DRC-2010-002103 - 0901a0688016e26e

OENISOJ)~~
MINES
February 26, 2010
VIA FEDERAL EXPRESS
Mr. Dane Finerfrock,
Co-Executive Secretary,
Utah Water Quality Board,
Utah Department of Environmental Quality,
168 North 1950 West
Salt Lake City, Utah 84114-4850
Dear Mr. Finerfrock:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: 303628·7798
Fax: 303 389·4125
www.denisonmines.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 4th Quarter of 2009
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
4A BAT Performance Standards Monitoring Report for the 4th Quarter of 2009, as required
under Parts LF.2 and LF.3 of the White Mesa Mill's State of Utah Groundwater Discharge
Permit No. UGW370004.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
cc Ron F. Hochstein
Harold R. Roberts
David C. Frydenlund
David E. Turk
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT
4th Quarter
October through December
2009
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Denison Mines (USA) Corp.
1050 I i h Street, Suite 950
Denver, CO. 80265
February 26,2010
TABLE OF CONTENTS
Page
I. INTRODUCTION......................................................................... 1
2. MEASUREMENTS TAKEN DURING THE QUARTER...................... 1
3. WEEKLY TAILINGS WASTE WATER POOL ELEVATION
MONITORING.................................................................................... 1
4. MONTHLY SLIMES DRAIN WATER LEVEL MONITORING ........... .
5. WEEKLY W ASTEW ATER LEVEL MONITORING: ROBERTS POND ..
6. WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND
INSPECTIONS OF FEEDSTOCK MATERIAL STORED OUTSIDE THE
3
3
FEEDSTOCK STORAGE AREA............................................................. 4
7. INSPECTIONS OF TAILINGS CELLS AND POND LINER SYSTEMS ... 4
8. CELL 4A BAT PERFORMANCE STANDARDS REPORT FOR THE
QUARTER.......................................................................................... 4
8.1 LDS Monitoring........................................................................... 5
a) Operational Status of LDS Pumping and Monitoring Equipment................... 5
b) Measurement (4 Weekly Fluid Head at the Lowest Point in the Secondary
Membrane....... ....... ....... ................. ......... ............... ........ .... ......... ........ 5
c) Measurement of the Volume of Fluids Pumpedfrom the LDS........................ 5
8.2 Measurement of Weekly Wastewater Fluids in Ce1l4A...................... ..... 5
8.3 Slimes Drain Recovery Head Monitoring............................................ 6
9. ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2009 ................................................................. ,...... 6
9.1 Individual Slimes Drain Recovery head Monitoring Data for 2009................. 6
9.2 Average Slimes Drain Recovery Head for 2009....................................... 6
9.3 Time Series Chart........................................................................... 6
9.4 Quality Assurance Evaluation and Data Validation.................................... 6
9.5 Demonstration of Compliance Status with the Requirements of Part I.D.3(b) and
I.E.7(b) of the Permit............................................................................... 8
9.5.1 Permit Requirements .................... """"'"'''''''''' ................... ,.... ..... 8
9.5.2 Demonstration ()f Compliance with Permit Requirements..................... 9
10. SIGNATURE AND CERTIFICATION ............................................ . 11
Attachment
A ................................... .
B .................................... .
C ................................... ..
D ................................... .
E ................................... .
F ................................... .
ATTACHMENTS
Description
Tailings Cell and Roberts Pond Wastewater Elevations
Monthly Cell 2 Slimes Drain Monitoring Data for 2009
Graph Showing Cell 2 Slimes Drain Water Levels Over Time
Liner Repair Report Dated June 25,2009
Cell 4A Leak Detection System Data
Monthly Cell 2 Slimes Drain Monitoring Data for 2008
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT FOR THE 4TH QUARTER
01<'2009
1. INTRODUCTION
This is the routine DMT Performance Standards Monitoring Report for the 4[h quarter of 2009
(the "Quarter") prepared by Denison Mines (USA) Corp. ("Denison"), as required under Part
I.F.2 of the White Mesa Mill's (the "Mill's") State of Utah Groundwater Discharge Permit No.
UGW370004 (the "Permit"), and the Routine Cell 4A BAT Performance Standards Monitoring
Report for the Quarter, as required under Part I.F.3 of the Penn it.
2. MEASUREMENTS TAKEN DURING THE QUARTER
During the Quarter, the following discharge minimization technology ("DMT") monitoring was
performed or addressed, as required under Part I.E.7 of the Permit:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3;
• Monthly slimes drain water levels in Cell 2;
• Weekly wastewater level measurements in Robert's Pond; and
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area.
Also during the Quarter, the following Cell 4A best available technology ("BAT") performance
standards monitoring was performed or addressed, as required by Part I.E.S of the Permit:
• Leak detection system ("LDS") monitoring for Cell 4A; and
• Weekly tailings wastewater pool elevations for tailings Cell 4A.
3. WEEKLY TAILINGS W ASTEW ATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in Tailings Cells 1,3
and 4A to ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the Mill's State of Utah Radioactive Materials License No. UT 1900479 (the
"License"). These measurements were made from an elevation survey. The results of such
monitoring, reported as feet above mean sea level (fmsl), are included in Attachment A.
Condition 10.3 of the License provides that freeboard limits for Cells 1 and 3 shall be set in
accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures:
1
a) The freeboard limits are set as per the January 10, 1990 Drainage Report for Cell 1 at a
liquid maximum elevation of 5,615.4 fmsl;
b) The freeboard limit for Cell 3 is determined annually using a formula set out in the
procedure. The current freeboard limit for Cell 3 was previously calculated under this
procedure at 5,601.6 fms!. However, in State of Utah Department of Environmental
Quality ("UDEQ") correspondence dated November 20, 2008 an interim variance and
limit was established at 5,602.5 fmsl for Cell 3; and
c) In conjunction with thc variance established under (b) above, an interim maximum
elevation for Ce1l4A was also established at 5,593.74
In addition, Part I.D.2 of the Permit provides that under no circumstances shall the freeboard of
any tailings cell be less than three feet, as measured from the top of the flexible membrane liner
("FML"). The top of the FML in Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 3 is at
5,608.5 fms!. This means that the maximum wastewater pool elevations in Cells 1 and 3
permitted under Part I.D.2 of the Permit are 5,615.5 and 5,605.5 fmsl, respectively.
As indicated in the table below, the waste water pool elevations in Cells 1 and 3, as measured
during the Quarter, did not exceed these regulatory standards:
Table I· Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Wastewater Wastewater
Elevation Elevation Elevation PeI'mitted
Measured During Permitted Under Under Part I.D.2 of
the License Condition the Permit (fmst)
Quarter (fmsl) 10.3 (fmsl)
CellI 5614.18 5615.4 5,615.5
Cell 3 5602.07 5,602.5 5,605.5
Cell4A 5582.67 ---------5593.74
Note: Interim maximum elevations of 5,602.5 fmsl and 5,593.74 fmsl for Cells 3 and 4A,
respectively, have been established in correspondence from UDEQ dated November 20, 2008.
The maximum elevation of 5,593.74 fmsl for Cell 4A has been set assuming that the total
probable maximum precipitation ("PMP") volume for Cells 2, 3 and 4A will be accommodated
in Cell 4A. By letter dated December 11, 2008 Denison applied for an amendment to the
License to set the freeboard limit for Cell4A at 5,593.74 fmsl and to eliminate the need to set a
freeboard limit for Cell 3, given that the freeboard limit of 5,593.74 fmsl for Cell 4A is adequate
to accommodate the total PMP volume for Cells 2, 3 and 4A.
2
4. MONTHLY SLIMES DRAIN WATER LEVEL MONITORING
Part LD.3(b)(1) of the Permit provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the White Mesa Mill Tailings Management
System and Discharge Minimization Technology (DMT) Monitoring Plan, 9/08 Revision:
Denison-6 (the "DMT Plan"). Part I.D.3(b)(3) of the Permit provides that for Cell 3, this
requirement shall apply after initiation of de-watering operations. Similarly, Part LD.6(c) of the
Permit provides that, after the Permittee initiates pumping conditions in the slimes drain layer in
Ce1l4A, the Permittee will provide: I) continuous declining fluid heads in the slimes drain layer,
in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a maximum head of 1.0
feet in the tailings (as measured from the lowest point of the upper FML) in 6.4 years or less.
Part LD.3(b)(2) of the Permit provides that the Permittee shall conduct a monthly slimes drain
recovery test at each tailings cell that meets the following minimum requirements: I) includes a
duration of at least 90-hours, as measured from the time that pumping ceases, and 2) achieves a
stable water level at the end of the test, as measured by three consecutive hourly water level
depth measurements, with no change in water level, as measured to the nearest 0.01 foot.
