DRC-2012-001806 - 0901a06880303baf

State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
201^-001806
MEMORANDUM
TO
THROUGH
FROM
DATE
SUBJECT
File
Phil Goble, Section Manager
Russell J Topham, P E
July 20, 2012
Compliance: Review of Discharge Mimmization Technology Monitonng Plan Revision
12 1 dated July, 2012 (DMT) and Tailings Management System Procedure Revision 2 1
dated July, 2012 (TMS) Groundwater Discharge Pemiit (GWDP) UG370004 - and
Radioactive Matenals License (RML) UT1900479, Denison Mines (USA) Corp (DUSA)
White Mesa Mill, Blanding, Utah
Following review of a draft of the referenced DMT and TMS documents, and a conference call between
DRC staff and representatives of DUSA, the DRC issued a Confirmatory Action Letter beanng the date
May 30, 2012 (CAL) This memorandum summanzes DRC staff review of the DUSA response to the
CAL, received in the DRC offices July 5, 2012 The cover letter bears the date July 2, 2012 The discussion
follows the same sequence as presented in the referenced CAL In addition<to responding to the CAL,
DUSA has incorporated a change in the DMT that the DRC requested in its Comment Letter dated January
19, 2012 (Comments) regarding the Nitrate Corrective Action Plan for White Mesa Mill Site dated
November 30, 2011 (Nitrate CAP) This additional change obviates the need for another round of revision
to the DMT As detailed below, I find that the referenced submittals reflect the DRC's intent in the
referenced CAL and Comments I recommend approval of the DMT and TMS documents, with the
understanding that review of the engineenng design of the Ammonium Sulfate Pad (Part 4 4 of the DMT,
answenng one of the Comments) may reveal a need for revision to the DMT language
1 Items 1 through 3 listed in the CAL presented DRC's intent to bnng uniformity to the leak
detection system (LDS) monitonng protocols for the various disposal cells at the White Mesa
Mill site Specifically, monitonng of Cells 1, 2 and 3 follow requirements in the RML, while
monitonng of Cells 4A and 4B reflect requirements of the GWDP The RML does not require
reporting of RML momtonng, while the GWDP does To improve protection of ground water and
to umfy the monitonng and reporting process, the DRC sought, and DUSA concurred, to include
the monitoring of Cell 1, 2 and 3 LDS m the DMT DMT language and attached monitoring
forms as presented in the proposed revisions reflect this change, answenng to Item 4 in the CAL
2 Item 5 in the CAL suggested cross-referencing the LDS momtonng in a similar way to other
cross-referencing already made a part of the proposed DMT and TMS documents The DRC did
not require these changes in the CAL, but presented the request as an opportunity to assist those
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implementing the protocols contained in the documents DUSA has included the indicated cross
references
Item 6 in the CAL put DUSA on notice that the DRC may include the LDS monitonng and
reporting requirements for Cells 1, 2 and 3, as outlined in Bullet 2 above, in the next renewal of
the DUSA GWDP The DRC requested no action on this item at this time
Comment 21 in the Comments requested DUSA to include in the DMT or a revision to the Nitrate
Corrective Action Plan an inspection, documentation and repair requirement for a new concrete
pad to be constmcted beneath the ammonium sulfate tank The Comments required this plan to
mirror the Decontamination Pad inspections currently mcluded in the DMT A new Part 4 4 of the
DMT includes suggested language
DUSA requested by telephone on June 26, 2012 consideration of some modifications to the
requirements for the ammonium sulfate pad as compared to the decontamination pads These
modifications center on the increased nsk of release of material to the environment should DUSA
take the ammonium sulfate tank out of service and transfer its contents to another container
pending repair of cracks in the pad Tom Rushing and I discussed this request at length, and
concluded that requinng repair of the pad within a sufficiently short period of time presented
supenor protection of the aquifer than other altematives
The proposed language requires repair of cracks in the concrete within 7 calendar days of
discovery, and also specifies keeping a wntten and photographic log of inspections I find this
proposal adequately to answer the intent of Comment 21, given what information we currently
have about the pad However, as design progresses, additional concems may emerge I
recommend approving the language as written, but explicitly to reserve the option to revise the
language should design review reveal an unexpected hazard to the underlying aquifer