A(2)-15/01:LINER
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.17 INTERROGATORY WHITE MESA CELL 4B lOCFR40,APPENDIX A,CRITERION
5A(4)-17/01:PREVENT OVERTOPPING
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.18 INTERROGATORY WHITE MESA CELL 4B lOCFR40,APPENDIX A,CRITERION
5A(5)-18/01:DIKES
INTERROGATORY STATEMENT:
To Be Determined.
OENISONr;)~~
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Denison Response
No comment at this time.
2.19 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(1)-19/01:COVER AND CLOSURE ATEND OF MILUNG OPERATIONS
INTERROGATORY STATEMENT:
2.19.1 Please provide an updated Reclamation Plan that includes the proposed design ofthe
final cover systems for the disposal cells,including Cells 4A and 4B,and addresses the design ofthe
radon barrier layer(s),including thickness and assumptions regarding initial and long-term moisture
content(s)in the radon barrier(s).
Denison Response
Denison submitted the Reclamation Plan,Rev.4.0 to the Executive Secretary on November 25,2009.
The Reclamation Plan,Rev.4.0 represents an update to Revision 3.0 of the Reclamation Plan to
reflect approved changes to the Reclamation Plan and to update outdated information,since the
Reclamation Plan as a whole was approved by NRC in 2000.However,while the Reclamation Plan,
Rev.4.0 incorporates a number of updates to the Reclamation Plan,the substantive provisions of the
Reclamation Plan were not changed.
As required by Part I.H.!!of the GWDP,Denison is in the process of completing an infiltration
and contaminant transport model of the final tailings cover system to demonstrate the long-term
ability of the cover to protect nearby groundwater quality.Upon review of such modeling,the
Executive Secretary will determine if changes to the cover system as set out in the Reclamation
Plan,Rev.4.0 are needed to ensure compliance with the performance criteria contained in Part
I.D.8 of the GWDP.Although the modeling has not been completed,modeling results to date
suggest that some changes to the final cover design will be needed.However,as the details of
such re-design have not been finalized at this time,the approved 2000 cover design and basis
continue to be used for the Reclamation Plan,Rev.4.0.The Reclamation Plan,Rev.4.0 will be
amended in the future to incorporate any changes to the design of the tailings cover system that
result from the current modeling effort.
Similarly,upon approval of the Amendment Request,the Reclamation Plan,Rev.4.0 will be amended
to include Ce1l4B.
2.19.2 Provide an assessment oflong-term radon emission rates for the final cover system(s).
Include assumptions andpresent and describe analysis methodologies used.
OENISOJ)JJ
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Denison Response
The EPA rules in 40 CFR Part 192 require that a "uranium tailings cover be designed to produce
reasonable assurance that the radon-222 release rate would not exceed 20 pCi/m2/sec for a period of
1,000 years to the extent reasonably achievable and in any case for at least 200 years when averaged
over the disposal area over at least a one year period"(NRC,1989).NRC regulations presented in 10
CFR Part 40 (incorporated by reference into UAC R313-24-4)also restrict radon flux to less than 20
pCi/m2/sec.
Section 3.3.2.1 of the Reclamation Plan,Rev.4.0 describes the modeling that was performed to
demonstrate that the CUlTent tailings cover design will meet these regulatory criteria.Section 3.3.2.2
of Reclamation Plan,Rev.4.0 sets out radon flux measurements for Cells 2 and 3 from 2004 through
2008,which demonstrate that the random fill cover alone,is currently providing an effective banier to
radon flux.Flux rates over those years have all been lower than the regulatory standard,based solely
on the interim random fill cover that has been placed over portions ofthose cells.
As mentioned in Section 2.19.1 above the cover design for the Mill's tailings cells is currently being
re-evaluated.Included in that analysis is a demonstration that the revised cover design will also
satisfy the regulatory radon emission standards for the facility.
Gamma will be measured at the surface of the final tailings cover to demonstrate that gamma rates are
within regulatory standards.Regulatory standards for gamma will be met if the radon flux rates are
within the regulatory standards and the materials used to construct the cover meet the prescribed
specifications.
2.19.3 Address the radiation protection design of the tailings disposal impoundment cover
for radon and gamma attenuation and assess the potential for settlement ofthe tailings impoundment
and resulting cracking ofthe radon barrier.
Denison Response
See Section 2.19.2 above for a discussion about the radiation protection design of the tailings disposal
impoundment cover for radon and gamma attenuation.
An analysis of the potential for settlement of the tailings impoundments and resulting cracking of the
radon barTier is set out in Appendix D ofthe Reclamation Plan,Rev.4.0.
2.20 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(2)-20/01:VERIFY EFFECTIVENESS OF FINAL RADONBARRIER
INTERROGATORY STATEMENT:
To Be Determined.
OENISONf)~~
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Denison Response
No comment at this time.
2.21 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(3)-21/01:PHASED EMPLACEMENT OF FINAL RADON BARRIER
INTERROGATORY STATEMENT:
Provide information regarding the schedule for and manner ofplacement of the final radon barrier
over the disposal cell areas,including Cell 4B.Describe any proposed phasing of radon barrier
placement.Describe methods to be used to verify the effectiveness ofthese radon barrier layers in
limiting long-term emissions (e.g.,radon)through the final closure cover(s).
Denison Response
Final reclamation of the tailings cells is planned as a phased approach,allowing for utilization of
excavated material from construction of new cells to be placed as the initial platform fill on areas of
existing cells that have reached design grade for tailings solids.The initial platform fill provides a
smcharge to the tailings solids and aids in the consolidation and dewatering of the tailings solids.
Settlement monitors placed in areas of partially reclaimed cells are monitored to evaluate the
consolidation of the solids.Timing of placement of the final cover over the platform fill is based on
the physical condition of the tailings cell and management's decision on overall long range Mill
operations and economics.Final cover design and radon barrier performance will be evaluated as a
part of the on-going infiltration analysis and re-design of the tailings cover.
See Section 2.19.2 above for a discussion of the methods to be used to verify the effectiveness of the
radon balTier layers in limiting long-telm emissions (e.g.,radon)through the final closure covers
2.22 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(4)-22/01:REPORTRADON BARRIER EFFECTIVENESS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
OENISOJ)~~
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46
2.23 INERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(5)-23/01:ELEVATED RADIUM CONCENTRATIONS INCOVER MATERIALS
INTERROGATORYSTATEMENT:
2.23.1 Demonstrate that adequate quantltles are available of all proposed rock cover
materials of suitable characteristics required for construction (such as provided in Section 7.2.1 of
NUREG 1623)ofall remaining covers ifDUSA requests are granted.