At this time initiation of de-watering operations have not commenced in Cell 3 nor has the Mill
initiated pumping conditions in the slimes drain layer of Cell 4A. As a result, the requirements
in Part LE.7(b) to monitor and record monthly the depth to wastewater in the slimes drain access
pipes as described in Part LD.3 of the Permit apply only to Cell 2 at this time. Accordingly, this
Report is limited to slimes drain recovery head information relating to Cell 2 only.
Pursuant to Parts I.E.7(b) and LF.2 of the Permit, Section 8.2 of the DMT Plan and
correspondence from UDEQ dated February 7, 2008, the results of monthly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Pecformance Standards Monitoring Report
and Cell 4A BAT Performance Standards Monitoring Report a (the"DMT Reports"). Further,
beginning in 2008, quarterly DMT Reports must include both the current year monthly values
and a graphic comparison to the previous year. An annual slimes drain recovery head report, that
addresses the requirements of Part LF.II of the Permit and Section 8.2 of the DMT Plan must be
included in the 4th quarter DMT Report, and is included in Section 9 below.
In accordance with these requirements, the monthly readings during the Quarter and for all of
2009 are included as Attachment B. A graph showing the readings for each month in 2009 and
2008 for which validated data is available (see Section 9.4 below) is included as Attachment C,
which shows a graphic comparison to the previous year.
5. WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
During the Quarter, Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part LD.3(e) of the
3
Permit. Part I.D.3(e) of the Permit provides that the water level in Robert's Pond shall not exceed
an elevation of 5624 fms!.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5623.14
fmsl, which did not exceed the maximum permitted elevation of 5,624 fms!. The results of such
monitoring are included in Attachment A.
6. WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the Permit and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part l.D.ll
of the Permit. The results of these inspections are recorded on the Weekly Mill Inspection
forms, which are available at the Mill for inspection. No variance in stored materials from these
requirements was observed during the inspections.
7. INSPECTIONS OF TAILINGS CELLS AND POND LINER SYSTEMS
The liner systems at Cells 1,2 and 3 were inspected on a daily basis pursuant to the requirements
of Sections 2.1 and 2.2 of the Mill's DMT Plan. The results of those inspections are recorded on
the Mill's Daily Inspection Data sheets, which are available at the Mill for inspection. A visual
inspection of Roberts Pond was performed on a weekly basis. The results of those inspections
are recorded on the Weekly Mill Inspection forms, which are available at the Mill for inspection.
In accordance with Part I.E.7(f) of the Permit, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part I.F. 2 of the Permit provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
During the Quarter, no liner repairs were performed at any of the Mill's tailings cells or at
Roberts Pond. Included as Attachment D is a report dated June 25, 2009, that relates to repairs
made to the Cell 1 liner in June, 2009, which was previously filed with the Executive Secretary
on June 26, 2009.
8. CELL 4A BAT PERFORMANCE STANDARDS REPORT IcOR THE QUARTER
This Section constitutes the routine Cell 4A BAT Performance Standards Monitoring Report for
the Quarter, as required under Part I.F.3 of the Permit.
4
8.1 LDS Monitoring
a) Operational Status ofLDS Pumping and Monitoring Equipment
Except as described below, the LDS pumping and monitoring equipment, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment
operated continuously during the Quarter:
(i) There was a power outage on November 5 and November 6, 2009 that impacted
the LDS monitoring system. It was not possible to perform daily monitoring of
the LDS on those da ys.
Except as noted above, during the Quarter, there was no failure of any pumping or monitoring
equipment not repaired and made fully operational within 24-hours of discovery, as
contemplated by Part I.E.8(a)(1) of the Permit.
b) Measurement of Weekly Fluid Head At the Lowest Point in the Secondary Membrane
The readings pertaining to the fluid head above the lowest point in the secondary FML are
provided in Attachment E. As can be seen from a review of Attachment E, at no point in the
Quarter did the flnid head in the Cell 4A LDS sump exceed a I-foot level above the lowest point
in the lower FML on the Cell floor (where for purposes of compliance monitoring this I-foot
distance shall equate to 2.28 feet above the LDS system transducer), as stipulated by Part
I.E.8(a)(2) of the Permit. During the Quarter, the fluid head in the Cell 4A LDS sump did not
exceed 10 inches above the LDS transducer.
c) Measurement of'the Volume of Fluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment E. As can
be seen from a review of Attachment E, during the Quarter, the average daily LDS flow volume
did not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the Permit (based on the
maximum head recorded on the FML during the Quarter of about 27.5 feet, the allowable
leakage rate would actually be approximately 20,800 gallons per day). For the Quarter, a total of
2,745 gallons were pumped, which equates to approximately 30 gallons per day.
8.2 Measurement of Weekly Wastewater Fluids in CeIl4A
Weekly fluid elevations for Cell 4A are provided in Attachment A along with elevations for
Cells 1 and 3 and Roberts Pond. During the Quarter, the Mill operated and maintained
wastewater levels in Cell 4A to provide the minimum vertical freeboard as required by Part
I.E.8(a)(4) of the Permit. See the discussion in Section 3 above.
5
8.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Cell 4A slimes drain system at this time,
monthly recovery head tests and fluid level measurements are not required to be made at this
time pursuant to Part I.E.S(b) of the Permit.
9. ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2009
This Section constitutes the annual slimes drain recovery head report for calendar year 2009 (the
"Period"), as required under Part I.F.ll of the Permit and Section S.2 of the DMT Plan.
9.1 Individual Slimes Drain Recovery Head Monitoring Data for 2009
The individnal monthly slimes drain recovery head monitoring data for the Period, which
includes the date and time for the start and end of the recovery test, the initial water level, and
the final depth to stable water level, is included as Attachment B to this Report. Since the
monthly slimes drain recover head data for 200S was not included in the 4th Quarter 200S DMT
Report, that data is included as Attachment F to this Report. The equivalent recovery water level
elevation is determined by subtracting the final depth to stable water measurement from the
sheets in Attachment B or F from 5614.S3 fmsl, being the surveyed elevation of the measuring
point. Those elevations are set out in Tables 3 and 4 below.
9.2 Average Slimes Drain Recovery Head for 2009
The simple average of the slimes drain recovery head for the Period was 5,603.23 fms!. By
comparison, the simple average slimes drain recovery head for the year immediately prior to the
Period was 5,603.63 fmsl, using data that meet the test performance standards found in Part
I.D.3(b)(2) of the Permit. See Section 9.4 below.
9.3 Time Series Chart
Included in Attachment C is a time series chart that shows trends in the monthly recovery water
level elevations in the Cell 2 slimes drain over time, using data that meet the test performance
standards found in Part I.D.3(b)(2) of the Permit. See Section 9.4 below.
9.4 Quality Assurance Evaluation and Data Validation
Denison management has evaluated all data collected, data collection methods, and all related
calculations required by the Permit, and have verified the accuracy and reliability of both the
data and calculations reported. Based on these evaluations, the following observations are made:
6
a) Improper Data Collection Prior to January 2009
As documented in correspondence between Denison and the Co-Executive Secretary of the
State of Utah Water Quality Board (the "Executive Secretary"), culminating in a Notice of
Non-Compliance dated April 7, 2009, Mill staff were operating under the mistaken
understanding that water level stabilization was fulfilled if either the 90 hour stabilization
period had been attained or if three successive readings revealed no change. They did not
realize that both stabilization requirements must be mel. As a result, all but two monthly
readings (January and November 2008) during the period from May 2007 through December
2008 did not meet the test performance standards found in Part I.D.3(b)(2) of the Permit.
