DRC-2009-006295 - 0901a0688014bd7b

h\^c- .7CC^h00uaHs
J>h DENISO
MINES
November 16,2009
VIA PDF AND FEDERAL EXPRESS
Denison Mines (USA) Corp.
1050 17th Streel, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denlsonmines.com
^>1~19.^'^
Mr, Dane Finerfrock
State of Utah Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
SaU Lake City, UT 84114-4850
Re: August 6, 2009 Letter, White Mesa Uranium Mill Ground Water Discharge Permit
No. UGW370004 for the White Mesa Mill - New Decontamination Pad [NDPl; June
5, 2009 and June 29, 2009 DUSA Letters; May 20, 2009, DUSA Drawings of NDP;
Request for Inrormation
Dear Mr. Finerfrock:
Reference is made to your Request for Informalion dated August 6, 2009 relating to lhe new
decontamination pad at the White Mesa Mill.
Denison Mines (USA) Corp. ("DUSA") has the following comments in response to your request
(your requests for information are staled in italics below, followed by our responses):
A. DRC proposed modifications to paragraph r) in Attachments - Proposed Modifications to
the DMT Plan found in the letter dated June 29. 2009 by Denison Mines (USA) Corp.
(hereafter''DUSA"}:
1. Modify the Daily Inspection Form (found in Section Vll) to include a location on the form
to record the daily visual inspection infonnation for presence nf fluid in all leak detection .system
(LDS) vertical inspection portals for the three chambers in the concrete settling tank system for
the decontamination pad.
We have modified Section VII of the Mill's Daily Inspection Form to include a location on the
form lo record lhe daily visual inspection information for each porlal. The actual portals will be
marked so lhat they can be idenlified by number.
2. On a quarterly basis submit with the DMT Performance Standard Monitoring Report a
summary of the daily visual inspections for the quarter for the presence of fluid in all LDS
vertical inspection portals for the primary and secondary containment for the three chcunhers in
lhe concrete seTtling lank system for the decrmtamination pud. The report wilt also include an
electronic or hard copy of daily inspection forms for the quarter and reporting of ony BAT
failures for the decontamination pad.
On a quarterly basis, DUSA will submit with its DMT Peiformance Siundiird Monitoring
Reports a summary of the daily visual inspections for the quarter for the presence of fluid in all
leak detection system ("LDS") vertical inspection portals for the primary and secondary
conlainmeiit for the three chambers in the concrete settling tank ("CST") system for the
decoiitaniinatioii pad. The repon will include a descriplion of any best available technology
("BAT") failures for the decontaminarion pad. However, DUSA does not agree lhat the report
should include an electronic or hard copy of ihc daily inspection forms themselves. The Mill
produces many periodic inspection forms, all of which are available for inspection at the Mill by
DRC staff No odier periodic reports prepared by the Mill are required to contain copies of any
such inspection forms.
3. Should any fluid he oh.served in any of the LDS vertical in.spection portals for the three
chambers in the ctmcrete settling tank system for the decontamination pad, the decontamination
pad will be immediately taken out of ser\'ice and be reported TO the Executive .Secretary as
required in Part I.G.3(a) ofthe Permit (see below).
Permit Part l.G.3(a): Failure lo Maintain DMT or BAT Required hy Permit
a) Permittee to Provide Information — in the event lhat Ihe Permittee fails to maintain
DMT or BAT or otherwise fails to meet DMT or BAT stondards as required by the
permit, the Permittee shall submit to the E.\ecutive Secretary a notification and
description of the failure according to R317-6-6.6.16(C){J}. Notification shall be
given orally within 24 hours ofthe Permittee's discovery of the failure of DMT or BAT,
and shall be followed up by written notification, including the information necessary to
make a determination under R3J7-6-6.J6(C)(2}, wiihin five days of the Permittee's
discovery of the failure of best available technology.
