DRC-2010-006186 - 0901a068801e458d

DENISO
MINES 1 o
\vC>,
10-006 186
Denison IVIInes (USA) Corp.
10S0 17tii Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmine8.com
November 29, 2010
Sent VIA Federal Express
Mr. Rusty Lundberg
Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Sak Lake City, UT 84114-4820
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 3rd Quarter of 2010
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
4A BAT Performance Standards Monitoring Report for the 3rd Quarter of 2010, as required
under Parts 1.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater Discharge
Permit No. UGW370004. Also enclosed are two CDs, each with an electronic word-searchable
copy of the enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
Yours very truly,
DENISON MINES (USA) CORP.
Jo Aim Tischier
Director, Compliance and Permitting
cc David C, Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Kathy Weinel
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT
3rd Quarter
July through September
2010
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO. 80265
November 29, 2010
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................................. 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER ......................................................................................................................... 1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING ...... 1
4.0 MONTHL Y SLIMES DRAIN WATER LEVEL MONITORING ............................... 3
4.1 GENERAL .............................................................................................................................. 3
4.2 RESULTS FOR THE QUARTER ................................................................................................. 4
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION .............................................. 5
4.4 GRAPHIC COMPARISON TO PREVIOUS yEAR ......................................................................... 5
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ................ 5
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK
STORAGE AREA ............................................................................................................. 6
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS .................................... 6
8.0 DECONTAMINATION PADS ......................................................................................... 7
8.1 SUMMARY OF WEEKLY WATER LEVEL (DEPTH) INSPECTIONS ............................................. 7
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ............................................... 8
8.3 NEW DECONTAMINATION PAD ............................................................................................. 8
9.0 CELL 4A BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER8
9.1 LDS MONITORING ................................................................................................................ 8
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment ................................ 8
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary Membrane .
... ............................................................... .................. ... ........................ ... 9
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ...................................... 9
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELL 4A .......................................... 9
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .................................................................... 9
10.0 SIGNATURE AND CERTIFICATION ........................................................................ 10
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LIST OF TABLES
Table 1 -Summary of Waste Water Pool Elevations
Table 2 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2009
Table 3 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2010
Table 4 -New Decontamination Pad Inspection Portal Level for the Second Quarter 2010
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part 1.G.3 of the Pennit
C Monthly Cell 2 Slimes Drain Water level Over Time
D Graph of Cell 2 Slimes Drain Water Levels over Time
E Cell Liner R~pair Reports and Notices
F Cell4A Leak Detection System Data for the Qu.arter
il
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT
FOR THE 3rd QUARTER OF 2010
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the 3rd quarter of2010 (the "Quarter") prepared by Denison Mines (USA)
Corp. ("Denison"), as required under Part I.F.2 of the White Mesa Mill's (the "Mill's") State of
Utah Groundwater Discharge Permit No. UGW370004 (the "Permit"), and the Routine Cell 4A
Best Available Technology ("BAT") Performance Standards Monitoring Report for the Quarter,
as required under Part I.F.3 of the Permit.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER
During the Quarter, the following DMT monitoring was performed or addressed, as required
under Part I.E.7 of the Permit:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3;
• Monthly slimes drain water levels in Cell 2;
• Weekly wastewater level measurements in Roberts Pond;
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area;
• Any tailings cell and pond liner system repairs; and
• Decontamination Pad Concrete Inspection (not required this reporting period)
Also during the Quarter, the following Cell 4A BAT performance standards monitoring was
performed or addressed, as required by Part I.E.8 ofthe Permit:
• Leak detection system ("LDS") monitoring for CeIl4A; and
• Weekly tailings wastewater pool elevations for tailings Ce1l4A.
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in Tailings Cells 1,3
and 4A to ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the Mill's State of Utah Radioactive Materials License No. UT 1900479 (the
"License"). These measurements were made from an elevation survey. The results of such
monitoring, reported as feet above mean sea level (fmsl), are included in Attachment A.
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Condition 10.3 of the License provides that the freeboard limit for Cell 1 shall be set in
accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures the freeboard limit for Cell 1 is set as per the
January 10, 1990 Drainage Report for CellI at a liquid maximum elevation of 5,615.4 fmsl.
Condition 10.3 ofthe License also provides that the freeboard limit for Cells 3, 4A and 4B shall
be recalculated annually in accordance with the procedures approved by the Executive Secretary
of the State of Utah Radiation Control Board (the "Executive Secretary"). The current freeboard
limit for Cell 3 was previously calculated under this procedure at 5,601.6 fmsl. However, in a
letter from the Executive Secretary dated November 20, 2008, an interim variance and limit was
established at 5,602.5 fmsl for Cell 3.
During the weekly tailings survey measurement performed at approximately 1 :00 pm on July 30,
2010, the wastewater pool elevation in Cell 3 was measured to be 5,603.10 finsl, compared to the
current freeboard limit for Cell 3 of 5,602.50 finsl, representing an exceedance of 0.6 feet, or 7.2
inches. During the weekly tailings survey measurement performed on July 23, 2010, the
wastewater pool elevation in Cell 3 was measured to be 5,602.76 finsl, compared to the current
freeboard limit for Cell 3 of 5,602.50 fmsl, representing an exceedance of 0.26 feet, or 3.12
inches. These exceedances of the freeboard limit for Cell 3 were the subject of a Notice to the
Executive Secretary under Part I.G.3 of the Permit and Utah Administrative Code ("UAC")
R317-6-6.16(C), dated August 4,2010, a copy of which is included in Attachment B.
