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Home My WebLink AboutDRC-2012-001955 - 0901a06880308d20DRC-2012-001955 DENISON MINES Denison Mines (USA) Corp. 1050 17th Street, Suite 950 Denver, CO 80265 USA Tel 303 628-7798 Fax • 303 389-4125 www denisonmlnes com April12, 2012 VIA E-MAIL AND OVERNIGHT DELIVERY Mr Rusty Lundberg Utah Department of Environmental Quality 195 North 1950 West PO Box 144850 Salt Lake City, UT 84114-4850 Re Storm Water Inspection at the White Mesa Uranium Docket No UGW 12-01, March 7, 2012 Dear Mr Lundberg Notice of Violation and Compliance Order, This letter transmits Denison Mines (USA) Corp's ("Denison's") response to the above-named Notice of Violation and Compliance Order (the "Order"), which Denison received on March 14, 2012 The Order cited five violations ofthe Groundwater Discharge Permit ("Permit") and ordered that Denison 1 Immediately initiate all actions necessary to achieve compliance with all applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements of the Denison Quality Assurance Plan ("QAP")) 2 Submit a report to the Co-Executive Secretary of the Utah Water Quality Board (the "Executive Secretary") within 30 calendar days of receipt of the Order to include but not be limited to the following Items a The root cause of the noncompliance, b Corrective steps taken or to be taken to prevent re-occurrence of the noncompliance, c Date when compliance was/or will be achieved This letter constitutes Denison's report in response to the above requirements As required by the Order, we have listed each cited violation below, followed by the response contents The Order states that "Based on the foregoing FINDINGS OF FACT, DUSA is in violation of the following Violation 1 "Part I D 11 of the Permit by failing to store and manage feedstock matenals in water tight containers (or water tight overpack) or on a qualified hardened surface" Y Mnspections and NOVs\Stormwater lnspections\Stormwater Inspection NOV and RFI 03 07 12\04 12 12 Response to DRC 03 07 12 NOV final doc Letter to Mr Rusty Lundberg Order Docket No UGW12-01 April 12, 2012 Page 2 Denison Response 1. Actions necessary to achieve compliance with all applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements ofthe QAP) All feedstock containers which are required by Part I D 11 of the Permit to be placed on a hardened surface designed, constructed, and operated in accordance with engineering plans and specifications approved in advance by the Executive Secretary were subsequently placed on such a hardened surface (an approved curbed concrete pad) during the week of October 25, 2011 2 a Root Cause of the Non-Compliance Operations in the alternate feed area require maneuvenng space for staging of drums of alternate feed to be opened, emptied and processed in each alternate feed campaign At the time of the October 2011 Storm Water Inspection, Denison had constructed an addition to the concrete pad area at the Alternate Feed Circuit based on a design which had been submitted to the Executive Secretary for approval The Utah Division of Radiation Control ("DRC") approved the proposed pad design in a letter dated September 30, 2011 The pad was constructed and the new concrete was set to cure during the first two weeks of October 2011 During a visit to the Mill on October 4, 2011, DRC staff noted that the pad construction, then in process, complied with the approved design plan At the time of the October 18, 2011 Storm Water Inspection, the as-built, submitted to the Executive Secretary, had not yet been approved, and the new concrete area had not yet been placed into service DRC subsequently approved the as-built drawing in a letter dated October 24, 2011 However, although this new addition is intended to provide more maneuvering space for staging of alternate feed drums and for opening, emptying and processing such drums, there was nevertheless sufficient previously-built and approved concrete surface area available for all the drums in use or staged at the alternate feed area at the time of the inspection It was therefore not necessary for any drums to have been placed directly on the ground surface at the time of the inspection The root cause of the violation was not the lack of adequate concrete surface area, but that the alternate feed operators had just recently been transferred to the alternate feed circuit and did not understand that the Permit does not permit the placement of non-water-tight drums on the ground surface New operators had been rotated into the alternate feed processing area for the alternate feed processing campaign The newly assigned operators opened and emptied, or partially-emptied, a number of feed drums for the alternate feed batch, placing some of the emptied open drums on the engineered concrete pad, and eight additional drums onto the ground surface 2 b. Corrective Steps Taken to Prevent Re-Occurrence of the Non-Compliance All alternate feed area operators have been retrained to understand which types of drums are required to be placed on an approved hardened surface and not directly on the ground