DRC-2011-007339 - 0901a0688026affd

September s, 2011
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Te!: 303 628-7798
Fax:[phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Executive Secretary, Utah Radiation Control Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Utah Division of Radiation Control ("DRC") May 10, 2011 Revised Confirmatory Action Letter, July
12, 2011 Conditional Approval Letter, and Denison Mines (USA) Corp. ("Denison") June 1, 2011
Response Regarding Cell 1 Inspection and Repairs.
Dear Mr. Lundberg:
This letter responds to DRC's May 10, 2011 Revised Confirmatory Action Letter and July 12, 2011
Conditional Approval Letter, and is a follow-up to Denison's June 1, 2011 letter regarding Cell 1 and Cell 3
Leak Detection system ("LDS") Repairs. This letter addresses the completion of the items in the Plan and
Schedule submitted by Denison on June 1, 2011 and conditions identified by DRC in the Conditional Approval
Letter of July 12, 2011, as enumerated below. The conditions stated by DRG are provided in italics, below,
followed by Denison's confirmatory response in regular type.
Confirmation of Conditions in Julv 12. 2011 Conditional Approval Letter
1. The proposed Cell 3 LDS standpipe design extension shall be constructed to allow a video log to be
performed to the bottom of the standpipe where liquids may collect.
Denison's Response:
The Cell 3 standpipe extension has been installed to allow a video-log to be performed to the bottom of the
LDS Drisco standpipe. The bottom of the LDS Drisco standpipe ties into the cell's under-drain system
through the elbow and reducer connections shown in Attachment 1. The Cell 3 standpipe installation allows
insertion of a camera probe to the bottom of the LDS Drisco standpipe where it ties into the cell's underdrain
system at the first 90 degree elbow.
2. The installation and reconfiguration of the Cell 1 and Cell 3 LDS monitoring upgrade will be completed
within 45 days of your receipt of this letter.
N:\Cell 1 and 3 LDS\Cell 1 and 3 LDS response 09.08.11\09.08.11 response to 05.10.11 letter Cell 1 Inspection and
Repairs.doc
Letter to Mr. Rusty Lundberg
September 8, 2011
Page 2
Denison's Response:
Denison committed in the May 31, 2011 letter to have the installation of upgrades to the Cell 1 and 3 LDS
completed within 45 days of our receipt of DRC's approval of this plan. DRC approved the May 31 plan in a
Conditional Approval Letter dated July 12, 2011 which Denison received on July 15, 2011. Upgrades on both
Cell 1 and Cell 3 were completed and placed into service on July 13, 2011. DRC confirmed on September 1,
2011 that they have observed the new system during an on-site inspection on Monday, August 29, 2011.
3. DUSA will submit pictures documenting the Tailings Cell 3 standpipe extension and the new upgraded
LDS monitoring equipment for both Tailings Cells 1 and 3 standpipe covers.
Denison's Response:
The Cell t and 3 LDS installation has upgraded each of these LDSs to systems equivalent to the LDS systems
already in place on Cells 4A and 4B. Systems for both of these cells were placed into service on July 13, 2011.
Denison has installed the following on each of Cells 1 and 3:
1) A "Y" split to simultaneously accommodate monitoring, pumping and, when required, camera
inspection and cleanout. Each Y has been installed in a manner that maintains clearance on the
cell dike roadway for vehicle access.
2) A liquid level transducer wired to output to an alarm light, which alarms when the transducer
detects a pressure of 24 inches of water head.
3) An Environmental Pump Solutions 25 gpm pump, Model 25S, which is set to cycle on automatically
when the transducer, set at the bottom of the pump, detects a pressure of 18 inches of water head.
This minimum head level prevents damage to the pump motor by ensuring that the pump is fully
submerged when the pump motor turns on. The pump turns off automatically when the fluid .level
breaks vacuum; that is, the pump will not operate if dry or not submerged.
4) A field panel with alarm light triggered by the transducer.
Photographs of the installed equipment for both cells are provided in Attachment 2. Pump specifications are
provided in Attachment 3 (refer to Figure A, not Figure B, in Attachment 3).
Based on the equipment design information and specifications described above, Denison recommends that the
draft Radioactive Materials License Condition 11.3, currently under discussion between DRG and Denison, be
revised. Denison's proposed revised language and allowable LDS standpipe levels for Cells 1 and 3 are
provided in Attachment 4.
Denison is currently planning comparable modifications to the existing system on the Cell 2 LDS. The Cell 2
LDS has a cover; the current cover was installed in 2009. A photograph of the cover is provided in Attachment
5. Denison proposes to complete installation on the Cell 2 LDS of a comparable transducer and automated
pump system as are in place on Cells 1 and 3, within 90 days of approval of this status letter. Proposed
language for License Condition 11.3 addressing Cell 2 is included in the redline draft in Attachment 4 to this
letter.
