DRC-2011-007620 - 0901a0688028f7ef

^^artment of
Environmental Quality /-// ^
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
3 P 9 1 1 -
Aw™ La U il
CERTIFIED MAIL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
ovember 3, 2(
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Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivety Fee
(Endorsement Reauired^
Total Posta
$
Postmark
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Tischler
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivety Fee
(Endorsement Reauired^
Total Posta
Postmark
Here
Tischler
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivety Fee
(Endorsement Reauired^
Total Posta
Postmark
Here
Tischler
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivety Fee
(Endorsement Reauired^
Total Posta Ms. Jo Ann
Postmark
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Tischler
Sent To
styeei'ApiN 1050 Seventeenth Street, Suite 950
or POBox Nc Den ver, CO 80265
City, State, Zl
PS Form 3800, August 2006 See Reverse for Instr^uctions
Dear Ms. Tischler:
SUBJECT: November 1, 2011 DUSA Response Letter and Transmittal of Movement (Displacement)
Monitoring Standard Operating Procedures [SOPs], J1/2011 Revision: DUSA-2.7;
October 17, 2011 DRC Request for Information Letter; December 1, 2010 DUSA
Transmittal Letter of Draft Movement Monitoring SOPs; Approval of Movement
(Displacement) Monitoring SOP
We have receivetd the subject November I, 201J DUSA letter which transmits the subject Movement
Monitoring Standard Operating Procedures (SOPs). The subject SOPs were submitted by DUSA in
response to our comment letter of October 17, 2011, and to comply with the requirements of License
Condition 11.8.
We have reviewed this submittal, and have no further comments. Therefore, we hereby approve the
subject Movement (Displacement) Monitoring SOPs.
If you have any questions on the above, please contact Mr. Rupp of DRC.
UTAH RADIATION CONTROL BOARD
Craig wSJones, ActmJ Executive Secretary
DAR:dr
F:\License\Move & Settle Monilors\Movement Monitors\MM SOP Apprvl 11-201 l.doc
195 North 1950 West • Sait Lake City. VT
Mailing Address: P.O. Box 144850'Salt Lake Cily. UT 841 14-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
wuw.deq.Utah.ijov
Printed on 100% recycled piiper
Dave Rupp - DRC Movement Monitoring SOP Comment Letter
From:
To:
Date:
Subject:
CC:
Attachments:
Dave Rupp
[e-mail]
10/31/2011 10:02 AM
DRC Movement Monitoring SOP Comment Letter
[e-mail]
RFI Letter.pdf
Attached is a pdf copy of the subject letter you requested. The file stamp shows it was mailed October 18,
2011. Thanks for following up on this. --
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake City, UT 84114-4850
Telephone [phone]
Fax [phone]
Email: [e-mail]
SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
• Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
• print your name and address on the reverse
so that we can return the card to you.
•. Attach this card to the back of the mailpiece,
'pr on the front if space permits.
A. Received by (Please Print Clearly) B. Datepf DeUvery
/o/x///j
• Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
• print your name and address on the reverse
so that we can return the card to you.
•. Attach this card to the back of the mailpiece,
'pr on the front if space permits.
C. Sign^re /
1. Article Addressed to: D. Is delivery address different from item 1? Cl Yes
' ^.S. enter deliverv address below: D No
RE. movement SOP's request for info/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
Service Type
• Certified Mail
• Registered
• Insured Mail
• Express Mail
• Return Receipt for Merchandise
• C.O.D.
4. Restricted Delivery? [Extra Fee) • Yes
2. Article Number (Copy from service label)' 7011 DUO 0001 7TS1 ISOb
PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789
file://C:\Documents and Settmgs\drupp\Local Settings\Temp\XPgrpwise\4EAE723FEQD. 10/31/2011
State of Utah
GARY R. HERBERT
Govenior
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Directfjr
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
October 17, 2 a
a
a
•
a
RE: movement SOP's request for info/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PS 'Fprm 386G;'August 2006 See Reverse for Instructions
Dear Ms. Tischler:
SUBJECT: June 23, 2011 DUSA Response Letter and Transmittal of Movement
(Displacement) Monitor Standard Operating Procedures [SOPs], 06/2011
Revision: DUSA-2, and a draft DMT Plan version 06/11 Revision: Denison 11.2;
June 13, 2011 DRC Request for Information Letter; December 1, 2010 DUSA
Transmittal Letter of Draft Movement Monitoring SOPs; Request for
Information
We have received the subject June 23, 2011 DUSA letter which transmits the subject Movement
Monitor Standard Operating Procedures (SOPs) and a draft DMT Plan. The draft DMT Plan will
be addressed under separate cover. The subject SOPs were submitted by DUSA in response to
our comment letter of June 13, 2011, and to comply with the requirements of License Condition
11.8.
