DRC-2012-001270 - 0901a068802bc90f

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State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
March 7 2012
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2012-00 1270
CERTIFIED MAIL
(Return Receipt Requested)
David Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp (DUSA)
1050 Seventeenth St Suite 950
Denver Colorado 80265
Subject Transmittal of Findings of the Utah Division of RadiaUon Control October 18 2011 Storm
Water Inspection at the White Mesa Uranium Mill and Review of the Denison Mines (USA)
Corp (DUSA) October 17 2011 Response to the DRC September 1 2011 Request for
Information and Confirmatory Action Letter DRC Fmdings, RFI, and Advisory
DearMr Frydenlund
This is to transmit the findings of the Utah Division of Radiation Control (DRC) storm water inspection
which took place on October 18 2011 at the White Mesa Uranium Mill and to provide the findings
regarding DRC review of the Denison Mines (USA) Corp (DUSA) October 27 2011 response to a
September 1 2011 DRC Request for Information (RFI) and Confirmatory Action Letter (CAL) regarding
findings dunng the 2010 DRC storm water inspecUon
Advisory
Please be advised that DRC idenUfied five violations of the Mill Ground Water Permit Permit No
UGW370004 dunng the Inspection walk through A copy of the DRC review memo regarding the
October 18 2011 inspecUon is attached which provides information and photos regarding these violations
As was discussed in the close out conference call between DRC and DUSA on February 22 2012 a Notice
of Violation and Order citing the five violauons is being submitted to DUSA under separate cover
October 2011 Storm Water Best Management Practices Plan (SWBMPP) Approval and Request for
Information
Based on DRC review ofthe DUSA October 2011 Revised SWBMPP it appears that the updates have
addressed the DRC concems m the September 1 2011 DRC RFI Letter (As discussed below) Therefore
the October 2011 SWBMPP is hereby approved
195 North 1950 West Salt Uke City UT
Mailing Address POBox 144850 Salt Uke City UT 84114 4850
Telephone [phone] Fax [phone] TDD [phone]
d q t hg
Pn ted o 100% re ycled p pe
David Frydenlund
Page 2
Request for Information
Please submit complete copies of the October 2011 Revised SWBMPP (including all appendices) in both
hard copy and text searchable electronic format (PDF) withm 30 calendar days of receipt ofthis letter It
appears that a full hard copy and electronic copy were not provided with the October 17 2011 DUSA
response letter
Findings DRC Review ofthe DUSA 10/17/11 Response to the 9/1/2011 DRC CAL and RFI
September 2, 2011 Confirmatory Action Items (3 Items)
CAL Item #1
DUSA violated the Groundwater Permit Part ID 11 by failing to manage drums containing altemate feed
matenal (located outside of the feedstock management area) in compliance with the required performance
standards
a Feedstock matenal was not stored in water tight containers
b Feedstock material was not stored on a hardened engineered surface or asphalt or
concrete
c Feedstock matenal was not stored in a designed and approved storage area (by the
Co Executive Secretary) or other approved area
DRC observed open and degraded contamers containing feedstock material on soil and located outside of
the feedstock management area
DUSA Response and Actions
DUSA constructed a concrete pad for temporary storage of drums containing altemate feedstock with
Executive Secretary approval The final approval and closeout letter was sent to DUSA by the Executive
Secretary dated October 24 2011
DRC Findings
DRC considers the DUSA follow up actions appropriate however DRC did observe opened and
rusted/perforated drums of feedstock material (outside of the feedstock management area) not in
compliance with Part ID 11 of the Groundwater Permit dunng the October 18 2011 storm water
inspecdon It was noted that the new pad had recently been poured and was still curing (was not yet in
operation)
CAL Item #2
DUSA violated the Groundwater Permit Part ID 10 by failing to replace/repair concrete in the secondary
containment of the Caustic Soda Tank
DUSA Response and Actions
Per the October 17 2011 DUSA response to the CAL and the 2011 DRC mspecnon walkthrough it was
venfied that the containment has been repaired
David Frydenlund
Page 3
DRC Findings
The DUSA Action appears to be appropnate and has addressed the CAL concem No additional action
needed
CAL Item #3
DUSA violated the Groundwater Permit Part 1D 10 by failing to repair cracks in the secondary
containment area of the soda ash tanks
DUSA Response and Actions
Per the October 17 2011 DUSA response to the DRC CAL and the 2011 DRC inspection walkthrough it
was verified that the soda ash tank secondary containment cracks have been repaired
DRC Fmdings
The DUSA Action appears to be appropnate and has addressed the CAL concem No additional action
needed
September 7, 2011 Request for Information hems (5 Items)
RFI#1
DRC requested information regarding updates to the plans/inspections to provide inspections according to
frequencies required by the Storm Water Best Management Practices Plan (SWBMPP) DRC noted for
example the SWBMPP requires a weekly inspection of the diversion ditches however they are conducted
monthly DRC noted that failure to either provide these inspections in conformance with the SWBMPP or
modify the SWBMPP is a violation ofthe Groundwater Permu Part ID 10 The Permittee will manage
all contact and non contact storm water and control contammant spills at the facility in accordance with
the currently approved storm water Best Management Practices Plan
DUSA Response and Actions
DUSA updated the White Mesa SWBMPP dated October 2011 The updated plan includes revised
inspection intervals which appear to correspond with the daily weekly monthly and quarterly inspection
forms
DRC Findings
Per DRC review the October 2011 Revised SWBMPP appears to address the RFI by changing the
frequency of the diversion ditch inspection to monthly and approval ofthe Revised SWBMPP is provided
above DRC also noted that the revised SWBMPP updates the tables listing quanUty and types of reagents
chemicals petroleum products and solvents stored at the Mill facility DRC did note that DUSA did not
submit a complete revised copy or electronic file of the Revised SWBMPP and has included an RFI for
DUSA to submit the copies withm 30 calendar days above
David Frydenlund
Page 4
RFI#2
DRC requested information regarding the inspection procedures for reagent storage tanks (including
intermediate process tanks eg Pregnant Liquors) which are installed on grade (on grade refers to tank
installations where the tank bottom is in contact with the ground) to insure that the structural integrity of
the tank bottom is acceptable/appropriate DRC noted that cathodic protection for on grade tanks is
prescribed on grade tanks in order for DUSA to comply with Part ID 10(a) of the groundwater permit
DUSA Response and Actions
DUSA will insure that all on grade reagent and intermediate process tanks are on concrete pedestals Per
the DUSA investigation there are two kerosene tanks which are on grade and need concrete pedestals to be
constructed All other on grade tanks have existing concrete pedestals
DRC Findings
The DUSA response is consistent with communication between DRC and DUSA conceming the on grade
tanks specifically DRC provided follow up response that on grade tanks will require either cathodic
protection or to be placed on concrete pedestals DRC will inspect the on grade tanks during the 2012
storm water inspection to ensure that concrete pedestals are provided
RFI#3
DRC requested an outline of a plant process for intemal notification and documentation ofthe cleanup of
small quantity spills (less than reportable quantities) Per the 2010 inspection it was noted that a fuel spill
had occurred at the fuel tank area however but had not been cleaned up and there did not appear to be a
process to identify document or clean up such spills DRC noted that failure to provide such a process is
not in conformance with the SWBMPP Pan 4 2 1
DUSA Response and Actions
In response to Request for Information item number 3 request with the findings ofthe 2010 DRC storm
water inspection DUSA provided a change to the small quantity spills protocols in the October 17 2011
response letter as follows
DUSA has implanted an intemal notification process for small quantity spills (less than reportable
