DRC-2011-007284 - 0901a0688026731a

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DENEOJ,/
MINES
- L\,J E! .L
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Oenver, CO 80265
USA
Tel : [phone]
Fax : [phone]
www.denisonmines.com
August 3I,20Il
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
Salt Lake city, uT 84114-4820
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A and
Cell 4B BAT Performance Standards Monitoring Report for the 2nd Quarter of 2011
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
44 and Cell 48 BAT Perforrnance Standards Monitoring Report for the 2nd Quarter of 2011, as
required under Parts I.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.
Please note that DUSA received your Draft Ql 2011 DMT Report, Findings and Closeout letter,
dated August 31, 2011, and that the text of the Q2 2011 DMT Report has been changed as
requested pursuant to the aforementioned letter.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
Jo Ann Tischler
Director, Compliance and Permitting
cc David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Kathy Weinel
Yours very truly,
DBNrsoN Mrxss (USA) ConP.
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A and
CELL 48 BAT PERFORMANCE STANDARDS MONITORING REPORT
2"d Quarter
April through June
2011
State of Utah
Groundwater Discharge Permit No. UGW37O0O4
Prepared By:
Denison Mines (USA) Corp.
1050 17th Sreet, Suite 950
Denver, CO. 80265
August 3l,20Il
1.0
2.0
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3.0
4.0
4.1
4.2
4.3
4.4
5.0
6.0
7.0
8.0
8.1
8.2
8.3
9.0
TABLE OF CONTENTS
INTRODUCTION......
MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER ...................1
WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING...................2
MONTHLY SLIMES DRAIN WATER LEVEL MONITORING............. ............4
GBNmRRT- .....................4
RESULTS FoR THE Quenrrn ..........5
Quar-trv AssuRANCE EvALUAToN AND Dare VALIDATIoN................ ..................5
Gnapurc CoupRRrsoN To PREvIous YEAR.... ...............,....6
WEEKLY WASTEWATBR LEVEL MONITORING: ROBERTS POND ..........6
WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS OF
FEBDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE AREA..6
TAILTNGS CELLS AND POND LINER SYSTEM REPAIRS. ..........6
DECONTAMINATION PADS
SuvuaRv oF WEEKLy INSPECTIoNS ................ ..................7
ANNUAL INSpECTToN op ExIsnNc DECoNTAMINATIoN PAD............ .......................8
ANuual INSpECTIoN oF NEw DECoNTAMINATIoN Plo............ ............9
CELL 4A AND CELL 48 BAT PERFORMANCE STANDARDS REPORT FOR THE
QUARTER
9.1 LDS MoNrroRrNG........... ...............9
9.1.t Operational Status of LDS Pumping and Monitoring Equipment.............. ............9
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary Membrane .........10
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS .. ........ I0
9.2 MEASUREMENT oF Weeru-v WASTEwATER FLUIDS tN CBt-t- 48.............. ..............1 I
9.3 SLTMES DRen RecoveRv HEAD MoNtronING ................ ..................-12
1O.O ANNUAL SLIMES DRAIN RECOVBRY HEAD REPORT FOR THE CALENDAR YEAR
2011
11.0 SIGNATURE AND CERTIFICATION................13
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I LIsr oF TABLES
Table 1 - Summary of Waste Water Pool Elevations
I Table 2 - New Decontamination Pad Inspection Portal lrvel for the Second Quarter 2011
ATTACHMENTS
r A Tailings Cell and Roberts Pond Wastewater Elevations
I B Notices Pursuant to Part I.G.3 of the GWDP
C Monthly Cell2 Slimes Drain Monitoring Data
t D Graph of Cell2 Slimes Drain Water Levels Over Timer E Cell Liner Repair Reports and Notices
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;;l,Jilrd
Cell48 Leak Detection System Data for the Quarter and BAr o&M Plan
G Annual lnspection Forms for Existing and New Decontamination Pads (Put I.F.12)
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WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE 2nd QUARTER OF 2011
INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Performance Standards
Monitoring Report for the 2nd quarter of 2oll (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 "GWDP"), and the Routine
Cell44 and Cell48 Best Available Technology ("BAT") Performance Standards Monitoring
Reports for the Quarter, as required under Part I.F.3 of the GWDP.
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 LD.3, I.8.7 , and I.F.l 1 of the GWDP:
o Weekly tailings wastewater pool elevations for tailings Cells I and 3 (Part
I.E.7(a));
o Monthly slimes drain water levels in Cell 2 (PNII'D.3(bX1) and (2))t;
o Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.11);
o Weekly wastewater level measurements in Roberts Pond (Part I.D.3(e) and Part
I.E.7(c));
o Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(0 and Parts I.E.7(d) and
(e));
o Any tailings cell and pond liner system repairs (Part I.E.7 (0 and Part I.E.(8)(c));
o Weekly New Decontamination Pad [nspection (Part I.E.7 (g)) and
o Annual Decontamination Pad Concrete Inspection (Part I.F.11) (not required this
reporting period)
Also during the Quarter, the following Cell 4,{ and 48 BAT perforrnance standards monitoring
was performed, or addressed, as applicable and as required by Parts I.E.8 and l.E.I2 of the
GWDP:
tThe GWDP, dated July 14, 2011, Part I.D.3 (bX2) states "effective July I1,201l, the Permittee shall conduct a
quarterly slimes drain recovery test...". Weekly testing was conducted during the second quarter. The frequency
change dictated by the GWDP was implemented in the third quarter 201 l.
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o Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.8.(a)) and Cell
4B (Part l.E.lz (a)); and
o Weekly tailings wastewater pool elevations for tailings Cell 4,{ (Part LE.S (a))
and Cell48 (Part I.E.12 (a)).
WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in Tailings Cells
during the second quarter 2011 except as noted below, 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"). The results of such monitoring, reported as
,/ feet above mean sea level (fmsl), are included in Attachment A. All cells met the maximum' wastewater criteria in License Condition 10.3 throughout the period.
The requirements to maintain a minimum freeboard in Cell 3 and Cell4,{ were removed by the
Executive Secretary of the State of Utah Radiation Control Board (the "Executive Secretary")
, during the first quarter 2011 as detailed below. It is important to note that wastewater pool/ elevation surveys were not conducted for Cell 48 until the week of May 27,201'1, because the
fluid levels were too low to measure; that is, below the level at which the survey can be
conducted from the bank of Cell 48.
