DRC-2012-002678 - 0901a06880346617

State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM DRC.a012-002678
TO
THROUGH
FROM
DATE
SUBJECT
File
Phil Goble, Section Manager
Russell J Topham, P E
June 12, 2012
L
Inspection of Disposal of Bulk Byproduct Matenal June 8, 2012 Radioactive Matenals
, License UTI 900479 (License) - Denison Mines (USA) Corp (DUSA) White Mesa Mill,
Blanding, Utah
On Apnl 13, 2012,1 conducted an inspection at the DUSA White Mesa null on behalf of the DRC My
pnmary task was to observe placement and bunal of bulk byproduct material generated at in-situ leach
facilities pursuant to a 11 e (2) Byproduct Receipt Notification from DUSA, dated May 29, 2012 DUSA
IS allowed to dispose this byproduct matenal m Tailings Cell 3 only, which is allowed by License
Condition 10 5 of the DUSA Radioactive Matenals License While onsite I checked the progress of repair
of cracked concrete floonng in the pnmary and altemate feed circuits and m the old and new
decontamination pads, reviewed performance of the altemate feed dmm management pads, inspected the
newly placed addition to the altemate feed dmm management pad, and looked over the Cell 1 liner repair
effort Comments regardmg the additional dmm management feed pad will appear in a separate project
closeout letter
Bulk Byproduct Material
On May 29, 2012 DRC received notice that DUSA would receive twelve loads of 1 le (2) byproduct
matenal, and intended to dispose of that waste m Cell 3 on June 8, 2012 Ten loads were ultimately
received I checked in at the White Mesa null at 7 25 a m on June 8, 2012 Soon thereafter I met with Mr
Gamn Palmer I was informed that the 1 le (2) waste disposal operation had concluded at about the time of
my am val Mr Palmer escorted me to the bunal location in Cell 3, where I observed excavations opened
for an anticipated June 14 bunal operation immediately adjacent to the bunal just concluded As with my
previous observations onsite, excavations extended mto the first 12 inches of tailings sand, and exposed
solution at approximately the elevation of the top of the tailings deposit I have no reason to expect that the
excavations filled on this day were any different than those immediately adjacent, or those observed on
other occasions The groonung effort following the disposal and subsequent filling, capping and
compaction appeared consistent with^other observed efforts
The disposal event on June 8, 2012 involved waste from three sources The first source, UEM Houston, has
a reserved area on the currently exposed tailings beach Seven loads received bunal in this location The
168 North 1950 West • Salt Lake City, UT
Maihng Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 'TDD [phone]
vvvvw deq utah gov
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designated areas for disposal of matenal from the other two sources he adjacent to one another m an area
already covered One load from Mestena Uranium received bunal in one trench, while the remaimng three
loads, from Smith Ranch, received placement in a second trench
Dunng document review following the field observation, I paid particular attention to documents detailing
honzontal and vertical location of the waste, both for this and for a number of previous bunal events
DUSA documents honzontal location of all bunals in an AutoCAD file and on a paper plat map, with all
waste from a given source receiving interment in a location reserved for that generator Vertical location
includes an elevation measurement taken immediately pnor to placement to establish the bottom of the
trench, and another measurement on the top of the waste load after placement in the trench but pnor to
placement of capping fill I reviewed at random approximately 30 records of vertical placement elevation
data, including the June 8,2012 instance, and found no case of the top of waste any higher than 1 6 feet
below the plane or grade of the top (at the cell penmeter) of the uppermost flexible membrane liner in the
cell Thus, DUSA appears compliant with Part 10 5 E (2) of the RML with respect to the elevation of
bunal
While I did not witness the burial operation, from the physical evidence visible onsite and from the
documents reviewed, it appeared that all provisions of the approved disposal SOP were followed dunng
placement and burial of the bulk waste Attachments to this report include bills of lading, radiation surveys,
shipping manifests, receipt for delivery, photos, and, in the case of the Smith Ranch product, sample
laboratory analyses Nine of the twelve loads are represented in the attached documents The
documentation form required as part of the approved 11 e'(2) disposal Standard Operating Procedure, and
bunal depth calculation sheets for each trench, also appear in the attachments
Floor Crack Repairs
Dunng an ISL disposal inspection on Apnl 12, 2012,1 noted ongoing efforts to patch cracbng m the floors
of the main leach circuit and the altemate feed circuit While prepanng for the June 8, 2012 inspection, I
received a request to observe the condition of the same floonng, to gage progress of the patching
operations No patching occurred dunng my visit, but I observed that the bulk of the floors had little or no
unpatched craclang m excess of 1/8-inch Most cracks that I had observed dunng^my April 12 visit had
been patched I have provided two photos of typical crack repair in the photo log attached to this report
Mr Palmer informed me that dunng inspections of the plant, DUSA inspectors now routinely inspect the
floors for cracking Cracks thus identified are placed on a pnonty list, assunng that the worst cracks get
repaired first Repair is ongoing, with a crew penodically (at least annually) dedicated solely for two to
four weeks at a time to patching
Decontamination Pads
I viewed both decontamination pads for cracking that might require patching No unpatched cracks were
observed The patching exhibited the same charactenstics as that shown in the photo log attached to this
report
Cell 1 Liner Repair
Repair of the flexible membrane liner (FML) in Cell 1 has concluded Crews have begun replacing the
protective soil cover over the FML At the time of my visit, I could view no portion of the FML, as loose
soil covered the intenor of all embankments Reportedly, the next step includes fine grading and track-
walbng the soil in place to reduce erosion Concurrent with, or following the regarding effort, DUSA will
reconnect power to the leak detection system and resume automated monitonng