If any fluid is observed in any of the LDS vertical inspection portals for the three chambers in the
CST system for the decontamination pad, this will be reported to the Executive Secretary as
required by Part I.G,3(a) of the Permit. The LDS will be pumped dry immediately after the
discovery of any such fluids. If fluids continue to build up in the LDS after it is pumped dry, or
DUSA is otherwise not able to identify and remedy the source of the fluids, the deconiainination
pad will be taken out of service until the source of the fluid is identified and remedied.
B. Regarding Design Issues:
4. Will the transmissivity of lhe compressed geonet, under fully loaded conditions,
significantly impede the flow of any horizontal flow of water through the ge<met Kf the
monitoring locations"? Please demonstrate that the compressed geonet, under fidly loaded
conditions will not significantly affect the flow of any leakage to the LDS monitoring pipe
locations.
DENISO
MINES
^u
The 300 mil HDPE geonel maierial used in the LDS is the same material approved for the Cell
4A tailings pond LDS. The CeU 4A LDS was approved aud operates with up to a 35 foot liquid
head on the geonet material. This is equivalent (o 15.1 pounds per square inch ("psi"). The
decontamination pad CSTs have approximately 5 feet of water plus the weight of the steel on the
geonet material. Conservatively assuming 0.5 inch of steel and 5 feet of water, the equivalent
pressure on lhe geonet material in the CSTs is 3.9 psi. The weight on the geonet material from
the water and steel lining will have little or no effect on the transmissivity ofthe geonet material.
5. The permeability of the concrete for the CST needs to he determined. Tite permeability of
the concrete can be estimated hy analyzing the concrete mi.K design, as discussed in the
publication of the Portland Cement Association, Design and Control of Concrete Mixtures.
EBOOL 13"' Ed., and other field and scmipling methods. We recommend the first method be used,
and the calculation for the estimated permeability of the concrete he submitted for review and
approval.
The permeability of the concrete for the CST has been estimated by Precision Systems
Engineering to likely be in the range of 2x 10"^ m' at 7-day cure. I x 10"^ m^ at 28-day cure.
0.7x10^ m^ at one year and 0.5x10^ m" at len years. A copy of Precision Systems Engineering's
analysis is attached to this letter.
6. Sheet 3 of the drawings indicate the CST subgrade is to he prepared level. Tlie as-built
elevations and grades of the cfmcrete floors and elevations of dte walls of the CST must be
submitted for review and approval
Please see the attached revised as-buill drawings, which indicate lhe as-built elevations and
grades of the concrete floors and elevations of the walls of the CST.
7. Wilh respect to ihe above determination, the CST leakage monitoring pipes must be
placed at the locations of the lowest floor elevation within each citcunber of dte CST. Please
revise the as-built drawings lo show the new locations ofthe CST leakage monitoring pipes and
stdymit the revised drawings for review and approved.
Please see lhe attached revised as-built drawings, which show the new locations ofthe CST
leakage monitoring pipes.
8. Related to the above, the upper and lower elevations of lhe water level measuring pipes
at these new locations mentioned above must be determined and shown on the final as-built
drawings.
Please see the attached revised as-built drawings, which show the upper and lower elevations of
the water level measuring pipes at the new locations.
DENISO
MINES
Mi
9, Tfie details of the overlap of lhe .steel liner cover over the exterior CST concrete walls,
wiih a specified drip ty-pe edging, is not .shown on lhe drawings. The design of the edging must
he so ihat it prevents intrusi(m of precipitation and wash water into the space benveen the steel
cover and the concrete surfaces. Please revise the as-built drawings to show the details of a
specific drip type edging over the exterior CST walls, which meets the foregoing criteria, and
sidnnit the revised drawings for review and approval.
Please see (he attached revised as-built drawings, which show the details of a speciflc drip type
edging over the exterior CST walls, which meets lhe foregoing criteria,
10. The exterior edges of the instaUed .steel liner cover over the CST must he tested to
detnonslraic a "roofing" ability, as discu.ssed in item 9 above. Please submit the resnlts of this
tesfing for rc'view and approval.
