DRC-2011-003865 - 0901a0688021e56c

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Phillip Goble - DUSA Tailings Cells 1 and 3 Leak Detection Systems - Meeting
Request
From: Phillip Goble
To: Frydenlund, David
Date: 3/31/2011 9:27 AM
Subject: DUSA Tailings Cells 1 and 3 Leak Detection Systems - Meeting Request
CC: Lundberg, Rusty; Morton, Loren; Roberts, Harold; Tischler, Jo Ann
Dave, j
We have reviewed the confirmation video logs of Cells 1 and 3 Leak Detection Systems included with the
December 27, 2010 DUSA letter and request a meeting with DUSA to discuss our findings and a path to move
forward.
The September 22, 2010 Confirmatory Action Letter (CAL) required submittal of the video logs. Item 3 under
Confirmatory Action states: ''If after review of both the above DUSA submittals, the DRC determines that
additional corrective action is required, DUSA will meet with the DRC to discuss and negotiate a plan of action
and schedule to resolve the Cell 1 LDS problems Identified/'
The DRC has concluded the following additional information is needed:
1. Item #2 of the September 22, 2010 CAL required DUSA to perform a video log of the Cell 1 LDS down to the
T-Joint. The video log showed that a T-Joint does not exist in the Cell 1 standpipe, instead only one collection
pipe enters the standpipe. We appreciate DUSA performing a video log of the Cell 3 LDS standpipe, even
though it wasn't contemplated in the September 22, 2010 CAL. The Cell 3 LDS video log showed that a
reducer was at the bottom of the standpipe and the contractor was not able to move its equipment through the
reducer into the collection pipe to show the collection pipe was free of debris. To verify that the Cell 3 LDS
is sensitive to detect leaks as early as possible. We request that DUSA perform another video log thru the
reducer down to the T-Joint and enter the 3" collection pipe and show it is clear to allow wastewater to move
freely. If debris is encountered, it must be removed and a confii'mation video log will be performed to show
it has been cleaned out successfully.
2. On August 10, 2010 DUSA added a 6-foot extension to the Cell 1 LDS standpipe. This extension raised the
standpipe off the ground surface, which should prevent stormwater and debris from falling into the standpipe in
the future. An extension must also be added to the Cell 3 standpipe to prevent stormwater and debris
entry. This extension does not need to be 6 feet, per say, but it does need to be sufficiently above the
ground surface.
3. Both the Cells 1 and 3 standpipes must also have an attached cap/cover to the standpipes, which will also
prevent debris from falling into the standpipe.
4. It is imperative that the LDS monitoring equipment/practice be able to physically reach the bottom of the
standpipe for the detection of fluid. The outcome of the video logs at the Cells 1 and 3 LDS demonstrates the
historic equipment and practice are unacceptable, and have not generated reliable and representation
monitoring information.
5. Therefore, it appears that the existing LDS system used by DUSA at Cells 1 and 3 cannot and will not be able
to comply with the requirements of Part II.C of the Permit. Further, the DRC is not confident that it is a reliable
detection method. Please replace this method with a more modern, reliable technique. It is absolutely vital that
the tailing cell leaks be detected as early as possible. This is an area where DUSA needs to be proactive and
not reactive. Please come prepared to discuss new detection equipment and methods for the detection of fluids
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within the Cells 1 and 3 LDS for our meeting.
We are free to meet with you anytime next week, please let us know what time work for you.
Thanks,
Phil Goble
Hydrogeologist
Utah Division of Radiation Control
[phone]
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