DRC-2009-007325 - 0901a0688015ea1f

State of Utah
GARY R. HERBERT
Guvcriior
GREG BELL
Lieutenant Governor
t^-3Cffi~DDl^?S
Department of
Environmental Quality
Amanda Smith
E.\ei iitl\c' DiiL'ctor
DIVISION OF RADIATION CONTROL
Dane L Finerfrock
Director
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
DUSA Documentum File
Dave Rupp, Geotechnical Services Section
December 23, 2009 /;?; A^/{\ t\mh
Engineering Module 75E
Tailings Cells 1-3 and Roberts Pond DMT and Cell 4A BAT Performance Standards
and Monitoring Inspection
An inspection was held on October 28-29, 2009 at the DUSA mill facilities near Blanding, Utah. Messrs.
David Rupp of DRC, David Turk, Ronnie Nieves, Ryan Palmer, and Rich Bartlett of DUSA each attended
portions ofthe inspection. A DRC letter dated November 25, 2009 was conveyed to DUSA requesting
final status of a few items, prior to closing the inspection. Photographs of this inspection can be found at
F:\drupp\DUSA\lnspections\DMT&BAT\2009\Photolog Fall 2009.ppt, and are attached as enclosure 1.
N.B. electronic margin comments are imbedded in the electronic version ofthis MEMO.
A. Problems and Remedies:
1). In the S.W. comer of Cell 4A the tailings solution recycle pipe from the pump contacts a
section ofthe FML not protected by an extra FML "rub sheet" for approximately 10-feet. In the
closeout meeting on site on October 29, 2009 Mr. Bartlett committed to adding a rub sheet to
protect the upper FML from the pipe by October 30, 2009.
The Cell 4A BAT Monitoring. Operations and Maintenance Plan, under Cell Operation, p. 3
requires that, 'The initial solution discharge will be in the southwest comer of the Cell. The
discharge pipe will be routed down the Splash Pad provided in the comer of the Cell to protect the
pipeline running from the solution reclaim barge." The retum piping is not on the rub sheet. See
photo no. 7 attached. This photo shows the return line as well as the discharge line in the S.W.
comer of cell 4A.
We recommended to DUSA that the Cell 4A BAT Monitoring, Operations and Maintenance Plan
be modified to require all pipelines entering or leaving Cell 4A be maintained with a rub sheet
beneath them.
2). Feedstock and other materials were observed on or very near the northem fence line of the
feedstock storage area. See photos no. 13-15 attached. Feedstock boundary encroachment has
been observed during other site visits by DRC.
The Ground Water Discharge Pei mit modification that is currently in process will establish certain
performance standards for feedstock found outside the feedstock storage area.
168 Norlh 1950 West • Salt Lake Cily, I'T
Mailing Address IM) Box 144850 • Sail Uke Citv. UT 84114-4850
TclcphonL-iKdl i 5.i(. 4250 • Fax [phone] .T.DD. [phone]
www.deq.Utah.^nv
I'rinft'tlon 100''^f recycled paper
Page 2
We recommend that DUSA establish minimum distances between the feedstock storage fence and
feedstock materials to prevent future violations of feedstock storage requirements outside the
boundary of the designed area. Such a buffer zone should be documented by an SOP or other
proposed method.
Mr. Bartlett conunitted that the encroaching feedstock materials would be removed from the
northem fence line ofthe feedstock storage area prior to November 15, 2009. A future DRC
inspection will revisit this issue. The HP section will probably do this. I made Ryan Johnson
aware Ofthis need, and he said he would follow up on it during a future inspection of his.
3). During our inspection it was apparent that some inspection notes taken by DUSA had been
discarded. Original handwritten copies of data should not be thrown away, even though data may
later be transcribed to electronic media. Part II.H of the Ground Water Discharge Permit requires
that the "permittee shall retain records of all monitoring information . .". This issue was brought to
DUSA's attention in my Request for Information letter, dated November 25, 2009.
4). In March of 2009 the LDS in Cell 4A had an incident for a few days where the pressure head
reached 40-inches or 3.33-feet. DRC was not previously notified ofthis incident either verbally or
in writing. Documentation ofthis event is discussed in a DUSA memo on the subject dated March
31, 2009 (see end. 2). It appears this event should have been reported per Ground Water
Discharge Permit Part I D.6 and I.G.3.
It does appear this is an anomalous event, apparently caused by reversing the polarity of the LDS
sump pump, which effectively disabled the pump.
The DMT Plan, paragraph 2.I.p, in the Daily Comprehensive Tailings Inspection section of the
plan states, "The solution level in Cell 4A leak detection is not allowed to be more than 1.0 foot
above the lowest point on the boUom flexible membrane liner (elevation 5556.14 feet amsl). If any
of these observations are made, the Mill Manager should be notified immediately and the leak
detection system pump started."