The Mill is filling Cell 3 to its final tailings solids capacity in preparation for closure, and Cell 3
is at this time nearly filled with solids and closure activities will begin shortly. The notice of
August 4, 2010 explained that it is no longer possible to manage the Cell 3 freeboard to achieve
the calculated freeboard limit during the final stages of filling Cell 3 with solids and closing Cell
3. The exceedances occurred despite the fact that monitoring and surveying were performed at
the required frequency, all pumping equipment was operating properly, and the liquid transfer
from Cell 3 to Cell 4A was occurring as planned. As discussed below, the freeboard limit for
Cell4A has been set to accommodate Cell 3 as well as CeIl4A.
In addition, Part I.D.2 of the Permit provides that under no circumstances shall the freeboard of
any tailings cell be less than three feet, as measured from the top of the flexible membrane liner
("FML"). The top of the FML in Cell 1 is at 5,618.5 fmsl, the top of the FML in Cell 3 is at
5,608.5 fmsl and the top of the FML in Cell 4A is at 5,598.5 fmsl. This means that the
maximum wastewater pool elevations in Cells 1, 3 and 4A permitted under Part I.D.2 of the
Permit are 5,615.5, 5,605.5 and 5,595.5 fmsl, respectively.
The wastewater pool elevations in Cells 1, 3 and 4A, as measured during the Quarter, are
summarized in the following Table 1. Except as indicated in Table 1, the applicable freeboard
limits were not exceeded during the Quarter for Cell 1 and Ce1l4A. As discussed above, Cell 3
is nearly full of solids and the freeboard limits are no longer meaningful.
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Table 1-Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part I.D.2 of
10.3 (fmsl) the Permit (fmsl)
Celli 5,614.22 5,615.4 5,615.5
Cell 3 5,604.88* 5,602.5** 5,605.5**
Cell4A 5,588.68 5,593.74+ 5,595.5
*ThIS IS the maximum wastewater elevatIOn in Cell 3 durmg the Quarter.
* * Cell 3 is nearly full of solids and the freeboard limit specified here is no longer meaningful.
+The freeboard limit for Cell4A is not set out in the License. The freeboard limit of 5,593.74 for Cell4A is set out
in a letter from the Executive Secretary dated November 20,2008. Denison has proposed in the DMT Plan revision
dated November 12,2010 the removal of the freeboard limit for Cell4A to be replaced by a freeboard limit for new
Cell4B that will accommodate the freeboard requirements of Cells 2,3, 4A, and 4B.
It should be noted that the maximum elevation of 5,593.74 fmsl for Cell 4A has been set
assuming that the total probable maximum precipitation ("PMP") volume for Cells 2, 3 and 4A
will be accommodated in Cell 4A. By letter dated December 11,2008, Denison applied for an
amendment to the License to set the freeboard limit for Ce1l4A at 5,593.74 finsl and to eliminate
the need to set a freeboard limit for Cell 3, given that the freeboard limit of 5,593.74 fmsl for
Cell 4A is adequate to accommodate the total PMP volume for Cells 2, 3 and 4A. The Utah
Division of Radiation Control ("DRC") has indicated, in a letter of April 29, 2010, their
agreement with Denison's proposed revisions to the freeboard limits for Cells 3 and 4A, pending
Denison's submittal of revisions to the Permit and the White Mesa Mill Tailings Management
System and Discharge Minimization Technology Monitoring Plan ("DMT Plan") reflecting the
proposed changes. Denison prepared and submitted these revisions on November 12, 2010.
4.0 MONTHLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(1) of the Permit provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b)(3) of the Permit
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Similarly, Part I.D.6(c) of the Permit provides that, after the Permittee initiates pumping
conditions in the slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements found
in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as measured from the lowest
point of the upper FML) in 6.4 years or less.
Part I.D.3(b )(2) of the Permit provides that the Permittee shall conduct a monthly slimes drain
recovery test at each tailings cell that meets the following minimum requirements: 1) includes a
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duration of at least 90-hours, as measured from the time that pumping ceases, and 2) achieves a
stable water level at the end of the test, as measured by three consecutive hourly water level
depth measurements, with no change in water level, as measured to the nearest 0.01 foot.
At this time, initiation of dewatering operations has not commenced in Cell 3 nor has the Mill
initiated pumping conditions in the slimes drain layer of Cell 4A. As a result, the requirements
in Part I.E.7(b) to monitor and record monthly the depth to wastewater in the slimes drain access
pipes as described in Part I.D.3 of the Permit apply only to Cell 2 at this time. Accordingly, this
Report is limited to slimes drain recovery head information relating to Cell 2 only.