Denison Response
Cover materials for final reclamation of the tailings cells are available from on-site stockpiles of soils,
clay and rock excavated from the cell construction.Current stockpiles exceed the volume of material
necessary for the remaining reclamation of Cells 2,3 and 4A.Additional clay is available from a
bOlTOW site located approximately 3 miles south of the site,and rip rap materials are available from
one or more BLM public pits located within 4 to 6 miles of the site.The construction of Cell 4B will
generate approximately 680,000 cubic yards of soil and clay,and 790,000 cubic yards of rock.Cell
4B reclamation requirements are estimated to be 410,000 cubic yards of soil and rock,68,000 cubic
yards of clay,and 35,000 cubic yards of rip rap.The Cell 4B requirements can easily be met from
material generated during construction or from offsite locations.
2.23.2 Demonstrate that the radium concentrations of candidate rock materials do not
exceed background levels for the vicinity of the White Mesa facility and will not appreciably affect
radonfluxes projectedfor the cover systemfollowing construction.
Denison Response
All cover materials are native soils and rock generated from the construction of the tailings cells or
from off site bon'ow locations.Radium concentration of the cover materials will be at naturally
OCCUlTing levels,and therefore at background levels.
2.24 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(6)-24/01:CONCENTRATIONS OF RADIONUCUDES OTHER THAN RADIUMIN SOIL
INTERROGATORYSTATEMENT:
To Be Determined.
Denison Response
No comment at this time.
OENISOJ)~J
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2.25 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6(7)-25/01:NONRADIOLOGICAL HAZARDS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.26 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
6A(1)-26/01:COMPLETION OF FINAL RADONBARRIER
INTERROGATORY STATEMENT:
Provide information regarding the schedule for and manner of placement of the final radon
barrier over the disposal cell areas,including Cell 4B.Demonstrate that the final radon barrier
will be placed as expeditiously as practicable considering technological feasibility after the
disposal cell areas or impoundments cease operation.
Denison Response
See Section 2.21 above.
2.27 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION 7-
29/01:PREOPERATIONALAND OPERATIONAL MONITORING PROGRAMS
INTERROGATORYSTATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.28 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIXA,CRITERION 8-
30/01:EFFLUENT CONTROLDURING OPERATIONS
INTERROGATORY STATEMENT:
2.28.1 Provide current information and analyses that demonstrate that milling operations
are and will be conducted so that all airborne effluent releases are reduced to levels that are as low as
is reasonably achievable (AlARA).Include an analysis ofthe efficiency ofthe equipment as designed
OENISONI)~
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48
and operated that prevent radiation.exposures to employees and members ofthe public and that limit
such exposures to ALARA levels.
Denison Response
The Mill has been operating since 1980 and has been inspected by NRC up until August 2004 and by
DRC since that time.The License was renewed in 1985 for five years and in 1997 for ten years,all of
which demonstrates that the Mill is capable of operating in a manner that satisfies all regulatory
standards and ALARA goals.Further,the periodic repOlts filed with the Executive Secretary are
inspected by DRC and demonstrate that the Mill is operating in compliance with all regulatory
standards and ALARA goals.See for example the Mill's recent Semi-Annual Effluent Reports,which
demonstrate that the Mill is operating within all applicable regulatory standards and ALARA goals.
See also Sections 2.19.1 and 2.19.2 above which discuss control of radon emissions from the Mill's
tailings cells.
The Amendment Request is not an application for the License or renewal of the License as a whole,
which are addressed in the 2007 License Renewal Application and the 2007 ER.
2.28.2 Provide a description ofmill waste and effluent control systems and equipment for
muunuzing to as low as is reasonably achievable the quantities of materials released into the
environment.Specify quantities,concentrations,and physical,chemical,and radiological
characteristics ofall materials released that depend upon characteristics ofore being processed and
state how these parameters affect projected dose rates.Average and maximum release rates should be
addressed plus all pertinent supporting information such as assumptions and computational methods
used.
Denison Response
The Amendment Request is not an application for the License or renewal of the License as a
whole,which are addressed in the 2007 License Renewal Application and the 2007 ER,nor is it
an application for approval of the siting and use of Cell 4B,which have already been evaluated
and approved and are included in the License as part of the original approval of the tailings
management system for the Mill.Rather,the Amendment Request is for the more detailed
amendments to the License required in connection with the actual construction and operation of
Ce1l4B.
The Mill's tailings cells are the "mill waste and effluent control systems and equipment for
nurunuzmg to as low as is reasonably achievable the quantities of materials released into the
environment."The construction and operation of Cell 4B will not add any new hazards or risks to
human health and the environment created by potential constituents of concem over and above
existing licensed facilities at the Mill.The physical,chemical and radiological make up of the tailings
is not expected to be significantly different from that of existing tailings or from the assumptions in
the 2008 MILDOS Evaluation.The tailings cell cover design will be the same as for the existing
tailings cells,including Cell 4A;therefore,radon emanations are not expected to be any different than
emanations from Ce1l4A.Cell4B will have a similar double liner/leak detection/slimes drain system
OENISONI)J~
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49
as Cell 4A,which is designed not to release tailings solutions to the environment.Any potential
releases will be detected by the Mill's groundwater monitoring program and remediated before there
could be any impact on the public.See Appendix B to the 2008 ER for Denison's proposed additions
to the site's groundwater monitoring program to accommodate Ce1l4B.
The hazards and risks to human health and the environment created by all potential constituents of
concern at the Mill site were assessed in detail by Dames and Moore in the 1978 ER and by NRC in
the FES.See Section 5.0 of the 1978 ER and Section 4.0 of the FES.
2.28.3 Please present and discuss information concerning any cumulative buildup of
radionuclides in the environment.Summarize data,assumptions,and models used in determining
radioactivity concentrations and burdens.Estimate the maximum radionuclide concentrations that
may be present in important local flora and local and migratory fauna.Values ofbioaccumulation
factors used in preparing the estimates should be based on site-specific data ifavailable;otherwise,
values from the literature may be used.The applicant should tabulate and reference the values of
bioaccumulationfactors used in the calculations.
Denison Response
The Amendment Request is not an application for the License or renewal of the License as a
whole,which are addressed in the 2007 License Renewal Application and the 2007 ER,nor is it
an application for approval of the siting and use of Cell 4B,which have already been evaluated
and approved and are included in the License as part of the original approval of the tailings
management system for the Mill.Rather,the Amendment Request is for the more detailed
amendments to the License required in cOlmection with the actual construction and operation of
CeIl4B.