quantities) with the following steps
1) Mill environmental personnel will fill out on the daily inspection form observations of spills of reagent
chemicals of any size The form will be amended to add spaces for this item
2) In addition all Mill employees will be trained to advise Mill environmental personnel of any spills that
they observe during the day and these will also be noted in the daily inspection form
3) If the spill IS of a reponable quantity environmental personnel will follow the procedures in the Mill s
SWBMPP plan
4) For spills smaller than reportable quantities the environmental inspector will record information
regarding the spill and the nature and type of cleanup on the form
5) The information on the inspection form will be added to a database maintained at the Mill The
database will be updated and maintamed on site indefinitely Cards are maintained for no longer than one
year
David Frydenlund
Page 5
DRC Findings
The corrective actions were not implemented at the Ume of the DRC October 18 2011 inspection the new
reporting and clean up processes will be reviewed during the DRC 2012 storm water inspection
RFI#4
DRC requested that DUSA review the facility SPCC plan to insure that all tanks included under the current
facility Spill Prevention Countermeasure and Control (SPCC) plan meet current requirements of current
EPA rules (40CFR112) Specifically it was noted that any non PCB containing tanks should be included
under oil inventory and be included with inspection protocols The RFI was required in orderyto insure
that current procedures and policies at the mill are up to date
DUSA Response and Actions
Per the October 17 2011 DUSA response DUSA provides a histoncal summary of the Mill and claims
that It IS not required to comply with the requirements of the SPCC rule due to the Mill being constructed
with an overall grade and diversion ditch system designed to channel any non recovered portion of any
matenal spill to the tailings management system DUSA does agree to review the SPCC Rule (Current
40CFR112) to determine whether or not any modifications to the SPCC plan would be appropriate for the
Mill
DRC Findings
DRC will follow up regarding the DUSA review of the rule and changes which are planned in the SPCC
dunng the 2012 storm water inspection
RFI#5
DRC requested that DUSA seal intenor drains in the vehicle maintenance areas that dram to outdoor
uncovered areas It was noted that this is specified in the facility SWBMPP and is considered a best
management practice to minimize the quannty of contaminated matenal DRC noted that the open drain is
not in conformance with the SWBMPP Part 4 3 1 second bullet clean up spills promptly don t let minor
spills spread
DUSA Response and Actions
The DUSA response described that water from the shop intenor drains into the outdoor sump (baffle box)
and IS then intermittently pumped to the tailings management system ( pump is tumed on/off by hand)
DRC Findings
The system was evaluated dunng the October 18 2011 storm water inspection DUSA representatives
tumed on the pump and drained a portion of the water contained in the baffle box DRC witnessed the
discharge undemeath the CCD circuit to Roberts Pond Based on DRC review of the response and
inspection the system seems adequately designed and managed to control discharge from the shop intenor
No additional action is required regarding RFI #5
David Frydenlund
Page 6
RFI#6
DRC requested that DUSA insure that the clean water tank valve is sealing properly Per the 2010 DRC
storm water inspection it was noted that this valve was leaking and was creating pond areas m unlined
ditch/soil areas It was noted that this is not in conformance with SecUon 4 1 4 of the SWBMPP which
states Areas requinng maintenance or repair such as excessive vegetative growth channel erosion or
pooling of surface water runoff will be report[ed] to site management and maintenance departments for
necessary action to repair damage or perform reconstruction in order for the control feature to perform as
intended
DUSA Response and Actions
Per the DUSA October 17 2011 response to the RFI it was noted that the discharge was not due to a faulty
or leaking valve but was due to the water level being filled above max DUSA pointed out that the tank is
filled automatically (Recapture Reservoir Water Line) and will routinely overfill the tank DRC pointed
out that this was resulting in standing water onsite on bare ground DUSA responded that they would
provide a closed pipe system which would route the overflow to Roberts Pond without ground contact Per
an e mail to DRC from David Turk (White Mesa Mill RSO) on November 4 2011 it was venfied that the
construcnon was complete Several photos of the construction and completed project were also provided
DRC Findings
The DUSA action appears to be appropriate and effective to control the overflow discharge DRC will
inspect the completed construction dunng the 2012 Storm Water Inspection
If you have any questions regarding this letter or the attached DRC Review Memo please contact Tom
Rushing at [phone]
Sincerely
UTAH WATER QUALFTY BOARD
Rusty Lundberg
Co Executive Secretary
RLTR tr
Enclosure DRC October 18 2011 White Mesa Uranium Mill Storm Water Inspection Review Memo
(22 pp text + 14 pp Photos)
White Mesa Mill
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Utah Division of Radiation Control (DRC)
Ground Water Module 65
Denison Mines White Mesa Uranium Mill
DRC Annual Storm Water Inspection
Ground Water Pennit UGW370004
Inspection Year 2011
Inspection Date October 18 2011
Module Reviewer Name/Initials
Phil Goble Compliance Section Manager
Module Prepared by/Date Prepared
Tom Rushing P G /February 21 2012 JC Z / -' ^ ' ^
DRC Staff Present
Tom Rushing
Phil Goble
Denison Mines Staff Present David Turk White Mesa Uranium Mill RSO
Denison Mines Staff Interviewed David Turk White Mesa Uranium Mill RSO
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the
White Mesa Uranium Mill
Date June 2008
Revision No 13
I Violations Identified in Last (2010) Inspection (list)
Three violations were identified dunng the 2010 storm water inspection as follows
1 DUSA violated the Groundwater Permit Part ID 11 by failing to manage dmms
containing altemate feed matenal (located outside of the feedstock management area)
in compliance with the required performance standards
a Feedstock matenal was not stored in water tight containers
b Feedstock matenal was not stored on a hardened engineered surface or
asphalt or concrete
c Feedstock matenal was not stored m a designed and approved storage area
(by the Co Executive Secretary) or other approved area
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d DRC observed open and degraded containers containing feedstock
matenal on soil and located outside of the feedstock management area
2 DUSA violated the Groundwater Permit Part ID 10 by failing to replace/repair
concrete in the secondary containment of the Caustic Soda Tank
3 DUSA violated the Groundwater Permit Part ID 10 by failing to repair cracks m the
secondary containment area for the soda ash tanks
DUSA was issued a Confirmatory Action Letter (CAL) regarding these violations dated
September 1 2011 and subsequently received a response of actions from DUSA dated
October 17 2011
II Requests for Information Per Previous (2010) Inspection
Six requests for information were noted dunng the DRC 2010 Storm Water Inspection as
follows
1 DRC requested information regarding updates to the plans/inspections to provide
inspections according to frequencies required by the Storm Water Best Management
Practices Plan (SWBMPP) DRC noted for example the SWBMPP requires a weekly
inspection of the diversion ditches however they are conducted monthly DRC
noted that failure to either provide these inspections in conformance with the
SWBMPP or modify the SWBMPP is a violation of the Groundwater Permit Part
ID 10 The Permittee will manage all contact and non contact stormwater and
control contaminant spills at the facility m accordance with the currently approved
Storm Water Best Management Practices Plan
2 DRC requested mformation regarding the inspection procedures for reagent storage
tanks (including intermediate process tanks e g Pregnant Liquors) which are
installed on grade (on grade refers to tank installations where the tank bottom is in
contact with the ground) to ensure that the stmctural integnty ofthe tank bottom is