Pursuant to Parts 1.E.7(b) and I.F.2 of the Permit, Section 8.2 of the DMT Plan and
correspondence from DRC, dated February 7, 2008, the results of monthly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Performance Standards Monitoring Report
and Cell 4A BAT Performance Standards Monitoring Report (the "DMT Reports"). Further,
beginning in 2008, quarterly DMT Reports must include both the current year monthly values
and a graphic comparison to the previous year. An annual slimes drain recovery head report, that
addresses the requirements of Part I.F.11 of the Permit and Section 8.2 of the DMT Plan must be
included in the 4th quarter DMT Report.
4.2 Results for the Quarter
In accordance with these requirements, the individual monthly slimes drain recovery head
monitoring data for the Quarter, which includes the date and time for the start and end of the
recovery test, the initial water level, and the final depth to stable water level, is included as
Attachment C to this Report. Those data, as well as the data for the previous year, including the
slimes drain recovery elevations ("SDRE"), are summarized in the following Tables 2 and 3 and
presented graphically in Attachment D.
Table 2 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2009
Elevation of Reported Final Depth to SDRE Values Reported
2009 Test Closinl,! Date Measurement Point Stable Water Level as fmsl
1/30/2009 5,614.83 11.25 5,603.58
2/27/2009 5,614.83 9.35 5,605.48
3/28/2009 5,614.83 8.84 5,605.99
4/27/2009 5,614.83 11.98 5,602.85
5/20/2009 5,614.83 10.28 5,604.55
6/22/2009 5,614.83 13.00 5,601.83
7/30/2009 5,614.83 13.00 5,601.83
8/3112009 5,614.83 11.04 5,603.79
9/28/2009 5,614.83 11.46 5,603.37
10/30/2009 5,614.83 13.35 5,601.48
11123/2009 5,614.83 12.49 5,602.34
12114/2009 5,614.83 13.12 5,601.71
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Table 3 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2010
Elevation of Reported Final Depth to SDRE Values Reported
2010 Test Closine: Date Measurement Point Stable Water Level as fmsl
1115/2010 5,614.83 13.96 5,600.87
2/2112010 5,614.83 12.50 5,602.33
3/15/2010 5,614.83 11.04 5,603.79
4/12/2010 5,614.83 10.40 5,604.43
5119/2010 5,614.83 10.43 5,604.40
6/30/2010 5,614.83 10.13 5,604.70
8/2/2010 5,614.83 10.74 5,604.09
9/1/2010 5,614.83 10.65 5,604.18
9/24/2010 5,614.83 11.50 5,603.33
4.3 Quality Assurance Evaluation and Data Validation
Denison management has evaluated all slimes drain data collected, data collection methods, and
all related calculations required by the Permit, and have verified the accuracy and reliability of
both the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, Denison has concluded
that all of the 1 st, 2nd and 3rd Quarter 2010 and all of the 2009 monthly slimes drain tailings fluid
elevation measurements set out in Tables 2 and 3 meet the test performance standards found in
Part LD.3(b )(2) of the Permit and can be used for purposes of determining compliance with the
requirements of Part LD.3(b )(2) of the Permit.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for each month in 2010 and 2009,
for which validated data is available (see Section 4.3 above), is included as Attachment D, which
shows a graphic comparison of this Quarter's data to data for the previous year.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
During the Quarter, Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part LD.3(e) of the
Permit. Part I.D.3(e) of the Permit provides that the water level in Roberts Pond shall not exceed
an elevation of 5,624 fmsl.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5,618.50
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The results of such
monitoring are included in Attachment A.
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6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the Permit and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part J.D. 11
of the Permit. The results of these inspections are recorded on the Weekly Mill Inspection
forms, which are available at the Mill for inspection. One item was noted during the weekly
feedstock storage area inspections. On July 30, 2010 a drum of Regeneration Material, an
alternate feed material, was knocked over and some of the contents were spilled. The spilled
materials were cleaned up on the same day.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, and 3 were inspected on a daily basis pursuant to the
requirements of Sections 2.1 and 2.2 of the Mill's DMT Plan. The results of those inspections
are recorded on the Mill's Daily Inspection Data sheets, which are available at the Mill for
review. A visual inspection of Roberts Pond was performed on a weekly basis. The results of
those inspections are recorded on the Weekly Mill Inspection forms, which are available at the
Mill for review.
In accordance with Part J.E.7(t) of the Permit, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part J.F. 2 of the Permit provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
Mill personnel detected an accumulation of fluid in the LDS standpipe of Cell 1 on Wednesday,
June 2, 2010. Transfer of fluids from Cell 1 to Ce1l4A to lower the CellI level sufficiently to
detect and repair any damage began on June 2,2010. Maintenance identified some FML damage
and performed repairs during the period when the level was lowest. Following the repairs, the
level was allowed to gradually return to its June 3 level of5614.57 feet and the LDS remained
dry until, after a period of heavy rains in late July and early August (and an increase in the
solution in level in Cell 1), a recurrence of the LDS liquid level was identified on August 7,
2010. At that time, Mill resumed pumping CellI to Cell 4 to lower the solution level.
During discussions on August 12, 2010, DRC personnel agreed with Denison that both the June
and August identifications of LDS solutions were part of one event. The temporary cessation of
flow into the LDS between June and August detections may have resulted from lowering the
solution level to a point below some tears or damage that were not identified during the July
repair efforts. Denison submitted to DRC a plan and schedule for inspection and repair, if
necessary, of the inside slope areas ofthe CellI FML above the 5613 foot level, on August 18,
2010, and updated plan on August 30, 2010. DRC conditionally approved the updated plan in a
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letter dated September 22,2010. The updated plan commits to completion of the repairs by July
31,2012.
