DRC-2008-002441 - 0901a068809be14f

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MINES
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-DnNrsoN MrNBs (USA) Conp
Steven D. Landau
Manager, Environmental Affairs
cc: Ron Hochstein
Harold Roberts
David Frydenlund
David Turk
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Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel :[phone]
Fax : [phone]
www.denisonmines.com
November 4,2008
VIA Electronic MaiI (PDF) and Federal Express
Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Dear Mr. Finerfrock:
Re: State of Utah Ground Water Discharge Permit No. UW370004 (the (GWDP,,) White
Mesa Uranium Mill - Modification to the White Mesa Mill Taitings Management System
and Discharge Minimization Technology (DMT) Monitoring plan
Please find enclosed a proposed modification (in redline-strikeout format) to Page 7 of the White
Mesa Mill Tailings Management System and Discharge Minimization Technology (DMT) Monitoring
Plan. The pu{pose of this revision to the Plan is to accommodate the current configuration and
operation of the Cell2 Slimes Drain pumping system. More specifically, the Cell 2 Slimes Drain now
operates by means of a float mechanism and water level probe system which replaces the previously
described pump/timer system. This change is an improvement over the previous system and has been
made by Denison in order to maintain the average wastewater head in the Cell 2 Slimes Drain as low
as reasonably achievable, as required by Part I.D.3.b) of the GWDP. Upon approval of these changes
to the Plan, Denison will republish the revised Plan as Revision 7 and ascribe the appropriate date of
approval to the Plan.
If you have any questions or require any further information, please contact the undersigned.
Yours very truly,
78e
+
White Mesa Mill - Standard Operating Procedures
Book 1 I : Environmental Protection Manual, Section 3. I
9/08 Revision: Denison-6
PageT of37
(iii)The slimes drain pump in CellL 2 is activated and de-activated by a float mechanism
and water level probe systern. When the water level reaches the level of the float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which turns the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe and the float valve is located at five feet
above the bottom of the slimes drain standpipe.
Ar qS min*es Uefere Ueing
ingt+n
in aeees's
pipe The average wastewater head in the Cell 2 slimes drain is therefore-legsllhan
abeut.s feet' The depth te water ef abent 28,50 feet after reeharge ^nd is below the
phreaticsurfaceoftailingsCe||2,@out20feetbelowthe
water level measuring point on the slimes drain access pipe. As a result, there is a
continuous flow of wastewater from Cell 2 into the slimes drain collection system.
Mill managernent considers that the average allowable wastewater head in the Cell 2
slimes drain resulting from pumping in this mannera*thesqin*walvis satisfactory
and is as low as reasonably achievable.
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and fl tim€Fis-s,elproperlS
which is noted on the Weekly Tailings lnspection Form. If at any time the pump is
observed to be not working properly, it will be fixed or replaced within l5 days;
(v) Depth to wastewater in the Cell2 slimes drain access pipe shall be monitored and
recorded weeklyto determine maximum and minimum fluid headbefore and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthlybasis, the slimes drain pump will be tumed off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (l) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, bymeasuringthedepthto waterbelow thewaterlevel
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Awund LMF
tih+. o, eea
Liner Maintenance Provisions-Cells 1 ,2,3 and Roberts Pond Pt-tt ?lan
Inspections
ATyad'tT I
Tailings cells 1, 2, and 3 are the sulrject of comprehensive daily inspections which are
conducted by either the Environmental Technician or the Radiation Technician, as well
as once per shift Daily Operations Inspections which are conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daily inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan.
In each case, these inspections are recorded on inspection forms (Daily Inspection Data
Form and Operating Foreman's Daily Inspection Form, r'espectively). In addition, non-
recotded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this facility is observed on a weekly basis when the
Environmental or Radiation Technician visits the facility for the recording of water levels
at that location.
Training
All individuals performing inspections described in Sections 2.1 and 2.? of the DMT
Monitoring Plan must have Tailings Management System Training as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systems" inspection, inspectors are trained and required to observe
the conditions of the PVC liner. Because the PVC liners in Tailings Cells l, 2 and 3 are
sensitive to sunlight and can degrade as a result of prolonged exposure, inspectors are
cautioned to observe any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are trained to cover
small areas of exposure immediately, whereas, larger areas are reported to the radiation
Safety Officer to prompt the issuance of a work order to the Maintenance Department. In
keeping with this inspection requirement, inspectors are trained to observe any
degradation of exposed liners. Such degradation can be that caused by eiposure to
sunlight, abrasion due to erosive wave'action and/or any rips or tears in the liner material.
Given the fact that the liner material is provided with an earthen cover, erosive damage
and/or rips and tears are unlikely. Inspectors are trained to record all observations of
liner exposure or disrepair on the inspection report, as well as the date and nature of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HDPE) material which is nor
sensitive to sun damagc and, as such, is not covered with earthen material. In this case
the inspector observes the conditions of the liner to the extent that visual observation is
possible (i.e. above the water level and any visually observable near surface condition).
As is the case for the tailing cell inspections, the liner will be observed for any abrasion
due to erosive wave action and/or any rips or tears in the liner material.
AryrovraC by DaC- l+'o{ O.t. aa, AooA
Repairs
Repairs to PVC liners in Cells 1,2 and 2 and to the HDPE liner in Roberts Pond are made
on a case by case basis and usually involves the installation of a repair patch over the
damaged location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HDPE repairs are accomplished by use of an extrusion
welder. Subsequent to any repair of a liner, the repair location will be tested using a
"vacuum box" and soapy water to assure that the repair is acceptable. The observation of
bubbles through the repair seam while vacuum is being applied to the seam constitutes
seam failure and the repair must be redone until all se{uns are acceptable. In the case of
Cells 1, 2, and3, after a patch has been applied, the repair location must be covered with
earthen material, again to avoid exposure to sunlight. Adequate supplies of PVC and
HDPE liner material, repair material and vacuum test equipment are maintained either in
the Mill warehouse or the maintenance department. The continued availability of these
supplies will be verified as an element of the Quarterly Tailings Inspection conducted by
the Radiation Safety Officer or his designee'
Any leak, hole or other damage to the liners in Cells l,2,3and the Roberts Pond will be
reported orally to the Executive Secretary within 24 hours of the discovery and in writing
within 5 days of the discovery. The oral and written notifications wili include a
notification"and description of the failure in accordance with Part I.G.3.(a) of the GWDP
and be in aeooidande with R317-6-6.16.C(1) of the regulations. In addition to the
descriptive infonnation 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);
Repair Report
Each report will be signed by a Utah licensed professional engineer and will address the
following elernents as they apply to the case-by-case.repairs which are implernented:
o Repair narrative describing the nature of the damage and the repair work
. completed to repair the damage.
o Repair material type used to complete the repair
o Repair material description
o Post repairs test specifications
o Test Methods (ASTM or other)
o Daily reports during the repair work
o Repair test results
o QualityAssurance/QualityControl Information
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for opeiating and maintenance ofmonitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPF"CTIONS
The following daily tailings inspections shall be performed:
2.1. DaillzComprehensiveTailings lnspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
Page I of36
White Mesa Mill - Standard Operating Procedures
Book 1 l: Environmental Protection Manual, Section 3.1
9i08 Revision: Denison-6
Page2 of36
which includes a tailings cells map, and spaces to record observations, especiallythose ofimmediate
concern and those requiring coffective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" speciffing what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 44, Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation,Cell2
spillway, Cell 3 spillway, Cell 3 and 4A liquid pools and associated liquid return equipment, cell
leak detection systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections ofthe tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurrylines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell 3
or Cell 4A; the pond retum line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
Cell 1.
Cell2.
Cell3.
Cell4,A'.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
g) The Cell 2 spillway, Cell 3 spillway, Cell 3 and Cell 4A liquid pools and
associated liquid return equipment.
i)
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
b)
c)
d)
e)
h)
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 3 of36
j) Wind movement of tailings and dust
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weeklybasis, or more frequently if warranted, and will be used to direct dust
minimization activities.
k) Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells
and 44.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
n) An estimate of flow for active tailings slurry and SX line(s).
o) An estimate of flow in the solution retum line(s).
p) Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in the Cell 1 and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell4,A. leak detection is not allowed to be more than 1.0 foot
above the lowest point on the bottom flexible membrane liner (elevation 5556.14
feet amsl). I{ any of these observation are made, the Mill Manager should be
notified immedi tron svstem
m)
White Mesa Mill - Standard Operating Procedures
Book 1 l : Environmental Protection Manual, Section 3. 1
9i08 Revision: Denison-6
Page 4 of36
Whenever the leak d-etegtion system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
brm. This data will be used in accordance with License
Condition 11.3.B through 11.3.8 of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,{.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daillz Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designatqd by the Radiation Safety Officer, will perform an inspection ofthe tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notiff the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
White Mesa Mill - Standard Operating Procedures
Book 1 1: Environmental Protection Manual, Section 3.I
9/08 Revision: Denison-6
Page 5 of36
2.5. TailingsEmergencies
lnspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notiff your supervisor and the Mill Manager immediately. The
Mill Manager will then notiff Corporate Management, MSHA (303-23T-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1 . Weekly Tailings lnspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
") Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. The Cell4,A. leak detection system is monitored on
a continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The pressure transducer is calibrated
for fluid with a specific gravity of 1.0. The water levels are measured every hour
andtheinformationisstoredforlaterretrieval.The@to
the nearest 0.10 inch. The data collector is currentlyprogrammed to store 7 days
of water level information. The number of days of stored data can be increased
beyond 7 days if needed. @is downloaded to a laptop
computer on a weekly basis and incorporated into the Mill's environmental
monitoring data base, and into the files for weekly inspection reports of the
tailings cell leak detection systems
White Mesa Mill Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 6 of36
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If sufficient fluid is present in the leak detection system of any cell, the fluid shall
to the extent reasonably possible,record the
volume of fluid recovered. Any fluid pumped from an LDA shall be returned to a
disposal cell.
-f$SfB:rl€8ffit.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 1 1.3 C. of the Radioactive Materials
License,
For Cell4,A., under no circumstance shall fluid head in the leak detection
system sump exceed a 1-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow
Rates in the Cell4A leak detection system, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
exceed 24,160 gal day.maximum dailv LDS
aga cell soluti
to ine the maximum daily allowable LDS flow volume for
1,tt*o ) . a
Y//t i *-?
varying head conditions in Cell 44.
Slimes Drain Water Level Monitoring
Cell 3 is an active tailings cell while Cell2 is partiallyreclaimed with approximately
90Yo of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell2, which, based on construction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
If fluid is pumped from an LDS, th. flo* rut. rhull b.
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
PageT of36
(iii)The slimes drain pump in Cell2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewater head in the Cell2 slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feetbelow the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, cycling the pump more than 15 minutes every
hour can rgsult in more replacement costs for pumps and more resulting system
downtime;
(iv)Cell2 slimes drain pump is checked weekly to observe that it is operating and
timer is set , which is noted on the Weekly Tailings Inspection Form.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
wastewater in the Cell2 slimes drain access shall be monitored and
weeklV to determine maximum and minimum fluid head
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
[ {ui)O, a monthly basis, the slimes drain pump will be turned off and the wastewater in
\ the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
I the water level has stabilized (based on no change in water level for three (3)
I successive readings taken no less than one (1) hour apart) the water level of the
I wastewater will be measured and recorded as a depth-in-pipe measurement on the
I Monthly Inspection Data form, by measuring the depth to water below the water level
t measuring point on the slimes drain access pipe;
(v)
(vii)
(viii)
No process liquids shall be allowed to be discharged into Cell 2;
If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year,the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell3 and Cell4A are currently active, no pumping from the Cell3 or Cell
4,{ slimes drain is authorized. Prior to initiation of tailings dewatering operations for
Cell 3 or Cell 4A, a similar procedure will be developed for ensuring that average
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 8 of36
head elevations in the Cell 3 and Cell 4A slimes drains are kept as low as reasonably
achievable, and that the Cell 3 and Cell 4A slimes drains are inspected and the results
reported in accordance with the requirements of the permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 3 and 4A and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. 821, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 1, 3 and 4A, and Roberts
Pond are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell I . The elevation of the metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3 and cell4A, the Reference Point is a piece of metal rebar
located on the south dike of Cell 3. The elevation at the top of this piece of rebar
(the Reference Point Elevation for Cell 3 and cell4,A') is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell 1 and Roberts
Pond, this is typically on the road on the Cell 1 south dike between Cell 1 and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3 and Cell4,A', this is typically on the road on the Cell 3 dike
approximately 100 feet east of the Cell 3 Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey lnstrument is level by
centering the bubble in the level gauge on the Survey lnstrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 and cell4,A. Reference Point. The Assistant will ensure that the
Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor
has established a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.I
9/08 Revision: Denison-6
Page 9 of36
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell3
A stake has been place in the central area of the south dike of Cell 3. The
Assistant will walk perpendicular to the dike from the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
B.Cell4,A.
The Assistant will walk down the slope in the northeast corner of Cell 4,{ and
place the Survey Rod at the liquid level.
C. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
D Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Northins Eastins
Roberts Pond 323,041 2.579.697
Cell 1 322.196 2.579.277
Cell3 320.s08 2.577.760
Cell4,{320.300 2,579,360
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l0 of36
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey lnstrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at orbelow the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area lnsoections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
b) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
White Mesa Mill - Standard Operating Procedures
Book I 1 : Environmental Protection Manual, Section 3. 1
9/08 Revision: Denison-6
Page 11 of36
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches 1,2 and3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm2 should be checked
for stability and signs of distress.
Sedimentation Pond.
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
Overspray Dust Minimization
The inspection shall include an evaluation of overspray minim ization,if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
,)
b)
c)
d)
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Ser:tion 3.1
9/08 Revision: Denison-6
Page l2 of36
e) Remarks
A section is included on the Monthty Inspection Data formfor remarks in which
recommendations can be made or observations of concern can be documented.
fl Summary of Daily, Weekl.y and Quarterly Inspections
The monthly inspection rvill also summaize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typ,ically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safely Department, havirrg the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspectiorr should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
a) Embankrnent Inspection
The Embankment inspeclion involves a visual inspection of the crest, slope and toe
of each dike for moveme.nt, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Mainterrance Review consists of reviewing Operations and
Maintenance activities perrtaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Revie,w consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual. Sbction 3.1
9/08 Revision: Denison-6
Page 13 of36
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary ofthe annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
ln the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concem. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 14 of36
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the colrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1" of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake city, Utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
,) Tailings Cells I and 4A
The freeboard limits are as per January 10, 1990 Drainage Report for Cells l
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell 1.
(ii) A liquid maximum elevation of 5,596.4 feet mean sea level in Cell4,{.
b) Tailings Cell 3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(iD An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the number oftons required
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l5 of36
(iv)
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 123.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the PMP
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the.calculation sheet filed in the Mill Central File.
c) Tailings Cell4A
The freeboard limit for Cell 44' is determined annually using the following
procedure:
The Cell 4,{ design includes a concrete spillway between Cell 3 and Cell 4,{,
with the invert elevation 4 feet below the top of the Cell 3 dike, at an elevation
of 5604.5 feet amsl. Should Cell 3 receive the fulIPMP volume of L23.4 acre
feet of water, approximately 62 acre feet of that volume would flow through
the spillway into Cell 4A..
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of
water (40 acres, plus the adjacent drainage area of 3.25 acres, times the PMP of
10 inches). This would result in a total flood volume of 98 acre-feet, including
the 62 acre-feet of solution from Cell 3. The freeboard depth required for Cell
4.A. from the PMP event would be2.44 feet, plus a wave run-up depth of 0.77 feet
(from the 1990 Drainage Report), for a total freeboard requirement of 3.2 feet.
This calculation is illustrated on Attachment 4. The Groundwater Quality
Discharge Permit, No. UGW370004, for the White Mesa Mill requires that the
minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2
feet below the top of liner. The freeboard for Cell 4,{ would therefore be 5595.3
amsl (top of liner 5598.5 -3.2 feet).
The calculation of the Total Required Freeboard for Cell 4,{ will be calculated
annually and the calculation sheet filed in the Mill Central File.
White Mesa Mill - Standard Operating Procedures
Book 1 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l6 of36
d) Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations shouldbe performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTINGREQUIREMENTS
In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
White Mesa Mill - Standard Operating Procedures
Book 1 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l7 of36
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part 1.F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph for each calendar year of the depth to wastewater in the Cell2 slimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, quarterly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill * Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 18 of36
APPENDIX A
FORMS
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White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3. I
9/08 Revision: Denison-6
Page23 of36
APPENDTX A (CONT)
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date:lnspectors:
l. Pond elevations (msl,ft) Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
5597
Cell3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation
5570
5564
(c)Depth of Water above FML ((a)-(b)
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
s612.34
2. Slimes Drain Liquid Levels Cell2 Pump functioning properly
Pump Timer set at l5min on 45 min off
Depth to Liquid pre-pump
Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump:
Post-pump head is 38'-Depth to Liquid Post-
pump:
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
9/08 Revision: Denison-6
Page 24 of 36
Observation:
Cell 1 Cell2 Cell3 Cell4,A.
Is LDS wet or dry?wet drv wet drv wet drv wet drv
If wet, Record
liquid level:
Ft to
Liouid
Ft to
Liouid
Ft to
Liquid
Ft to
Liouid *
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate
Volume
Flow Rate
Volume
Flow Rate_
Volume
Flow Rate_
Was fluid sample
collected?
yes_no yes_no yes_no yes no
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
* Does Level exceed l2 inches above the lowest point on the bottom f'lexible nrembrzrne liner (elevation
5556.14 amsl)'l n0 _ yes
If Cell4A leak detection systen] level exceecls 12 inches ahove the lox,est point on the bottonr flexible
rnembrane liner (elevation 5556.14 amsl), notity supelvisor or Mill rnanager inrrnediatelv.
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 25 of36
APPENDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
1. Slurry Pipeline:
Pipe Thickness:(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch I Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing yes_no yes_no yes no
Erosion yes no yes no yes noUndesirable yes_no yes_no yes_no
Vegetation
Obstruction of Flow yes_no yes no yes_no
Diversion Berm:
Stability Issues
Signs of Distress
Comments:
yes no
yes no
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book 1 1: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: yes
9/08 Revision: Denison-6
Page26 of36
no
Overspray carried more than 50 feet from the cell: yes
If "yes", was system immediately shut off? yes.
Comments:
5. Remarks:
6. Settlement Monitors
Cell2 Wl:
Cell2W2:
Cell2 W3:
Cell2 W4:
Cetl2W7-C:
Cell2 W7N:
Cell2 W6C:
Cell4A-Toe:
Cell3-2C:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell2 East:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell3-2S:
Cell3-lN:
Cell3-lC:
Cell3-1S:
Cell3-2N:
Cell2W5-N:
Cell2 W6N:
Cell2 W4N:
Cell2 W5C:
7. Summary of Daily, Weekly and Quarterly Inspections:
8. Monthly Slimes Drain Static Head Measurement for CelI2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page27 of36
PPENDTX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activites:
4. Summary:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
Week of
Inspector:
9/08 Revision: Denison-6
Page 28 of36
APPFNDTX A (CONT.)
OR.E STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
through Date of Inspection:_
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:_ no:
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers :.
yes:_ no:_
to--*tr f.. g., .*ditiors of containers):
Conditions of storage areas for materials:
Other comments:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page29 of36
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualiffing management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Dailyt'ailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concem exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and speciff the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concem is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one ofwhom will notify Corporate
Management. If dam failure occurs, notiffyour supervisor and the Mill Manager immediately. The
Mill Manager will then notiff Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 30 of36
,
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orienlation.
Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas ofconcern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern forponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,{ solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. [n Cells I and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas ofconcern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
White Mesa Mill - Standard Operating Procedures
Book 1 1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 3l of36
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern :
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
5.
6.
7.
8.
1.
2.
J.
4.
Cover area
Beach/tailing sands area
Solution as it exists
Pump lines
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 32 of36
9.
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
1. Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. A11 personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review ofthe
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
10.
11.
White Mesa Mill - Standard Operating Procedures
Book 11; Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 33 of36
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certiff that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 34 of36
APPENDD( D
FEEDSTOCK STORAGE AREA
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 35 of36
APPENDX E
TABLES
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 36 of36
Table 1
Calculated Action leakage Rates
for Various head Conditions
Cell44. White mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( sallons I acre / dav )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.s0
30 543.88
35 s87.46
37 604.01
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White Mes Mill - Sknau* O*utn, ,ro""J ?08 Revision: Denkon-,].
Page 2l of36
CONCERN Action Requlred
I white Mesa Mill - Shndard OpeEtin8 Procedues
Book I I : Environmnbl ProtectioD Maoul, Sedion l. I
908 Rcvision: Dcnisn.l
Page 22 ol 36
.. !hld:? |
[MAP OF TAILINGS AREA]
VII. DAILY Lf,AK DETECTION CHECX
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White Mesa Mill * Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page I of33
WHITE MESA MILL TATLINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring plan (the"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900419 (the"Radioactive Materials License"), as well as procedures fbr operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under Stateof Utah Ground water Discharge Permir No. 370004 for rhe Mill (the "GwDp;).
This Plan is designed as a systematic program tbr constant surveillance and documentation of theintegrity of the tailings impoundment system including dike stability, liner integrity, and rransport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas aL theMill' The Plan requires daily, weekly, quar terly, monthly and annual inspections and evaluations and
monthly repofting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily railings inspecrions shall be pertbrmed:
2.1 . Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connecred with the tirur tailings cells will beinspected. Observations will be made of the cuuent condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Racliation Technician is responsible for performing the daily tailingsinspections, except on weekends when the Shitt Foreman will perform the weekeni tailinlsinspections. The Radiation Safety Officer may designate other inclividuals with training, is
described in Section 2.4 below, to pertbrm the daily tailings inspecrion.
Observations made by the inspector will be recorded on Lhe Daily Inspection Data form (a copy ofwhich is attached in Appendix A). The Daily Inspection Dara tbrm conrains an in.spection checklist,
.3 .09I
gA
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 2 of 33
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concel'n and those requiring corective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" speciiying what the
concern is.and,what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell l, 2,3, and 44, Dikes l, 2, 3, 4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation, Cell 2
spillway, Cell 3 spillway, Cell 3 and 4A liquid pools and associated liquid return equipment, cell
leak detection systems, and the wildlife ponds.