acceptable/appropnate DRC noted that cathodic protection for on grade tanks is
prescnbed for on grade tanks in order for DUSA to comply with Part I D 10(a) of the
groundwater permit
3 DRC requested an outline of a plant process for intemal notification and
documentation of the cleanup of small quantity spills (less than reportable quantities)
Per the 2010 inspection it was noted that a fuel spill had occurred at the fuel tank
area however the spill had not been cleaned up and there did not appear to be a
process to identify document or clean up such spills DRC noted that failure to
provide such a process is not m conformance with the SWBMPP Part 4 2 1
4 DRC requested that DUSA review the facility SPCC plan to ensure that all tanks
included under the current facility Spill Prevention Countermeasure and Control
(SPCC) plan meet current requirements of current EPA rules (40CFR112)
Specifically it was noted that any non PCB containing tanks should be included
under oil mventory and be included with inspection protocols The Request For
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Information was required m order to ensure that current procedures and policies at the
mill are up to date
5 DRC requested that DUSA seal intenor drains in the vehicle maintenance areas that
dram to outdoor uncovered areas It was noted that this is specified m the facility
SWBMPP and is considered a best management practice to minimize the quantity of
contaminated matenal DRC noted that the open dram is not m conformance with the
SWBMPP part 4 3 1 second bullet clean up spills prompfiy don t let minor spills
spread
6 DRC requested that DUSA ensure that the clean water tank valve is sealing properly
Per the 2010 storm water inspection it was noted that this valve was leaking and was
creating pond areas in unlined ditch/soil areas It was noted that this is not in
conformance with Section 4 1 4 of the SWBMPP which states Areas requinng
maintenance or repair such as excessive vegetative growth channel erosion or
pooling of surface water mnoff will be report[ed] to site management and
maintenance departments for necessary action to repair damage or perform
reconstruction in order for the control feature to perfonn as intended
DUSA was issued a Request for Information (RFI) regarding these violations dated
September 1 2011 and subsequently received a response of actions from DUSA dated
October 17 2011
III October, 2011 Inspection (Current), DRC Staff Findings
Section I - Document Review
SWBIVIPP (Documentation Requirements)
Part 4 14 Diversion ditches, drainage channels and surface water control structures
in and around the Mill area will be inspected at least weekly Areas requiring
maintenance or repair, such as excessive vegetative growth channel erosion or pooling
of surface water runoff, will be reported to appropriate departments and all follow up
actions are to be documented
Findings
The DRC conducted an inspection of all upland Diversion Ditches 1 and 2 as shown on the
DUSA Storm Water Best Management Practices Plan Figure 1 DRC found the ditches to
be adequately maintamed Photos of the ditches taken dunng the day of the inspection are
included the memo attachment photo numbers 53 and 54
DUSA inspects the diversion ditches monthly and appropnate fields for inspection are
included on the monthly inspection data form DRC reviewed the October 4 2011 monthly
form and noted that the DUSA Inspector (Tanner Holliday) noted that Diversion Ditches 1
and 2 showed no sloughing erosion undesirable vegetaUon or obstmctions of flow It was
noted that Diversion Ditch 3 had minor problems with erosion and vegetation The
inspection form noted that the utility crew was notified and waiting for the grader to be
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fixed going to run a loader through the bottom to clear out the vegetation There were no
additional notes included on the form regarding follow up
Spill Prevention, Control and Countermeasures Plan (SPCC) (Documentation
Requirements)
1 6 1 - Daily monitoring of propane tanks required
Findings
Per the 2009 and 2010 DRC review of the DUSA Storm Water Inspection forms it was
noted that the inspection of the propane tanks is included on the daily foreman s inspection
checklist Per RFI # 3 above DRC requested a change m process for DUSA to identify and
clean up small quantity spills In response DUSA agreed to track inspections of Mill areas
on the daily inspection form which will include more detailed inspection findings DRC will
inspect the protocol changes dunng the 2012 inspection and ensure that the propane tanks are
one of the items included on the daily inspection form
1 9 1 - External Notification of "reportable quantity" spills
Findings No reportable quantity spills were noted per DRC document reviews and
interviews dunng the October 18 2011 inspection
19 2 Internal Notification of incidents, spills, and significant spills
Performance Standards (list)
Fmdings In response to Request for Information item number 3 request with the findings of
the 2010 storm water inspection DUSA provided a change to the small quantity spills
protocols in the October 17 2011 response letter as follows
DUSA has implanted an intemal notification process for small quantity spills (less than
reportable quantities) with the following steps
1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size The form will be amended to add spaces for this item
2) In addition all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day and these will also be noted in the daily
inspection form
3) If the spill IS of a reportable quantity environmental personnel will follow the procedures
in the Mill s SWBMPP plan
4) For spills smaller than reportable quantities the environmental inspector will record
information regarding the spill and the nature and type of cleanup on the form
5) The information on the inspection form will be added to a database maintained at the Mil
The database will be updated and maintained on site indefinitely Cards are maintained for
no longer than one year
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Note that these corrective actions were not implemented before the DRC October 18 2011
inspection therefore the new repomng process will not be reviewed until the DRC 2012
storm water inspection
110 Records and Reports
Penod of Records Examined Dunng Inspection
Begin/Ending 9/1/2011 through 9/30/2011
No of On site Records Required Daily Weekly and Monthly Forms
No of On site Records Found All Records/Reports Onsite
No of Records Examined 10% (Percent of Total)
How Selected DRC Inspected a full month of daily weekly and monthly forms
Daily Tailings Inspection Data
Findings
DUSA inspection of 1 Tailings slurry transport system 2 Operational systems (water level
beach liner and cover) 3 Dikes and embankments 4 Physical inspection of the slurry lines
and 5 Dust control and leak detection are conducted daily and documented on a daily
inspection form DRC randomly selected and reviewed all of the daily forms for the month
of September 2011
Per discussion of intemal identification of small quantity spills DRC expect that DUSA will
update the daily inspection forms to include items outlined in the October 17 2011 response
to the DRC RFI Additionally DRC has identified an issue regarding the documentation of
follow up actions for problems noted on daily inspection forms DRC has requested (2009
and 2010 inspections) that DUSA document the follow up action on the same form where the
problem was initially noted
Per the 2011 inspection there was some improvement regarding the documentation of
follow up actions however DRC notes that a consistent protocol has not yet been
implemented DRC will review the protocols dunng the 2012 storm water inspection to
identify which items have been addressed by the DUSA revision to the daily inspection form
Weekly Tailings Inspections and Survey
Fmdings The weekly tailings inspection was done and documented on a weekly tailings
inspection form The form includes sections to document pond elevations (solution
elevation FML bottom elevation and depth of water above FML) for Cells 1 3 4A and
Roberts Pond as well as slimes drain liquid levels in Cell 2 The form also includes
information regarding the leak detection systems for Cells 1 2 3 and 4A as well as the
potential blowing of tailings The form as part of the Standard Operating Procedures also
includes sections for reporting parameters about the Leak Detection Systems (part ofthe