Cell 48 is a new cell authorized for use by the Executive Secretary on January 27 ,2011. Cell 48
has received fluids since that time but its total solution volume has remained at a very low level
/1tess than 24 feet of solution or more than 13 feet of freeboard) through June 2011. The
solutions levels during this period were too low to be measured by either a) the survey method
from the top of the cell dike as authorized in the approved DMT Plan or the alternative method
of measuring by tape along the sidewall. By May 2011, the solution level could be reached by a
technician climbing down along the sidewall with a measuring tape, but could not be surveyed
from the top of the cell dike. The DUSA notice regarding the safety issues associated with
measuring the Cell48 fluid levels, submitted to DRC on June 6,2011 is included in Attachment
B.
As discussed above, fluid level measurements were initiated the week of May 27,2011 by tape
measure. The following week, maintenance was in the process of constructing a platform and
, walkway to provide a safer access to the location along the Cell 48 side-slope where
/ measurements were to be taken, so that survey measurements could be initiated. As a result of
construction at that location, measurements were not possible during the week of June 3,20ll.
Measurements resumed the week of June 10, 20t1, and have continued unintemrpted since that
time.
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 Cell I at a liquid maximum elevation of 5,615.4 fmsl.
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Condition 10.3 of the License also provides that the freeboard limit for Cells 3,4A and 48 shall
be recalculated annually in accordance with the procedures approved by the Executive Secretary.
A letter from the Executive Secretary dated January 27 ,2011 which approved the use of Cell 4B
and a subsequent letter dated March 14,2011, stated that authorization of the use of Cell 48 and
approval of the DMT and Cell 44 Operations and Maintenance ("O&M") Plans effectively
eliminated the former freeboard elevation requirements for tailings Cell 3. The approvals of the
DMT and Cell 44 O&M Plans also resolved previous freeboard exceedance issues and further
stated that former issues regarding the freeboard exceedances for Cell 3 are closed-out. Pursuant
to the receipt of the March 14,2Ol1 letter, freeboard elevation survey measurements in Cell 3
were no longer required or conducted.
A letter from the Executive Secretary dated January 27 ,2011 which approved the use of Cell 48
and a subsequent letter dated March 15,2011, stated approval of the DMT and Cell 4.{
Operations and Maintenance ("O&M") Plans effectively eliminated the former freeboard
elevation requirements for tailings Cell 4,{. The approvals of the DMT and Cell 4A and 48
O&M Plans also resolved previous freeboard exceedance issues and further stated that former
issues regarding the freeboard exceedances for Cell 44 are closed-out. Pursuant to the receipt of
the March 15,2}ll letter, freeboard limits in Cell 4,{ were no longer required. The solution
elevation measurements in Cell 44 are required for the calculation of the daily allowable volume
of fluids pumped from the Cell 44 LDS; however, the measurements were inadvertently omitted.
A more detailed discussion of this issue is included in Section 9.0.
In addition,Partl.D.2 of the GWDP 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 I is at 5,618.5 fmsl, the top of the FML in Cell 4,{ is at
5,598.5 fmsl and the top of the FML in Cell 48 is 5600.4 fmsl. This means that the maximum
wastewater pool elevations in Cells 1, 44 and 48 permitted under Part |.D.2 of the GWDP are
5,615.5, 5,595.5 and 5597.4 fmsl, respectively.
The wastewater pool elevations in Cells I and 48, as measured during the Quarter are
summarized in the following Table 1. The requirement to meet freeboard elevation limits in Cell
3 and Cell 4A was eliminated as documented on March 14 and 15, 2Ol1 respectively. As
previously noted the wastewater pool elevations were not measured in Cell 4B prior to May 27,
2}ll, because the fluid levels were too low to measure; that is, below the level at which the
survey can be conducted from the banks of Cell 48 or, alternately, reached by measuring tape.
The DUSA notice regarding the safety issues associated with measuring the Cell 48 fluid levels,
submitted to DRC on June 6,2011 is included in Attachment B.$qfqdt-calgdrnAallp 1, the
applicable freeloard limits were not exceeded during the Quarter for any cell.
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Table L - Summary of Waste Water Pool Elevations
fThe E*ecutive Secretary approved the removal of the Cell 3 freeboard limit and authorized the use of Cell 48 on
January 27,2011. Cell 3 is nearly full ofsolids, and is undergoing pre-closure steps.
** The Executive Secretary granted a variance from the Cell 4A freeboard limit on January 13,2011, and approved
the removal of the Cell 4A limit and authorized the use of Cell 48 on January 27 ,201I . The previous freeboard limit
noted above for Cell 4A, was not set out in the License. The freeboard limit of 5,593.'74 for Cell 4A was set out in a
letter from the Executive Secretary dated November 20, 2008. Denison proposed in the DMT Plan revision dated
November 12,2OlO the removal of the freeboard limit for Cell 4A to be replaced by a freeboard limit for new Cell
4B that will accommodate the freeboard requirements of Cells 2,3,4A, and 48.
*** Measurement of the wastewater elevation in Cell 48 began on May 27 ,2011.
/'It should be noted that the Executive Secretary
authorized use of Cell 48 on January 27,2011.
3 and Cell 4A are no longer required.
approved the revisions to the DMT Plan, and
Based on this approval, freeboard limits in Cell
4.0
4.1
MONTHLY SLIMES DRAIN WATER LEVEL MONITORING
General
Part I.D.3(bX1) of the GWDP 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 GWDP
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the GWDP provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 44, the Permittee will provide: l) 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. Similarly, Part I.D.13(c) of the GWDP provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 48, 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 5.5 years or less.
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Tailings
Cell
Maximum
Wastewater Elevation
Measured During the
Quarter (fmsl)
Maximum
Wastewater Elevation
Permitted Under
License Condition
10.3 (fms1)
Maximum
Wastewater
Elevation Permitted
Under Part I.D.2 of
the GWDP (fmsl)
Cell I 5613.39 5.615.40 5,615.50
Cell3 Not Measured - freeboard
limit was removed in Ql
20tl
No Limit
(5,602.50*)
No Limit
(5,605.50*)
Cell4A Not Measured - freeboard
limit was removed in Ql
20fi
No Limit
(5,593.74**)
No Limit
(5,595.50*x)
Cell48 5581.59***5594.6 5597.4
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Part I.D.3(b)(2) of the GWDP dated February 15,2011, 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 duration of at least 9O-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. The GWDP, dated July 14, 2011, revised the frequency of the slimes
drain recovery test at each tailings cell to quarterly. The change in frequency will begin in the
third quarter 2011.
At this time, dewatering operations have not commenced in Cell 3 nor has the Mill initiated
pumping conditions in the slimes drain layer of Cell 4A or Cell 48. 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 GWDP 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 I.E.7(b) and I.F.2 of the GWDP, 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 Cell4A and Cell48 BAT Perfonnance Standards Monitoring Reports (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.l 1 of the GWDP and Section 8.2 of the DMT
Plan must be included in the 4'h 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.
