DRC-2009-006467 - 0901a0688014f6ae

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State ofUtah
GARY R HERBERT
Goterm/r
GREG BELL
Lieutenant GoVirmor
IVX' cXvq^rc.ir-Hir]
Department of
Environmental Quality
.Amanda Smith
P\ci nmv Direaor
DIV ISION OF RADIATION CONTRtJL
Dane L Finerfrock
Din-rltir
November 25, 2009
Certified Mail
(Retum Receipt Requested)
Mr. Steven Landau
Environmenlal Manager
Denison Mines (USA) Corporation
1050 IV*^ Streei, Suite 950
Denver, CO 80265
Dear Mr. Landau:
.SUBJECT: Denison Mines (USA) Corporation (DUSA) While Mesa Mill Facility
DRC Inspection Results: Tailings Cells 1-3 and Roberts Pond DMT and Cell 4A BAT
Performance Standards and Monitoring Inspection Engineering In.spection Module 75E;
Report of Findings and Request for Information
.An inspection on the subject was held on October 28-29, 2009 at lhe DUSA mill facilities near Blanding,
Utah. David Rupp represented DRC, David Turk and Ronnie Nieves of DUSA attended on October 28,
2009. Messrs. Ryan Palmer, Ronnie Nieves. and Rich Bartlell of DUSA were in the office and attended a
closeout meeting with Mr. Rupp on October 29. 2009. DRC is requesting information on some issues
idenrified in section A below:
A. Issues Identified, Remedies Proposed and Requesl for Infonnation :
1. In the S.W. comer of Cell 4A the tailings solution recycle pipe from the pump contacts a
secrion of the FML not protected by an FML "rub sheet" for appro.xiniaiely 10-feet. In the
closeout meeting on sile on October 29, 2009 Mr. Bartlett offered to add a rub sheet under
the piping lo protect the upper FML from the pipe by October 30, 2009. See photo no. 7
attached. We request DUSA supply a photograph ofthe completed adjustment.
The CeU 4A B.'\T Moniioring, Operations and Maintenance Plun. under Cell Operation, p.
3 requires. 'The initial solution discharge will be in the southwest comer of the Cell. The
discharge pipe will be routed down the Splash Pad provided in the corner ofthe Cell to
protect the pipeline running from the solution reclaim barge." The splash pad mentioned is
the "Yub sheel" discussed above.
We reconrunend the CeU 4A BAT Monitorin,'^, Operarions and Maintenance Plan be
modified to require all pipelines entering oi leaving Cell 4A be maintained with a rub sheet
beneath them.
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Mr. Steven Landau
November 25, 2009 ;
Page 2
2. Feedstock and other materials were observed on or very near the northern fence line ofthe
feedstock storage area. See photos no. 13-15 attached. Feedstock boundary encroachment
has been observed during other site visits by DRC.
The Ground Water Discharge Permit modification that is currently in process will establish
certain performjmce standards for feedstock found outside the feedstock .storage area.
We recommend that DUSA establish minimum distances between the feedstock storage
fence and feedstock materials to prevent future violations of feedstock storage
requirements outside the boundary of the designed area. Such a buffer zone should be
documented by an SOP or other proposed method.
Mr. Bartlett committed that the encroaching feedstock materials would be removed from
the northem fence line of the feedstock storage area prior to November 15, 2009. A future
DRC inspecrion will revisit this issue.
3. During our inspection it was apparent that some inspection notes laken by DUSA had been
discarded. Original handwritten copies of data should not be thrown away, even though
dala may later be transcribed to electronic media. Please be advised that Part II.H of the
Ground Water Discharge Pennit requires diat the ''permittee shall retain records of all
monitoring information . . ."
4. In March of 2009 the LDS in Cell 4A had an incident for a few days where lhe pressure
head reached 40-inches or 3.33-feet. DRC was not previously notified of this incident.
Documentarion of this evenl is discussed in a DUSA memo on the subject dated March 3 \,
2009 (end. 2). 1( appears this evenl should have been reported per Ground Water
Discharge Permit Part 1 D.G and l.G.3.
h does appear (his is an anomalous event, apparently caused by reversing die polarity of
the LDS sump pump, which effectively disabled the pump.
The DMT Plan, paragraph 2.1.p, in the Daily Comprehensive Tailings Inspection section
of the plan states, 'The solution level in Cell 4A leak detecdon is not allowed lo be more
than 1.0 foot above the lowest point on die bottom flexible membrane liner (elevation
5556.14 feet amsl). If any of these observations are made, the Mill Manager should be
notified immediately and the leak detection system pump slarted."
The March 31, 2009 DUSA memo shows good faith effort was made m this regard, in that
repairs to the LDS pun^p were completed within 2-days of discovery of the problem and
mill management was norified.
5. Weekly inspection reports observed since August 2009 show a seven-inch (7") water level
in the Cell 2 LDS. This water was analyzed by DUS.A. Copies of an analysis of this water
by Energy Laboratories dated August 27, 2009 were provided DRC during the inspection.
During the inspecrion DUSA staff explained that DUSA had previously placed a lid on the
LDS observation port to prevent liquids intruding intothe LDS moniioring pipe. The staff
also meniioned improvemem of this lid is planned. DRC review of this matter is ongoing.