The construction and operation ofCell 4B will not add any new hazards or risks to human health and
the environment created by potential constituents of concern over and above existing licensed
facilities at the Mill.The physical,chemical and radiological make up of the tailings is not expected
to be significantly different from that of existing tailings or from the assumptions in the 2008
Mll..-DOS Evaluation.The tailings cell cover design will be the same as for the existing tailings cells,
including Cell 4A;therefore,radon emanations are not expected to be any different than emanations
from Ce1l4A.Cell4B will have a similar double liner/leak detection/slimes drain system as Ce1l4A,
which is designed not to release tailings solutions to the environment.Any potential releases will be
detected by the Mill's groundwater monitoring program and remediated before there could be any
impact on the public.See Appendix B to the 2008 ER for Denison's proposed additions to the site's
groundwater monitoring program to accommodate CeIl4B.
Further,in accordance with 40 CPR 61.252 (b)(i),the Mill cannot have more than 2 tailings
impoundments in operation at anyone time.This means that as Cell4B comes into operation,Cell 3
must cease operations.As a result,the total emissions from the addition of Cell 4B will not be
significantly different from previously licensed operations.The 2008 Mll..-DOS Evaluation takes
these factors into account.
OENISONI)~~
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The hazards and risks to human health and the environment created by all potential constituents of
concern at the Mill site were assessed in detail by Dames and Moore in the 1978 ER and by NRC in
the PES.See Section 5.0 ofthe 1978 ER and Section 4.0 of the PES.
On a review of the Mill's Semi Annual Effluent Reports,it is evident that there are no significant
trends in monitoring results for swface water,soils or vegetation in the vicinity of the Mill.This is the
best evidence that there has been no significant cumulative buildup of radionuclides in the
enviromnent from Mill operations over the last 30 years.
2.28.4 Describe in detail the proposed effluent and environmental monitoring programs,
including methods and procedures for measuring concentrations and quantities ofboth radioactive
and non-radioactive materials released to the environs from the proposed Cell 4B and neighboring
cells.In the description of the proposed monitoring programs,include the technical basis used to
determine that environmental concentrations comply with applicable regulatory requirements
Describe the proposed sampling program to determine concentrations of airborne radioactive
materials (including radon)during routine and non-routine operations,maintenance,and cleanup
activities.In the description ofthe sampling program,address the following:
•Criteria for determining sampling locations with respect to process operations and
personneloccupanc~
•Frequency ofsampling,
•Typeofanaryse~
•Sensitivity ofoverall sampling and analyses,
•Action levels,
•Management audits,
•Corrective action requirements,
•Instrumentation calibrationfrequency,and
•Procedures for sample analyses and instrument calibration (in an appendix).
Denison Response
The Mill has nwnerous established effluent and environmental monitoring programs.Those approved
programs are described in detail in Section 2.3 ofthe Reclamation Plan,Rev.4.0.The technical bases
for all of those programs have been approved by NRC and/or the Executive Secretary who,in doing
so,have determined that environmental concentrations comply with applicable regulatory
requirements.fu reviewing the 2007 License Renewal Application,the Executive Secretary will have
an oppOltunity to review all of the existing effluent and environmental monitoring programs to
determine if any adjustments to those programs are necessary.
The existing effluent and monitoring programs will continue to be applied to the Mill after the
construction of Cell 4B,with the proposed addition of two new groundwater monitoring wells,as
discussed in the Report entitled Site Hydrogeology Estimation of Groundwater Travel Times and
Recommended Additional Monitoring wellsfor Proposed Tailings Cell 4B,White Mesa Uranium Mill
Site Near Blanding,Utah,dated January 8,2008,prepared by Hydro Geo Chern,fuc.,which is
attached as Appendix A to the 2008 ER.
OENISOJ)~~
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51
SENES Consultants Ltd reviewed the envirorunental radiological monitoring programs at the Mill to
determine whether or not any changes to those programs are warranted by the addition of Cell 4B.
SENES concluded that the CUlTent radiological monitoring programs at the Mill will continue to
adequately monitor the release of radioactive materials to the local envirorunent with the addition of
CeIl4B.
2.28.5 Describe the detection monitoring program to be used to determine whether process
effluents are reaching site ground water supplies from Cell 4B and neighboring cells.Describe the
planned monitoring to detect the presence ofprocess effluents in any local suiface waters.Provide the
technical basis for the monitoring programs,including the number and location of monitoring
stations,the criteria used for locating sampling stations and determining sampling frequency,and
action levels and corrective action requirements.Provide procedures for sample collection and
analysesfor the constituents ofconcernfound in tailings liquor in an appendix.
Denison Response
See Section 2.28.4 above.In addition,Cell 4B will have a leak detection system,similar to the leak
detection system in CeIl4A,which will be monitored regularly.
2.29 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
8A-31/01:DAILYINSPECTIONS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.30 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIXA,CRITERION 9-
32/01:FINANCIAL SURETYARRANGEMENTS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
OENISON')~
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2.31 INTERROGATORY WHITE MESA CELL 4B 10CFR40,APPENDIX A,CRITERION
10-33/01:COSTS OF LONG-TERM SURVEILLANCE
INTERROGATORY STATEMENT:
Provide an engineering estimate ofthe costs attributable to the proposed Cell 4B ofconducting
long-term surveillance in compliance with all requirements applicable to US DOE's long-term
stewardship program.Demonstrate that the estimated cost will be acceptable to US DOE.
Denison Response
Cost estimates for implementation of the Reclamation Plan,Rev.4.0 are included in Attachment C of
that Plan.The estimated costs include an amount, specified by DOE,to be provided as a Long Term
Surveillance Fund.This fund is specific to the entire site and is not designated for individual features
of the site.There will be no increase in the calculated amount of the fund from the addition of Cell
4B.
2.32 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.3-35/01:GROUND
WATER DISCHARGE PERMITAPPliCATION
INTERROGATORYSTATEMENT:
2.32.1 Provide a detailed geologic map for the site,including the footprint area and vicinity
ofproposed Cell 4B.Include geologic cross sections with geology to characterize the surface and
subsurface conditions in the Cell 4B area.
Denison Response
A Colorado Plateau geologic map and a map showing the geology of the Mill site and surrounding
areas are found as Figures 1.6.1 and 1.6.2,respectively,of the Reclamation Plan,Rev.4.0.A figure
showing the generalized stratigraphy of the Mill site is included as Figure 6 of the 2008 ER and Figure
1.5-1 of the Reclamation Plan,Rev.4.0.