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 GWDP, 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 2009,2010 slimes drain tailings fluid elevation measurements and the 2011
monthly slimes drain tailings fluid elevation measurements to date meet the test performance
standards found in Part I.D.3(bX2) of the GWDP and can be used for purposes of determining
compliance with the requirements of Part I.D.3(bX2) of the GWDP.
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4.4 Graphic Comparison to Previous Year
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A graph showing the final depth to stable water level readings for each month in 2009 through
2011, 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 2009 and2010.
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 I.D.3(e) of the
GWDP. Part I.D.3(e) of the GWDP 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 5621.5
fmsl, which did not exceed the maximum permitted elevation of 5,624 fmsl. The results of such
monitoring are included in Attachment A.
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 GWDP and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part I.D.1 1
of the GWDP. The results of these inspections are recorded on the Weekly Mill tnspection
forms, which are available at the Mill for inspection. One item was noted during the second
quarter inspections. During the weekly inspection conducted during the week of April 24,20II,
it was noted that two drums of the Regeneration Material from Cameco ("Regen material") were
leaking and had to be overpacked. The corrective action was completed immediately and no
further follow-up was necessary. No other items were noted during the second quarter
inspections.
7.O TAILINGS CELLS AND POND LINER SYSTBM REPAIRS
The liner systems at Cells 1,2,3,4,{, and 48 were inspected on a daily basis pursuant to the
requirements of Sections 2.1 and2.2 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 I.E.7(0 of the GWDP, 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 I.F. 2 of the GWDP provides that when a
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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 Cell 4,{ to lower the Cell 1 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 of 56t457 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, the Mill resumed pumping Cell 1 to Cell4,{ to lower the solution level.
During discussions on August L2,2010, 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 of the Cell 1 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
letter dated September 22,2010. The updated plan commits to completion of the repairs by July
31,2012.
The September 22, 20IO DRC letter and Part 1.F.2 of the GWDP require that the repairs be
documented in a liner repair report which shall be included with the next quarterly DMT report,
that is, in the DMT Report 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 were
conducted during the months of September and October 201.0, ceased during the months of
November and December 2010. Repairs to the Cell 1 liner resumed in April 201I.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the GWDP and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be performed, including 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 BAT
performance standards for the New Decontamination Pad are set out in Part LD.l4 of the
GWDP. 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
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of a cease and desist order from DRC dated May 18, 2010. Because the New Decontamination
Pad was not in use after the second quarter 2010, the weekly inspections of the containments
were stopped for the remainder of 2010. The Executive Secretary provided authorization for use
of the New Decontamination Pad in a letter dated February l, 2011. Use of the New
Decontamination Pad resumed in February 20ll and the weekly inspections were resumed as
required.
Table 2 below indicates the water level measurements in each portal measured during the lst
quarter 201 I after receipt of authorization for use from the Executive Secretary that correspond
to the usage of the New Decontamination Pad.
Table 2 - New Decontamination Pad Inspection Portal Level for the Second Quarter 20L1
Date
Portal I
Liquid Level
(in Feet)r
Portal L
Liquid Level
(in Feet)
Portal 1
Liquid Level
(in Feet)
4t1t20 0.00 0.00 0.00
4tr4t20 0.00 0.00 0.00
4t2U20 0.00 0.00 0.00
4t28/20 0.00 0.00 0.00
5/5t20 0.00 0.00 0.00
5^2t20 0.00 0.00 0.00
5fi9t20 0.00 0.00 0.00
5t26/20 0.00 0.00 0.00
6t2t20 0.00 0.00 0.00
6t9t20 0.00 0.00 0.00
6n6/20 0.00 0.00 0.00
6t23t20 0.00 0.00 0.00
6t29/20 0.00 0.00 0.00
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the second quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part I.D.14 (a) of the GWDP and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 1/8" were observed during any weekly
inspections.
8.2 Annual Inspection of Existing Decontamination Pad
The Existing Decontamination Pad was taken out of service and inspected during the second
quarter on May 19,2011, to ensure the integrity of the steel tank, as required by Part I.H.5(c) of
the Permit and Section 6.5 of the DMT Plan. No significant deterioration or damage was
observed. Repairs and maintenance, including caulking and sealing of cracks, were completed
on May 26, and,May 27,201I. The decontamination pad was placed back into service after the
completion of the repair and maintenance activities.
8
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The inspection report and photos taken during the inspection are provided in Attachment G-1.
8.3 Annual Inspection of 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
was granted on February 1, 2011, following 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 reviewed by DRC. Hydrostatic
testing was re-performed from November 24 to 26,2010 following a 10-day advanced notice to
DRC on November 12,2010. The Executive Secretary provided an authorization for use of the
New Decontamination Pad in a letter dated February 1,2011. Use of the New Decontamination
Pad resumed in February 2011.
The New Decontamination Pad was taken out of service and inspected on April 6, 2011 to ensure
integrity of the wash pad's exposed concrete surface, as required by Part l.F.lz of the GWDP
and Section 6.5 of the DMT Plan. No abnormalities were identified. No significant cracks
(greater than l/8 inch), deterioration or damage were identified. A few minor cracks (less than
l/8 inch) and a small area of surface flaking were observed. These minor cracks and the surface
flaking were repaired to prevent additional deterioration even though the repairs are not required
by the GWDP. The2012 annual inspection will be conducted during the second quarter of 2012.
The inspection report and photos taken during the inspection are provided in Attachment G-2.
9.0 CELL 4A AND CELL 48 BAT PERFORMANCE STANDARDS REPORT FOR
THE QUARTER
This Section constitutes the routine Cell 4A and Cell 48 BAT Performance Standards
Monitoring Report for the Quarter, as required under Part I.F.3 of the GWDP.
9.1 LDS Monitoring
9.1.1 Operational Status of LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell4,A. and Cell4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the Quarter except as noted below and as detailed in the Notice
pursuant to Part t.G.3 of the GWDP which is included in Attachment B of this report.
Cell4A
There was one failure of the monitoring equipment in Cell 44. LDS which was not made
operational within 24-hours of discovery, as contemplated by Part I.E.8(a)(1) of the GWDP for
Cell 44. It is important to note that the pumping equipment for Cell 4A LDS remained fully
9
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operations throughout the quarter, but the electronic data logging equipment associated with the
Cell 44 LDS malfunctioned during the quarter. Detailed information regarding the root cause,
corrective actions and the affirmative defense surrounding this issue are included in the Notice
pursuant to Part I.G.3 of the GWDP which was submitted to UDEQ on July 6,2011 and is
included in Attachment B of this report.
No data were lost as the result of the data capture system malfunction. The data are manually
recorded daily by the Mill Environmental Technicians. The manual data captured during the
daily inspections are used for all compliance determinations.
