DRC-2010-003523 - 0901a068801948b0

BilM"
State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenani Governor
Department of
Environmental Quality
Amanda Smith
Executive Direcior
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
TOi
FROMi
MEMORANDUM
File
Dave Rupp ^z^^^*-
Geotechnical Services Section
DATE: June 3, 2010
SUBJECT: DUSA 2010 BAT/DMT Inspection; DRC Letter dated June 3, 2010; Engineering
Inspection Module 75E; Supplemental Infomiation
An inspection on the subject was held on May 4, 2010 at the DUSA mill facilities near Blanding, Utah.
Messrs. Phillip Goble and David Rupp represented DRC, David Turk and Ryan Palmer of DUSA attended
the field and office inspection that day. Also, Mr. Rich Bartlett of DUSA later attended a closeout meeting
with the whole group later that day. The DRC staff was on site from 8:30 a.m. to 12:50 p.m. that day.
Later that evening at about 8 p.m., Mr. Rupp spoke with Mr. Frydenlund of DUSA regarding item A2
below. The information below uses the same numbering system as our corresponding letter of June 2010.
This MEMO should be used as supplemental information.
A. Issues Identified, Remedies Proposed and Requests for Information :
1. There was some encroachment of ore-like materials on the northem ore stockpile boundary fence.
Photo No. 20 shows this. Requirements for ore feedstock area boundary clearance are discussed
here:
a. In the permit, a 4-foot clearance of feedstock from the perimeter of the ore storage pad
fence will be required by the upcoming amendment to the Ground Water Discharge Permit
Part I.D.3.f, as follows: "The Permittee shall maintain a minimum 4-foot wide buffer zone
on the inside margin of the Feedstock Storage Area between the storage area fence and the
Feedstock which shall be absent of feed material in order to assure that materials do not
encroach on the boundary of the storage area."
b. Also, the current DUSA DMT Plan paragraph 3.3.b states that, "a 4 ft. buffer is maintained
at the periphery of the storage area which is absent bulk material in order to assure that the
materials do not encroach upon the boundary of the storage area;"
We requested a photo of the completed removal work.
2. Mr. T. Rushing of DRC will follow up in an inspection this October on the improvements for the
drainage around the east of mill VPL and water tanks. Mr. Rushing coordinates storm water work
at the site. See attached photos Nos. 15-18.
195 North 1950 West • Salt Uke City, UT
Mailing Address: P.O. Bo\ 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 • T.D.D. [phone]
www.fieq.ulah.f^ov
Printed on loo's' recycled paper
MEMO
Engineering Inspection Module 75E
June 3, 2010
Page 2
3. Apparent nee(iless concems about the common dike between Cells 4A and 4B: The total top width
of the current dike between Cells 4A and new Cell 4B mistakenly appeared to me to be less than
20-feet from grading activities on the Cell 4B side of the dike, i.e. more like 13-feet in total width.
This was an illusion. The narrow travel lane is actually bounded by the fence on the east, but the
top width of the dike continues easterly. However, without photos or measurements it seemed in
memory that 13-feet was the total top width of the dike. At the time of the inspection, the apparent
"narrow top width" for the dike was a concem. I discussed a "narrow travel lane" with Messrs.
Snyder and Bartlett.
They indicated they were considering using fences and gates to control access to this dike, and
only certain traffic would be allowed. This seemed like a reasonable course of action. So, I was
not alarmed. The eastem crest of the dike has FML on top, anchor trench and a fence. From the
fence west to the westem edge of the dike is unlined soil, and appeared to be about 13-feet. No
photo was taken.
Current drawing sheet 5 of the Cell 4B White Mesa Mill project, cross-section detail 7B-3, shows
the travel lane on the dike top to be 12-feet wide, with 4-feet of the dike to be covered on each side
with geosynthetic liner materials. A 2-foot wide FML anchor trench is also shown on each side of
the detail. See copy of drawing sheet no. 5 attached.
Later, the following week I discussed this apparent narrow dike width with Loren. He consulted
with URS. We became concemed that potentially the dike was unstable. This concem was due to
the tailings load on from Cell 4A from the east and no opposing load from Cell 4B on the west.
Potentially the dike was so weakened from narrowing its width, that we had an existing structurally
unstable dike. In a telephone discussion on this topic with Ms. Tischler on May 17, 2010, it was
understood that DUSA was planning to restore the dike width with fill material.
On May 19, 2010 in a telephone discussion with Mr. Harold Roberts of DUSA, he indicated that
the total existing dike width from shoulder to shoulder measured 22 or more feet wide. He did
state that a short safety berm had been removed from the west side of the dike. This makes the
dike travel lane to the edge of the dike about 14-feet wide. Therefore, our concems regarding the
structure of the dike, associated with a "narrower dike width" appear to be based on visual and
communication misperceptions.
4. Surveying of Settlement Monitors: These remarks are provided as recommendations to help