2.32.2 Provide additional information on the potential presence and distribution offractures
and/or joints,and uncemented/higher permeability intervals in the unsaturated and saturated zone
portions ofthe Dakota Sandstone and Burro Canyon geologic units underlying the site area,including
thefootprint area ofand downgradient vicinity ofproposed Cell 4B.
Denison Response
The potential presence and distribution offractures and/or joints,and uncemented/higher permeability
intervals in the unsaturated and saturated zone portions of the Dakota Sandstone and BUlTO canyon
geologic units underlying the site area,including the footprint area of and downgradient vicinity of
proposed Cell 4B has been analyzed by Hydro Geo Chern,Inc.See the November 10,2009 letter
report attached as Attachment 1 to this letter.Hydro Geo Chern concludes that the reported sub-
OENISOJ)~~
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53
horizontal,limonite-stained features interpreted by Dames and Moore in the 1978 ER as bedding
plane fractures may not be actual fractures but may represent stmcturally weaker zones along bedding
planes that appear as pmtings in core samples.Examination of core samples collected during drilling
of mlgle borings beneath tailings Cells 3 and 4A indicate that where fractures were present in cores,
they were cemented with gypsum.Open fractures significant enough to impact groundwater
movement in the perched zone were not identified in that investigation.Hydro Geo Chern further
concluded that no fractures were reported in cores from MW-3A,MW-16,nor WM-23,the existing
wells adjacent to or at the location of proposed Ce1l4B.Hydro Geo Chern concludes that this makes
it even less likely that potentially undetected fractures could significantly affect subsurface fluid flow
in the vicinity of proposed Cell 4B,mld that,should the sub-horizontal features reported in the 1978
ER actually represent fractures,their sub-horizontal nature would prevent them from acting as vertical
conduits from the tailing cell to the perched groundwater.
2.32.3 Define and provide information regarding all present and assumed future potential
points of discharge for effluent or leachate,including sump collection areas ofthe disposal cells as
applicable.
Denison Response
The design of Cell 4B will be essentially the same as the design of Cell 4A.Cell 4A has been and
Cell 4B will be designed and constmcted with dual synthetic liners,a leak detection system between
the liners and a geoclay layer beneath the synthetic liners.This liner system is overlain by a slimes
drain system.The cells are therefore designed without any present,and there m'e no assumed future
potential,points of discharge for effluents or leachate from the cells.
2.32.4 Provide information on the relationship between any inferredfractures and/or joints,
and uncementedlhigherpermeability intervals and the potentialfuture location(s)ofseepagefrom the
disposal cells,including Cell 4B.
Denison Response
See the discussion in Sections 2.32.3 and 2.32.4 above.No un-cemented fractures or joints have been
observed in the vicinity of CeIl4B,and there are no expected potential locations ofseepage from Cell
4B.
2.32.5 Evaluate and discuss the potential effects ofsuch features on permeability values and
other aquifer properties and evaluate their potential effects on groundwaterflow pathways andflow
rates,including estimated contaminant travel times to the perched groundwater zone,beneath and
downgradient of the disposal cells,including Cell 4B.Summarize the potential impacts of such
fractures!joints in these formations on the predicted performance ofcontainment systems that will be
installed in the waste disposal/containment cells,including Cell 4B.
Denison Response
A detailed analysis of site hydrology,including pelmeability values and other aquifer propelties,
groundwater flow pathways and flow rates,is set out in the Report entitled Site Hydrogeology
OENISON'lJ ~
MINES
54
Estimation of Groundwater Travel Times and Recommended Additional Monitoring Wells for
Proposed Tailings Cell 4B,White Mesa Uranium Mill Site Near Blanding,Utah,dated January 8,
2008,prepared by Hydro Geo Chem,Inc.A similar RepOlt,with updated site infOlmation is entitled
Site Hydrogeology and Estimation of Groundwater Travel Times in the Perched Zone White Mesa
Uranium Mill Site Near Blanding,Utah,dated August 27,2009,prepared by Hydro Geo Chern,Inc.,
a copy ofwhich is included as Appendix B to the Reclamation Plan,Rev.4.0.
As discussed in Section 2.32.2 above,there are no observed un-cemented fractures or joints in the Mill
vicinity that could impact the predicted performance of Cell4B.
2.32.6 Provide information to demonstrate that existing groundwater compliance monitoring
wells MW-5,MW-12,and MW-15 would be preserved and maintained during Cell 4B construction
operations.Describe measures to be implemented to protect these monitoring wells during cell
construction and provide criteria to be usedfor determining that repair or replacement ofthese wells
is required ifdamage occurs to any ofthese wells during Cell4B construction.
Denison Response
Each groundwater monitoring well at the Mill site,including MW-5,MW-12 and MW-15,is
protected by four posts,forming the comers of a square that surrounds the well.Each post is a four-
inch metal pipe filled with concrete that is sunk three feet into the ground and that protrudes three feet
above the ground.Each post and the monitoring well casing is painted red for easy visual
identification.
In the unlikely event that a monitoring well is damaged,given the above protections,the Executive
Secretary would be notified,and the well would be repaired in accordance with a plan that would be
submitted to the Executive Secretary for approval and approved prior to commencement ofrepair.
2.32.7 Please provide well logs for wells MW-3,MW-4,MW-5,MW-ll,MW-12,MW-14,
MW-15,MW-20, MW-21,MW-22,MW-23,and temporary perched water zone wells TW4-4 and
TW4-5.
Denison Response
Welliboring logs for wells MW-1,MW-2, MW-3,MW-4,MW-5,MW-11,MW-12,MW-14,
MW-15,MW-16,MW-17, MW-18,and MW-19,are included as Appendix A to the
Hydrological Evaluation of Whiter Mesa Uranium Mill,July 1994,prepared by Titan
Environmental Corporation (the "1994 Titan Report").A copy of the 1994 Titan Report
accompanied the 2009 GWDP Renewal Application.
Lithologic and core logs for wells MW-3A,MW-23,MW-24,MW-25,MW-27,MW-28,MW-
29,MW-30 and MW-31 are included as Appendix A to the Report:Perched Monitoring Well
Installation and Testing at the White Mesa Uranium Mill April Through June 2005,August 3,
2005,prepared by Hydro Geo Chern,Inc.,a copy of which Report accompanied the 2009 GWDP
Renewal Application.
