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Home My WebLink AboutDRC-2009-006823 - 0901a06880152c31'•'.^tftt'' State of Utah GARY R. HERBERT GREG BELL Lictiiriiaiit Govenioi- \:^'.^Ci^i~coh^p-^ Department of Environmental Quality Ani;inda Smith f.\r\-i/tn-c Divcrioi DIV|SI0^ OF RADIATION CONTROL n;mc L. FinerfrOL:k iyii-eiiov December 12, 2009 CERTIFIED MAIL (Retum Receipt Requested) David C. Frydenlund, Vice President, Regulatory Affairs and Counsel Denison Mines (USA) Corp. 1050 ) 7"" Street Suite 950 Denver. CO 80265 Dear Mr. Frydenlund: Subject: Denison Mines (USA) Corporation (DUSA) White Mesa Mill Facility DRC Inspection Results: Storm Water Best Management Practices Plan (SWBMPP), Ground Water Module 65, October 19, 2009: DRC Findings, Recommendations, and Request for Information On October 19, 2009 Tom Rushing of DRC met with David Turk of DUSA to conduct a storm water inspection at the DUSA mill facilities near Blanding. Utah. DRC appreciates the high level of cooperation by DUSA during the inspection. This letter is to provide findings related lo observed improvements lo storm water management at the mill, provide recommendations for needed improvements associated with findings during this inspection, and, request additional information lo clarify a few issues thai were not completely resolved. A copy of the DRC photos taken during the inspection is also attached for your information. Findings of Improvement: DRC noted several improvements in slorin water managemenl per the bullet hsl below: • A new underground drainage pipe was instaDed from the clenn water tank conlaitiment area to Roberts pond. This improvemenl alleviates some of the slorm water run on contributing to standing water in the area. • A new underground drainage pipe was installed from the sulfuric lank secondary containment lo Roberts pond, this again alleviates some of the storm water run on contributions lo standing water in the area. • The wetland vegeiahon in ihc aiea ofthe sulfuric acid lanks was removed and the area was dewatered and graded to remove the "swamp" area. • Work is being undeitaken to move (he decontamination pad lo. an area away front the mill processing. • A new reagent slorage building is being cunstiucled to house barrels etc. which ;ire cunently in a If.RNoiEh 195(1 Wfii-S;,!! Lake City. I'T Miiilmo Eddies'. P.G tjji-^ l448Mt • S.TII Lnke Cilj LiT841|d4S50 :ek-nlKinv(80|-. ^.";6425(|. Ru (KOI)5V-4i)07 • T.D D ISOl i 536-4414 il 11 lll.W,.!!/.'//. [•••C PDIITL'LI Oil iU'i'i; ivc ycltil |i.i|ii.i Steven Landau DRC Storm Water Inspection Findings Page 3 • DRC noied that the secondary containment for the caustic soda lank was highly deteriorated. DRC recommends thai the secondary containmenl floor for the caustic .soda tank be repaired or replaced. (See photo log, photos 27, 28 and 30) • DRC noted that the secondary containment for the soda ash tanks showed cracking on the floor (See photo log, photos 33 and 34). DRC recommends that ihe cracks be sealed/repaired. • Alternate Feed staging is currently conducted on the south side of ihe processing area on ihe soil without berms or t;ontainment. DRC noted that one of the drums which had been removed from its overpack was badly con'oded and that alternate feed material (black flake) was visible through a hole in the top ofthe barrel (see photos). DRC also noted that a trace amount ofthe black flake was visible on Ihe ground al the base of the drum. Although the storage during staging is not currently a violalicjn ofthe ground water permit, please be advised that Part I.D. 11 ofthe revised pennit will include BAT requirements for feedstock material slorage. Il is recommended thai the banels be kept in the overpack until ready to be loaded onto the alternate feed rack within the containment area i:>r other altemative method al the discretion of Denison. • DRC noted that when water from the decontamination pad tanks is transferred to the concrete vault (flushed from the Vecycle tanks) it is allowed lo discharge across open ground. DRC recommends that piping from the decontamination tanks be extended to the concrete vault to avoid potential erosion impacts and/or infiltration concems (see photos). Request for Additional Inpfrmalion: DRC IS requesting sOdhioyial informstion regarding the [allowing 2 items within 30 ca}en6ar dayj> from your receipt of this letter. -: • DRC noted that the SPCC Plan requires tank to soil potential measurements. It was unclear whether this item was being undertaken. Please provide information to clarify the intent of these measurements and whether or not the measurements are currently conducted. • Please clarify the protocols to determine whether used oil generated at the White Mesa facility is detemiined contaiiijnated (i.e. lle.(2) byproduct material) and disposed of in the tailings cell, or determined uncontaminated (or not 1 lc.(2) byproduct material) and sent offsite for recycling. Close-out Meeting ami Clt)se-oitt Conference Calls A close-oul meeting was conducted at the completion ofthe inspection on October 19, 2009 between Tom Rushing (DRC) and Davit] Turk (Denison). Additionally, a close out telephone conference call was conducted prior to mail om of this letter on December 10 amongst Loren Morton (DRC), Tom Rushing (DRC). Dave Frydenlund (Denison) and Steve Landau (Denison). If you have questions or concerns regarding this letter please contact me al (801) 536-0080. Thank you. Sincere!' honias Rushing, P.G. Geotechnical Services SeoLion Altachment: 2009 DRC Storm Water Inspection Photo Log F-nciiiRiti Wlme McsiiXblorni Wnier M,in;i^eiiicnt\L)e[]ist>iiSUTmWalei200'JHiTidinL'sLeln.i dof White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 1 of 21 Utah Division of Radiation Control Storm Water Inspection Denison Mines Corp., White Mesa Uranium Mill Inspection Date: October 26, 2009 Photo Pages Photo 1 – Sodium chlorate tanks and secondary containment. Water in containment is from and adjacent wash-down area. Photo 2 -- Kerosene tanks and soil secondary containment. Silty/clay material used for berms. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 2 of 21 Photo 3 – Ammonia tanks and soil secondary containment area. Facility reported that the tanks only required soil containment due to the age of the tanks. Photo 4 – Shop floor drain. Note oil barrel containers behind the drain and oil residue surrounding drain. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 3 of 21 Photo 5 – outdoor storage tank for shop area runoff as well as discharge from the floor drain inside of the building. DRC noted that the water in the western most tank (photo foreground) was extremely oily. Photo 6 – Shop area used oil tank and Kerosene. Facility reported that the secondary containment area is designed for the larger (used oil) tank. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 4 of 21 Photo 7 – Shop area barrel storage. Note that these barrels do not have open taps and thus do not require secondary containment. Photo 8 -- Open sump (storm water discharge point) below the ore storage pad. Discharge is to the tailings cells. DRC noted that the sump had a large accumulation of soil/clay inside. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 5 of 21 Photo 9 – Open sump (storm water discharge point) below the ore storage pad. Discharge is to the tailings cells. DRC noted that the sump had a large accumulation of soil/clay inside. Photo 10 – Proposed new vehicle contamination facility storage tanks. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 6 of 21 Photo 11 – Diversion ditch sump, below the new proposed vehicle decontamination area. Photo 12 – Diversion ditch below the proposed decontamination facility (vehicle wash). HDPE was left over from cell 4A construction. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 7 of 21 Photo 13 – Fuel tank and pump area, northeast area of facility confines (close to the scale house). Note secondary containment. Photo 14 – Fuel tank and pump area, northeast area of facility confines (close to the scale house). White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 8 of 21 Photo 15 – Current vehicle wash (Decontamination Pad). Photo 16 – Washwater containment tank (Water discharged here is after recycling of the water for truck washing/wheel washing). White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 9 of 21 Photo 17 – Wash pad discharge tank (foreground) is used after recycling of water. Discharge is to the storm water/washwater pond. Photo 18 – Pulp tank and secondary containment. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 10 of 21 Photo 19 – Area between sulfuric acid tank and water tank has been cleaned and graded. This area was previously wet, due to previous water handling, and was covered in vegetation (wetland). Work was conducted per a DRC confirmatory action letter. Photo 20 – Water tank overflow area. A new discharge line (black PVC) was installed (photo center partially covered by grass) to discharge directly to the storm water/washwater pond and prevent surface water accumulations. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 11 of 21 Photo 21 – Area between sulfuric acid tank and water tank has been cleaned and graded. This area was previously wet, due to previous water handling, and was covered in vegetation (wetland). Work was conducted per a DRC confirmatory action letter. Photo 22 – Sulfuric acid tank White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 12 of 21 Photo 23 – Sulfuric acid secondary containment water removal line, newly installed per DRC comments. Discharge from sulfuric containment is to the storm water/washwater pond. Photo 24 – Sulfuric acid tank valves and fittings (note containment area). White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 13 of 21 Photo 25 – Propane tank controls. Denison Mines recently replaced the entire system. Photo 26 – Storm Water/Wash Water pond (Should be predominantly uncontaminated water) White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 14 of 21 Photo 27 – Caustic Soda tank and secondary containment. Photo 28 – Secondary containment area for caustic soda storage. Note the highly deteriorated concrete, DRC recommended replacement/resurfacing of cement areas. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 15 of 21 Photo 29 – SX building roof drainage. Water accumulation is pumped to the SX building final tank (thence to cell 1). Photo 30 – Secondary containment area for caustic soda storage. Note the highly deteriorated concrete, DRC recommended replacement/resurfacing of cement areas. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 16 of 21 Photo 31 – SX building final tank area (blue door leads to tank). Note white trough for roof storm water collection (right side of photo). Photo 32 – Final tank inside of the SX building, discharge to Cell 1. Tanks receives water from outdoor secondary containment areas surrounding the SX building. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 17 of 21 Photo 33 – Soda Ash tanks and secondary containment. Photo 34 – Crack in secondary containment (soda ash area north of SX Building). White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 18 of 21 Photo 35 – Alternate feed circuit secondary containment and sump. Sump accumulation is pumped vertically into the circuit tanks (note black hose in photo). Photo 36 – Alternate feed circuit secondary containment and sump. Sump accumulation is pumped vertically into the circuit tanks. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 19 of 21 Photo 37 – Alternate Feed Storage (note yellow over containers background and removed barrels foreground. The barrels are highly deteriorated. Storage location is due south of the alternate feed circuit, runoff is to the alternate feed secondary storage. Photo 38 – Alternate Feed Storage (note yellow over containers background and removed barrels foreground. The barrels are highly deteriorated. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 20 of 21 Photo 39 – Photo of new chemical storage building construction. A building sump will be installed on the northeast building corner (left foreground of photo). Sump accumulations will be manually discharged to the tailings cells. Photo 40 – Large upland diversion ditch, north of cell 1 (outside of fenced facility confines). Ditch was recently re-graded and is maintained regularly. White Mesa Mill DRC Storm Water Inspection, 10/19/2009 Page 21 of 21 Photo 41 – Large upland diversion ditch, north of cell 1 (outside of fenced facility confines). Ditch is maintained regularly.