DRC-2011-007452 - 0901a06880278910

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•007452
Phillip Goble - License Condition 11.3 Language
From: Phillip Goble
To: Frydenlund, David
Date: 9/22/2011 7:40 AM
Subject: License Condition 11.3 Language
CC: Henderson, Dean; Roberts, Harold; Tischler, Jo Ann
Attachments: DUSA LC 11.3.LDSdoc-pg.doc
Dave,
Last week we promised we would get some revised language for License Condition 11.3 to you by Monday.
Sorry for not meeting our commitment. The DRC been discussing internally what is appropriate for the LDS
at Tailings Cells 1, 2, 3.
On June 1, 2011 DUSA submitted a Plan and Schedule for an update of the Cell 1 and Cell 3 Leak Detection
Systems. The DRC conditionally approved the Plan and Schedule on July 12, 2011.
After reviewing the DUSA September 8, 2011 Response Regarding the Cell 1 and 3 Inspection and Repairs, it
appears that the proposed LDS set up does not meet what DUSA originally proposed in the June 1, 2011 Plan
and Schedule, which was conditionally approved by the DRC on July 12, 2011.
For example in the June 1, 2011 Plan and Schedule, it states (emphasis added):
"Den/son agrees to remove the existing blow tube monitoring devices from both the Cell 1 and Cell 3 LDS •
standpipes. Each of the Cell 1 and Cell 3 standpipes would be fitted with level sensing probes coupled to:
a) A digital level readout
b) An alarm light
Each cell's LDS standpipe would also have a dedicated manual start pump. The level sensors would be set
to activate the alarm light when it detected any liquid level in the standpipe. Mill environniental
personnel would record the LDS liquid level during the weekly tailings inspection^ They would also check the
alarm light during the daily tailings inspection and if the alarm light indicated a liquid level during
any inspection, the environmental personnel would turn on the pump, and proceed with the
sample collection, fluid flow rate determination, and notice procedures consistent with Condition
11.3 of the Mill's Radioactive Materials License. "
Translation: The sensor would be set at the lowest point possible in the LDS Standpipe (bottom of
standpipe). When any water is detected by the sensor, the alarm light would be turned on, and DUSA staff
would: 1) Turn on the pump, 2) Collect a sample, determine fluid flow rate, and provide appropriate
notifications. Any LDS water observed would be pumped to an approved tailings cell.
In the September 8, 2011 submittal, DUSA describes that they have installed liquid level transducers at Cells 1
and 3 that have been wired to output to an alarm light when the transducer detects a pressure of 24
inches of water head. When the transducer detect a pressure of 18 inches of water, the pump will
turn on and will pump until it breaks vacuum (e.g. the pump will not operate if not submerged). In the
September 8,2011 submittal, DUSA also proposed revised language to License Condition 11.3 to support this
proposal.
• , • . • i
Translation: Water head will be allowed to accumulate up to 18" within the standpipe before the pump turns
on. The pump will pump until it breaks vacuum (e.g. the pump will not operate if not submerged). It's possible
that pumping could stop at 17". DUSA's equipment will not activate unless there is at least 18 inches ofwater
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in the standpipe. The alarm will not activate unless the water head in the standpipe reaches 24". DUSA will not
determine the root cause of the leak unless water is observed in the standpipe above 24 inches.
DRC Comment: DUSA is proposing a system that is similar to what is at Tailings Cells 4A and 4B, which were
constructed using Best Available Technology (BAT) (e.g. double lined HDPE FML). If the upper liner leaks,
wastewater will be stopped by the second liner. Tailings Cells 1 and 3 were constructed using Discharge
Minimization Technology (DMT) and was constructed with a single lined FML over crushed sandstone. If the
liner leaks, the wastewater could ultimately end up in the local aquifer (waters of the state) if not dealt with in a
timely manner. Therefore, the September 8, 2011 DUSA proposal for the LDS at Tailings Cells 1 and 3 can
not meet the Utah Water Quality Act (UCA 19-5-107), as follows (emphasis added)"
^^19-5-107. Discharge of pollutants unlav\/ful ~ Discharge permit required.
(1) (a) Except as provided in this chapter or rules made under it, it is unlawful for any
person to discharge a pollutant into waters of the state or to cause pollution which
constitutes a menace to public health and welfare, or is harmful to wildlife, fish or aquatic life,
or impairs domestic, agricultural, industrial, recreational, or other beneficial uses ofwater, or
to place or cause to be placed any wastes in a location where there is probable
cause to believe it will cause pollution.
The DRC appreciates DUSA willingness to improve the LDS at Tailings Cells 1 and 3; however, what DUSA has
proposed is not appropriate, a leak at Tailings Cells 1 and 3 need to be dealt with ASAP, not monitored with a
LDS. Therefore, please see the attached revised License Condition 11.3. This version of License Condition 11.3
was built using the original language used for the License Renewal sent to DUSA by e-mail on July 19, 2011.
I also included the items that DUSA and the DRC had previously agreed to. As stated in a previous
communication with DUSA, the DRC plans to go to public comment in a few weeks; therefore, we would like to
have a meeting (by phone) with you to discuss this further. We are free next week on Tuesday September 27
from 9:00 - 11:00, 1:00 - 2:00, and 3:00 - 4:30 and Thursday September 29, 2011 from 8:00 - 10:00 and 1:00 -
4:30. Please let us know what time works best for you.
Thanks,
Phil
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