DMT plan requirements not storm water related)
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Per the 2011 DRC storm water inspection there are no comments regarding the forms
Monthly Tailings Inspection, Pipeline Thickness
Findings
The monthly inspection report includes 1 A summary of the slurry pipeline condition and
measurement of pipe thickness which is applicable only when the Mill is operational 2
Inspection protocols and observations related to the diversion ditches berms sedimentation
pond dust control settlement monitors and slimes drain static head measurements for Cells
2 and 3
DRC reviewed the monthly inspection report dated October 4 2011 Note that the monthly
inspection reports include comments related to the upland ditches DRC has no additional
comments related to the reviewed monthly inspection report
Quarterly Tailings Inspection
Findings
The quarterly inspection form includes fields for 1 Embankment Inspection 2
Operations/Maintenance Review 3 Constmction Activities and 4 Summary
DRC reviewed the quarterly inspection report dated October 4 2011 DRC notes that this
form includes an evaluation of erosion on the embankments ofthe tailings cells DRC has no
additional comments related to the reviewed quarterly inspection report
Tank to soil potential measurements
Fmdings
This Item was included as part of the September 1 2011 RFI RFI # 2 DRC had concems
regarding on grade tanks (tanks where the bottom is in contact with soil Per DRC
communication with DUSA it was clanfied that tanks which sit on the ground must have
cathodic protection installed if they are in contact with soil or must be placed on a concrete
foundation (no steel/soil contact)
The DUSA October 17 2011 response states
The following results ofthe tank inspection were noted
• There are three kerosene tanks The east tank is on a concrete pedestal The two
west tanks are place on grade on the ground surface
• 772^ ammonia tanks are on concrete pedestals
• The sulfuric acid tank is on a concrete pedestal
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• The exterior VPL and water tank by the Old Decontamination Pad are on concrete
pedestals Dirt had filled in the area around the pedestals and at the time ofthe
2010 inspection gave the mistaken impression that the tanks wer on grade
DUSA had discussed with the DRC the installation of cathodic protection on reagent or fuel
tanks that were not on pedestals saddles or dikes specifically the kerosene tanks DUSA has
since decided that it would be more prudent to construct comparable concrete bases
(pedestals) for the remaining kerosene tanks as are in place on the other flat bottom
tanks
The DRC communication that concrete pedestals were appropnate (in lieu of cathodic
protection) was sent to DUSA via e mail on September 26 2011 Therefore the DUSA
action IS appropnate and is consistent with State and Federal regulattons
DRC will inspect the tank foundations dunng the 2012 inspection to ensure that the
improvements to the kerosene tanks have been completed
Annual bulk oil and fuel tank visual inspections
Findings
Per the DRC 2009 inspection review comments {December 10 2009 Ground Water Module
65 Inspection Storm Water Best Management Practices Plan (SWBMPP) Inspection DRC
Review Memo) tank condition is not specifically checked by the mill DRC did note that a
general inspection of the tank area is conducted (listed as fuel area) and documented on the
operating foreman s daily inspection log however this does not comprehensively address
the conditions of each tank at the facility DRC also noted that daily volume measurements
are recorded for the fuel tanks but again the tank condition is not taken into account These
omissions on DUSA inspection reports were noted to be the same per the 2010 and 2011
inspection Per DRC review of the facility Groundwater Permit and SWBMP it was noted
that there is not requirement for DUSA to inspect and document the condition of these tanks
It is recommended that inspections to visually inspect the integnty of each of these tanks be
included m the Permit at least an annual frequency (Item to be included in a Ground Water
Permit Modification)
RFI #4 requires DUSA to review the cunent Spill Prevention Countermeasure and Control
Plan for the mill to ensure that all inspection processes and oil containers are in conformance
with those Federal (40CFR112) regulations Per the October 17 2011 DUSA response
DUSA provides a histoncal summary of the Mill and claims that it is not required to comply
with the requirements of the SPCC mle but will review the rule to determine whether or not
any modifications to the SPCC plan would be appropriate for the Mill
Tank and pipeline thickness tests
Findings Per DRC review the only thickness test noted was the slurry pipeline thickness
and this is only taken during times when the Mill is operating The thickness test is reported
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on the monthly report The report which was reviewed by DRC for the 2011 Storm Water
inspection did not include a thickness test since the Mill was not operational at the time
Quarterly and annua] PCB transformer inspections (currently PCB only)
Findings
The Mill currently does not inspect the transformers smce (per the 2009 inspection) it was
reported that all transformers contain non PCB based oil
Tank supports and foundation inspections
Fmdings
The operating foreman s daily inspection provides a general inspection of the Fuel Area but
does not provide a specific inspection of tank supports and foundation This item is also
covered in the tank condition inspection section above DRC noted that the inspection
frequency is not noted it was interpreted that this inspection relates to a visual inspection of
the integnty of tank supports only and is likely conducted with the tanks condition report
DRC will continue follow up with this item dunng the 2012 storm water inspection
Specifically DRC will ensure that tank supports and foundations are inspected and
documented wjth the tank condition reports
Spill Incident Reports
Findings
This Item is discussed above in the section related to reportable quantity spills Per the
October 17 2011 DUSA response to the 2010 DRC RFI DUSA is instituting a new process
for reporting small quantity spills DRC will follow up on the process dunng the 2012
mspecnon
Latest revision of SPCC plan (onsite and available*^)
Findings The cunent SPCC plan (dated June 2008) was onsite and available dunng the
inspection
111 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files)
DRC reviewed the log of people who have been trained to conduct the daily inspecttons at
the White Mesa facility as beJow
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Penod of Records Examined
Begin Calendar year 2011
Ending Calendar year 2011
No of Records Found 4
No of Records Examined 4 (100 Percent of Total)
How Selected Comprehensive Review of this Training
Fmdings DRC found that specific to 2011 4 people had been trained including those
conducting current daily inspections at the site The Radiation Safety Personnel also signed
the forms certifying the trainee as qualified to conduct the daily inspections
Section II Site Walk through Inspection
Areas and Observations
Ore Storage
Observations Ore is currently being stockpiled at the facility until a large enough quantity is
stored for an ore run DRC noted that a mnoff drain (piped to the tailmgs cells) was
constmcted at the southwest comer of the ore storage area per past DRC comments and that
the dram appeared to be clean and that the overflow pipe was visible above accumulations of
sediment Although accumulations of silt/clay were withm the dram it did not appear that
the integnty of the drain was impacted and that it was likely free draining Also the berm on
the southem boundary of the tailings storage area was maintained (Photos 6 and 7)
DRC noted that offsite discharge had occuned at the southeast comer of the ore storage pad
Specifically it appeared that the collection sump at the southeast comer at the terminus of a
ditch along the east margin of the facility (see Photo 10) overflowed and discharged to the
southeast outside of the fenced area (Photos 8 and 11) DRC noted a discharge depression
nil leaving the fenced area as well as evidence of discharge (mud cracks and nils) outside of
the fenced area DRC recommends that a formal Notice of Violation be issued to DUSA for
the violation