Operational features of the tailings area are checked fbr conditions of potential concern. The
fbllowing items require visual inspection during the daily tailings inspection:
Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell I, Cell 3
or Cell 4A; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions l}om one cell to another.
Cell l.
Cell2.
Cell3.
Cell4.A.
Dike structures including dikes l, 2, 3, 4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 spillway, Cell 3 and Cell 4A liquid pools and
associated liquid return equiprnent.
Presence of wildlif'e and/or domesticated animals in the tailings area, including
watedowl and burrowing animal habitations.
Spray evaporation pumps and lines.
a)
b)
c)
d)
e)
c)
h)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 3 of33
j)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated fbr conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the tbllowing: I ) areas of tailings subject to blowing andlor wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evapomtion
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
and 4A.
k)
r)
m)Locations of slurry and SX discharge within the active cells. Slury and SX
discharge points need to be indicated on the tailings cells map included in the
Daily lnspection Data form.
n)An estimate of t'low fbr active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).o)
p) Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
Jhllllig3lil-tor tqrther action when evaluating the measurements in any of.tfis
feak detection systems is a sain of more than 12 inches in ?4 hours-If this
immediately and the
leak detection system pump started.
Whenever the leak detection system pump is opcrating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition I L3.B through I 1.3.E of the Mill's Radioactive Materials License, to
determine whether or not the tlow rate into the leak detection system is in excess
of the License Conditions.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
7/08 Revision: Denison-4
Page 4 of 33
q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands lbr
Cells 3 and 4A.
Items (a), (m), (n), and (o) are to be done only when the Mill is operaring. When the Mill is down,
these items cannot be performed.
2.2.Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be rccorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings al'ea at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Saf'ety Oflicer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings erxergency has occurred.
2.4.Training
All individuals pertbrming inspections described in Sections 2. I and 2.2 above must. have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure tbr
pertbrming the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certitication form, indicating rhat training
has been received rplative to his/her duties as an inspector.
2.5. TailingsEmergencies
lnspectors will notify the Radiation Safety Officer and/or Mill management immediately if, cluring
their inspection, they discover that an abnormal condition exists or an event has occumed that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
White Mesa Mill - Standard Operating Procedurcs
Bc.rok I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 5 of 33
Any rnajor catastrophic eveuts or conditions pcrtaining to thc tailings arei] should be reported
imrnediatcly to the Mill Manager or the Radiatitxr Sat'ety OfTicer, one of whorn will notily Corporate
Management. If darn f aiiure occurs, notily your supervisor and the Mill Manager immediately. The
Mill Manager will then notity Corporate Managemcnt, MSHA (303-231-5465), and the State o{'
Utah, Division of Dam Saf'ety (801-538-7200).
3. WEEKLY TAILINGS AND DMT TNSPEC'TION
3.1 Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Sat'ety Department and include the
tollowing:
Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. Il marked wet, thc liquid levels need to bc measured and
reported. ln Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed lrorn the system which wilt indicate the presence of
solutions in the LDS system. Ihr; Cell44 lglk*dp-tssllitt;y$11x1ls_J1jlg-rirUg$-A1
a ciin-LlnupqI"-.fra$ir'h:"*g$g_Jr- a J?rg.sr*{S-."fiA*$dUtff-_"l"hal "_{-Wtt""ygX*ky*
tili1g]-Ul!-l11l"Llrr un clc,. trr.rrric' d;11rt glrl!_r',r tlI.*lJ1c_ lqlqglqy!:L3rc$r,dsrt1*lxl S"_v_!:ty
urinutr anql-tlls_!.nliltlurg1,n !,s-ptprid kL!*tqt:fst{iqyi*!* "1 S,!s are
$lgiit$$*Xl,lr)-llir nSflig$ir,-I0 inch.*Jlfe da1i1g1lle$urr is nllrlutlb B$grarnrrrecltu
"3t*{s":*day;".ot:ytL],sr-k-y-p:!jL*trnlati cn,-'.lk-l rtl1;bgl:l)J.t},lygs[,ls{sd-d*H-qa,ilr*
in*rvased hslt)rldJ cloy$-d-$rsilsd"_lhq.lyill&r la"yddiitiui-rk):v-jdtadslr*io_a
kmmr.-cs$]rul$r:--0fi--i,- -w"eskly*M*into thr Millls
f1l-vtJgjlltlgglal LUOlliltll-ltrg rl;tta-h.!ru, ;rnrl i-ltrr thc_-lilr".1lirr 11gckl;i*l!$flgsliftn
rpufifi.ildlhg-iail,txg$-srLilsirk ds!:,e-1i{"}n-i'lyllgu:t.lt
If sufticient fluid is present in the leak detectitx system of any cell, the tluid shall
be pumped trorn the LDS, to the extent reasonably possible, and record thc
volume of fluid recovercd. Any fluid pumped lrom an LDA shall be returned to a
disposal cell.
Il fluicl is pumpecl from an l,DS, the flow rate shall bs calculated by dividing the
recorded volume of fluid recovered by the elapsed time since lluid rvas last
pumped or increases in thc I-DS fluid levels wcre recordecl, whichevcr is thc
more recent. This calculation shall be documented as part o1' the weekly
inspection.
Upon thc initial pumping ol fluid l'rom an LDS, a fluid sample shall bs collectecl
a)
| -'-
I Deleted: has i blow tlrb!'. which hasi been mersured and marked. Once
i solutions have beetr identiFied by blowing
air into the lubc at a giyetr depth, the hrbe
is pullt'd fronr thc lubing enciscnrclt and
the mersurenpnts arc extracted lroot lbe
rnarkcd ubing.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Ilevision: Denison-4
Page 6 of 33
and analyzed in accordance with paraglaph I 1 .3 C. of the Radioactive Materials
License.
For Cell 4A', under no circumstance shall fluid heacl in the leak detection
system sump exceed a l-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow
Rates in the Qpll 44, leak detection system, the toral volume of all fluids
pumped fiom the LDS on a weekly basis shall be recovered fi'om the data
collecto$ and that int-ormation will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table I in
Appendix A, to determine the maximum daily allowable LDS tlow volume tbr
varying head conditions in Cell 4A..
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is an active tailings cell while Cell 2 is partially reclaimed with approximately
9OVo of the surface covered by platform till. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2 has a purnp placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slirnes drain is
38 f'eet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surf'ace level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point ol the
FML in Cell 2, which, based on construction reports, is at a depth of 39 I'eet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slirnes drain pump in Cell 2 is on a timed system, under which it pumps tbr 15
minutes each hour, thereby allowing the slimes wastewater to recharge tbr 45
minutes betbre being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 t'eet
betbre each pumping and is pumped to a depth of 3&feet after each pumping, in each
case measured below the water level measuring pointon the slimes drain access pipe.
The average wastewater head in the Cell 2 slimes drain is therefbre about 5 f'eet. The
depth to water of about 28.50 feet atier recharge is below the phreatic surface of
tailings CeLl2, which is at a depth of about 20 f'eet below the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous tlow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisf'actory and is as low as reasonably
bsesd---:: -:::l
[:9E:* ry:'y:g--- - --;
White Mesa Mill - Standa;d Operating Procedures
Book I l: Environmental Protection Manual, Section 3. I
7/08 Revision: Denison-4
Page 7 of 33
achievable. Based on past experience, cycling the pump more than l5 minutes every
hour can result in more replacement costs tbr pumps and mote resulting system
downtime;
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the Weekly Tailings Inspection Form.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum f'luid head before and atler a
pumping cycle, respectively. All head measurements must be made tiom the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize tbr at least 90 hours. Once
the water level has stabilized (based on no change in water level tbt three (3)
successive readings taken no less than one (l) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
rneasuring point on the slimes drain access pipe;
(vii)
(viii)
No process liquids shall be allowed to be discharged into Cell2;
If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head fbr the prcvious calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requiremcnt to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Cell 44 are currently active, no pumping tiom the Cell 3 or Cell
4,A. slimes drain is authorized. Prior to initiation of tailings dewatering operations for
Cell 3 or Cell 4A, a similar procedure will be developed for ensuring that average
head elevations in the Cell 3 and Cell 44. slimes drains are kept as low as reasonably
achievable, and that the Cell 3 and Ce[14A, slirnes drains are inspected and the results
reported in accordance with the requirements of the permit."
Wind Movement of Tctilings
An evaluation of wind movemenl of tailings or dusting and control measures
shall be taken if needed.
TaiLittgs Wastevvater Pool ELevation Monitoring
Solution elevation measurements in Cells l, 3 and 4A and Roberts Pond are to be taken by
survey on a weekly basis as tbllows:
c)
d)
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Book I 1: Environmental Protection Manual. Section 3.1
7/08 Revision: Denison-4
Page 8 of 33
(i) The survey will be pertbrmed by the Mill's Radiation Saf'ety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be pertbrmed using a survey instrumenr (the "survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. 82l, ot' equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 fbot incremenrs;
(iii)The rel'erence Points (the "Retbrence Points") for Cells l, 3 and 4A, and Roberrs
Pond are known points established by prof'essional survey. For Cell I and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell l. The elevation of the metal disk (the "Reference Point
Elevation") tbr Cell I and Roberts Pond is at 5,623.14 f'eet above mean sea level
("FMSL"). For Cell 3 and cell 4A, the Ref'erence Point is a piece of metal rebar
located on the south dike of Cell 3. The elevation at the top of this piece of rebar
(the Ret'erence Point Elevation tbr Cell 3 and cell 4A) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey Instrument in a location where both the
applicable Retbrence Point and pond surface are visible. For Cell I and Roberrs
Pond, this is typically on the road on the Cell I south dike between Cell I and
Roberts Pond, approximately 100 t'eet east of the Cell l/Roberts Pond Ret'erence
Point. For Cell 3 and Cell 4,A., this is typically on the road on the Cell 3 dike
approximately 100 leet east o[ the Cell 3 Ret'erence Point;
(v) Once in location, the Sulveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Ref'erence Point (on thc
metal disk on the Cell l/Roberts Pond Ret'erence Point and on the top of the rebar
on the Cell 3 and cell 4A Relerence Point. The Assistant will ensure that the'survey Rod is vertical by gently rocking the rod back and tbrth until rhe Surveyor
has established a lcvel reading;
(vii)The Surveyor will lbcus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number ol l'eet the Survey Instrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surtace ol'the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell3
A stake has been place in the cen[al area of the sourh dike olCell 3. The
Assistant will walk perpendicular to the dike fl'orn the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 9 of 33
B.Cell4A
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
C. Cell I
A mark has been painted on the north side of the ramp going to the pump
platform in Cell l. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one endjust touching the liquid surface; and
D Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surflace.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points tbr Roberts Pond and the Cells are:
Northins Easting
Roberts Pond 323,04r 2.579.697
Cell I 322.t96 2.579.277
Cell3 320,508 2.577.760
Celt4A 320,300 2,519,360
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
iust touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will tbcus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
reprcsents the nurnber of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Ret'erence Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation tbr the Cell or Roberts Pond and subtracting the Pond Surtace Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3. t
7/08 llevision: Denison4
Page l0 of33
e) Sumnrury
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailittgs and DMT Inspection torm. Based on historical observations, the FML at the Pond
Surface Reading area tbr Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be pertbrmed by the Radiation Safety Department, to
conflrm that:
the bulk feedstock materials are stored and maintained within the defined area desclibed in
the GWDP, as indicated on the map attached herero as Appendix D; and
all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Are Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in storcd materials from this
requirement. or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within l5 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Sal'ety Otfrcer or his designee from
the Radiation Sat'ety Department and recorded onthe Monthly Inspection Data frtrm, an example of
which is contained in Appendix A. Monthly inspections are to be pertormed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The tbllowing items are to be inspected:
a)
b)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
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Page ll of33
Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be rnonitored will be determined by the Radiation Saf'ety
Of'ficer or his dcsignee tiom the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly fbr sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion bermZshould be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities areasedimentation pond shall be summarized
tbr the month.
Ov e rs p ray D ust M inimizat io n
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 f'eet tl'orn the cell, the overspray system should
be irnmediately shut-otT.
Rentarks
A section is included on lhe Monthly Inspection Dcta form fbr remarks in which
recommendations can be made or observations of concern can be documented.
f) Sttmmary of Daily, Weekly an.d Quanerly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
a)
b)
c)
d)
e)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 12 of33
The quarterly tailings inspection is performed by the Radiation Safety Olficer or his designee tiom
the Radiation Saf'ety Department, having the training specitled in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was perfbrmed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as tbllows:
Embankment Inspection
The Embankment inspection involves a visual inspection of the ct'est, slope and toe
ofeach dike tbr movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
O p e rat io n.s/M aintenanc e Rev iew
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis,
Constructiott Review
The Construction Review consists of reviewing any construction changes or
moditlcations rnade to the tailings alea on a quarterly basis.
Sum.m.ary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspectiort Data torm. An example of the Quarterly lnspection Data
tbrm is provided in Appendix A.
6. ANNUALEVALUATIONS
The following annual evaluations shall be pertbrmed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings managcment system is pertbrmed by a registered
professional engineer (PE), who has experience and training in the area ofgeotechnical aspects of
a)
b)
c)
d)
White Mesa Mill - Standard Operating Procedutes
Book I l: Environmental Protection Manual, Section 3. I
7/08 Revision: Denison-4
Page l3 of33
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings recolds fbr the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and coresponding dikes will be inspected fbr signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were pertbrmed tbr the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries ol'observations of concern and the con'ective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September l" of every year to:
6.2.
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salr Lake City, Utah 841 l6-3156
Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data genelated
tiorn this survey is reviewed and incorporated into the Annual Technical Evaluation Report of lhe
tailings management system.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3
7/08 Revision: Denison-4
Page 14 of 33
6.3 Freeboard Limits
a)Tailings CeLls I and 4A
The lreeboard limits are asper January 10, 1990 Drainage Reportfor Celts I
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615,4 feet mean sea level in Cell l.
(ii) A liquid maximum elevation of 5,596.4 feet mean sea level in Cell 4A.
TaiLings Cell3
The fieeboard limit fbr Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surlace will be determined.
(ii) An estimate of the maximum tons of dr.y tailings to be generared during
the next l2 months will be made. Thisestimare is multipliedby 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the nurnber ol'tons required
to reduce the pool size by one acre and then subtr.acted from the pool
surface (determined in Step i), yielding the Reduced pool Area.
(iv) The PMP Flood Volume Requiremenr, as per. the Jarutary l0; 1990
Drainage Report, is 123.4 acre feer. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to deterrnine the pMp
Freeboard Level.
The Wave Run Up of 0.78 t-eet (as specified intheleuumry 10, 1990
Drainage Reporr) is added to the PMP Freeboar:d Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard fbr cell 3 will be calculated
annually and the calculation sheet tiled in the Mill Central File.
c) Tailings Cell4A
The tieeboard limit tbr Cell 4A is cletermined annually using the following
procedure:
b)
(v)
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 15 of33
The Cell 4A design includes a concrete spillway between Cell 3 and Cell 4,A.,
with the invert elevation 4 f'eet below the top of the Cell 3 dike, at an elevation
of 5604.5 t'eet amsl. Should Cell 3 receive the f ull PMP volume of 123.4 acre
feet of water, approximately 62 acre f'eet of that volume would flow through
the spillway into Cell 4A..
The tlood volume from the PMP event over the Cell 4A area is 36 acre-t'eet of
water (40 acres, plus the adjacent drainage area of 3.25 acres, times the PMP of
l0 inches). This would result in a total flood volume of 98 acre-feet, including
the 62 acre-feet of solution ftom Cell 3. The freeboard depth required for Cell
4A from the PMP event would be2.44 feet, plus a wave run-up depth of 0.77 feet
(trom the 1990 Drainage Report), tbr a total freeboard requirement of 3.2 feet.
This calculation is illustrated on Attachment 4. The Groundwater Quality
Discharge Permit, No. UGW370004, ibr the White Mesa Mill requires rhat the
minimum freeboard be no less than 3.0 t'eet tbr any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2
t'eet below the top of liner. The freeboard fbr Cell 4.A, would therefore be 5595.3
amsl (top of liner 5598.5 - 3.2 t'eet).
The calculation of the Total Required Freeboard tbr Cell 4A will be calculated
annually and the calculation sheet filed in the Mill Central File.
d) Roberts Pond
The fieeboard limit tbr Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection systen:r, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set tbrth in License
Condition I1.3.C. The rcsults of the analysis will be rcviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be perlbrmed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
8. REPORTINGREQUIREMENTS
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Page 16 of 33
In addition tothe Doily In.spection Dctta,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2, 3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the fbllowing additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings l'eports are prepared every month and summarize the previous month's activities
al'ound the tailings area. If not prepared by the Radiation Sat'ety Otficer, the report shall be
submitted to the Radiation Safety Ofticer tbr review. The Mill Manager will review the report as
well before the rcport is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrcctive measures
taken during the month will be documented along with the observations where appropriate. Alldaily
and weekly tailings inspection tbrms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection fbrms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety OtTicer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part 1.F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater PoolElevation Monitoring),3.2 (Weekly Inspection of
Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph lbr each calendar year of the depth to wastewater in the Cell 2 stimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, qual'terly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
lr*.
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Book I I : Environmental Protection Manual, Section 3.1
7/08 Revisionr Denison-4
Page l7 of33
APPENDIXA
['oRMS
o
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Page l8 of33
White Mesa Mil['- Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Date;--
Accompanied by:_
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
Insoection Items Conditionq of Potential Concern Cell Cell 2 Cell 3 Cell44
Slurrv Pioeline Leaks, Damaqe, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pioeline Suooorts Damaee. Loss ofSupoort
Valves Leaks, Blocked, Closed
Point(s) of Discharue Imorooer Location or Orientation
TI. OPERATIONAL SYSTEMS
Greater Than Operating Level, Large Change
Since Previous Insoection
Cracks, Severe Erosion, Subsidence
Liner and Covet Erosion of cover. Exoosure of Liner'
III. DIKES AND EMBANKMENTS
Sloughs or Sliding Cracks, Bulges, Subsidence,
Severe Erosion, Moist Areas, Areas ol Seepage
Outbreak
Cracks. Subsidence, Severe Erosion
IV. FLOWRATES
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
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Page l9 of 33
V. PHYSICAL INSPECTION OF SLURRY
I,INES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VIII OBSERVATIONS OF POTENTIAL CONCERN I Action Required
Yes
Yes
No
No
VI. DUST CONTROL
Cell2 Cell3
Dustins
Wind Movement of Tailinss I
Precioitation: inches liquid \
General Meteorological conditions:
VII. DAILY LEAKDETECTION CHECK I
Cell I Cell 2 Cell3 I
Leak Detection System
Checked
-Checked-wet-DryInitial level-
Final level-
Gal. oumoed
_Checked
Wet_Dry
Initial level_
Final level_
Cal. oumoed
_Checked
_Wet-Dry
lnitial level
Final level_
Cal. oumped
\-J
lni
Fir
Ca
White Mesa Mill - Standard Operating Procedurcs
Book I l: Environmental Protection Manual, Section 3. I
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Page 20 of33
White Mesa Mill * Standard Operating Procedures
Book I t: Envimnmental Proteclion Manual, Section 3.1
708 Revision: Denison-4
Page 2l of 33
[MAPOFTAILINCS AREA]
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
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Page 22 of 33
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEBKT,Y TAILINGS INSPECTION
Date:lnspectors:
l. Pond elevations (msl,li) Cell I : (a) Pond Solution Elevation
(b) FML Bottom Elevation _5597
(c) Depth of Water above FML ((a)-(b))
Cell 3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth ol Water above FML ((a)-(b)
C*ll 4A: {n}Pond $*ilulion flevati*n
5570
{h)FMI" $of{om filevation qirid
{*.}l}*pth s}f Wat*r atx}ve I;'ML {(*}-{h})
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottorn Elevation _5612.34-
(c)Depth of Water above FIvIL ((a)-(h))
2. Slimes Dmin Liquid Levels Cell 2 Pump t'unctioning properly
Pump Timer set at l5ntin on 45 min off _
Depth to Liquid pre"pump
Depth to Liquid Posr-punrp
(all measurements are depth-in-pipe)
Prc-purnp head is 38'-Depth to Liquid Pre-pump -
Post-pump head is 3tl' -Depth to Liquid Post-
PUmP =
-
,tr o
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Page 23 of 33
White Mesa Mill - Standard Operating Procedures
Book I t: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
+ Does Level exceed I 2 inches'i
--
no _- yes
Il'cell 4r\ leak detection system level exceeds I2 inches, notily supervisor or Mill mana-qer immediately.
Observation:
Cell I Cell2 Cell3 Cell4A
ls LDS wet ol drv?wet dry wet dry wet-dry wet drv
lf wet, Recod
tiouid level:
Ft to
Ll"rid
_Ft to
Liquid
Ft to
Liauid
Ft to
Liouid *
If sufficient fluid is
present, record
volume of t'luid
pumped and flow
rate:
Volume
-
Flow Rate_Volume
-
Flow Rate_
Volume
Flow Rate-
Volume
Flow Rate_
Was lluid sample
collected?
yes no ves no ves no ves no
.t,'-a
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 24 of 33
APPENDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
1. Slurry Pipeline:
PipeThieknesS:-(TobemeasuredonlyduringperiodswhentheMillisoperating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch I Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing yes_no _yes no _yes_noErosion _yes_no _yes_no _yes_noUndesirable _yes no yes no ves no
Vegetation
Obstruction of Flow _yes_no yes no ves no
Diversion Berm:
Stability Issues
--yes_no
Signs of Distress ves no
Comments:
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Opelating Procedures
Book I I: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: _yes_no
Overspray cal'ried more than 50 f'eet liom the cell:
-yes-no
If "yes", was system imrnediately shut off? "-yes_no
Comments:
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Page 25 of 33
5. Remarks:
6. Settlement Monitors
Cell 2 Wl:
Cell2 W2:
Cell2 W3:
Cell 2 W4:
Cell2WT-C:
Cell2 W7N:
Cell2 W6C:
Cell 4A-Toe:
Cell 3-2C:
Cell2W3-S:
Cell 2El-N:
Cell 2El-lS:
Cell 2El-2S:
Cell 2 East:
Cell 2 W7S:
Cell2 W6S:
Cell 2 W4S:
Cell 3-2S:
Cell 3-lN:
Cell3-lC:
Cell 3-lS:
Cell 3-2N:
Cell2W5-N:
Cell 2 W6N:
Cell2 W4N:
Cell 2 W5C:
7. Summary of Daily, Weekly and Quarterly Inspeetions:
8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
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Page26 of 33
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankmentlnspection:
2. Operations/Maintenance Review:
3. ConstructionActivites:
4. Summary:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
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Page21 of33
APPENDTX A (CONT.)