The March 31, 2009 DUSA memo shows good faith effort was made in this regard, in that repairs
to the LDS pump were completed within 2-days of discovery of the problem and mill management
was notified. However, because no verbal and written notice was provided to the DRC,
enforcement action is recommended by DRC staff, and will be prepared as a separate action.
5). Weekly inspection reports observed since August 2009, show a seven-inch (7") water level in
the Cell 2 LDS. This water was analyzed by DUSA. Copies ofthe analysis from Energy
Laboratories dated August 27, 2009 (end. 3). During the inspection DUSA staff explained that
DUSA had previously placed a lid on the LDS observation port to prevent precipitation and runoff
intrusion, and improvement of this lid is planned. These events necessitate further investigation
for compliance with the Ground Water Discharge Permit and License Conditions in this regard. A
copy ofthis memo will be shared with DRC hydro-geology staff for further investigation. DRC
review ofthis matter is ongoing.
B. Misc. Observations:
1). Mounds of tailings exist in west central Cell 3, elevated above the dike top. See Item C, below
and photos no. 10 and 12, attached.
2). DUSA continues to survey elevations of pond surfaces on Fridays.
3). Inspection of feedstock pile locations are being done by the Radiation Safety section at the
mill. Ronnie Nieves is in that section, managed by D. Turk.
Page 3
4). The leak detection system (LDS) for Cell 4A can read negative elevations. Up to -0.6-inches
has been observed by DUSA. During my visit to the site 1 watched the pump lower the LDS head.
until I stopped the LDS pump at -0.1-inches.
5). On-site DUSA records examined for DMT and BAT weekly monitoring showed no reports
were missing.
6). LDS showed a total leakage rate through Cell 4A upper liner of about 40.3 gpd, see Item E
below. The limit for the current elevation of 26.5-feet is about 500 gal/acre-day per Table 1 in the
DMT Plan. This demonstrates a cuirently very good FML leakage barrier.
7). An observed weekly inspection record on site dated August 7, 2009 showed that the Cell 2
Slimes Drain Static Head Measurements are being made in accordance with section I.E.7.b ofthe
permit.
C. Maximum Tailings Waste Solids Elevation:
"Upon closure ofany tailings cell, the Permittee shall ensure that the maximum elevation ofthe
tailings waste solids does not exceed the top ofthe flexible membrane liner (FTVIL)." [Giound
Water Discharge Permit Part I.D.3(c)]. This item was discussed during the inspection. Mounds of
tailings do currently exist in west central Cell 3, elevated above the dike top. See photos no. 10 &
12. This is not the final elevation for the tailings rriaterial. See enclosed drawing (end. 4).
Because the current requirement at Part I.D.3( c) is limited to cell closure, enforcement action is
not appropriate at this time.
D. Incident of Higher Elevation in Cell 4A
DUSA on-site records showed that on March 31, 2009 the Cell 4A LDS had an incident ofthe
elevation reaching 40-inches for 1-day. Prior to this the sump had attained a maximum level up to
26.5". The circumstances of this event are detailed in the attached memo from DUSA on the
subject dated March 31, 2009.
E. Maximum Allowable Daily LDS Flow Rates - LDS showed a leakage rate through Cell 4A
upper liner of about 40.3 gpd. The limit for the cun-ent elevation of 26.5-feet is about 500 gal/acre-
day. This demonstrates a currently very good leakage barrier.
The enclosures to this MEMO are as described below.
Enclosures:
1. Captioned photographs (6 pp.).
2. DUSA Memo dated March 31, 2009 (1 p.)
3. Water Sample Analysis by Energy Labs (2 pp).
4. Drawing of Cell 3 Mounds by R. Palmer of DUSA (1 p.).
cc: Phil Goble, DRC (w/ enclosures)
-END-
F.\drupp\DllSAN lnspcclions\20(y) MF.MO 75E I I -()<).doc
Photo 1. Inflow onto Cell 4A beach, near the northern dike.Photo 2. Spray lines for evap assistance in Cell 4A.
Photo 3. Tailings slurry influent. Cell 4A Photo 4. Former high water line. South dike of cell 4A.
Photo 5. Beach area on Cell 4A. Looking northwest.Photo 6. Wooden ramp for liquid influent and effluent from barge pump. Cell 4A.
Photo 7. Barge Pump discharge above or north in photo of influent line to Cell 4A.
Note northern line is not on rub sheet.
Photo 8. Cell 4A LDS pump flowmeter and totalizer prior to beginning pump out test.