surface In addition, Denison has sought a further expansion of the alternate feed area concrete pad to accommodate the number of drums anticipated for the spnng 2012 alternate feed processing schedule, in a manner that provides more maneuvering space for handling the drums and that will reduce the chance that any damaged drums will inadvertently be placed directly on the ground surface Denison submitted an engineenng design to DENISO MINES Letter to Mr Rusty Lundberg Order Docket No UGW12-01 April 12, 2012 Page 3 the Executive Secretary for approval on March 27, 2012 At the time of this wnting, Denison is awaiting Executive Secretary approval of the design To prevent future non-compliance, the spnng alternate feed processing program will be delayed until the approval is received, and the expansion of the concrete pad is constructed, cured, and placed into service 2 c Date When Compliance Was/Wiii Be Achieved Compliance was achieved during the week of October 18, 2011 when the eight drums placed on the ground surface were removed from the ground surface and placed on the existing concrete surface Following approval of the concrete pad expansion as-built on October 24, 2011, the expanded concrete area was placed into service Feed drums for the spring 2012 processing campaign are either on the existing expanded concrete pad, or are in the alternate feed storage area awaiting approval and construction of the proposed expansion of the alternate feed processing area concrete Violation 2 "Part I D 10 of the Permit by failing to manage all contact and non-contact storm water in accordance with the currently approved Storm Water Best Management Practices Plan ("SWBMPP") Specifically. DUSA violated Section 2 0 of the SWBMPP by failing to provide an adequate ditch and diversion system to channel and contain the surface runoff to the tailings management system " 1 Actions necessary to achieve compliance with ail applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements ofthe QAP) Denison pumped the water in the overfilled sump to the New Decontamination Pad sump, as originally designed, and repaired the failed berm that resulted in the apparent discharge observed by DRC dunng the October 2011 inspection 2 a Root Cause of the Non-Compliance In 2010, Denison constructed a paved surface drainage ditch designed to dram the area east of the New Decontamination Pad The drainage ditch was intended to prevent accumulation of run-on water on the roadway east of the New Decontamination Pad used by reagent delivery trucks, in an effort to minimize muddy conditions that could anse after heavy rainfall The surface ditch conveyed run-on water to a sump, surrounded by an earthen berm, near the southeast corner of the ore storage pad When filled, the sump is emptied by means of a sump pump through a Dnsco pipeline, and the pumped water is returned to the New Decontamination Pad sump The Mill experienced high rainfall during October 2011 One of the rainfall events overtopped both the surface ditch and the collection sump before Mill operations personnel were able to activate the pump return system to empty the sump The overtopping resulted in breakdown and carryover of berm soils and water, creating the rills and carryover observed by DRC dunng the October 2011 inspection 2. b. Corrective Steps Taken to Prevent Re-Occurrence of the Non-Compliance Denison has implemented more frequent inspections of the ditch and sump system, and more frequent pumping/emptying of the sump during and after rainstorm events, to prevent a recurrence of the overflow situation DENISO MINES Letter to Mr Rusty Lundberg Order Docket No UGW12-01 April 12. 2012 Page 4 2 c Date When Compliance Was/Wiii Be Achieved Compliance was achieved dunng October 2011 when the overfilled sump was pumped out to the New Decontamination Pad The overtopped soil berm was subsequently repaired dunng planned maintenance activities in Apnl 2012 Violation 3 "Part I D 10 of the Permit by failing to provide adequate active operational measures to discover, prevent, control, contain, and clean-up spills of kerosene outside of the secondary containment located north of the shop building" 1 Actions necessary to achieve compliance with all applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements ofthe QAP) Denison moved the kerosene tank to a location within the existing concrete lined and walled pad, from which it would no longer drip outside the concrete pad area 2 a Root Cause of the Non-Compliance The kerosene storage tank in question consists of a horizontal tank on a metal saddle, with a hose and pump system, all of which are located on an existing concrete pad surrounded by a 2 Vz foot concrete wall The drum and drum saddle had been moved by operations personnel to a position near the wall that resulted in the hose and pump handle being directly above the wall When the hose and handle system dripped kerosene as it was used, the dnps fell outside the concrete pad area, on and along the outside edge of the wall Dunng the October 2011 inspection, DRC observed staining on the wall and