ORE STORAGE/SAMPLE PI,ANT WEEKLY INSPECTION REPORT
Week of _ through Date of Inspection:
Inspector:
Weather conditions tbr the week:
Blowing dust conditions fbr the week:
Conective actions needed or taken for the week:
Are all bulk I'eedstock materials stored in the arta indicated on the attached diagram:yes:_ lro:_
comments:
Are all alternate feedstock materials located outside the arca indicated on the attached diagram maintained
within water+ight containers:ves: no:
comments (e.g., conditions of containers):
Conditions of storage areas tbr materials:
Other comments:
:.r
White Mesa Mill - Standald Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 28 of 33
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessaly tbr qualifying management-designated individuals t'or
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee tiom the Radiation
Sat'ety Department is responsible lbr perfbrming monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas ofconcern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and speoify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Ollicer, one of whom will notify Corporate
Management. If dam f'ailure occurs, notity your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Saf'ery (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection fbrm. Refer to Appendix A tbr an example of the daily tailings
inspection fbrm. The inspection fbrm consists of three pages and is summarized as tbllows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected tbr leaks, damage, and sharp bends. The pipelinejoints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Book ll: Environmental Pr:otection Manual, Section 3.1
inspected tbr damage and loss of support. Valves are
leaks, blocked valves, and closed valves. Points of
improper location and orientation.
2. Operational Systems:
7/08 Revision: Denison-4
Page29 of33
also to be inspected particularly tbr
discharge need to be inspected for
3.
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond arc potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severc
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence ofcover from erosion are potential items ofconcern tbr ponds and
covercd areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4A solution levels are to be monitored closely for conditions nearing
maximum operating levdl and for large changes in the water level since the last inspection.
All pumping activities atfecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely tbr exposed liner', especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be coverecl by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and recluire immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Sat'ety OtTicer and turned into the Maintenance Department. AII such repairs
should be noted in the report and should contain the start. and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
tbr that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
rnice holes and more importantly filr pr:airie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:4-
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o
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Page 30 of 33
5.
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the tlow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the t'lags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Sat'ety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shitier as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
AII observations of concern dur:ing the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order [o assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
l.
2.
-)-
4.
Cover area
Beach/tailing sands area
Solution as it exists
Pump lines
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page3l of33
9.
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repails, etc.)
6. Slurry discharge when operating
1. Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations fbr the tailings area. Please pay particular notice to the
tbllowing rules:
l. The posted speed limit tbr the tailings area is l5 mph and should not be exceeded.
2. No fbod or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a fbur-wheel drive vehicle is required in the
area.
7. Any work pertbrmed in which there is a danger oi talling or slipping in the cell will
require the use of a saf'ety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to pertbrm any work; an approved tit'e jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well,
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlit'e observed should be reported on the Wildlile Report Worksheet
during each shift. Waterfbwl seen near the tailings cells should be discouraged from landing
by the use ol noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Saf'ety Officer authorizes certilication. Ref'er to the Certification
Form, Appendix C. This form should be signed and dated only alter a thorough review of the
tailings information previously presented. The tbrm will then be signed by the Radiation
Safety OtTicer and filed.
10.
11.
r.l
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7/08 Revision: Denison-4
Page 32 of 33
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled'Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to pertbrm the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Pmtection Manual, Section 3.1
708 Revision: Denison4
Page 33 of33
APPENDTX D
FEEDSTOCK STORAGE AREA
(
DENISONMINES
March 14,2007
VIA FEDERAL EXPRESS <:,\:)'
Mr. Dane L. Finerfrock t"tjl'
Executive Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality168 North 1950 West
salt Lake ciry, uT 84114-4950
Dear Mr. Finerfrock:
Re: White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Plan -Your Letter of January 24,2007
r
This letter is in response to your letter of January 24,2007 , which we received on January 29, t
2007, in which you provided comments on the draft DMT Plan we sent to you on November 9,
2006.
In this letter, your comments are set out in italics, followed by our responses.
1. In the plan, paragraphs 3.].d.viii.B & C need to be completed to indicate the actions to
take with respect to the painted marks and the surface measurements.
The last sentence of each of those paragraphs has been changed to read: "The Assistant will
place the Survey Rod against that mark and hold the rod vertically, with one end just touching
the liquid surface."
2. The items in the Quarterly Inspection Dataform in Appendix A need to be renumbered to
begin with item one rather than eight.
The items in the Quarterly Inspection Data form have been renumbered as requested.
3. Paragraph 3.l.vi in the plan needs to make clear thatfor the Cell2 slimes drain, the
head recovery test requires at least 90 hours for the head to stabilize (as of November 2006).
1 050 1 7th Street, Suite 950
Denver, CO, USA 80265
Tel : [phone]
Fax : [phone]
Denison Mines (USA) Corp. Iwww.denisonmines.com I
For details, refer to the attached recovery graphfrom data provided by Denison Mines at our
visit on December 5,2006.
The first sentence of that paragraph has been changed to read: "On a monthly basis, the slimes
drain pump will be turned off and the wastewater in the slimes drain access pipe will be allowed
to stabilize for at least 90 hours."
4. Paragraph 3.I.b.iii of the current DMT plan mentions that mill management considers
that the head in Cell 2 from the existing pumping system is ALARA. However, no justification
for this claim was provided. As noted above, the head in the cell may have been stabilized by the
existing pumping system, but it may not be ALARA. This is because more fficient pumping
systems may be available to lower the head evenfurther.
Please provide additional information and justffication to show the existing pumping system
equipment and operation provides both a cost effective and maximum annual wastewater
removal. Conversely, if there are other pumping systems that can produce a maximum annual
removal of wastewater in a cost effective manner, please identifu and describe them.
To verifu that the existing pumping system is ALARA will require two demonstrations, as follows:
a) Maximum and Cost Effective Removal of Wastewater, as mentioned above, and
b) A Declining or Static Wastewater Head - Evidence must be provided that the slimes
drain wastewater head in Cell2 is declining or static. The static head case is
appropriate in the event that the above cost effective and maximum pumping case is
made and accepted. Conversely, an increasing wastewater head in Cell2 is not ALARA,
and is not acceptable to the DRC
The current pumping system satisfactorily pumps out the slimes drain access pipe. There is no
need to consider other types of pumps for that function. The ability of the system to reduce the
static head in Cell 2 is a function of the currently engineered slimes collection system, which
feeds solutions into the slimes drain access pipe, not a function of the speed of pumping out the
slimes drain access pipe itself. The current pump drains the slimes drain access pipe; changing
the pump will not cause the slimes drain collection system to feed solutions into the slimes drain
access pipe any quicker. Denison believes that the currently engineered slimes collection system
will adequately dewater Cell 2. There are no practical alternatives to the currently engineered
system. Therefore, Denison proposes that the static head in the Cell2 slimes drain be monitored
as follows:
1. The average head for 2008 will be compared to the average head for 2007.2. If the average head is declining, then that should be considered satisfactory evidence that
the current slimes dewatering system is working and is ALARA.3. If a comparison of the 2008 and 2007 average results indicates that the static head is
static or increasing, then further evaluation will be required at that time.
The DMT plan needs to include the following:
a) Exclusion of all process liquid inflow to Cell 2. (Part I.D.3.b)
The following has been added as a new paragraph 3.1 b) (vii): "No process liquids shall be
allowed to be discharged into Cell 2;"
b) Effective immediately, the monthly slimes drain head recovery test results and readings
for Cell2 are to be reported with the quarterly reports per Part 1.F.2 of the permit. The
reports will include the content required by Part II.G of the permit. Records will be
maintained in accordance with Part II.H of the permit.
The monthly slimes drain head recovery test results and readings for Cell 2 will be reported with
the quarterly reports per Part I.F.2 of the permit, commencing with the first quarter 2007 report
(which will include monthly data for March 2007). Such reports will include the content
required by Part II.G of the permit. Records will be maintained in accordance with Part ILH of
the permit
In addition,
(i) All recovery tests must be performed each month at regular intervals, andfor a
minimum duration of 90 hours each.
See item 3 above.
(ii) All head measurements must be made from the same measuring point (notch at
the north side of the access pipe), and made to the nearest 0.01 foot.
The following sentence has been added as a new second sentence in paragraph 3.1 b) (v): "All
head measurements must be made from the same measuring point (the notch at the north side of
the access pipe), and made to the nearest 0.01 foot."
(iii) An annual summary and graphfor each calendar year of these measurements
must be included in the fourth quarter report. After the first year, and beginning
in 2008, quarterly reports shall include both the current year monthly values and
a graphic comparison to the previous year.
The following two sentences have been added to the end of paragraph 8.2: "An annual
summary and graph for each calendar year of the depth to wastewater in the Cell2
slimes drain must be included in the fourth quarter report. After the first year, and
beginning in 2008, quarterly reports shall include both the current year monthly values
and a graphic comparison to the previous year."
c) A performance standard such that if at any time the most recent average annual head is
found to have increased above the average headfor the previous calendar year, Denison
Mines will comply with the DMT Failure requirements of Part 1.G.3 of the Permit
(including but not limited to reporting and corrective actions).
The following has been added as a new paragraph 3.1 b) (ix): "If at ary time the most recent
average annual head in the Cell 2 slimes drain is found to have increased above the average head
for the previous calendar year, the Licensee will comply with the requirements of Part I.G.3 of
the GWDP, including the requirement to provide notification to the Executive Secretary orally
within 24 hours followed by written notification;"
In reviewing the DMT plan, we made two additional corrections. We changed the word
"recycling" to "cycling" in the last sentence of paragraph 3.1 b) (iii), and we added some
additional settlement monitors into Section 6 of the Monthly Inspection Data form, that were
inadvertently omitted in previous drafts of the plan.
Enclosed with this letter are clean and blacklined versions of the revised DMT Plan. The
blacklined version indicates changes over the previous version of the draft plan provided to you.
Yours very truly,
DnNrsoN
Vice President Regulatory Affairs and Counsel
Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
David C. Frjrdenlund
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page I of 32 ' '1'"
.:'
r,i. lJ
,:i. L'
'\,!i-
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGB MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings lnspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform(a copy of
which is attached in Appendix A). The Daily Inspection Dataform contains an inspection checklist,
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which includes a tailings cells map, and spaces to record observations, especiallythose of immediate
concern and those requiring coffective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concem
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 44, Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation, Cell}
spillway, Cell 3 and 4,A. liquid pools and associated liquid retum equipment, cell leak detection
systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool retum pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell I or Cell
3; the pond return line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another.
b) Cell 1.
Cell2.
Cell3.
CeIl4,\.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell4,A' liquid pools and associated liquid retum
equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
c)
d)
e)
g)
h)
i)
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i)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and"/or wind movement,2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weeklybasis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
and 4,{.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
D aily Inspection Data forrn
An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in any of the
leak detection systems is a gain of more than 12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Dataform. This data will be used in accordance with License
Condition 1l.3.Bthrough 11.3.E of theMill'sRadioactiveMaterialsLicense,to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
k)
1)
m)
n)
o)
p)
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q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,A..
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations lnspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
ln addition to the inspections described in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Trainins
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. tn addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. TailingsEmergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
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Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell 1 and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. Cell 4,A. has a blow tube, which has been measured
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be retumed to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 11.3 C. of the Radioactive Materials
License.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is an active tailings cell while Cell2 is partiallyreclaimed with approximately
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90Vo of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell2, which, based on construction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewater head in the Cell2 slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feet below the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, cycling the pump more than 15 minutes every
hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the Weekly Tailings lnspection Form.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
(v) Depth to wastewater in the Cell2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings lnspection Form;
(vi)On a monthly basis, the slimes drain pump will be tumed off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
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(vii) No process liquids shall be allowed to be discharged into Cell 2;(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 is currently active, no pumping from the Cell 3 slimes drain is
authorized. Prior to initiation of tailings dewatering operations for Cell 3, a similar
procedure will be developed for ensuring that average head elevations in the Cell 3
slimes drain are kept as low as reasonably achievable, and that the Cell 3 slimes drain
is inspected and the results reported in accordance with the requirements of the
permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells I and 3 and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey lnstrument")
accurate to 0.01 feet, such as a Sokkai No. 821, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 1 and 3 and Roberts Pond
are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast comer of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3, the Reference Point is a piece of metal rebar located on the
south dike of Cell 3. The elevation at the top of this piece of rebar (the Reference
Point Elevation for Cell 3) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell 1 and Roberts
Pond, this is typically on the road on the Cell 1 south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3, this is typically on the road on the Cell 3 dike approximately
100 feet east of the Cell 3 Reference Point;
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(v) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey lnstrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey lnstrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell3
A stake has been place in the central area of the south dike of Cell 3. The
Assistant will walk perpendicular to the dike from the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
B. Cell I
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
C. Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northine Eastins
Roberts Pond 323,041 2,579,697
Cell I 322,196 2,579,277
Cell3 320,508 2,577,760
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These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey lnstrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey lnstrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e)Summary
In addition, the weekly inspection should summarize all activities concemingthe
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly lnspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area lnspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
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b) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking altemate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recordedonthe Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentationpond shall be summarized
for the month.
Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
b)
c)
d)
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e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
ln addition, settlement monitors are typically surveyed monthly and the results reported on the
M onthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an OperationsAylaintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The OperationsAvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
d) Summary
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The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. AI\NUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
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The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1't of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
salt Lake city, Utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January 10, 1990 Drainage Report for Cells l
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell l.
(iD A liquid maximum elevation of 5,596.4 feet mean sea level in Cell4A.
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the number of tons required
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to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 123.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the PMp
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
arurually and the calculation sheet filed in the Mill Central File.
c) Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTIIE,R INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and,
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
(iv)
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Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part l.P .2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution lrvels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area lnspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph for each calendar year of the depth to wastewater in the Cell2 slimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, quarterly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3,I
3/07 Revision: Denison-3
Page 16 of32
APPENDIX A
FORl\(S
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page 17 of 32
APPENDTX A (CONT.)
DAILY INSPECTION DATA
Inspector:
Date:
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
A
I. TAILINGS SLURRY TRANSPORT SYSTEM
Insnection Items Conditions of Potential Concern Cell I Cell2 Cell3
Slurrv Pipeline Leaks, Damase, Blockaee. Sham Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharee Improper Location or Orientation
II. OPERATIONAL SYSTEMS
Inspection Items Conditions of Potential Concern Cell Cell2 Cell3
Water Level Greater Than Operating Level, Large Change
Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
III. DIKES AND EMBANKMENTS
Sloughs or Sliding Cracks, Bulges, Subsidence,
Severe Erosion, Moist Areas, Areas of Seepage
Outbreak
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
V. PHYSICAL INSPECTION OF SLURRY
LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
Yes
3/07 Revision: Denison-3
Page 18 of32
-No
No
VI. DUST CONTROL
Wind Movement of Taili
General Meteorological conditions:
VII. DAILY LEAK DETECTION CIIECK
Leak Detection System
Checked
-wet-DryInitial level
Wet Dry
Initial level_
Final level_
Checked
_wet_Dry
Initial level_
Final level
Gal.
VIII OBSERVATIONS OF POTENTIAL CONCERN I Action Required
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page 19 of32
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page20 of32
IMAP OF TAILINGS AREA]
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page2l of32
APPENDTX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date:Inspectors:
l. Pond elevations (msl,ft) Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation _5597
(c) Depth of Water above FML ((a)-(b))
Cell 3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
5570
_56t2.34-
2. Slimes Drain Liquid Levels Cell2 Pump functioning properly
Pump Timer set at l5min on 45 min off
,3#,:";ffifffi-":1"
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
PumP =
White Mesa Mill - Standard Operating Procedures
Book 1 l: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
3/07 Revision: Denison-3
Page22 of32
Observation:
Cell 1 Cell2 Cell3 Cell4A
Is LDS wet or dry?
-wet-dry -wet-dry -wet-dry
wet drv
If wet, Record
liquid level:
_Ft to
Liquid
_Ft to
Liouid
_Ft to
Liouid
Ft to
Liquid
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate_Volume
Flow Rate
Volume
Flow Rate
Volume
Flow Rate_
Was fluid sample
collected?
ves no ves no ves no ves no
5. Control Methods Implemented:
6.
7.Contaminated Waste Dump:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page23 of32
APPENDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeline:
PipeThickneSS:-(TobemeasuredonlyduringperiodswhentheMillisoperating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch I Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing
-yes-no -yes-no -yes-no
Erosion _yes_no _yes_no _yes_noUndesirable ves no ves no ves no
Vegetation
Obstruction of Flow ves no ves no ves no
Diversion Berm:
Stability Issues
Signs of Distress
Comments:
ves no
ves no
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: _yes_no
Overspray carried more than 50 feet from the cell: _yes_no
If "yes", was system immediately shut off? _yes_no
Comments:
3/07 Revision: Denison-3
Page24 of32
5. Remarks:
6. Settlement Monitors
Cell2 Wl:
Cell2W2:
Cell2 W3:
Cell2W4:
Cell2WT-C:
Cell2 W7N:
Cell2 W6C:
Cell4A-Toe:
Cell3-2C:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell2 East:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell3-2S:
Cell3-1N:
Cell3-lC:
Cell3-1S:
Cell3-2N:
Cell2W5-N:
Cell2 W6N:
Cell2 W4N:
Cell2 W5C:
7. Summary of Daily, Weekly and Quarterly Inspections:
8. Monthly Slimes
Reading):
Drain Static Head Measurement for Cell2 (Depth-in-Pipe Water Level
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page25 of32
APPENDTX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankment Inspection:
2. Operations/lVlaintenance Review:
3. Construction Activites:
4. Summary:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.I
3/07 Revision: Denison-3
Page26 of32
APPENDTX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of
-
through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
VCS: NO:
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
ves: no:
comments (e.g., conditions of containers):
Conditions of storage areas for materials:
Other comments:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page27 of32
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concem regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concem is made, it should be noted on the tailings report until the corrective action is
taken and the concem is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-23I-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The sluny pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page28 of32
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
lnspection items include the slopes and the crests of each dike. For slopes, areas of concem
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "Xo' mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
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Page29 of32
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concem noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
l. Cover area
2. BeacMailing sands area
3. Solution as it exists
4. Pump lines
5.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page 3O of 32
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)6. Slurry discharge when operating
7. Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
atea.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-wayhand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Referto the Certification
Form, Appendix C. This form shouldbe signed and dated only after athoroughreview of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
9.
10.
11.
White Mesa Mill - Standard Operating Procedures
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3/07 Revision: Denison-3
Page3l of32
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety PersonneU Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
3/07 Revision: Denison-3
Page32 of32
APPENDX D
FEEDSTOCK STORAGE AREA
S:\BM\US Prcjects\Chlorcfom\dw9\whib-1,,t€_2004-Oc-Pad.dw9, f Ed st(Yed C3545 PS.pd, L€tts
11p, 08y'032006 4:10:16 tt1,
International Uranium (USA) Corporation
Pmject wHlrE MESA MILL
Feedstock Storage Area Map
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page I of 32
t'l '
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform(a copy of
which is attached in Appendix A). The Daily Inspection Dataform contains an inspection checklist,
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page2 of32
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concem is and what corrective measures will resolve the problem. This observation of concem
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 4A, Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation , Cell2
spillway, Cell 3 and 4A liquid pools and associated liquid return equipment, cell leak detection
systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool retum pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell I or Cell
3; the pond return line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another.
b) Cell 1.
Cell2.
Cell3.
Cell4,A'.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell 4,A, liquid pools and associated liquid retum
equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
c)
d)
e)
s)
h)
i)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2]07 Revision: Denison-23
Page 3 of 32
i)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and"/or wind movement,2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust controVspray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
and 4,A..
l,ocations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in any of the
leak detection systems is a gain of more than 12 inches in 24 hours. ff this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition 11.3.B through I1.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
k)
l)
m)
n)
o)
p)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page 4 of 32
q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,A'.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations lnspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the lnspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Dailv Operations Patrol
In addition to the inspections described in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. TailingsEmergencies
lnspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: Denison-33
Page5 of 32
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and. the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AI\D DMT INSPECTION
3.1. Weekly Tailings lnspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell 1 and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. Cell 4,A' has a blow tube, which has been measured
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be retumed to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 11.3 C. of the Radioactive Materials
License.
Slimes Drain Water Level Monitoring
(i) Cell 3 is an active tailings cell while Cell2 is partially reclaimed with approximately
a)
b)
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
23107 Revision: Denison-23
Page 6 of 32
90Vo of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell Zhas a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell2, which, based on construction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewaterhead inthe Cell2 slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feet below the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, recycling the pump more than 15 minutes
every hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the WeeklyTailings InspectionForm.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
(v) Depth to wastewater in the CellZ slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe). and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements onthe
Weekly Tailings lnspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-Z1
PageT of32
(vii) No process liquids shall be allowed to be discharged into Cell 2:(viii) [f at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar )rear. the
Licensee will complv with the requirements of Part I.G.3 of the GWDP. including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification:(+iil(ix) Because Cell 3 is currently active, no pumping from the Cell 3 slimes drain is
authorized. Prior to initiation of tailings dewatering operations for Cell 3, a similar
procedure will be developed for ensuring that average head elevations in the Cell 3
slimes drain are kept as low as reasonably achievable, and that the Cell 3 slimes drain
is inspected and the results reported in accordance with the requirements of the
permit."
Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
Tailing s Wastewater P ool Elevation M onitoring
Solution elevation measurements in Cells I and 3 and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "survey lnstrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 1 and 3 and Roberts Pond
are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3, the Reference Point is a piece of metal rebar located on the
south dike of Cell 3. The elevation at the top of this piece of rebar (the Reference
Point Elevation for Cell 3) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey lnstrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell I south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3, this is typically on the road on the Cell 3 dike approximately
100 feet east of the Cell 3 Reference Point;
c)
d)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
23107 Revision: Denison-23
Page 8 of 32
(v) Once in location, the Surveyor will ensure that the Survey lnstrument is level by
centering the bubble in the level gauge on the Survey lnstrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey lnstrument on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey lnstrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell3
A stake has been place in the central area of the south dike of Cell 3. The
Assistant will walk perpendicular to the dike from the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
B. Cell I
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will heldplace the Survey Rod against that
mark and hold the rod veft ;
and
C. Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will hsldplaee the Survey Rod against that mark gnd_bqld-.1!he rod
vertically. with one end just touchins the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northine Eastins
Roberts Pond 323,041 2,579,697
Cell I 322,t96 2.579.277
Cell3 320,508 2,577,760
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
2]07 Revision: Denison-?3
Page9 of32
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey lnstrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey lnstrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e)Summary
In addition, the weekly inspection should summarize all activities conceming the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is -approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storase Area lnspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page l0 of32
b) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded onthe Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm2 should be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
Ov e r sp ray D u st M inimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
c)
d)
I Wtrite Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
3ll07 Revision: Denison-Z3
Page I I of32
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concem can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection D ata form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an OperationsAylaintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The OperationsAvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
d) Summary
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3ll07 Revision: Denison-Z3
Page 12 of 32
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
ff any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Dataform. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
altemate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
2ll07 Revision: Denison-3J
Page 13 of 32
A liquid maximum elevation of 5,615.4 feet mean sea level in Cell l.
A liquid maximum elevation of 5,596.4 feet mean sea level in Cell4,A,.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concem and the coffective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1't of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake city, utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January 10, 1990 Drainage Report for Cells t
and 4A and are stated below:
(i)
(ii)
b) Tailinss Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(iD An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
(iii) The Maximum Mill Production is divided by the number of tons required
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
23107 Revision: Denison-23
Page 14 of32
acre and then subtracted from the pool
yielding the Reduced Pool Area.
to reduce the pool size by one
surface (determined in Step i),
The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 123.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the PMP
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Central File.
Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
Annual Leak Detection Fluid Samples
(iv)
c)
6.4.
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTIMR INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1.Monthlv Tailings Reports
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-Z3
Page 15 of32
Monthly tailings reports are prepared every month and surnmarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concem noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part 1.F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area lnspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph for each calendar year of the depth to wastewater in the Cell 2 slimes drain must
be included in the fourth quafter report. After the first year. and beginning in 2008. quarterlyreports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/07 Revision: Denison-Z3
Page 16 of32
APPENDIX A
FORMS
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
33/07 Revision: Denison-33
PagelT of32
APPENDTX A (CONT.)
DAILY INSPECTION DATA
lnspector:
Date:
Accompanied by:_
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Insoection Items Conditions of Potential Concern Cell Cell2 Cell3
Slurrv Pioeline Leaks, Damage, Blockaee, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharse Improper Location or Orientation
II. OPERATIONAL SYSTEMS
Insnection Items Conditions of Potential Concern Cell I Cell2 Cell3
Water Level Greater Than Operating Level, Large Change
Since Previous Insoection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
III. DIKES AND EMBANKMENTS
Sloughs or Sliding Cracks, Bulges, Subsidence,
Severe Erosion, Moist Areas, Areas of Seepage
Outbreak
Cracks, Subsidence. Severe Erosion
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
V. PHYSICAL INSPECTION OF SLURRY
LrNES(S)
Walked to Discharge Point
Observed Entire Discharge Line
2ll07 Revision: Denison-23
Page 18 of32
-No-No
Yes
Yes
IV. FLOW RATES
VI. DUST CONTROL
Wind Movement of Taili
General Meteorological conditions:
VII. DAILY LEAK DETECTION CIMCK
Leak Detection System
Checked Wet_Dry
lnitial level_
Final level
Wet_Dry
Initial level_
Final level_
Checked
-wet-DryInitial level_
Final level
VIII OBSERVATIONS OF POTENTIAL CONCERN I Action Required
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2!07 Revision: Denison-31
Page 19 of 32
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-3J
Page2o of32
IMAP OF TAILINGS AREA]
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Book I l: Environmental Protection Manual, Section 3.1
2]07 Revision: Denison-23
Page2l of32
APPENDTX A (CONT)
DENTSON MrNES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date:Inspectors:
1. Pond elevations (msl,ft) Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation _5597
(c) Depth of Water above FML ((a)-(b))
Cell3: (a)Pond Solution Elevation
(b)FML Bottom Elevation _5570
(c)Depth of Water above FML ((a)-(b))
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
_56t2.34-
2. Slimes Drain Liquid Levels Cell2 Pump functioning properly
Pump Timer set at l5min on 45 min off
Deoth to Liouid Dre-DumD
Deoth to Liouid Post-oumo
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
PumP =
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
3ll07 Revision: Denison-Z3
Page22 of32
Observation:
Cell I Cell2 Cell3 Cell4,A'
Is LDS wet or dry?wet drv wet drv wet drv
-wet-dry
If wet, Record
liquid level:
_Ft to
Liquid
Ft to
Ltrrtd
Ft to
Liouid
Ft to
Liouid
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate_Volume
Flow Rate_Volume
Flow Rate_
Volume
Flow Rate
Was fluid sample
collected?
ves no yes no ves no ves no
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
I Wtrite Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.I
2107 Revision: Denison-23
Page23 of32
APPENDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
1. Slurry Pipeline:
Pipe Thickness:-(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing
-yes-no -yes_no
_yes_noErosion _yes_no _yes_no _yes_noUndesirable ves no ves no ves no
Vegetation
Obstruction of Flow yes no ves no ves no
Diversion Berm:
Stability Issues _yes_no
Signs of Distress _yes_no
Comments:
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
2ll07 Revision: Denison-23
Page24 of32
Overspray system functioning properly:
-yes-no
Overspray carried more than 50 feet from the cell: yes-no
lf "yes", was system immediately shut off?
-yes_noComments:
5. Remarks:
6. Settlement Monitors
Cell2 W1:
Cell2W2:
Cell2 W3:
Cell2W4:
Cell2WT-C:
C,ell2 W7N:
Cell2W3-S:
Cell2El-N:
Cell2El-1S:
Cell2El-2S:
Cell2 East:
Cell3-lN:
Cell3-1C:
Cell3-1S:
Cell3-2N:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell2W5-N:
Cell2 W6N:
Cell2 W6C:C.ell2 W4N:
Cell4A-Toe:
Cell i-2C:
Cell2 W5C:
Cell 3-2S:
7. Summary of Daily, Weekly and Quarterly Inspections:
8. Monthly Slimes Drain Static Head Measurement for Cell2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill - Standard Operating Procedures
Book I l; Environmental Protection Manual, Section 3.1
21i07 Revision: Denison-23
Page25 of32
APPENDTX A (CONT.)
WHITE MESA MILL
TAILINGS MAI\AGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
| *f.nn tankment Inspection:
I qZ.Operations/lVlaintenance Review:
| ++f. Construction Activites:
I ++.4. summary:
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page26 of32
APPENDTX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of _ through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
ves: no:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:yes:_ no:_
comments (e.g., conditions of containers):
Conditions of storage areas for materials:
Other comments:
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2ll07 Revision: Denison-Z3
Page27 of32
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Dailytailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concem regarding the tailings ileas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) orthat conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page}8 of 32
Valves are also to be inspected particularly for
Points of discharge need to be inspected for
,,
inspected for damage and loss of support.
leaks, blocked valves, and closed valves.
improper location and orientation.
0perational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concem and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concem for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,A, solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas ofconcem are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2J/07 Revision: Denison-21
Page29 of32
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all sluny lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concem during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
5.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-23
Page3} of32
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
Safety Rules:
A1l safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Referto the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
9.
L0.
11.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: Denison-23
Page3l of32
APPENDIX C
CERTIFICATION F'ORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
lnspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
I Wtrite Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1
2ll07 Revision: Denison-2J
Page3? of32
APPENDX D
FEEDSTOCK STORAGE AREA
International Uranium (USA) Corporation
Feedstock Storage Area Map
Ilill (jrrrtttttl*'.t[c[ [)i:schar''c Pcrnrit
('l rtlu r tdw,rtc r !t tl t t i Ltrr i rt g Prttcr:d ure
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Tvoe of SamPle Srmole
Taken
(clrcle)
Samole Volume
(lndlcate if other
than as soecilled
lielow)
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(circle)
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(clrcle)
VOCs YN 3x40 ml YN HCL Y N
Nutrients YN 100 ml YN H"SO, Y N
Heavv Metals YN 250 ml YN HNO" Y N
All Other Non-
Radioloeics
YN 250 ml YN No Preservative Added
Gross Alpha YN [,000 ml YN H,SO, Y N
Other (specify)YN Sample volume YN
If a preservative is used,
Specify Type and
Quantity of Preservative:
Ti^e
_,[400
1300
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32, Sx
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lvlill .-Croundwatcr Disch:u'ge Permit Dfttc:.1.1().05 Rcvision: I
Croundw uter lVlonitoring Procedurc
ATTACHNIENT I
FIELD DATA WORKSHEET FOR GROI,JI\ID WATER
| ,*u,,on (weu namer Sf ;^.s C rf : ft#t;#',fi ^* ltl 6 /O 6
-
pH Buffer 7.0 pH Buffer 4.0
SpecificConductance_uMHOS/cm Well Depth_
Depth to Water Casing Volume (V) 4' Well: (.653h)
3" Well: (.367h)
Conductance (avg)
Well Water Temperature (avg)
Page l5 of 17
conductance_
-
pH-
-
Conductance
pH
Temperature Temperature
Temperature.
Pumping Rate Calculation
Flow Rate (Q), in gpm.
5/60 = =
Time:
Time to evacuate two casing volumes (2V)
T =ZYIQ=
Time:
Conductance
pH
Temperature
Conductance_
pH
S[,'^.s G Il t
.rd
State of Utah
JON M. HUNTSMAN, JR
Govemor
GARY HERBERT
Lieutenant Governor
)Tepartment of
Environmental Quality
William J. Sinclair
Acting Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
January 8,2009
CERTIFIED MAIL
(Return Receipt Requested)
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Mr. Landau:
S{IBJECT:November 4,2008 Proposed Modifications to the Wite Mesa Mill Tailings
Management System and Discharge Minimization Technology Monitoing Plan
(DMT Plan); December 1, 2008 Wite Mesa Mill DMT Performance Standard
Monitoring Report,3'd Quarter,2008 including Celt2 Slimes Drain Monitoring;
Division of Radiation Control (DRC) letter dated December 1 1, 2008 Regarding
the Monitoring Report: Comments and Requests on DMT Plan Modifications
We received your letter dated November 4,2008 subject as above. We have reviewed the
proposed modifications and have the following comments:
1. In the proposed modifications to the DMT Plan by DUSA, we suggest the following
changes in paragraph 3.1.b(iii) be made, such that it reads: "The slimes drain pump in Cell
2 is activated and de-activated by a float mechanism and water level probe system. When
the water level reaches the level of the float mechanism the pump is activated. Pumping
then occurs until the water level reaches the lower probe which turns the pump off. The
lower probe is located one foot above the bottom of the slimes drain standpipe and the
float valve ntec:lwnisru is located at five feet above the bottom of the slimes drain
standpipe. The average wastewater head in the Cell? slimes drain standpipe is therefore
less than 5 feet wh.en the ou,ntpirzp svste.m is properlv op€ratin,s,'t
2. We request the remaining portion of paragraph 3.1.b(iii) be deleted, as it contains
unnecessary information.
168 North 1950 West. Sah Lake Cily, UT
Mailing Address: P.O. Box 144850 . Salt l^ake City, UT 84114-4850
Telephone (80 I ) 536-4250 . Fax [phone] . T.D.D. (801 ) 536-441 4
www.tleq.utah.got,
Printed on 100% recycled paper
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State of Utah
JON M. HUNTSMAN, JR.
Govemor
GARY HERBERT
Lieutenant Governor
t-Department o[
Environmental Quality
Richard W. Sprott
Exetutive Direttrn'
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
October 30,2008
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265 USA
Subject: White Mesa - June 12, 2008 DUSA Liner Maintenance Provisions- Cells 1, 2,3 and Roberts
Pond Ground Water Discharge Permit (No. UGW370004): Closeout letter
Dear Mr. Landau,
We have received your final copy dated October 6, 2008, for the Liner Maintenance Provisions, Revision 0
for Cells 1,2,3 and Roberts Pond which constitutes, Appendix D, to the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan. Therefore the
matter of white mesa mill liner maintenance provisions for cell 1, 2,3, and Roberts Pond is closed out,
Please be advised that these provisions will be incorporated into the ground water discharge permit in an
upcoming permit modifi cation.
Thank you for the revised submittal and please note that the DRC views the DUSA Liner maintenance
provisions to be effective immediately.
If you have any questions or conments, please contact David Esser at [phone].
UTAH WATER QUALITY BOARD
Dane L. Finerfrock Co-Executive Secretary
DKE: de
F:\FACILITIES\Densison Mine\proposal review\Liner Maintenance Provisions
Closeout ktter.doc
Conditional approvaM008-10-30 Liner Maintenance Provisions
I 68 North 1950 West . Salt takq City, UT
Mailing Address: P.O. Box 144850. Salt Lake City, UT 841 l4-4850
Telephone [phone]. Fax [phone]'T.D.D. [phone]. wwu'.tleq.uloh.gov
Printed on l00ol, recycled paper
State of Utah
JON M. HUNTSMAN, JR,
Governor
CARY HERBERT
Lieutenant Governor
t
Department of
Environmental Quality
Richard W. Sprott
Execulit e Dircrtor
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Direfior
October 9, 2008
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 17m Street, Suite 950
Denver, CO 80265 USA
Subject:White Mesa - June 12, 2008 DUSA Liner Maintenance Provisions- Cells 1, 2,3 and Roberts
Pond Ground Water Discharge Permit (No. UGW370004): Conditional Approval
Dear Mr. Landau,
We have received your revised proposal sent via e-mail dated September 29, 2008, for the liner
maintenance provisions for Cells 1,2,3 and Roberts Pond, Appendix D, to the White Mesa Mill Tailings
Management System and Discharge Minimization Technology (DMT) Monitoring Plan. Summarized
below are parts of the final flexible liner (FML) maintenance provision proposal:
- All FML repairs will be made on a case by case basis.
- Prior verbal and written notification of a FML leak, hole, or other damage, will be made to the
DRC in accordance with the requirements of part I.G.3(a) of the permit.
A time limit for FML repair is provided for DRC approval in accordance with part I.G.3(c) of the
permit.
Document the repair with the DRC by submitting a written report within 30 days of all FML
repairs to the DRC for review, and approval.
Specifications, details, and standards for the repair report were provided. Including the following:
narrative of the repair, FML material types used in the repair, material specifications, post repair
test specifications (e.g., 50 psi air test), ASTM testing method(s), daily reports, material testing
results, and quality assurance/ quality control information reviewed, stamped and signed by a Utah
licensed professional engineer.
168 North 1950 West . Salt Lake City, UT
Mailing Address: P.o. Box I44850 . Salt l-ake City, UT 841l4-4850
Telephone (801) 536'4250. Fax [phone]'T.D.D. [phone]
www.deq.utnh.got'
hinted on I00%, recycled paper
aPage2
Based on the revised September 29, 2008 plan the DRC conditionally approves the DUSA Liner
maintenance provisions provided: 1) hard copies are sent to the DRC by November l, 2008. The final
hard copies must show the revision number and the date of approval October 6, 2008.
Thank you for the revised submittal and please note that the DRC views the DUSA Liner maintenance
provisions to be effective immediately.
If you have any questions or comments, please contact David Esser at [phone].
trTAlI WATER QUALITY BOARD
Dane L. Finerfrock Co-Executive Secretary
DKE: de
F:\FACILITIBS\Dcnsison Mine\proposal review\Liner Maintenance hovisions- Conditional approvaMfi)8106 Liner Maintenance hovisions
Approval kner.doc
roN M. lLrro*.,*
Govenutr
GARY HERBERT
Lieutenanl Goverrurr
State of Utah
Department of
Environmental Quality
Richard W. Sprott
Executive Director
DTVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
August 1,2008
CERTIFIED MAIL
RBTURN RECEIPT REOUESTED
Mr. Steven D. Landau
Manager, Environmental Affairs
Denison Mines (USA) Corp.
1050 lTth Street, Suite 950
Denver. CO 80265 USA
Subject:White Mesa - June 12, 2008 DUSA Liner Maintenance Provisions- Cells 1, 2,3 and Roberts
Pond Ground Water Discharge Permit (No. UGW370004): Request for lnformation, Plan
Revision, and Confirmatory Action Letter
Dear Mr. Landau,
We have received your proposal dated June 12, 2008, of liner maintenance provisions for Cells 1, 2,3 and
Roberts Pond, Appendix D, to the White Mesa Mill Tailings Management System and Discharge
Minimization Technology (DMT) Monitoring Plan. Summarized below are the three basic parts of the
June 12 flexible liner (FML) maintenance provision proposal:
l) Inspection - Comprehensive daily inspections will be done by trained staff on a set schedule and
results will be recorded on daily inspection forms. Problems will be addressed as needed.
2) Training - Individuals performing the FML inspections will have very specific training on specific
possible problems that may be founded with the different types of cell liners. For example: rips,
tearing, or sun exposure.
3) Repairs - Based on the type of FML material PVC or HDPE different patch repair methods will be
used i.e. glues, adhesive, solvents or extrusion welding. Repair could be different in every case.
Please revise the plan and resubmit within 30 days to include the following additional information:
- All FML repairs will be made on a case by case basis.
Verbal and written notification of a FML leak, hole, or other damage, will be made to the DRC in
accordance with the requirements of part I.G.3(a) of the permit.
168 North 1950 Wesr . PO Box 144850. Salt l-ake City, UT 841I4-4850. phone [phone]. fax [phone]
T.D.D. [phone] . www.deq.utah.gov
Page 2
- A time limit for FML repair is provided for DRC approval in accordance with part I.G.3(c) of the
permit.
- Document the repair with the DRC by submitting a written report within 30 days of all FML
repairs to the DRC for review, and approval.
- The FML maintenance provision lacks specification and details. Therefore please write a standard
for the repair report. For example: The repair report shall include the following: narrative of the
repair, FML material types used in the repair, material specifications, post repair test specifications
(e.g., 50 psi air test), ASTM testing method(s), daily reports, material testing results, and quality
assurance/ quality control information reviewed, stamped and signed by a Utah licensed
professional engineer.
During a phone call on July 28, 2008, you agreed that the above changes would be made and a revised plan
submitted to the DRC on or before September 1, 2008. Should this not be your understanding please
contact the DRC in writing within 3 working days of receiving this letter.
Thank you for the submittal and the DRC looks forward to reviewing the revised liner maintenance plan or
any additional information you may provide regarding the liner maintenance provisions.
If you have any questions or cornrnents, please contact David Esser at [phone].
Sincerely,
Dane L. Finerfrock Executive Secretary
UTAH WATER QUALITY BOARD
DKE: de
F:\FACILITIES\Densison Mine\proposal review\Liner Maintenance hovisions- Conditional approval\2O08-7-28 Liner Maintenance Provisions-
RFl.doc
t
NTERNATIONAL URANTUM (UsA) CORPOMTTONUI TJC
November 9,2006
.(l\$-Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental euality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4910
Dear Mr. Finerfrock:
Re:
Tel:[phone]
Fax [phone]
This letter is in response to your letter dated September 26,2006, in which you requested additionalinformation relating to lnternational Uranium (US4) Corporation's ("lUSA's") Rugusi C,-zOOO Draft TailingsManage_ment System & Discharge Minimization Technology elan ithe "oruf edn"y, ino to our telephon"ecallon September 22,2006 relating thereto.
ln the discussion that follows, the requests in your september 26, 2006 letter are set out in italics,followed by our responses.
1. lt was the intent of the Ground Water Diyharg_e Permit part l.H.13.a, and our correspondingcomments of February 21, 2006, for llJC to estabtish fixed locations for measurement of the'liquid iurtaceelevations' Therefore, to eliminate random locations from being used, verbiage needs to be added to theDMT plan, which describes fixed locations for the liquid surfaci elevation meZsurements. The methodsto consistently use the same locations should be inctuded in the plan. A potential location for some cellsmight be the water surface adjacent to the pump intake.
ln addition to the aboue-, an! to be in agreement with the above intent, we recommend the verbiage insection 3'1.d of the DMT plan be revised to reflect the use of specific locations.
For allthe Cells and R_oberts Pond, the pond bottom elevation, and the depth of the water above thelowest point of the FML need to be recorded on the Weekly Tailings tnspection form, revised to inctudesuch.
Paragraph 3.1(d)(viii) of the DMT Plan has been revised to describe fixed locations for measurement ofthe liquid surface elevations on Cells 1 and 3 and Roberts Pond, and the methods to consistenfly use thesame locations.
ln addition, the Weekly Tajlings lnspection form has been revised to allow for the depth ol water abovethe lowest point on the FML to be recorded on a weekly basis.
2. The DMT Plan needs to include a method to measure the static head above the tiner in Ceil No. 2as part of the performance criteria for the ground water discharge permit (UGWD7 part l.D.S.b). By
! 1050 Seventeenth St., Suite 950
I Denve[ Colorado, USA 90265 I [e-mail]
I *.intluranium.com
measuring the change of the static water level in the taitings, tlJC wilt be able to show if the drop in headis being optimized by the pumping technique being used.
Potential options to measure the static head above the liner include installing a piezometer near the
/im?s drain access pipe,.or shutting off the pump and measuring the water-levelafter static equilibriumhas been reached (i.e; a.head recovery test) tf a recovery fesf E used, a standard methodotogy wouldneed to be developed. Also, the fixed location for the measurement on the piezometer or acceis pipewould need to be specified.
As a future reference, the ground water discharge permit witl need to be modified to include a dectine ofthe static water levels in the tailings as a pertormance criterion (UGWDp part l.D.3.b).
The Weekly Tailings lnspection form witl need to be revised to inctude the static head measurement.
IUSA believes that installing a piezometer near the slimes drain access pipe would risk damage to theintegrity of the tailings cell, and has therefore decided not to pursue that'option. However, we haveadded a new paragraph 3.1(b)(vi) to the DMT Plan, which seis out a standard methodology to be used toshut off the pump once per month and to measure the water level after static equilibrium has beenreached (i.e., a head recovery test).
