DRC-2010-003909 - 0901a068801a51a9

--- ••• •> State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieiilenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director DRC-2010-003909
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Direcior
TO:
FROM:
DATE:
SUBJECT:
MEMORANDUM
File-DUSA
Construction of Cell 4B, and Other Misc. Items
Dave Rupp '^^p^
July 7, 2010
Denison Mines (DUSA) White Mesa Uranium Mill
Cell 4B Construction Project: Site Visit 06-28-2010
On June 28, 2010 I visited the site and met with Messrs. Ryan Palmer, David Turk, Steve Snyder and
Richard Bartlett of DUSA.
Cell 4B Construction:
On June 28, 2010 I visited the Cell 4B project construction site with David Turk of DUSA. It was a
pleasant weather day, with the ambient temperature roughly 85° F. There was a slight breeze, soil was
generally dry, and dust could be kicked up by traffic. About 30 contractor workers were on site. The
attached photographs, F:\DUSA\Photos Taken at DUSA June 28, 2010.doc, depict the current scenario.
Regarding Cell 4B, the GCL and the LDS sub-liner work has just begun, with only a few panels of each
installed. The liner is being placed on the eastem dike. The work scheduling status is unknown. However,
the excavation work is probably behind schedule, as on May 4, 2010 this contractor had expressed to me a
hope they'd be done with bottom excavation in 2-months. See photo nos. 5, 12-15.
The liner contractor is independent from the excavator. The superintendent is Mike Beaman of AEGL.
This company is headquartered in Cleveland, OH. Mike is from Buffalo, NY. Robert Kowey is the
superintendent of the excavation contractor, KGL. Stewart Irwin is the project inspector for GeoSyntec.
Stewart seems to be very detailed in the inspection, and his QA role, for proper results, appears to be in
good hands. Steven Snyder of DUSA is the site representative for the mill.
The liner contractor seems to be following proper subgrade pre-wetting and post-wetting procedures for the
GCL. The preliminary moisture content (MC) test results of the GCL, by micro-waving cut samples, are
about 80% water content by weight. The specification is 50% MC minimum. Photo Nos. 3, 4, and 9-12
show liner work.
Earthwork subgrade completion to smooth grade on dikes was being done by a long armed crawler
operating with a narrow roller. See photo no. 8.
195 Nonh 1950 West • Salt Lake City. UT
MaiUng Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
WHH'. deq. mah.iiuv
Printed on 100*^' recycled paper
MEMO
DUSA Cell 4B Construction and Misc. Other Items
July?, 2010
Page 2
Misc. Items:
1. ISL Disposal. Non-barreled ISL debris was delivered onto Cell 3 to prepare for disposal.
However, the backhoe was temporarily broken down, so burial could not take place that day. The
main concem regarding ISL waste is barreled waste. DUSA had sent us notice regarding this
disposal action. According to Mr. Turk, they expect large amounts of similar material this July.
See photo nos. 1 and 2.
2. Boundaries for Staging of Feedstock Material. Feedstock material had been removed from the
feedstock area fence. Photo no. 15 shows this separation on the northern feedstock fence line.
This appears to meet the new requirements in the DMT Plan of a 4-foot separation.
3. New Decontamination Pad Concrete Tank. Photo no. 16 shows this tank is not being used, per
current requirements. Mill personnel were curious as to the status of DRC approval.
4. Liner Leakage into the Cell 1 Leak Detection System (LDS): DUSA submitted notification of liner
leakage by letter dated June 7, 2010 (DRC-2010-003526). According to the mill personnel
mentioned above, the water level in Cell 1 has been lowered, and some small tears were found and
repaired. The mill staff did not describe to me the root cause of the FML damage.
According to mill staff, since lowering the water level in the cell, the LDS went dry on 6-22-2010,
the LDS is still dry, and possible leaks, from small tears, may exist in the NE comer of cell. Mill
personnel stated they plan to remove all soil cover above water on east dike, examine the FML for
liner defects, and later may examine the entire perimeter for liner defects.
Some current requirements for DUSA regarding liner leakage in DMT regulated cells is given in
the currently approved Liner Maintenance Procedure (LMP) and the Ground Water Discharge
Permit noted below:
LMP (Revision 1 (10-18-09)):
Any leak, hole or other damage to tlie liners in Cells 1, 2, 3 and the Roberts Pond will be
reported orally to the Executive Secretary within 24 hours of die discovery and in writing
within 5 days of the discovery. The oral and written notifications will include a
notification and description of the failure in accordance with Part I.G.3.(a) of the GWDP
and be in accordance with R317-6-6.16.C(1) of the regulations. In addition to the
descriptive information about the failure, a plan and schedule for the FML repair will be
included with the notification to the Executive Secretary (in accordance with Part
I.G.3.(c) of the Permit).
Ground Water Discharge Permit (17 June 2010):
I.E.7.f:
Inspections of Tailing Cell and Pond Liner Systems - the Permittee shall inspect the liner system at
Tailing Cells 1, 2, and 3 on a daily basis pursuant to the requirements of Sections 2.1 and 2.2 ofthe
currently approved DMT Monitoring Plan. The Permittee shall conduct visual inspections at the
Roberts Pond on a weekly basis. In the event that any liner defect or damage is identified during a
liner system inspection, the Permittee shall: 1) report and repair said defect or damage pursuant to
Part I.G.3 by implementation of the currently approved Liner Maintenance Provisions, and 2)
report all repairs made pursuant to Part I.F.2.
MEMO
DUSA Cell 4B Constmction and Misc. Other Items
July?, 2010
Page 3
I.F.2:
Routine DMT Performance Standards Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT perfonnance standards monitoring required by Parts
I.D.3 and I.E.? of this Permit. DMT monitoring shall be conducted in compliance with this
Permit and the currently approved DMT Monitoring Plan. When a liner repair is performed
at the Roberts Pond or any DMT impoundment, a Repair Report is required by the Liner
Maintenance Provisions. This Repair Report shall be included with the next quarterly DMT
Report. Said monitoring reports and results shall be submitted for Executive Secretary
approval on the schedule provided in Table ?, above [same schedule as quarterly monitoring
reports].
5. Cell 2 LDS Leakage: Seven-inches of water persists in the LDS of Cell 2. This item is being
pursued by D. Henderson of DRC. During the inspection, R. Palmer of DUSA remarked that:
a. Peristaltic pumping did not produce any water discharge from the LDS.
b. It seems that the bottom of the LDS is too irregular to support a pump.
c. The method of measuring the ?-inch leakage depth has been by raising a graduation
marked blow-tube, near the side of the LDS casing.
-END-
Enclosure: Photographs
Cc: D. Henderson
P. Goble
F:\drupp\Denison MinesXCell 4B\Construction Inspections \MEMO 6-28-2010 lnsp.doc