MINES
Letter to Mr. Rusty Lundberg
September 8, 2011
Page 3
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISON^jJ / MINES
Attachment 1
^ i^^-^-j L.-.„.J r.:.. .J I- J rl^ .J
Cell 3 - Underdrain System; Final Piping Tie-m and Rock
Stabilization
Attachment 2
Cell #1 newly installed "Y" with
SMI,.... ...
Cell #1 side view of newly installed
"Y" with dedicated Dump and hose
Cell #1 LDS Control Panel
Cell #3 newly installed "Y" with
dedicated pump and hose
Cell #3 side view of newly installed
''Y" with dedicated pump and hose
Cell #3 Roadway to LDS
Attachment 3
'Aug 26 08 01:07p Environmental Pump 7249382725 P-3
MODEL 255 25 GPAA TECHNICAL DATA
DIMENSIONS AND WEIGHTS
mroB PISCH. DfMiNSlONS m 8NCKES APPROX.
MODE!. NO. HP SIZE A e e 0 E smpwT.
msmmimm A ^ > 1/2 - .4* 11/2" NPT mmm 3.8 3*9 26
25807-5 A 3/4 4^ 1 1i2- NPI 10.7 10.2 3.8 3.9 28
25S10-7 A 1 4" 1 ^2" NPT 23.7 11.8 11.9 3.8 3.9 29
25S15-9 A 1 1/2 4" 1 1/2" NFl 27.1 13.6 13.5 3.8 3.9 34.
25S20-11 A 2 4" 1 1^2^ NPI 30.3 15.1 15,2 3.8 3.9 37
25S30'15 A 3 t 1/2" NPT 39.1 20.8 las 3.8 3.9 59
25S50-26 A 5 1 1/2" NPT 51.2 23.6 27.6 3.8 3,9 76
25S7&.39DS A 7 1/2 1 1/2" NPT 66.8 24.2 42.6 5.4 4.6 168
258100-5208" B 10 1 1^2" MP! 90.9 25.4 66^ 5.4 5.4 226
NOTES: All models suitable for use in 4* wells, unless otherwise sioted
Weights incltKJe pump end with motor in lbs.
" BuHl into s?««ve 1 hY ft/3PT discharge, 6" nsn. well dia.
A C
MATERIALS OF CONSTRUCTION
NOTES: Spedficatjons ar<3 subject to chair^ge v^thout notice.
VaiQx® is a foggstered trademaHk of Gervesal Becirte Co.
\fectra® is a registered trademark of Hoechast CaTanese Corposratfon.
RyBon® 95 a registered ti^demailc of PWSilps 66.
If using 4* rwn-sfcamtarell motors, refer to 329.'420/43i Stalnfess Steel A coypjing key Is not required.
e
r-l'
Fig, B
SPL2MED SHAFT I3-.28 Bttfs4 CYUMDRICAL SHAFT (39 Stss=) DEgPSET(S2Stas|
Clieck Valve Housing 304 Siainiess Steel 304 Stainless Steel 304 Stainless Steel
Check Valve 304 stainless Steel 304 Statniess Steel 304 Stainless Steel
Diffuser Chamber 304 Stainless SteeS 304 Stainless Steel 304 Stainless Steel
impeller 304 Stainless Stee! 304 StaNess Steet 304 Stainless Steel
Suction Jnterconnector 304 Stainless Sleel 304 Sls^nless Steel 304 Stainless Steel
inlet Scieen 304 Stainless Steel 304 Stainless Seeel 304 Stainless Steel
Punnp Shaft 304 Stainless Steel 431 Stainless Steel 43r Stainless Steel
Straps 304 Stainless Steel 304 Statniess Steel 304 Stainless Steel
Cable Guard 304 Stainless Steel 304 Stainless Steel 304 Stainless Steel
Priniiffug Iriducer 304 Stainless Steel 304 Stainless Steel 304 Stainless Steel
Coupling 316/431 Sla^ntess Steel 316/431 Stainless Sleel 329/416 Stainless Steei"^
Check Valve Seat M8R/304StainJess Steel NBR/316 Stainless Steel NBR/316 Stainless Steel
Top Beaffng mR N3R/3i6 StalnSess Steel |HBR/316 Stainless SteeJ
Impeller SeaJ Rln^ NBR/P8T (Valox®) NBR/PPS {Ryton€)) NBR/PPS fRyton®)
InJefmediate Bearirt^s N8R 304 Stainless Steel NBR/316 Stainless Steel
ShafiWasher Not Required LCP^Vectra®) LCP (Vec5tna€>)
Split Cone . NolRecrulfed 304 StainSess Steel 304 Staintess Steel
Split Cone Nut J^ot^egufrecf 316 Stdifiless Sleel 304 Slainfess Steel
Sleeve Not Reqttlr&d Mot RequSreid 316 Stainless Stee!