IUSA has determined that it would be more appropriate to perform this test once per month rather thanonce per week, because, based on one test performed to date, it appears that it would normally take afew days for the water level to equilibrate. lf this test were to be pe#ormed once pei weet<, thapumpwould be inactive for too high a percentage of the time.
A line has been added to the Monthly lnspection Data form to allow for recording the monthly slimes drainstatic head measurement as a depth-in-pipe water level reading in cell2.
Finally, IUSA does not believe that the ground water discharge permit needs to be modified to include adecline of the static water levels in the tailings as a performaice criteria (UGDWp part l.D.3.b). IUSAbelieves that the requirement to maintain the average wastewater head in the slimes drain access pipe tobe as low as reasonably achievable is sufficient to ensure that the slimes are being dewatered to themaximum extent practicable. However, IUSA would agree to an amendment to th6 permit to the effectthat the permittee will periodically measure the water level in the slimes drain access pipe after staticequilibrium has been reached, although IUSA does not believe such an amendment is necessary giventhe proposed changes to the DMT plan as discussed above.
3. No comment or response.
4. For the Roberts Pond, the elevation of the pond pump support appears to need to be recorded onthe Weekly Tailing lnspection form to determine the lowest pond'bottom elevation.
IUSA h19 surveyed the lowest pond bottom elevation of Roberts Pond and have included that elevationon the Weekly Tailings lnspection form. As a result, IUSA does not believe that the elevation of the pumpsupport also needs to be recorded on the Weekly Tailings lnspection form in order to determine thatelevation.
5.-14. No comments on the responses.
A copy of the revised draft DMT Plan (including inspection forms), blacklined to indicate the foregoingproposed changes, is included with this letter.
lf you have any questions or require any further information relating to the foregoing, please contact the
-ILJC
undersigned.
Yours very truly,
Ron F. Hochstein
Harold R. Roberts
Stephen D. Landau
David Turk
v[" i,i".i,r6;i;;;'a"""rar counser
.ITJC
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
,q,ugus+Nqy9!0bgl _, 2006
on a daily basis, including weekends, all areas connected with the fourinspected. Observations will be made of the current condition of each cell,
action that needs to be taken.
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring plan (the"Plan") for the White Mesa Mill (the "Mill") provides procedures for moniioring of the tiilings cellsystem as required under State of utah Radioactive Materials License No. urtgoo+ls lthe"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoringequipment and reporting procedures that are adequate to demonstrate DMT compliance under Stateof utah Ground water Discharge permit No. 370004 for the Mill (the,.GwDp;,).
This Plan is designed as a systematic program for constant surveillance and documentation of theintegrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock rtorug" areas at theMill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations andmonthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
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tailings cells will be
noting any corrective
The Environmental or Radiation Technician is responsible for performing
inspections, except on weekends when the shift Foreman will perforr., trr"inspections. The Radiation Safety Officer may designate other individuals
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform(a copy ofwhich is attached in Appendix A). The D aily Inspection Dataform contains an inspection checkiist,
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the daily tailings
weekend tailings
with training, as
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which includes a tailings cells map, and spaces to record observations, especiallythose of immediate
concern and those requiring colrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items wher" "onditiors of potential concern areobserved should be marked with an "X". A note should accompany the "X'i specifying what theconcern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective actionwas taken should be noted as well.
Areas to be inspected include the following: cell 1,2,3, and 44, Dikes 1,2,3,4A-s, and 4A-w,wind movement of tailings, effectiveness of dust minimization methods, spray evaporation , Cell2spillway, Cell 3 and 4.{ liquid pools and associated liquid return equipmeni, cell leak detectionsystems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. Thefollowing items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1 or Cell3; the pond retum line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another.
Cell 1.
Cell2.
Cell3.
Cell4,A..
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell 4,{ liquid pools and associated liquid return
equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
b)
c)
d)
e)
s)
h)
i)
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sumps of the tailings
solution level of the
j)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to browing and/or wind movement,2)liquid pool size, 3) areas not subject to blowing and./or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells l, 3,
and 4A.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
D aily Ins p e c ti on D at a form.
k)
r)
m)
n) An estimate of flow for active tailings slurry and SX line(s).
o) An estimate of flow in the solution return line(s).
p) Daily measurements in the leak detection system
cells will be made when warranted by changes
respective leak detection system.
(LDS)
in the
The trigger for further action when evaluating the measurements in any of theleak detection systems is a gain of more than 12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on theDaily Inspection Dataform. This data will be used in accordance with License
Condition 11.3.8 through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
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q) An estimate of the percentage of the tailings beach surface area and solutionpool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,A..
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line andtailings arca at least once per shift, paying close attention for potential leaks and to the dischargesfrom the pipelines. Observations by the Inspector will be rectrded on the appropriate line on iheOperating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
ln addition to the inspections described in Sections 2.I artd2.2 above,a Mill employee will patrol
the tailings urea at least twice per shift during Mill operations to ensure that there are no obvioussafety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officerand/or Mill management in the event that during their inspection they discover that an abnormalcondition or tailings emergency has occurred.
2.4. Trainins
All individuals performing inspections described in Sections 2.1 andZ.2above must have TailingsManagement System training as set out in the Tailings Inspection Training procedure, whichls
attached as Appendix B. This training will include alraining pack explainlng the procedure forperforming the inspection and addressing inspection items to be observed. In addition, eachindividual, after reviewing the training pack, will sign a certification form, indicating that traininghas been received relative to hisftrer duties as an inspector.
2.5. TailingsEmergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, duringtheir inspection, they discover that an abnormal condition exists or an event has occurred that couldcause a tailings emergency. Until relieved by the Environmental or Radiation Technician orRadiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
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Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mitl Manager or the Radiation Safety Officer, one of whom will notify CorporateManagement. If dam failure occurs, notify your supervisor and the Mill Manager immediatety. rneMill Manager will then notify Corporate Managemenr, MSHA (303-23l-5+651, andthe State ofUtah, Division of Dam Safety (801-53g-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include thefollowing:
Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of apipe that is removed from the system which will indicate the presence of
solutions in the LDS system. Cell4,{ has a blow tube, which has been measured
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shallbe pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be returned to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing therecorded volume of fluid recovered by the elapsed time since fluid was lastpumped or increases in the LDS fluid levels were recorded, whichever is themore recent' This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and, analyzed in accordance with paragraph I 1.3 C. of the Radioactive Materials
License.
Slimes Drain Water Level Monitoring
(i) Cell3 is an active tailings cell while Cell2is partiallyreclaimed with approximately
a)
b)
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9OVo of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;(ii) Cell Zhas a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of theFML in Cell2, which, based on construction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for cell 2;(iii)The slimes drain pump in Cell2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about ig.SO f""t
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewater head in the Cell2 slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feetbelow the water level measuringpoint on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, recycling the pump more than 15 minutes
every hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the Weekly Tailings Inspection Form.If at any time the pump is observed to be not working p.ope.ly, it witt be fixed or
replaced within 15 days;
(v) Depth to wastewater in the Cell2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after apumping cycle, respectively. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings lnspection Form;
On basis. the slimes drain will be t and the w ter in
allo bilize.
chan r level J
a water level meas
fo
ftil(vii) Because Cell 3 is currently active, no pumping from the Cell 3 slimes drain isauthorized. Prior to initiation of tailings dewatering operations for Cell 3, a similar
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procedure will be developed for ensuring that average head elevations in the Cell 3
slimes drain are kept as low as reasonably achievable, and that the Cell 3 slimes drainis inspected and the results reported in accordance with the requirements of the
permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells I and 3 and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "survey lnstrument',)
accurate to 0.01 feet, such as a Sokkai No. B2l, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;(iii)The reference Points (the "Reference Points") for Cells 1 and 3 and Roberts pond
are known points established by professional survey. For Cell 1 and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1. The elevation of the metal disk (the "Reference point
Elevation") for Cell I and Roberts Pond is at 5,623.14 feetabove mean sea level("FMSL"). For Cell 3, the Reference Point is a piece of metal rebar located on the
south dike of Cell 3. The elevation at the top of this piece of rebar (the Reference
Point Elevation for Cell 3) is at 5,607.g3 FMSL;
(iv) The Surveyor will set up the Survey lnstrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell I south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell 1/Roberts Pond Reference
Point. For Cell 3, this is typically on the road on the Cell 3 dike approximately
100 feet east of the Cell 3 Reference point;
(v) Once in location, the Surveyor will ensure that the Survey lnstrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 Reference Point. The Assistant will ensure that the Survey Rod isvertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
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(vii) The Surveyor will focus the cross hairs of the Survey lnstrument on the scale on
the Survey Rod, and record the number (the "Reference point Reading,,), which
represents the number of feet the Survey lnstrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated locationplaee where the Survey
Rod can be placed on the surface of the main solution pond in the Cell or Roberts
Pond, as the case may be
A. Cell3
south
ill walk the
has
urface od at
B. Cell 1
C. Roberts Pond
A mark of the
iBased on the foregoing methods. Tthe approximate
coordinate locations for the measuring points for Roberts Pond and the Cells are:
and
Assistant will hold the Survey Rod aeainst that mark
Nqrthine Eastins
Roberts Pond 323.041 2.579.697
Cell I 322,196 2.579.277
Cell3 320.508 2,577.760
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rodjust touching the pond surface. The Assistant will ensure that the Survey noa is
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vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey lnstrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Summary
In addition, the weekly inspection should summarize all activities concemingthe
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekty Tailings and DMT Inspectionform. An example of the Weekly Tailings and DMT Inspectionform is provided in Appendix A.
3.2. Weekly lnspection of Solution Levels in Roberts pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the pond
Surface Reading area for Roberts Pond, whiehis
approximately six inches above the lowest point on the pond's FML. If the pond solution eievation
ML for
being dry.
3.3. Weekly Feedstock Storage Area [nspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, toconfirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
b) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
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Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and record ed, onthe Monthly Inspection Dataform, an example ofwhich is contained in Appendix A. Monthly inspections are to be performed no sooner than t4 days
since the last monthly tailings inspection and can be conduct"d "or"rrrently with the quarteriy
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 7, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm2should be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization,if applicable.
This entails ensuring that the overspray system is functioning properly. tn-tire event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
Remarks
A section is included on the Monthly Inspection Data form for remarks in which
c)
d)
e)
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f) Summary of Daily, Weekly and euarterly Inspections
The monthly inspection will also summarize the daily,
quarterly tailings inspections for the specific month.
ln addition, settlement monitors are typically surveyed monthly and
M onthly Inspection Data form.
recommendations can be made or observations of concern can be documented.
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weekly and, if applicable,
the results reported on the
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee fromthe Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since ihe
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/lVlaintenance
Review, a Construction Review and a Summary, as follows:
Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
O pe rations/M aint enanc e Rev iew
The OperationsAvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
a)
b)
c)
d)
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documented in the Quarterly Inspection Dataform. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. AI\NUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects ofretention structures. The technical evaluation includes an on-site inspection of the iailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits aie being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will bereviewed as a part of the Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copieswill then be included in the Annual Technical Evaruation Report.
The Annual Technical Evaluation Report must be submitted by September l't of every year to:
Directing Dam Safety Engineer
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State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake City, utah g4116-3156
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6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying moniiors along dikes 3-S,4A-W' and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of thetailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January 10, lgg0 Drainage Report for Cells t
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell 1.
(iD A liquid maximum elevation of 5,596.4 feet mean sea level in Cell44.
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, ;factor of safety, to yield the Maximum Mill production.
(iii) The Maximum Mill Production is divided by the number of tons required
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced pool Area.
(iv) The PMP Flood volume Requirement, as per the January 10, lgg0
Drainage Report, is 123.4 acre feet. The pMp Flood volume
Requirement is divided by the Reduced Pool Area to determine the pMp
Freeboard Level.
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(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Central File.
c) Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTIIER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectivelY, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
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also be attached. Quarterly inspection forms will accompany the report when applicable. The reportwill be signed and dated by the preparer in addition to the Radiation Safety Offi".. and the MillManager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by part l.F .2 ofthe GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water LevelMonitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly tnspection ofSolution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will beprovided to the Executive Secretary on the schedule provided in Table 5 of the GWDp.
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APPENDIX A
FORMS
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APPENDTX A (CONT.)
DAILY INSPECTION DATA
Inspector:
Date;
Accompanied by:_
Time:
Any Item not "oK" must be documented. A check mark = oK, x = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Slurrv Pineline , Blockaee. Sham Bends
Location or Orientation
II. OPERATIONAL SYSTBMS
Inspection Items Conditions of Potential Concern Cell 1 Cell2 Cell3
Water Level Greater Than Operating Level, Large Change
Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
III. DIKES AND EMBANKMENTS
Sloughs or Sliding Cracks, Bulges, Subsidence,
Severe Erosion, Moist Areas, Areas of Seepage
Outbreak
Cracks, Subsidence, Severe Erosion
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V. PHYSICAL INSPECTION OF SLURRY
LrNES(S)
Walked to Discharge Point
Observed Entire Discharge Line
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Yes
-No
NoYes
IV. FLOW RATBS
VI. DUST CONTROL
Wind Movement of Taili
inches lioui
General Meteorological conditions:_
VII. DAILY LEAK DETECTION CITECK
Leak Detection System
Checked
-wet_DryInitial level--
Final level--
-wet_DryInitial level_
Final level
-wet_DryInitial level_
Final level
VIII oBsERvATIoNs oF POTENTIAL CONCERN -T- A"tton R"q,rt.ed
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Book I 1 : Environmental Protection Manual, Section 3. l, Appendix E
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[MAP OF TAILTNGS AREAI
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Page2l of33
APPENDTX A (CONT)
INTERNATIONAL URANIUM (USA) CORPORATION
WEEKLY TAILINGS INSPECTION
Date:Inspectors:
l. Pond elevations (msl,ft)Cell l: (a) Pond Solution Elevatiou
2. Slimes Drain Liquid Levels CellZ
(b) FML Bottom Elevation
5597
(c) Depth of Water above FML ((a)-(b)!.-
Cell 3: (a)Pond Solution Elevation
O}.FML Bottom Elevation
s570
(c)Depth of Water above FML ((a)-(b))
Roberts
Pond:@n
-6)-FML
Bottom Elevation -_s612.34
-(c)4eDepth
of Water above FML ((a)-(b)!-
Pump functioning properly
--Pump Timer set at l5min on 45 min off
d,:t11fJi:,.fi[?
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid pre-pump =
Post-pump head is 38' -Depth ro Liquid posG
pump -
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3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
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Observation:
Cell I Cell2 Cell3 Cell4,A.
Is LDS wet or dry?wet drv wet drv wet dry wet drvIf wet, Record
liquid level:
Ft to
Liquid
-Ft
to
Liquid
Ft to
Liquid
_Ft to
LiquidIf sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate
Volume
Flow Rate_Volume
Flow Rate_Volume
Flow Rate
Was fluid sample
collected?-Yes-no -yes_no
ves no ves no
5. Control Methods Implemented:
Remarks:6.
7.Contaminated Waste Dump:
Draft Date: Angus+3NgyelqbCf9, 2006
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Page 24 of 33
APPENDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
1. Slurry Pipeline:
Pipe Thickness:-(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Comments:
Diversion Ditch I
ves no
-Yes_no
ves no
ves no
Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
_yes_no _yes_no_yes_no _yes_no_yes_no _yes_no
_yes_no _-ves_no
-yes_no
-yes_no
3. Summary of Activities Around Sedimentation pond:
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White Mesa Mill - Standard Operating procedures
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,A,ug{rs+NAygrnbgl _, 2006
4. Overspray Dust Minimization:
Overspray system functioning properly:
--yes--noOverspray carried more than 50 feet from the cell: _yes_noIf "yes", was system immediately shut off? _yes_no
Comments:
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5. Remarks:
6. Settlement Monitors
Cell2 Wl:
Cell2W2:
Cell2 W3:
Cell2W4:
Cell2WT-C:
Cell4A-Toe:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell 2 East:
Cell3-lN:
Cell3-1C:
Cell3-lS:
Cell3-2N:
Cell2W5-N:
7. Summary of Daily, Weekly and euarterly Inspections:
Draft Date:,augus+3Ngyclqbgl_9, 2006
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APPENDTX A (CONT.)
WHITE MESA I\[LL
TAILINGS MAI\AGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
8. Embankment Inspection:
9. Operations/lVlaintenance Review:
10. Construction Activites:
1L. Summary:
Draft Date: Aueuse3Npyqqkr,q, 2006
White Mesa Mill - Standard Operating procedures
Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
,+ueus+N9le!qb9l _, 2006
Revision: ruSA-2
Page27 of33
APPENDTX A (CONT.)
ORB STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of _ through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:yes:_ no:_
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintainedwithin water-tight containers :yes:_ no:
Conditions of storage areas for materials:
Other comments:
Draft Date: Aueusr-3NAyelqbgr,g, 2006
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APPENDIX B
TAI LI NGS'NSPECTO R TRAI N I NG
This document provides the training necessaryfor qualifying management-designated individuals forconducting daily tailings inspections. Training information is presented Uyitre Radiation Safety
Officer or designee from the Environmental Department. Dailytailings inspections are conducted inaccordance with the White Mesa Mill Tailings Management Systernand bischarge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection i"portr, which summarize theconditions, activities, and areas of concern regarding the tailings u."ur.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an ,,X', in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If anobservable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediatel,. ffr"Mill Manager will then notify Corporate Management, MSHA (303-Z3l-5i651, andthe Siate of
Utah, Division of Dam Safety (801-533-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to benoted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailingsinspection form. The inspection form consists of three pages and is ,r--a.ir"d as follows:
1. Tailings Slurry Transport System:
The sluny pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
Draft Date: Augus{3NQyglqbgl9, 2006
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Revision: IUSA-2
Page 29 of 33
inspected particularly for
need to be inspected for
inspected for damage and loss of support. valves are also to be
leaks, blocked valves, and closed valves. points of discharge
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to beinspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concem and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,{ solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moiit areas, and areas of
seepage outbreak. For crests, areas of concem are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely formice holes and more importantly for prairie dog holes, as the prairie dogs are likeiy to
burrow in deep, possibly to the liner. If any of these condition, "iirt, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
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Revision:IUSA-2
Page 30 of 33
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond retum, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4hours during operation of themill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and,4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should bedocumented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
1. Cover area2. Beach/tailing sands area3. Solution as it exists
4. Pump lines
7.
8.
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White Mesa Mill - Standard Operating procedures
Book I I : Environmental Protection Manual, Section 3.1, Appendix E
+ugus+Nqyqlqbg _,2006
5. Activities around tailings cell (i.e. hauling rrash6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
Revision: IUSA-2
Page3l of33
to the dump, liner repairs, etc.)
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to thefollowing rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.2. No food or drink is permitted in the area.3. All personnel entering the tailings area must have access to a two-way radio.4. Horseplay is not permitted at any time.5. Only those specifically authorized may operate motor vehicles in the restricted area.6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved lifejacket. A portable eyewash must be present on site as well.8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be wom at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daiiy tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review of thetailings information previously presented. The form will then be signed by the Radiation
Safety Officer and fited.
10.
11.
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Revision: IUSA-2
Page 32 of 33
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potentiai problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Persormel/ Tailings System
Supervisor
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Book I 1: Environmental Protection Manual, Section 3. 1, Appendix E page 33 of 33
,q,ugus+NqI9lqber _, 2006
APPENDX D
FEESTOCK STORAGE AREA
Draft Date: +ugusgNeyelgbgr,2, 2006
o
NTERNATIONAL URANTUM (UsA) CORPOMTTON*I TJC
August 3, 2006
Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Dear Mr. Finerfrock:
This letter is in response to your letter dated February 21,2006, in which you requested additionalinformation relating to our June 7, 2OO5 Draft Tailing Management System & Discharge Minimization
Technology Plan (the "DMT Plan"), and to our conference Call on July 5, 2006 relatinj thereto.
ln the discussion that follows, the requests in your February 21, 2OOO letter are set out in italics, followedby our responses.
1. The report nee.ds to detail the procedures for the measurement of the tailings cell poot elevationsand establish fixed locations for making the measurements. [part t.H.t3.al
Section 3.1 d) of the DMT Plan wiil be replaced with the following:
"Solution elevation measurements in Cells 1 and 3 and Roberts Pond are to be taken by survey
on a weekly basis as follows:
!e:,.1I!t=?4 2,,99I=Prll!fqilings [t{glaq$nent=9vslem I Discharqe Minimization rechnotoqv ptan
lnformation Letter Dated Februarv 21. 2006
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee(the "surveyo/') with the assistance of another Mill workei (the ,,Assistantj;
(ii) The survey will be performed using a survey instrument (the "survey lnstrumenf')
accurate to 0.01 feet, such as a sokkai No. B21, or equivalent, together with asurvey rod (the "survey Rod") having a visible scale in 0.01 foot increments;(iii) The reference Points (the "Reference points") for cells 1 and 3 and Roberts
Pond are known points established by professionalsurvey. For cell 1 andRoberts Pond, the Reference Point is a wooden stake with a metaldisk on it
located on the southeast corner of Cell '1. The elevation of the metal disk (the
"Reference Point Elevation") for cell 1 and Roberts pond is at 5,623.14 feet
above mean sea level ("FMSL"). For cell 3, the Reference point is a piece of
metal rebar located on the south dike of Cell 3. The elevation at the top of thispieceof rebar (the Reference Point Elevation for cell 3) is at 5,607.33 FMSL;(iv) The Surveyor will set up the Survey lnstrument in a location where both theapplicable Reference Point and pond surface are visible. For Cell 1 and Roberts
Pond, this is typically on the road on the cell 1 south dike between cell 1 and
Roberts Pond, approximately 100 feet east of the Cell 1/Roberts Pond ReferencePoint. For cell 3, this is typicalty on the road on the cell 3 dike approximately
100 feet east of the Cell 3 Reference point;
Tel:[phone]
Fax [phone] I f050 Seventeenth St., Suite 950
I Denver, Colorado, USA 802G5 I [e-mail]
I www.intluranium.com
ot
2.