Violation
DUSA violated the Utah Ground Water Discharge Permit UGW370004 Part I D 10 by
failing to manage all contact and non contact storm water m accordance with the currently
approved Storm Water Best Management Practices Plan (SWBMPP) Specifically DUSA
violated Part 2 0 of the SWBMPP by failing to provide an adequate ditch and diversion
system to channel and contain the surface mnoff to the tailings management system which
resulted in offsite discharge(s) of contact stormwater out of the restncted area at the northeast
comer of the White Mesa Mill Facility
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Reagent Yard
Observations
Per DRC inspection of the reagent yard and storage building it appeared that drum storage
was appropnate No degraded or tapped dmms were noted in those areas (Note that
altemate feed/intermediate product drum storage are logged in other sections below)
Shop/Vehicle Maintenance Area
Observations
Oil Drum Storage Rack
DRC noted multiple spills on the ground from dmms on the storage racks east ofthe shop
building (See photos 19 20 21 22) The spills were due to leaky valves on the banels and
inadequate management by DUSA to provide secondary containment The spills are a
violation of the Groundwater Permit Part ID 10 It is recommended that a formal Notice of
Violation be issued for the violation
Violation
DUSA violated the Utah Ground Water Discharge Permit UGW370004 Part I D 10 by failing
to provide adequate active operational measures to discover prevent control contain and
clean up spills of oil from drums stored on racks east of the shop building Multiple on
ground spills were observed dunng the DRC 2011 Storm Water Inspection
(October 18 2011)
Shop Building Drain to Baffle Box
Per the September 1 2011 RFI letter RFI #5 above DRC requested that DUSA seal intenor
drains in the vehicle maintenance areas that drain to outdoor uncovered areas It was noted
that this IS specified in the facility SWBMPP and is considered a best management practice
to minimize the quantity of contaminated material DRC noted that the open drain is not in
conformance with the SWBMPP part 4 31 second bullet clean up spills promptly don t let
minor spills spread
DRC reviewed the DUSA response to the RFI and noted that water from the shop intenor
drains into the outdoor sump (baffle box) and is then intermittently pumped to the tailings
management system (manual pump) Based on DRC review of the response the system
seems adequately designed and managed to control discharge from the shop mtenor The
shop discharge to the tailings management system and is illustrated in Photo 29
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Used Oil/Kerosene Tank North of Shop Building
DRC observed spills outside of the secondary containment from the Kerosene Tank located
m the secondary containment north of the shop building to the ground (See Photo 27) The
spills appeared to be caused by the poor location of the tank valve outside of the containment
and a leaking valve and/or overflow when filling vessels The spills are a viol ation of the
Groundwater Permit Part ID 10 It is recommended that a formal Notice of Violation be
issued for the violation
Violation
DUSA violated the Utah Ground Water Discharge Permit UGW370004 Part I D 10 by failing
to provide adequate active operational measures to discover prevent control contain and
clean up spills of kerosene outside of the secondary containment located north of the shop
buildmg On ground spills were observed dunng the DRC 2011 Storm Water Inspecnon
Mill Processing Areas
SX Building Roof Drainage
Comments regarding needed improvements to the SX buildmg roof drain system are ongoing
since 2009 The drainage will be re evaluated dunng the 2012 storm water inspection
Alternate Feed Circuit South of SX Building
Observations
Per the DRC Violatton # 1 listed above and the subsequent confirmatory action item
regarding the storage of open drums containing altemate feed matenal violation of Part
ID 11 of the Groundwater Permit DUSA responded with plans to constmct a hardened
(concrete) pad for the drum storage pnor to processing At the time of the DRC inspection
October 18 2011 the concrete pad had been poured and was being allowed to cure pnor to
being used (Photo 47) The engineenng and constmction have since been approved by the
Executive Secretary
DRC noted that at the time of the inspection altemate feed dmms were stored on the ground
in two places Approximately 60 dmms were stored on the northwest side of the new storage
pad (on the ground next to the pad Photos 45 46) these dmms were stored and sealed in
their overpacks in conformance with the Ground Water Pennit requirements However there
were an additional 8 drums containing altemate feed waiting to be processed located south
of the new storage pad (on the ground) all of which had their tops opened and some which
were not m their overpacks The drums which were not m overpacks were in poor condition
(rusted through m places) (Photos 48 49 51) This same violation of Part ID 11 of the
permit was also identtfied dunng the 2009 and 2010 DRC storm water inspecti on and has
been extensively discussed with DUSA by the DRC
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Therefore formal enforcement for this violation is recommended Notice of Violation and
Order as follows
Violation
DUSA violated Ground Water Permit UGW370004 Part ID 11 by failing to store and
manage feedstock matenals in water tight containers (or water tight overpack) or on a
qualified hardened surface Specifically DRC found dunng the 2011 storm water inspection
(October 18 2011) that eight opened drums containing feedstock matenals were stored on
the ground m the area south of the altemate feed circuit Some of the dmms were in
overpacks but were opened and therefore not water tight Some drums were not in overpacks
were opened and were badly detenorated (perforated and msted through)
Old Decontamination Pad
The decontamination pad is no longer in operation DRC did note that the discharge tank
was full of water (Photo 38) DRC will inspect the condition/maintenance of the discharge
vault dunng the 2012 storm water inspecnon
New Decontamination Pad
Observattons
DRC observed that the decontamination pad pump back system was leaking to the ground
dunng the 2011 inspecnon (Photos 13 14 15) The amount of leakage was a minor volume
(approx 0 5 gallons/mmute) however The leakage was composed of contact wash water
from the final baffle containment for the decontamination pad The leakage is a violatton of
the Groundwater Permit Part ID 10 as follows
Violation
DUSA violated the Ground Water Permit Permit No UGW370004 Part ID 10 by failing to
control contact wash water at the New Decontamination Pad near the scale house
Specifically DRC found dunng the 2011 Storm Water Inspection (October 18 2011) that
the pumpback system pump was leaking to the ground Leakage volume was esttmated at a
half gallon per minute
Reagent Tanks
Sodium Chloride Tanks - DRC noted that the containment area was earthen It was
reported that this was allowable due to the age of the tanks Per discussion betAveen TR and
LIVI It was noted that LM had a past discussion with Harold Roberts regarding the secondary
containment An agreement was forged that all reagent tanks that pre existed the Ground
Water Permit (3/05) would be acceptable as is - and that as upgrades or replacements were
installed DUSA would work to meet BAT requirements More detail regarding this
agreement is m the December 2004 Statement of Basis and in Part I D 3(g) (Photo 1)
White Mesa Mill
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Kerosene Tanks (West of Shop) - DUSA will provide concrete foundattons for the tanks as
per the 2011 DRC RFI #2 (See Above) and the DUSA 10/17/2011 Response (Photos 2 3)
DRC will follow up dunng the 2012 Storm Water Inspecnon to ensure that the concrete
foundattons have been completed
Secondary containment is earthen under the same agreement as the sodium chlonde tanks
Ammonia Tanks - No issues noted secondary containment is earthen per the same
agreement as the sodium chlonde tanks Photo 13
Used Oil Tank — See Shop/Vehicle Maintenance Areas Comments Above
Kerosene Tank — See Shop/Vehicle Mamtenance Areas Comments Above
Fuel Tanks - Above ground tanks appeared maintained and had secondary containment
(Photo 5) DRC did note that the northeast comer of the secondary containment for the diesel