Cell48
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 I.E.8(a)(1) of
for Cell 48.
9.1.2 Measurement of 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
44, and Cell48 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 44 LDS sump exceed a l-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this l-foot distance equates to 2.28 feet
above the LDS system transducer), as stipulated by Part I.E.S(aX2) of the GWDP. During the
Quarter, the fluid head in the Cell 4A LDS sump did not exceed 12.7 inches above the LDS
transducer.
As can be seen from a review of Attachment F, at no point in the Quarter did the fluid head in the
Cell 48 LDS sump exceed a l-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part LE.l2(a)(z) of the GWDP. For the purposes of compliance
monitoring this l-foot distance equates to 2.25 feet above the LDS system transducer. During
the quarter the fluid head in Cell 48 sump did not exceed 14.7 inches above the LDS transducer.
9. 1.3 Measurement of the Volume of Fluids Pumped from the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F.
Cell4,{
As can be seen from a review of Attachment F, a total of 190 gallons were pumped from the Cell
4A LDS for the second quarter of 2011. Based on this measured value, the average daily LDS
flow volume in Cell 4,{ could not possibly have exceeded 24,160 gallons/day, as stipulated by
Part LE.8(aX3) of the GWDP, and in fact averaged no more than 2.08 gallons per day for 91
days.
10
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Daily allowable volume of fluids pumped from the Cell 4,A. LDS have also been calculated based
on weekly tailings cell fluid measurements using the calculations provided in the Cell 4A BAT
Operations and Maintenance Plan. A letter from the Executive Secretary dated January 27,
2011 which approved the use of Cell 48, and a subsequent letter dated March 15,2011, stated
approval of the DMT and Cell 4A Operations and Maintenance ("O&M") Plans effectively
eliminated the former freeboard elevation requirements for tailings Cell 4,\. Pursuant to the
rgceipt of the March 15, 2011 letter, freeboard limits in Cell 4.\ were no longer required.
Denison corporate staff misinterpreted this waiver as meaning that the weekly elevations no
longer needed to be conducted. As a result, these measurements were not collected during the
period. Although, the allowable daily limit of the volume of fluids pumped from the Cell 44'
LDS cannot be calculated directly from elevation measurements, as indicated above the total
volume pumped from the LDS was so small that compliance with the I.E.8(a)(3) requirement
was maintained. Moreover, calculations can be completed using conservative assumptions that
the fluid level remained as high as possible in Cell44' without flow over the spillway. Using the
assumption of maximum level provides the most conservative calculation of the daily leakage
rate. Based on these assumptions, the maximum head recorded on the FML during the Quarter of
about 39 feet, the allowable flow rate would be approximately 23,955 gallons per day, as
determined under the Mill's Cell 4A BAT Operations and Maintenance Plan, Table 1A (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. The average daily flow volume in Cell 4,{ obviously
did not exceed the calculated flow volume of 23,955 gallons/day. As previously stated, during
second quarter 2011, a total of 190 gallons were pumped from Cell 4A LDS which is
significantly below the GWDP and calculated daily leakage rate.
Cell48
As previously stated, wastewater pool elevation surveys were initiated during the week of May
27 ,201I for Cell 48 because the fluid levels were too low to measure from the top of the dike of
Cell48. These measurements were collected each week except the week of June 3,2011, during
which the measurement platform was being constructed. Based on the wastewater pool elevation
surveys conducted since the week of N{ay 27,2011, the maximum head recorded on the FML
during the Quarter of about 24 feet, the allowable flow rate would be approximately 415.6
gallons/acres/day, as determined under the Mill's Cell 48 BAT Operations and Maintenance
Plan, Table 1B (also included in Attachment F of this report), and assuming a liner elevation of
5557.5 feet and approximately 33 acres of liquid area. The average daily flow volume in Cell
44 did not exceed the calculated flow volume of 15,695 gallons/day. During second quarter
20Il,atotal of 41,133 gallonswerepumpedfromCell 48LDSduringtheentireperiod,oran
average of458.6 gallons per day.
9.2 Measurement of Weekly Wastewater Fluids in Cell48
Weekly fluid elevations for Cell 48, except as noted for the beginning of the quarter are
provided in Attachment A along with elevations for Cells I and Roberts Pond.
LL
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I 93 Slimes Drain Recovery Head Monitoring
I As the Mill has not initiated pumping conditions in the Cell4A or Cell4B slimes drain system atr this time. monthly recovery head tests and fluid level measurements are not required to be made
I
at this time pursuant to Part I.E.8(b) of the GWDP.
1O.O ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
I CALENDAR YEAR 2011
The annual slimes drain recovery head report for Cell 2 for calendar year 2011 (the "Period"), as
f required under Parts I.D.3 (b) and I.F.11 of the GWDP and Section 8.2 of the DMT Plan is
I included with the 4th quarter DMT report which will be submitted on or before March 1,20t2.
I N:\Required Reports\DMT Reportsg0l I DMT\Q2 20t I DMT Report\Q2 201I DMT Report.docxI
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1T..0 SIGNATURE AND CERTIFICATION
This document was prepared by Denison on August 3l,z0tl.
Denison Mines (U$A) Corp.
By:
David
Vice President, Regulatory Affairs and Counsel
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Denison Mines (USA) Corp.
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CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supirvision 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
p"rionr *ho *unuge the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including the ility of fine and imprisonment for knowing violations.
Davi
Vice
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Attachment A
Tailings Pond Elevations
2nd Quarter Elevations
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Date
Free Board I
41112011
4/812011
411512011
412212011
51612011
511312011
512012011
512712011
61312011
611012011
611712011
612412011
71112011
Cell 4A 3
5593.74
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
lnadvertently
omitted
Inadvertently
omitted
Gell 48 a
5594.60
5580.75
5581.11
5581.59
5580.87
5580.69
Cell 1 Cell 32 RobertsPond
5615.40 5602.50 5624.00
5613.39 No longer required 5619.5
5612.69 No longer required 5620.3
5612.62 No longer required 5620.5
5612.68 No longer required 5620.8
5612.52 No longer required 562'1.3
5612.37 No longer required 5621.5
5612.41 No longer required 5619.0
5612.32 No longer required 5618.6
5612.20 No longer required DRY
5612.12 No longer required Dry
5612.04 No longer required 5619.1
5611.89 No longer required Dry
5611.65 No longer required Dry
x The wastewater elevations were not measured in Cell 4B at the beginning of the quarter because the fluid levels
were below the the level at which the survey can be conducted from the bank of Cell 48.
x* The weekly measurement for June 3,2011 was not conducted during the construction of a platform and walkway
Measurements resumed the week of June 10, 201 1.
t Freeboard as permitted under License condition 10.3 is no longer applicable to Cell 3 or Cell 4A.