(v) Once in location, the Surveyor will ensure that the Survey lnstrume4l.i6fevel bycentering the bubble in the level gauge on the Survey lnstrumenJ,t
(vi)The Assistant will place the Survey Rod vertically onihe
metal disk on the Cell 1/Roberts pond Reference poin the top of therebar on the cell 3 Reference point. The Assistant wihenr6fre that the surveyRod is vertical by gently rocking the rod back and forth until the Surveyor hasestablished a level reading;
(vii) The Surveyor will focus the cross hairs of the Survey Instrument on the scale onthe Survey Rod, and record the number (the "Reference Point Readino"). which , ,represents the number of feet the Survey.lnstrument is reading aboveihe f.+.J]ysReference Point; - l,q'*iJ t1e,*ccttti(viii) The Asgstalrf ifitt tnei move to f,pdce where the Survey Rod can be ptacedon thefurface of the main solution pond in the Cellor Roblrts pond, as the casemay be, which is typically near the pump ramp for each Cell and off the end ofthe pond pump support in Roberts pq11Q;._,- t,1*iA
(ix) The Assistant.will hold$e-8utrEfHod verticaliy with one end of the Survey Rodjust touching the pondfurface. The Assistant will ensure that the Survey iod isverticalby gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The Surveyor willfocus the cross hairs of the Survey lnstrument on the scale onthe Survey Rod, and record the number (the "Pond Surface Reading"), whichrepresents the number of feet the Survey lnstrument is reading above the pondsurface level;
(xi) The Surveyor will calculate the elevation of the pond surface as FSML by addingthe Reference Point Reading for the Cell or Roberts Pond, as the case may be,-to the Reference Point Elevation for the Cell or Roberts Pond and subtracting thePond Surface Reading for the Cell or Roberts Pond, and will record the numberaccurate to 0.01 feet.,,
The elevation of the FML for Tailings Cetts 2 and 3 needs to be determined and reported. [partLH.1Scl
we have replaced section 3.1 (b) of the DMT plan with the following:
"b) Slimes Drain Water LevelMonitoring WZ
(i)cell 3 is an active tailings cell while cell 2 is partially reclaimed withapproximately 90% of the surface covered by platform filt. each cell has
a. slimes drain system which aids in dewatering the slimes and sandsplaced in the cell;
peltl 2 has a pump placed inside of the stimes drain access pipe at thebottom of the slimes drain. As taken from actual measurements, thebottom of the slimes drain is 38 feet below a water level measuring pointat the centerline of the slimes drain access pipe, at the ground surfacelevel. This means that the bottom of the slimes drain pool and thelocation oI the pump are one foot above the lowest point of the FML incell 2, which, based on construction reports, is at a depth of 39 feetbelow the water level measuring point on the slimes drain access pipe
for Cell2;
The slimes drain pump in cell 2 is on a timed system, under which itpumps for 15 minutes each hour, thereby allowing ihe slimes wastewaterto recharge lor 45 minutes before being pumped again. Based onmeasurements taken in August 2006, the water level in the cell 2 slimesdrain recharges to a depth of about 29.50 feet before each pumping andis pumped to a depth of 38 feet after each pumping, in each -case
measured below the water level measuring point on lhe slimes drain
(ii)
Q *iT.-
---T,1JJlEryi-,li ,Y/*,.4: >F {lf ?*"*C,, L.i.LrrUJ >"ho"z
't':-:- '-'
&tt z t,s"ro}
{t €-ItJ',
...1.L. rnt^
,
" {3L
h"
?^*"e *l'
--..|*-:*J_
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fo a"" aI1 o<.ol 'r 'ntr otg
ow\,w t YS:: ^'t tslt*
@ 7u,re,"iti 9*"fatc (iii)
;ffi*d'''l IJC
access pipe. The depth to water of about 2g.50 feet after recharge isbelow the phreatic surface of tailings cell2, which is at a depth of about20 feet below the water level measuring point on the slimes drain accesspipe. As a result, there is a continuous flow of wastewater from cell2into the slimes drain collection system. Mill management considers thatthe average-allowable wastew# infromlng at these intervals is satis and is as low as
on past
ALA,zh
* frt*y Bunn.ao$
ft,e r^r, n.+-Ti'e-canAc tr -iultc-
t*" ?
-{.8. tl,tcwttlL{* 4r'{"'/b
lo {"f, Frll ekv,
g) oc-&
f-oi-q*!Iaii- 1 5 iii iri ufiis-"eve rX hg*ur can res u tt in m ore
f 6ipump-seiia-iiid?6?-dsuliif iisystemdowntime;Tor pumps ano more resutting system downtime;(iv) The cell 2 slimes drain pump is checked weekly to observe that it isoperating and that the timer is set properly, which is noted on the weeklyTailings lnspection Form. lf at any time the pump is observed to be not
. . working properly, it will be fixed or replaced within 15 days;(v) Depth to wastewater in the cell 2 slimes drain access pipe will bemonitored and recorded weekly to determine maximum and minimumfluid head before and after a pumping cycle, respectively. The resultswill be recorded as depth-in-pipe measurements on the Weekly Tailingslnspection Form;
(vi) -Because Cell 3 is currenily active, no pumpinq from
3.
rs aurnonzeo. pnor to rnitiation of tailings dewatering operations for3, a similar procedure wiil be developed for ensuring ihat averagehead elevations in the cell 3 slimes drain are kept as low-as reasonab-lyachievable, and that the cell 3 slimes drain is inspected and the results
reported in accordance with the requirements of the permit.,,
The lowest point on Cell 2's FML is correlated to the lowest point in the Cell2 slimes drain, whichis correlated to the measuring point on the Cell 2 slimes drain access pipe. From this information,it is possible to determine the wastewater head in the Cell2 slimes drain system. Similarcalculations will be performed for cell 3 prior to initiation of dewatering activities in that cell. -4J
Data showing the average head elevations in the slimes drain layers in Ceils 2 and S are as-low-as-reasonably-achievable. The weekly form ne-eds to specify if ihis information is a depth-in-pipemeasurement or a mean-sea-levelelevation. lf conversion factors are used, they need to beshown on the form. [Part l.H.tA.d] [part l.E.6.b)]
See the response to item 2 above. We have also made changes to the Weekly Tailingslnspection Form to indicate that the measurements are on a dipth-to-pipe basis.
The solution elevation in Roberts Pond needs to be correlated to the lowest point on the pond'sFML. [Part LH.13.e]
The following sentence has been added to the end of Section 3.2 of the DMT plan:
"Based on historical observations, the Pond Surface Reading area for RobertsPond, which is typically off the end of the pond pump support, is approximatelysix inches above the lowest point on the pond,s FML."'
The.Weekly Mill lnspection form needs to be updated for the additional monitoring requirementsunder the permit (i.e., Monitoring the Feedstock storage Area). [part t.H.ls.f]
The feedstock storage area monitoring requirements set out in part l.H.l3.f) of the Mill'sGroundwater Discharge Permit (he "GWDP") are recorded on the Ore Stoiage/S"ij'tng ehntWeekly lnspection Report, a copy of which is attached as Appendix A to this letter.
4.
5.
-l[Jc
6. The draft report did not address Weekly monitoring and record keeping of the DMT MonitoringWells at Cett t. fpart t.H.tO.g]
As required.by Part l.H.t.1.a) of the GWDP, three Cell 1 DMT monitoring wells (MW-2 4, MW-27and MW-28) were added as compliance monitoring wells, along with the 6xisting monitorlng wellsand other new compliance monitoring wells added under Part t.H.r.O.) of the GfrDp. As th-eseCell 1 DMT monitoring wells are treated the same as the other compliance monitoring wells underthe GWDP, the monitoring and record keeping requirements applicable to those wells areadequately set out in the GWDP. There is no need for additional monitoring and recordkeepingrequirements for these wells in the DMT plan.
7. Data showing the maximum allowable head in the slimes drain for Celts 2 and 3 need to bedetermined. The report showing what contingency actions wiil be taken should the pump fail.[Part t.D.g.b).1]
See the response to item 2 above.
8. The report needs to address the maximum taitings waste solids elevation. [part l.D.g.b).2)]
Part l.D.3.b).2) of the GWDP sets out the specific requirement that must be met. Section 5.3 ofthe Mill's draft Contingency Plan sets out procedures that will be followed in the event that thisspecific requirement is not satisfied. Accordingly, there is no need to add anything further to theDMT Plan to address this requirement of the eWOp.
9. The plan for operating Cetts 2 and 3 in order to prevent groundwater quality conditions inmonitoring wells from exceeding the Compliance Limits established ii raote 2 of the permit
needs to be addressed. [part l.D.S.b).S)]
The specific monitoring and reporting requirements set out in the GWDP constitute the plan foroperating Cells 2 and 3 in order to prevent groundwater quality conditions in monitoring wellsfrom exceeding the Compliance Limits established in Table 2 ot tne CWOp. ln additioi, thespecific provisions of the GWDP relating to slimes drain maximum allowable head (part l.D.3.b)1)) and maximum tailings waste solids elevation (Part l.D.3.b)2)), and the correspondingprovisions in the DMT Plan (Sections 3.1(b)) and the Mill's drafi'Contingency ptan (Secion 5.3),together with the groundwater sampling procedures in the Mill's GrounJwater euality RssurancePlan further ensure that the requirements of Part l.D.3.b)3) of the GWDp will be satiifieO. Thereis no need to require anything further in the DMT Plan to ensure compliance with this provision ofthe GWDP.
10. The report needs to address the steps that will be taken should the wastewater etevation exceedthe two feet of freeboard requirement in Roberts Pond. The report needs to detailthe procedurefor measuring the pond elevation and establish a fixed locatioi for making it. [part t.o.5.c1.1 partl.E.6.c)l
The steps that will be taken should the wastewater elevation exceed the two feet of freeboardrequirement in Roberts Pond are set out in generalterms in Part l.D.3.c) of the permit and morespecifically in Section 5.4 of the Mill's draft Contingency plan dated tvtarbn 31, 2006 which wassubmitted to the Executive Secretary for review on nprit 7,2006. Accordingly, no additional stepsneed be included in the DMT plan.
The procedure for measuring the pond elevation, including the establishment of locations formaking such measurements are included in the revised Section 3.1 d) of the DMT plan,
described in the response to item 1 above. ln order to reflect the inclusion of such procedures in, ( Section 3.1 d) of the DMT Plan, the first sentence in Section 3.2 of the DMT ptan will be modified
|,t lk I ?Lldgilg]o the end of that sentence the following phrase: ",in accordance with the proceduresv ( set out in Section 3.1 d) above.", and by deleting the second sentence in Section 3.2.
-lr.JC
11.The report needs to address how compliance with the Feedstock storage area locationrequirements will be ensured. [Part LD.3.d)]
Section 3.3 of the draft DMT Plan currently addresses how compliance with the FeedstockStorage Area location requirements will be ensured. This Section will be expanded to referencean appended map which will identify the defined Feedstock Area. We will aiso change theSection to require that any variance f rom the requirements will be rectif ied within 15 lays, ratherthan "promptly''. The revised Section 3.3 will be as follows:
weekly feedstock storage area inspections will be performed by theRadiation Safety Department, to confirm that:
a) the bulk feedstock materials are stored and maintained within thedefined area described in the GWDp, as indicated on the map
attached as Appendix D hereto; and
b) all alternate feedstock located outside the defined Feedstock Area
are maintained within water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample
Plant Weekly lnspection Report. Any variance in stored materiali from t'hisrequirement or observed leaking alternate feedstock drums or othercontainers will be brought to the attention of Mill Management and rectifiedwithin 15 days."
The reporT needs to address secondary containment for mitl site chemical reagents. [partl.D.3.e)l
Part l.D.3.e) of the GWDP sets out the requirement for the Mill to have secondary containment tocapture and contain allvolumes of reagents that might be released at an individual storage area.The manner in which this requirement is implemented for the various chemical storage areas attle.tvtlt site and the potential for spill sources and spill containment are addressed in the Mill,sSpill Prevention, Control, and Countermeasures Plan For Chemicals and petroleum products,
September 2005, included as Appendix 1 to the Mill's Stormwater Best Management practices
Plan, January 2006. The specific wording of the GWDP, together with the pr6cedures set out in
1t19[ltan adequately allow for the implementation of the requirements of part t.D.3.e.) of theGWDP in a manner that is capable of inspection by UDEQ. Accordingly, there is no need to alsoaddress these matters in the DMT plan.
The report needs to include the SOPs for the Feedstock Storage Area inspection. fpart t.E.6.d)]
fPart LE.6.d)i]
The revised Section 3.3 of the DMT Plan described in response to item 11 above is intended toconstitute the standard operating procedure for the Feedstock Storage Area inspection.
The report needs to define the SOPs for ensuring the alternate feedstock materiats locatedoutside the Feedstock Storage Area are maintained within water-tight containers. [part t.E.6.d).ii]
The revised Section 3.3 of the DMT Plan described in response to item 11 above is intended toconstitute the SOP for ensuring that alternate feedstock materials located outside the FeedstockStorage Area are maintained within water-tight containers.
12.
13.
-ILJC
A copy of the revised draft DMT Plan, blacklined to indicate the foregoing proposed changes, is includedwith this letter.
lf you have any questions or require any further information relating to the foregoing, please contact theundersigned.
Yours very truly,
Ron F. Hochstein
Harold R. Roberts
.I[JC
Appendix A
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of _ through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:yes:_ no:_
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram
maintained within water-tight containers:yes:_ no:_
comments (e.g., conditions of containers):
Conditions of storage areas for materials:
Other comments:
-I[JC
s:\BM\Us Prcjet\chlorcform\dws\whhe-Ma-2trc4-oe-pad.dws, feed * *t.rrrt, *r*a,ro,ru *,
International Uranium (USA) CorporationProject wHlrE MESA M|LL
Feedstock Storage Area Map
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
JulyAucu$ _,20W
2.1. Daily Comprehensive Tailines Inspection
on a daily basis, including weekends, all areas connected with the
inspected. observations will be made of the current condition of each
action that needs to be taken.
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1.. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring plan (the"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UTl90O+li lthe"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground water Discharge Permit No. 370004 for the Mill (the .,GwDp;;.
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at theMill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
Revision: ruSA-2
Page I of33
four tailings cells will be
cell, noting any corrective
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekenO tuitirrgtinspections. The Radiation Safety Officer may designate other individuals with trainirg, i,
described in Section 2.4below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform(a copy of
which is attached in Appendix A). The D aily Inspection Dataform contains an inspection checklist,
Draft Date: June-l+AugU9l_1, 20056
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
JulyAuCqiI _,20056
Revision: IUSA-2
Page 2 of 33
which includes a tailings cells map, and spaces to record observations, especiallythose of immediate
concem and those requiring coffective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X'i specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 44, Dikes 1,2,3,4A-s, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation , Cell2
spillway, Cell 3 and 4,A liquid pools and associated liquid return equipment, cell leak detection
systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1 or Cell
3; the pond retum line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another.
b) cell 1.
Cell2.
Cell3.
Cell4,{.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell4,A' liquid pools and associated liquid return
equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
c)
d)
e)
s)
h)
i)
Draft Date: June-++AUgUgt i, 20056
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix EtulyAucu!_,20056
Revision: IUSA-2
Page 3 of33
Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing taiings
sand' During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement,2)
liquid pool size, 3) areas not subject to blowing and./or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust controUspray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
and 4A..
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
D aily I ns p e c ti on D ata form.
An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
p) Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in any of the
leak detection systems is a gain of more than 12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Dataform. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
j)
k)
l)
m)
n)
o)
Draft Date: Jrtne-t?Algu$ l, 20050
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.l, Appendix EturyAue!$_,200s0
Revision: ruSA-2
Page 4 of 33
q) An estimate of the percentage of the tailings beach surface area and solutionpool
area is made, including estimates of solutions, cover areas, and tailings sandi for
Cells 3 and 44.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations lnspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line andtailings area at least once per shift, paying close attention for potential leaks and to the Jischargesfrom the pipelines. Observations by the Inspector will be recorded on the appropriate line on iheOperating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
ln addition to the inspections described in Sections 2.1 and,2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormalcondition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and2.Zabove must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, whichls
attached as Appendix B. This training will include a training pack explaining the procedure forperforming the inspection and addressing inspection items to be observed. In addition, eachindividual, after reviewing the training pack, will sign a certification form, indicating that traininghas been received relative to hisftrer duties as an inspector.
2.5. TailingsEmergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that couldcause a tailings emergency. Until relieved by the Environmental or Radiation Technician orRadiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Draft Date: l€ne-++4Ue!g!.i, 20056
White Mesa Mill - Standard Operating procedures
Book 1 l: Environmental Protection Manual, Section 3.1, Appendix EHyAqClqt_,2005A
Revision: IUSA-2
Page 5 of33
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. 1.n"Mill Manager will then notify Corporate Management, MSHA (303-231-5i651, and the State ofUtah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailinss tnspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include thefollowing:
Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell 1 and Cell 3 the leak detection system is measured by use of apipe that is removed from the system which will indicate the presence of
solutions in the LDS system. cell 4A has a blow tube, which has been measured
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be returned to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is themore recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 1 1.3 C. of the Radioactive Materials
License.
Slimes Drain Water Level Monitoring
a)
b)
cell whi
Draft Date: June-+TAggqill, 2005!
White Mesa Mill - Standard Operating procedures
Book I I : Environmental Protection Manual, Section 3. l, Appendix E
JuryAuCs$_,20056
Revision: IUSA-2
Page 6 of 33
907o of the surface covered by platform fill. Each cell has a slimes drain slzstem
which aids in dewatering the slimes and sands placed in the cell:(ii) Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements. the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access DiDe. at the ground surface level. This means that the bottom of the slimes
drain Dool and the location of the pump are one foot above the lowest point of theFML in Cell 2. which. based on construction reports. is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2:(iii)The slimes drain pump in Cell 2 is on a timed system. under which it pumps for 15
minutes each hour. thereby allowing the slimes wastewater to rechargi for 45
minutes before being pumped again. Based on measurements taken in August 200e
the water level in the Cell 2 slimes drain recharges to a depth of about i8.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping. inrach-
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewaterhead in the Cell 2 slimes drain is therefore about 5 feet Ttre
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailin8s Cell 2. which is at a depth of about 20 feet below the water level measuring
Point on the slimes drain access pipe. As a result. there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimei drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience. recycling the pump more than 15 mimrtes
every hour can result in more replacement costs for oumps and more resulting system
downtime:
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly. which is noted on the Weekly Tailings tnsplction Forrnlf at any time the pump is observed to be not working properl)r. it will be fixed or
replaced within 15 days:
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
DumPinB cYcle. respectively. The results will be recorded as depth-in-pipe
measurements on the Weeklv Tailings lnspection Form;
(vi)Because Cell 3 is currently active. no pumping from the Cell 3 slimes drain is
authorized. Prior to initiation of tailings dewatering operations for Cell 3. a similar
Drocedure will be developed for ensuring that average head elevations in the Cell j
slimes drain are kept as low as reasonably achievable. and that the Cell 3 slimes drain
is inspected and the results reported in accordance with the requirements of thepermit."
tt 2 ts parriatty re
Draft Date: June{+4uguil1, 20056
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
Ju{yAuCu$ _,20056
Revision: IUSA-2
PageT of33
c)
d)
Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
Tailings Wastewater Pool Elevation Monitoring
ion elevation measurements in cells I and 3 and Roberts pond are to be
survey on a weekly basis as follows:
the Mill'
(the "Surveyor") with the assistance of another Mill worker (the ..Assistant,i:
rnst
to 0.01 f or eouiv r with
surve foot i
The ref the "Refr nts") f 3 and
ished b rvev.Robert
wooden a metal ed on
Draft Date: lune-++AUgUSLl, 20056
this
disk Pointof Cell l.
and
tion of
levation"isat5 2
tsa
ike of Cell 3.tion at
Point Elevation for Cell 3) is at 5.607.83 FMSL:
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
HyAUgu$ _,20W
will set Ins
Revision: IUSA-2
Page 8 of 33
both
a
Pond
Roberts
ference
icallv on tti
and
the Cell dike betw
east of /Roberts
int. For road on dike
100 feet east of the Cell 3 Reference point:
--.----._.-----.
the S
centering the bubble in the level gauge on the Survey Instrument:
ment is
vi)The Assi Rod vertithe Survey Rod verticallv on the int (on
disk
Cell 3
a level readinq:
Ref
int. T istant will
rod brth unti
rebar
t the Surv 1S
has
1/R
w us the of the
scale on
surfi
Rod. a
ts the nu
the
the nu
for each
"Refere
off the en
ew
the1n
pond pump support in Roberts Pond:
The Assi will hold t Rod verti with o
S oft rface addi
case mains for the
yor w
Point
Point Elev the Cell Pond ins t rface R
Cell the
e) Summary
In addition, the weekly inspection should summarize all activities conceming the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspectionform' An example of the Weekly Tailings and DMT Inspectionform is provided in Appendix A.
Draft Date: June-++AUgU!L1, 20050
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
Ju+AqCqSt _,20}so
3.2. Weekly Inspection of Solution Levels in Roberts pond
Revision: IUSA-2
Page 9 of 33
weekl ion elevati onR ith thein Section 3.
Weeklv Tailinps and
e. The W
ction f
ution ed
on hi Surf
Readi orR
ix inches
which is t
owest
off
@ien
3.3. Weekly Feedstock Storage Area Inspections
Weeklv f
confirm that:
ons will ion Safet
ults of this i ion will ont r ora
ofw 1X V ials f
r observ alterna
ill rectifi
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and record ed, onthe Monthly Inspection Dataform, an example ofwhich is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
Draft Date: June-+TeUgUSLl, 20056
A.
dru
hin
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.l, Appendix EHyAucui!_,200s6
Revision: IUSA-2
Page l0 of33
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1,2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm}should be checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentationpond shall be summarized
for the month.
Ov e rs p ray Du st M inimi zat ion
The inspection shall include an evaluation of overspray minimization,if applicable.
This entails ensuring that the overspray system is functioning properly. tnthe event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekty and euarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on theM onthly I ns p e c ti on D ata form.