increase surveying accuracy for the Settlement Monitoring System.
The items below this point are not included in the June 3, 2010 letter.
5. Excavation Contractor. DRC staff observed the excavation work on proposed Cell 4B area. It
appears that potentially, months of excavation remains to be done. Mr. Robert Kowey(sp) of KGL
Excavating appears to be the excavation superintendent.
6. Regarding the Cell 2 Leak Detection System (LDS). DRC staff noted that 7-inches of water
continues to persist at the bottom of this LDS. DUSA daily reports show a seven-inch (7") water
level in the Cell 2 LDS beginning in November 2008. An entry of "Working on pumping out
solutions," was reported in a daily inspection report of November 12, 2008. A sample of the
water was analyzed and the lab results report dated August 27, 2009 by Energy Laboratories.
Copy attached.
MEMO
Engineering Inspection Module 75E
June 3, 2010
Page 4
D. All sampling, analysis, and evaluation of LDS fluids shall be documented and retained onsite
until license termination for Executive Secretary inspection."
B. Maximum Allowable Daily LDS Flow Rates - During the inspection the pump in Cell 4A LDS
was not manually operated. The volume of water removed by the pump over the time period ofthe
last leakage collection period of October 28, 2009 to March 12, 2010 was 3,295 gallons. This
volume spread over a 136 day collection period shows an average leakage rate through the Cell 4A
upper liner of about 24.2 gallons per day (gpd) for the entire pond. The leakage rate limit for the
estimated Cell 4A water depth of 26.5-feet on the upper liner is about 500 gallons/acre-day or
about 20,000 gpd. This indicates a good liner performance and minimal leakage is occurring in
Cell 4A. Email and other records regarding this information is also attached.
Attachments:
1. Inspection Photos
2. C2 LDS Leakage Chemical Analysis dated August 27, 2009 by Energy Laboratories
3. Drawing Sheet 5
4. Records of Cell 4A Leakage Rates
DAR:dr
Cc: D. Henderson
T. Rushing
F:\DUSA\Insps\2010 MEMO BAT-DMT 5-lO.doc
File: Documentum
MEMO
Engineering Inspection Module 75E
June 3. 2010
Page 3
During the inspection DUSA staff showed and explained that there is a lid in place on the LDS
monitoring port, to prevent precipitation from entering the LDS monitoring port standpipe. The lid
does not completely seal the monitoring port. The DUSA staff mentioned that improvement to this
lid has not occurred yet. Photos Nos. 2 and 4 show this lid. Continued DRC review ofthis matter
will be assigned to a Geotechnical Services Section hydro-geologist.
For Reference on DMT Leakage:
Regarding leakage from Cell 2, License Condition 11.3 includes provisions A-D that,
A. "...If sufficient fluid is present in the leak detection system (LDS) of any cell, the licensee
shall pump fluid from the LDS, to the extent reasonably possible, and record the volume of
fluid recovered. Any fluid pumped from an LDS shall be retumed to a disposal cell.
If fluid is pumped from an LDS, the licensee shall calculate the flow rate by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last pumped or
increases in the LDS fluid levels were recorded, whichever is the more recent. The licensee
shall document the results of this calculation.
B. Upon the initial pumping of fluid from an LDS, the licensee shall collect a fluid sample and
analyze the fluid for pH and the parameters listed in paragraph A of this license condition. The
licensee shall determine whether the LDS fluid originated from the disposal cell by
ascertaining if the collected fluid contains elevated levels of the constituents listed in paragraph
A of this license condition or has a pH level less than 5.0. If either elevated constituent levels
or a pH less than 5.0 is observed, the licensee shall assume that the disposal cell is the origin of
the fluid.
If the LDS fluid is determined not to have originated from the disposal cell, the licensee shall
continue with weekly measurements of "depth to fluid" in the LDS standpipes. The licensee
shall confirm, on an annual basis, that fluid from the disposal cell has not entered the LDS by
collecting (to the extent possible) and analyzing an LDS fluid sample for the above stated
parameters.
C. Upon indication that the LDS fluids originated from the disposal cell, the licensee shall
determine the flow rate through the liner by the calculation method in paragraph B of this
license condition. If the flow rate is equal to or greater than one gallon per minute, the licensee
shall:
(1) Evaluate the cause of the liner distress and take appropriate and timely actions to
mitigate the leak and any consequent potential impacts;
(2) Continue to measure and record LDS "depth to fluid" measurements weekly; and
(3) Notify the Executive Secretary by telephone within 48 hours, in accordance with
License Condition 9.2, and submit a written report within 30 calendar days of
notifying the Executive Secretary by telephone, in accordance with License
Condition 9.2. The written report shall include a description of the mitigative
action(s) taken and a discussion of the mitigative action results.
If the calculated flow rate is less than one gallon per minute, the licensee shall continue
with weekly measurements of "depth to fluid" in the LDS standpipes.
DUSA Inspection Photos by D.Rupp, taken 5/4/2010.