Please see the attached revised as-buill drawings, which show the details of a specific drip type
edging over the exterior CST walls, which meeis the foregoing criteria. The steel liner extends
approximately 6 inches down lhe outside edge ofthe CST. The extension ofthe steel liner down
the outside of the concrete containment will prevent solutions or precipitation from entering the
area between the steel liner and the concrete walls. DUSA knows of no lest to prove this
"rooflng" ability. Should solution be detected in the LDS. this overlap of (he steel liner will be
inspected as a possible source of leakage.
IL It is recotnmended DUSA perform a hydrostatic test on the steel liner prior to
installation. This test should be done outside the CST before the steel liner is installed, .so leaks
can be easily observed and repaired. Please provide an appropriate standardized and industry
approved mt'thod for this testing (e.g. A.STM), for DRC review and approval.
The sleel liner has been installed in the CST: therefore, it is not possible to perform a hydrostatic
test on the steel liner prior to installation, or outside the CST.
DUSA is not aware of a standardized industry approved melhod for testing, such as an ASTM
standard. Therefore, as discussed widi DRC staff, Denison proposes to perform the following
hydrostatic test:
• The LDS will be inspected to make sure it is dry;
• All caps wiU be secured on the LDS standpipes to ensure that no moisture will get into
the LDS from the standpipes;
• All three of the CSTs will be rilled with clean water and will be left for a period of at
least 48 hours; and
• During and after the 48 hour (or longer) period, the LDS standpipes will be inspected for
any fluids. If there are no fluids, then (he test will have successfully indicated that (he
DENISO
MINES
Mi
steel liners are not leaking. If there are fluids in the LDS as observed from any of the
standpipes, then this would be an indication that the steel liner is leaking.
DUSA iiitendft (o perform the foregoi/ig hydrostatic test commencing on December 1. 2009.
Please advise if the proposed hydrostatic lest will not be acceptable or if DRC intends lo observe
the test.
If you have any questions or require any further information, please coniact the undersigned.
Yours tnily.
David C. Frydenlund
Vice President Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Robens
Steven D. Landau
David E. Turk
DENISO
MINES
MOii
OENISOJ)~~
MINES
November 16, 2009
VIA PDF AND FEDERAL EXPRESS
Mr. Dane Finerfrock
State of Utah Department of Environmental Quality
Division of Radiation Control
168 North 1950 West
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: 303 626·7796
Fax : 303 369·4125
www.denlsonmines.com
Re: August 6, 2009 Letter, White Mesa Uranium Mill Ground Water Discharge Permit
No. UGW370004 for the White Mesa Mill-New Decontamination Pad [NDP]; June
5, 2009 and June 29, 2009 DUSA Letters; May 20, 2009, DUSA Drawings of NDP;
Request for Information
Dear Mr. Finerfrock:
Reference is made to your Request for Information dated August 6, 2009 relating to the new
decontamination pad at the White Mesa Mill.
Denison Mines (USA) Corp. ("DUSA") has the following comments in re sponse to you r request
(your requests for information are stated in italics below, followed by our responses):
A. DRC proposed modifications to paragraph r) in Attachments -Proposed Modifications to
the DMT Plan found in the letter dated June 29, 2009 by Denison Mines (USA) Corp.
(hereafter "DUSA "):
I. Modify the Daily [n~pection Form (found in Section VII) to include a location on the form
to record the daily visual inspection informationfor presence offluid in all leak detection system
(LDS) vertical inspection portals for the three chambers in the concrete settling tank system for
the decontamination pad.
We have modified Section VII of the Mill's Daily In spection Form to include a location on the
form to record the daily visual inspection information for each portal. The actual portals will be
marked so that they can be identified by number.
2. On a quarterly basis submit with the DMT Performance Standard Monitoring Report a
summary of the daily visual inspections for the quarter for the presence of fluid in all LDS
vertical inspection portals for the primary and secondary containment for the three chambers in
the concrete settling tank system for the decontamination pad. The report will also include an
electronic or hard copy of daily impection forms for the quarter and reporting of any BA T
failures for the decontamination pad.
