DRC-2012-001717 - 0901a068802f977b

State ofUtah
GARY R HERBERT
Govemor
GREG BELL
Lieutenant Governor
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
20t2-001717
TO
FROM
DATE
SUBJECT
MEMORANDUM
Phil Goble, Section Manager
Russell J Topham, P E
March 14, 2012
Review ofthe 4'*' Quarter, 2011 (dated Febmary 27, 2012) DMT Perfomiance Standards
Monitoring Report and Cell 4A and Cell 4B BAT Performance Standards Monitonng
Report (Report) Groundwater Discharge Permit (GWDP) UG370004 - Denison Mines
(USA) Corp (DUSA) White Mesa Mill, Blanding, Utah
This IS a summary ofUtah 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 Febmary 27, 2012, and covering the 4th Quarter (October-December) 2011 monitoring period
(Report) DRC received the Report on Febmary 28, 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
in force dunng the Penod 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 Monitoring
Plan
2 DUSA has provided the data required in Part I D 3(b)(2) ofthe GWDP The data demonstrate
compliance with the requirements of the GWDP for shmes 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 dunng the quarter
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
for Cell 1 and Cell 3
195 North 1950 West • Salt Uke City UT
Mailing Address PO Box 144850 • Salt Uke City UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq uiah gov
Printed on 100% recycled paper
Page 2
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 in the Report
Attachments
8 DUSA experienced failure of the Cell 4B leak detection flow totalizer on November 3, 2011
DUSA attempted repair, only to have a repeat failure on November 22, 2011 The latter repair
extended beyond the 24-hour limit provided in the GWDP to bring the system into fiill operation
following discovery of a failure Troubleshooting and working with the system vendor
commenced immediately, but procurement of the required replacement parts took until December
6, 2011, well beyond the 24-hour repair time limit DUSA did act responsibly in its
troubleshooting and repair efforts The Report cites a failure on December 13, 2011 Upon
- discovery. Plant personnel reset the totalizer No problems have been observed sine DRC should
issuie a Notice of Enforcement Discretion and closeout, given the actions DUSA has taken and
the absence of another problem with the totalizer since December 13
9 DUSA completed no work on the approved Cell 1 lmer repair plan during 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 I F 2 ofthe GWDP requires DUSA to include in the Report, all DMT performance standards
monitonng detailed in Parts 1 D 3 and 1 E 7 ofthe GWDP Part ID 3(b)(1) ofthe GWDP requires DUSA
to maintain the fluid level in the shmes drain 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)
of the GWDP requires monthly monitonng and recording of the depth to wastewater in the shmes drain
access pipe as described in Part ID 3 of the GWDP and the current DMT Momtonng Plan Part 3 l(b)(v)
requires DUSA to monitor and record weekly the depth to wastewater in the Cell 2 shmes 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 reporting period, as dewatenng operations have not commenced in Cell 3
2 Weekly water level monitoring of the Cell 2 shmes drain is not required as part of the DMT plan,
but IS required under Part I D 3(b)(1) of the GWDP Inasmuch as this data is not currently being
reported elsewhere, DUSA agreed in a conference call on October 26, 2011 to provide the data as
part ofthe quarterly DMT Report until a more appropnate reporting mechanism is instituted
DUSA has mcluded this data in Attachment C to the Report
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 shmes drain as low as reasonably achievable, as required in GWDP Part
ID 3(b)(1)
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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 shmes drain as low as reasonably achievable
Part ID 3(b)(2) of the revision of the GWDP in force during the fourth quarter of 2011 required DUSA to
perform a quarterly shmes drain head recovery test at each tailings cell shmes drain Specifications for the
head recovery test appear in Parts ID 3(b)(2)(i) and (ii) ofthe GWDP
Part 8 2(e) requires each quarterly report to contain the cunent year monthly fluid level values and a
graphical comparison with previous years for the Cell 2 shmes drain Part ID 3(b)(3) of the GWDP
includes an analytical test to determine annual shmes drain 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 shmes drain must fall each year for the shmes drain to remain in compliance The latest
revision ofthe GWDP changes the recovery test frequency from 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 shmes drain
7 The Report for the fourth quarter of 2010 contained Cell 2 shmes drain recovery test data which
indicated violation of the 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 Part 1D 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 shmes
drain fluid 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) ofthe 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 I D 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) ofthe 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
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
Page 4
3 Attachment A to the Report contains weekly pool elevations for Roberts Pond indicating
compliance with the prescribed freeboard 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 dunng 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 and the entire fourth quarter of 2011