The September 22 DRC letter and Part I.F.2 of the groundwater discharge permit require that the
repairs be documented in a liner repair report which shall be included with the next quarterly
DMT report, that is, following completion of the repairs to be reported. Consistent with the
proposed date for completion of repairs in July 2012, Denison will include the required repair
report with the third quarter DMT report to be submitted on December 1,2012.
During the Quarter, no liner repairs were performed at any of the Mill's tailings cells other than
Cell 1. Consistent with the approved repair plan and schedule, repairs to the Cell 1 FML are
ongomg.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Water Level (Depth) Inspections
Section 3.1 of the DMT Plan requires that the vertical inspection portals on the New
Decontamination Pad which are located between the primary and secondary containments be
visually observed on a weekly basis as a means of detecting any leakage from the primary
containment into the void between the primary and secondary containments. The New
Decontamination Pad was placed into service on March 22, 2010. Use of the New
Decontamination Pad was temporarily suspended during the second quarter 2010 as a result of a
cease and desist order from DRC dated May 18,2010. Because the New Decontamination Pad
was not in use, the weekly inspections of the containments were stopped. Table 4 below
indicates the water level measurements in each portal measured during the second quarter 2010
that correspond to the last usage of the New Decontamination Pad. The data have been
maintained here for information purposes only.
Table 4 -New Decontamination Pad Inspection Portal Level for the Second Quarter 2010
Portal! Portal! Portal!
Liquid Level Liquid Level Liquid Level
Date (in Feet) (in Feet) (in Feet)
4/2/10 0.00 0.00 0.00
4/9/10 0.00 0.00 0.00
4/16/10 0.00 0.00 0.00
4/23/10 0.00 0.00 0.00
4/30/10 0.00 0.00 0.00
517110 0.00 0.00 0.00
5/14/10 0.00 0.00 0.00
5/21110 0.00 0.00 0.00
5/28/10 0.00 0.00 0.00
6/4/10 0.00 0.00 0.00
6/11/10 0.00 0.00 0.00
6/18/10 0.00 0.00 0.00
6/25/10 0.00 0.00 0.00
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As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the second quarter.
8.2 Annual Inspection of Existing Decontamination Pad
As required by the Party I.H.5 (c) of the Permit, annual inspections of the existing
decontamination were conducted during the second quarter 2010. The documentation for the
annual inspections are reported in the Second Quarter DMT report submitted on August 30,
2010.
8.3 New Decontamination Pad
As previously stated, the New Decontamination Pad was placed into service on March 22,2010.
Use of the New Decontamination Pad was temporarily suspended as a result of a cease and desist
order from DRC dated May 18,2010. DRC's approval for use of the New Decontamination Pad
has been withheld pending submittal of revisions to the DMT Plan and DRC observation of
hydrostatic testing of the in-ground water holding tanks. Revisions to the DMT Plan were
submitted by Denison on November 12, 2010 and are currently under review by DRC.
Hydrostatic testing will be re-performed during the fourth quarter of 20 1 0, and at the time of this
report, advance notice has been provided to DRC to allow DRC staffto observe testing.
The New Decontamination Pad was taken out of service and inspected during the second quarter
on April 13, 2010 to ensure integrity of the washpad's exposed concrete surface, as required by
Part I.H.4(a)3 of the Permit and Section 6.5 of the DMT Plan. No abnormalities were identified.
No significant cracks (greater than 1/8 inch), deterioration or damage were identified. No repairs
were required at the time of the inspection. A few minor cracks (less than 1/8 inch) were
observed. These minor cracks are being monitored to determine whether they expand over time
and require repair.
9.0 CELL 4A BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER
This Section constitutes the routine Ce1l4A BAT Performance Standards Monitoring Report for
the Quarter, as required under Part I.F.3 of the Permit.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment, including, but not limited to, the submersible
pump, pump controller, head monitoring, and flow meter equipment operated continuously
during the Quarter.
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During the Quarter, there were no failures of any pumping or monitoring equipment not repaired
and made fully operational within 24-hours of discovery, as contemplated by Part LE.8(a)(I) of
the Permit.
9.1.2 Measurement o/Weekly Fluid Head at the Lowest Point in the Secondary Membrane
The readings pertaining to the fluid head above the lowest point in the secondary FML for Cell
4A are provided in Attachment F. As can be seen from a review of Attachment F, at no point in
the Quarter did the fluid head in the Cell 4A LDS sump exceed a I-foot level above the lowest
point in the lower FML on the Cell floor (where for purposes of compliance monitoring this 1-
foot distance equates to 2.28 feet above the LDS system transducer), as stipulated by Part
LE.8(a)(2) of the Permit. During the Quarter, the fluid head in the Cell 4A LDS sump did not
exceed 9.7 inches above the LDS transducer.