Photos Taken at DUSA June 28, 2010 by Dave Rupp

Photo No. 1: ISL Debris in Cell 3. N.B: No barrels.
Debris located about eastern semi-center of tailings pond,
looking west.

Photo No. 2: ISL Debris. Same as above.
Photo No. 3: Towing GCL up-slope. East dike of C4B. Subgrade is being
Pre-moistened by the contractor prior to GCL installation.

Photo No. 4: Dike between C4A and C4B with dividing fence. Looking north,
Note the liner crew is at the top and bottom of dike. Hoisting liner from top.

Photo No. 5: C4B: Continuation of cut and fill. South dike looking west.
Photo No. 6: Pump Station in S.W. corner of C4A.

Photo No. 7: C4A 2/3 full of fluids. See beaches along north dike.

Photo No. 8: Long armed crawler operating narrow roller on north dike,
Near the N.E. corner of C4B. Depth of material left to excavate
can be seen in the distance of C4B.
Photo No. 9: Dozer at N.E. corner of C4B.

Photo No. 10: Note LDS trench at toe of E. slope of C4B.
(Looking south)

Photo No. 11: Shadow of track-hoe only cast on east C4B interior
dike. Hoe used as fulcrum pulley point for liner towing cable.
Photo No. 12: Same as above, from further west.
(Looking east).

Photo No. 13: A significant amount of material for excavation remains,
as seen from this northern view of the western half of tailings pond 4B.

Photo No. 14: Same as above, but viewing further east.
Photo No. 15: Soils being watered for use as fill in Cell 4B. Looking east.

Photo No. 15: Picture along north side of feedstock storage area.
Looking west.

Photo No. 16: Dry Cells of New Decontamination Pad Concrete
Storage Structure. Looking south.

F:\drupp\DUSA\Cell 4B\Constr Inspections\Photos taken at DUSA June 28, 2010.doc