On a quarterly basis, OUSA will submit with its OMT Performance Standard Monitoring
Reports a summary of the daily visual inspections for the quarter for the presence of fluid in all
leak detection system ("LOS") vertical inspection portals for the primary and secondary
containment for the three chambers in the concrete settling tank ("CST") system for the
decontamination pad. The report will include a description of any best available technology
("BAT") failures for the decontamination pad. However, OUSA does not agree that the report
should include an electronic or hard copy of the daily inspection forms themselves. The Mill
produces many periodic inspection forms, all of which are available for inspection at the Mill by
ORC staff. No other periodic reports prepared by the Mill are required to contain copies of any
such inspection forms.
3. Should any fluid be observed in any of the LDS vertical inspection portals for the three
chambers in the concrete settling tank system for the decontamination pad, the decontamination
pad will be immediately taken out of service and be reported to the Executive Secretary as
required in Part J.G.3(a} of the Permit (see below).
Permit Part I. G.3(a}: Failure to Maintain DMT or BAT Required by Permit
a) Permittee to Provide Information --in the event that the Permittee fails to maintain
DMT or BAT or otherwise fails to meet DMT or BAT standards as required by the
permit, the Permittee shall submit to the Executive Secretary a notification and
description of the failure according to R317-6-6.6.I6(C)( I). Notification shall be
given orally within 24 hours of the Permittee's discovery of the failure of DMTor BAT,
and shall be followed up by written notification, including the information necessary to
make a determination under R317-6-6.I6(C)(2}, within five days of the Permittee's
discovery of the failure of best available technology.
If any fluid is observed in any of the LOS vertical inspection portals for the three chambers in the
CST system for the decontamination pad, this wi ll be reported to the Executive Secretary as
required by Part J.G.3(a) of the Permit. The LOS will be pumped dry immediately after the
discovery of any such fluids. If fluids continue to build up in the LOS after it is pumped dry, or
OUSA is otherwise not able to identify and remedy the source of the fluids, the decontamination
pad will be taken out of service until the source of the fluid is identified and remedied.
B. Regarding Design Issues:
4. Will the transmissivity of the compressed geonet, under fully loaded conditions,
significantly impede the flow of any horizontal flow of water through the geonet to the
monitoring locations"? Please demonstrate that the compressed geonet, under fully loaded
conditions will not significantly ciffect the flow of any leakage to the LDS monitoring pipe
locations.
OENISOJ)JJ
MINES
2
The 300 mil HOPE geonet material used in the LOS is the same material approved for the Cell
4A tailings pond LOS. The Cell 4A LOS was approved and operates with up to a 35 foot liquid
head on the geonet material. This is equivalent to l 5.1 pounds pel' square inch ("psi"). The
decontamination pad CSTs have approximately 5 feet of water plus the weight of the steel on the
geonet material. Conservatively assuming 0.5 inch of steel and 5 feet of water, the equivalent
pressure on the geonet material in the CSTs is 3.9 psi. The weight on the geonet material from
the water and steel lining will have little 01' no effect on the transmissivity of the geonet material.
5. The permeability of the concrete for the CST needs to be determined. The permeability of
the concrete can be estimated by analyzing the concrete mix design, as discussed in the
publication of the Portland Cement Association, Design and Control of Concrete Mixtures,
EB001, 131h Ed., and other field and sampling methods. We recommend the first method be used,
and the calculation for the estimated permeability of the concrete be submitted for review and
approval.
The permeability of the concrete for the CST has been estimated by Precision Systems
Engineerin¥ to likely be in the range of 2xlO'7 m2 at 7-day cure, I x 10'7 m2 at 28-day cure,
0.7xlo,7 m at one year and 0.5xlO,7 m2 at ten years. A copy of Precision Systems Engineering's
analysis is attached to this letter.
6, Sheet 3 of the drawings indicate the CST subgrade is to be prepared level. The as-built
elevations and grades of the concrete floors and elevations of the walls of the CST must be
submitted for review and approval.