5 Attachment A to the Report includes solution pool elevation readings for Cell 4B indicating
compliance with the prescribed freeboard 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
altematlve 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
DUSA failed to monitor the Cell 4B solution pool elevation for the first two quarters and part ofthe third
quarter of 2011, but has returned to compliance No additional response from DRC is required
DUSA failed to provide to DRC results of tailings beach elevation and area surveys, either as a part ofthe
quarterly DMT/BAT report or under separate cover through the first three quarters of 2011 DUSA
provided the survey data for the fourth quarter of 2011, and has returned to compliance No additional
response from DRC is required
3.0 Leak Detection System Monitoring
Part 3 1(a) of the 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 fourth
quarter of 2011
Findings Cell 1 and Cell 3 seem to have had no detectable leakage during the fourth quarter of 2011
Part ID 6(a) of the GWDP requires DUSA to operate Cell 4A in a manner to maintain fluid head in the
leak detection system (LDS) not more than 1 foot above the lowest point on the lower FML on the cell
floor Part I D 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 measuring 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 of the 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 fluid 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, extracting fluid when it exists in the LDS, and
maintaining FML leakage rate below the prescribed limits
Part I E 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 I E 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 November 3, 2011, while performing the daily inspection regimen, DUSA plant personnel
discovered that the flow totalizer for the LDS pumping system indicated flow, even though the
system recorded no pump starts Plant personnel, in conference with the system vendor, attempted
repair of the totalizer through installation of a software upgrade The repair was completed within
24 hours of discovery of the problem, and appeared to have been successful
9 On November 22, 2011, while performing the daily inspection regimen, DUSA plant personnel
discovered that the flow totalizer was again recording flow without a pump start Dusa again
contacted the system vendor and engaged in trouble shooting Problem identification and
procurement and installation of a new digital processor took until December 6, 2011
10 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
full operation within 24 hours constitutes a violation of the GWDP and of BAT
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11 DUSA notified the DRC on December 1, 2011 by telephone, with wntten notice, including
corrective actions taken provided in a Notice dated December 6, 2011, of the condition and
violation Additional information related to the violation and corrective actions taken appears in
the Report
12 The totalizer again recorded flow while the pump was not m operation on December 13, 2011
Plant personnel reset the totalizer and restarted the system No recurrence of the problem has
occurred since December 13, 2011
13 DUSA used the data from the flow totalizer in its calculation of LDS performance under the
philosophy that doing so was more conservative Using the inflated flow volume in LDS
performance deterrmnations did not resuh in violation of the GWDP provisions for LDS
performance
Findings DUSA experienced failure of the Cell 4B leak detection pump flow totalizer and attempted repair
in accordance with GWDP intentions The repair did not succeed, and subsequent repair efforts extended
well beyond the 24 hour limit, violating the GWDP The failure resulted in inflated flow totals for the LDS
pumping system Using the inflated values in performance calculations did not result in violation of 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
December 13, 2011, DRC should consider the issue closed
Part I E 7(f) of the 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
14 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 1 (e)(i) of the 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
in width or other abnormalities in the pad surface Part 3 1 (e)(ii) imposes requirements to inspect weekly
the integrity 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 of the 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
Page 7
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 Routine inspection
on October 28, 2011 by DUSA revealed that Cabot matenal had migrated closer to the fence then
desired The encroachment was remedied immediately upon discovery No material escaped the
fenced enclosure
2 Standing water from heavy rains was noted in the feedstock storage area This water was directed
to the sump, and ultimately to Cell 1 for disposal
3 Plant personnel discovered hydraulic fluid spills from ore tmcks The contaminated soils were
moved to Cell 3 for placement and disposal
Findings DUSA has met the provisions of the DMT/BAT Plan with regard to feed material stockpiles
6.0 Recommendations
1 DUSA should seek clarification of the conflict between the two narratives addressing the failure of
the Cell 4B LDS pump flow totalizer Assuming the data provided as clarification does not reveal
other issues needing correction, DRC should issue a Notice of Enforcement Discretion to
document the violation of the GWDP with respect to the failure and attempted repair of the Cell 4B
LDS pump flow totalizer and DUSA's retum to compliance