1. Photo of Cell 4A LDS Controller/Recorder Board. 8.2” of leakage.
Volume totalizer read 257,250 gallons pumped since estimated LDS
startup date on 9/17/2008.

2. Existing yellow plastic lid to exclude precipitation from the
LDS for Cell 2.

3. Slimes drain control box and top of standpipe for Cell 2 Slimes.

4. Close-up of existing yellow plastic lid to exclude precipitation from the LDS
for Cell 2. Depth graduated PVC blow tube exposed and attached to lid slot.

5. Archaeological site excavation in or near west dike of Cell 4B.
6. Beach surface only existing on north side of Cell 4A.

7. Cut into existing dike on Cell 4B side of Cell 3/4B dike.

8. Northern dike of future Cell 4B on interior looking west.

9. Area of the northeast corner of future Cell 4B.

10. Truck hauling excavation from future Cell 4B.

11. Sprayer spouts for evaporation on south dike of Cell 1.

12. Roof trusses and walls of new Reagent Building.

13. Pallets with reagents on sump of reagent storage bldg.

14. Northern opening to reagent storage building.

15. Mud and water pooling from storm water runoff and steam near the
pictured VPL and water tank just east of Mill building.
16. Mud and water pooling from storm water runoff and steam near the
VPL and water tank just east of Mill building. See above photo.

17. Mud and water pooling from storm water runoff and steam east of the
pictured VPL and water tank just east of Mill building. See above photo.

18. Pipe from the existing decontamination pad adjacent and north of the
VPL and water tank just east of Mill building. See above photo.

19. Existing Decontamination Pad (EDP), just east of Mill building.

20. Northern fence of the ore stockpile area, looking east.
Fence across from cut-off ore pile still has soils against the fence.

21. Water entering the south compartment of the steel lined concrete storage tank (CST)
on May 4, 2010.

Photo 22. 5/4/10 view of the CST from the southern end.