9.1.3 Measurement o/the Volume 0/ Fluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F. As can
be seen from a review of Attachment F, during the Quarter, the average daily LDS flow volume
did not exceed 24,160 gallons/day, as stipulated by Part LE.8(a)(3) of the Permit. Based on the
maximum head recorded on the FML during the Quarter of about 33 feet, the allowable flow rate
would actually be approximately 23,299 gallons per day, as determined under the Mill's Cell 4A
BAT Operations and Maintenance Plan, Table 1 (also included in Attachment F of this report),
and assuming a liner elevation of 5555.55 feet and approximately 39.66 acres of liquid area. It is
important to note that the calculation of the allowable flow rate per day is based on a maximum
head of 35 feet, since Table 1 does not specify a rate for 33 feet of head. For third quarter 2010,
a total of3,600 gallons were pumped.
9.2 Measurement of Weekly Wastewater Fluids in Cell4A
Weekly fluid elevations for Cell 4A are provided in Attachment A along with elevations for
Cells 1 and 3 and Roberts Pond. During the Quarter, the Mill operated and maintained
wastewater levels in Cell 4A to provide the minimum vertical freeboard as required by Part
LE.8(a)(4) of the Permit. See the discussion in Section 3 above.
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Ce1l4A slimes drain system at this time,
monthly recovery head tests and fluid level measurements are not required to be made at this
time pursuant to Part LE.8(b) of the Permit.
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10.0 SIGNATURE AND CERTIFICATION
This document was prepared by Denison on November 29,2010.
By:
David C Frydenlund
Vice President, Regulatory Affairs and Counsel
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the infl rmation submitted is, to the best of my knowledge and belief, true, accurate
and complete. I a aware that there are significant penalties for submitting false information,
includin t e pos ility of fine and imprisonment for knowing violations.
Da d C. Frydenlund
Vice President, Regulatory affairs and Counsel
Denison Mines (USA) Corp.
10
N:\Required Reports\DMT ReportslQ3 2010 DMT ReportlQ3 2010 DMT Report.docx
INDEX OF AITACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part I.G.3 of the Permit
C Monthly Cell 2 Slimes Drain Water level Over Time
D Graph of Cell 2 Slimes Drain Water Levels over Time
E Cell Liner Repair Reports and Notices
F Cell4A Leak Detection System Data for the Quarter
Attachment A
Tailings Cell and Roberts Pond Wastewater Elevations
Roberts
Date Cell 1 Cell 3 Cell4A Pond
7/2/2010 5613.65 5601.36 5586.66 5618.03
7/16/2010 5614.13 5601.86 5586.45 5618.50
7123/2010 5614.21 5602.76 5586.35 5618.37
7130/2010 5614.00 5603.10 5586.33 5618.42
8/6/2010 5614.22 5603.22 5586.45 5617.31
8/13/2010 5614.21 5603.24 5586.78 5618.09
8/20/2010 5613.81 5602.25 5587.53 5618.01
8/27/2010 5613.63 5602.86 5587.97 5617.63
9/3/2010 5613.26 5602.88 5588.33 5617.66
9/10/2010 5613.24 5604.62 5588.40 DRY
9/17/2010 5613.20 5604.44 5588.63 DRY
9124/2010 5613.36 5604.88 5588.68 5617.96
Attachment B
Notices Pursuant to Part 1.0.3 ofthe Permit
OENISOJ)~J
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August 4, 2010
VIA PDF AND EXPRESS DELIVERY
Rusty Lundberg, Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Dear Mr. Lundberg:
Denllon MIne. (USA) Corp.
1050 17th Str •• t, Suite 950
Denver, CO 80265
USA
Tel: 303 628·n98
Fax: [phone]
www.d.nlsonmln ••• com
Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa
Uranium MiII-Notice Pursuant to Part I.G.3 of the Permit and UAC R317-6-6.16(C)
Please take notice pursuant to Part I.G.3 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Pennit No. UGW370004 (the "Pennit") and Utah Administrative Code
("UAC") R313-6-6.16(C) that Denison Mines (USA) Corp. ("Denison"), as operator of the Mill
and holder of the Pelmit, failed to meet the discharge minimization technology ("DMT")
standards in Part I.D.2 of the Pennit, by allowing the wastewater elevation in the Mill's tailings
Cell 3 to exceed the freeboard limit for that Cell by approximately 7.2 inches, as described in
more detail below.
This exceedance was discovered at 1 :00 pm on Friday July 30,2010. Initial notice of this failure
to maintain DMT was given by telephone to the Utah Department of Environmental Quality
("UDEQ") by phone call to Mr. David Rupp at I :30 pm on August 2, 2010.
1. Facts and Background Information
a) Condition 10.3 of the Mill's State of Utah Radioactive Materials License No.
