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Home My WebLink AboutDRC-2012-001311 - 0901a068802c5865State of Utah GARY R HERBERT Govemor GREG BELL Lieutenant Govemor March 15 2012 Department of Environmental Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director CERTIFIED MAIL fliC- ?0 1 ?" 00 1 31 1 RETURN RECEIPT REQUESTED ^ fe-^ *- ^W1-^*X Mr David C Frydenlund Vice President and General Counsel Denison Mines (USA) Corp (DUSA) 1050 Seventeenth St Suite 950 Denver Colorado 80265 Subject 4^ Quarter 2011 DUSA DMT Performance Standards Monitoring Report and Cell 4A and Cell 4B Performance Standards Monitonng Report (Dated February 27 2012) Ground Water Quality Discharge Permit UGW370004 DRC Findings, Notice of Enforcement Discretion and Closeout Dear Mr Frydenlund On February 28 2012 the Utah Division of Radiation Control (DRC) received the 4th Quarter 2011 DMT Performance Standards Monitoring Report and Cell 4A and Cell 4B Performance Standards Momtonng Report (dated February 27 2012) for the DUSA White Mesa Mill near Blanding Utah This letter summanzes the outcome of our staff review of the Report The DRC findings were as follows 1 Part IE 8(a)(1) ofthe GWDP requires DUSA to provide continuous operation of the Cell 4B LDS pumping and monitoring equipment and to make such equipment operational withm 24 hours of discovery of a failure of such equipment On November 3 2011 Mill personnel discovered that the LDS monitonng flow totalizer had recorded flow dunng a time that the pump was off and the flow meter recorded no flow Plant personnel conferred with the system vendor and received and installed a software update The totalizer seemed to operate correctly upon restarting the system 2 On November 22 2012 dunng daily inspection Plant personnel again noted the flow totalizer recording flow Plant personnel venfied that the pump was off and that the flow meter was reading no flow Plant personnel again engaged the vendor in trouble shooting Diagnosis and troubleshooting continued through December 1 2011 The vendor determined on December 2 2011 that repair required installing a new digital processor DUSA ordered the new processor which amved on December 6 2011 and was installed immediately Again the system appeared to ftinction correctly upon startup 3 DUSA notified the DRC verbally of the failure on December 1 2011 and in wnting on January 6 2011 195 North 1950 West Salt Lake City UT Mailing Address POBox 144850 Salt Lake City UT 84114-4850 Telephone (801) 536-4250 Fax (801) 533-4097 TDD (801)536-4414 www deq tai go Printed 0 100/recycled paper David C Frydenlund Page 2 March 15 2012 4 On December 13 2011 the totalizer again recorded flow while the pump was off and the flow meter showed no flow Plant personnel reset the totalizer and rechecked the system finding it to operate as designed To date the problem has not recurred 5 DUSA used the values generated by the flow totalizer in making compliance determinations for the reportmg penod thus overstating cell liner leakage rates Use of the inflated leakage rate did not result in violating the established liner performance standards 6 In all other respects it appears DUSA complied with applicable standards as detailed in the DMT and BAT Plans Notice of Enforcement Discretion Although DUSA failed to retum the Cell 4B leak detection system flow totalizer to full fiinctionality withm 24 hours of discovenng a failure of the product the Executive Secretary has determined to use enforcement discretion in this matter based on 1 DUSA personnel made reasonable efforts to troubleshoot and repair the flow totalizer 2 DUSA continued to monitor the system to ensure proper operation detecting recurrent problems as they occurred rather than days later 3 The product failure and protracted trouble shooting did not result in a violation ofthe performance standards for the leak detection system or result in failure to detect a liner breach 4 Repairs which DUSA has made appear to have retumed the equipment to proper operation Closeout Inasmuch as no open issues remain DRC considers the review of the 4* Quarter 2011 DUSA DMT Performance Standards Monitormg Report and the Cell 4A and Cell 4B Performance Standards Momtonng Report and the failure of the flow totalizer to be hereby closed Questions should be directed to Russ Topham at (801) 536-4256 UTAH WATER QUALITY BOARD Rusty Lundberg ^ Co Executive Secretary RL/RJTr)t 1 '• CO m o HI cr I r- o a o HI HI • HI • U.S. Postal Service TM CERTIFIED MAILM RECEIPT (Domestic Mail Only; Nm Insurance Cmverage Prmvitied) RE NOED& CLOSEOUT/RJT David C Frydenlund Vice President & General Counsel Denison Mines (USA) Corp (DUSA) 1050 17th ST^TE 950 _ Denver CO 80265 - ^ rs F«rm 3»M, August 2MS y-\ J X F«r delivery information visit •ur website at www.usiis.c«mR ^ 1 C i A i . USE Postage $ Certif ed Fe Postma k See Reverse f»r Instruction^- \ y V r ( •/ J ! r SENDER: COMPLETE THIS SECTION Complete items 1 2 and 3 Also complete Item 4 if RestncteieilPelivery is desired Print your name an^^dress on the reverse so that we can retur^me card to you Attach this card to tf^back of the mailpiece or on the front if space permits 1 Article Addressed to RE NOED& CLOSEOUT/RJT COMPLETE THIS SECTION ON BELIVEPY David C Frydenlund Vice President & General Counsel Denison Mines^USA) Corp (DUSA) 1050 17th ST STE 950 Denver CO 80265 A SIgnatu B Receiveo-t • Agent • Addressee B Received-tjyfPr/ntedWame) 0 Date bf Delivery D Isdeligayagldt<agajlffeitwtfrpmitenrt 1? DYes < If YES, > 6- J 4 Restnct^pelijireiy; (Drtftf'/^^' 2 Article Number (Transfer from service labeD 7011 •110-Dim--7T51 031fl y 4. d ( fl PS Form 3811 February 2004 Domestic Retum Receipt 102595-02 M 1540 |*\