The fact that Mill personnel were not performing the recovery head tests properly was
brought to the attention of Denison by the Executive Secretary by a letter dated December
17, 2008. After being advised of their mistake, Mill staff performed all subsequent recovery
tests in accordance with the requirements of Part 1.0.3, commencing in January 2009. As a
result of the foregoing, the Executive Secretary, concluded in the April 7, 2009 Notice of
Non Compliance that the non-compliant data from 2008 is not representative of the required
monitoring.
b) Lost Data For January and February 2009
As noted on the Monthly Head Measurement Test sheets for January and February, 2009,
included in Attachment B, the Mill Slimes Drain Recovery folder that housed all the monthly
recovery test data for January and February, 2009 was lost. However, the final report
numbers, i.e., the water levels represented by the three stable one-hour readings, were
recorded elsewhere and are not in doubt. The remainder of the hour-to-hour information was
pieced together by Mill staff from undated field notebooks that Mill staff is confident, but not
certain, represent the lost data. Denison management is satisfied that the recorded stabilized
water levels, as indicated on the Monthly Head Measurement Test sheets for January and
February 2009 are accurate, are in compliance with Part 1.0.3 of the Permit, and can be relied
upon. Denison management believes that the measurements for each of January and
February 2009 represent the third stable reading of the last three readings of each month,
taken one hour apart and at least 90 hours after cessation of pumping, because Denison and
Mill staff revised their test practices to accord with the requirements of Part 1.0.3 of the
Permit after being advised of the need to do so by the Executive Secretary in December
2008. These revised practices were instituted commencing in January 2009.
The monthly tailings fluid elevation measurements for each month in 2009 were reviewed and
found to meet the test performance standards found in Part I.D.3(b)(2) and to be suitable for use
in demonstrating compliance status in Section 9.5 below.
As a result of its quality assurance evaluation and data validation review, Denison has concluded
that:
• Of the data generated prior to January 2009, only the monthly slimes drain tailings fluid
elevation measurements for January 2008 and November 2008 meet the test performance
7
standards found in Part I.D.3(b)(2) of the Permit, and can be used for purposes of
determining compliance with the requirements of Part I.D.3(b)(2) of the Permit; and
• All of the 2009 monthly slimes drain tailings fluid elevation measurements meet the test
performance standards found in Part I.D.3(b)(2) of the Permit and can be used for
purposes of determining compliance with the requirements of Part I.D.3(b)(2) of the
Permit.
9.5 Demonstration of Compliance Status with the Requirements of Part I.D.3(b) and
I.E.7(b) of the Permit
9.5.1 Permit Requirements
Partl.D.3 of the Permit provides that annual slimes drain compliance shall be achieved when the
average annnal wastewater recovery elevation in the slimes drain access pipe, as determined
pursuant to the DMT Plan, meets the conditions in Equation 1, below:
Equation 1:
[2.:Ey + 2.:Ey-1 + 2.:Ey-2]I [Ny + Ny_I + Ny_2 ] < 12.:Ey-1 + 2.:Ey-2 + 2.:Ey-3]I [ Ny_I + Ny_2 + Ny_3]
Where:
Ny_I
Sum of all monthly slimes drain tailings fluid elevation measurements that meet
the test performance standards found in Part I.D.3(b)(2), during the calendar year
of interest. Hereafter, these water level measurements are referred to as slimes
drain recovery elevations (SDRE). Pursuant to the DMT Plan, these recovery
tests are to be conducted monthly and the SDRE values reported in units of feet
above mean sea level (mnsl).
Sum of all SDRE measurements made in the year previous to the calendar year of
interest.
Sum of all SDRE measurements made in the second year previous to the calendar
year of interest.
Sum of all SD RE measurements made in the third year previous to the calendar
year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted during the calendar year of interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted in the year previous to the calendar year of interest.
8
Ny-2 =
Ny-3 =
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted in the second year previous to the calendar year of
interest.
Total number of SDRE tests that meet the test performance standards found in
Part I.D.3(b)(2), conducted in the third year previous to the calendar year of
interest.
Part I.D.3 further provides that prior to January 1, 2013, the following values for E and N values
in Equation I shall be based on SDRE data from the following calendar years.
Table 2 -SDRE Data to be Used for Certain Years
Report Source of Data By Calendar Year for Equation I Variables (right
for side)
Calendar Ey_1 EY_2 Ey-3 Ny_I Ny_2 Ny-3
Year
2010 2009 2009 2009 2009 2009 2009
2011 2010 2009 2009 2010 2009 2009
2012 2011 2010 2009 2011 2010 2009
As Table 2 does not address this Report, which is for the Calendar year 2009, Denison has
shifted each year in Table 2 back by one year for purposes of applying Equation I to the Period.
Part I.D.3 provides that failure to satisfy conditions in Equation I shall constitute DMT failure
and non-compliance with the Permit, and that for Cell 3, this requirement shall apply after
initiation of de-watering operations.
9.5.2 Demonstration (if Compliance With Permit Requirements
2009 SDRE values that meet the test performance standards found in Part I.D.3(b)(2), reported in
units of feet above mean sea level (fmsl) are as follows:
9
Table 3 -SDRE Values for2009
2009 Test Closing Elevation of Reported Highest SDRE Values
Date Measurement Point Level Reported as fmsl
1130/2009 5614.83 11.25 5603.58
2/27/2009 5614.83 9.35 5605.48
3/28/2009 5614.83 8.84 5605.99
4/27/2009 5614.83 11.98 5602.85
5/20/2009 5614.83 10.28 5604.55
6/22/2009 5614.83 13 5601.83
7/30/2009 5614.83 13 5601.83
8/3112009 5614.83 11.04 5603.79
9/28/2009 5614.83 11.46 5603.37
10/30/2009 5614.83 13.35 5601.48
11/23/2009 5614.83 12.49 5602.34
12114/2009 5614.83 13.12 5601.71
IE2009 =67238.8
N2OO9 = 12
2008 SDRE values that meet the test performance standards found in Part I.D.3(b)(2), reported in
units of feet above mean sea level (fmsl) are as follows:
Table 4 -SDRE Values for 2008
2008 Test Closing Elevation of Reported Highest SDRE Values
Date Measurement Point Level Reported as fmsl
1125/2008 5614.83 10.9 5603.93
11124/2008 5614.83 11.5 5603.33
L:E2008 =11207.26
N2008 =2
Based on the foregoing, it is evident that L:E2009 = 67238.8 fmsl, and N2009 = 12, and that L:E2008
= 11207.26 fmsl, and N2008 = 2
Also, based on Table 2 above,
E2008 = EY·1 = EY·2 = Ey.3 and N2008 = NY·1 = Ny.2 = NY•3
Based on these values, equation 1 can be applied as follows:
10
[IEy + IEy-l + IEy-2] 1 INy + NY_l + Ny-2 ] = 167,238.8 + 11,207.26 +11,207.261/112 + 2 +2J = 5603.33
fmsl
and
[IEy-1 + IEy-2 + IEy-3 ] 1 1 Ny_I + Ny-2 + Ny-3 ] =[11,207.26 + 11,207.26 +11,207.26]/[2 + 2 + 2J =
5603.63 fmsl
Since 5,603.33 fmsl < 5,603.63 fmsl, annual slimes drain compliance has been achieved for
2009.
10. SIGNATURE AND CERTIFICATION
This document was prepared by Denison on February 26, 2010.
Denison Mines ,USA) Corp.
By: II. ,_! !!~I DaVid C. Fryd nlund
Vice President, Regulatory affairs and Counsel
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
includin the i)ossibility of fine and imprisonment or knowing violations.
David C. Frydenlund
Vice President, Regulatory affairs and Counsel
Denison Mines (USA) Corp.
11
Tab A
Tailings Pond Elevations
4th Quarter Elevations
Date Cell 1 Cell 3 Roberts Pond Cell4A
Free Board 5615.40 5602.50 5624.00 5593.74
10/2/2009 5614.18 5599.73 5617.12 5581.17
10/9/2009 5613.58 5599.67 5620.59 5581.67
10/13/2009 5613.53 5599.62 5620.48 5581.96
10/23/2009 5613.25 5601.78 5623.14 5581.62
10/30/2009 5613.21 5601.68 5620.75 5581.67
11/6/2009 5613.22 5601.7 5620.84 5581.88
11/12/2009 5613.11 5601.8 5620.85 5582.2
11/20/2009 5613.18 5601.79 5621.34 5581.97
11/25/2009 5613.15 5601.77 5621.46 5581.92
12/4/2009 5613.07 5601.89 5621.21 5581.9
12/10/2009 5613.31 5601.97 5621.35 5582.16
12/18/2009 5613.32 5601.95 5621.9 5582.15
12/25/2009 5613.43 5602.04 5621.98 5582.23
12/31/2009 5613.43 5602.07 Unable to shoot 5582.67
Tab B
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 12/14/2009
Slimes Cell # 2
Sampler: Tanner Holliday, Ryan Palmer
David Turk.