Draft Date: June-l+AUgUSt l, 20056
c)
d)
e)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
turyAucli!_,2o0so
5. QUARTERLY TAILINGS INSPECTION
Revision: ruSA-2
Page 11 of33
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment lnspection, an Operations/lVlaintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
d exposed liner.
b) Operations/Nlaintenance Review
The Operations/Jvlaintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
Draft Date: June-l+AggUill, 20056
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix EJulyAuc$t _,20056
Revision: ruSA-2
Page 12 of33
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical asfects ofretention structures. The technical evaluation includes an on-site inspiction of the iailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water controlstructures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt ofalternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. Theamount of tailings added to the system since the last evaluation will also be calculated to determinethe estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.These inspection records will be evaluated to determine if any ireeboard limits aie being
approached. Records will also be reviewed to summarize observations of potential concern. Theevaluation also involves discussion with the Environmental and/or Radiation Technician and theRadiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will bereviewed as a part of the Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concem and the corrective actions taken. These copieswill then be included in the Annual rechnical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September l't of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake City, Utah g4tl6-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the secondquarter of each year. The movement monitor survey consists of surveying moniiors along dikes 3-S,4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Refortof the
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Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
JulyAuCs$ _,20056
tailings management system.
6.3. Freeboard Limits
Revision: ruSA-2
Page l3 of33
a) Tailings Cells I and 4A
The freeboard limits are as per January 10,
and 4A and are stated below:
1990 Drainage Report for Cells I
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell l.
(ii) A liquid maximum elevation of 5,596.4feet mean sea level in Cell44.
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(D From a survey of cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multiplied by 1.5, ;
factor of safety, to yield the Maximum Mill production.
(iii) The Maximum Mill Production is divided by the number of tons required
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced pool Area.
(iv) The PMP Flood volume Requirement, as per the January 10, lgg0Drainage Report, is 123.4 acre feet. The pMp Flood volume
Requirement is divided by the Reduced Pool Area to determine the pMp
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the January 10, lgg0
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill central File.
c) Roberts Pond
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6.4.
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on anannual basis. This sample will be analyzed according to the conditions set forth in LicenseCondition 11.3.C. The results of the analysis will be reviewed to determine the origin of thesolution.
7. OTIIER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed asspecified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conductedafter any significant storm or significant naturar or man-made event o."orr.
8. REPORTINGREQUIREMENTS
ln addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5respectively, and the Operating Foreman's Daily Inspection and, Weekty Mill Inspection formsdescribed in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthlv Tailings Reporrs
Monthly tailings reports are prepared every month and summarize theprevious month,s activitiesaround the tailings area. If not prepared by the Radiation Safety Oificer, the report shall besubmitted to the Radiation Safety Officer for review. The Mill Manager will reviewthe report aswell before the report is filed in the Mill Central File. The report will contain a summary ofobservations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All dailyand weekly tailings inspection forms will be attached to the report. A monthly irspection form wilialso be attached. Quarterly inspection forms will accompurry th" report when applicable. The reportwill be signed and dated by the preparer in addition to the Radiation Safety Offi"", and the MillManager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by part | .F .2 ofthe GWDP relating to the inspections described in Section 3.1(b) (Slimei Drain Water LevelMonitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring),3.2 (Weekly Inspection ofSolution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area tnspections) will be
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Page 15 of33
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDp.
Draft Date: June-HAugUqt t, 20056
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JUIyAUCqSI_,2006{
APPBNDIX A
FORMS
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JulyAuCu$ _,20056
APPENDTX A (CONT.)
DAILY INSPECTION DATA
Inspector:
Date;
Accompanied by:_
Time:
Any Item not "oK" must be documented. A check ffiork = oK, x = Action Required
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Page 17 of33
I. TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concern Cell I Cell2 Cell3
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharse Improper Location or Orientation
II. OPERATIONAL SYSTEMS
Greater Than Operating Level, Large Change
Since Previous Inspection
Cracks, Severe Erosion, Subsidence
Liner and Cover
III. DIKBS AND EMBANKMENTS
Sloughs or Sliding Cracks, Bulges, Subsidence,
Severe Erosion, Moist Areas, Areas of Seepage
Outbreak
Cracks, Subsidence, Severe Erosion
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JCIAUSEI _,20056
V. PHYSICAL INSPECTION OF SLURRY
LrNES(S)
Walked to Discharge point
Observed Entire Discharge Line
Yes
Yes
Revision: ruSA-2
Page 18 of33
--No
----No
IV. FLOW RATES
VI. DUST CONTROL
Wind Movement of Taili
Precioitation:inches liquid
General Meteorological conditions:
VII. DAILY LEAK DETECTION CHECK
Leak Detection System
Checked
-Wet-DryInitial Ievel
Final level
Wet_Dry
Initial level
Final level
-wet_DryInitial level---
Final level
Gal.
VIII OBSERVATIONS OF POTEN
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JulyAuCu$ _,2005.6
[MAP OF TAILINGS AREA]
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Page 2l of 33
H
InsDectors:
Cell l:
Cell3:
Roberts Pond:
Pump functioning properly
Pump Timer set at l5min on 45 min off
(all measurements are depth-in-pipe)
Post-pump head is 38' -Depth to Liquid posr
PumD =
h^+^.
Date:
l. Pond elevations (msl.ft)
2. Slimes Drain Liouid Levels Cett 2
3. Leak Detection Systems
APPENDTX A (CONT)
INTERNATIONAL URANIUM (USA) CORPORATION
WBEKLY TAILINGS INSPECTION
Draft Date: J$e-++dqg!Slll, 20056
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4. Tailings Area Inspection (Note dispersal of blowing tailings):
Revision: ruSA-2
Page 22 of 33
Observation:
Cell I Cell2 Cell3 Cell4,A.
Is LDS wet or dry?wet drv wet drv wet drv wet drvIf wet, Record
liquid level:
Ft to
Liquid
_Ft to
Liquid
_Ft to
Liquid --Ft
to
LiquidIf sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate
Volume
Flow Rate
Volume
Flow Rate
Volume
Flow Rate
Was fluid sample
collected?-yes_no -yes-no -yes_no -yes_no
5. Control Methods Implemented:
Remarks:6.
7.Contaminated Waste Dump:
Draft Date: June-t+4Ugqqll, 20056
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Page 23 of 33
APPBNDTX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeline:
Pipe Thickness:(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch I
-yes_no
VCS NO
_yes_no
-yes-no
Diversion Ditch 2
-yes_no
ves no
_yes_no
-Yes
no
Diversion Ditch 3 Diversion Berm 2
-yes-no
ves no
_yes_no
ves no
-yes_no
-yes_no
3. Summary of Activities Around Sedimentation pond:
Draft Date: June{+Augqgll, 20056
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4. Overspray Dust Minimization:
Overspray system functioning properly: _yes_no
Revision: ruSA-2
Page 24 of 33
Overspray carried more than 50 feet from the cell:
If "yes", was system immediately shut off?
Comments:
yes_no
-yes_no
5. Remarks:
6. Settlement Monitors
Cell2 Wl:
Cell2W2:
Cell2 W3:
Cell2 W4:
Cell2WT-C:
Cell4A-Toe:
Cell2W3-S:
Cell2El-N:
Cell2El-1S:
Cell2El-2S:
Cell2 East:
Cell3-1N:
Cell3-1C:
Cell3-lS:
Cell3-2N:
Cell2W5-N:
7. Summary of Daily, Weekly and euarterly Inspections:
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APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
8. Embankment Inspection:
9. Operations/lVlaintenance Review:
10. Construction Activites:
11.. Summary:
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Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
yes: no:
Conditions of storage areas for materials:
Other comments:
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JulyAuCli! _,20056
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Draft Date: Jrlne-l?AuSull3, 20056
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APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals forconducting daily tailings inspections. Training information is piesented byitre Radiation SafetyOfficer or designee from the Environmental Department. Oailytailings inspections are conducted inaccordance with the White Mesa Mill Tailings Management Systemand bischarge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Ofiicer or designee from the RadiationSafety Department is responsible for performing monthly and quarterly tailirigs inspections. Tailingsinspection forms will be included in the monthly tailings inspection reports, which summarize theconditions, activities, and areas of concem regarding the tailings ur.ur.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring noaction) or that conditions of potential concern exist (requiring action). A "check,, mark indicates noaction required. If conditions of potential concem exist the inspector should mark an..X,, in the areathe condition pertains to, note the condition, and specify the corrective action to be taken. If anobservable concem is made, it should be noted on the tailings report until the corrective action istaken and the concern is remedied. The dates of all corrective actions should be noted on the reportsas well.
Any major catastrophic events or conditions pertaining to the tailings area should be reportedimmediately to the Mill Manager or the Radiation Safety bfficer, one of whom will notify Co.porut"Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. rfr"Mill Manager will then notify Corporate Management, MSHA (303-231-5+?S), anO the State ofUtah, Division of Dam Safety (S01-539-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to benoted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailingsinspection form' The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
Draft Date: Jr*e-++AUguit_1, 20056
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JcyAUgq! _,20056
Revision: ruSA-2
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inspected particularly for
need to be inspected for
inspected for damage and loss of support. Valves are also to be
leaks, blocked valves, and closed valves. points of discharge
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concem for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. tn Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and tumed into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
lnspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas ofconcern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
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Page 30 of 33
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all sluny lines has to be made every hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and,4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. [n addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
1. Cover area
2. BeacMailing sands area
3. Solution as it exists
4. Pump lines
Draft Date: June-l+AUgUrt l, 20056
7.
8.
White Mesa Mill - Standard Operating Procedures
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Revision: IUSA-2
Page3l of33
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)6. Slurry discharge when operating7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
l. The posted speed limit for the tailings area is 15 mph and should not be exceeded.2. No food or drink is permitted in the area.3. All personnel entering the tailings area must have access to a two-way radio.4. Horseplay is not permitted at any time.5. Only those specifically authorized may operate motor vehicles in the restricted area.6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
atea.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved lifejacket. A portable eyewash must be present on site as well.8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daiiy tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
10.
11.
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JulyAqCus! _,200!d
Revision; IUSA-2
Page 32 of 33
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potentiat problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
Draft Date: J+rne-++AggUst .1, 20056
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JulyAucu$ _,20056
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APPENDX D
FEESTOCK STORAGE AREA
Draft Date: Jnae-l+AUgUSE, 20056
IxrgnNnuoNAL
Unextutvt (usn)
ConponATIoN
lndependence plaza, Suite g50 r 1050 Seventeenth street o Denver, co 80265 . 303 628 7798 (main) ' 303 389 4125 (fax)
June 17,2005
VIA FEDEX
Dane L. Finerfrock, Executive Secretary
Utah Radiation Control Board
Utah Department of Environmental Quality
168 North 1950 West
P.O. Box 144810
Salt Lake City, uT 84114-4810
., )C05'\*
Re: Draft Tailings Management System and Discharge Minimization Technology
("DMT") Plan Untler State of Utah Ground Water Discharge Permit No.
UW370004 (the .'GWDP") for the White Mesa Uranium Mill
Dear Mr. Finerfrock:
Enclosed please find a draft White Mesa Mill Tailings Management System and
Discharge Minimization Technology (DMT) Plan (the "Plan"), as required under Part
LH.i3 of the GWDP, lbr your review and comment.
A number of the DMT requirements under the GWDP are already incorporated into the
Mill's existing Tailings Management System Monitoring Plan under the Mill's State of
Utah Radioactive Materials License No. UT1900479. That existing plan has been
modified and expanded to include the remaining DMT concepts required under the
GWDP. The Plan, as rnodified, is intended to continue to be a procedure under the
Radioactive Materials License.
If you have any questions or require any further information, please contact the
undersigned.
Yours truly,
Ron Hochstein
Harold Roberts
T. Ken Miyoshi
Ron Berg
David C. firydenlund
Vice President and General Counsel
White Mesa Mill - Standard Operating Procedures
Book 1 I : Environmental Protection Manual, Section 3. I , Appendix EJuly ,2005
Revision: IUSA-2
Page I of27
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring ofthe tailings cell
system as required under State of Utah Radioactive Materials License No. UT19OO479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike itability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at theMill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Dail),ComprehensiveTailingsInspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with trainirg, u,
described in Section 2.4 below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Dataform(a copy of
which is attached in Appendix A). The Daily Inspection Dataform contains an inspection checklist,
Draft Date: Jurre 17,2005
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision:IUSA-2
Page2 of27
which includes atailings cells map, and spaces to record observations, especiallythose of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" speciSring what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 44, Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation , Cell}
spillway, Cell 3 and 44 liquid pools and associated liquid return equipment, cell leak detection
systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
i)
Draft Date: June 17,2005
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurrylines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell I or Cell
3; the pond return line from the tailings area to the Mill; and, lines transporting
pond solutions from one cell to another.
Cell I
Cell2.
Cell 3.
Cell4,{.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 and Cell 4,A' liquid pools and associated liquid return
equipment.
Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
b)
c)
d)
e)
s)
h)
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision:IUSA-2
Page3 of27
Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement,2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as apercentage ofthe total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
and4A.
Locations of slury and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
p) Daily measurements in the leak detection system (LDS) sumps of the
cells will be made when warranted by changes in the solution level
respective leak detection system.
The trigger for further action when evaluating the measurements in any of the
leak detection systems is a gain of more than 12 inches in 24 hours. If this
observation is made, the Mill Manager should be notified immediately and the
leak detection system pump started.
whenever the leak detection system pur.np is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition I 1.3.B through 1 1.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
i)
k)
r)
m)
n)
o)
tailings
of the
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book 1 l : Environmental Protection Manual, Section 3. 1 , Appendix EJuly ,2005
Revision: IUSA-2
Page 4 of27
q) An estimate of the percentage of the tailings beach surface area and solutionpool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4,A..
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Dail), Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection ofthe tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on ihe
Operating Foreman's Daily Inspection form.
2.3. Dail), Operations Patrol
In addition to the inspections desuibed in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Trainine
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure forperforming the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. TailingsEmergencies
Inspectors will notifr the Radiation Safety Officer andlor Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page 5 of27
Any major catastrophic events or conditions pertaining to the tailings a.rea should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notiff Corporate
Management. If dam failure occurs, notiff your supervisor and the Mill Manager immediately. TheMill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailines Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. Cell 4,{ has a blow tube, which has been measured
and marked. Once solutions have been identified by blowing air into the tube at a
given depth, the tube is pulled from the tubing encasement and the measurements
are extracted from the marked tubing.
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be retumed to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and analyzed in accordance with paragraph 1 1.3 C. of the Radioactive Materials
License.
Slimes Drain Water Level Monitoring
Cell 3 is an active tailings cell while Cell 2 is partially reclaimed with
a)
b)
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page 6 of27
approximately 90o/o of the surface covered by platform fill. Each cell has a
slimes drain system which aids in dewatering the slimes and sands placed in the
cell. Depth to wastewater in the slimes drain access pipes shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and
after a pumping cycle, respectively. The slimes drains in cells 2 and 3 are
checked for depth to solution using the notched area on the center-line of the
access pipe as a reference point and measuring the distance to the wetted end of
the inserted pipe after it has been removed from the system. Because Cell 3 is
currently active, no pumping from the slimes drain is authorized. Cell 2 has a
pump placed inside of an access pipe and at the bottom of the slimes pool depth
approximately one foot above the flexible membrane liner ("FML"), which,
based on historical construction information, is the lowest point on the FML
found at or near the base of the slimes drain access pipe for Cell 2. This pump is
on a timed system, which maintains the liquid level at or near the pump suction,
which is placed at the lowest point possible in the slimes drain access pipe. This
maintains the water level as low as is reasonably achievable. The Cell2 slimes
drain is pumped every fifteen minutes automatically and the pump is checked
weekly to observe that the pump is operating.
Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1 and 3 are to be taken on a weekly
basis using survey equipment that is accurate to 0.1 inches.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are to be taken on Roberts Pond. The measurement is the
depth to solution level in Roberts Pond off the end of the pond pump support using a transit and
surveying rod and a reference survey point. The Weekly solution level in Roberts Pond is recorded
Draft Date: June 17,2005
c)
d)
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
PageT of27
on the Weekly Tailings and DMT Inspection form.
3.3. Weekly Feedstock Storaqe Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that the bulk feedstock materials are stored and maintained within the defined area described
in the GWDP and that all alternate feedstock located outside the defined Feedstock Area are
maintained within water tight containers. The results of this inspection will be recorded on the
Weekly Mill Inspection form. Any variance in stored materials from this requirement or observed
leaking alternate feedstock drums or other containers will be brought to the attention of Mill
Management and promptly rectified.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data fonrr,an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined bythe Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches I,2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm2shouldbe checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentationpond shall be summarized
for the month.
Overspray Dust Minimization
a)
b)
4
d)
Draft Date: June 17, 2005
White Mesa Mill - Standard Operaring Procedures
Book I 1 : Environmental Protection Manual, Section 3. I , Appendix EJuly ,2005
Revision: IUSA-2
Page 8 of27
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
Oper atio ns / Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
Construcl.ion Review
The Construction Review consists of reviewing any construction changes or
J)
o)
b)
c)
Draft Date: June 17,2005
White Mesa Mill Standard Operaring Procedures
Book l1: Environmental Protection Manual, Section 3.1, Appendix
July _, 2005
Revision: IUSA-2E Page9 of27
a quarterly basis.modifications made to the tailings area on
d) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measues taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and conesponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterlytailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concem. The
evaluation also involves discussion with the Environmental andlor Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
Draft Date: June 17, 2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3. 1 , Appendix E
July _, 2005
Revision:IUSA-2
Page 10 of27
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September I't of every year to:
6.2.
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake city, utah 84116-3156
Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Eyaluation Report of the
tailings management system.
6.3. Freeboard Limits
Tailings Cells I and 4A
The fi'eeboard limits are as per January
and 4A and are stated below:
10, 1990 Drainage Reportfor Cells l
a)
(i)
(ii)
b) Tailings Cell 3
A liquid maximum elevation of 5,615.4 feet mean sea level in cell 1.
A liquid maximum elevation of 5,596.4 feet mean sea level in cell44.
The fieeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
(ii) An estimate of the maximum tons of dry tailings to be generated during
the next 12 months will be made. This estimate is multipried by 1.5, a
factor of safety, to yield the Maximum Mill production.
Draft Date: June 17, 2005
(iii) The Maximum Mill Production is divided by the number oftons required
White Mesa Mill - Standard Operating Procedures
Book 1 I : Environmental Protection Manual, Section 3. I , Appendix Ejuly _, 2005
(i")
6.4.
Revision: IUSA-2
Page 1 I of27
(v)
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 723.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the pMp
Freeboard Level.
The Wave RunUp of 0.78 feet (as specified inthe January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
c)
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Central File.
Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be atalyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Dato and,
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailines Reports
Dralt Date: June I 7. 2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision:IUSA-2
Page 12 of27
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Offrcer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along withthe observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part LF.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution Levels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP.
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
APPENDIX A
FORMS
Revision:IUSA-2
Page 13 of27
Draft Date: June 17, 2005
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CELL 1.I
CELL {.A
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page 18 of27
Date:
l. Pond elevations (msl,ft)
2. Slimes Drain Liquid Levels
APPENDTX A (CONT)
INTERNATIONAL URANIUM (USA) CORPORATION
WEEKLY TAILINGS INSPBCTION
lnspectors:
Cell 1:
Cell 3:
Roberts Pond:
Cell 1:
Cell2:pohms
Cell 3:
Cell4,A:
3. Leak Detection Systems
4. Tailings Area Inspection QrJote dispersal of blowing tailings):
Feet to Liquid
Gallons Pumped
Beginning Level
Ending Level
Gallons Pumped
Observation:
Cell I Cell2 Cell3 Cell4A
Is LDS wet or drv?wet drv wet drv wet drv wet drvIf wet, Record
liquid level:
_Ft to
Liquid
_Ft to
Liquid
Ft to
Liquid
Ft to
Liquid
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volunre
Flow Rate
Volume
Flow Rate
Volume
Flow Rate
Volume
Flow Rate_
Was fluid sample
collected?
_yes_no ves no _yes_no yes_no
5. Control Methods Implemented:
Draft Date: June 17,2005
White Mesa Mill - Standard Operating procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page 19 of27
6. Remarks:
7. Contaminated Waste Dump:
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3. I , Appendix E
July _, 2005
Revision: IUSA-2
Page2} of27
APPENDX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeline:
Pipe Thickness:(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Comments:
Diversion Ditch I
_yes_noyes_no
_yes_no
Diversion Ditch 2
yes no
yes
_yes_no yes
no yes
Diversion Ditch 3 Diversion Berm 2
yes noyes no
yes ves
yes
yes
no
no
3. Summary of Activities Around Sedimentation pond:
Draft Date: June I 7. 2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3.l, Appendix E
July _, 2005
4. Overspray Dust Minimization:
Overspray system functioning properly: yes_no
Overspray carried rnore than 50 feet from the cell: _yesIf "yes", was system immediately shut offl
Comments:
ves
Revision:IUSA-2
Page2l of27
5. Remarks:
6. Settlement Monitors
Cell 2 W1:
Cell2W2:
Cell2 W3:
Cell2 W4:
Cell2WT-C:
Cell4A-Toe:
Cell2W3-S:
Cell2El-N:
Cell2El-1S:
Cell2El-2S:
Cell2 East:
Cell3-1N:
Cell3-lC:
Cell3-lS:
Cell3-2N:
Cell2W5-N:
7. Summary of Daily, Weekly and Quarterly Inspections:
Draft Date: June 17, 2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page22 of27
APPENDTX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
8. Embankment Inspection:
9. Operations/lVlaintenance Review:
10. Construction Activites:
[1. Summary:
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1, AppendixJuly ,2005
Revision: IUSA-2
Page23 of27
APPENDIX B
TA I LI N GS'NSPECTO R T RAI N I N G
This document provides the training necessary for qualifiring management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will noti$u Corporate
Management. If dam failure occurs, notiff your supervisor and the Mill Manager immediately. TheMill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
Draft Date: June I 7, 2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3. I , Appendix E
July _, 2005
Revision: IUSA-2
Page24 of27
inspected particularly for
need to be inspected for
)
inspected for damage and loss of support. Valves are also to be
leaks, blocked valves, and closed valves. Points of discharge
improper location and orientation.
Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas ofconcern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concem forponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposrre to sunlight will cause degradation
ofthe PVC liner. Small areas of exposed liner should be covered byhand. Largesections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. Afterthese conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Bmbankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas ofconcern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
Flow Rates:
3.
4.
Draft Date: June 17.2005
White Mesa Mill - Standard Operating Procedures
Book I I : Environmental Protection Manual, Section 3. I , Appendix E
July _, 2005
Revision: IUSA-2
Page25 of27
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation ofthemill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
5.
