DRC-2008-002502 - 0901a06880abe0a6

Repajn
Repairs to PVC liners in Cells I ,2 and 2 and to the HDPE liner in Roberts PondX1p,gruqi$
S$--e {({$S*b}-gASe- haUiS-xxrLS$UAl!:: involves the installation of a repair patch over the
damaged location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HDPE repairs are accomplished by use of an extrusion
wclder. Subsequent to any repair of a liner, the repair location will be tested using ao'vitouum box" and soapy water to assure that the repair is acceptable. The observation of
bubbles through the repair seam while vacuum is being applied to the seam constitutes
seam failure and the repair must be redone until all seams are acceptable. In the case of
Cells 1, 2, and 3, after a patch has been applied, the repair location must be covered with
eafihen material, again to avoid exposure to sunlight. Adequate supplies of PVC and
HDPE liner matedal, repair material and vacuum test equipment are maintained either in
the Mill warehouse or the maintenance department. The continued availability of these
supplies will be verified as an element of the Quarterly Tailings Inspection conducted by
the Radiation Safety Oflicer or his designee.
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Liner Maintenance Provisions-Cells l, 2,3 and Roberts pond
Inspections
Tailings cells l, 2, and 3 are the subject of comprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
In each case, these inspections are recorded on inspection foms (Daily Inspection Data
Form and Operating Foreman's Daily Inspection Form, respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
Al1 individuals performing inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells 1, 2 and 3 are
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are tmined to cover
small areas of exposure imrnediately, whereas, larger areas are reported to the radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requitement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by exposure to
sunlight, abrasion due to erosive wave action and/or any rips or tears in the liner material.
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HDPE) material which is not
sensitive to sun damage and, as such, is not covered with earthen material. In this case
the inspector observes the conditions of the liner to the extent that visual obseration is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
From:
To:
Date:
Subject:
Steve Landau <SLandau @ denisonmines.com>
"desser@ utah. gov" <desser@ utah.gov>
9l29l2OOB 1:54 PM
Liner Maintenance Plan
Dear Mr. Esser,
This it to confirm that the revisions to the Liner Maintenance Plan requested in your correspondence of August 1, 2008 will be
completed and transmitted to the UDEQ by Monday September 13, 2008.
Sincerely,
Steven D. Landau
Steve Landau
Manager, Environmental Affairs
t: [phone] | f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265
DENTSON MrNES (USA) CORP
www.denisonmines.com<http://vww.denisonmines.com/>
This e-mail is intended for exclusive use the person(s) mentioned as the recipient(s). This message and any attached files with it
are confidential and may contain privileged or proprietary information. lf you are not the intended recipient(s) please delete this
message and notify the sender. You may not use, distribute print or copy this message il you are not the intended recipient(s).
State of Utah
JON M. HUNTSMAN, JR
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
October 30, 2008
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 17'h Street, Suite 950
Denver, CO 80265 USA
Subject:White Mesa - June 12, 2008 DUSA Liner Maintenance Provisions- Cells 1, 2,3 and Roberts
Pond Ground Water Discharge Permit (No. UGW370004): Closeout letter
Dear Mr. Landau,
We have received your final copy dated October 6,2008, for the Liner Maintenance Provisions, Revision 0
for Cells L, 2,3 and Roberts Pond which constitutes, Appendix D, to the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan. Therefore the
matter of white mesa mill liner maintenance provisions for cell 1,.2,3, and Roberts Pond is closed out.
Please be advised that these provisions will be incorporated into the ground water discharge permit in an
upcoming permit modifi cation.
Thank you for the revised submittal and please note that the DRC views the DUSA Liner maintenance
provisions to be effective immediately.
If you have any questions or comments, please contact David Esser at [phone].
Ll"rAH WATER QUALTTY BOARD
Dane L. Finerfilbck Co-Executive Secretary
DKE: de
F:\FACILITIES\Densison Mine\proposal review\Liner Maintenance Provisions- Conditional approval\20O8-10-30 Liner Maintenance Provisions
Closeout Lrtter.doc
168 North 1950 West . Salt Lake City, UT
Mailing Address: P.O. Box 144850 . Salt Lake City, UT 841l4-4850
Telephone [phone]. Fax [phone]. T.D.D. (801) 536-,t414
wrtl.deq.utoh.got,
hinted on 100% recycled paper
DENI
E nilttr(tEAlG.e.tlllriltrt.l tlfrtl
Danir, G0 Ealul
?rl:30tl}7ltlFs:Sll.ltll
October 22,2008
Sent VIA Federal Express
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
Dear Mr. Finerfrock,
Re: White Mesa Mill Liner Maintenance Provisions-Cells 1,2,3 and Roberts Pond
Pursuant to the requirement of Part l.H.lz of the Ground Water Discharge Permit (No. UGW370004)
for the White Mesa Mill, discussions with Mr. Dave Esser of the Division, and your correspondence
dated October 9, 2008 please find enclosed the final version (Revision 0) of the Liner Maintenance
Provisionsfor Cells l, 2, 3 and Roberts Pond. This document has been revised in accordance with
your corespondence to include a revision designation and the approval date.