UT1900479 (the "License") provides that freeboard limits for Cells 1 and 3 shall be set
in accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures:
(i) The freeboard limits are set as per the January 10, 1990 Drainage Report for Cell
1 at a liquid maximum elevation of 5,615.4 feet above mean sea level ("finsl");
(ii) The fi'eeboard limit for Cell 3 is determined annually using a formula set out in
the procedure. The current fi'eeboard limit for Cell 3 was previously calculated
under this procedure at 5,601.6 finsl. However, in UDEQ correspondence dated
November 20, 2008 an interim variance and limit was established at 5,602.5 fmsl
for Cell 3;
(iii) In conjunction with the variance established under (ii) above, an interim
maximum elevation for Ce114A was also established at 5,593.74 finsl;
(iv) The maximum elevation of 5,593.74 fmsl for Cell 4A has been set assuming that
the total probable maximum precipitation ("PMP") volume for Cells 2, 3 and 4A
will be accommodated in Cell 4A. By letter dated December 11, 2008, Denison
applied for an amendment to the License to set the freeboard limit for Cell 4A at
5,593.74 fmsl and to eliminate the need to set a freeboard limit for Cell 3, given
that the freeboard limit of 5,593.74 fmsl for Cell 4A is adequate to accommodate
the total PMP volume for Cells 2, 3 and 4A; and
(v) In addition, Part 1.0.2 of the Permit provides that under no circumstances shall the
freeboard of any tailings cell be less than three feet, as measured from the top of
the flexible membrane liner ("FML"). The top of the FML in Cell 1 is at 5,618.5
finsl, and the top of the FML in Cell 3 is at 5,608.5 finsl. This means that Part
1.0.2 of the Permit provides a secondary requirement that the maximum
wastewater pool elevations in Cells 1 and 3 cannot exceed 5,615.5 and 5,605.5
finsl, respectively.
b) In a letter to Denison dated April 29, 2010, UDEQ has indicated their agreement with
Denison's position that the freeboard limit is not applicable to Cell 3, since Cell 3 is in
pre-closure stages, and the PMP flood volume of Cell 3 can be attributed to, and
managed in, Cell 4A. The April 29 letter indicated that to formalize this removal of
freeboard limit, Denison needed to provide revisions to two documents, specifically the
Discharge Minimization Technology ("DMT") Plan, and the Cell 4A Operations and
Maintenance ("O&M") Plan. The requested revisions to both the DMT Plan and O&M
Plan are being submitted with this notice.
c) During the weekly tailings survey measurement performed at approximately 1 :00 pm
on July 30, 2010, the wastewater pool elevation in Cell 3 was measured to be 5,603.10
2
finsl, compared to the current freeboard limit for Cell 3 of 5,602.50 finsl, representing
an exceedance of 0.6 feet, or 7.2 inches.
d) During the weekly tailings survey measurement performed on July 23, 2010, the
wastewater pool elevation in Cell 3 was measured to be 5,602.76 finsl, compared to the
current freeboard limit for Cell 3 of 5,602.50 finsl, representing an exceedance of 0.26
feet, or 3. 12 inches.
e) The July 23, 2010 elevation of Cell 3 was not reported to Denison's corporate
personnel until August 2,2010, (while corporate personnel were collecting information
regarding the exceedance on July 30). On August 2, 2010, Mill personnel advised
corporate personnel that the primary person responsible for the weekly tailings
inspection was on vacation on July 23,2010. The substitute personnel did perform the
inspection and record the results; however, no notification was given to Denver
Corporate personnel upon recording of the elevated liquid level.
f) It should be noted that the current freeboard limit in Cell 3 of 5,602.5 fmsl is 6 feet
below the top of the FML in Cell 3, so the exceedance of the current freeboard limit by
7.2 inches resulted in a wastewater pool elevation that was still over five feet below the
top of the FML and over two feet below the secondary freeboard limit of 5,605.5 feet
set out in Part 1.0.2 of the Permit. As a result, there was no risk of the wastewater in
Cell 3 overflowing over the top of the Cell 3 FML. Also, as mentioned above, since
the freeboard limit in Cell 4A has been set to accommodate the PMP event for Cells 2,
3, and 4A, there was also no risk that even if a PMP event were to occur there would
not have been adequate freeboard available in Cell 4A. The wastewater elevation
survey for Cell 4A performed on July 30, 2010 indicated a wastewater elevation 89
inches (7.4 feet) below the freeboard limit of 5,593.74 finsl for Ce114A.
g) The Mill has been running on a 10-days on and 4-days off operating cycle. The 4-days
off cycle resumed when the Mill shut down at 4:00 am on Saturday July 31, 2010.
h) As part of the plan to fill Cell 3 with tailings solids and to close Cell 3, the Mill has
been alternating between periods of pumping Cell 3 liquids into Cell 4A and
discharging CCD solids into Cell 3. The transfer pump from Cell 3 to Ce1l4A operates
for the duration of the 10 days that the Mill operates each run. The transfer pump was
operating on July 23 and July 30.
i) The intention was to discharge tailings solids into Cell 3 at a rate that, given the rate
solutions were being pumped from Cell 3 to Cell 4A, would not result in an
exceedence of the freeboard limit in Cell 3. Earlier in 2010, the Mill staff had replaced
aENlsoNI)A,~
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3
the existing pump in Cell 3 with a new pump to increase the flow rate of solutions fi'om
Cell 3 to Cell 4A during the liquid transfer cycle.
j) The Mill completed a cycle of removing liquids from Cell 3, and was in a cycle of
operating and discharging CCD solids into Cell 3 at the time of the exceedence.
k) Cell 3 was receiving only CCD solids and solutions from the Cell 2 slimes drain, and
Ce1l4A was receiving all other tailings liquids, at the time of the exceedence.