We have reviewed the subject Movement Monitor SOPs, and have the following comments:
As requested in comments no. 1 and 8 in our previous letter of June 13, 2011, the subject
SOPs need to be corrected for speUing and typographical errors. Such errors have
somehow perpetuated in the subject SOPs, and need to be corrected in the final copy.
I also suggest the title, and paragraph line 1, be changed to "Movement (Displacement).
Monitoring", rather than "Movement (Displacement) Monitor."
Please review the above comments, and respond in writing, incorporating the above comments as
appropriate, and submit a revised Movement Monitoring Standard Operating Procedures
document with a unique version number. Per your email dated October 14, 2011 you committed
195 North 1950 West • Salt Lake City. LIT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Primed on 100% recycled paper
Page 2
that DUSA would fully respond to this letter within 14 calendar days of receipt. If you have any
questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
F:\License\Move & Settle Monitors\Movement MonitorCmt3 10-201 l.doc
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DENISO
MINES
November 1, 2011
Denison Miircs (USA) ^p.'
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax:[phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of October 17, 2011 Regarding Movement
Monitoring SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill Movement
Monitoring SOP. This letter also responds to DRC's letter of October 17, 2011, which we received on
October 21, 2011 providing DRC's comments on the subject SOP. We have provided in Attachment 1 an
edited redline copy of the SOP in which Denison's modifications in response to DRC comments are indicated
in color, and a clean copy for ease of review.
We have provided, below, specific responses to each request in DRC's October 17, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC October 17, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. We have reviewed the subject Movement Monitor SOPs, and have the following comments:
As requested in comments no. 1 and 8 in our previous letter of June 13, 2011, the
subject SOPs need to be corrected for spelling and typographical errors. Such errors
have somehow perpetuated in the subject SOPs, and need to be corrected in the final
copy.
Denison Response: The Movement Monitoring SOP has been edited and typographical and spelling errors
have been corrected.
/ also suggest the title, and paragraph line 1, be changed to "Movement (Displacement)
Monitoring", rather than "Movement (Displacement) Monitor."
Denison Response: The requested change has been made.
N:\SOPs and ProceduresMVIovement monitor SOP and commentsM 1.G1.11 response to 10.17.11 RFI on Movement
Monitoring S0P\11.01.11 Response to DEQ 10.17.11 RFI Movement Monitor SOP.doc
Letter to Mr. Rusty Lundbe^^
Movement Monitor SOP RFI Response
November 1, 2011
Page 2
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Attachments
DENISO
MINES
Letter to Mr. Rusty Lundbe^l^
Movement Monitor SOP RFI Response
November 3, 2011
Page 3
ATTACHMENT 1
Revised Movement Monitor SOP
DENISO
MINES
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
1.
1.1
MOVEMENT (DISPLACEMENT) MONITORING
Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of movement (displacement) monitors that are placed along the constructed
dike portions of the tailings cells. All data collected for these purposes, as described below, will
be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive
Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to
License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of new dike construction activities, Movement Monitors will be
installed and surveyed by a Utah-Licensed Land Surveyor. Movement monitors, at a minimum,
without regard to each dike longitudinal direction, will be installed in single straight lines for
each pertinent dike. The line for the movement monitors will change direction at each pertinent
dike intersection, but will run continuous along and on top of, all exterior exposed dikes
comprising the southem boundary of the tailing cells.
All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah-
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.
On an annual basis, a Utah-Licensed Professional Engineer will review, analyze, correct, and
certify the semi-annual and annual data in writing, which will be submitted as part of the ATER
as required by RML License Condition 12.3.
1.3 Design of Settlement Monitors
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The movement monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument including, but not limited to, vehicle and
constmction traffic damage. A piece of rebar, 24 inches in length, will be driven into the hole.
The new monument will be set in line with the other movement monitors for the given dike. The
White Mesa Mill - Standard Operating Procedures Date: 11/2011 Revision: DUSA-2.1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4
hole will be back-filled and the top of the rebar will be at least 4-inches below surface grade.
Each monument will be individually tagged and numbered.