If you should have any questions regarding this please contact me.
Yours very truly,
I
soJy
INES
skatuDcxrsox MrNEs (USA) Conp.
Steven D. Landau
Manager, Environmental Affairs
Cc. Ron F. Hochstern
Harold R. Roberts
David C. Frydenlund
David E. Turk
,.\j0i.c*L'i-'./C1 tl
*l,on' o-original
Approved: October 6, 2008
Liner Maintenance Provisions-Cells I,2,3 and Roberts Pond
Inspections
Tailings cells 1, 2, and 3 are the subject of comprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
In each case, these inspections are recorded on inspection forms (Daily Inspection Data
Form and Operating Foreman's Daily Inspection Form, respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
All individuals performing inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells l, 2 and3 are
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are trained to cover
small areas of exposure immediately, whereas, larger areas are reported to the radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requirement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by exposure to
sunlight, abrasion due to erosive wave action and/or any rips or tears in the liner material.
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HDPE) material which is not
sensitive to sun damage and, as such, is not covered with earthen material. In this case
the inspector observes the conditions of the liner to the extent that visual observation is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
*ls,or,, o-original
Approved: October 6, 2008
Repairs
Repairs to PVC liners in Cells 1,2 and2 and, to the HDPE liner in Roberts Pond are made
on a case by case basis and usually involves the installation of a repair patch over the
damaged location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HDPE repairs are accomplished by use of an extrusion
welder. Subsequent to any repair of a liner, the repair location will be tested using a
"vacuum box" and soapy water to assure that the repair is acceptable. The observation of
bubbles through the repair seam while vacuum is being applied to the seam constitutes
seam failure and the repair must be redone until all seams are acceptable. In the case of
Cells 1, 2, and 3, after a patch has been applied, the repair location must be covered with
earthen material, again to avoid exposure to sunlight. Adequate supplies of PVC and
HDPE liner material, repair material and vacuum test equipment are maintained either in
the Mill warehouse or the maintenance department. The continued availability of these
supplies will be verified as an element of the Quarterly Tailings Inspection conducted by
the Radiation Safety Officer or his designee.
Any leak, hole or other damage to the liners in Cells 1,2,3 and the Roberts Pond will be
reported orally to the Executive Secretary within 24 hours of the discovery and in writing
within 5 days of the discovery. The oral and written notifications will include a
notification and description of the failure in accordance with Part I.G.3.(a) of the GWDP
and be in accordance with R3l7-6-6.16.C(1) of the regulations. In addition to the
descriptive information about the failure, a plan and schedule for the FML repair will be
included with the notification to the Executive Secretary (in accordance with Part
I.G.3.(c) of the Permit).
Repair Report
Each report will be signed by a Utah licensed professional engineer and will address the
following elements as they apply to the case-by-case repairs which are implemented:
o Repair narrative describing the nature of the damage and the repair work
completed to repair the damage.o Repair material type used to complete the repairo Repair material descriptiono Post repairs test specificationso Test Methods (ASTM or other). Daily reports during the repair worko Repair test resultso Quality Assurance/Quality Control Information
State of Utah
JON M. HI,JNTSMAN, JR.
Governor
GARY HERBERT
Lieutenant Governor
a
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
October 9, 2008
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 170'Street, Suite 950
Denver, CO 80265 USA
Subject White Mesa - June 12, 2008 DUSA Liner Maintenance kovisions- Cells 1, 2,3 andRoberts
Pond Ground Water Discharge Permit (No. UGW370004): Conditional Approval
Dear Mr. Landau,
We have received your revised proposal sent via e-mail dated September 29, 2008,
maintenance provisions for Cells I,2,3 and Roberts Pond, Appendix D, to the White Mesa
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
below are parts of the final flexible liner (FML) maintenance provision proposal:
- All FML repairs will be made on a case by case basis.
- Prior verbal and written notification of a FML leak, hole, or other damage, will be
DRC in accordance with the requirements of part I.G.3(a) of the permit.
for the liner
Mill Tailings
Summarized
made to the
- A time
permit.
limit for FML repair is provided for DRC approval in accordance with part I.G.3(c) of the
Document the repair with the DRC by submitting a written report within 30 days of all FML
repairs to the DRC for review, and approval.
Specifications, details, and standards for the repair report were provided. Including the following:
narrative of the repair, FML material types used in the repair, material specifications, post repair
test specifications (e.g., 50 psi air test), ASTM testing method(s), daily reports, material testing
results, and quality assurance/ quality control information reviewed, stamped and signed by a Utah
licensed professional engineer.
168 North 1950 West. Salt Lake City, UT
Mailing Address: P.O. Box 144850. Salt lake City, UT 841l4-4850
Telephone (801 ) 536-4250 . Fax [phone] . T.D.D. (80 I ) 536-441 4
nww.cleq.utah.gov
Printed on 100% rccycled paper
Page2.
