DRC-2012-001722 - 0901a068802f9cc7

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State ofUtah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Govemor
August 8, 2012
DRC-2012-001722
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
CERTIFIED MAIL
(Return Receipt Requested)
JO Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp (DUSA)
1050 Seventeenth St Suite 950
Denver, Colorado, 80265
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RE 8/8/12, MINOR PERMIT MOD/CB
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, CO 80265
PS Form 3»00, August 2006 Seis Reverse for Instructions
Subject August 8,2012 Minor Permit Modification, Ground Water Quality Discharge Permit
UGW370004 for the DUSA White Mesa Mill
Dear Ms Tischler
The DUSA Ground Water Quality Discharge Permit, UGW37000, has been modified m accordance with
the Division of Radiation Control letter to Jo Ann Tischler, of DUSA, dated August 2,2012 A copy of the
Permit showmg the modifications m red-line stnkeout format is included as Attachment A ofthe Statement
of Basis (SOB) Also enclosed is a signed copy of the first page of the Permit and the pages affected by
this modification These Permit modifications were considered minor or more protective to public health
and the environment, therefore, it was not necessary to conduct a public meeting for the revised Permit
These modifications have been mcorporated mto Ground Water Quality Discharge Permit UGW370004
Permit effective August 8,2012 Enclosed are copies of the SOB and the Final Revised Permit
We request that you carefiilly review the permit m order to ensure future compliance with its provisions If
you have any questions or comments, please contact Charles Bishop at [phone]
Division of Radiation Control
Director \J Rusty Lundb
RL/CB cb
Enclosures SOB, and affected Pages of the Ground Water Quality Discharge Permit
F V \wp\Denison\l'* 2012 Permit Mod\8-8-2012 Permit Mod transmittal letter docx
168 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850 ^
Telephone [phone] • Fax [phone] -TDD (801) 536^14
www deq Utah gov
Pnnted on 100% recycled paper
Page 2
Pemiit No. UGW370004
STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CITY, UTAH 84114-4870
GROUND WATER DISCHARGE PERMIT
In comphance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 17*" Street
Denver, Colorado 80265
IS granted a ground water discharge permit for the operation of a uramimi milling and tailings
disposal facility located approximately 6 miles south of Blanding, Utah The facility is located on a
tract of land m Sections 28,29,32, and 33, Tovmship 37 South, Range 22 East, Salt Lake Base and
Mendian, San Juan County, Utah.
The permit is based on representations made by the Permittee and other information contamed m the
admimstrative record. It is the responsibility of the Permittee to read and understand all provisions of
this Permit
The miUmg and tailmgs disposal facility shall be operated and revised m accordance with conditions
set forth m the Permit and the Utah Ground Water Quality Protection Regulations.
This modified Ground Water Quality Discharge Permit amends and supersedes all other Ground
Water Discharge permits for this facility issued previously
This Permit shall become effective on August 8.2012.
