DRC-2012-001802 - 0901a06880303bee

State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
Department
Environmental Quality
Amanda Smitii
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Luniiberg
Director
2012-00183?
MEMORANDUM
TO File
THROUGH Phil Goble, Section Manager
FROM Russell J Topham, P E
DATE July 6, 2012
SUBJECT Review ofthe 1'' Quarter, 2012 (dated May 30, 2012) DMT Performance Standards
Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Momtonng
Report (Report) Groundwater Discharge Permit (GWDP) UG3 70004 - Denison Mines
(USA) Corp (DUSA) White Mesa Mill, Blanding, Utah
This IS a summary of Utah Division of Radiation Control (DRC) staff review of the DUSA DMT
Performance Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Monitoring Report
dated May 30, 2012, and covering the Quarter (January-March) 2012 momtonng period (Report) DRC
received the Report on May 31, 2012 in both hard copy and soft copy CD formats Discussions in this
document reference the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, Revision 11 1 (DMT/BAT Plan) The DMT/BAT Plan m force
during the Period in question was executed on January 20, 2011
After review of this report, DRC staff findings and recommendations are as follows
1 DUSA has provided the weekly slimes drain maximum/minimum fluid level monitoring data in
support of compliance with Part IF 2 of the GWDP and Part 3 l(b)(v) of the DMT Monitonng
Plan
2 DUSA has provided the data required in Part ID 3(b)(2) of the GWDP The lata demonstrate
comphance with the requirements of the GWDP for slimes drain head recovery testing
3 The data presented in the report demonstrate DUSA compliance with the solution pool
operational requirements of the License and the DMT/BAT plan in force dur ng the quarter
J
4 DUSA monitored the Cell 4B solution pool elevation as required to demonstrate compliance with
the freeboard requirement
5 DUSA included in the Report data from tailings beach elevation and area surveys
6 DUSA included in the Report leak detection system monitonng data and leakage rate calculations
195 Nortli 1950 West • Salt Lalce City, UT
Mailmg Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq utah gov
Printed on 100% recycled paper
Page 2
for Cell 1 and Cell 3
7 DUSA performed solution pool elevation monitoring in Cell 4A to facilitate determination of
allowable FML leak rate Cell 4A solution pool monitoring data and the numerical determination
of compliance with FML leak rate standards for Cell 4A and Cell 4B appear m the Report
Attachments
8 DUSA expenenced a failure in the programmable logic controller (PLC) recording the data
measured in the leak detection system (LDS) All portions of the LDS ftinctioned properly except
the module recording the flow rate being pumped from the LDS The failure occurred March 13,
2012 after the daily inspection of the system was concluded DUSA detected the failure dunng
daily inspection on March 14, 2012 DUSA provided notification by telephone on March 14,
2012 and written notification on March 19, 2012 Upon discovery of the failure, DUSA
immediately commenced trouble shooting and repair Working with the equipment vendor, on
March 15, 2012 DUSA identified the need to replace the PLC board DUSA received and
installed the replacement on March 16, 2012 Sufficient data exists to demonstrate proper
functiomng of the LDS throughout the momtonng system failure Specifically, DUSA can
calculate flow rates from quantities pumped and penods of pump operation, thus replacing data
the system failed to record The DRC should issue a Notice of Enforcement Discretion for this
occurrence inasmuch as prompt action facilitated rapid repair, the failure appeared unforeseeable
and unpreventable, and the LDS continued to function properly notwithstanding the failure
9 DUSA completed no work on the approved Cell 1 liner repair plan dunng the Report penod
10 Data presented in the report demonstrate DUSA compliance with the decontamination pad
inspection and maintenance requirements of the DMT/BAT Plan
11 DUSA has met the provisions of the DMT/BAT Plan with regard to feed material stockpiles
1.0 Slimes Drain Water Level Monitoring
Part IF 2 of the GWDP requires DUSA to include in the Report, all DMT performance standards
monitonng detailed in Parts ID 3 and IE 7 ofthe GWDP Part ID 3(b)(1) ofthe GWDP requires DUSA to
maintain the fluid level in the slimes dram of Cells 2 and 3 as low as reasonably achievable at all times,
and to demonstrate that performance through adherence to the current DMT Monitonng Plan Part IE 7(b)
ofthe GWDP requires monthly monitonng and recording of the depth to wastewater in the slimes drain
access pipe as described in Part ID 3 ofthe GWDP and the current DMT Momtonng Plan Part 3 l(b)(v)