2. Action Taken
Upon receipt of the initial survey results, the Mill's Environmental Coordinator notified the Mill
Manager at I 1 :55am that day. The following plan of action was immediately put into place in
accordance with section 5.1 of the Mill's Contingency Plan:
a) The transfer pump from Cell 3 to Cell 4A has been on and remains on in an effort to
reduce the liquid level;
b) Verbal notification was given to Mr. David Rupp ofUDEQ at 1:30 pm on August 2,
2010. The verbal notification was not given within 24 hours after discovery of the
event, due to a miscommunication resulting in the failure of Denver staff to file the
notification within that time period. This verbal notiiication was followed by this
written notification within five days of discovery;
c) Solutions continued to be pumped from Cell 3 to Cell 4A in order to reduce the
solution in Cell 3;
d) Compliance will be achieved during the week of August 2,2010. Solutions continue to
be pumped from Cell 3 to Cell 4A to continue the reduction in the Cell 3 liquid level;
and
e) The Mill staff has been advised that required notifications need to occur even in the
absence of primary environmental personnel, and backup staff are to be trained to
contact corporate staff with timely notification oflevel exceedances.
3. Root Cause
The root cause analysis is as follows
4
IlENISONl)i
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a) The Mill has been alternating between continually pumping Cell 3 liquids into Cell 4A,
while discharging CCO solids into Cell 3 during the Mill's operating periods.
b) Cell 3 was receiving only CCD solids, and Cell 4A was receiving all tailings liquids at
the time of the exceedence. The Mill continues to pump solutions from Cell 3 to Cell
4A before and while solids are introduced into Cell 3, in an effort to maintain the
solution level in Cell 3 below the freeboard limit during this process.
c) As a result of following the planned program of filling Cell 3 for closure, the remaining
pond area in Cell 3 is small, approximately 7 to 10 acres, and is continually being
reduced by the planned expansion of the solids beach as Cell 3 approaches its final
tailings capacity.
d) As a result of the decreasing pond area, the ability to manage the freeboard level has
become increasingly difficult.
e) Mill personnel received a copy of the April 29, 2010 letter from UDEQ which agreed
with the need to remove the freeboard limit tl'om Cell 3 to allow filling and closure,
and which identified plan documents that should be updated to reflect this change.
f) Mill personnel were under the mistaken impression, as a result of the April 29, 2010
UDEQ letter, that the freeboard notification requirements for Cell 3 had been relaxed
and instantaneous reporting of liquid levels was no longer required.
g) Upon review of the circumstances, after the discovery of the exceedance, it is again
evident that it is no longer possible to manage the Cell 3 freeboard to achieve the
calculated freeboard limit during the final stages of filling Cell 3 with solids and
closing Cell 3. The exceedence occurred despite the fact that monitoring and surveying
were perfonned at the required frequency, all pumping equipment was operating
properly, and the liquid transfer from Cell 3 to Cell 4A was occurring as planned.
4. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following actions will be taken to prevent a reoccun-ence of this incident:
a) The Mill will continue to pump liquids from Cell 3 to Cell 4A, in preparation for
dewatering and closure of Cell 3; and
b) Denison has completed and submitted with this notice draft revisions to the documents
identified in UDEQ's April 19,2010 letter, to document the elimination of freeboard
5
OENISONI)~ I~
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limits for Cell 3.
5. Affirmative Defense
Denison believes that the affirmative defense in Pmt LG.3.c) of the Permit should be applicable
to this incident, for the following reasons:
a) Notification
By viltue of the initial oral notification given to the UDEQ Duty Officer at I :30 pm on August 2,
2010, and this written notice, Denison has submitted notification according to UAC R317-6-
6.13. The oral notification exceeded the 24 hour requirement, but Denison submits that
substantial compliance with the notification requirements have been met in the circumstances,
given that Cell 3 freeboard limit is a matter that is currently under discussion between Denison
and UDEQ.
b) Failure was not Intentional or Caused by the Petmittee's Negligence
The exceedance of the freeboard limit was not intentional or caused by Denison's negligence,
either in action or in failure to act. The Mill was taking actions to manage the freeboard
requirements of all of its active tailings cells while filling Cell 3 to its final tailings solids
capacity in preparation for closure. Based on a survey of the wastewater elevation in Cell 3 taken
the week of Friday July 16, it appeared that there was ample freeboard in Cell 3, and, based on
past Mill experience it was not unreasonable for Mill staff to come to that conclusion. The fact
that the water level in Cell 3 increased at an unexpectedly fast rate was due to the planned
discharge of CCD solids into Cell 3 coupled with the issue of managing liquids in a pool of
decreasing size as the solids fill the cell. This discharge, and the pool's size reduction, are
necessary to complete the filling and closure of the Cell.
c) The Permittee has Taken Adequate Measures to Meet Petmit Conditions
Denison has taken adequate measures to meet Permit conditions in a timely manner. The
provisions of the Mill's Contingency Plan are being implemented at the time of this notice.
d) The Provisions of UCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated. There has been no discharge of a
pollutant into waters of the state. Denison has not caused pollution which constitutes a menace
to public health and welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic,
OENISONI)~ :l,J
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6
agricultural, industrial, recreational, or other beneficial uses of water, nor has Denison placed or
caused to be placed any waste in a location where there is probable cause to believe it will cause
pollution.