This Permit shall expue March 8,2010 (This Permit is in Trniely Renewal)
Application for Permit Renewal was received September 1, 2009, and resubmitted on July 13,
2012 at the request ofthe DRC
Signed this^^day of A^gU^2011
Duector
Division of Radiation Control
Table of Contents
PART I SPECIFIC PERMIT CONDITIONS . 1
A. GROUND WATER CLASSMCATION ... . 1
B. BACKGROUND WATER QUALITY . ... 1
C PERMIT LIMITS . . . . 2
1 Ground Water Compliance Limits ... ... 2
2 Tailings Cell Operations ... . .. 2
3 Prohibited Discharges . . ... 2
D. DISCHARGE MINIMIZATION AND BEST AVAILABLE TECHNOLOGY STANDAPODS 6
1. DMT Design Standards for Existing Tailings Cells 1, 2, and 3 .... .. 6
2. Existing Tailings Cell Construction Authonzed . . . . .8
3 Existmg Facility DMT Performance Standards ... . .. .8
4 Best Avallable Technology Requirements for New Constmction. . .. .11
5. BAT Design Standards for Tailings Cell 4A . ... 11
6 BAT Performance Standards for Tailings Cell 4A . . ..14
7 Defimtionof lle(2) Waste .... .14
8 Closed Cell Performance Requirements . .14
9 Facility Reclamation Requirements . • ..15
10 Stormwater Management and Spill Control Requirements ... . 15
11 Requirements for Feedstock Matenal Stored Outside the Feedstock Storage Area . 15
12 BAT Design Standards for Tailings Cell 4B 16
13 BAT Performance Standards for Tailmgs Cell 4B . . .... 19
14 BAT Performance Standards for the New Decontamination Pad. 19
E GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING . 20
I Routme Groundwater Compliance Momtonng . 20
2—Groundwater Momtonng- General Momtonng Wells MW-20 and MW-22 2t~
3 Groundwater Head Momtonng . . . ... 21
4 Groundwater Momtonng Well Design and Constmction Cntena .. 21
5 Momtonng Procedures for Wells . .... . 22
6 White Mesa Seep and Spnng Momtonng ... .22
7 DMT Performance Standard Momtonng. . ... . . . .23
8 BAT Performance Standard Momtonng . . .... . ... 24
9 On-site Chemicals Inventory . . 25
10 Tailmgs Cell Wastewater Quality Momtonng . 25
II Groundwater Momtonng Modifications .... ... 26
12 BAT Performance Standard Momtonng . .... . . ... 26
F REPORTING REQUIREMENTS. . 27
1 Routme Groundwater Momtonng Reports . ... ... 27
2 Routine DMT Performance Standard Momtonng Report ... 28
3 Routine BAT Performance Standard Momtonng Reports .. . .29
4 DMT and BAT Performance Upset Reports . ... .29
5. Other Information . 29
6 Groundwater Monitonng Well As-Built Reports .. .29
7 White Mesa Seeps and Spnngs Momtonng Reports . 30
8 Chemicals Inventory Report .... . ..31
9 Tailings Cell Wastewater Quality Reports .. . 31
10 Revised Hydrogeologic Report . . .31
11 Annual Slimes Dram Recovery Head Report . ..31
l:2~DecontaminatioirPads AnnuarinspectionTRepoff 3T
G OUT OF CoMPLL\NCE STATUS . . 32
PartlE
PemutNo UGW370004
head m the leak detection system sump exceed a 1-foot level above the lowest pomt
m the lower flexible membrane lmer on the cell floor For purposes of comphance
momtonng this 1-foot distance shall equate to 2 28 feet above the leak detection
system transducer
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS Under no circumstances shall the average
daily LDS flow volume exceed 24,160 gallons/day.
4) 3-foot Minimum Vertical Freeboard Cntena - the Permittee shall operate and
mamtam wastewater levels to provide a 3-foot Minimum of vertical freeboard m
Tailmgs Cell 4A Said measurements shall be made to the nearest 0.1 foot
b) Quarterly Slimes Dram Recovery Head Momtonng - immediately after the Permittee
imtiates pumpmg conditions in the Tailmgs Cell 4A slimes dram system, quarterly
recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts ID 3 and I E.7(b) of this Permit and the currently approved Cell
4A BAT, Momtormg, Operations and Maintenance Plan.