12/9/2009 12/10/2009 12/11/2009 12/12/2009 12/13/2009 12/14/2009
600
700 17.29 15.33
800 24.04 17.21 15.3 13.31
900 23.44 17.09 15.26 13.31
1000 22.81 16.97 15.22 13.3
1100 22.24 16.84 15.17 13.2
1200 21.87 16.7 15.09 13.12
1300 21.33 16.57 15.02 13.12
1400 20.92 16.5 14.95 13.12
1500 20.56 16.44 14.93
1600 13.99 13.52
13.12
Comments: The Report number is 13.12 for the month of December. The reading on the 12th
was done by Tanner at 1630, and the one on the 13th was done by Ryan at 1710. David Turk
completed the test for us on the 14th.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 11/23/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
11/16/2009 11/17/2009 11/18/2009 11/19/2009 11/20/2009
600
700 17.53 15.47 14.48 13.92
800 24.22 17.4 15.43 14.46 13.92
900 23.68 17.28 15.38 14.44 13.9
1000 23.03 17.16 15.33 14.42 13.88
1100 22.4 17.02 15.28 14.39 13.85
1200 21.96 16.88 15.2 14.33 13.79
1300 21.53 16.77 15.11 14.3 13.75
1400 21.14 16.63 15.06 14.27 13.72
1500 20.72 16.52 15.01 14.25 13.69
1600
Comments: The report number is 12.49. On the weekend days one reading was collected
each day. On the 21st the head was at 13.03 on the 22nd the head was 12.57 these readings
were both taken in the late afternoon.
11/23/2009
12.49
12.49
12.49
12.49
12.49
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 10/30/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan palmer
10/26/2009 10/27/2009 10/28/2009 10/29/2009 10/30/2009
600
700 13.83 13.35
800 16.74 14.5 13.8 13.35
900 16.61 14.48 13.77 13.35
1000 24.41 16.43 14.44 13.75 13.35
1100 24.1 16.18 14.41 13.74
1200 23.78 15.95 14.34 13.71
1300 23.15 15.77 14.27 13.69
1400 21.7 15.67 14.24 13.66
1500 21.22 15.53 14.2 13.64
1600
Comments: The report number is 13.35
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 9/28/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
9/21/2009 9/22/2009 9/23/2009 9/24/2009 9/25/2009 9/28/2009
600
700 20.5 15.48 13.31 12.69 11.46
800 20.12 15.37 14.07 13.26 12.67 11.46
900 19.64 15.35 14.04 13.23 12.65 11.46
1000 19.32 15.34 13.99 13.21 12.64 11.46
1100 19.05 15.34 13.95 13.2 12.62
1200 18.75 15.19 13.92 13.16 12.59
1300 18.49 15.03 13.85 13.11 12.57
1400 18.1 14.98 13.85 13.06 12.54
1500 17.98 14.92 13.75 13.04 12.52
1600
Comments: Two additional readings were taken over the weekend, one reading each
day. On the 26th at 1700 hrs the measurement was 12.08. On the 27th at 1600 hrs the
measurment was 11.55. The head finally stabalized on the 28th at 11.46, this number
will be used as the report number.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 8/31/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
8/24/2009 8/25/2009 8/26/2009 8/27/2009 8/28/2009 8/29/2009 8/30/2009 8/31/2009
600
700 14.3 13.1 12.51 12.11 11.28 11.04
800 14.22 13.09 12.49 12.1 11.04
900 25 14.2 13.05 12.46 12.09 11.04
1000 22.19 14.08 13.02 12.45 12.08
1100 21.04 14.03 12.99 12.43 12.06
1200 20.14 13.95 12.96 12.41 12.04
1300 19.27 13.86 12.94 12.38 12.02
1400 18.39 13.81 12.9 12.36 11.98
1500 17.73 13.72 12.85 12.33 11.95
1600 11.4
11.04
comments: 11.04 will be used as report number. It took longer than normal to stabilize
it also recovered to a higher level than it did in previous months. It may have had
something to do with the various problems we have been having with the pump.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 7/30/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
7/24/2009 7/25/2009 7/26/2009 7/27/2009 7/28/2009 7/29/2009 7/30/009
600
700 14.62 13.96 13.41 13.01
800 14.6 13.87 13.39 13
900 14.55 13.86 13.36 13
1000 14.49 13.82 13.34 13
1100 14.47 13.8 13.33 13
1200 14.42 13.77 13.3 13
1300 14.38 13.74 13.28
1400 17.18 14.34 13.69 13.21
1500 17.08 14.3 13.65 13.18
1600 15.75 14.9
Comments: We experienced some problems with the pump once again on the 24th
during our daily inspection. The Monthly head test was started because ofthe
problems. After the test was complete we tried to start the slimes with the rebuilt
pump, we continued to have problems with the pump. Maintenance was
contacted and they are working on getting the pump fully functional once again.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 6/22/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
6/15/2009 6/16/2009 6/17/2009 6/18/2009 6/19/2009 6/20/2009 6/22/2009
600
700 19.39 16.75 15.46 14.62 13.62 13.00
800 19.2 16.7 15.43 14.61 13.00
900 19.03 16.68 15.38 14.58 13.00
1000 18.84 16.62 15.35 14.55
1100 26.16 18.72 16.56 15.29 14.52
1200 25.52 18.55 16.49 15.26 14.47
1300 24.77 18.41 16.41 15.2 14.44
1400 24.05 18.25 16.34 15.15 14.4
1500 23.59 18.05 16.24 15.1 14.35
1600
13.00
Comments During down time the gasket was replaced on the flange just outside
the slimes pipe. The report number will be 13.00
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 5/20/2009
Slimes Cell # 2
Sampler: Tanner Holliday
5/15/2009 5/16/2009 5/17/2009 5/18/2009 5/19/2009
600
700 11.28 11.11 11 10.74 10.52
800 11.28 11.11 11 10.74 10.51
900 11.28 11.11 10.99 10.74 10.5
1000 11.27 11.11 10.97 10.74 10.49
1100 11.27 11.11 10.97 10.72 10.48
1200 11.24 11.11 10.95 10.7 10.45
1300 11.23 11.11 10.95 10.68 10.42
1400 11.22 11.08 10.94 10.66 10.41
1500 11.19 11.06 10.91 10.63 10.38
1600
Comments: Test was started mid week so repairs could be made to the slimes pump.
Environmental staff worked thorugh weekend on other projects, so they recorded the
slimes information as well.
5/20/2009
10.28
10.28
10.28
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 4/27/2009
Slimes Cell # 2
Sampler: Ryan Palmer
4/20/2009 4/21/2009 4/22/2009 4/23/2009 4/24/2009 4/27/2009
600
700 16.79 15.44 14.43 13.66 13.05 11.98
800 16.73 15.4 14.41 13.64 13.04 11.98
900 16.65 15.37 14.39 13.63 13.01 11.98
1000 16.6 1531 14.35 13.6 12.99
1100 16.58 15.27 14.32 13.57 12.98
1200 16.51 15.24 14.28 13.53 12.95
1300 16.4 15.18 14.22 13.49 12.92
1400 16.32 15.1 14.17 13.44 12.89
1500 16.27 15.04 14.14 13.41 12.85
1600
Comments: Start number was low because over the weekend of april 18th and 19th
power was cut to the tailings area for some high voltage repair work. This power outage
stopped the pump from working on the slimes drain. When they turned the power back
on the breaker was tripped leaving pump off until the Monthly head test was started
Monday the 20th of april. After completetion of test the pump was turned back on. The
report number is going to be 11.98.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 3/28/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
3/24/2009 3/25/2009 3/26/2009 3/27/2009 3/28/2009
600
700 12.98 9.97 9.16 8.99 8.84
800 12.92 9.93 9.18 8.99 8.84
900 12.67 9.91 9.16 8.99 8.84
1000 12.37 9.89 9.06 8.99 8.84
1100 12.15 9.83 9.04 8.98
1200 11.94 9.75 9.03 8.97
1300 11.76 9.69 9.02 8.97
1400 11.59 9.64 9.02 8.96
1500 11.36 9.61 9.02 8.95
1600
Comments: We have been having some problems with the slimes drain pump. We've
placed a new pump in the drain and it didn't seem to work at full capacity, pulled that
pump. Conducted monthly recovery test at this time, after test we then placed another
pump in the drain, it seems to be working a lot better. We will keep an eye on the new
pump to insure it funcitons properly.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 2/27/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
2/23/2009 2/24/2009 2/25/2009 2/26/2009 2/27/2009 2/28/2009
600
700 13.78 11.21 10.22 9.52
800 13.6 11.16 10.18 9.5
900 13.42 10.99 10.14 9.48
1000 13.18 10.93 10.11 9.45
1100 12.96 10.88 10.08 9.43
1200 12.78 10.84 10.05 9.42
1300 12.69 10.79 10.03 9.39
1400 12.58 10.76 10.03 9.38
1500 12.46 10.72 10.02 9.38
1600
Comments: 9.35 will be the report number. Pump has been giving problems. Found
that the discharge end was clogged with a build up of solids. Repaired problem and
began recovery test on Tuesday 24th. Readings were taken on Saterday to ensure
compliance. Sometime between March 19th and March 30th the slimes drain recovery
folder which housed all the monthly recovery test was lost. We are missing the data
points for January 2009 and February 2009.