of the DMT Momtonng Plan requires DUSA to monitor and record weekly the depth to wastewater in the
Cell 2 slimes drain access pipe to determine maximum and minimum head before and after a pumping
cycle, respectively
1 Section 4 1 of the Report asserts that the above discussed monitonng requirements only pertain to
Cell 2 for the reportmg period, as dewatenng operations have not commenced m Cell 3
2 Weekly water level monitoring of the Cell 2 slimes drain is not required as part of the DMT plan,
but IS required under Part ID 3(b)(1) of the GWDP Inasmuch as this data is not currently bemg
reported elsewhere, DUSA agreed in a conference call on October 26, 2011 to provide the data as
part of the quarterly DMT Report until a more appropnate reporting mechanism is instituted
DUSA has included this data in Attachment C to the Report
Page 3
3 Attachment C to the Report contains data from the monthly/quarterly recovery head measurements
(discussed in the next paragraph)
4 The recovery head monitoring data provides indirect evidence that DUSA has maintained the fluid
level in the Cell 2 slimes drain as low as reasonably achievable, as required in GWDP, Part
ID 3(b)(1)
Finding Data provided in Attachment C to the Report supports a conclusion that DUSA has met the
requirement to keep water levels in the Cell 2 slimes drain as low as reasonably achievable
Part ID 3(b)(2) of the revision of the GWDP in force during the fourth quarter of 2012 required DUSA to
perform a quarterly slimes drain head recovery test at each tailings cell slimes drain Specifications for the
head recovery test appear in Parts ID 3(b)(2)(i) and (ii) ofthe GWDP
;
Part IDS 2(e) of the GWDP requires each quarterly report to contain the current year monthly fluid level
values and a graphical comparison with previous years for the Cell 2 slimes drain Part ID 3(b)(3) of the
GWDP includes an analytical test to determine annual slimes dram compliance The analytical procedure
provides a means of demonstrating the success of dewatenng operations in the tailings cell The average
annual fluid level in the slimes drain must fall each year for the slimes drain to remain in compliance The
latest revision ofthe GWDP changes the recovery test frequency fi^om monthly to quarterly
5 Attachment C to the Report contains the required head recovery test data
6 Attachment D to the Report contains the required graphical comparison The regression senes
included on the chart shows graphical evidence of general compliance with the requirement to
reduce fluid head in the slimes drain
7 The Report for the fourth quarter of 2011 contained Cell 2 slimes drain recovery test data which
indicated violation ofthe cnteria in Part ID 3(b)(3) of the GWDP That issue is being addressed
separately from this review
Findings DUSA has provided the data required in Parti D 3(b)(2) of the GWDP The data demonstrate
compliance with the requirements of the GWDP for slimes drain head recovery testing The Cell 2 slimes
drain fiwd level appeared to continue its declining trend, as required, and in contrast to the increased
elevation noted during the fourth quarter of 2010
2.0 Tailings Wastewater Pool Elevation Monitoring and Roberts Pond Solution Level Monitoring
Part I E 7(a) of the GWDP requires DUSA to monitor and record weekly the elevation of the wastewater
pool in Tailings Cells 1 and 3 to ensure compliance with Condition 10 3 of the License Part ID 3(e)
requires DUSA to operate Roberts Pond so as to provide a minimum two feet of freeboard at all times Part
3 1 (d) of the DMT/BAT Plan requires DUSA to measure the solution pool elevation in Cells 4A and 4B
weekly, and the tailings beach maximum elevation and area within Cells 4A and 4B monthly
Tailings have nearly completely filled Cell 3 Recognizing this, letters from the Executive Secretary dated
January 27, 2011 and March 14, 2011 formally eliminated the need for solution pool elevation
measurement in Cell 3 The previously cited January 27, 2011 letter and another letter from the Executive
Secretary dated March 15, 2011 concluded a process obviating the need for freeboard-related solution pool
elevation monitoring in Cell 4A However, Part 3 1 (a) of the DMT/BAT Plan requires monitonng solution
pool elevations in Cells 4A and 4B to facilitate determination of compliance with FML leakage rate
limitations
Page 4
1 Attachment A to the Report contains weekly pool elevations for Cell 1 indicating compliance with
the prescnbed freeboard requirements
2 As noted above, no requirement for weekly solution pool elevation measurement at Cell 3 existed
during the fourth quarter Attachment A to the report reflects no measurements for the reported
quarter
