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Home My WebLink AboutDRC-2012-001808 - 0901a06880303be4State of Utah GARYR HERBERT Governor GREG BELL Lieutenant Governor department of ^ Environmental Quality Amanda Smith Executive Director DIVISION OF RADL\TI0N CONTROL Rusty Lundberg Director RC-20ft-001808 TO FROM DATE SUBJECT MEMORANDUM Phil Goble, Section Manager ^ ' Russell J Topham, P E May 23,2012 Resuhs of Review of Apnl, 2012 Demson Mmes USA Discharge Mmimization Plan Revision 12 0 and Tailmgs Management System Revision 2 0, White Mesa Mill, Blandmg, Utah This IS a summary of Utah Division of Radiation Control (DRC) staff review of the Demson Mines USA (DUSA) Discharge Mimmization Technology Monitonng Plan (DMT Plan) Revision 12 0 and Tailings Management System (TMS) Revision 2 0 The documents appear generally acceptable in form and content I recommend, for umformity, amending Part 8 of the TMS to require quarterly reporting of leak detection system monitonng for Cells 1, 2 and 3 to parallel that required for Cells 4A and 4B Without recounting the entire history, for several years, the DMT Plan and the TMS have resided in a single document DUSA petitioned the DRC on October 26, 2011 for approval to split the DMT Plan and TMS into separate documents inasmuch as the DMT Plan reflects requu-ements of the Ground Water Discharge Permit (GWDP), while the Radioactive Matenals License issued to DUSA dnves the TMS Inasmuch as DUSA had undertaken other imtiatives involved with the DMT plan, the DRC agreed to wait until DUSA received approval of Revision 11 5 of the DMT Plan before considenng this "split plan " Revision 115 bears a revision date of Febmary, 2012 and received DRC approval on March 12, 2012 The DRC received the captioned documents on Apnl 13, 2012 The DMT Plan includes robust quarterly reporting requirements The TMS only requires retention of records of inspection activities for DRC review upon DRC visiting the facility, and submitting an annual report to the DRC and the State Engineer addressing geotechnical stability of the embankments The level of monitonng required in these two documents appears sufficient, however, the reporting requirements result in inconsistencies with respect to the treatment of slimes drain monitoring, as discussed in the following three paragraphs Part 3 1 ofthe TMS requires daily inspection of the leak detection system (LDS) for Cells 1, 2 and 3 The inspector looks for presence or absence of fluid in the slimes drain Upon detecting fluid, the inspector reports the LDS as wet, notes the fluid level, and activates the pump system Upon extractmg fluid from the LDS, the inspector records the new fluid level and quantity of fluid pumped DUSA makes this information available for DRC inspectors, upon request, when the DRC visits the site 195 North 1950 West • Salt Lake City, UT Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536^250 • Fax (801) 533^097 'TDD (801) 536^414 www deq Utah gov Printed on 100% recycled paper Page 2 By contrast, the DMT Plan calls for continuous momtonng of the LDS in Cells 4A and 4B through the automation system Fluid levels and extracted volumes get logged as the events occur, and DUSA includes this information m quarterly reports The technologies m use to momtor Cells 1, 2 and 3 differ from those used to monitor Cells 4A and 4B Notwithstanding, the DRC can benefit from quarterly reporting of LDS monitonng activity for cells 1, 2 and 3 I recommend requinng quarterly reporting of this data for Cells 1, 2 and 3 to mirror reporting already occumng for Cells 4A and 4B In a Confirmatory Action Letter dated October 27, 2011, the DRC documented a commitment from DUSA to include the LDS monitoring data from Cells 1, 2 and 3 in the quarterly DMT Reports The current GWDP and RML contain no reporting requirements for the Cells 1, 2 and 3 LDS This requirement should appear in Section VII of Appendix Al to the DMT Plan (the Daily Inspection Data Form), with supporting language appeanng in Part 3 of the main body of the DMT Plan Part 8 of the DMT requires quarterly reporting of the data captured on the forms in Appendix A, thus captunng this requirement m the same manner as the reporting for Cells 4A and 4B Cross reference can appear m Part 8 ofthe TMS document The Annual Technical Evaluation Report required under the TMS appears adequately to treat the remaimng monitonng required under the TMS Likewise, the reporting requirements contained in the DMT Plan appear sufficiently comprehensive, and the frequency appears appropnate I might have employed different prose to make the test more readable, and moved histoncal narratives to an appendix, but I can find no compelling reason to require those changes Therefore, except as noted above, I have no objection to the proposed text as wntten