Please see the attached revised as-built drawings, which indicate the as-built elevations and
grades of the concrete fl oors and elevations of the walls of the CST.
7. With respect to the above determination, the CST leakage monitoring pipes must be
placed at the locations of the lowest f700r elevation within each chamber of the CST. Please
revise the as-built drawings to show the new locations of the CST leakage monitoring pipes and
submit the revised drawings for review and approval.
Please see the attached revised as-built drawings, which show the new locations of the CST
leakage monitoring pipes.
8. Related to the above, the upper and lower elevations of the water level measuring pipes
at these new locations mentioned above must be determined and shown on the final as-built
drawings.
Please see the attached revised as-built drawin gs, which show the upper and lower elevations of
the water level measuring pipes at the new locations.
OENISONr;)~~
MINES
3
9. The details of the overlap of the steel liner cover over the exterior CST concrete walls,
with a 5pecified drip type edging, is not shown on the drawings. The design of the edging must
be so that it prevents intrusion of precipitation and wash water into the 5pace between the steel
cover and the concrete surfaces. Please revise the as-built drawings to show the details of a
specific drip type edging over the exterior CST walls, which meets the foregoing criteria, and
submit the revised drawings for review and approval.
Please see the attached revised as-built drawings, which show the details of a specific drip type
edging over the exterior CST walls, which meets the foregoing criteria.
10. The exterior edges of the installed steel liner cover over the CST must be tested to
demonstrate a "roofing" ability, as discussed in item 9 above. Please submit the results of this
testing for review and approval.
Please see the attached revised as-built drawings, which show the details of a specific drip type
edging over the exterior CST walls, which meets the foregoing criteria. The steel liner extends
approximately 6 inches down the outside edge of the CST. The extension of the steel liner down
the outsid e of the concrete containment will prevent solutions or precipitation from entering th e
area between the steel liner and the concrete walls. OUSA knows of no test to prove this
"roofing" ability. Should solution be detected in the LOS, thi s overlap of the steel liner will be
inspected as a poss ible source of leakage.
II. It is recommended DUSA perform a hydrostatic test on the steel liner prior to
installation. This test should be done outside the CST, before the steel liner is installed, so leaks
can be easily observed and repaired. Please provide an appropriate standardized and industry
approved method for this testing (e.g. ASTM),for DRC review and approval.
The steel liner has been installed in the CST; therefore, it is not possible to perform a hydrostatic
test on the steel liner prior to installation, or outside the CST.
OUSA is not aware of a standardized industry approved method for testing, such as an ASTM
standard. Therefore, as di scussed with ORe staff, Denison proposes to perform the following
hydrostatic test:
• The LOS will be inspected to make sure it is dry;
• All caps will be secured on the LOS standpipes to ensure that no moisture will get into
the LOS from the standpipes;
• All three of the eSTs will be filled with clean water and will be left for a period of at
least 48 hours; and
• Ouring and after the 48 hour (o r longer) period, the LOS standpipes will be inspected for
any fluids. If there are no fluids, then the test will have successfully indicated that the
OENISONI)~~
MINES
4
steel liners are not leaking. If there are flu ids in the LDS as observed from any of the
standpipes, then this would be an indication that the steel liner is leaking.
DUSA intends to perform the foregoing hydrostatic test commencing on December 1,2009.
Please advise if the proposed hydrostatic test will not be acceptable or if DRC intends to observe
the test.
If you have any questions or require any further information, please contact the undersigned.
Yours truly,
c#/.~
l-().r-
David C. Frydenlund
Vice President Regulatory Affairs and Counsel
cc: Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
OENISONr)JJ
MINES
5
Daily Inspection Form Revision
I
White Mesa Mill -Standard Operating Procedures
Book II: Environmental Protection Manual, Section 3.1
VII. DAilY lEAK DETECTION CHECK
CellI
Leak Detection Checked
System Checked
Wet __ Dry
Initial Initial
level level
Final Final
level level
Gal. Gal.