3 Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating
compliance with the prescribed fi-eeboard requirements
4 Attachment A to the Report contains weekly solution pool elevations for Cell 4A in support of
calculating acceptable leak rates for the liner system DUSA failed to take the required solution
pool measurements in Cell 4A during the first and second quarters, and part of the third quarter of
2011 However, DUSA has retumed to compliance, having taken and reported the required
elevation readings for the latter portion of the third quarter the entire fourth quarter of 2011, and
the first quarter of 2012
5 Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating
compliance with the prescribed fi-eeboard requirements
6 The License requires measuring and reporting tailings beach maximum elevation and area While
not a DMT/BAT requirement, no other report currently captures this data Until instituting another
mechanism for capturing this data, the quarterly DMT/BAT report provides a convenient
alternative The report contains no data or narrative relative to tailings beach surveys for any cell
Findings The data presented in the report demonstrate DUSA compliance with the solution pool
operational requirements of the License and the DMT/BAT plan in force during the quarter
3.0 Leak Detection System Monitoring
Part 3 1(a) ofthe DMT/BAT Plan requires DUSA to monitor the leak detection system (LDS) for Cell 1
and Cell 3 weekly DUSA would either report the LDS as dry or report the fluid level in the LDS monitor
pipe Presence of fluid in the LDS tnggers a requirement to extract the fluid, measure the extracted volume,
and compute a leakage rate for the cell
1 Attachment C to the Report contains data showing the Cell 1 and Cell 3 LDS dry during the first
quarter of 2012
Findings Cell 1 and Cell 3 seem to have had no detectable leakage during the first quarter of 2012
Part ID 6(a) ofthe GWDP requires DUSA to operate Cell 4A m a manner to maintain fluid head in the
LDS not more than 1 -foot above the lowest point on the lower FML on the cell floor Part ID 6(b) requires
that the leak rate through the Cell 4A FML not exceed 24,160 gallons per day Part 3 1(a) of the
DMT/BAT Plan reiterates the GWDP requirements just discussed Table 1A in Appendix E to the
DMT/BAT Plan relates solution pool head above the liner system to maximum allowable FML leak rate
2 Calculation of solution pool head requires measunng the solution pool elevation Attachment A to
the Report presents the required solution pool elevation readings for Cell 4A
Page 5
3 Attachment F to the Report presents LDS fluid level monitonng data and number of gallons
pumped from the LDS
4 Quantities of fluid pumped from the Cell 4A LDS support a finding of compliance with the
operational requirements ofthe GWDP and DMT/BAT Plan
Findings DUSA is compliant with the FML leakage rate provisions of the DMT/BAT Plan with respect to
cell 4A This includes solution pool elevation monitoring, extracting fiuid when it exists in the LDS, and
maintaining FML leakage rate below the prescribed limits
Part ID 13(a) of the GWDP requires DUSA to operate Cell 4B in a manner to maintain fluid head in the
LDS not more than 1-foot above the lowest point on the lower FML on the cell floor Part ID 13(b)
requires that the leak rate through the Cell 4B FML not exceed 26,145 gallons per day Part 3 1(a) of the
DMT/BAT Plan reiterates the GWDP requirements just discussed Table IB in Appendix E to the
DMT/BAT Plan relates solution pool head above the liner system to maximum allowable FML leak rate
5 Calculation of solution pool head requires measuring the solution pool elevation Attachment A to
the Report presents the required solution pool elevation readings for Cell 4B
6 Attachment F to the report presents LDS fluid level monitonng data and number of gallons
pumped from the LDS
7 Quantities of fluid pumped from the Cell 4A LDS support a finding of compliance with the
operational requirements ofthe GWDP and DMT/BAT Plan
Findings DUSA is compliant with the FML leakage rate provisions of the DMT/BAT Plan with respect to
cell 4B This includes solution pool elevation monitoring, extractingfiuid when it exists in the LDS, and
maintaining FML leakage rate below the prescribed limits
Part IE 8(a)(1) of the GWDP requires DUSA to provide continuous operation of the Cell 4A LDS
pumping and monitoring equipment, and to make such equipment operational within 24 hours of discovery
of a failure of such equipment Part ID 12(a)(1) of the GWDP requires DUSA to provide continuous
operation ofthe Cell 4B LDS pumping and monitonng equipment, and to make such equipment
operational within 24 hours of discovery of a failure of such equipment