'C"ll 3 is nearly full of solids, is undergoing pre-closure steps, and the freeboard limit specified here is no longer
required and the weekly measurements are no longer required per the January 2'7 and March 14,2}ll letters from
DRC.
3 The freeboard limit for Cell 4A is not set out in the License. The freeboard limit of 5,593 ;74 for Cell 4A is set out
in a letter from the Executive Secretary dated November 20,2008. Denison proposed in the DMT Plan revision
dated November 12,2010 the removal of the freeboard limit for Cell 4A to be replaced by a freeboard limit for new
Cell 48 that will accommodate the freeboard requirements of Cells 2,3,4A, and 48. The Executive Secretary
granted a variance from the Cell 44, freeboard limit on January 13,2011 and approved the removal of the Cell 44
limit and the use of Cell 48 on January 21 ,2011. The weekly measurements are no longer required for compliance
with freeboard limts. The measurements have resumed in Q3 201 1 to complete the daily leakage rate for Cell 4A.
a The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool
surface area of 40 acres is used because there are no beaches present in Cell 48 at this time.
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Attachment B
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DENISOJ)II
Oonbon liinec (USA) Corp.
1050 lTth Strogl" Suito 050
Denver, CO 80255
USA
Tel : [phone]
Fax: 303 389.{125
www.denisonmines.com
IYTINES
June 6, 201 1
VIA E.IIIAIL AND OVERNIGHT DELIVERY
Rusty Lundberg, Co-Executive Secretiary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Re: State of Utah Ground Water Discharge Permit No. UGllY370004 White illesa Uranium i,lill -
Notice Pursuantto Part !.G.3 of the Permitand UAC R3f 765.16(C)
Dear Mr. Lundberg:
Please take notice pursuant to Part 1.G.3 of the White Mesa Mill's (the 'Mill's") State of Utah Groundwater
Discharge Permit No. UGW370004 (the'Permif') and Utah Administrative Code (.UAC') R313€-6.16(C) that
Denison Mines (USA) Corp. ("Denison'), as operator of the Mill and holder of the Permit, failed to meet he
Best Available iechnology fiBRt"; standards in Part 1.D.13.d) of the Permit, by not measuring weekly
wastewater levels on newly-approved Cell 48 until May 31 ,2011, as described in more detail below.
This exceedance was discovered on Tuesday May 31 ,2011. lnitial notice of this failure to maintain BAT was
given by telephone to Mr. David Rupp of the Utah Department of Environmental Quality at 3:45pm on
Wednesday June 1 ,2011 at801-5364023 (within 24 hours of the discovery).
1. Facts and Background lnformation
a) DRC provided authorization for use of Cell 48 on January 27 ,201'1.
b) Section 3.1d) of the Mill's DMT Monitoring Plan requires that "solution elevation measurement in
Cells 4A, 48 and Roberts Pond are to be taken by survey on a weekly basis"
c) Denison began transferring solutions to Cell 48 (by siphon) on February 1,2011.
d) Until May 31, 2011, the solution level in Cell 48 was too low to be measured safely either by survey
instrument, or by measuring tape along the sidewall (dike).
e) Unlike the other tailings celts constructed at 3 to 1 sideslopes, the sidewall (dike) of Cell 48,
constructed at2 to 1 sideslope, is too steep to allow a worker to be lowered by harness safely until
the solution level reached approximately 25 feet.
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Letter to Mr. Rus$ Lundberg
June 6, 201 1
Page 2
0 Denison began measuring solution level in Cell 48 on May 31 2011 by dropping a tape along the
sidewall of the dike. This was the first date on which the solution level could safely be reached by
measuring tape. At that time the solution level was 5581 .10 feet, that is, approximately 23.6 feet of
solution. That means over 19 feet of freeboard remained.
g) At the time of this notice, the solution level is still too low to be measured by survey instrument.
h) Denison notified UDEQ by phone call at 3:45pm on Wednesday, June 1, 20'11 that the Cell 4B liquid
level could be reached by tape from the sidewall, that the weekly measurements by tape had begun,
and that the liquid level still could not be measured by survey instrument.
i) The Millhas been running on a 10{ay on and 44ay ofl operating cycle.
2. Action Taken
Upon receipt of the initial survey results, the Mill's Environmental Coordinator notified the Mill Manager at
3:45pm that day. The following plan of actron was immediately put into place in accordance with section 5.1
of the Mill's Contingency Plan:
a) The Cell 48 solution level was measured the first day that the solution could be reached by tape
along the side wall;
b) Mill personnel have been instructed to continue solution level measurements by tape until such time
as the solution level is high enough to be read by survey instrument;
c) Verbal notification was given to the DRC at 3:45pm on June 1,2011, within 24 hours of discovery.
This verbal notification was followed by this written notification within five days of discovery;
3. RootCause
The root cause analysis is as follows
a) The DMT Plan does not address measurement of cell solution level during cell startup conditions, that
is when solution level is too low to be safely measured by survey instrument and too low to be safely
reached by suspending a worker by cable to take a tape measurement in circumstances when the
solution level is nowhere near the freeboard limit for Cell 48.
b) Denison made the judgment not to risk the safety of a worker by requiring them to be suspended
along the steep bank above the Cell 48 solutions in order to collect an environmental measurement.
4. Actions That Will be Taken to Prevent a Reoccurtence of this lncident
The following actions will be taken to prevent a reoccurrence of this incident;
a) The Cell 48 solution has reached a level that can be accessed safely by measuring tape.
DENI5OJ)II
MINES
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Letter to Mr. Rusty Lundberg
June 6, 201 1
Page 3
b) Measurements by tape have commenced and will continue until the solutton level can be measured
by survey instrument.
c) Denison will propose revisions to the DMT Plan to address the cell startup (low solution level)
situation.
5. Affirmative Defense
Denison believes that the affirmative defense in Part l.G.3.c) of the Permit should be applicable to this
incident, for the following reasons:
a) Notification
By virtue of the initial oral notification given to UDEQ at 3:45 PM on Wednesday, June 1,2011 (within 24
hours of the discovery) and this written notice, Denison has submitted notification according to UAC R3176-
6.13.
b) Failure was not lntentional or Caused by the Permittee's Negligence
The failure to survey the water level in Cell48 was not caused by Denison's negligence, either in action or in
failure to act, TG Mill made a judgment not to risk the safety of an employee in order to take an
environmential measurement, partiCularly when the solution level in Cell 48 is obviously lower than the
freeboard limit. The DMT Plan does not address the low solution level situation adequately.
c) The Permittee has Taken Adequate Measures to Meet Permit Conditions
Denison has measured the Cell 48 solution level as soon as a tape measurement c,ould safely be perforrned.