Cell 2
Checked
Wet __ Dry
pumped pumped
911/0&2 Revision: Denison-6
Page 22 of38
Cell 3
Checked
--Wet __ Dry
Initial
level
Final
level
Gal.
pumped
Cell4A
Checked
Wet __ Dry
Initia l
level
Final
level
Gal.
pumped
New Decon. Pad
Portal
1 ~ReelEee
--Wet __ Dry
Portal 2
Wet DrY
Portal 3
Wet DrY
Contact RSO if
Liquid is Obse rved
In Inspection Portal
z
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LW
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:;
Concrete Permeability Analysis
Precision Systems Engineering
November 13,2009
Steve Snyder
Denison Mines (USA) Corp
P.O. Box 809
Blanding, UT 84511
[e-mail]
A Consulting Engineering Rrm
fOIl,. ... OIN .. ~ .. I,.IH'I\~ rud.ly
Subj ect: Concrete Mix Assessment
Pereability
Dear Mr. Snyder:
I have reviewed the concrete mix design that you sent to Mike Vuicll'on November 9, 2009
(attached) and offer the following assessment:
I. The mix is a common design for!e' = 4000 psi air entrained concrete with a water
reducing additive. This design has the general properties of medium strength with low
W/C ratio and good workability. Permeability is low for this design as compared to
similar designs without the air entraining and water reduci ng admixes.
2. An actual value for permeability is difficult to determine from the mix design information
alone. It was likely in the range of 2x1O·7 1I,z at 7 day cure, 1.\'10,711,z at 28 day cure,
O. 7.~1O'7 11/ at one year and 0.5X}([7 11/2 at ten years.
Without testing and rigorous analysis it is not possible to determine the actual permeability of the
concrete in question. Assuming that the actual mix met the requirements of the mix design, the
concrete was placed and fini shed properly and it remains in good condition (no significant
damage, cracking, spalling, etc.) then permeability should be relatively low as compared to other
mix designs.
I hope this assessment is sufficient for your needs. If you need additional assistance with this
matter pl ease let me know.
David P. Brown, P.E., S.E.
Vice President, Operations
Cc: Mike Vuich
Attachment
PRECISION SYSTE)IS ENG INEF.IUNG 19805 Soulh 500 Wcst I Sandy. Utah 84070
Telephone (801) 9H·S555 ! Fax (801) 9"3-592 2
j\!UV IV Vtl VL.Djti nVLLlU,'-\ 1 \vVI'/01 f\.UV llVI~ fJ. I
B0e0G000000eaeee6e0~ p.e~
--IlltlDlLlLllliJ)ltr ©Ill!MSlIR\lJJ©1l'mFt!, n!~t"
BIl~ 5U2
Blanding, Utah 1l451i
t43li) 678-2028 -Office
[phone] -Residence
CONCREl'E MIle DESIGN'
MIX ID SOND 600JA r 1 4000 PSI 0J./2'1./%
CONSTRUCTION TYPE, eKterior flacwork
WElGaTS PER. CUBIC YJ\RD
Holnam ~e I-II, LB
~STM C33 Sand, US
ASTM C33 *57 1"-Rock, LB
WATER, GAL-Us (GAL-US)
TOTAL AIR, %
Hill. Bros HICO 610 WRA, OZ
Hill Bros HlCO 303 Air, OZ
WATER/Cl!NENT AATIO, LBS/r..s
SLUMP, IN
CONCRETE UNIT WEI<JllT, PC!;'
(SATURATED, -'SOR.FACE-PRYl
564
123'7
InS
33.2
6.0
YIELD, CO" 1'1'
2.87
7.63
10.63
('33.2) 4.44
+/-LO 1.63
TOl'AL
16.92 V'
G.D V
27.20
0.49 V--
4.00 V
139.6
Note! Air dosage may be adjusted to get s-~ air in ooncrete
WRA dosage may be adjust:ed for up for hot or down for cold weathe
Richard Warren
1-"l 4-'t t..
As Built Drawings
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