8 On March 14, 2012, while performing the daily inspection regimen, DUSA plant personnel
discovered that the flow rate reporting circuit for the LDS pumping system had ceased recording or
displaying pumped flow rate shortly following the previous day's inspection Plant personnel, in
conference with the system vendor, attempted repair of circuit on March 14 and 15, ultimately
determining that the PLC required replacement The new PLC amved March 16, whereupon plant
personnel completed the replacement and restarted the system The repair was not completed
within 24 hours of discovery of the problem, but was completed as rapidly as DUSA could acquire
the required parts The repair appears to have been successftil
9 Section I E 8(a)(1) of the GWDP requires DUSA to provide continuous operation of all elements
ofthe leak detection systems for the various cells Failure to repair a failed system and bnng it to
ftill operation within 24 hours constitutes a violation of the GWDP and of BAT
10 DUSA notified the DRC on March 14, 2012 by telephone, with wntten notice, including corrective
actions taken provided in a Notice dated March 19, 2012, of the condition and violation
Additional information related to the violation and corrective actions taken appears in the Report
Page 6
11 DUSA has not experienced a repeat failure installation of the new PLC
Findings DUSA experienced failure of the Cell 4B leak detection pump rate recording module within the
PLC and attempted repair in accordance with GWDP intentions The repair did not succeed, and
acquisition ofthe replacement PLC extended well beyond the 24 hour limit, violating the GWDP Sufficient
information existed in the remaining records to demonstrate compliance with GWDP provisions for LDS
performance The system is now repaired and functioning properly DRC should issue a Notice of
Enforcement Discretion regarding this issue Recognizing that the problem has not recurred since repair
on March 15, 2012, the DRC should consider the issue closed
Part I E 7(f) ofthe GWDP stipulates procedures to implement upon detection of any FML defect or
damage On September 22, 2010 DRC extended conditional approval for a liner repair plan for Cell 1
DUSA committed to complete repairs under that plan by July 31, 2012
12 DUSA completed no repair work on the Cell 1 liner during the Report penod
Findings DUSA completed no work on the approved Celll liner repair plan during the Report period
4.0 Decontamination Pad Inspections
Part 3 l(e)(i) ofthe DMT/BAT Plan sets forth requirements for monitonng the New Decontamination Pad
Subpart (B) requires weekly measurement of fluid level in the inspection portals to detect leakage of the
primary containment bamer Subpart (F) imposes requirements to inspect weekly the integrity of the
concrete comprising the New Decontamination Pad surfaces and to repair any cracks greater than 1/8 inch
m width or other abnormalities in the pad surface Part 3 1 (e)(ii) imposes requirements to inspect weekly
the integnty of the concrete comprising the Existing Decontamination Pad surfaces and to repair any cracks
greater than 1/8 inch in width or other abnormalities in the pad surface
1 The inspection portals of the New Decontamination Pad contained no fluid at the weekly
inspections
2 No cracking in excess of 1/8 inch or other abnormality ofthe surface of the New Decontamination
Pad was observed dunng the Report quarter
3 Although measunng less that 1/8 inch, cracks in the surface of the Existing Decontamination Pad
were repaired Inspectors noted no other anomalies on the pad surface
Findings Data presented in the report demonstrate DUSA compliance with the decontamination pad
inspection and maintenance requirements of the DMT/BAT Plan
5.0 Feedstock Storage Area Inspections
Part 3 3 of the DMT/BAT Plan requires weekly confirmation that bulk feedstock storage occurs in the
areas defined in the GWDP, that a four foot buffer exist between feedstock stockpiles and the storage area
boundary, and that altemate feedstock stored outside the defined feedstock storage area is maintained in
water tight containers or are placed on a hardened surface
1 Location of stockpiles within the bulk storage area appeared properly placed
2 Standing water fi-om rain events was noted in the feedstock storage area This water was directed to
the sump, and ultimately to Cell 1 for disposal
Page 7
Findings DUSA has met the provisions of the DMT/BAT Plan with regard to feed material stockpiles
6.0 Recommendations
1 The DRC should issue a Notice of Enforcement Discretion and Closeout to document the violation
of the GWDP with respect to the failure and attempted repair of the Cell 4B LDS PLC and
DUSA's retum to compliance
2 The DRC should issue a closeout letter with respect to the Report