Based on the solution measurement taken on May 31,2011, the freeboard level was significantly lower (met)
the requirement for the entire period from cell startup on February 1,2011 through May 31, 201 1 , All other
required measurements in Part 1D.13 have been made and recorded since cellstartup. Based on the solution
level measurement made on May 31 , 201 1 and the calculated action leakage rates from table 1B of the BAT
O&M Plan, Cell48 has not exceided the maximum allowable average daily leakage rate during the period'
d) Denison has taken adequate measures to meet Permit conditions in a timely manner.
The provisions of the Permit were implemented immediately. UDEQ was notified within 24 hours of discovery
of the solution measurement information. Measurements of cell solution level began as soon as
measurement could safely be achieved,
e) 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 harmfulto wildlife, flsh or aquatic life, or impairs domestic, 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.
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OENISOJ)II
MINES
Leter to Mr. Rusty Lundberg
June6,2011
Page 4
Please contactthe undersigned lf you have any questions or require any further inbrmation.
Yours very truly,
DEmsoN Mrxes (USA) Conp.
Director, Compliance and Permitting
@: Rich Bartlett
David C. Frydenlund
Harold R. Roberts
David E. Turk
Centralfiles
DENISOJ)IImtNEs
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DENISOJ)/I
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : [phone]
www.denisonmines.com
MINES
July 6, 2011
VlA E.MAIL AND OVERNIGHT 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 84114-4810
Re: State of Utah Ground Water Discharge Permit No. UGW370004 White Mesa Uranium Mill-
Notice Pursuant to Part t.G.3 of the Permit and UAC R317-6-6.16(C)
Dear Mr. Lundberg:
Please take notice pursuant to Part 1.G.3 of the White Mesa Mill's (the "Mill's") State of Utah Groundwater
Discharge Permit No. UGW370004 (the "Permit") 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 Permit, failed to meet the
Best Available Technology ("BAT") standards in Part 1.E.8.a.1 of the Permit, by not providing continuous
operation of the Cell aA leak detection system ('LDS') data recording equipment, as described in more detail
below.
This failure was discovered on Monday, June 27,201 1 . lnitial notice of this failure to maintain BAT was given
by telephone to Mr. David Rupp of the Utah Department of Environmental Quality at 3:30pm on Wednesday
June 28, 201 1 at 801-536-4023 (within 24 hours of the discovery).
1. Facts and Background lnformation
a) The Cell 4A LDS instrumentation was installed in August 2008.
b) Section 1.E.8.a.1 of the Permit requires that "the Permittee shall provide continuous operation of the
leak detection system pumping and monitoring equipment, including, but not limited to, the
submersible pump, pump controller, head monitoring, and flow meter equipment approved by the
Executive Secretary. Failure of any LDS pumping or monitoring equipment not repaired or made fully
operational within 24-hours of discovery shall constitute a failure of BAT, and a violation of this
permit."
c) The Mill identified on June 27,2011, at the time of the weekly tailings inspection, that the electronic
LDS log was not operating, and determined from review of the data log that it had not operated since
June 3, 201 1.
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f)
s)
h)
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Letter to Mr. Rusty Lundberg
July 6, 2011
Page 2
d) At the time of discovery, Mill environmental personnel immediately rebooted the data computer, reset
the system, and data logging resumed.
e) The data logging system computer and data storage flash drive have the capacity to store
approximately six weeks of data.
Mill environmental technicians manually record the same data daily during daily tailings inspections.
That is all data relative for BAT compliance was manually recorded even during the periods of
electronic data outage.
Environmental technicians have historically encountered periods when data could not be
downloaded from the Cell 44 LDS storage device. Environmental technicians were under the
mistaken impression that the system required time for data uploads from the level sensor to the data
computer, during which downloads were not feasible.
During the period from June 3 to June 27, encompassing three weekly attempts at the LDS data
download, environmental technicians assumed at each unsuccessful attempt that the system was
uploading, and that data was being stored for collection during a subsequent week. Fufiher
inspectioh on June 27 identified that the system was not uploading, but had stopped recording.
Following the initial discovery of the system malfunction, Mill environmental personnel monitored the
system more closely in order to diagnose the cause of the shutdown. The data logger continued to
have the same problems with electronic shutdowns that required rebooting and resetting as follows:
Date system
rebooted
Days ol
operation before
malfunction
Date of
malfunction
Days of
missing data
before next
identified
June 27 2 June 29 2
Julv 1 4 Julv 5 1
2. Actions Taken
Upon identification of the initial malfunction, Denison took the lollowing actions:
a) Mill environmental personnel notified Denison Corporate environmental staff;
b) The data computer was rebooted and the logger reset; and
c) Environmental technicians obserued the system more frequently to confirm whether the correction
had rectified the malfunction, that is, whether the system would run continuously.
When the more frequent monitoring identified the recurring malfunction, Denison took the following actions:
Millenvironmental personnel notified Denison Corporate environmentalstaff;
Mill environmental technicians contacted the manufacturer's technical team for assistance in
diagnosing the cause of the malfunction;
a)
b)
DENISOJ)dT
MINES
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Letter to Mr. Rusty Lundberg
July 6, 2011
Page 3
c) Mill environmental personnel developed a stepwise approach for isolating the cause of repeqted
system failure, as described in Section 4, below.
3. Root Cause
The root cause analysis is as follows:
a) Environmental technicians have historically encountered periods when data could not be downloaded
from the Cell 4A LDS storage device. Environmental technicians were under the mistaken
impression that the system required time for data uploads from the level sensor to the data computer,
Ouring which downloads were not feasible. Environmental technicians were also aware that the
storage system could maintain up to six weeks of data, and assumed that because data was being
stored foi multiple weeks, it was sufficient to return the following week for the data that could not be
downloaded.
b) During the period from June 3 to June 27, encompassing three weekly attempts at the LDS data' download, environmental technicians assumed at each unsuccessful attempt that the system was
uploading, and that data was being stored for collection during a subsequent week. Further
inspection on June 27 identified that the system was not uploading, but had stopped recording.
c) Environmentaltechnicians were also aware that daily manual recording of the same data as collected
by the electronic logger is used for reporting, and mistakenly assumed that the electronic data was
redundant and not required.