OENISOJ)J~
MINES
55
Lithologic and core logs for well MW-26 (previously named TW4-15)and well MW-32 (previously
named TW4-17)are included as Appendix A to the LetterReport dated August 29,2002,prepared by
Hydro Geo Chem,Inc.and addressed to Harold Robelts,a copy of which RepOlt accompanied the
2009 GWDP Renewal Application.
Lithologic and core logs for wells MW-20,MW-21 and MW-22 are included in a June 21,2001 letter
report from Hydro Geo Chern,Inc.,which is attachment A to Denison's June 22,2001 letter to the
Executive Secretary in response to the Executive Secretary's request for additional site hydrology
information.
Lithologic and core logs for wells TW4-4 and TW4-5 are included in an October 4,2000 repOlt
prepared by Hydro Geo Chern,Inc.,which has previously been submitted to the Executive Secretary.
2.33 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.4-36/01:ISSUANCE OF
DISCHARGE PERMIT
INTERROGATORY STATEMENT:
To complete the application for a Utah Ground Water Discharge Permit (Permit),provide the
following information or identify documents in which DUSA has already provided such information:
•An updated plat map showing all water wells,including the status and use ofeach
well,Drinking Water source protection zones,topography,springs,water bodies,
drainages,and man-made structures within a one-mile radius of the discharge.The
plat map must also show the location and depth of existing or proposed wells to be
used for monitoring ground water quality.Identify any applicable Drinking Water
source protection ordinances and their impacts on the proposed permit.
•Geologic,hydrologic,and agricultural description of the geographic area within a
one-mile radius ofthe point ofdischarge,including soil types,aquifers,ground water
flow direction,ground water quality,aquifer material,and well logs.
•The type,source,and chemical,physical,radiological,and toxic characteristics ofthe
effluent or leachate to be discharged;the average and maximum daily amount of
effluent or leachate discharged (gpd),the discharge rate (gpm),and the expected
concentrations of any pollutant (mg/l)in each discharge or combination of
discharges.Ifmore than one discharge point is used,informationfor each point must
be given separately.
•Information which shows that the discharge can be controlled and will not migrate
into or adversely affect the quality of any other waters of the state,including the
applicable surface water quality standards,that the discharge is compatible with the
receiving ground water,and that the discharge will comply with the applicable class
TDS limits,ground water quality standards, class protection levels or an alternate
concentration limit proposed by the facility.
•For areas where the ground water has not been classified by the Board,information
on the quality of the receiving ground water sufficient to determine the applicable
protection levels.
OENISOJ)~~
MINES
56
A proposed sampling and analysis monitoring plan which conforms to EPA Guidance
for Quality Assurance Project Plans,EPA QA/G-5 (EPA/600/R-98/018,February
1998)and includes a description,where appropriate,ofthe following:
-/Ground water monitoring to determine ground water flow direction and
gradient,background quality at the site,and the quality ofground water at the
compliance monitoring point;
-/Installation,use and maintenance ofmonitoring devices;
-/Description of the compliance monitoring area defined by the compliance
monitoring points including the dimensions and hydrologic and geologic data
used to determine the dimensions;
-/Monitoring ofthe vadose zone;
-/Measures to prevent ground water contamination after the cessation of
operation,including post-operational monitoring;
-/Monitoring well construction and ground water sampling which conform
where applicable to the Handbook of Suggested Practices for Design and
Installation of Ground-Water Monitoring Wells (EPA/600/4-89/034,March
1991),ASTM Standards on Ground Water and Vadose Investigations (1996),
Practical Guide for Ground Water Sampling EPA/60012-85/104,(November
1985)and RCRA Ground Water Monitoring Technical Enforcement Guidance
Document (1986),unless otherwise specified by the Executive Secretary;
-/Description and justification ofparameters to be monitored;
-/Quality assurance and control provisions for monitoring data.
•The plans and specifications relating to construction,modification,and operation of
discharge systems.
•The description of the ground water most likely to be affected by the discharge,
including water quality information ofthe receiving ground water prior to discharge,
a description ofthe aquifer in which the ground water occurs,the depth to the ground
water,the saturated thickness,flow direction,porosity,hydraulic conductivity,and
flow systems characteristics.
•For any existing facility,a corrective action plan or identification of other response
measures to be taken to remedy any violation of applicable ground water quality
standards,class TDS limits or permit limit established under R317-6-6.4E.which has
resulted from discharges occurring prior to issuance of a ground water discharge
permit.
•Contingency plan for regaining and maintaining compliance with the permit limits
andfor reestablishing best available technology as defined in the permit.
• A closure and post closure management plan demonstrating measures to prevent
ground water contamination during the closure and post closure phases of an
operation.
Provide information including narrative descriptions,figures,table,drawings,analyses,and
supporting documentation to demonstrate that:
OENISOJ)~~
MINES
57
•Applicable class TDS limits,ground water quality standards andprotection levels will
be met ifthe proposed amendment is granted.
•The monitoring plan,including sampling and reporting commitments,are adequate to
determine compliance with applicable requirements.
•DUSA utilizes treatment and discharge minimization technology commensurate with
plant process design capability and similar or equivalent to that utilized by facilities
that produce similar products or services with similar production process technology.
•DUSA projects that no impairment ofpresent andfuture beneficial uses ofthe ground
water will resultfrom the proposed amendment.
Denison Response
The foregoing interrogatories are addressed in detail in the 2009 GWDP Renewal Application.
The Amendment Request is not in support of an application for the GWDP or renewal of the GWDP
as a whole,which are addressed in the 2009 GWDP Renewal Application.
The construction and operation ofCell 4B will not add any new hazards or risks to human health and
the environment created by potential constituents of concern over and above existing licensed
facilities at the Mill.The physical,chemical and radiological make up of the tailings is not expected
to be significantly different from that of existing tailings or from the assumptions in the GWDP.Cell
4B will have a similar double linerlleak detection/slimes drain system as Cell 4A,which is designed
not to release tailings solutions to the environment.Any potential releases will be detected by the
Mill's groundwater monitoring program and remediated before there could be any impact on the
public.See Appendix B to the 2008 ER for Denison's proposed additions to the site's growldwater
monitoring program to accommodate Ce1l4B.
2.34 INTERROGATORY WHITE MESA CELL 4B VAC R317-6-6.9-37/01:PERMIT
COMPliANCE MONITORING
INTERROGATORY STATEMENT:
2.34.1 Provide information demonstrating that the proposed groundwater monitoring system,
including the proposed new monitoring wells (MW-33 and MW-34)installed downgradient offuture
Cell 4B,together with well MW-14 and MW-15 (if preserved),and the other existing downgradient
monitoring wells,are sufficient in number,are properly located,and are properly designed to provide
reasonable assurance ofproviding timely,reliable,and representative data for detecting potential
future releases from the disposal cells,including Cell 4B,considering the potential distribution of
fractures and/or joints,and uncemented intervals/higher permeability zones in the subsuiface
geologic units underlying/downgradient of the disposal cells area.