The hourly data represented here is questionable. The first two months of 2009 slimes
test were lost during a ALARA audit. The report number is recorded in another location
so those nubmers are completely accurate. The hour to hour information was taken off
some field notebooks that were used around the time of the test. The page didn't have
dates but pages that were dated prior and after would make it seem to fit.
9.35
9.35
9.35
9.35
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 1/30/2009
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
1/26/2009 1/27/2009 1/28/2009 1/29/2009 1/30/2009
600
700 22.02 14.03 13.59 12.03 11.29
800 21.23 15.92 13.45 12.01 11.28
900 21.14 15.79 13.32 11.99 11.27
1000 20.78 15.7 13.24 11.97 11.26
1100 20.1 15.57 13.11 11.94 11.26
1200 19.99 15.42 13.06 11.92 11.25
1300 19.34 15.28 12.99 11.89 11.25
1400 18.97 15.14 12.94 11.88 11.25
1500 18.22 15.01 12.91 11.86
1600
11.25
Comments: 11.25 is going to be the report number.
The hourly data represented here is questionable. The first two months of 2009 slimes
test were lost during a ALARA audit. The report number is recorded in another location
so those nubmers are completely accurate. The hour to hour information was taken off
some field notebooks that were used around the time of the test. The page didn't have
dates but pages that were dated prior and after would make it seem to fit.
Tab C
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Tab D
David Frydenlund
From:
Sent:
To:
Cc:
Subject:
Attachments:
Dear Mr. Finerfrock,
Steve Landau
Friday, June 26,20094:11 PM
[e-mail]
Dave Rupp; Harold Roberts; David Frydenlund
Cell 1 Liner Repair
Scan001 4173.PDF
Please find attached the Liner Repair Report documenting the repairs that were made and the testing that was
conducted in relation to Cell 1 liner damage that was ({Noticed" to the Division on 5-19-09. The document has been
prepared in ((text searchable" format as per the regulations.
If you should have any questions regarding this Report, please contact either Harold Roberts or me. A hard copy of this
report will be transmitted via regular mail as well.
Yours Truly,
Steven D. Landau
Steve Landau
Manager, Environmental Affairs
t: [phone] I f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265
DENISON MINES (USA) CORP
www.denisonmines.com
This e-mail is intended for exclusive usetheperson(s) mentionedastherecipient(s). This message and any attached files with it are confidential and may contain privileged
or proprietary information. II you are not the intended recipient(s) please delete this message and notily the sender. You may not use, distribute print or copy this message il
you are not the intended recipient(s).
1
Memorandum
To: Steve Landau
From: Harold R. Roberts, P.E.
Date: June 25, 2009
Re: Cell 1 liner Repairs
cc:
DenIson MinH CUSA, Corp.
1050 17th SlNet, Sutt. '50
Denver, CO 80285
USA
Tel: [phone]
Fax: [phone]
denIsonml.,...COIII
On June 10 and 11, 2009 I visited the White mesa Mill site for the purpose of observing the repair activity on the
PVC lining material in the Cell 1 Evaporation Pond. The area of damage was along the east side of the Cell,
toward the northeast corner, and above the solution level of the Cell. The liner damage was caused by a
sudden, unexpected flow of water during routine maintenance on one of the tailings pipelines. The flow of
solution washed the soil cover off the liner and damaged the liner such that the underlying soil was eroded,
resulting in further damage to the liner.
An area of liner approximately 15 feet by 50 feet was totally replaced after the foundation materials were
rep!aced and compacted into place. The liner was replaced with 30 mil PVC roll stock supplied by Colorado
lining, Inc. In order to reduce the amount of field seam the liner was replaced entirely in to the anchor trench
along the area of damage.
Prior to placement of the new lining material, the soil surface was compacted and swept clean of any protruding
rocks that might damage the lining material. Prior to seaming, the fining material was cleaned with methyl ethyl
ketone (MEK) as recommended by Colorado Lining, Inc. The liner was then seamed using an adhesive
supplied by Colorado Lining, Inc. The repaired seams were then 100% vacuum box tested according to the
procedures in the attached report. Testing results are included in the attached daily reports of the repair
activities. The final repair activities involved the replacement of the soil cover in order to protect the lining
material from exposure to UV degradation.
During my 2 day site visit I personally witnessed foundation preparation activities, liner placement, cleaning and
seaming of the liner, and vacuum box testing of the repaired seams. I also reviewed the records and
documentation of the work beginning on June 5, 2009. Photo documentation is included for each day's
activities. Weather conditions and repair activities for each day are documented in the daily reports. All of the
work was being performed in good workman like manner, and the repairs I observed were completed in
accordance with industry standard practices. The vacuum box testing was being conducted in accordance with
the manufactures recommendations and in general agreement the ASTM D 5641 . The regulated pressure to
the vacuum box was maintained at 15 psig during the test process and vacuum pressure within the box was
recorded in inches of mercury, thus documenting the integrity of the seam. Photos taken on the days of my
inspection are attached to this memorandum.
The attached report documents the repairs in accordance with the White Mesa Mill's Discharge Minimization
Plan, revision 06, dated September 2008, and more specifically the procedure "Liner Maintenance Provisions -
Cells 1,2,3 and Roberts Pond·, d~. 6,200 . .
.~
..,t"Iaro/d R. Roberts, Utah Registered Professional Engineer No. 165838
Maintenance
Evaporation Cell #1
). The Successful Completion of Cell #1 was taken place
on 12th of June 2009.
). Proper Training and detailed explanation of the repairs
conducted were evaluated and documented.
). Date, Time and Weather conditions were recorded.
Maintenance Department
Evaporation Cell # 1
IN THIS SECTION:
» Repairs
)-Repair Report
)-Inspections
)-Training
Maintenance
EvaporatIon Cell #1
IN THIS SECTION:
)-Job Site
)0 Earth Work
). Liner
). Wrap-up
Inspectiom
'.
Revision: ()..()rlginal
Approved: October 6, 2008
Liner Maintenance Provisions--Cetls I, 2, 3 and Roberts Pond
Tailinss cells 1. 2. and J are the subject of comprehensive daily inspections which are
conducted by either the Environmental Tedmiclan or the Radiation TeChnician, as weJl
as once per shift Daily Operations Inspections which art conducted by the Mill Shift
Foreman or other trained personnel designated by the Shift Foreman. The details of these
daUy inspections are outlined in Sections 2.1 and 2.2 of the White Mesa Mill Tailings
Management System and Discharge MiDimiDtion Technology (DM!) Monitoring Plan.
In each case, these inspections are reconfed on inspection forms (Doll)' Inspection DlIIa
Form and Operating Foreman's Daily Inspection Form. respectively). In addition, non-
recorded Daily Operations Patrols are conducted twice per shift by operations personnel.
With regard to Roberts Pond, this faciJity is observed on a weekly basis when the
BnvironmentaJ or Radiation Technician visits the facility for the recording of water levels
at that location.
TrainiDa
AU individuals performing inspections described in Sections 2.1 and 2.2 of the DMT
Monitoring Plan must have Tailings Management System Trainill8 as described in
Appendix C to the DMT Monitoring Plan (Tailings Inspection Training). As and element
of the "Operational Systemsn inspection. inspectors are trained and required to observe
the CODditions oftbe PVC liner. Because the PVC liners in Ta1Uaas Cells It 2 and 3 are
sensitive to sunlight and can degrade as a result of prolonged exposwe. inspectors are
cautioned to observe: any situation where the liner is exposed. These exposure situations
are considered serious and require immediate attention. Inspectors are crained to cover
small areas of exposure immediately. whereas, larger areas are reported to the radiation
Safety Oflicer to prompt the issuance of a WOJt order to the Maintenance ~ In
kecpiDa with this inspection requimnenl. inspectors are traiDed to observe any
degradation of exposed liners. Such degradation cm:a be that caused by eJCpOSUle to
suoligbl, abrasion due to erosive wave action and/or any rips or tears in the liDer material.