Begun at 251,210 gallons end at 253,955 in 68 days since last pumped = 40.3 gpd.
Photo 9. Wooden approach bridge to barge Cell 4A. Note green discharge from
smaller diameter white pipe, pumped from LDS sump.
Photo 10. Cell 3. Mound of material above dike, disposal of metal containers. West
side of Cell 3. Other mounds higher than dike can be seen in photo 12 below.
Photo 11. A northern and most west corner marking for Feedstock Storage Area on
northern side of storage area. Most northern marker is about 100’ due north at fence.
Photo 12. See note above. High mound on left. Solution pool in Cell 3.
.
Photo 13. Photo 14.
Photo 13. View from the east side of a stockpile. Feedstock possibly encroaching
northern fence of storage area. Cannot differentiate feedstock for border berm soils.
Recommend DUSA establish SOP for minimum distance to fences
Photo 14. View from the west side of same stockpile. Feedstock possibly
encroaching northern fence of storage area.
Photo 15. Photo 16. New decon pad. Steel channel tops steel liner. Monitoring port looped by
vacuum hose. Channel from wash area above not currently connected.
Photo 15. View from the east side of a stockpile, north of the storage area
northern fence line. Feedstock possibly penetrating northern fence of storage
area. Cannot differentiate this material whether feedstock for border berm
soils. Recommend DUSA establish SOP for minimum distance to fences
Photo 17. Better view of the channel steel topping the exterior concrete wall of the
new decontamination pad.
Photo 18. No Photo.
Photo 18. End of Run. Meter read elevation of -0.1” at shut-off. After shut-off drainage
flow brought meter back to +0.5”. Total gals 253,955. Pump run time can be viewed, if
needed, by expanding photograph electronically.No Photo.
Denison Mines Corp.
6425 S. Highway 191, PO Box 809
Blanding, UT 84511
USA
Tel : [phone]
Fax : [phone]
www.denisonmines.com
Memorandum
To: David Turk cc: Central Files
From: Ryan Palmer
Date: 3/31/09
Re: Cell 4A leak Detection System
This report is being submitted in order to stay in compliance with the BAT monitoring syslem. The BAT
states the following will occur if an equipment failure takes place. Mill management will be notified, description
of the failure and the root cause of failure will be documented in a report to mill management. The equipment
was not running at capacity causing the head in the LDS to exceed the established limit of 12 inches above the
Secondary Flexible Membrane Liner, which on the readout is 25 inches. This exceedance created a system
failure.
On March SO"* at approximately 1050 AM the LDS on C4A was found alarming. The alarm is set to go
off at 25" of head in the leak detection pipe. When I arrived the readout said 26.5" the pump was on but the flow
meter wasn't registering the flow. New flow meter was installed a few days prior so we thought the pump had
started to go out which would account for the low yield of solution being pumped. The pump was pulled but
looked like it was just fine. We placed the pump back in the pipe and tried to pump again thinking maybe
something was clogging up the intake on the pump like crystal formation. When the pump was restarted it
seemed to pump slightly better but not what it should. At this time it was getting late in the day and the decision
was made to allow the pump to try and pump overnight and see if the pump would pick back up.
Upon arriving the morning of March 31^' the LDS was found to worse off than the day before. The
readout was in the 40 plus inches of head. It was decided the pump must be worn out so we again pulled the
pump. We tried running the pump through clean warm water out of a 60 Gallon drum, the pump performed
better than it did in the pipe so again it was thought nothing was wrong with the pump. After discussion we
decided to place a new pump in the pipe just to make sure it wasn't the pump. The new pump went in and it
also struggled much the same as the old pump did. After further talking, the electrician suggested reversing the
electncal connection on the pump. This was done and the pump began pumping at a very high volume where it
should have been pumping all along.
We are assuming that when an electrical contractor was doing some work at the substation by C4A
LDS they must have inadvertently switched the wiring on the supply end. So when our in house electrician
switched the pump connection end the pump was able to perform at full capacity once again. We feel that the
other pump which was taken out ofthe LDS is still in good working condition and will be maintained as the
backup pump for this system.
^yf^^^cX Z-
/H^VtrMefAidaiellMS
ENERGYLABOMTOP"'% INC. - 2393 Salt Creek Highway (82601)-P.O. B^'^3258 - Casper, WY82602
Toll Free 888.235.0515 • i F35.0515 - Fax [phone] • casper@energyl m' www.energylab.com
LABORATORY ANALYTICAL REPORT
Client:
Project:
Lab ID:
Client Sample ID:
Denison Mines (USA) Corp
Annual Tailings
Ce9080228^04
C2 LDS _
Report Date: 08/27/09
Collection Date: 08/04/09 11:25
DateReceived: 08/06/09
Matrix: Aqueous
Analyses Result Units Qualifiers Ri.