There was no discharge of solutions from the Mill's tailings impoundments, and there was ample
freeboard in Cell 4A to accommodate the PMP for Cells 2, 3, and 4A.
Please contact the undersigned if you have any questions or require any further information.
Yours truly,
~~
JoAnn Tischler
Director, Compliance and Permitting
cc: Rich Bartlett
David C, Frydenlund
Ron F. Hochstein
Ryan Palmer
Harold R. Roberts
David E. Turk
f)ENISOJ)~ ~
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7
Attachment C
Monthly Cell 2 Slimes Drain Water level Over Time
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 7/26/10-8/2/10
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
7/26/2010 7/27/2010 7/28/2010 7/29/2010 7/30/2010 8/1/2010 8/2/2010
600
700 16.09 14.19 13.16 12.32 10.74
800 23.95 15.99 14.15 13.13 12.30 10.74
900 23.18 15.90 14.10 13.10 12.28 10.74
1000 22.25 15.82 14.05 13.05 12.24
1100 21.61 15.64 14.00 13.01 12.22
1200 20.99 15.53 13.95 12.98 12.21
1300 20.55 15.42 13.89 12.94 12.14
1400 20.13 15.32 13.83 12.86 12.10
1500 19.79 15.24 13.77 12.82 12.05
1600 10.94
10.74
Comments: Report number that will be used is 10.74
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 8/25/2010
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
8/25/2010 8/26/2010 8/27/2010 8/28/2010 8/29/2010 8/30/2010 8/31/2010 9/1/2010
600
700 15.85 13.92 11.46 11.08 10.65
800 15.75 13.88 11.43 11.06 10.65
900 21.85 15.61 13.83 11.42 11.05 10.65
1000 21.40 15.50 13.77 11.40 11.04
1100 20.96 15.44 13.70 11.38 11.03
1200 20.38 15.34 13.62 11.36 11.00
1300 19.97 15.25 13.58 11.32 10.97
1400 19.58 15.15 13.52 11.29 10.95
1500 19.23 15.04 13.45 11.56 11.25 10.93
1600
10.65
Comments: Slimes Drain was started a little late on the 25th of August. The full test was
completed on September 1st 2010. the report number is 10.65 for this, August 2010.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 9/24/2010
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
9/20/2010 9/21/2010 9/22/2010 9/23/2010 9/24/2010
600
700 15.35 13.07 11.99 11.50
800 25.95 15.20 13.00 11.98 11.50
900 23.78 ·15.06 12.95 11.97 11.50
1000 23.22 14.90 12.90 11.96
1100 22.30 14.77 12.85 11.94
1200 21.48 14.65 12.79 11.92
1300 20.67 14.52 12.73 11.89
1400 20.32 14.40 12.67 11.87
1500 19.75 14.28 12.61 11.84
1600
Comments: Report number that will be used is 11.50
Attachment D
Graph of Cell 2 Slimes Drain Water Levels over Time
n It)
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(I' --0
3
It) en
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Dl
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RO
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~ o
til ro ..,
iii' III I-'
c:
:J ro Ql ..,
VI ro ..,
~'
.!::
I-' O'l I-' .j:> I-' N
Feet Below Top of Standpipe
I-' o 00 O'l .j:> N o
I " I 1-1/30/2009
2/20/2009
3/13/2009
4/3/2009
4/24/2009
5/15/2009
6/5/2009
6/26/2009
7/17/2009
8/7/2009
-8/28/2009
9/18/2009
10/9/2009
10/30/2009
11/20/2009
12/11/2009
1/1/2010
1/22/2010
2/12/2010
3/5/2010
3/26/2010
4/16/2010
5/7/2010
5/28/2010
6/18/2010
7/9/2010
7/30/2010
8/20/2010
9/10/2010
Attachment E
Cell Liner Repair Reports and Notices
This Attachment was intentionally left blank. There were no Cell liner repair notices submitted during
this reporting period.
Attachment F
Ce1l4A Leak Detection System Data for the Quarter
Cell 4A lOS Monitoring Information
July 2010
Date
7/9/2010
7/16/2010
7/23/2010
7/30/2010
Measurements in Inches
9.0
9.7
0.8
1.3
Flow Meter in Gallons
257250
257250
260731
260731
Highest level for the month was 9.7 inches. Total number of gallons pumped was 3,481.
August 2010
Date
8/6/2010
8/13/2010
8/20/2010
8/27/2010
Measurements in Inches
0.0
0.0
1.0
0.5
Flow Meter in Gallons
260850
260850
260850
260850
Highest level for the month was 1.0 inches. Total number of gallons pumped was 119.
September 2010
Date
9/3/2010
9/10/2010
9/17/2010
9/24/2010
10/1/2010
Measurements in Inches
1.1
2.2
2.1
3.9
3.0
Flow Meter in Gallons
260850
260850
260850
260850
260850
Highest level for the month was 3.9 inches. Total number of gallons pumped was O.
!
1 .
I
I.
Table 1
calculated Action Leakage Rates
for VarIous Head Conditions
Cell 4A White Mesa Mill
Blanding. 4tah
Head Above Liner Calculated Action Leakage
System (feet) Rate (gallons/acre/dav)
6 222.04
10 314.01
16 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
GeoSyntec Consultants
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