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Home My WebLink AboutDRC-2011-007296 - 0901a06880268640State of Utah GARY R. HERBERT Governor GREG BELL Lieutenant Governor Departmentof Environmental Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director August 31, 2011 CERTIFIED MAIL (Return Receipt Requested) Ms. Jo Ann Tischler Director, Compliance and Permitting Denison Mines (USA) Corp. (DUSA) 1050 l?"^ Street, Suite 950 Denver, CO 80265 Dear Ms. Tischler: SUBJECT: May 31, 2011 White Mesa Mill Discharge Minimization Technology (DMT) Performance Standard Monitoring Report (DMT Report), and Cell 4A BAT Performance Standards Monitoring Report (Cell 4A BAT Report) for the 1st Quarter, 2011, Submitted as a Single Volume, Findings and Closeout Letter We received the subject combined DMT and Cell 4A BAT Reports for the Quarter, 2011, dated May 31, 2011. These two reports were submitted as a combined single bound volume under one title, as described in the subject block above. An electronic copy of the volume was also submitted on compact disk. We have reviewed this information, and recognize the following items: 1. Weekly tailings wastewater pool elevations for Cell 4B were not taken during the l^VQuarter of 2011. This deficiency was reported by DUSA in a letter to DRC dated June 6, 2011. This will be addressed by DRC outside this report review, under separate cover. 2. In Section 3.0 of the subject volume, in the sixth and last paragraphs, water surface measurements for Cell 4A are discussed. These paragraphs reference the DRC letter of March 15, 2011. While it is correct that water surface measurements for Cell 3 are no longer required by the latest DMT and BAT O&M Plans, weekly water surface measurements for Cell 4A are still required by the plans (See DMT Plan, Section 3. l.d and BAT O&M Plan p. 12, paragraph under "Solution Elevation"). Measurements for Cell 4A are necessary to determine the allowable leakage for Cell 4A during each quarter. The last sentences, in both the sixth and last paragraph of Section 3.0, need to be corrected. They should state that water level elevation survey measurements for Cell 4A still need to be conducted, rather than the current that elevation survey measurements in Cell 4A are no longer required dr conducted. These statements in these paragraphs must be corrected in the upcoming 2011 2"^ Quarter Report. 3. In Attachment "A" of the subject volume, a table titled. Tailings Pond Elevations, 1^^ Quarter 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O Box 144850'Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801) 533-4097 • T.D.D. (801) 536-4414 www.dcq.utah.gov Printed on 100% riecycled paper Page 2 Elevations 2011 is provided. In the column underlined "Cell 4A," no solution elevations are provided for the weeks of 3/11/2011 through 4/1/2011, and the verbiage, "No Longer Required" is shown. These readings must be reinstated, and the "No Longer Required" verbiage removed from the table, in the upcoming 2011 2""^ Quarter Report. 4. In section 6.0 of the report, it is noted that during the week of March 20, 2011 the road grader hit 4 drums of KF Altemate Feed that is stored in steel drums on the Ore Pad. The four drums^ were placed in steel over-pack drums and placed back into the stockpile. 5. Section 7.0 of the report discusses liner repairs underway for the Cell 1 liner, as a result of discovery of leakage in the Cell 1 Leak Detection System (LDS) on June 2, 2010 and later on August 7, 2010. As approved in a DRC Confirmatory Action Letter (CAL) dated September 22, 2010, DUSA has committed to complete repair of these leaks by July 31, 2012, and submittal of the required repair report by December 1, 2012. 6. No leakage is noted each week of the 1^^ Quarter in the LDS inspections for the New Decontamination Pad (NDP) Sedimentation Tank at the mill. The report notes that repairs to observed cracks in the pad were completed, although the cracks were less than 1/8-inch in width. DRC authorized use of the NDP on February 1, 2011. 7. LDS Monitoring. Section 9.1 of the subject report states that during the quarter there were no failures of any LDS pumping or monitoring equipment not made operational within 24-hours of discovery. However for reference, by letter dated July 6, 2011 DUSA informed DRC that the Cell 4A LDS electronic log has had a period of non-operation from June 3, 2011 through June 27, 2011. This will be addressed by DRC outside this report review, under separate cover. Cell 4A had a total collected leakage for the quarter of 3,160 gallons, compared to allowable leakage of 23,955 gallons per day. The allowable leakage rate for Cell 4B was 460.8 gallons per acre-day (based on the table in the BAT O&M Plan) or 18,432 gallons per day for 40 acres, with the maximum height of water in the cell at 5581.10 fmsl as measured May 31, 2011. New Cell 4B had a total collected leakage and collected condensate volume of 310,433 gallons or 4,927 gallons per day for the 63 days the cell was in operation. The leakage rate in Cell 4B was well below the maximum limit. We have no further comments on the subject volume. Therefore our review of this item is hereby closed- out. If you have any questions regarding the above, please contact Mr. Dave Rupp of my staff. UTAH WATER QUALITY BOARD RustyLundberg Co-Executive Secretary DAR:dr Cc: Phillip Goble, DRC F:\drupp\DUSA\GWDPrelateddocs\DMTV2011 1st Qtr Findings & Closeout Letter.doc 2010 4th Qtr Report Reference: DRC-2011-002214 cr cr ru •r a a.I o a CT O a p- CEBTiFIED MAIL n RECEIPT ./f .'lV VDo/nesf/c-Wa// Of,V;Wdc/nsora^ncfCoverage,ProWderfi -.For delivery information visit\our website^at vyww.usps.comi^ ^ OFFICIAL ll c c %S# & Postage $ Certified Fee RE: 8/31/11; 5/31/11 findings closeout / DR Jo Ann Tischler Denison Mines (USA) Corp 1050 Seventeenth ST, STE 950 Denver, Co 80265 .;R& FoVnt'^afOOaAeigust 2006 ; SeeiReverseTor^liistruetioris^