6.
7.
8.
l.
2.
1J.
4.
Cover area
Beach/tailing sands area
Solution as it exists
Pump lines
Draft Date: June 17,2005
White Mesa Mill - Standard Operating Procedures
Book l1: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page26 of27
9.
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)6. Slurry discharge when operating7. Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
atea.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved lifejacket. A portable eyewash must be present on site as well.8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review ofthe
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
10.
11.
Draft Date: June 17, 2005
White Mesa Mill - Standard Operating procedures
Book ll: Environmental Protection Manual, Section 3.1, Appendix E
July _, 2005
Revision: IUSA-2
Page27 of27
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person
system at the White Mesa Mill.
is qualified to perform the daily inspection of the tailings
Radiation Safety Personnel/ Tailings System
Supervisor
Draft Date: June I 7, 2005
State of Utah
JON M. HUNTSMAN, JR
Governor
GARY HERBERT
Lieutenant Govemor
!)r*r*ent of
Environmental Quality
Richard W. Sprott
E*ecutive Director
DIVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
September 17,2008
Mr. Ron Hochstein, President
Denison Mines (USA) Corp. (DUSA)
1050 l7th Street, Ste. 950
Denver, CO 80225
Dear Mr. Hochstein:
SIJBJECT: September 16, 2008 DUSA Email Conveying Proposed Revisions tothe CelI4A BAT
Monitoring, Operations and Maintenance Plan (O&M Plan); September 16, 2008 DRC
Email with Comments on the O&M Plan; September 12,2008 DUSA Email conveying
Proposed Revisions to the Wite Mesa Mill Tailings Management System; and Discharge
MinimizationTechno;logy @Mf) Monitoring Plan (DMT Plan) and the O&M Plan; '
O&M and DMT Plan Approval, and Authorization to Operate Tailings Cell4A
We have received and reviewed the subject submittals. The September 16,2008 DUSA submittal
conveyed the "09/08 Revision Denison 1.3" of the O&M Plan for Cell4A without figure attachments. The
September 12,2008 DUSA submittal conveyed "09/08 Revision: Denison-6" of the DMT Plan and an
earlier "09/08 Revision Denison l.2" version of the O&M Plan with all attachments. We have compared
these submittals to our corlment email dated September 16, 2008, and to our previous comment lefter
dated September 10, 2008. Therefore, we hereby approve these versions of the Cell 4,A. O&M Plan and
the DMT Plan with the September 12,2008 attachments, copies of these documents are attached herewith.
The items in our letter of July 29,2OO8 regarding major items needing reqolution prior tb beginning the
operation of the cell now appear to be completed, therefore we hereby authorize DUSA to operate
reconstructed Cell4A.
IJTAH RADIATION CONTROL BOARD
DLF:LBM:DAR:dT
Attachments
cc: Mr. Harold Roberts, Executive V.P., DUSA
F:\DUSA\Cell 4A\Op ApprovalWlonitoring, O&M Plan\Plan Approvals & Auth to Operate 09-08
168 North I 950 West . Salt lake City, UT
Mailing Address: P.O. Box 144850 . Salt lake City, UT 841l4-4850
Telephone [phone]. Fax [phone] . T.D.D. (801) 5364414
www.deq.utoh.gov
Printed on 100% recycled paper
Dane L. Finerfroc
Executive Secretary
roNM.ilro*,r*.
Govemor
GARY HERBERT
Lieutenant Governor
State of Utah
Department of
Environmental QualitY
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
Il,day 9,2007
David C. Frydenlund
Denison Mines (USA) CorPoration
Independen ce Plaza, Suite 950
1050 Seventeenth Sffeet
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: January 24,2007 Unresolved Issues and Request for Information; Novembet 9,2$6Draft
White Mesa Mill Tailings Management System and Discharge MinimizationTechnology
@MD Monitoring Plan;July 10,2006 DRC Confirmatory Action Letter
We received revision 3/07 of the subject plan with your cover letter dated March 14,2OO7 . The submittal
met the response date required by the subject January 24,2007 DRC letter, and addresses the majority of
the points iaised. Thereiore, til 03/07 Revision of the White Mesa Mill Tailings Management System and
Disiharge MinimizationTechnology @MD Monitoring Plar submitted is hereby approved with the
following comments:
1. In Section 3.3, Weekly Feedstock Storage Area Inspections, the results of the inspections are to be
recorded on the Ore itorage/Sample Plant Weekly Inspection Report, which has been omitted.
This report form must be added to Appendix A. The adequacy of the form will be evaluated at the
next related DRC insPection.
2. Regarding Cell},
A.) The DMT plan and the cover letter express that there is no need to consider other types of
pumping systems, as the reduction of the static head in Cell 2 is not a function of the speed
of pr-p1ng out of the slimes drain access pipe and there are no practical alternatives.
However, no justification for these claims was provided'
B.) Apart from pumping, it is important to note that the depth of static head on the Cell 2 liner
can be reduced by methods such as covering the tailings, improving transpiration, etc., to
meet the DMT performance standards (Ground Water Discharge Permit I.D.3'b).
C.) Attaining minimum head on the Cell 2liner is a major step to closure of the cell.
168 North 1950 west . pO Box 144850. Salt Lake City, UT 841 144850. phone [phone] 'fax [phone],97
T.D.D. (801 ) 536-4414' www.deq.utah. gov
David Frydenlund
May 9,2007
Page2
D.) please be advised the Ground Water Discharge Permit will soon be modified to reflect the
new DMT performance standard for average annual head on the Cell 2 slimes drain'
rn the future, please submit the quarterly DMT Monitoring Reports under separate cover from the quarterly
ground water quality rePorts.
If you have any questions on the above, please contact Dave Rupp at (801) 5364250'
UTAH RADIATION CONTROL BOARD'
0., "\Dane{inerfrock '\f
Executive Secreta
DLF:LBM:DAR:dT
Cc: Dean Henderson
F:\drupp\wp\ IUC\ G.W.D.P. & DMT Plan\DMT Plan Approval 0547
Fite: 137 IUC DMT Plan
State of Utah
DePartment of
Environmental QualitY
Dianne R. Nielson, Ph'D'
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
JON M. HUNTSMAN, JR
Govemor
GARY HERBERT
Lieutenant Governor
January 24,2007
168 North 1950 west. Po Box 144850. Salt lake Ciry, UT 841 14.4850. phone [phone]. fax [phone]
CERTIFIED MAIL
(Return ReceiPt Requested)
David C. Frydenlund
Denison Mines (USA) CorPoration
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: september 26,zu'Unresolved Issues and Request for Information; August 3, 2006 Draft
Wite Mesa Mill Tailings Management System and Discharge Minimization Technology
(DMT) Plan;ttly 10, 2006 DRC Confirmatory Action Letter
We received your letter dated Novembe r 9,20O6 on the subject' The letter met the response date required
by the subject September 26,2OO6DRC letter. we note that an acceptable method for monitoring the
head in the slimes drains is now provided in the plan. Also, your proposed change in the frequency of such
monitoring to monthly from weekly is acceptable'
However, we did find the response to be incomplete' Please revise the plan to fully resolve the following
comments:
l. ln the plan, paragraphs 3.l.d.viii.B & c need to be completed to indicate the actions to take with
,"tp".l to the painted marks and the surface measurements'
2. The items in the Quarterly Inspections Data form in Appendix A need to be renumbered to begin
with item one rather than eight'
3. paragraph 3.l.vi in the plan needs to make clear that for the Cell 2 slimes drain, the head recovery
test requires at least g0iours for the head to stabilize (as of November 2006)' For details, refer to
theattachedrecoverygraphfromdataprovidedbyDenisonMinesatourvisitonDecember5,
2006.
T.D.D. (801 ) 536-4414' www'deq'utah'8ov
David Frydenlund
January 24,2007
Page2
4. Regarding the wastewater head on the liner in cell2'Part I'H'13'd of the Permit requires the
permittee to determine an average ailowable head that is as low as reasonably achievable
(ALARA). The existing pumping .v.1"* n"t been functioning there for a long time' If there have
been no pro."r, irno*i it " ti"rA ;;r;r; been. stabilized to a static level by that same pumping
system. Ho*"ro, ,t e head "outo
ulro be increasing or decreasing. The monthly changes in the
head are ,rk ;;; b"cause no historic head monitoring has been done'
Paragraph 3.1.b.iii of the current DMT plan mentioT.that mill management considers that the head
in cell 2 from the existing pu-pi,g ,y.iem is ALIRA. However, no justification for this claim
was provide;. A, not"d ibor", the"head in the cell may have been stabilized by the existing
pumping ryri"-, U", it may not be ALARA. This is because more efficient pumping systems may
be available to lower the head even further'
Please provide additional information and justification to show the existing pumping system
equipmentandoperationprovidesbothac'osteffectiveandmaximumannualwastewaterremoval'
conversely, if there are other pumping systems-that can produce-a maximum annual removal of
wastewater in a cost effective -urr"r, pi"ase identify and describe them'
To verify that the existing pumping system is ALARA will require two demonstrations' as
follows:
a,MaximumandCostEffectiveRemovalofWastewater,asmentionedabove,and
b. A Declining or Static wastewater Head - Evidence must be provided that the slimes drain
wastewater head in celll.i, j".rining or static. The static head case is appropriate in the event
that the above cost effectiv" unJrnu*Ir.rum pumping case is made and accepted' conversely'
an increasing wastewater tread in Cell1is not eln-nA' and is not accePtable to the DRC'
Byexclusionofallprocessliqlidinflowtocell2,measuringmonthlythestabilizedstaticwater
level in the tailings and using head recovery tests, reports ani graphs will be generated which show
monthly *"rJ. uid un urruul ur"rug" headfor the ylar 2007' The following calendar year'
measurements will be comparea io-tt pr""ious year. If the average annual head is not decreasing'
it will be necessary to install u lnor" efficient pumping system' until Denison can determine an
average allowable head that is ALARA' as described above'
Therefore, the DMT Plan needs to include the following:
a. n*"turion oiutt p.o""rs liquid inflow to cell 2. (PartI.D.3.b)
b. Effective immediately, tt " montt'iv slimes drain head recovery test results and readings for
cell2are to be reported with the quarterly-reports per P1t I r'.2 of.the permit' The reports will
include the content required bt P; II.G ;f the permit' Records will be maintained in
u."oroun.L *itt' p* i'}I of tire permit' In addjtion'
(1) All recovery tests must b" il be performed each month at regular intervals' and for a
minimum duration of 90 hours each'
rt (notch at the north
(2)Allheadmeasurementsmustbemadefromthesamemeasunngpolr
,iO. of it'" uccess pipe)' and made to the nearest 0'01 foot'
(3)An.,,,"r.u,n*ury",ag'upt,rorelhc.alendaryearofthese.measurementsmustbe
included in the fourth qr"""i."ion. Rrr", the first year, and-beginning in 2008, quarterly
reports strAr include uottr ttre .rit " year monthly values and a graphic comparison to the
Previous Year'
David Frydenlund
January 24,2N7
Page3
c.Aperformancestandardsuchthatifatanytimethemostrecentaverageannualheadisfound
to have increased above the average head for ihe previous calendar year, Denison Mines will
comply with the DMT Failure requirements of Part I.G.3 of the Permit (including but not limited to
reporting and corrective actions)'
please review the above comments, and incorporate needed charges intoaJinal-revisedwhite Mesa Mill
Tailings Management System and Dischargi t tini*tro'ion Technolog (DMT) Plan' and submit such for
our approval. Per yow dir.urrion with David Rupp of DRC on-January 8, 1_001.f:aSreed
to fully
respond to these items within 45-days of receipt ofint letter. If you have any questions on the above'
please contact him at (801) 5364250'
UTAH RADIATION CONTROL BOARD,
Enclosure: Slimes Drain Recovery Graph
DAR:dr
F:\drupp\wp\ IUO G.W.D'P' & DMT Plan\DMT Rev2 0147
File: 13? IUC DMT Plan
Dane Finerfrock
Executive Secret
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State of Utah
Depafiment of
Environmental QualitY
Dianne R. Nielson, Ph.D.
Execulive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
roN M. rt *o*, r*.
Governor
GARY HERBERT
Lieutenant Govemor
September 26,2006
168Northl950West.POBox144850'SaltLakeciry,UT84ll4-4850'phone[phone]'fax[phone]'7
T.D.D. (801 ) 53 6-441 4' wunv'deq'utah' gov
David C. Frydenlund
lnternational Uranium (USA) Corporation
Independenc e Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Dear Mr. Frydenlundi
SUBJECT: August 3,2OO6Draft Tailings Managementsystem & Discharge Minimization
r".nrorogv @MT) plan; Jujy 10, 2d06 DRC Confirmatory Action Letter: Unresolved
Issues and Request for lnformation
we received your letter dated Augus t3,2}06on the subject. The letter met the response date required by
the subject DRC Confirmatory Aition lette, aateO July t0, 2006. However, we found the response to be
incomplete. our comments follow, with the item numbers colTesponding to the same item numbers in your
letter:
l. It was the intent of the Ground Water Discharge Permit part I.H.l3'a, and our corresponding
comments "f F"b*rrl il,2006,r* ruc to es'tablish fixed locations for measurement of the liquid
surface elevations. Therefore, to eliminate random locations from being used, verbiage needs to be
added to the UMT plan, which describes fixed locations for the liquid surface elevation
measurements. The methods to consistently use the same locations should be included in the plan'
Apotentiallocationforsomecellsmightbethewatersurfaceadjacentthepumpintake'
lnadditiontotheabove'andtobeinagreemenlwiththeaboveintent,welecommendtheverbiage
in Section l. t a of ttre DMT plan be revised to leflect the use of specific locations'
For all the cells and Roberts Pond, the pond bottom elevation, and the depth of the water above the
lowestpointofth"FMLneedtoberecordedontheWeeklyTailingslnspectionform,revisedto
include such.
Z. The DMT plan needs to include a method to measure the static head above the liner in Cell No' 2
as part of the performance criteria for the ground water discharge permit ruGwDP Part I'D'3'b)'
By measuring the change of the static watlr level in the tailings, IUC will be able to show if the
diop in f,"uJL being oitimized by the pumping technique being used.
David Frydenlund
September 26,2006
Page2
Potential options to measure the static head above the liner include installing a piezometer near the
slimes drain access pipe, or shutting off the pump and measuring the water level after static
equilibrium has been reached (i.e. a head recovery tes0. Ifa recovery test is used, a standard
methodology would need to be developed. Also, the fixed location for the measurement on the
piezometer or access pipe would need to be specified.
As a future reference, the ground water discharge permit will need to be modified to include a
decline of the static water levels in the tailings as a performance criterion (UGWDP Part I.D.3.b).
The Weekly Tailings lnspection form will need to be revised to include the static head
measurement.
3. No comment on response.
4. For the Roberts Pond, the elevation of the pond pump support appears to need to be recorded on
the Weekly Tailings lnspection form to determine the lowest pond bottom elevation.
5- 14. No comments on the responses.
Please review the above comments, and incorporate appropriale changes into a revised Drafi Tailings
Management System & Discharge Minimization Technology (DMT) Plan, and resubmit such for our
approval. On September 22,2006 you discussed the above by telephone with Mr. David Rupp of the DRC.
You committed that IUC would fully respond to the above concerns on or before November 10, 2006. If
you have any questions on the above, please contact David Rupp at (801) 5364250.
UTAH RADIATION CONTROL BOARD,
DAR:dr
F:\drupp\wp\ ruC\ G.W.D.P
File: 137 IUC DMT Plan
& DMT Plan\DMT Revl review 09-06
tt
ri
o
HUNTSMAN
Govemor
JON M.
GARY HERBERT
Lieutenant Governor
, JR.rffit
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OFRADTATION
CONTROL
Dane L. Finerfrock
Direaor
July 10,2006
CEIITIFIED MAIL
(Return Receipt Requested)
Mr. Harold R. Roberts
Vice President - Corporate Development
International Uranium (IUSA) Corporation
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Dear Mr. Roberts:
Subject:Confirmatory Action Letter - ruC Wite Mesa Mill Tailings Management
System and Discharge Minimization Technology (DMT) Mtnitoring Plan, and
DRC Irtter Requesting Additional Information
We received the subject plan via an IUC letter dated June 17, 2005, as required by Part I.H.l3 of
your Ground Water Discharge Permit. Following, by DRC letter dated February 2I,2006,we
requested additional information. Yesterday, July 5,2006, an enforcement conference was held
under the authority of UAC R313-14-15(5Xb). This phone call included you, David Frydenlund,
Loren Morton and David Rupp. During this conference call we agreed upon the date of August 4,
2006, for IUC to submit a complete response on this matter. In addition, we also discussed the
items in the February 2l,2006letter.
Our review of the submittal will be based upon the IUC Ground Water Discharge Permit, and
Discharge Minimization Technology as outlined in Parts I.D. and I.H.l3 of the permit.
168 North ! 950 West . PO Box 144850 . Sah Lake City, UT 841 l4-4850 . phone [phone]' fax [phone]'7
T.D.D. (801) 536-4/14 . wu,tat.deq.utah.Sov
We await your response on this matter.
UTAH RADIATION CONTROL BOARD,
F:\druppVUC\Action L.t.r DMT Plan 07-06.doc
File: IUC G.W. Permit Section 137
,ffi o
HTJNTSMAN
Govemor
JON M.
GARY HERBERT
Lieutenant Governor
, JR.
State of Utah
Departrnent of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Arector
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
w,t'
February 2L,2O06
David C. Frydenlund
International Uranium (IUSA) Corporation
Independen ce Plaza, Suite 950
1050 Seventeenth Street
Denver, CO 80265
Subject: June 7, 2005 Draft Tailings Management System & Discharge Minimization Plan
Technology for UGWDP #LIW370004 for the White Mesa Uranium Mill (UT1900479)
Request for Additional Information
Dear Mr. Frydenlund,
We have reviewed the Draft Tailings Management System & Discharge Minimization Plan
Technology submitted on June 7, 2005 in accordance with the UGWDP #UW370004. We have
noted several deficiencies in the submittal.
1. The report needs to detail the procedures for the measurement of the tailings cell pool
elevations and establish fixed locations for making the measurements. [Part I.H.13.a]
lPart I.E.6.a)l
2. The elevation of the FML for Tailings Cells 2 and 3 need to be determined and
reported. [Part I.H. 13.c]
Data showing the average head elevations in the slimes drain layers in Cells 2 and 3
are as-low-as-reasonably-achievable. The weekly form needs to specify if this
information is a depth-in-pipe measurement or a mean-sea-level elevation. If
conversion factors are used, they need to be shown on the form. [Part I.H.13.d] [Pan
r.E.6.b).1
The solution elevation in Roberts Pond needs to be correlated to the lowest point on
the pond's FML. [Part I.H.13.e]
The Weekly Mill Inspection form needs to be updated for the additional monitoring
requirements under the permit (i.e. Monitoring the Feedstock Storage Area). [Part
r.H.l3.fl
The draft report did not address Weekly monitoring and record keeping of the DMT
168 North 1950 West. PO Box 144850. Salt Lake City, UT 841 14-4850. phone [phone]. fax [phone]
T.D.D. (801) 5364414. wwu).deq.utah.gov
3.
4.
5.
6.
Page2 #I-]T1900479
Amendment #0
Monitoring Wells at Cell 1. [Paft I.H.13.g]
7. Data showing the maximum allowable head in the slimes drain for Cells 2 and 3 need
to be determined. The report showing what contingency actions will be taken should
the pump fail. [Part I.D.3.b).1)]
8. The report needs to address the maximum tailings waste solids elevation. [Part
r.D.3.b).2)lg. The plan for operating Cells 2 and 3 in order to prevent groundwater quality conditions
in mbnitoring wells from exceeding the Compliance Limits established in Table 2 of
the Permit needs to be addressed. [Part I'D.3.b).3)]
er elevation10. The report needs to address the steps that will be taken should the wastewatr
ex.eed the two feet of freeboard requirement in Roberts Pond. The report needs to
detail the procedure for measuring the pond elevation and establish a fixed.location for
making it. lPart I.D.3.c).] [Part 1.E.6.c)]
11. The report needs to address how compliance with
requirements will be ensured. [Part I.D.3.d)]
the Feedstock storage area location
12. The report needs to address secondary containment for mill site chemical reagents.
lPart I.D.3.e)l
13. The report needs to include the SOPs for the Feedstock Storage Area inspection. [Part
I.E.6.d).1 [Part I.E.6.d).i.]
14. The report needs to define the SOPs for ensuring the alternate feedstock materials
located outside the Feedstock Storage Area are maintained within water-tight
containers. lPart I.E.6.d).ii.]
If you have any questions or comments, please contact Loren Morton at [phone].
Sincerely,
JPC: jc
F:\FACILITIESUUC - WHITE MESA\Discharge Minimization TechnologyV006-02-09 Irtter -dmt -final.doc
Johnathan P. Cook, P.E.
Environmental Engineer
$,ffi$
,ll. rr*rrMAN.JR.
Goventor
GARY HERBERT
Lieulenari Got,ernor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DIVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
SUBJECT:
MEMORANDTIM
John Cook
Dean Henderson
December 28,2005
Discharge Minimization Technology (DMT) Monitoring PIan
Ground Water Discharge Permit (Permit)
Intemational Uranium Corporation (IUC)
White Mesa Mill, Blanding, Utah
I have reviewed the IUC DMT Monitoring PIan submitted on June 17, 2005. I found that
the DMT Monitoring Plan did not address and needs to include the following as required in
Part LII.13.B) of the Permit:
Part I.D.3.a) DMT Monitoring Wells at Tailings Cell 1 -at all times the Permittee
shall operate and maintain Tailings Cell I to prevent groundwater quality conditions
in any nearby monitoring well from exceeding any Ground Water Compliance Limit
established in Table 2 of this Permit.
Pan I.D.3.b).3) DMT Monitoring Wells - at all times the Permittee shall operate and
maintain Tailings Cells 2 and 3 to prevent groundwater quality conditions in any
nearby monitoring well from exceeding any Ground Water Compliance Limit
established in Table 2 of this Permit.
168 North 1950 West. PO Box I44850. Salt Lake City, UT 841 14-4850. phone [phone]. fax [phone]
T.D.D. [phone]. www.deq.utah.gov