DRC-2010-001342 - 0901a0688015ea41

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State of Utah
GARY R. HERBERT
Gmernnr
GREG BELL
Lieutenant Giivernor
Department of
Environmental Quality
Amanda Smith
Executive Dirciiiir
DIVISION OF RADIATION CONTROL
Dane L. Finerfiock
Diredor
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MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
DUSA Files
David Rupp <^^
January 19, 2010
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Cell 4A Leak Detection System (LDS)
Omission of Reporting and Exceedance of Pressure Limit on the LDS Liner
Notice of Violation and Compliance Order (NOV/CO)
References:
a. DRC Letter November 25, 2009, Subject: Engineering Module 75E; Request for
Information; Documentum No. DRC-2009-006467
b. NOV/CO, Docket Number UGW09-13.
c. DUSA Memorandum March 31, 2009, Subject: Cell 4A Leak Detection System; Copy of
this DUSA Memo is aUached.
Introduction:
On October 28-29, 2009 I visited the DUSA White Mesa Mill to inspect the facility for
compliance with DMT/BAT requirements. A DUSA memo was identified dated March 31, 2009,
reference c above. This memo shows DUSA allowed the LDS sump system for Cell 4A to exceed
the allowable head limit of 1-foot on the lowest liner elevation. This limitation is set at 1-foot by
the Ground Water Discharge Permit Part I.D.6(a) as follows:
"Leak Detection System (LDS) Maximum Allowable Daily Head - the fluid head in the
LDS shall not exceed 1 foot above the lowest point on the lower membrane liner . . ."
The Ground Water Discharge Permit Part I.G.3(a) also requires:
"Permittee to Provide Information - in the event that the Permittee fails to maintain DMT
or BAT or otherwise fails to meet DMT or BAT standards as required by the permit, the
Peimittee shall submit to the Executive Secretary a notification and description ofthe
failure according to R317-6-6.16(C)(1). Notification shall be given orally within 24 hottrs
of the Permittee's discovery of the failure of DMT or BAT, and shall be followed up by
written notification, including the information necessary to make a determination under
R317-6-6.16(C)(2), within five dtiys ofthe Permittee's discovery ofthe failure of best
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NOV Memorandum
January 19,2010
Page 2
available technology."
During the inspection, other records were reviewed to find records of the head limit exceedance
occumng. No other DUSA records of the exceedance were found, either in the applicable
quarterly report, or in the daily mill inspection records. Also, no evidence of verbal notice to
DRC ofthis exceedance was identified.
Basically, the NOV/CO, listed as reference b, is for not providing notification of exceedance of
the pressure or head in the Cell 4A LDS. Initially an announcement of this issue was given to
DUSA per reference a.
Although within the NOV/CO the DRC gives sevet-al references to the actual head exceedance
violation, the emphasis of this NOV/CO is no notification being provided. This is stated near the
end ofthe findings in the NOV/CO Finding of Facts item seven (7).
Good faith effort was exercised at the DUSA staff level by writing the memorandum, reference c.
This intemal memo notifies DUSA management ofthe problem. However, company management
did not provide any verbal or written notice to the DRC.
The actual physical problem was apparently caused by a latent crossing the pump and other grid
system wiring, and thus changing the polarity of the electrical power to the pump. This caused the
pump motor to rotate the wrong direction, thus not pumping the LDS sump.
Attachment: Reference c.
F:\DUSA\NOV MEMO Jan 2010.doc
MINES
DsnisDn Mines Corp.
Si)Z6 S. Highway 191, PO Box 8D9
BIhndlng.UT S-ISII
USA
Tel : 435 67B-2221
Fax : [phone]
wwvtwJenlaonmlres.com
Memorandum
To: David Turk cc: Centra! Files
From: Ryan Palmer
Date: 3/31/09
Re: Cell 4A ieak Detection System
This report Is being submlttetj in order to stay in compliance with the BAT monitoring syslem. The BAT
states the following will occur if an equipment failure takes place, Mill management will be notified, description
of the failure and the root cause of failure will be documented in a report to mill management. The equipment
was not running at capacity causing the head in the LDS to exceed the established limit of 12 inches above the
Secondary FleKibls Membrane Liner, which on the readout is 25 inches. This exceedance created a system
failure,
On March 30"' at approximately 1050 AM the LDS on C4A was found alarming. The alarm is set to go
off al 25" of heat) in the leak detection pipe. When t arrived the readout said 26.5" the pump was on but the flow
meter wasn't registering the flow. New flow meter was installed a few days prior so we thought the pump had
started to go oi.it which wouW account for the low yield of soiution being pumped. The pump was pulled but
looked like it was just fine. We placed the pump back in the pipe and tried to pump again thinking maybe
something was clogging up the intake on the pump like crystal formation. When the pump was restarted it
seemed to pump slightiy better but not what it should. At this time it was getting late in the day and the decision
was made to allow the pump to try and pump overnight and see if the pump would pick back up.
Upon arriving the morning of March 31'' the LDS was found to worse off than the day before. The
readout was in the 40 plus inches of head. It was decided the pump must be wom out so we again pulled the
pump. We tried running the pump through ciean warm water out of a 60 Gallon drum, the pump performed
better than it did in the pipe so again it was thought nothing was wrong with the pump. After discussion we
decided to place a new pump in the pipe just to make sure it wasn't the pump. The new pump went in and it
also struggled much the same as the old pump did. After further talking, the electrician suggested reversing the
electrical connection on Ihe pump. This was done and the pump began pumping at a very high volume where it
should have been pumping all along.
We are assuming that when an electrical contractor was doing some work at the substation fay C4A
LDS they must have inadvertently switched the wiring on the supply end. So when our in house electrician
switched the pump connection end the pump was able to perform at full capacity once again. We feel that the
other pump which was taken out of the LDS is still in good working condition and will be maintained as the
backup pump for this system.