Denison Response
A detailed analysis of site hydrology,including pelmeability values and other aquifer properties,
groundwater flow pathways and flow rates,is set out in the Report entitled Site Hydrogeology
Estimation of Groundwater Travel Times and Recommended Additional Monitoring Wells for
OENISONI)J J
MINES
58
Proposed Tailings Cell 4B,White Mesa Uranium Mill Site Near Blanding,Utah,dated January 8,
2008,prepared by Hydro Geo Chem,Inc.A similar Report,with updated site infOlmation is entitled
Site Hydrogeology and Estimation of Groundwater Travel Times in the Perched Zone White Mesa
Uranium Mill Site Near Blanding,Utah,dated August 27,2009,prepared by Hydro Geo Chern,Inc.,
a copy of which is included as Appendix B to the Reclamation Plan,Rev.4.0.
Those RepOlts provide information demonstrating that the proposed groundwater monitoring system,
including the proposed new monitoring wells (MW-33 and MW-34)installed downgradient of future
Cell 4B,together with well MW-14 and MW-15,and the other existing downgt'adient monitoring
wells,are sufficient in number,are properly located,and are properly designed to provide reasonable
assurance of providing timely,reliable,and representative data for detecting potential future releases
from the disposal cells,including Ce1l4B.
As discussed in Section 2.32.2 above,there are no observed un-cemented fractures or joints in the Mill
vicinity that impact the conclusions in those RepOlts.
2.34.2 Evaluate whether an alternative conceptual model or models (such as one
incorporating "preferential"flow through fractures,joints,uncementedlhigher permeability zones,
etc.,and/or different hypotheticalfuture source term [leakage]locations,such asfrom beneath one or
more sumps in one or more ofthe disposal cells including Cell 4B),if considered,would affect the
locations,screened interval(s),and/or required number of poc wells for providing timely/reliable
detection ofpotential releases from the disposal cells area.
Denison Response
See the discussion in Sections 2.32.2 and 2.34.1 above.An altemate conceptual model is not
necessary and would be inappropriate given the studies and empirical evidence to date.
2.35 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.10-38/01:BACKGROUND
WATER QUAliTYDETERMINATION
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.36 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.12-40/01:SUBMISSION
OF DATA
INTERROGATORYSTATEMENT:
2.36.1 Provide evidence demonstrating that all laboratory analysis of samples collected to
determine compliance with groundwater protection standards have been peiformed in accordance
OENISOJ)J
MINES
59
with standard procedures by the Utah Division ofLaboratory Services or by a laboratory certified by
the Utah Department ofHealth.
Denison Response
All site groundwater data generated since the date of issue of the GWDP have been repOlted in
quarterly monitoring reports that have been filed with the Executive Secretary.Each of those repOlts
contains a QA/QC analysis to determine,among other things,that the analysis of samples collected
has been performed in accordance with standard procedures by a Utah certified laboratory.Those
quarterly reports,including the QA/QC analysis are inspected by DRC.
The Mill is also subject to the QAP,which sets out detailed sampling,analysis and QA/
QC procedures that must be followed by Mill staff in conducting all water sampling at the site.
Data collected prior to the issuance of the GWDP were subject to a thorough QA/QC analysis in the
Background RepOlts.See Section 4.0 of the Existing Well Background Report,Section 5.0 of the
New Well Background RepOlt and Section 6.5 of the Regional Background Report.
2.36.2 Provide evidence demonstrating that all field analyses to determine compliance with
groundwater protection standards have been conducted in accordance with standard procedures
specified in R317-6-6.3.L.
Denison Response
All site groundwater data generated since the date of issue of the GWDP have been repOlted in
quarterly monitoring repOlts that have been filed with the Executive Secretary.Each of those reports
contains a QA/QC analysis to determine,among other things,that all field analysis to determine
compliance with groundwater protection standards has been conducted in accordance with procedures
that have been approved by the Executive Secretary,including the QAP.Those qUa.J.terly repOlts,
including the QA/QC analysis are inspected by DRC.
Data collected prior to the issuance of the GWDP were subject to a thorough QA/QC analysis in the
Background Reports.See Section 4.0 of the Existing Well Background Report,Section 5.0 of the
New Well Background RepOlt and Section 6.5 ofthe Regional Backgrow1d RepOlt.
2.37 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.13-41/01:REPORTING
OF MECHANICAL PROBLEMS OR DISCHARGE SYSTEM FAILURES
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
OENISOJ)J~
MINES
60
2.38 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.10-42/01:CORRECTION
OF ADVERSE EFFECTS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.39 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.10-43/01:OUT-OF-
COMPliANCE STATUS
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
2.40 INTERROGATORY WHITE MESA CELL 4B UAC R317-6-6.10-44/01:PROCEDURE
WHENA FACIliTYIS OUT-OF-COMPliANCE
INTERROGATORY STATEMENT:
To Be Determined.
Denison Response
No comment at this time.
If you should have any questions or require additional information,please contact the
OENISOJ)~~
MINES
61
undersigned.
Yours very truly,
By:
Davi .ry enlund
Vice resident,Regulatory Affairs and Counsel
cc:Ron F.Hochstein
Harold R.Roberts
Steven D.Landau
David E.Turk
62
OENISOJ)JJ
MINES
REFERENCES
Dames and Moore,1978,"Environmental Report,White Mesa Uranium Project,San Juan County,
Utah."Prepared for Energy Fuels Nuclear,Inc"January 1978.
Denison Mines (USA)Corp,February 28,2007.White Mesa Uranium Mill License Renewal
Application State of Utah Radioactive Materials License No.UT1900479.
Denison Mines (USA)Corp,February 28,2007.White Mesa Uranium Mill Environmental
Report In Support ofthe License Renewal Application State ofUtah Radioactive Materials
License No.UT1900479.
Denison Mines (USA)Corp,September 2009.White Mesa Uranium Mill,Renewal Application,
State of Utah Ground Water Discharge Permit No.UGW370004.
Denison Mines (USA)Corp.,November 2009.Reclamation Plan,White Mesa Mill,Blanding
Utah,Revision 4.0.