1.4 Monitoring and Maintenance of Movement Devices
1.4.1 Monitoring and Documentation of Condition of Devices
The movement monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The movement monitors will be installed in such a way to prevent damage by equipment. All
new movement monitors installed after June 2010 will be installed near the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The movement monitors will be installed such
that the monument is at least 4-inches below the actual ground surface level, so the potential for
damage by equipment is further minimized. However, if a monument is disturbed, the
information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and replacement and/or repairs to the
damaged movement monitor and the surveying and documentation of changes will be completed
within 30 calendar days of the discovery of the damage. The general condition of the movement
monitors will be evaluated on a monthly basis and the inspection documented as a part of
Monthly Tailings Inspection.
If any movement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
30 calendar-days of the discovery of the damage. The replacement device will be placed in the
same excavated hole from which the damaged device was removed. Data from the new device
will be correlated to data from the removed damaged device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and the new device will be installed at the vertical and horizontal
coordinates of the device prior to the damage.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the adjacent devices, the procedures in Section 1.6
will be implemented.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
Page 3 of 4
1.5 Documentation
The Utah-Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater will be
evaluated according to the procedure described in section 1.6
The list of records generated as a result of this SOP includes:
• Utah-Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• ATER
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.
1.6 Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical or horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:
1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
4. Report this information to the Executive Secretary within 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with the Environmental
Department records and will be submitted as part of the ATER as required by RML
Condition 12.3.
Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a
manner approved by the Executive Secretary.
On an annual basis, a Utah-Licensed Professional Engineer will review, analyze, correct, certify
and submit the semi-annual and annual data in writing, including an explanation of the methods
and basis used for the review, analysis, and corrections including ongoing graphical updates for
the movement monitors. Movement data will be presented in a tabular format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
Page 4 of 4
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah-Registered Professional Engineer. This information
will be maintained with the Environmental Department records and will be submitted as part of
the ATER as required by RML License Condition 12.3, along with a description of any
corrective actions performed.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUS A-2 J.
Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
1.
1.1
MOVEMENT (DISPLACEMENT) MONITORING
Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Mmovement (©displacement) Mmonitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of new dike constmction activities. Movement Monitors will be
installed and surveyed by a Utah—Licensed Land Surveyor. mMovement monitors, at a
minimum, without regard to each dike longitudinal direction, will be installed in single straight
lines for each pertinent dike. The line for the movement monitors will change direction at each
pertinent dike intersection, but will mn continuous along and on top of, all exterior exposed
dikes comprising the southem boundary of the tailing cells.
All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah^
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.
On an annual basis, a Utah-^Licensed Professional Engineer will review, analyze, correct, and
certify the semi-annual and annual data in writing, which will be submitted as part of the ATER
as required by RML License Condition 12.3.
1.3 Design of Settlement Monitors
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The movement monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument including, but not limited to, vehicle and
constmction traffic damage. A piece of rebar, 24 inches in length, will be driven into the hole.
The new monument will be set in line with the other movement monitors for the given dike. The
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 06n./2011 Revision: DUS A-2 J.
Page 2 of4
hole will be back-filled and the top of the rebar will be at least 4-inches below surface grade.
Each monument will be individually tagged and numbered.
1.4
1.4.1
Monitoring and Maintenance of Movement Devices
Monitoring and Documentation of Condition of Devices
The movement monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed irt Section
1.2, and documented in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The Mmovement Mmonitors will be installed in such a way to prevent damage by equipment.
All new movement monitors installed after June 2010 will be installed near the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The movement monitors will be installed such
that the monument is at least 4-irtches below the actual ground surface level, so the potential for
damage by equipment is further minimized. However, if a monument is disturbed, the
information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and replacement and/or repairs to the
damaged movement monitor and the surveying and documentation of changes will be completed
within 30 calendar days of the discovery of the damage. The general condition of the movement
monitors will be evaluated on a monthly basis and the inspection documented as a part of
Monthly Tailings Inspection.
If any Mmovement Mmonitoring device is irreparably damaged as a result of environmental
stresses or man-caused contact, it will be promptly replaced with an identical or equivalent
device within 30 calendar-days of the discovery of the damage. The replacement device will be
placed in the same excavated hole from which the damaged device was removed. Data from the
new device will be correlated to data from the removed damaged device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and -the new device will be installed at the vertical and horizontal
coordinates of the device prior to the damage.
3. If the survey indicated O.I foot or greater of vertical or horizontal change, from the
previous measurement, to either of the adjacent devices, the procedures in sSection 1.6
will be implemented.