tanks has an accumulation of water due to overspray from the dust tmcks however the
volume accumulated was not large and would not impact the effecUveness of the
containment
Uranium Liquor Tanks - Containment areas appeared to be in good condttion
Vanadium Pregnant Liquor (VPL) Tanks - Per comments related to an Engineenng
(Discharge MinimizaUon) mspecnon conducted by DRC personnel dunng 2010 it was noted
that steam condensate from the VPL tanks was being allowed to accumulate m the area of the
tanks and around the tanks In response to these comments DUSA agreed to provide a
concrete secondary containment and pumpout system for the steam condensate DRC found
dunng the 2011 storm water inspecnon that the concrete has been poured for the
containment and that the project was snll in process (Photos 36 37) DRC will provide
addttional follow up dunng the 2012 inspecnon
Also per the DRC RFI comment #2 regardmg on grade tanks DUSA has excavated around
the bottom of the VPL tanks and found them to have exisUng concrete foundations (Photo
35)
Clean Water Tank -
Per the DRC RFI number 6 above DRC was concemed that the clean water tank discharge
seal was not working correctly smce a discharge was noted Per the DUSA October 17 2011
response to the RFI it was noted that the discharge was not due to a faulty or leaking valve
but was due to the water level being filled above max DUSA pointed out that the tank is
filled automatically (Recapture Reservoir Water Line) and will routinely overfill the tank
(Photo 41) DRC pointed out that this was resulting m standing water onsite (conUnual
ponding and vegetaUon growth) on bare ground (Photos 40 42) DUSA responded that they
would provide a closed pipe system which would route the overflow to Roberts Pond without
White Mesa Mill
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Storm Water Management
Page 14 of 23
ground contact Per an e mail to DRC from David Turk on November 4 2011 it was venfied
that the constmction had been complete The e mail also included several pictures of the
completed project Three of the pictures are included below
This action appears to be appropnate/effective to control the overflow discharge DRC will
inspect the completed construcnon dunng the 2012 Storm Water Inspecnon
Sulfuric Acid Tank - The tank appeared in good condUion (Photo 44)
Propane Tank - Tanks and area appeared to be m good condttion
Caustic Soda Tank -
Per the Violation/CAL item #2 as stated above DUSA violated the Groundwater Permit Part
ID 10 by failing to replace/repair concrete in the secondary containment ofthe Causnc Soda
Tank
Per the October 17 2011 DUSA response to the CAL and the 2011 DRC inspecnon
walkthrough it was venfied that the containment has been repaired (Photos 30 31) The
DUSA Acnon appears to be appropnate and has addressed the CAL concem
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Storm Water Management
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Soda Ash Tanks -
Per the Violation/CAL item #3 DUSA violated the Groundwater Permit Part I D 10 by
failing to repair cracks in the secondary containment area for the soda ash tanks
Per the October 17 2011 DUSA response to the CAL and the 2011 DRC mspecnon
walkthrough it was venfied that the containment cracks have been repaired (Photo 32) The
DUSA Acnon appears to be appropnate and has addressed the CAL concem
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Cells 1 2 3 4A and 4B and observed the condttion of the
outer toe areas of the dikes to ensure that excessive erosion or damage (e g burrowing
animal mtmsion or roonng damage) was not present Per the DRC review the dikes appeared
in good condttion
Summary of Onsite Closeout Meeting
Date/Time October 18 2011/1530
DUSA Representatives Present Daniel Hillsten Mill Manager
David Turk RSO
DRC Representatives Present - Phil Goble Compliance Section Manager
Tom Rushing P G
An onsite close out meeUng took place amongst Phil Goble (DRC) Tom Rushing (DRC)
Dan Hillsten (DUSA Mill Manager) and David Turk (DUSA) Dunng this meettng DRC
informed the DUSA representaUve of the issues stated m the inspecnon above
Conclusions
DRC will anange a conference call with DUSA representanves to discuss the violattons
found dunng the 2011 inspection and will prepare a Nonce of ViolaUon and Order for the
violanons as hsted below and discussed in this memo above
The NOV cover letter will include a discussion of the DUSA 10/17/11 response to the DRC
9/1/11 CAL and RFI
It was noted that as part of the RFI response DUSA submitted a revised SWBN4PP (dated
Oct 2011) The revised SWBMPP will be revised and a full hard copy and te:xt searchable
copy of the revision will be requested to be submitted to DRC withm 30 calenc5ar days of
DUSA receipt of the DRC letter as discussed m the sections below
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Violations
Five violanons of the Ground Water Quality Discharge Permit Permit No UGW370004 were
noted dunng the 2011 DRC Storm Water Inspecnon (October 18 2011) it is recommended
that they be cited in a formal Nonce of Violanon and Order
Violation I
DUSA violated the Utah Ground Water Discharge Permit UGW370004 Part I D 10 by
failing to manage all contact and non contact storm water in accordance with the currently
approved Storm Water Best Management Pracnces Plan (SWBIVIPP) Specifically DUSA
violated Part 2 0 of the SWBMPP by failing to provide an adequate ditch and diversion
system to channel and contain the surface mnoff to the tailings management system which
resulted in offsite discharge(s) of contact stormwater out of the restncted area at the southeast
comer of the White Mesa Mill Facility
Violation 2
DUSA violated Ground Water Permit UGW370004 Part ID 11 by failing to store and
manage feedstock matenals m water nght containers (or water nght overpack) or on a
qualified hardened surface Specifically DRC found dunng the 2011 storm water mspecnon
(October 18 2011) that eight opened dmms containing feedstock matenals were stored on
the ground in the area south of the altemate feed circuit Some of the drums were m
overpacks but were opened and therefore not water nght some drums were not in overpacks
were opened and were badly detenorated (perforated and rusted through)
Violation 3
DUSA violated the Utah Ground Water Discharge Permit UGW370004 Part I D 10 by failing
to provide adequate active operational measures to discover prevent control contain and
clean up spills of kerosene outside of the secondary containment located north of the shop
building On ground spills were observed dunng the DRC 2011 Storm Water Inspecnon
Violation 4
DUSA violated the Utah Ground Water Discharge Pennit UGW370004 Part I D 10 by failing
to provide adequate active operational measures to discover prevent control contain and
clean up spills of oil from drums stored on racks east of the shop buildmg MuUiple on
ground spills were observed dunng the DRC 2011 Storm Water Inspecnon
(October 18 2011)
Violation 5
DUSA Part ID 10 of the Ground Water Permit Pennit No UGW370004 by failing to
control contact wash water at the New Decontamination Pad near the scale house
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Specifically DRC found dunng the 2011 Storm Water Inspecnon (October 18 2011) that the
pumpback system pump was leaking to the ground Leakage volume was esnmated at a half
gallon per minute '
Findings DRC Review ofthe DUSA 10/17/11 Response to the 9/1/2011 DRC CAL and
RFI
Confirmatory Action Items (3 Items)
CAL Item #1
DUSA violated the Groundwater Permit Part ID II by failing to manage drums containing
alternate feed material (located outside ofthe feedstock management area) in compliance
with the required performance standards
a Feedstock material was not stored in water tight containers
b Feedstock material was not stored on a hardened engineered- surface or
asphalt or concrete
c Feedstock material was not stored in a designed and approx^ed storage
area (by the Co Executive Secretary) or other approved area
DRC observed open and degraded containers containing feedstock material on soil and
located outside of the feedstock management area
DUSA Response and Acnons
DUSA constmcted a concrete pad for temporary storage of drums containing altemate
feedstock with Executive Secretary approval The final approval and close out letter was
sent to DUSA by the Execunve Secretary dated October 24 2011
DRC Findings
DRC considers the DUSA follow up actions appropnate No addinonal achon needed