Division of Radiation Control,Utah,December 1,2004.Statement of Basis for a Uranium
Milling Facility at White Mesa,South of Blanding,Utah,Owned and Operated by
International Uranium (USA)Corporation.
Division of Radiation Control,Utah,September 2009.Statement ofBasis for a Uranium Milling
Facility South of Blanding,Utah,Owned and operated by Denison Mines (USA)Corp.
Hydro Geo Chern,Inc.,2001.Update to Report "Investigation of Elevated Chloroform
Concentrations in Perched Groundwater at the White Mesa Uranium Mill Near Blanding,
Utah".
Hydro Geo Chern,Inc.,2002.Hydraulic Testing at the White Mesa Uranium Mill Near Blanding,
Utah During July,2002.
Hydro Geo Chern,Inc.,2005.Perched Monitoring Well Installation and Testing at the White
Mesa Uranium Mill,April Through June,2005.
Hydro Geo Chern,Inc.,2007.Preliminary Corrective Action Plan,White Mesa Mill Near
Blanding,Utah,August 27,2007.
Hydro Geo Chern,Inc.,2007.Contamination Investigation Report,White Mesa Mill Near
Blanding,Utah,December 21,2007.
Hydro Geo Chern,Inc.,2008.Site Hydrogeology,Estimation of Groundwater Travel Times and
Recommended Additional Monitoring Wells for Proposed Tailings Cell 4B,White Mesa
Uranium Mill Site Near Blanding,Utah,January 8,2008.
Hydro Geo Chern,Inc.,August 27,2009.Site Hydrogeology and Estimation of Groundwater
Travel Times in the Perched Zone,White Mesa Uranium Mill Site Near Blanding,Utah.
INTERA,Inc.,October 2007.Revised Background Groundwater Quality Report:Existing
Wells For Denison Mines (USA)Corp.'s White Mesa Mill Site,San Juan County,Utah.
INTERA,Inc.,November 16,2007.Revised Addendum:--Evaluation of Available
Pre-Operational and Regional Background Data,Background Groundwater Quality
Report:Existing Wells For Denison Mines (USA)Corp.'s White Mesa Mill Site,San
Juan County,Utah.
INTERA,Inc.,April 30,2008.Revised Addendum:--Background Groundwater Quality Report:
New Wells For Denison Mines (USA)Corp.'s White Mesa Mill Site,San Juan County,
Utah.
National Oceanic and Atmospheric Administration (NOAA),1977.Probable Maximum
Precipitation Estimates,Colorado River and Great Basin Drainages.Hydrometerological
Report (HMR)No.49.
NUREG-1140,January 1988.A Regulatory Analysis on Emergency Preparedness for Fuel Cycle
and other Radioactive Materials Licensees,S.A.McGuire.
Titan Environmental Corporation,1994a.Hydrogeologic Evaluation of White Mesa Uranium
Mill,July 1994.
Titan Environmental Corporation,1994b.Points of Compliance,White Mesa Uranium Mill,
September 1994.
University of Utah,Department ofGeophysics (T.Grant Hurst and D.Kip Solomon),May 2008.
Summary of work completed,data results,interpretations and recommendations for the
July 2007 Sampling Event at the Denison Mines,USA,White Mesa Uranium Mill Near
Blanding Utah.
U.S.Department of Energy,1993,"Environmental Assessment of Remedial Action at the Slick
Rock Uranium Mill Tailings Sites,Slick Rock,Colorado."UMTRA Project Office,
Albuquerque,New Mexico,February.
U.S.Nuclear Regulatory Commission,1979.Final Environmental Statement -White Mesa
Uranium Project,NUREG-0556.

Figures
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AVG.WINO SPEED:OA.TE:PROJECfNO.:
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WIND ROSE PLOT:
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Blanding,Utah
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Attachment 1
HYDRO GEO CHEM,INC.
ElIvil'Olmtmtal Science &Technology
November 10,2009
David Frydenlund,Esq.
Denison Mines (USA)Corporation
1050 17th Street,Suite 950
Denver,Colorado 80265
Dear Mr.Frydenlund,
This letter provides a response to a portion of the interrogatory statement regarding the
Groundwater Discharge Permit for proposed tailing Cell4B (Figure 1)at the Whjte Mesa Uranium
Mill site (the site).In particular,this letter addresses concerns over the possible fracturing in Dakota
Sandstone and Burro Canyon Formation that will underlie CeIl4B.
Overview
The interrogatory expresses concern about "the potential presence and distribution of
fractures and/or joints and uncemented/higher permeability intervals in the unsaturated and
saturated zone portions ofthe Dakota Sandstone and Burro Canyon geologic units underlying the
site area."Logging ofdrill cuttings and core samples recovered during drilling,and hydraulic testing
of numerous vertical and four angle borings at the sjte,have shown that relatively thin,higher
permeability zones are associated with coarser grained and/or poorly cemented portions of these
geologic units in localized areas.Known zones affecting perched groundwater flow have been
identifjed primarily through hydraulic testing ofmonitoring wells screened within the BunoCanyon
Formation,which hosts most of the perched groundwater beneath the site.The most continuous of
these identified zones is associated with the elevated chloroform detected upgradient and cross-
gradient (northeast and east)ofthe existing tai}jng cells.However,open fractures sigmficant enough
to impact groundwater movement in the perched zone have not been identified and are not
considered to ofconcern in siting Cell 4B.
H:1718000lceU4bI091110 response ltr.doc
51 West Wetmore,Suite 101 Tucson,Arizona 85705-1678
c
PI 520.293.1500 520.293.1550-l'ax 800.727.5547-Toll Free
David Frydenlund,Esq.
November 10,2009
Page 2
Past Findings
The interrogatory cites logs of two borings discussed in Dames and Moore,19781;boring#19
and boring #28 (not shown on Figure 1).Boring #19 is reported to be located near the proposed Cell
4B footprint and boring#28 about 2,200 feet south of the proposed Cell 4B footprint.Horizontal
fracturing in one or more depth zones of the borings is discussed.Examination of the drill logs
indicates that one interval reported to contain bedding plane fractures was logged in borehole #19,
and a second deeper interval was ambiguously described as "moderately well-cemented
conglomerate orfractured sandstone".Near-horizontal fractures were also reported at two intervals
in boring #28.The reported fractures in three of the intervals were described as associated with
limonite staining.
The reported features interpreted by Dames and Moore as bedding plane fractures are likely
insignificant with respect to groundwater flow,and because they are sub-horizontal,could not serve
as vertical conduits for fluid flow from the tailings cells to the perched groundwater zone.
