DRC-2012-001723 - 0901a068802f9cc8

2012-001723 /"FILE
GROUND WATER QUALITY DISCHARGE PERMIT UGW370004
Statement of Basis
Fora
Uramum Millmg Facihty
South of Blanding, Utah
Owned and Operated by
Demson Mines (USA) Corp.
Independence Plaza, Smte 950
1050 17th Street
Denver, Colorado 80265
August 6, 2012
PURPOSE
This Statement of Basis (hereafter SOB) descnbes the techmcal and regulatory basis for a
proposed modification to a requirement found in Ground Water Quality Discharge Pemut No
UGW370004, (hereafter Permit) for the Demson Mines (USA) Corp. (hereafter DUSA) uramum
mill facility located about six miles south of Blandmg, Utah m Sections 28, 29, 32, and 33,
Township 37 South, Range 22 East, Salt Lake Baseline and Mendian, San Juan County, Utah
The Permit is issued piu-suant to Utah Water Quality Rule Section R317-6, which requires any
persons who constmct, mstall, or operate any new facility or modify an existmg or a new facility,
not permitted by mle under R317-6-6.2, which discharges water or would probably result m a
discharge of water, to obtain a Ground Water Quality Discharge Permit Pursuant to 19-5-102
Utah Code Annotated the Utah Division of Radiation Control (hereafter DRC) has the
junsdictional authonty and oversees the Permittee's Ground Water Quality Discharge Permit and
ensures that all applicable regulatory requirements are met
The change to the permit is considered mmor by the Director of the DRC, and therefore it does
not need to be submitted for public comment Mmor changes to the Permit are those that are
considered to have no impact on the protection ofthe environment, to be more strmgent or
protective than those afready authonzed m the existmg Permit, or administration m nature to
clanfy Permit conditions. The change considered below, will be mtegrated into the next Permit
modification, which will succeed the previous Permit modification, dated July 14,2011 (see
Attachment A for the redlme/stnkeout pages affected by this revision of the Permit)
The change associated with this Mmor Permit modification is the requurement to collect field
measurements pH, temperature, and specific conductivity at the tailmg cells for tailmgs
wastewater samplmg on an annual basis is removed. The DRC evaluated the need for this
requirement m a memorandum dated July 19, 2012 (see Attachment B) Field conditions make
these measurements relatively imprecise, since the low pH ofthe tailing cells wastewater affects
the precision of the mstruments. In addition, null personal collecting these wastewater samples
are at nsk, due to the corrosive nature of the wastewater they are m contact with, dunng the time
it requires to take these measurements Groundwater protection is not compromised by
removmg this requirement, given that they are akeady recorded at the analytical laboratory with
much more precision, and safety at the facility will be mcreased The DRC informed DUSA of
the removal of Part E.IO (d)(1) ofthe Permit m a DRC letter dated August 2,2012 (see
attachment C)
References
Utah Division of Radiation Control, July 190, 2012, Mmor modification to DUSA Ground Water
Discharge Permit (hereafter "Permit") UGW370004 White Mesa Uramum Mill, near
Blanding Utah Memorandum from Dean Henderson to Charles Bishop
Utah Division of Radiation Control, August 2,2012, DRC Letter, Tailings Cell, Leak Detection
System and Slimes Dram Sampling and Analysis Plan Revision 2 1, Denison Mines
(USA) Corp White Mesa Uramum Mill, near Blanding Utah, Approval
Attachment A
redlme/stnkeout pages affected by this revision of the Permit
PennitNo 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 compliance with the provisions ofthe Utah Water Quahty 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 uramum millmg and tailings
disposal facility located approximately 6 miles south of Blandmg, Utah. The facility is located on
a tract of land in Sections 28, 29, 32, and 33, Township 37 South, Range 22 East, Salt Lake Base
and Mendian, San Juan County, Utah.
The permit is based on representations made by the Pemuttee and other mformation contamed m
the admimstrative record. It is the responsibility of the Permittee to read and understand all
provisions of this Permit
The millmg 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 facihty issued previously
This Permit shall become effective on August 8, 2012
This Pemut shall expire March 8. 2010 (This Permit is m Tunely Renewal)
Apphcation for Permit Renewal was received September 1, 2009, and resubmitted on Julv 13,
2012 at the request ofthe DRC
Signed this day of , 2012
Director
Division of Radiation Control
Part IE
PemutNo UGW370004
d) All such samplmg shall be conducted in August of each calendar year m compliance
with the currently approved White Mesa Uramum Mill Tailmg and Slimes Dram
Samplmg Program Said annual momtonng shall mclude, but is not limited to
1) Field Measurements—mcludmg pH, temperature, and specific conductivity
2) 1} Water Quality Samplmg and Analysis - the Permittee shall collect grab
samples and perform laboratory analysis of all-
I Water quality parameters identified m 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.