Given the fact that the liner material is provided with an earthen cover, erosive damaae
andIor rips and tears are unlikely. Inspectors are trained to record alJ observations of
liner exposure or disRpair on the inspection repon. as well as the date and DI&Ure of any
repair activity.
Roberts Pond is lined with Hi Density Polyethylene (HOPE) material which is not
sensitive to sun damage and, as such, is DOt covered with earthen material. In this case
the inspector observes the CODditions of the liner to the extent that visual obserwIion is
possaOJe (i.e. above the water leveJ and any visually observable near surface coadition).
As is the case for the tailing cell inspectioos, the liner ~iU be observed for any abruion
due to erosive wave action and/or any rips or tears in the liner material.
1
Revision: ()..()rlginal
Approved: October 6, 2008
(', Repairs
("
Repairs to PVC liners in Cells 1,2 and 2 and to the HOPE liner in Roberts Pond are made
on a case by we basis and usuaUy involves the installation of a repair patch over the damaled location. PVC patches require the use of glues or adhesive solvents to fuse the
patch to the repair location. HOPE repairs are accomplished by use of an exUusion
welder. Subsequcr.nt to any repair of a linert 1be .."air location will be tested usiBa a
"vacuum box" end soapy water to assure 1hIt the npair is acccp&ab1a. The observation of
bubbles tbrouah the repair seam while vacuum is being applied to the seam CODStitutes
scam failure and the repair must be redone untiJ all seams are acc:eptable. In the case of
Cells 1,2. end J, 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 maintcnaJlce depIrtmeDt. lhe continued availability of these
supplies will be verified as an element of the Quarterly TaiJinp Inspocdoa CXJIIdlICted by
the Radiation Safety Officer or his desipee.
Any leak. hole or other damage to the Jirutrs in Cells 1, 2. 3 and the Roberts PODd win 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 wiD include a
notification and description of the failtft in accordance with Part LO.l.(a) of tile OWDP
and be in accordance with RJI1--6-6.16.C(I) of the regulations. In addition to the
descriptive informaIion about the failure, a pJan and schedule for the FML repair will be
included with the notification to the Executive Secretary (in accordanto with Part
I.OJ.(c) of the Permit),
Re,pairRumt
Each report will be signed by a Utah licensed professional engineer and will addms the
following elements as they apply to the case·by-case repairs which are impIcmentod:
• Repair narrative describina the nature of the damage and the repair work
completed to NpIir the damage.
• Repair material type used to complete the repair
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other) .
• Daily reports during the repair WOJk
• Repair test results
• Quality ~Qua1ity Control Information
2
--
OPERAnON OFTSP VACUUM LEAK. TESTING
BOX
t. W~iU SafCl) (';b~~'s
2. Install ~n(enclosed) ball valve
3. Remove paper masking from top of Vacuum Box.
4. Connect 40 to 60 lbs of air to quick coupler~ (%" Hose is ideal for this procedure).
S. Be sure surface to be tested is reasonably smooth and clean.
6. Apply diluted .. Leat Test Concentlatefl solution to weld to be tested.
7. Place box over area to be tested. press down aDd tum on air at baH valve. 10 seconds of
Vacuum is enough time to ~ bubbles in aml tested. 00 not exceed 1 S inches (Ibs) of
Hg. Tum off'vacuum and move to next area to be tested.
8. Do not stand near~ exhaust
9. Store Vacuum box on clean flal surface (shipping container) so psket wiD not be damaged to. Clean sJass with solution of dishwashing detergent and rinse with clear clean water. Dry
11. with soft cloth to plevent scratching
12. To obtain replacement gaskets call 1-800-734-9266 or email: bnekjr@ts~
J J. Ills lhe responsibility olllle user 10 mabli8h appropriate $IIfo1}' Il1Id health practl«.t and
determine lhe application of replotory limitations prior to use
'\...;.;/
~ -~~ "".-: .. ~
" ,/ /
Cell #1 Repairs
lune sth of 2009.
7am-2pm.
Personnel: Devin, Kendall, Johnson, Kenneth and Casey.
Please read: Small Brief and training on all Personnel working on the tailings pooel
Weather: 66 degrees F. 7:35am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(Cleaner), Wire brush and paint brushes.
8:00 a.m. -10:00 a.m. lob site.
Repair work need's done do to extreme tares on the
liner. 35'x18' section is exposed and replacement of old
liner will be repaired. We have 1500 sq.ft. of liner and
10 gal. of PVC to PVC adhesive. I did a small training
on Devin Mitchell and Kendall Benally on how to repair
liner. We also have a vacuum box that will check joints
for potential leaks. Re routed Pond Return line and
Shortened old tails line In order to perform work.
10am.-noon. Earth Work.
Removed a section of the old liner. Graded and
removed any potential obstructfon that would damage
liner. Compacted and smoothed area being lined.
noon -1pm. Uner.
deaned old liner With MEK (Methyl Ethyl Ketone),
Ruffed up 8"-12" of the existing liner in order create a
bond wIth the new liner. Using new PVC liner and PVC
to PVC adhesive. We were able to glue the upper
section of the liner. We will conduct a Vacuum box test
after section of liner Is cured.
Ryan Palmer came out and visited and took pictures of
the area beIng worked on. Spoke to him what we got
done and said we will continue Monday.
1:00 p.m. -2:00 p.m. Wrap-up
Additional Information:
The weather did not permit us to work on the liner do
to high winds. Covered the area and will begin on the
project on Monday 8th of June. 2009.
We were able to glue the first upper section of the liner. Due to high winds we were not able to set the first
section of liner. We will continue to make repaIrs Monday 8th of June. 2009.
{ . , ,
L:
Blartding, Utah (84511) Conditions & Forecast: Weather Undewound
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Maintenance
E~poratlon Cell #1
IN THIS SECTION:
» Job Site
» Earth Work
» Unar
> Wrap-up
Cell #1 Repairs
June 8th of 2009.
7am-3:30pm.
Personnel: Devin, Kendall and Johnson.
Please read: Small Brief and training on all Personnel working on the tailings pond.
Weather: 60 degrees F. 7:35am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(CIeaner), Wire brush and paint brushes.
7:00 a.m. -10:00 a.m. Job site.
Repair work was conducted today. The Maintenance
department was able to get 2 sections of PVC liner
glued down.
10am.-noon. Earth Work.
Removed a section of the old liner. Graded and
removed any potential obstruction that would damage
liner. Added 2nd liner and glued the north, east and
west side of liners.
noon -lpm. Uner.
Cleaned old liner with MEK (Methyl Ethyl Ketone),
Ruffed up 8"-12" of the existing liner in order create a
bond with the new liner. Using new PVC liner and PVC
to PVC adhesive. We were able to glue the upper
section of the liner. We will conduct a Vacuum box test
after section of liner Is cured.
David Turk went to the site.
1:00 p.m. -2:00 p.m. Wrap-up
Additional Infonnation:
There were some winds from the south at about Smph.
PIctures were taken on the finished 2nd PVC liner
section. We made 14 tests not to exceed 1Spslon the
Pressure regulator. All tests passed using a small
amount of soap water. Test: 1) 2Hg. 2) SHg. 3) 4Hg. 4)
2Hg. 5) 2Hg. 6) 2Hg. 7) 2 Hg. 8) 4Hg. 9) 4Hg. 10) SHg.
11) 4Hg. 12) 2Hg. 13) 4Hg. 14) 4Hg.
We were able glue all 4 sides of the first liner section. We also glued the west and east of the 2nd section of
liners.
I \
\
.' ) C.-
\
( )
Maintenance
Evaporation Cell #1
IN THIS SECTION:
)0 Job Site
) Earth Work
)-Uner
)0 Wrap-up
Cell #1 Repairs
lune 9U1 of 2009.
7am-3:30pm.
Personnel: Devin, Kendall, Casey and Johnson.
Please read: N/A
Weather: 54 degrees F. 7:35am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(Oeaner), Wire brush and paint brushes.
7:00 a.m. -10:00 a.m. lob site.
Repair work was conducted today. The Maintenance
department was able to get 3 sections of PVC liner
glued down.
10am.-noon. Earth Work.
Removed a section of the old liner. Graded and
removed any potential obstruction that would damage
liner. Added 3rd, 4th and 5th liners.
noon -Ipm. Liner.
Cleaned old liner with MEK (Methyl Ethyl Ketone),
Ruffed up 8"-12" of the existing liner in order create a
bond with the new liner. Using new PVC liner and PVC
to PVC adhesive. We were able to glue the upper
section of the liner. We will conduct a Vacuum box test
after section of liner is cured.