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUSA-2J.
Page 3 of 4
1.5 Documentation
The Utah—Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater will be
evaluated according to the procedure described in section 1.6
The list of records generated as a result of this SOP includes:
• Utah--Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• Annual Technical Evaluation ReportATER
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.
1.6 Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical or horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:
1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
4. Report this information to the Executive Secretary within 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with the Environmental
Department records and will be submitted as part of the ATER as required by RML
Condition 12.3.
Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods -may be subject to accelerated monitoring at a frequency and in a
manner approved by the Executive Secretary.
On an annual basis, a Utah--Licensed Professional Engineer will review, analyze, correct, certify
and submit the semi-annual and annual data in writing, including an explanation of the methods
and basis used for the review, analysis, and corrections including ongoing graphical updates for
the Mmovement Mmonitors. Movement data will be presented in a tabular format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
White Mesa Mill - Standard Operating Procedures Date: 0611/2011 Revision: DUS A-2 J.
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah—Registered Professional Engineer. This information
will be maintained with the Environmental Department records and will be submitted as part of
the ATER as required by RML License Condition 12.3, along with a description of any
corrective actions performed.
Receive
I N 1 Q \ tM
M 2011
Division of Control
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax : [phone]
www.denisonmines.com
June 23, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of April 20, 2011 Regarding Movement
Monitoring SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill Movement
Monitoring SOP. This letter also responds to DRC's letter of June 13, 2011, which we received on June 15,
2011 providing DRC's proposed redlines and comments on the subject SOP. We have provided in
Attachment 1 an edited redline copy ofthe SOP in which Denison's modifications or additional language in
response to DRC comments are indicated in a second color, and a clean black-line copy for ease of review.
In addition, Denison has prepared a draft of changes to the Tailings Management System and Discharge
Minimization Technoiogy ("DMT") Plan, to address:
• Changes in tailings inspection forms to correspond to this Movement Monitor SOP;
• Changes to address the startup of new cells, during which solution level cannot be surveyed or tape
measured until the solution level is high enough to be safely reached;
• Changes to reflect the removal of the freeboard limits from Cells 3 and 4A; and
• Other language changes to more correctly reflect current conditions and procedures at the tailings
system and Mill.
A redline copy and clean blackline copy of the proposed DMT changes are provided in Attachment 2.
We have provided, below, specific responses to each request in DRC's June 13, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC June 13, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General. Some new additional suggested red-line strike-out changes for the subject SOPs are
attached. Please note some sections contain more than one change of wording. Unfortunately, these
N:\SOPs and Procedures\Movement monitor SOP and comments\06.23.11 response to 06.13.11 RFI on Movement monitor
SOP\06.23.11 submittal to Rlundberg Movemt Monitors\06.23.11 Response to DEQ 06.13.11 RFI Movement Monitor
SOP.doc
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 2
changes appear in the same color as our previous suggested red-line strike out changes. However, the
most significant changes are described in more detail below:
a. Section 1.2: In the last paragraph we add the wording, "semi-annual and..."
b. Section 1.4.2: In the second sentence we add the words "near" and "but," and deleted the word
"on."
c. Section 1.5:
(1) . In the first sentence we add the phase, "of the movement monitors."
(2) . In the last sentence of the first paragraph we add "of 0.1 foot or," and delete "than 0.1
foot" This is explained further below in paragraph 1e.
(3) . In the second paragraph we add the new phasing shown to capture the semi-annual
survey and mapping reports.
d. Section 1.6:
(1) . In the first paragraph we add, "or greater." This is explained further below in paragraph
le.
(2) . In the last paragraph, the first sentence, we add, "and submit, " and "semi-annual and
annual."
(3) . In the second sentence of the last paragraph we add, "and" and delete "or."
(4) . In the fourth sentence ofthe last paragraph we add, "also."
e. To be consistent with paragraphs 1.4.2.2 and 1.4.2.3, regarding distances of "0.1 foot or
greater," as the actionable distance for the SOPs, some of the sentences described above
have been adjusted with suggested wording, such that any distance readings of 0.1 foot would
not be vague as to the SOP requirements.
Denison Response: The changes have been accepted as proposed.
2. No further comment.
Denison Response: No response required.
3. No further comment.
Denison Response: No response required.
