DRC-2010-004003 - 0901a068801a9186

DENISO
MINES
^ 4 Oenisan Mines (USA) Conx
10M 17th Straat, SUHB 950
Ooiwar, CO 8028S
USA
Tel: [phone]
Fax: [phone]
wwMr.doniaonmines.com
DHC-2010-004005
July 15, 2010
VIA OVERNIGHT DELIVERY AND E-MAIL
Mr. Rusty Lundberg
Executive Secretary
Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, Utah 84114-4810
Re: Denison Mines (USA) Corp. White Mesa Uranium Mill, Groundwater Discharge
Permit No. UGW370004 (the '^GWDP") - Request for Information Regarding New
Decontaniination Pad and Submittal of Documents under Part I.H.4 and I.H.5 of the
GWDP
Dear Mr. Lundberg:
Denison Mines (USA) Corp. ("Denison") is providing the follow responses to the June 3, 2010,
report of Findings and Request for Information from Mr. David Rupp of the Division of
Radiation Control ("DRC"). Each DRC request is shown in italics below, followed by Denison's
response to the question and/or request for information.
Comment 1.
Ore Storage Pad Buffer Zone. Along the southern border of the ore storage pad area, ore-
like appearing materials were noted to be in contact with the fence. The depth of this
material in contact with the fence was about 2-feet. Mr. Bartlett of DUSA offered to remove
the material that day, which was accepted by the DRC representatives. The 4-foot buffer is a
current requirement of the DMT Plan, and if the current permit changes are approved, it will
be a Ground Water Discharge Permit requirement as well.
We request DUSA supply a photograph of this completed work.
Response
The "ore-like" material was removed from contact with the fence on May 4, 2010. A photograph
of the current condition, indicating that the material has been cleared to conform to the four-foot
Letter to Rusty Lundberg
July 15, 2010
Page 2
buffer requirement in the Discharge Management Technology plan, is provided as Attachment 1
to this letter.
Comment 2.
Pooling Water. Pooling water was observed up to about 50-feet in radius, surrounding the
tall vanadium pregnant liquor tank and water tank east of the Mill building. Sources for the
water appeared to be storm water run-on, direct precipitation and steam condensation. At
our exit meeting at the White Mesa Mill Administration Office, various proposed
configurations to eliminate this water pooling were discussed.
However, as mentioned above, Messrs. Rupp and Frydenlund spoke about this item later that
evening. It was discussed that DUSA needs to assure that the area around the tanks fully
drains to Cell 1. Complete drainage to Cell 1, rather than pooling or retention of water, is a
requirement of the DUSA Storm Water Best Management Practices Plan (SWBMPP).
In our discussion on May 17, 2010 you agreed that this work would be completed on or prior
to September 30, 2010. We acknowledged that response to this item may include required
provisions for leak containment of the VPL tank. Completion of this work will be verified
during the annual DUSA storm water management inspection by DRC to be conducted this
fall.
Response
Denison appreciates DRC's observation and comment on this item.
The water present in the bermed area at the time of the May 4, 2010 inspection consisted of a
combination of steam condensate from a heat exchanger on the VPL tank, and some precipitation
water. Mill operations staff generally check for standing water in this area and remove standing
water by pumping out the stormwater collection sump within the existing berm. Due to the
recent rainfall preceding the inspection date, the pooled water did, in fact, contain some
precipitation, and the sump had not yet been pumped on the moming of the inspection.
Following the inspection, the sump was pumped out on May 4, 2010.
Denison understands the inspectors' concem with the presence of the berm and their rationale,
stated at the on-site meeting, and the June 3, letter, requesting that it be removed to allow
drainage to the tailings system, consistent with the SWBMPP. However, Denison plans to
maintain this berm and address the standing water as discussed below.
DENISO
MINES
Letter to Rusty Lundberg
July 15,2010
Page 3
The White Mesa Mill's Groundwater Discharge Permit requires, in Section I.D.3(g), that the
Mill provide secondary containment for all chemical reagent storage. Although the vanadium
pregnant liquor tank and the water tank addressed in this comment are not reagent tanks, and the
condition in the GWDP is not strictly applicable to process and intermediate tanks, Denison still
plans to maintain this berm. It is Denison's policy to provide, at a minimum, secondary
containment berms or catchment sumps around all outdoor tanks. Even though the SWBMPP
indicates the need to allow free drainage of spilled liquids and/or precipitation directly to the
tailings cell area, the use of containment berms, and collection and pumping of accumulated
liquid within the berms, helps minimize the opportunity for process solutions, or precipitation
and mnoff commingled with process solutions, to affect groundwater.
Denison proposed to manage precipitation in the VPL and water tank area as follows. Denison
proposes to constmct a concrete-lined contairmient, which is consistent with current GWDP
requirements for new constmction, around the pumps and piping at the base of these two tanks.
The earthen berm will remain in place. Standing liquids in the new concrete containment area
and the existing stormwater sump will be removed by portable pump as required.