B. Maximum Allowable Daily LDS Flow Rates - During (he inspection lhe pump in Cell 4A LDS
was nianujilly operated. The volume of water removed by the pump over the time period of
leakage collection suggesied an average leakage rate through the Cell 4A upper liner of aboul 40.3
gallons per day (gpd). The leakage rate limit for the eurreni Cell 4A water depth of 26.5-teet on
Mr. Steven Landau
November 25, 2009
Page 3
the upper liner was about 500 gallons/acre-day or about 20,(KK) gpd. This indicates a good liner
performance and minimal leakage.
In a lelephone conversation with you on November 24. 2009 we discussed the items above. You
committed that DUSA would fully respond to this letter within 45 days of receipt. Please contact me ifyou
have any questions.
Sineerelv,
.'•'^Vi:^LnA Ar i*^^--:^^—
David A. Rupp. P.E. ^"""^-^
Geotechnical Services Secrion
F:\driipp\DtIS.A-. Lii,peciion.'!\Surety\2(]l)9\kFI 11-09 dof.
MINES
Denl&Dn Mines Corp.
6425 S. Highway 191, PD Box 8D8
Blanding, UT 8«11
USA
Tel :435 67B-2221
Fax : [phone]
www.,denlSDnmlnes.com
Memorandum
To: David Turk cc: Central Files
From: Ryan Palmer
Date: 3/31/09
Re: Cell 4A leak Detection System
This report is being submitted In order to stay in compliance with the BAT monitoring system. The BAT
states the following will occur if an equipment failure takes place, Mill management will be notified, description
of the failure and the root cause of failure will be documented in a report to mill management. The equipment
was not running at capacity causing the head in the LDS to exceed the established limit of 12 inches above the
Secondary Flexible Membrane Liner, which on the readout is 25 inches. This exceedance created a system
failure.
On March 30"^ at approximately 1050 AM the LDS on C4A was found alarming. The alarm is sel to go
off al 25" of head in the leak detection pipe. When t arrived the readout said 26.5" the pump was on but the flow
meter wasn't registering the flow. New flow meter was installed a few days prior so we thought the pump had
started to go OLit which would account for the low yield of solution being pumped. The pump was pulled but
looked like it was just fine. We placed the pump back in the pipe and tried to pump again thinking maybe
something was clogging up the intake on the pump like crystal formation. When the pump was restarted it
seemed to pump slightly belter but not what it should. At this time it was getting late in the day and the decision
was made to allow the pump to try and pump overnight and see if the pump would pick back up.
Upon arriving the morning of March 31 "^ the LDS was found to worse off than the day before. The
readout was in the 40 plus inches of head. It was decided the pump must be worn out so we again pulled the
pump. We tried running the pump through clean warm water out of a 60 Gallon drum, the pump performed
better than It did in the pipe so again It was thought nothing was wrong with the pump. After discussion we
decided to place a new pump in the pip© just to make sure it wasn't the pump. The new pump went in and it
also struggled much the same as the old pump did. After further talking, the electrician suggested reversing the
electritial connection on the pump. This was done and the pump began pumping at a very high volume where It
should have been pumping all along.
We are assuming that when an electrical contractor was doing some work at the substation by C4A
LDS they must have inadvertently switched the wiring on the supply end. So when our in house electrician
switched the pump connection end the pump was able to perform at full capacity once again. We feel that the
other pump which was taken out ofthe LDS Is still in good working condition and will be maintained as the
backup pump for this system.
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Photo 1. Inflow onto Cell 4A beach, near the northern dike.Photo 2. Spray lines for evap assistance in Cell 4A.
Photo 3. Tailings slurry influent. Cell 4A Photo 4. Former high water line. South dike of cell 4A.
Photo 5. Beach area on Cell 4A. Looking northwest.Photo 6. Wooden ramp for liquid influent and effluent from barge pump. Cell 4A.
Photo 7. Barge Pump discharge above or north in photo of influent line to Cell 4A.
Note northern line is not on rub sheet.
Photo 8. Cell 4A LDS pump flowmeter and totalizer prior to beginning pump out test.
Begun at 251,210 gallons end at 253,955 in 68 days since last pumped = 40.3 gpd.
Photo 9. Wooden approach bridge to barge Cell 4A. Note green discharge from
smaller diameter white pipe, pumped from LDS sump.
Photo 10. Cell 3. Mound of material above dike, disposal of metal containers. West
side of Cell 3. Other mounds higher than dike can be seen in photo 12 below.
Photo 11. A northern and most west corner marking for Feedstock Storage Area on
northern side of storage area. Most northern marker is about 100’ due north at fence.
Photo 12. See note above. High mound on left. Solution pool in Cell 3.
.
Photo 13. Photo 14.
Photo 13. View from the east side of a stockpile. Feedstock possibly encroaching
northern fence of storage area. Cannot differentiate feedstock for border berm soils.
Recommend DUSA establish SOP for minimum distance to fences
Photo 14. View from the west side of same stockpile. Feedstock possibly
encroaching northern fence of storage area.
Photo 15. Photo 16. New decon pad. Steel channel tops steel liner. Monitoring port looped by
vacuum hose. Channel from wash area above not currently connected.
Photo 15. View from the east side of a stockpile, north of the storage area
northern fence line. Feedstock possibly penetrating northern fence of storage
area. Cannot differentiate this material whether feedstock for border berm
soils. Recommend DUSA establish SOP for minimum distance to fences
Photo 17. Better view of the channel steel topping the exterior concrete wall of the
new decontamination pad.
Photo 18. No Photo.
Photo 18. End of Run. Meter read elevation of -0.1” at shut-off. After shut-off drainage
flow brought meter back to +0.5”. Total gals 253,955. Pump run time can be viewed, if
needed, by expanding photograph electronically.No Photo.