23. East wall of the new decontamination pad (NDP) to the left, and the
CST from southern end.

24. View from the top of the eastern NDP wash wall and the CST
seen from above.

25. Washing down exiting ore truck on the NDP. May 4, 2010.

26. Wash down water from the NDP discharging into west side
of the CST on 5/4/10.

F:\drupp\DUSA\Insps\DMT&BAT\InspPhotos 5/4/10.doc
wmmm ENERGY LABORATOP"=% INC. ^ 2393 Salt Creek Highway (82601)-P.O. 80^3258 - Casper, WY82602
Toll Free 688.235.0515 • . 135.0515 • Fax [phone] • casper@energyl. m' Vfww.erier^^.com
LABORATORY ANALYTICAL REPORT
Client:
Project:
Lab ID:
Client Sam|4|e ID: 02 LDS
Denison Mines (USA) Corp
Annual Tailings
G09O8O228=eO4
Report Date: 08/27/09
Collection Date: 08/04/0911:25
DateReceived: 08/06/09
Matrix: Aqueous
MCL/
Result Units Qualifiers RL QCL Method Analysis Data \ By
MAJOR IONS
Carbonate as C03 ND mg/L 1 A2320 B 08/14/09 11:52/Ijl
Bicarbonate as HC03 168 mg/L 1 A2320B 08/14/09 11:52/Ijl
Calcium 711 mg/L D 2 E200.7 08/19/09 13:58/cp
Chtoricie 1750 mg/L 1 A4500-CI B 08/19/09 15:42/jal
Fluoride 0.4 mg/L 0.1 A4500-F C 08/18/09 18:21 /civg
Magnesium 596 mg/L D 0.9 E200.7 08/19/09 13:58/cp
Nitrogen, Aitinionia as N 32.6 mg/L D 0.2 A4500-NH3 G 08/10/09 12:32/jal
Nitrogen, Nitrate-fNitrife as N 2.8 nng/L 0.1 E353.2 08/17/09 15:10/jal
Potassium 22 mg/L D 1 E200.7 08/19/09 13:58/cp
Sodium 412 mg/L D 2 E200.7 08/19/09 13:58/cp
Sulfate 2700 mg/L D 60 A4500-SO4 E 08/18/09 10:30/jal
PHYSICAL PROPERTIES
pH 6.60 s.u. 0.01 A4500-H B 08/07/09 11:23/hd
Solids, Total Dissolved TDS @ 180 C 6750 mg/L 10 A2540C 08/07/09 15:33/ emm
METALS - DISSOLVED
Arsenic ND ug/L 5.0 E200.8 08/12/09 06:28/smi
Beryllium ND ug/L 0.50 E200.8 08/12/09 06:28/smi
Cadmium 33.4 ug/L 0.50 E200.8 08/12/09 06:28/smI
Chromium ND ug/L 25 E200.8 08/11/09 01:03/ts.
Cobalt 314 ug/L 10 E200.8 08/12/09 06:28/smi
Copper 59 ug/L 10 E200.8 08/12/09 06:28/smi
Iron 208 ug/L 30 E200.8 08/12/09 06:28/smi
Lead ND ug/L 1.0 E200.8 08/12/09.06:28/smi
Manganese 1810 ug/L 10 E200.e 08/12/09 06:28/smi
Mercury ND ug/L 0.50 E200.8 08/11/09 01:03/ts
Molybdenum 21 ug/L 10 E200.8 08/12/0906:28/smi
Nickel 948 ug/L 20 E200.8 08/12/09 06:28/smi
Selenium 7.9 ug/L 5.0 E200.8 08/12/09 06:28/smi .
Silver ND ug/L 10 E200.8 08/11/09 01:03/ts
Tfiallium 0.92 ug/L 0.50 E200.8 08/12/09 06.26/smi
Tin ND ug/L 100 E200.8 08/12/09 06:28/smi
Uranium 83.8 ug/L 0.30 E200.8 08/12/09 06:28/smi
Vanadium 22 ug/L 15 E200.8 08/12/09 06:28/smi
Zinc 4220 ugA. 10 E200.8 08/12/09 06:28/smi .
RADIONUCLIDES - DISSOLVED
Gross Alpha minus Rn & U 13.5 pCi/L E900.1 08/24/09 16:21 / cgr
Gross Alpha minus Rn & U Precision (±) 1.8 pCi/L E900.1 08/24/09 16:21 /cgr