MCL/
QCL ^Aet^^od Analysis Date (By
IVIAJOR IONS
Carbonate as COS
Bicarbonate as HC03
Calcium
Chloride
Fluoride
Magnesium
Nitrogen, Ammonia as N
Nitrogen, Nltrate+Nitrite as N
Potassium
Sodium
Sulfate
PHYSICAL PROPERTIES
pH
Solids, Total Dissolved TDS @ 180 C
METALS - DISSOLVED
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Sliver
Thallium
Tin
Uranium
Vanadium
Zinc
RADIONUCLIDES - DISSOLVED
Gross Alpha minus Rn & U
Gross Alpha minus Rn & U Precision (±)
Gross Alpha minus Rn & U MDC
ND
168
711
1750
0.4
598
32.6
2.8
22
412
2700
6.60
6750
ND
ND
33.4
ND
314
59
208
ND
1810
ND
21
948
7.9
ND
0.92
ND
83.8
22
4220
13.5
1.8
0.8
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
s.u.
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
pCI/L
pCI/L
pCI/L
D
D
D
D
D
D
1
1
2
1
0.1
0.9
0.2
0.1
1
2
60
0.01
10
5.0
0.50
0.50
25
10
10
30
1.0
10
0.50
10
20
5.0
10
0.50
100
0.30
15
10
A2320 B
A2320 B
E200.7
A4500-CI B
A4500-F C
E200.7
A4500-NH3 G
E353.2
E200.7
E200.7
A4500-SO4 E
A4500-H B
A2540 C
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E200.8
E900.1
E900.1
E900.1
08/14/09 11:52/Ijl
08/14/09 11:52/Ijl
08/19/09 13:58/cp
08/19/09 15:42/jal
08/18/09 18:21/dvg
08/19/09 13:58/cp
08/10/09 12:32/jal
08/17/09 15:10/Jal
08/19/09 13:58/cp
08/19/09 13:58/cp
08/18/09 10:30/jal
08/07/09 11:23/hd
08/07/09 15:33/emm
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/11/09 01:03/ts
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/11/09 01:03/ts
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/11/09 01:03/ts
08/12/09 06:26/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/12/09 06:28/sml
08/24/09 16:21/cgr
08/24/09 16:21 /cgr
08/24/09 16:21/cgr
Report
Definitions:
RL - Analyte reporting limit.
QCL - Quality control limit.
MDC - Minimum detectable concentration
MCL - Maximum contaminant level.
ND - Not detected at the reporting limit.
D - RL increased due to sample matrix interference.
,^^ceA 3
mmmm
HKiMMrPJiMdlMt
ENERGY LABORATOR"'S, INC. - 2393 Salt Creek Highway (82601) • P.O. Bnv 3258 • Casper, WY 82602
Toll Free 888.235.0515 - i ?35.0515 ' Fax [phone] • casper@energyli m • www.energylab.com
LABORATORY ANALYTICAL REPORT
Client:
Project:
Lab ID:
Client Sample ID:
Analyses
DATA QUALITY
A/C Balance (± 5)
Anions
Cations
Denison Mines (USA) Corp
Annual Tailings
C09080228-004
C2LDS
Solids, Total Dissolved Calculated
TDS Balance (0.80 -1.20)
VOLATILE ORGANIC COMPOUNDS
Acetone
Benzene
Carbon tetrachloride
Chloroform
Chloromethane
Methyl ethyl ketone
Methylene chloride
Naphthalene
Toluene
Xylenes, Total
Surr: Dibromofluoromethane
Surr: p-Bromofluorobenzene
Surr: Toluene-d8
Surr: 1,2-Dlchlorobenzene-d4
Result
-1.52
109
105
6300
1.07
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
95.0
102
96.0
106
Units
%
meq/L
meq/L
mg/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
%REC
%REC
%REC
%REC
Qualifiers RL
20
1.0
1.0
1.0
1.0
20
1.0
1.0
1.0
2.0
70-130
80-120
80-120
80-120
Report Date: 08/27/09
Collection Date: 08/04/09 11:25
DateReceived: 08/06/09
Matrix: Aqueous
IMCL/
QCL IVIethod
Calculation
Calculation
Calculation
Calculation
Calculation
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
Analysis Date / By
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01/jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01/jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jir
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
08/13/09 04:01 /jlr
Report
Definitions:
RL - Analyte reporting limit.
QCL - Quality control limit.
MCL - Maximum contaminant level.
ND - Not detected at the reporting limit.
C^ ^d
TAIL
^iU rfSPCCTIOM REPORT
DATE;
ISSPECT08;
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