Based on the revised September 29, 2008 plan the DRC conditionally approves the DUSA Liner
maintenance provisions provided: 1) hard copies are sent to the DRC by November 1, 2008. The final
hard copies must show the revision number and the date of approval October 6,2008.
Thank you for the revised submittal and please note that the DRC views the DUSA Liner maintenance
provisions to be effective immediately.
If you have any questions or comments, please contact David Esser at [phone].
UTAH WATER QUALITY BOARD
Dane L. Finerflock Co-Executive Secretary
DKE: de
F:\FACILITIES\Densison Mine\proposal review\Liner Maintenance Provisions- Conditional approvaM00E-10-6 Liner Maintenance hovisions
Approval l.ener.doc
GARY HERBERT
Lieulenant Govenwr
State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DIVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
August 1,2008
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 17th Sffeet, Suite 950
Denver, CO 80265 USA
Subject:White Mesa - June 12, 2008 DUSA Liner Maintenance Provisions- Cells 1, 2,3 and Roberts
Pond Ground Water Discharge Permit (No. UGW370004): Request for Information, Plan
Revision, and Conflrmatory Action Letter
Dear Mr. Landau,
We have received your proposal dated June 12, 2008, of liner maintenance provisions for Cells 1,2,3 and
Roberts Pond, Appendix D, to the White Mesa Mill Tailings Management System and Discharge
Minimization Technology (DMT) Monitoring Plan. Summarized below are the three basic'parts of the
June 12 flexible liner (FML) maintenance provision proposal:
1) Inspection - Comprehensive daily inspections will be done by trained staff on a set schedule and
results will be recorded on daily inspection forms. Problems will be addressed as needed.
2) Training - Individuals performing the FML inspections will have very specific training on specific
possible problems that may be founded with the different types of cell liners. For example: rips,
tearing, or sun exposure.3) Repairs - Based on the type of FML material PVC or HDPE different patch repair methods will be
used i.e. glues, adhesive, solvents or extrusion welding. Repair couldbe different in every case.
Please revise the plan and resubmit within 30 days to include the following additional information:
- All FML repairs will be made on a case by case basis.
Verbal and written notification of a FML leak, hole, or other damage, will be made to the DRC in
accordance with the requirements of part LG.3(a) of the permit.
168 North 1950 West. PO Box 144850. Salt l-ake City, UT 841 14-4850. phone [phone]. fax [phone]-l
T.D.D. [phone] . v,ww.deq.utaltgov
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June 12,2008
Sent VIA Electronic and Regular Mail
Mr. Dane L. Finerfrock
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake city, UT 84114-4850
Dear Mr. Finerfrock
Donbon mn ! (USA) Corp.
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_ Division ofHadiation Con{rol
Re: White Mesa Mill Liner Maintenance Provisions-Cells 1,2,3 and Roberts Pond
Pursuant to the requirement of Part I'H.lz of the Ground Water Discharge Permit (No. UGW370004)
for the White Mesa Mill, please find enclosed the liner maintenance provisions for Cells 1,2,3 and
Roberts Pond. This document has been prepared as Appendix D to the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
If you should have any questions regarding this Appendix and its liner maintenance provisions, please
contact me.
Yours very truly,
h-l*DrNrsox Mrxcs (USA) Conp.
Steven D. Landau
Manager, Environmental Affairs
Cc. Ron F. Hochstein
Harold R. Roberts
David C. Frydenlund
David E. Turk
Appendix D
Liner Maintenance Provisions- Cells I,2,3 and Roberts Pond
Inspections
Tailings cells 1, 2 and 3 are the subject of comprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
In each case, these inspections are recorded on inspection forms (Daily Inspection Data
Form and Operating Foreman's Daily Inspection Form, respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
All individuals performing inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings lnspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells l, 2 andare
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any sifuation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are trained to cover
small areas of exposure immediately, whereas, larger areas are reported to the Radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requirement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by exposure to
sunlight, abrasion due to erosive wave action and/or any rips or tears in the liner material.
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with High Density Polyethylene (HDPE) material which is not
sensitive to sun damage and, as such, is not covered with earthen material. In this case
the inspector observes the condition of the liner to the extent that visual observation is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
Repairs
Repairs to PVC liners in Cells 1,2 and 3 and to the HDPE liner in Roberts Pond involves
the installation of a repair patch over the damaged location. PVC patches require the use
of glues or adhesive solvents to fuse the patch to the repair location. HDPE repairs are
accomplished by use of an extrusion welder. Subsequent to any repair of a liner, the
repair location will be tested using a "vacuum box" and soapy water to assure that the
repair is acceptable. The observation of bubbles through the repair seam while vacuum is
being applied to the seam constitutes seam failure and the repair must be redone until all
seams are acceptable. In the case of Cells 1, 2 and 3, after a patch has been applied, the
repair location must be covered with earthen material, again to avoid exposure to
sunlight. Adequate supplies of PVC and HDPE liner material, repair material and
vacuum test equipment are maintained either in the Mill warehouse or the maintenance
department. The continued availability of these supplies will be verified as an element of
the Quarterly Tailings Inspection conducted by the Radiation Safety Officer or his
designee.