4. Actions That Will be Taken to Prevent a Reoccurrence of this lncident
The following actions will be taken to prevent a re-occurrence of this incident:
a) Mill environmental technicians are in the process of procuring, installing, and testing one or more
alternate, more durable, data storage flash drive devices, consistent with the manufacturer's technical
team recommendation. lnstallation and testing will be complete by July 31, 20'11.
b) Mill environmental technicians will attempt to download, install and test an upgraded version of the
data management software, consistent with the manufacturer's technical team recommendation.
lnstallation and testing will be complete by July 31 ' 201 1.
c) Mill environmental personnel will monitor the newly installed data device and software daily for one
month after installaiion, through August 31, 201 1, to confirm whether either or both of these were the
cause of the rePeated outages.
d) lf the modifications have not corrected the recurring outages by August 31, 2011, Denison will
evaluate further steps, potentially including repair or replacement of the storage computer. Denison
will develop and discuss a schedule for furlher steps with DRC at that time.
5. Affirmative Defense
Denison believes that the affirmative defense in Part l.G.3.c) of the Permit should be applicable to this
incident, for the following reasons:
oENrsoJ)l/
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Letter to Mr. Rusty Lundberg
July 6, 2011
Page 4
a) Notification
By virtue of the initial oral notification given to UDEQ at 3:30 PM on Tuesday, June 28, 2011 (within 24 hours
of the discovery) and this written notice, Denison has submitted notification according to UAC R317-6-6.13.
b) Failure was not lntentional or Caused bythe Permittee's Negligence
The failure of the LDS instrumentation to record level data was not caused by Denison's negligence, either in
action or in failure to act. As discussed above, Mill personnel made weekly attempts to download the level
data, as well as daily visits to hand record and preserve data. The equipment malfunctioned between
monitoring events. Mill personnel have made efforts, in progress, to diagnose and correct the system.
c) The Permittee has Taken Adequate Measures to Meet Permit Conditions
Mill personnel have made multiple efforts to diagnose and correct the system, and proposed corrections to the
system are in progress. During the period in question, all of the relevant data was recorded manually to ensure
cbmpliance with the applicable requirements in the Permit. The solution level within the LDS and the flow rate
were within the prescribed limits.
d) Denison has taken adequate measures to meet Permit conditions in a timely manner.
The provisions of the Permit were implemented immediately. UDEQ was notified within 24 hours of discovery
of the solution measurement information. ln each case when the data recording system malfunctioned, it was
reset immediately upon discovery by Mill environmental personnel.
e) 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 harmfulto wildlife, fish or aquatic life, or impairs domestic, 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.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
Derursor,r MINES (USA) Conp.
]rC*',- ilzil'/luu
/
I Jo Ann Tischler
I Director, Compliance and Permitting
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Letter to Mr. Rusty Lundberg
July 6, 2011
Page 5
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Ryan Palmer
Katherine Weinel
Centralfiles
DEN'sOJ)//
,UIINES
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Attachment C
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t MONTHTY HEAD MEASUREMENT TEST
I Location:Date: 4/25/2OtL
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Slirnes Cell # 2
500
-----
700 24.48 15.40 13.69 t2.94
-----
800 23.02 L5.26 13.58 72.9tf
- -G
I 900 22,23 1s.12 13.68 12.88r looo
-i
-E6i'TiF -iil;
-
-- --
r 1100 20.80 14.9s 13.61 t2.82I
--- -
I 1200 20.37 t4.82 13.50 12.81
- --
1300 79.73 L4.77 13.40 12.78I 14oo -1676. -E'--E - -
I lsoo ---iili ---A
-32e'- -
-----
I
1500
T Comments: The report number for the month of April is 11.57
The Head test was started on a Tuesday due to some minor power issues that needed to
Sampler:Tanner Holliday
Garrin Palmer
4ltelzol.L 4l20l20,] 4127/20Lt 4/221207L 4l23l20tL 4l24l20LL 4l2sl20Lt
------71,.57
tL.57
L7.57
11.65
I be adressed on Monday the 18th.
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I MONTHLY HEAD MEASUREMENT TEST
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Location:
-
Slimes Cell # 2
Date:
Sampler:Tanner Holliday
Garrin Palmer
5lt6lz0tl Sh7/zOLL sl].slzoLt sl7elz0],t 5l2Ol2OL7
ltltttttttlttttttlE----
-----
24.89 16,ss 14.61 13.69 13.20
-----
23.4s 16.44 14.55 13,66 13.19
-----
22.85 16.30 14.48 13.63 13.18
sl2al20LL
6@
700
800
900
1000
1100
1200
1300
1400
1500
1500
21.91.16.20 13.61 13.17
21.53 15.07 14.36 13.58
-
L3.t7
21.10 1s.9S 74.12 13.56 L3.L7
-----
20.s2 1s.85 t4.27 13.54
-----
20.09 ts.t6 t4.22 13.52
19.75 15.54 L4.16 13.50
----
13.17
---Comments: the report number is 13.17 for the month of May.
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T MONTHTY HEAD MEASUREMENT TEST
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Location:Date:6/23120LL
Slimes Celltr 2
Sampler: tannerHolliday
Ryan Shierman
6lt3lzotL 6lt4/2otl 6lrsl20t7 6lt6/2q11 6lt7lz0tt 611812},: 6l20l217t
-------
-------
700 24.90 17.L6 15.28 t4.14 13.55 13.04 12.18
800 23.90 17.05 15.24 14.10 13.49 12.18
900 23.26 16.9s 1s.20 14.05 13.47 12.18
1000 22.49 16.84 L5.L7 t4.o2 t3.46
1100 21.95 16.7L 1s.11 13.99 13.45
21.53 15.53 15.03 13.95 13.4s
'llllllllllllllllllllllllllllll|||-------21.01 15.55 1,4.95 13.91 13.43
1200
1300
1400
1s00
20.51 16.40 L4.87 13.85 13.40I
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13.79 13.32
-------
1600
-E-----
12.18
-------
Comments The report number is 12.18 for the month of June 2011.
19.97 16.31 L4.79
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Attachment D
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Attachment E
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1l This attachmentbas been delib€ratetyleft blank.
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I Attachment F
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Cell4A LDS Monitoring lnformation
April 2011
I Measurements in inches from
transducer at the bottom of
I Date the LDS sump. Flow Meter in Gallons
4l7l7L 3.1 264OLOI Y',:Y,i: '-:i lZlZ:Z
4128/77 2.6 264070
I Highest level for the month was !2.7inches and the lowest level for the month was 2.6 inches. Total
number of gallons pumped was 0.
I May 2011
t Measurements in inches from
transducer at the bottom of
I ,7i'i,
the LDSrsumP' Flow Meter in Gallons
2640LO
sl7zlt]- s.8 264OLOI Z":Z!,:: ": :21:ZZ
I Highest level for the month was 11.2 inches and the lowest level for the month was 2.5 inches. Totalr number of gallons pumped was 145.