c) Lmer Mamtenance and Repair - all repairs to the lmer shall be completed m accordance
with Section 9.4 of the approved June 2007 Geosyntec Consultants Cell 4A
Constmction Quality Assurance Plan (CQA/QC Plan) as found m Table 5 of this Permit
Repairs shall be performed by qualified lmer repair personnel and shall be reported m a
Lmer Repair Report, certified by a Utah hcensed Professional Engmeer The Lmer Repau
Report shall be submitted to for Executive Secretary approval in accordance with Part
T F 3 of the Permit Any leak, hole, or other damage to the hner will be reported to the
Executive Secretary pursuant to the requirements found m Part IG 3
9. On-site Chemicals Inventory - the Permittee shall monitor and mamtain a current mventory
of all chemicals used at the facility at rates equal to or greater than 100 kg/yr Said mventory
shall be mamtamed on-site, and shall mclude, but is not limited to
a) Identification of chemicals used m the millmg process and the on-site laboratory, and
b) Determination of volume and mass of each raw chemical currently held m storage at the
facility
10. Tailmgs Cell Wastewater Quality Momtormg - on an annual basis, the Permittee shall collect
wastewater quality samples from each wastewater source at each tailmgs cell at the facility,
mcludmg, but not limited to*
a) One surface impounded wastewater location at each of Tailmgs Cells 1, 3,4A, and 4B.
b) One slimes drain wastewater access pipe at each of Tailmgs Cells 2,3,4A, and 4B For
Cells 3, 4A, and 4B, this requirement shall apply immediately after imtiation of de-
watenng operations at these cells, and
c) One leak detection wastewater access pipe at Tailmgs Cells 4A and 4B
d) All such sampling shall be conducted m August of each calendar year in comphance with
the currently approved White Mesa Uramum Mill Tailing and Slimes Dram Sampling
Program. Said annual momtormg shall mclude, but is not limited to.
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Part IE
Permit No. UGW370004
1) Water Quality Sampling and Analysis - the Permittee shall collect grab samples and
perform laboratory analysis of all
I Water quality parameters identified in Table 2 of this Permit, and
II Semi-volatile compounds identified m EPA Method 8270D
2) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory.
3) Analytical Methods - all laboratory analysis shall be conducted using analytical
methods listed m the currently approved QAP pursuant to Part I E.l of this Permit
4) Mimmum Detection Limits - all water quality analyses reported shall have a
mimmum detection limit or reportmg limit that is less than or equal to the respective
I Ground Water Quality Standards concentrations defined in Table 2 of this Penmt,
II For TDS, Sulfate, and Chlonde, the Mimmum Detection Limit for those
constituents for Tailing Cell wastewater momtonng will be as follows 1,000
mg/L, 1,000 mg/L, and 1 mg/L, respectively, and
111. Lower limits of quantitation for groundwater for semi-volatile organic
compounds listed m Table 2 of EPA Method 8270D, Revision 4, dated Febmary,
2007
5) Quality Control Samples - the Permittee will conduct quality control (QC) sampling
and analysis as a part of all tailmgs wastewater sampling, m accordance with the
requirements of Section 4 3 of the currently approved QAP, pursuant to Part IE 1 of
this Permit Said QC samples shall include, but are not limited to- tnp blanks,
duplicate samples, and equipment nnse blanks
6) Pnor Notification - at least 30 calendar days before any water quality sample
collection, the Permittee shall provide vmtten notice to allow the Executive Secretary
to observe or split sample any tailings cell, shmes dram, or leak detection
wastewaters
7) Sample Omission - m the course of each aimual sampling event, the Permittee shall
sample and analyze all tailmgs cell, slimes drain, and leak detection wastewater
sources identified m the currently approved Tailmgs and Shmes Dram Sampling
Program (pp 1 -3), or as required by this Permit, whichever is greater The Permittee
shall not omit samplmg of any of tailings cell wastewater source dunng said annual
event, without pnor wntten approval from the Executive Secretary
11 Groundwater Momtormg Modifications - before any modification of groundwater momtormg
or analysis procedures, methods, or equipment, the Permittee must obtain pnor wntten
approval from the Executive Secretary
12 Cell 4B BAT Performance Standards Momtonng and Maintenance - immediately followmg
Executive Secretary approval ofthe Cell 4B BAT, Momtonng, Operations and Mamtenance
Plan, the Permittee shall immediately implement all momtonng and recordkeeping
requirements therein The Cell 4B BAT momtormg shall include the following
a) Weekly Leak Detection System (LDS) Momtonng - mcludmg
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