spillage on the soil outside the concrete pad area, which had resulted from the hose and pump dnpping onto the wall 2 b Corrective Steps Taken to Prevent Re-Occurrence of the Non-Compliance Dunng March of 2012, Denison moved the tank and saddle, and its associated hose and pump, such that the entire system is within the concrete pad area and no part is on or above the wall 2 c Date When Compliance Was/Will Be Achieved Compliance was achieved during the October 2011 inspection when the visibly stained soils outside the concrete pad and wall were removed and disposed in the tailings cells The tank, saddle and pump were subsequently moved further back inside the concrete pad area, and the stained concrete wall was brush- scrubbed, dunng planned maintenance activities in March 2012 Violation 4 "Part I D 10 of the Permit by failing to provide adequate active operational measures to discover, prevent, control, contain, and clean-up spills of oil from drums stored on racks east of the shop building " 1 Actions necessary to achieve compliance with all applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements of the QAP) DENISO MINES Letter to Mr Rusty Lundberg Order Docket No UGW 12-01 April 12, 2012 Page 5 The Mill's three horizontal oil drum racks have been removed from service Oil drums from all three of the racks have been removed and placed upnght in individual oil spill prevention pallets 2 a. Root Cause of the Non-Compliance The Mill formerly stored unopened oil drums for maintenance or Mill area use on one of three horizontal two-tier racks outside the maintenance area Each rack had an attached dnp collection pan below and in front of the rack to collect any leaked fluids from the bungs or caps of the horizontal drums One of the racks with its attached dnp pan was placed on uneven ground such that the rack and plan tilted down at one end Leaked fluids accumulated at the lower end of the tilted pan and overtopped the pan at the low end, staining the surrounding soils 2. b Corrective Steps Taken to Prevent Re-Occurrence of the Non-Compliance During the October 2011 inspection, the spilled fluids were collected from the dram pan, and the stained soils outside the collection pan were removed and disposed m the tailings cells The horizontal drum racks were removed from service and the drums placed upright in new individual spill prevention pallets during planned maintenance activities in March 2012 2 c Date When Compliance Was/Will Be Achieved Compliance was achieved during the October 2011 inspection, when the spilled fluids and stained soils were removed and disposed in the tailings cells Violation 5. Part I D 10 of the Permit by failing to control contact wash water by effective operational measures at the New Decontamination Pad near the scale house Denison Response. 1 Actions necessary to achieve compliance with all applicable provisions of the Utah Water Quality Act, Ground Water Quality Rules in the Utah Administrative Code, and the Permit (including but not limited to requirements of the QAP) Mill maintenance staff has provided ongoing repairs to the New Decontamination Pad pump packing to minimize recirculation water leakage The New Decontamination Pad recirculation pump also requires extension of the concrete footing to increase the area covered by concrete and minimize the bare ground surface adjacent to the pump piping that could be exposed to any recirculation water leakage 2 a Root Cause of the Non-Compliance The New Decontamination Pad wash water pump is positioned on a small concrete footing which is set directly on bare ground Leaks from packing in the pump, which are not directly above the concrete footing can reach the bare ground surface Due to the nature of the pump's service, it has not been possible to ensure zero leakage of packing and joints 100 percent of the pump's service hours As a result, additional concrete coverage to protect soil from occasional leaks of re-circulated wash water from the pump will be required DENISO MINES Letter to Mr Rusty Lundberg Order Docket No UGW12-01 April 12. 2012 Page 6 2. b. Corrective Steps Taken to Prevent Re-Occurrence of the Non-Compliance Denison has prepared a design modification to the New Decontamination Pad pump system A design drawing has been provided as Attachment 1 to this submittal The system modification will be constructed within 15 days of Denison's receipt of the Executive Secretary's approval of the design drawings 2. 0. Date When Compliance WasA^ili Be Achieved Compliance will be achieved when the modification is constructed, within 15 days of receipt of the Executive Secretary's approval fo the design drawings Please contact me if you have any questions or require any further information Yours very truly, DENISON MINES (USA) CORP Jo Ann Tischler Director, Compliance and Permitting cc David C Frydenlund Dan Hillsten Harold R Roberts David E Turk KathenneA Weinel DENISO MINES Letter to Mr Rusty Lundberg Order Docket No UGW 12-01 April 12, 2012 Page 7 ATTACHMENT 1 DENISO MINES NOTEt I sitauM SHMj. 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