Gross Alpha minus Rn & U MDC 0.8 pCi/L E900.1 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.
•L ADORA rORIBS'
ENERGY LABORATOR""i, INC. ' 2393 Salt Creek Highway (8^1) • P.O. Bny3258 • Casper, WY82602
Toll Free 888.235.0515 • i 135.0515 • Fax [phone] • casper@energyli m • www.energylab.com
LABORATORY ANALYTICAL REPORT
Client:
Project:
Lab ID:
Client Sample ID:
Denison Mines (USA) Corp
Annual Tailings
C09080228-004
C2 LDS
Report Date: 08/27/09
Collection Date: 08/04/09 11:25
DateReceived: 08/06/09
Matrix: Aqueous
Analyses Result Units Qualifiers RL
MCU
QCL Method Analysis Date / By
DATA QUALITY
NZ Balance (± 5)
Anions
Cations
Solids, Total Dissolved Calculated
TDS Balance (0.80 -1.20)
-1.52
109
105
6300
1.07
%
meq/L
meq/L
mg/L
Calculation
Calculation
Calculation
Calculation
Calculation
08/24/09 08:07 / Icbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
08/24/09 08:07 / kbh
VOLATILE ORGANIC COMPOUNDS
Acetone ND
Benzene ND
Carbon tetrachloride NO
Chloroform ND
Chloromethane ND
Methyl ethyl ketone ND
Methylene chloride ND
Naphthalene ND
Toluene ND
Xylenes, Total ND
Surr: Dibromofluoromethane 95.0
Surr: p-Bromofluorobenzene 102
Surr: Toluen6-d8 96.0
Surr: 1,2-Dichlorobenzene-d4 106
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
ug/L
%REC
%REC
%REC
%REC
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
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
SW8260B
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
08/13/09
04:01 /jlr
04:01 / jlr
04:01 /jlr
04:01 /jlr
04:01 / jlr
04:01 / jlr
04:01 /jlr
04:01 / jlr
04:01 / jlr
04:01 / jlr
04:01 / jlr
04:01 / jlr
04:01 / jlr
04:01 /jlr
Report
Definitions:
RL - Analyte reporting limit.
QCL - Quality control limit.
MCL - Maximum c:ontaminant level.
ND - Not detected at the reporting limit.
OAiu rfspecnow REPORT
TAiLlHfiS SLUm DISCHARGE LOCATION
DATE: ^
ISSPECTOR:
Page 1 of 1
Dave Rupp - Cell 4A LDS numbers
•f^^-:.7ns,:mmifwj.-}i»Ke>m^^'..>/.-i<'/:%
From: Ryan Palmer <[e-mail]>
To: "[e-mail]" <[e-mail]>
Date: 5/10/2010 12:45 PM
Subject: Cell 4A LDS numbers
CC: David Turk <[e-mail]>
Mr. Rupp, •
I located the information that you requested. On October 28 2009 the reading on solution level was 10.1 and the total
volume pumped reading was 251210. On October 29 2009 the solution level was 2.1 and the volume total was 253955. This
reading then carries you into the information that you collected here at the mill during your inspection on May 4 2010. If you
need any additional information please let me know.
Ryan Palmer
Enviro-tech/Accounting
t; 435-678-2221 x102 | f: 435-678-2224
6425 8. Highway 191, PO Box 809, Blanding, UT 84511
DENISON MINES (USA) CORP
www.denisonmines.com
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