David Turk went to the site.
1:00 p.m. -3:30 p.m. Wrap-up
Additional Infonnation:
It started to rain at about 1 :30pm had stop progress for
a while and then continued. Pictures were taken by
Wade Hancock on the finished PVC riner sections. We
made 2 tests not to exceed 15psi. All tests passed using
a small amount of soap water. Test: 1) 4Hg. 2) 5 Hg.
We were able to glue aI/ the sides of the 3rd and 4th liner and the 5th on all three sides.
(,.)
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Blanding. Utah (84511) Conditions & Forecast: Weather Underground
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Page 1 ofl
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Maintenance
Evaporation Cell #1
IN THIS SECTION:
» Job Site
). Earth Work
» Liner
). Wrap-up
Cell #1 Repairs
June 10tfl of 2009.
7am-3:30pm.
Personnel: Devin, Kendall, casey and Johnson.
Please read: Nt A
Weather: 47 degrees F. 7am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(Cleaner), Sand bags, Wire brush and paint brushes.
8:30 a.m. -10:00 a.m. Job site.
We had some light showers last night and this
morning. We will continue to make repairs on the liner.
10am.-noon. Earth Work.
The maintenance deparbnent will dig back towards the
East and replace the liner going Into the trench. We
come to point where the break or crack of the liner has
stopped on the south side.
noon -2pm. Liner.
Did not lay any liner down. The maintenance
deparbnent mainly concentrated on removing dirt and
grading the surface for preparation of the liner. Mr.
Bartlett, Mr. Roberts and Mr. Turk were at the site.
2:00 p.m. -3:30 p.m. Wrap-up
Additional Information:
No tests were conducted. Found the end of the break of
the liner. We will continue to uncover the existing liner
and prep the area to lay new PVC liner.
We started at 8:30am. It was a little cool and we,had some moisture that morning.
Blanding. Ulall (84'11) Conditions &. Fom:ut : Wc:adler UndergroWld
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Maintenance
Evaporation Cell #1
IN ntiS SECTION:
» Job Site
» EarthWork
» Uner
> Wrap-up
Cell #1 Repairs
June 11th of 2009.
7am-3:30pm.
Personnel: Devin, Kendall, Casey and Johnson.
Please read: N/A
Weather: SS degrees F. 7am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(Cleaner), Sand bags, Wire brush and paint brushes.
7:30 a.m. -10:00 a.m. Job site.
Continued with repairs. Uttle sunny and cool.
10am.-noon. Earth Work.
Graded and cleaned up the last area. Dug the rest of
the trench.
noon -2pm. Liner.
Set the rest of the liners. aeaned and glued them
down.
2:00 p.m. -3:30 p.m. Wrap-up
Additional Information:
It stayed sunny throughout the day. Finished adding all
the liners and oonducted 55 tests. #3 Uner Bottom: 1)
3Hg. 2) 3Hg. 3)3Hg. Top: 4) 3Hg. 5) 3Hg. 6) 3Hg. Top
to Bottom: 7) 3Hg. 8) 3 Hg. 9) 3 Hg. 10) 3Hg. 11) 3Hg.
12) 3 Hg. 13) 3 Hg. 14} 3 Hg. #4 Uner Top: 15)3 Hg.
16)3 Hg. 17)3 Hg. Top to Bottom: 18) 4 Hg. 19) 4 Hg.
20} 4 Hg. 21}4 Hg. 22) 3 Hg. 23) 4 Hg. 24) 4 Hg.
Bottom: 25) 3 Hg. 26) 3 Hg. 27) 2 Hg. #S liner Top:
28)3 Hg. 29}4 Hg. 30)4 Hg. Top to Bottom: 31) 4 Hg.
32) 3 Hg. 33) 3 Hg. 34)3 Hg 35) 2 Hg. 36) 3 Hg. 37) 3
Hg. 38) 3 Hg. Bottom: 39} 3 Hg. 40) 3 Hg. 41)3 Hg.
#6 Uner Top: 42)4 Hg. 43)3 Hg. 44) 3 Hg. Top: 45) 3
Hg. 46) 3 Hg. 47)3 Hg. 48) 3 Hg. 49) 3 Hg.50) 3 Hg.
51) 3 Hg. 52) 2 Hg. 53) 3 Hg. 54) 3 Hg. 55) 3 Hg.
We started at 7:30am. It was a little cool and Sunny. Finished Installing all the PVC liner. Conducted 55 tests. Will
finish tomorrow and with the earth work and testing.
Blanding, Utah (84511) Conditions &. Forec:&U : Weather Underground
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Maintenance
Evaporation Cell 111
IN THIS SECTION:
). Job Site
)0 Earth Work
). Liner
)0 Wrap-up
Cell #1 Repairs
lune 12U1 of 2009.
7am-3:30pm.
Personnel: Devin, Kendall, casey and Johnson.
Please read: Documents attached.
Weather: 47 degrees F. 7:28am.
Cell # 1
Material: PVC liner, PVC to PVC adhesive, MEK(Oeaner), Sand bags, Wire brush and paint brushes.
7;25 a.m. -8:45 a.m. Job site.
8:45am.-l0am.
lOam. -l1am.
118m. -3:30 p.m.
Additional Information:
The Maintenance department will test the rest of the
seams and cover liner with dirt.
Earth Work.
David Turk, Ryan Palmer and Tanner Holiday inspected
and took pictures. David asked me to cover the liner
with dirt 6"-12".
Liner.
Tests were conducted made the last tests and they all
passed. Mr. Bartlett Inspected and took pictures and
said go ahead and cover it.
Wrap-up
Oean up and back filled 6"-12" of dirt. Conducted 50
tests. #7 Liner Top: 1)3Hg. 2)3Hg. 3)3Hg. Top to
Bottom: 4) 3Hg. 5) 3Hg. 6) 3Hg. Top to Bottom: 7)3
Hg. 8) 3Hg. 9) 3Hg. 10) 2Hg. Bottom: U} 3Hg. 12} 3
Hg. #8 Liner: 13) 4Hg. 14} 5Hg. 15)4Hg. 16)SHg.
17)5Hg. 18) 4Hg. 19) SHg. Bottom: 20) 5Hg. 21)5Hg.
22) 4Hg. #9 Liner: 23) 4Hg. 24) 5Hg. 25) 4Hg. 26) 4
Hg. 27} 4Hg. 28)4Hg. 29)4Hg. 30)4Hg. 31) 3Hg. 32) 3
Hg. 33) 3Hg. 34)3Hg. 35) 3Hg. 36) 3Hg. 37) 2Hg. 38) 3
Hg. 39) 3Hg. 40) 2Hg. 41) 3Hg. 42) 3Hg. #10 Liner:
43) 3Hg. 44) 3Hg. 45} 3Hg. 46} 3Hg. 47) 3Hg. 48) 3
Hg. 49) 3 Hg.sO) 3 Hg.
We started at 7:20am. It was a little cool and Sunny. Finished Installing all the PVC liner. Conducted 50 tests.
Everything is completed installing liners and Vacuum tests. We added 6-12 Inches of dirt.
All documentation of training is provided on this file. Vacuum test procedures are logged In and photographs
were taken to keep track of evidence and progress of the job. Completion status 100%.
-(
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BJauding. Utah (84511) Conditions &; FOIeCIIIl : WOIIIhcr Undergrouod
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Tab E
CELL 4A LEAK DETECTION SYSTEM DATA, 4TH QUARTER 2009
(Measurements in inches represent inches above the leak detection system transducer)
October 2009
Date
1012/09
1019/09
10113/09
10123110
10/30109
Measurements in Inches
9.4
9.8
9.5
10.0
2.3
Flow Meter in Gallons
251210
251210
251210
251210
253955
Highest level for the month was 10 inches. Total number of gallons pumped was 2,745.
November 2009
Date
1116/09
11/12/09
11120/09
11125/09
Measurements in Inches
NI A-power outage on tails
3.6
3.4
3.8
Flow Meter in Gallons
253955
253955
253955
253955
Highest level for the month was 3.8 inches. Total number of gallons pumped was O.
December 2009
Date Measurements in Inches Flow Meter in Gallons
12/4/09 4.1 253955
12/10/09 4.1 253955
12/18/09 4.5 253955
12/25/09 4.2 253955
12/31109 4.7 253955
Highest level for the month was 4.7 inches. Total number of gallons pumped was O.
For the 4th Quarter 2009, the highest level was 10 inches above the Ce1l4A leak detection system
transducer, and a total of 2,745 gallons were pumped.