4. A monthly inspection of the movement monitors is described at the end of the first paragraph of section
1.4.2 in the subject SOPs. It appears this necessitates some corresponding additions to the monthly
tailings inspection form, for inspection of the movement monitors. Please provide the proposed
changes in the form (DMT Plan) for approval.
Denison Response: Proposed revisions to the DMT Plan, including changes to the monthly tailings
inspection form, are attached.
5. No further comment.
Denison Response: No response required.
DENISON
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 3
6. No further comment
Denison Response: No response required.
7. No further comment
Denison Response: No response required.
The document has been reviewed for spelling and typographical errors.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Attachments
DENISON
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 4
ATTACHMENT 1
Revised Movement Monitor SOP
DENISOl
MINES
White Mesa Mill - Standard Operating Procedures Date: 0^644/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
rPARMarkup 06 20111
1. MOVEMENT (DISPLACEMENT) MONITOR
1.1 Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Movement (Displacement) Monitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of new dike construction activities, Movement Monitors will be
installed and surveyed by a Utah Licensed Land Surveyor. The installation of thcao
mmMovement monitors^ at a minimum, without regard to each dike longitudinal direction, will
be installed in a-single straight lines for each pertinent dike. The line for the movement monitors
will chanRe direction at each pertinent dike intersection, but will run contitiuous along and on top
of. all exterior exposed dikes comprising the southem boundary the exposed dike-of the tailing
cells.
All new movement monitors (installed afler June, 2010) will be surveyed and mapped by a Utah
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed afler June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.
On an
annual basis, a Utah Licensed Professional Engineer will review, analyze, correct and certify the
semi-annual and annual data in writing, which will be submitted as part of the ATER as required
by RML License Condition 12.3.
1.3 Design of Settlement Monitors
F:\WP\Division of Radiation ControrjJenison Mines. DUS AVATCR Antiual Tech Eval RcportsVMovcment & Setttetwem
Monitors'iMovemcnt MonitorsVMarlaip of Prop Movement Monit SOPs ^ 20iQ.docF:\WP'DiviGion of Radiation Control\Dcnison
Minos, DUSAUTER Annual Tech Eval RoportG\MoveiTiont & Settlement Monitors'Movcmont MonitorsVProp Movement Monit
SOP:; Mov2010.doc
White Mesa Mill - Standard Operating Procedures Date: 0^6U/201 IQ Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5,1 Page 2 of 4
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The mMovement mMonitor placement will be established by digging a hole in the desired
location, -to minimize accidental damage to the monument including, but not limited to. vehicle
and construction traffic damage.T A piece of rebar, 24 inches in length, will be driven into the
hole. The new monument will be set in -line with the other movement monitors for the given
dike. The hole will be back—filled and the top of the rebar will be at least 4X-inches below
surface grade. Each monument will be individually tagged and numbered.
1.4 Monitoring and Maintenance of Movement Devices
1.4.1 Monitoring and Documentation of Condition of Devices
The mMovement mMonitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The Movement Monitors will be installed in such a way to prevent damage by equipment. AH . •
new movement monitors installed after June 2010 will be installed jiearefflJhe edge ot^the di^ke ^ , - -{ Formatted: Font color: Auto.
crest, but off the horizontal road surface. Movement monitors in this location will be out ofthe
pathway for maintenance activities and traffic. The mMovement mMonitors will be installed
such that the monument is at least 4X-inches below the actual ground surface level, so the
potential for damage by equipment is further minimized. However, if a monument is disturbed,
the information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and a corrective action plan will be
created for replacement and/or repairs to the damaged movement monitor and the surveying and
documentation of any-changes will be completed within 30XX calendar days of the discovery of
the damage. The general condition ofthe movement monitors will be evaluated on a monthlv
basis and the inspection documented as a part of Monthlv Tailings Inspection.
Ifany Movement Monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
30XX calendar-days of the discovery of the damage. The replacement device will be placed in
the same excavated hole from which the damaged device was removed. Data from the new
device will be correlated to data from the removed damaged device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
F:\WP'Division of Radiation Control\Denison Mines. DUSA\ATER Annual Tech Eval ReportsVNtovement & Settlement
Monitors\Movenient Monitor5''Jvfarkup of Prop Movement Monit SOPs '\ 2010.docF:\WP\Division of Radiation Control\Denison
Mines, DUSA\ATER Annual Tech Ev^al Reports\Movement & Settiement MonitorS'Movement Monitors\Prop Movement Monit
SQPsNov2Q10.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0^644/201.10 Revision: DUSA-24-
Page 3 of 4
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamagedadjacent devices, it will be assumed that no damage had
occurred to the adiacent devices and no adjuatment will be made to the survey data of the
new device will bc installed at the vertical and horizontal coordinates of the device prior
to the damage.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the undamagedadjacent devices, the procedures in
section 1.6 will be implemented, survey results for the new device will be adjusted by
the average change obser\'ed in the two adjacent devices.—This adjustment will be
documented in the Utah-Licensed Land Surveyors report and in the annual ATER.