4) 3} ^Analytical Methods - all laboratory analysis shall be conducted usmg
analytical methods listed m the currently approved QAP pursuant to Part IE 1 of
this Permit.
5) 4) ^Minimum 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:
' 1. Groimd Water Quahty Standards concentrations defined m Table 2 of this
Permit,
11 For TDS, Sulfate, and Chlonde, the Minimum Detection Limit for those
constituents for Tailmg Cell wastewater monitonng 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 orgamc
compounds listed m Table 2 of EPA Method 8270D, Revision 4, dated
Febmary, 2007
6) 5} Quality Control Samples - the Permittee will conduct quality control (QC)
samplmg and analysis as a part of all tailmgs wastewater samplmg, m accordance
with the requirements of Section 4 3 of the currently approved QAP; pursuant to
Part I.E 1 of this Penmt. Said QC samples shall mclude, but are not limited to.
tnp blanks, duplicate samples, and equipment nnse blanks
7) 6} ^Pnor Notification - at least 30 calendar days before any water quality
sample collection, the Permittee shall provide wntten notice to allow the
Executive Secretary to observe or spht sample any tailmgs cell, slunes dram, or
leak detection wastewaters
S)7} Sample Omission - in the course of each aimual samplmg event, the
Pemuttee shall sample and analyze all tailings cell, slimes dram, and leak
detection wastewater sources identified m the currently approved Taihngs and
Shmes Drain Sampling Program (pp 1-3), or as requured by this Pemut,
whichever is greater The Pemuttee shall not omit samplmg of any of taihngs cell
wastewater source dunng said annual event, without pnor wntten approval from
the Executive Secretary
Attachment B
Memorandum
State ofUtah
GARY R HERBERT
Govemor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO
FROM
DATE:
SUBJECT:
Charlie Bishop
Dean Henderson
July 19,2012
Mmor Modification to DUSA Ground Water Discharge Pemut (hereafter 'Termit")
UGW370004 White Mesa Uramum Mill, near Blandmg, Utah
The taihngs wastewater solutions have pH measurements between 1 and 3. These solutions
corrode the field meters dunng the collection of field measurements (pH, specific conductivity,
and temperature) To prevent equipment damage, loss of measurements, and to protect health and
safety of null personnel from the corrosive tailmgs wastewater solutions, DRC Staff believes that
the measurements of field parameters are not necessary. The parameter pH will still be analyzed
by the analytical laboratory. The DRC already knows that pH in the waste water from tailmg cells
are very low, we don't need a field measurement to prove it to us Therefore, Part IE 10(d)(1) of
the Permit that requires: "Field Measurements - includingpH, temperature, and specific
conductivity" is not necessary and can be removed
Attachment C
Letter to DUSA
State ofUtah
GARY R. HERBERT
Governor
<JREGBEIX
Ueutenant Govemor
Department of
Enviromnental Quality
Amanda Stiudi
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundboig
Director
August 2,2012
CERTIPIEDMAIL
RETURNED RECEIPT REOUESTED
Jo Ann Tischler
Director, Comphaoce and Permitting
Demson Mines (USA) Corp, (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
SUBJECT: Taihngs Cell, Leak Detection System and Slimes Dram Sampling and Analysis Plan,
Revision 2.1, Denison Mmes (USA) Coip., White Mesa Uramum Mill, near Blanding,
Utah, Approval
Dear Ms. Tischler.
On July 30,2012 the Division of Radiation Conlzol CDRC) received by email an electronic copy of the
Tailmgs Cell, Leak Detection System and Shmes Dram Sampling and Analysis Plan, Revision 2.1 ('Tlan*')
Denison Mines (USA) Corp, C'DUSA'*)' Based on the review of the Plan all modifications requested in the
DRC letter and Request for Additional Infonnation dated July 26,2012 were made and the Plan is
approved.
To assure the Plan meets DUSA Ground Water Discharge Permit UGW370004 CTeraiir), Part
I E.10(d)(l) ofthe Permit will be removed. This is considered a mmor mddification to the Permit and no
public comment period is necessary. DUSA will be notified ofthe Permit change when the modification to
the Permit is final.
Thank you fbr your cooperation in this matter. Ifyou have any questions or comments regarding this
letter, please contact Dean Hoiderson at [phone].
Smcerely,
Rusty Lundberg
Director
RL/DH
195 North 1950 West • Salt Lake City, ITT
Mailing Addicss P O Box 144850 * Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533-W97 'TDD [phone]
www deq utaKgon>
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