Tab F
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 12/19/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
12/15/2008 12/16/2008 12/17/2008 12/18/2008
600
700 14.27 12.66 11.77
800 14.15 12.63 11.75
900 20.84 14.05 12.6 11.75
1000 19.99 13.96 12.57 11.75
1100 19.25 13.89 12.53 11.75
1200 18.76 13.8 12.51
1300 18.19 13.69 12.49
1400 17.74 13.61 12.47
1500 17.44 13.55 12.36
1600
11.75
Comments: 11.75 was used as the report number.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 11/24/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
11/19/2008 11/20/2008 11/21/2008 11/22/2008 11/23/2008
600
700 21.49 14.62 12.96 Did not take readings
800 20.97 14.51 12.91 over the weekend.
900 20.26 14.37 12.87
1000 19.52 14.33 12.82
1100 19.04 14.21 12.79
1200 18.26 14.09 12.74
1300 17.99 13.98 12.68
1400 17.58 13.91 12.63
1500 17.3 13.87 12.58
1600
Comments: Test was started midweek in order to fit in before the long holliday weekend.
Final readings were taken Monday morning, report number is 11.50
11/24/2008
11.5
11.5
11.5
11.5
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 10/31/2008
Slimes Cell # 2
Sampler: Tanner Holliday
10/27/2008 10/28/2008 10/29/2008 10/30/2008 10/31/2008
600
700 22.55 15.52 13.71 12.94 12.47
800 21.79 15.41 13.69 12.93 12.45
900 21.14 15.32 13.66 12.92 12.44
1000 20.59 15.23 13.64 12.9 12.44
1100 19.88 15.1 13.59 12.87 12.41
1200 19.36 15 13.55 12.84 12.39
1300 19.06 14.9 13.51 12.81 12.35
1400 18.65 14.78 13.43 12.79 12.31
1500 18.27 14.65 13.37 12.76 12.29
1600
12.29
Comments: 12.29 is the final number for reporting purposes. --------~~~~~~~~~~~~--------
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 9/29/80-10/3/08
Slimes Cell # 2
Sampler: Tanner Holliday
9/29/2008 9/30/2008 10/1/2008 10/2/2008 10/3/2008
600
700 24.34 16.26 14.35 13.36 12.57
800 23.15 16.15 14.31 13.34 12.56
900 22.43 16.03 14.28 13.32 12.55
1000 21.97 15.92 14.24 13.28 12.51
1100 21.21 15.79 14.19 13.25 12.48
1200 20.53 15.68 14.15 13.22 12.44
1300 20.09 15.54 14.11 13.17 12.4
1400 19.71 15.42 14.05 13.11 12.38
1500 19.35 15.3 13.99 13.05 12.36
1600
12.36
Comments: Due to conflicts in schedules some of the test had to be pushed into
October. The report number is 12.36.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 8/22/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
8/18/2008 8/19/2008 8/20/2008 8/21/2008 8/22/2008
600
700 24.95 16.43 14.54 13.49 12.81
800 23.79 16.3 14.49 13.46 12.79
900 23.26 16.15 14.45 13.44 12.77
1000 22.39 16.01 14.4 13.38 12.75
1100 21.77 15.94 14.36 13.32 12.73
1200 21.25 15.83 14.31 13.26 12.7
1300 20.84 15.75 14.25 13.24 12.67
1400 20.41 15.66 14.19 13.22 12.64
1500 19.83 15.57 14.11 13.2 12.61
1600
12.61
Comments: 12.61 was the report number.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 7/25/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
7/21/2008 7/22/2008 7/23/2008 7/24/2008 7/25/2008
600
700 26.03 16.84 14.95 13.76 12.99
800 24.05 16.69 14.9 13.71 12.97
900 23.41 16.55 14.76 13.66 12.95
1000 22.86 16.41 14.71 13.61 12.92
1100 22.1 16.3 14.63 13.57 12.87
1200 21.32 16.18 14.59 13.51 12.85
1300 21.02 16.06 14.51 13.47 12.83
1400 20.59 15.95 14.41 13.45 12.81
1500 20.17 15.83 14.3 13.4 12.79
1600
12.79
Comments: 12.79 was the report number.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 6/27/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ryan Palmer
6/23/2008 6/24/2008 6/25/2008 6/26/2008 6/27/2008 6/30/2008
600
700 25.25 16.98 15.16 14.1 13.31 11.91
800 24.75 16.89 15.12 14.05 13.3
900 23.5 16.8 15.08 14.02 13.29
1000 22.98 16.71 15.02 14 13.23
1100 22.33 16.57 14.98 13.97 13.19
1200 21.87 16.47 14.92 13.93 13.07
1300 21.32 16.32 14.87 13.82 12.98
1400 20.9 16.1 14.84 13.76 12.91
1500 20.63 16.09 14.63 13.71 12.89
1600
11.91
Comments:
One additional reading was taken on 6/30/08 at 0700. This number was used for report.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 5/23/2008
Slimes Cell # 2
Sampler: Tanner Holliday
Ronnie Nieves
5/19/2008 5/20/2008 5/21/2008 5/22/2008 5/23/2008
600
700 25.7 17.21 14.8 12.55 11.91
800 24.7 16.84 14.71 12.52 11.9
900 23.5 16.69 14.6 12.47 11.88
1000 22.5 16.54 14.52 12.42 11.84
1100 22.4 16.45 14.41 12.39 11.82
1200 21.4 16.4 14.34 12.34 11.79
1300 20.8 16.28 14.29 12.28 11.75
1400 20.46 16.19 14.24 12.2 11.73
1500 20.33 16.07 14.2 12.14 11.69
1600
11.69
Comments: 11.69 will be used as report number. Head never completely stabalized.
MONTHLY HEAD MEASUREMENT TEST
location: Date: 4/28/2008
Slimes Cell # 2
Sampler: Ryan Palmer
4/28/2008 4/29/2008 4/30/2008 5/1/2008 5/2/2008
600
700 24.75 15.31 13.3 12.49 11.99
800 23.68 15.18 13.26 12.45 11.97
900 22.54 15.04 13.15 12.44 11.94
1000 21.93 14.97 13.09 12.41 11.92
1100 21.03 14.89 13.01 12.39 11.89
1200 20.46 14.72 12.95 12.36 11.87
1300 19.67 14.59 12.91 12.32 11.85
1400 19.37 14.5 12.87 12.3 11.83
1500 18.96 14.38 12.83 12.27 11.82
1600
11.82
Comments: 10.52 Final report number. Head never completely stabilized.
Took another reading on 5/5/08 of 10.52 then turned pump back on.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 3/21/2008
Slimes Cell # 2
Sampler: Ryan Palmer
3/17/2008 3/18/2008 3/19/2008 3/20/2008 3/21/2008
600
700 14.41 12.54 11.67 11.23
800 14.24 12.52 11.65 11.21
900 22.48 14.1 12.49 11.64 11.19
1000 21.52 13.92 12.47 11.62 11.18
1100 19.72 13.78 12.42 11.58 11.15
1200 19.2 13.61 12.37 11.55 11.12
1300 18.5 13.55 12.31 11.52 11.09
1400 17.93 13.46 12.26 11.49 11.05
1500 17.41 13.4 12.19 11.44 11.03
1600 17.03 12.15
11.03
Comments: 11.03 will be used as the report number.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 2/28/2009
Slimes Cell # 2
Sampler: Ryan Palmer
2/25/2008 2/26/2008 2/27/2008 2/28/2008
600
700 23.08 13.85 12.28 11.27
800 21.81 13.69 12.23 11.27
900 20.7 13.61 12.19 11.27
1000 19.62 13.44 12.14
1100 19.01 13.32 12.1
1200 18.78 13.16 12.04
1300 18.42 13.14 11.97
1400 18.34 13.13 11.92
1500 18.02 13.13 11.85
1600
11.27
Comments: -------------------------------------
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 1/25/2009
Slimes Cell # 2
Sampler: Ryan Palmer
1/21/2008 1/22/2008 1/23/2008 1/24/2008 1/25/2008
600
700 21.17 13.41 12.06 11.24 10.9
800 19.9 13.33 12.06 11.19 10.9
900 19.11 13.24 12.01 11.16 10.9
1000 18.36 13.19 11.97 11.1
1100 17.8 13.11 11.91 11.07
1200 17.21 13.01 11.85 11.01
1300 16.77 12.92 11.79 10.98
1400 16.38 12.86 11.73 10.96
1500 16.02 12.81 11.69 10.93
1600
10.9
Comments: -------------------------------------------