CAL Item #2
DUSA violated the Groundwater Permit Part ID 10 by failing to replace/repai r concrete in
the secondary containment of the Caustic Soda Tank
DUSA Response and Acnons
Per the October 17 2011 DUSA response to the CAL and the 2011 DRC inspecnon
walkthrough it was venfied that the containment has been repaired
White Mesa Mill
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Page 18 of 23
DRC Findings
The DUSA Acnon appears to be appropnate and has addressed the CAL concem No
additional action needed
CAL Item #3
DUSA violated the Groundwater Permit Part ID 10 by failing to repair cracks in the
secondary containment area for the soda ash tanks
DUSA Response and Acnons
Per the October 17 2011 DUSA response to the DRC CAL and the 2011 DRC inspecnon
walkthrough it was venfied that the soda ash tank secondary containment cracks have been
repaired
DRC Findings
The DUSA Action appears to be appropnate and has addressed the CAL concem No
addinonal acnon needed
Request for Information Items (5 Items)
RFI#1
DRC requested information regarding updates to the plans/inspections to prov'ide inspections
according to frequencies required by the Storm Water Best Management Practices Plan
(SWBMPP) DRC noted for example the SWBMPP requires a weekly inspection ofthe
diversion ditches however they are conducted monthly DRC noted that failure to either
provide these inspections in conformance with the SWBMPP or modify the SWBMPP is a
violation of the Groundwater Permit Part ID 10 The Permittee will manage all contact
and non contact storm water and control contaminant spills at the facility in accordance
with the currently approved storm water Best Management Practices Plan
DUSA Response and Acnons
DUSA updated the White Mesa SWBMPP dated October 2011 The updated plan includes
revised inspecnon intervals which correspond with the daily weekly monthly and quarterly
mspecnon forms
DRC Findings
Per DRC review the October 2011 revised SWBMPP appears to address the RFI by
changing the frequency of the diversion ditch inspection to monthly DRC also noted that the
revised SWBMPP updates the tables listing quantity and types of reagents chemicals and
petroleum products and solvents stored at the Mill facility DRC did note that DUSA did not
White Mesa Mill
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Storm Water Management
Page 19 of 23
submit a complete revised copy or electronic file of the revised SWBMPP DRC will request
that DUSA submit the copies
October 2011 Storm Water Best Management Practices Plan Approval and Request for
Information
Based on review of the DUSA revised SWBMPP it appears that the updates have addressed
the DRC concems in the September 1 2011 DRC RFI Therefore the October 2011
SWBMPP IS approved and will be used for compliance purposes
DRC does require that DUSA submit complete copies of the October 2011 SWBMPP
including both Appendices in both hard copy and text searchable electronic format (PDF)
withm 30 calendar days of receipt of this letter DRC noted that a full copy was not provided
with the October 17 2011 DUSA response letter
RFI#2
DRC requested information regarding the inspection procedures for reagent storage tanks
(including intermediate process tanks eg Pregnant Liquors) which are installed on grade
(on grade refers to tank installations where the tank bottom is in contact with the ground) to
ensure that the structural integrity ofthe tank bottom is acceptable/appropnate DRC noted
that cathodic protection for on grade tanks is prescribed on grade tanks in order for DUSA
to comply with Part ID 10(a) of the groundwater permit
DUSA Response and Acnons
DUSA will ensure that all on grade reagent and intermediate process tanks are on concrete
pedestals Per the DUSA mvestiganon there are two kerosene tanks which are on grade and
will require concrete pedestals to be constmcted All other on grade tanks have existing
concrete pedestals
DRC Findings
The DUSA response is consistent with commumcatton between DRC and DUSA conceming
the on grade tanks specifically DRC provided response that on-grade tanks will require
either cathodic protecUon or to be placed on concrete pedestals DRC will inspect the on-
grade tanks dunng the 2012 storm water mspecnon to ensure that they all have concrete
pedestals
Rn#3
DRC requested an outline of a plant process for intemal notification and documentation of
the cleanup of small quantity spills (less than reportable quantities) Per the 2O10 inspection
it was noted that a fuel spill had occurred at the fuel tank area however but had not been
cleaned up and there did not appear to be a process to identify document or clean up such
spills DRC noted that failure to provide such a process is not in conformance with the
SWBMPP Part 4 2 1
White Mesa Mill
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Page 20 of 23
DUSA Response and Acnons
In response to Request for Informanon item number 3 request with the findings of the 2010
storm water inspection DUSA provided a change to the small quannty spills protocols in the
October 17 2011 response letter as follows
DUSA has implanted an intemal notification process for small quantity spills (less than
reportable quantities) with the following steps
1) Mill environmental personnel will fill out on the daily inspection form observations of
spills of reagent chemicals of any size The form will be amended to add spaces for this item
2) In addition all Mill employees will be trained to advise Mill environmental personnel of
any spills that they observe during the day and these will also he noted in the daily
inspection form
3) Ifthe spill IS of a reportable quantity environmental personnel will follow the procedures
in the Mill s SWBMPP plan
4) For spills smaller than reportable quantities the environmental inspector will record
infonnation regarding the spill and the nature and type of cleanup on the form
5) The information on the inspection form will he added to a database maintained at the Mil
The database will be updated and maintained on site indefinitely Cards are maintained for
no longer than one year
DRC Findings
The conecnve acnons were not implemented before the DRC October 18 2011 inspecnon
therefore the new reporting process will be reviewed dunng the DRC 2012 storm water
inspecnon
RH#4
DRC requested that DUSA review the facility SPCC plan to ensure that all tanks included
under the current facility Spill Prevention Countermeasure and Control (SPCC) plan meet
current requirements of current EPA mies (40CFRII2) Specifically it was noted that any
non PCB containing tanks should be included under oil inventory and be included with
inspection protocols The RFI was required in order to ensure that current procedures and
policies at the mill are up to date
DUSA Response and Actions
Per the October 17 2011 DUSA response DUSA provides a histoncal summary of the Mill
and claims that it is not required to comply with the requirements of the SPCC rule due to the
Mill being constructed with an overall grade and diversion ditch system designed to
channel any non recovered portion of any material spill to the tailings management system
DUSA does agree to review the SPCC Rule (Current 40CFR112) to determine whether or
not any modifications to the SPCC plan would be appropriate for the Mill
White Mesa Mill
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Storm Water Management
Page 21 of 23
DRC Findmgs
DRC will follow up regarding the DUSA review of the rule and changes which are planned
m the SPCC dunng the 2012 storm water inspecnon
RFI #5
DRC requested that DUSA seal mtenor drains in the vehicle maintenance areas that dram to
outdoor uncovered areas It was noted that this is specified m the facility SWBMPP and is
considered a best management pracnce to minimize the quannty of contaminated matenal
DRC noted that the open dram is not in conformance with the SWBMPP part 4 3 1 second
bullet clean up spills promptly don t let minor spills spread
DUSA Response and Acnons
The DUSA response descnbed that water from the shop intenor drains into the outdoor sump
(baffle box) and is then intermittenfly pumped to the tailings management system ( pump is
tumed on/off by hand)
DRC Fmdings
The system was evaluated dunng the October 18 2011 storm water inspecnon DUSA
representanves tumed on the pump and drained a portion ofthe water contained m the baffle
box DRC witnessed the discharge undemeath the CCD circuit to Roberts Pond Based on