I T;Tffiff:Iil:H,x:T
Date the LDS sump. Flow Meter in GallonsI z!,1!,:: i:" :.li'z
6/L6l1L 6.9 264lss
I 6/23/tL s.3 2l47ss
6/29/tL 10.s 264200
I Highest level for the month was 10.5 inches and the lowest level for the month was 3.9 inches. Total
number of gallons pumped was 45.
I For the 2nd Quarte r 2OL7,the highest level was 12.7 inches and the lowest level was 2.5 inches. A total of
190 gallons were pumped.
I rune 2011
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I Celt48 LDS Monitoring lnformation
Aoril201"1I
I Measurements in inches from
transducer at the bottom ofthe
I -7:;i, ttt::it Frow Meter in Garrons
327L26
4lt2/Lt t4.L 33s473
I ?":z!,:: lij #:::
I Highest level for the month was 14.66 inches and the lowest level for the month was 2.97 inches. Total
I number of gallons pumped was 33,386'
I
MaY 2011
Measurements in inches from
I transducer at the bottom ofthe
I Date LDS sump' Flow Meter in Gallons
sl3lll 3.s 350s13t z!,:y,:: i:l l:3lii
5/24ltt 4.6 360s13
I
Sl3L/Lt s.e7 350s13
Highest level for the month was 8.1 inches and the lowest level for the month was 3.25 inches. Total
I
number of gallons pumped was 8,347.
June 2011
I Measurements in inches from
transducer at the bottom of the
I ui'l)i' LDSsump' Flow Meter in Gallons
360513
6lt4ltt 8.s 360s13I z!,:;!,:: :i= l:Hl:
I Highest level for the month was 11.32 inches and the lowest level for the month was 7.43 inches. Total
r number of gallons pumped was 0.
For the 2nd Quarter 2011, the highest level was 14,56 inches and the lowest level was 2.97 inches. A total
I of 41,733 gallons were PumPed.I
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I
Cell 48 LDS Monitoring lnformation
I April2011
Measurements in inches from
transducer at the bottom of the
I ^7:;i,
t";Tt Frow Meter in Garrons
327726
I ^/,:3"i: 11:i 1:-Z::,;
4/26/LL L4.7 3s2t66
I Highest level for the month was L4.7 inches and the lowest levet for the month was 3.0 inches. Totalr number of gallons pumped was 33,385.
I ,ff:;:::[."fiJ1ffH""",T"
Date LDS sump. Flow Meter in GallonsI :l:r;, ii i:3;il
s/t7lL7 4.6 360s13I z!,1:"i: !i, l:Hil
I Highest level for the month was 8.1 inches and the lowest level for the month was 3.2 inches. Total
I number of gallons pumped was 8,347.
Measurements in inches from
transduceratrtli,lil" *tn"
Frow Meter in Garons
6/711.t 8.s 360s13I 2!,1,?"ii 3l l:Hil
6128/1]- 11.3 360s13
I Highest level for the month was 11.3 inches and the lowest level for the month was 7 .4inches. Total
number of gallons pumped was 0.
I For the 2nd Quarter 2011, the highest level was 14.7 inches and the lowest level was 3.0 inches. A total of
4t,733 gallons were PumPed.
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June 2011
Getrly-aE@lttsullrlnF TTHG IA
fthulddAcflqt lerhgr nrtltfurt rtlout tlcad Cmdftlone
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Attachment G
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Attachment G-1
Existing Decon Pad lnspection and Photographs
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Plotection Manual, Section 3.1
3/10 Revision: Denison-9
Page35 of 46
APpENDTX A (CONT.)
ANNUAL DECONTAMINATION PAD INSPECTION
Dateorlnspecrion: 5'tq'^ '' -d*/rL"( * 5//7/2"//
lnspector:
contamination Pad:
Are there any cracks on the wash pad surface Breater than l/8 inch of separation? -Yes No
Is there any significant deterioration or damage of the pad surface?
-Yes -No
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Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank?
-Yes
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Attachment G-2
New Decon Pad lnspection and Photographs
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White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/ I 0 Revision: Denison-9
Page 35 of46
APPENDTX A (CONT.)
ANNUAL DECONTAMTNATION PAD INSPECTION
Dateof Inspecrion: A{tcit L, /Att
Inspecton ?.l,,,, D+l^re -.
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than l/8 inch of separation? -
Is there any significant deterioration or damage of the pad surface?
-Yes
-6o
Findings:
S 3-,d,.a-'f $uu; -\ar{oc<- LrcL) -rc,1c(trc {)"r1,.
\:pair Work Required:
Yes K,
b,nr^ ru<J-f'*rc
Existing Decontamination Pad:./
Vy'ere there any observed problems with the steel tank? Yes / |lo
Repair Work Required:
1'.,*tt t ,1//t<r{
Ta^L 71.^u \
New Decontamination Pad (NDP)
Removed grating showing area cleaned out
North- NDP- Cross Section
Of Grate Area
NDP - Minor Cracks
NDP - Minor Cracks
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NDP - Minor Cracks
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NDP - Main Grates
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North - NDP East Platform
North - NDP South Enclosure
Tank (after cleanout)
North - NDP Middle Enclosure
Tank (during cleanout)
NDP North Enclosure Tank
North - NDP West Outer Wall
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Heat Exchanger
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North - NDP
East wall looking North
NDP - Discharge from grates
lnto Tank
North - NDP
South Enclosure
NDP - South Enclosure
NDP - South Enclosure LDS
NDP - South Enclosure
NDP - South Enclosure
NDP - Fresh Water line DroP
NDP - Recycle Line Valve
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NDP - Middle LDS Port
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NDP - Middle Enclosure
NDP - Middle Enclosure
NDP - North LDS Port
NDP - North Enclosure
NDP - North Enclosure
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NDP - North Enclosure
NDP - North Enclosure
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NDP - North Enclosure
NDP - Sealed Seams
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NDP - Sealed Seams
NDP - Sealed Minor Crack
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NDP - Sealed Minor Crack
NDP - Sealed Minor Crack
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NDP - Repaired Pitted Concrete
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NDP - Repaired Broken/Chipped
Concrete (outside pad)
NDP - Repaired Broken/Chipped
Concrete (outside pad)
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NDP - Repaired Broken/ChiPPed
Concrete(outside Pad)
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NDP - Repaired Broken/Chipped
Concrete(outside pad)
Concrete(outside pad)
NDP - Repaired Broken/Chipped
NDP - Repaired Chipped
Concrete
NDP - Repaired Chipped
Concrete
NDP - Repaired Chipped
Concrete
NDP - South Enclosure Cleaned
NDP - Cleaned South Enclosure
NDP - Cleaned South Enclosure
NDP - Sealed Minor Crack
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