Furthermore,these features may not be actual fractures but may represent structurally weaker zones
along bedding planes that appear as partings in core samples.Partings along bedding planes have
been observed in cores at the site by Hydro Oeo Chem,Inc (HOC)during drilling of perched zone
monitoring wells (as will be described below).In some cases the partings were associated with
limonite staining.In most cases this staining was consistent with a diagenetic origin.
HOC,2001 2 discusses the results of a 1994 drilling program that consisted ofthe installation
ofthree perched zone monitoring wells and four angle borings beneath cell #3 and cell #4A.Work
(performed primarily by Peel Environmental Services)included coring,lithologic logging,
geophysical logging,and video logging of the borings and field and laboratory permeability testing
of the Dakota Sandstone,Burro Canyon Formation,and underlying Brushy Basin shale.Based on
examination of core samples,the video logs,and interpretation of raw data collected during field
permeability tests,the following observations were made:
1)The Dakota and Burro Canyon sandstones are predominantly composed of hard,fine-to
medium-grained,locally cross-bedded sandstones with interbedded conglomeratic layers
and layers of shale or claystone.
2)Few fractures are present in the cores or are observable in the video logs.Where present
fractures in cores are closed and/or sealed with gypsum.Partings in the cores are
primarily related to bedding planes and shale or clay interbeds.
3)Video logs show conglomeratic zones,occasional cross-bedding features,and scour
features within planes perpendicular to the direction of drilling.These scour features,
which often appear on only one side ofthe boring,are most likely related to scouring by
the drill bit.
1 Dames and Moore.1978.Environmental Report.White Mesa Uranium Project,San JuanCounty,Utah.Submitted to
Energy Fuels Nuclear,Inc.
2 Hydro Geo Chem,Inc.200I.Letter to Mr.Harold Roberts,Intemational Uranium (USA)Corporation.
H:1718000\ce1l4bI091110 response Itr.dnc
David Frydenlund,Esq.
November 10,2009
Page 3
4)Video logs also show washouts in claystones,small washouts parallel to bedding planes
in sandstone,and smaller washouts offiner-grained matrix material sUlTounding clasts in
conglomeratic zones.
With regard to subsurface water movement,HGC concluded that ''fluids present in the
subsurface will be transmitted primarily via intergranular porosity,and that minor fractures,
because they are few in nwnber and are closed and/or jllled with gypsum,are expected to have a
negligible effect onfluid movement."
Drilling and hydraulic testing ofeight new perched zone monitoring wells around the existing
tailing cells and a replacement for MW-3 are consistent with these results as discussed HGC,2005 3.
Core samples were collected during drilling of six of the new wells.Relatively thin intervals of
limonite and hematite staining associated with low angle,bedding-plane partings at various depths
were reported in these borings.Disseminated limonite staining associated with oxidized pyrite was
also reported.
The limonite present in the thin zones associated with bedding plane features is likely of
diagenetic origin.Fluid movement during post-depositional compaction could have mobilized iron
present in the sediments and resulted in deposition of the iron oxides limonite and hematite along
bedding planes.Because the sandstones underlying the site,especially the BUlTO Canyon Formation,
are composed of alternating sequences of oxidized and reduced materials,pyrite that formed in
reducing environments could have encountered oxidized diagenetic fluids that migrated from
oxidized zones resulting in oxidation of the pyrite to limonite and hematite.The presence of these
oxides does not necessarily indicate that significant fluid movement occurred in the vadose zone in
the post-diagenetic environment,nor does it necessarily indicate the presence of fractures.
Data specific to the area ofproposed Cell 4B
Wells in the immediate vicinity ofproposed Ce1l4B include MW-S,MW-12,MW-1S,and
MW-23.FormerWell MW-16 (Figure 1)was located near the center ofproposed Ce1l4B,but was
dry.Well MW-3 and adjacent well MW-3A are located downgradient of proposed Cell 4B.
Detailed logs are available for wells MW-3A,MW-16,and MW-23.
Coring logs for MW-16 (UMETCO and PEEL,19934),MW-3A,and MW-24 indicate
conditions that are similar to those described above.Limonite staining is described in relatively thin
intervals at various depths.Occasional partings associated with shaly interbeds,bedding planes,and
friable zones are reported.Partings associated with limonite staining are described as sub-horizontal.
No fractures are reported in the logs for the three wells.
3 Hydro Geo Chem,Inc.2005.Perched Monitoring Well Installation and Testing at the White Mesa Uranium Mill,
April Through June,2005.Submitted to International Uranium (USA)Corporation.
4 UMETCO Minerals Corporation and PEELEnvironmental Services.1993.GroundwaterStudy.WhiteMesa Facility,
Blanding,Utah.
H:\718000\ce114b\091110 response Itr.doc
David Fryclenlund,Esq.
November 10,2009
Page 4
Conclusions
The reported sub-horizontal,limonite-stained features interpreted by Dames and Moore as
bedding plane fractures may not be actual fractures but may represent structurally weaker zones
along bedding planes that appear as partings in core samples.Partings along bedding planes have
been observed by HOC in cores collected at the site during drilling of perched zone monitoring
wells,including well MW-3A,located downgradient of proposed Cell 4B,and well MW-23,
adjacent to proposed CeIl4B.Similar features werereported by UMETCO and PEEL at former well
MW-16,located near the center of proposed tailing Cell 4B.The observed partings were in some
cases associated with limonite staining.In most cases this staining was consistent with a diagenetic
origin.
Examination ofcore samples collected during drilling of angle borings beneath tailing cells
#3 and #4-A indicate the presence ofsimilarfeatures.Where fractures were present in these cores,
they were cemented with gypsum.Open fractures significant enough to impact groundwater
movement in the perched zone were not identified in this investigation.
Furthermore,no fractures were reported in cores from MW-3A,MW-16,nor MW-23.This
makes it even less likely that potentially undetected fractures could significantly affect subsurface
fluid flow in the vicinity ofproposed CeIl4B.Should the sub-horizontal features reported in Dames
and Moore actually represent fractures,their subhorizontal nature would prevent them from acting as
vertical conduits from the tailing cell to the perched groundwater.
Sincerely,
Attachmcnt (I)
1-1:\71 HOOO\cell-lh\091110 resplliheltuloL'
ATTACHMENTS
FIGURE
Site Plan Showing Perched Well Locations and Proposed Cell4B
FIGURE
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HYDRO
GEO
CHEM,INC.APPROVED
SJS
REFERENCE
H:/718000/ceIl4b/ceIl4b.srf
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