Sleeve FSanqe Not Raqytred Not Required 304 Stainless Steel
Coupiiftg Key Not Requingd Not Requfred 302/304 Stainless Steel**
for cQwpging.
Aug 06'08 01:07p tnvlronmental Pump 7249382725 p.2
PERFORMANCE CURVES 25 GPM MODEL 25S
FLOW RANGE: 18 -32 GPM
1600
OUTLET SIZE: IVa "NPT NOMINAL DIA. 4"
10 15 20
CAPACITY (GPM)
SP£ClFllC«riONS SUBJECT TO CHANGE WITHOUT NOHCE. 4" fc«OTOR STANDAHD, .5 -5 HP/34SQ BPM. 6" MOIOR STAWCMH&75 -10HPW50 RPM.
Performastce conforms to ISO 9906.1999 (E) Anim A
Minimum submergance li Z fast.
Attachment 4
11.3 The licensee shall implement a monitoring program of the leak detection systems for disposal
Cells 4A and 4B in accordance with requirements of the Permit. The licensee shall also
implement an operation, maintenance, and monitoring program of the leak detection systems for
disposal Cells 1, 2, and 3 as follows:
A. The licensee shall maintain all leak detection system piping, including any access pipes,
open, fully functional and free of soil, debris or detritus. All access pipes shall be
capped to prevent inflow of rainwater, soil, debris, or detritus when not in use for
monitoring or pumping. The licensee shall conduct annual video logs of said access
pipes to demonstrate the physical condition of the system. In the event that the licensee
determines any access pipe is blocked, partially blocked, or otherwise not fully
functional, the licensee shall: 1) remove all blockages within 72-hours 14 calendar
days of discovery, and 2) submit a written report for Executive Secretary approval
within 530-calendar days of discovery.
The licensee shall measure and record the ''depthto fiuid''inches of water pressure head
on the pump transducer in each of the tailings disposal cell standpipes on a weekly basis
in a manner approved by the Executive Secretary. The transducer and pump will be
placed as low as reasonablv practical in the standpipe as approved by the Executive
Secretary. The svstem will be set such that that the alarm will be triggered when the
transducer senses a pressure of 24 inches of water head or greater, and the pump will
turn on when the transducer senses a pressure of 18 inches of water head or greater. If
afty-fluid is present in the leak detection system (LDS) of any cell above a transducer
pressure of 24 inches of water head, the licensee shall:
1. Pump the fluid from the LDS within 2 calendar days -of discovery, to- a transducer
pressure of 24 inches of water head or less.the depth or dcvatien approved by the
Executive-Secretary, as shown in Table 1 below.
Table!
LDS Standpipe
€elt4
TBB
TB©
2. Immediately commence and continue daily monitoring of LDS i
aed record LPS fluid depth, elevattonpressure head on the transducer, and
volumes removed, until otherwise approved by the Executive Secretary.
3. Maintain the LDS fluid elevation at or below the-depth-er-elevatiee^^
Table 1 afeevea transducer pressure of 24 inches of water head.
4. Return any LDS fluid pumped to an approved disposal cell.
DRC-04
Page 2 of2
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
License #UT1900479
Amendment #5
C. Failure to maintain the LDS fluid level elevation pursuant to License Condition
11.3(B)(31), above, shall constitute a violation of this License. Immediately upon
determination of said failure, the Licensee shall:
(1) Evaluate the root cause of the liner distressfailure and take appropriate and
timely actions to mitigate the leak-failure and any consequent potential impacts;
(2) Continue to measure and record LDS ''depth to fluid'\ elevationpressure head on
the transducer, and removed volume measurements daily until otherwise
approved by the Executive Secretary; and
(3) Notify the Executive Secretary by telephone within 48 hours, in accordance with
License Condition 9.2, and submit a written report, for Executive Secretary
approval, within 30 calendar days of said telephone notice, in accordance with
License Condition 9.2. The written report shall include a description of the
mitigative action(s) taken and a discussion of the mitigative action results. In
the event that mitigative actions have yet to be taken, the written report will
include a detailed workplan and schedule.
D. In addition to the reporting required in License Condition 11.3(A), (B), and (CD), all
sampling, analysis, and evaluation of LDS fluids shall be documented and all records
retained onsite until license termination for Executive Secretary inspection.
[Applicable UDRC Amendment 3] [Applicable UDRC Amendment: 4]
[Applicable UDRC Amendment: 5 Renewal]
Attachments
Cell #2 LDS Standpipe Cover