DRC review of the response and inspecnon the system seems adequately designed and
managed to control discharge from the shop intenor No additional acnon is required
regardmg RFI #5
RFI#6
DRC requested that DUSA ensure that the clean water tank valve is sealing properly Per the
2010 storm water inspection it was noted that this valve was leaking and was creaUng pond
areas in unlined ditch/soil areas It was noted that this is not m conformance with SecUon
4 1 4 of the SWBMPP which states Areas requinng maintenance or repair such as
excessive vegetauve growth channel erosion or pooling of surface water runoff will be
report[ed] to site management and maintenance departments for necessary action to repair
damage or peiform reconstruction in order for the control feature to perform as intended
DUSA Response and Actions
Per the DUSA October 17 2011 response to the RFI it was noted that the discharge was not
due to a faulty or leaking valve but was due to the water level being filled above max
DUSA pointed out that the tank is filled automatically (Recapture Reservoir Water Line) and
will routinely overfill the tank DRC pointed out that this was resulnng in standing water
onsite on bare ground DUSA responded that they would provide a closed pipe system which
would route the overflow to Roberts Pond without ground contact Per an e mail to DRC
White Mesa Mill >
Ground Water Module 65 ' , ^ -
Storm Water Management
Page 22 of 23 ^ , -
from David Turk on November 4 2011 it was yenfied that the constmcnon had been
complete Several photos of the construction and completed project ^ere also provided
DRC Findings (
This action appears to be appropn ate/effective to control the overflow dischai:ge DRC will
inspect the completed constmcnon dunng the 2012 Storm Water Inspecnon ^
_ y ^ F \DUSA\Storm Water Management\2011 bispection\2011 SW Inspection Memo DUSA White Mesa Mill docx ,
r J
i
Appendix 1 - Photo Pages
Appendix 1 - Photo Pages
Demson Mines White Mesa Mill
2011 DRC Storm Water Inspecnon
Photo Pages
Page 1 of 14
Photo 1 - Sodium chlorate tanks Photo 3 - Kerosene tank on concrete pad
Photo 2 - Kerosene tank note that the tank will be
reconstmcted on a concrete pad per the 2010 DRC
storm water inspection findings
Photo 4 - Intermediate process tanks east of the SX
building note secondary containment is made of
liner matenal DRC noted that the Imer matenal
was npped and showed precipitate from past
spillage
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecnon
Photo Pages ,
Photo 5 - Intermediate SX tanks note missing
section of secondary containment liner the Imer
was very bnttle
Photo 7 - Drainage berm on the southem side ofthe
; ore storage pad '
Photo 6 - Ore tailings pad drain located at the
south east comer of the tailings pad
Photo 8 - Photo taken at the south east comer ofthe
facility confines Note that a drainage swale has
been formed to allow drainage from the
decontaminafion sump (see photo 11) DRC noted
evidence that drainage out of the facility had
; occurred at this point
)
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspection
Photo Pages
Page 3 of14
Photo 9 - Drainage ditch (note white liner) on east
facility margin for overflow from the
decontamination pad
%j. ....J. i-- w.!^_i,v'-.-»,...»
Photo 10 - Another view of the east ditch note
decontamination pad in the left backgrotmd
Photo 11 - East drainage ditch closed sump DRC
noted overflow discharge had occurred offsite
Photo 12 - Decontaminafion pad discharge into
holding tanks (center nght pipe discharge)
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 4 of 14
Photo 13 - Decontamination pad pump back Photo 15 - Decontamination pad pump back view
of location
Photo 14 - Decontaminafion pad pump back note
leak '
Photo 16 - Fuel pump area
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 5 of 14
Photo 17 - Fuel pump area note soil on top of the
concrete pad
Photo 19 - Full oil dmm storage (pnmanly
hydraulic type oil) east of shop area Note spill on
gravel foreground
Photo 18 - Altemate feed dmm storage Photo 20 - More oil spills around storage rack
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspection
Photo Pages
Page 6 of 14
Photo 21 - More oil spills around storage rack Photo 23 - Spill clean up matenal on the shop floor
Photo 22 - Oil spill undemeath storage rack likely
from faulty barrel valve
Photo 24 - Spill clean up matenal inside of shop
area
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 7 of 14
Photo 25 - Spill clean up matenal inside of shop Photo 27 - Spill from kerosene tank outside of the
containment (note stained concrete and residue on
groimd
Photo 26 - Oil inside of shop leaks from valves Photo 28 - Discharge pipe for water separator
outside of the shop (outdoor baffle box north side of
shop)
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 8 of 14
•&J!^^0;^i'--•
Photo 29 - Shop Discharge to Roberts Pond note
that the discharge water is pumped from the shop to
this locafion undemeath the CCD circuit by the Mill
Building
, Photo 31 - Causfic soda tank secondary
containment, any accumulated fluid enters the SX
C building inlet center photo
Photo 30 - Caustic soda tank secondary
containment the floor has been temporanly
resurfaced pending replacement of the tank
Photo 32 - Soda ash tank secondary contaimnent
note that cracks identtfied dunng the 2009 and 2010
DRC storm water inspection have been patched
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 9 of 14
Photo 33 - Additional improvements made to the
soda ash secondary containment curbing and mlet
Photo 35 - Vanadium Pregnant Liquor (VPL) tanks
note that the foundations have been dug out to
expose the concrete bottom pads (previously buned)
Photo 34 - Soda ash secondary containment Photo 36 - VPL tanks, new concrete pad per DRC
comments noted dunng a DMT inspection
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspection
Photo Pages
Page 10 of 14
Photo 37 - VPL tanks concrete pad to capture ^
condensate
Phbto 39- '
Photo 38 - Old decontamination facility discharge
tank note that the pad is not currently in operation
Photo 40 - Cl^an water tank DRC noted that ^
overflow is mnning across groimd and allowing
vegetafion growth and potential infiltrafion to
) ^ ground water
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 11 of 14
Photo 41 - Influent into the clean water tank line
from Recapture Reservoir is on an automafic fill
valve
Photo 43 - Clean water tank piping
Photo 42 - Clean water tank discharge, due to
intermittent overfilling of the tank
Photo 44 - Sulfunc acid tank and newly constmcted
berm to keep any potential discharges out of the
adjacent power sub station
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 12 of 14
Photo 45 - Altemate feed dmms in overpacks
located beside to new management area
Photo 47 - Newly poured concrete management pad
I for altemate feed dmms
Photo 46 - Altemate feed drums m overpacks
located north north west side of the new altemate
feed management pad note that the barrels are not
on the newly poured pad
Photo 48 - Example of a drum located on the
southeast of the altemate feed management pad not
on the pad containing altemate feed matenal but
not stored in it s overpack
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecfion
Photo Pages
Page 13 of 14
Photo 49 - Altemate feed dmm which contains
altemate feed matenal not in an overpack not
covered and not located on a hardened engineered
surface
Photo 51 - Examples of altemate feed dmms some
are in over packs but have been opened some are
not in over packs (these dmms are prepped to enter
the altemate feed circuit
Photo 50 - Reagent Storage Building Photo 52 - SX building liquid containment
Denison Mines White Mesa Mill
2011 DRC Storm Water Inspecnon
Photo Pages
Page 14 of 14
Photo 53 - Diversion Ditch 1, Upland Run on.
Control Maintained \
Photo 54 - Diversion Ditch 2 Upland Run on
Control Maintained
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U.S. Postal ServiceTM
CERTIFIED MAILn RECEIPT
(Dmmestic Mail Only; N0 Insurance Cmverage Prmviile^)
For delivery information visit our website at www.usos.com*
1 C I A L u s ^
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RE ORG FINDINGS RFI AND ADVISORY / TR
David C Frydenlund
Vice President & General Counsel
Denison Mmes (USA) Corp (DUSA)
1050 17th ST STE 950
Denver CO 80265
Cty Slate ZIP 4
PS Farin 3t«l. Aufust 2«te
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