A sketch of the proposed VPL area concrete contairmient design has been provided as
Attachment 2 to this letter. Denison will commence constmction on the proposed design within
30 days of receiving written concurrence from DRC on the attached drawing.
Denison has added an item to the Ore Storage/Sample Plant Weekly Inspection Checklist,
requiring that the Radiation Department staff perform an inspection identify to any standing
water in bermed areas, instmct operations to have the water removed, and document that the
removal was performed. A copy of the revised Ore Storage/Sample Plant Weekly Inspection
Checklist including these new requirements has been provided as Attachment 3 to this letter.
The new checklist requirements for weekly inspection and pumping are not limited to the VPL
and water tank area, but include observation and response to standing water any outdoor areas of
the Mill.
Comment 3
Apparent Narrow Travel Lane on the Dike between Cells 4A and 4B. During the May 4, 2010
inspection, Messrs. Snyder and Bartlett indicated they were considering using fences and
gates to control access to the narrow travel lane on this dike, and that only certain traffic
would be allowed. No photos or measurements were taken during the inspection. Later, we
expressed some concerns that the total dike width may be too narrow. On May 19, 2010 Mr.
Harold Roberts of DUSA telephoned with measurements, stating the dike met or exceeded the
current construction width requirements.
DENISO
MINES
Letter to Rusty Lundberg
July 15,2010
Page 4
Response
As indicated in the comment, the dike does meet the current constmction width requirements.
No fiirther action will be taken in response to this comment.
Comment 4.
Surveying of Settlement Monitors: Recommendations for Improvement. It appears there may be
potential error reduction if DUSA used a more organized ledger form for collecting and
reducing survey notes. Avoiding long distance survey rod readings by using turning points,
additional benchmarks or other methods could also significantly reduce errors. These actions
may produce less erroneous data for the analysis, explanation, correction and resolution
required in proposed new License Conditions 11.7.E and 11.7. /.
Response
Denison has noted Mr. Rupp's recommendations.
If you have any questions on the attached information and documents please feel free to contact
me at [phone].
Yours very tmly.
Jo Aim Tischler
Director, Compliance and Permitting
Enclosures
cc: Ron F. Hochstein
Harold R. Roberts
David A. Rupp
Jo Ann S. Tischler
Rich E. Bartlett
David E. Turk
DENISO
MINES
ATTACHMENT 1
Photograph of
Current Ore Pad
Fence-line Conditions
ATTACHMENT 2
Proposed VPL Containment Area Design
ATTACHMENT 3
Revisions to
Ore Storage/Sample Plant
Weekly Inspection Checklist
White Mesa Mill - Standard Operating Procedures 9/0&7/10 Revision_l: Denison-67
Book 11: Environmental Protection Manual, Section 3.1 Page 1 of 2
APPENDIX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:
comments:
Are all altemate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no:
comments (e.g., conditions of containers):_
Me all sumris and low laying areas free ofa standing solutions?
Yes: No:
If'YesNo". how was the situation corrected, supervisor contacted and correction date?
Conditions of storage areas for materialsls there free standing water or water running otTof the feedstock
stockpiles?
Yes: No:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
9/0*7/10 Revision J.: Denison-67
Page 2 of2
Comments:
Other comments:
m m m mm mm mm mm mm mm
ill
(/) n n -I
a z
tx) I ta
(/)
X rn n
o
TB
fflii
Hii
=11=11=11
n n
-H
a z
3> I 3>
-0
> Z
a i/t
< §
(/) C/) M
to X) 70 s CO f
i tn cn cn \ V.
ru ro ru cn cn cn \ \ g 1—.
o o o n
<
TJ
X} rn >
n • z
m
> X) X) > .z
Cl
m
m
ON cn CJ
X
m
>
m
3> (/) C X} X3 a c z a
</> -t c X n m
X
»—I
m
a°
mm
^ I—1
' I—»
-•>;$
X zm
< >
;PMXJ
z • -n
a z -n
P z •
CO X
n • z o
X)
rn
m
n X) a m
Z (z)
-I >
> XJ
i -
rn
C/)
(/> X >
TJ
to
O
rn
>
X)
m
2 to X •—• a m
Cl
m
XJ n
a XI 3> Cl
m
m
n a z -I
z c a c
TJ
<
n
m
XJ
P, m
CJ
3> <=
z a
3: -I c • z
• m -n
ro
ru
(/) n -I o ;o z rn n
Z XJ CT m -I -i X m
• CO •n X > r-
o |-
o
°w
•—'
• m rn z -< TJ m
z a
rn to CT m > 3> XJ to XJ -I a • -tec
X XJ z
-n -H t:s m "0 {_ a X)
r m
CO TJ • > px)
cofi
> • z z tu CO
Si
XJ"
m S
>—i i X) a m m
•n XJ m
rn
I—I . CT X
CO
9J y>
X
>
n
z
TJ XJ
m CO CO
< m
La
z< CT > |-
-i "n X CO n a • "n 2 -1 TJ 3> > n z —I a m a