1.5 Documentation
The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater than 0.1 foot
vvill be evaluated according to the procedure described in section 1.6
The list of records generated as a result ofthis SOP includes:
o Utah Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
o Annual Technical Evaluation Report
o Observations, if there are any to be noted, on the monthlv Tailings Inspection Report
All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.
1.6 Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical or
horizontal vertical movement on the movement monitors. If there is a diligence of 0.1 foot -or
greater between two consecutive measuremenffltsenths^, then the corrective actions will be taken
as follows:
-1-i^Resurvey the movement monitor that shows vertical or horizontal vertical movement of*
O.l foot or more, within 3QXX days of discovery of the problem.r
22. Document site conditions.
3^3^Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
44^Report this information to the Executive Secretary within a timely manner45XX calendar
days for approval and include in that notification the investigation steps, movement
evaluation and corrective actions -stepstaken. This report will be also be maintained
- - Formatted: Numbered + Level: 1 +
Numbering Style: 1,2,3,... + Start at: 1 +
Alignment: Left + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Bullets and Numbering
F \WP\Divi!;ion of Radintion ContFol\DeniGon Minei,. DUSA'ATER Annual Tech Eval Reports^Movomcnt & Sentemewt
Monitors'uMovement MonitoffivMarkup of Prop Movement Monit SQPo A 20U).docF:\WT'\Divi;-.ion of Radiation ContrQl\Deniso»
Mines. DUSA\ArER Annual Tech Evnl Reports Movement &- Settlement MomtorsVMovement Monitora'Prop Movement Monit
SOPsNov2010.doc
White Mesa Mill - Standard Operating Procedures Date: 0^644/20119 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4
withift the Environmental Department records and will be submitted as part ofthe ATER
as required by RML Condition 12.3.
Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods or horizontal movement of O.X foot or greater for two
consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a
manner approved by the Execufive Secretary.
On an annual basis, a Utah Licensed Professional Engineer will review, analyze. Correct, and
certify and submit the semi-annual and annual data in writing, including an explanation of the
methods and basis used for the review, analysis, and corrections including ongoing graphical
updates for the Movement Monitors. Movement data will be presented in a tabular format,
showing all previous annual OF-and semi-annual data, for ease in evaluating the total record of
movement measurements. Data from all previous measurements will be compared against the
current measurement and an evaluation made as to any long—term trends which may be apparent-
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah Registered Professional Engineer. which Thjs
information will be maintained within the Environmental Department records and will be
submitted as part of the ATER as required by RML License Condifion 12.3, along with a
description of any corrective actions performed.
F:\WP'^Divi5ion of Radiation Control\DeniGon Mines. DUSANATER Annual Toch Eval RoponsXMovemont & Sotttemevit
Monitors\Movcmunt MonitorsVMaikui) of Prop Movement Monit SOPs 1 2010 docF:\WP\DiviGion of Radiation Controi .Denison
Minos, DUSA'-ATER Annual Tech Eval Roports\Movement & Settlement MonitorG\Movemcnt MonitorsMVop Movement Monit
SOPs Nov 2010.doc
June 23,2011 ' Response
Page 5
Revised D/schamII^^^"^^'^T 2
-Charge M,n,m/za«on Technology p,an
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 5
ATTACHMENT 2
Revised Discharge Minimization Technology Plan
DENISO
MINES
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denison 11.2+
Book 11: Environmental Protection Manual, Section 3.1 Page I of 57
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. UTI900479 (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 ofthe
integrity ofthe 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 few-five tailings cells will be
inspected. Observations will be made ofthe 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. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4 below, 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,
which includes a tailings cells map, and spaces to record observafions, especially those of immediate
N:\SOPs and Procedures\Movement monitor SOP and comments\06.23.11 response tn 06.13.11 Rfl on Movement monitor SOP\Tailin^s Mgnt
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc doo
White Mesa Mill - Standard Operating Procedures 0+06/11 Revision: Denisonl 1.2+
Book 11: Environmental Protection Manual, Section 3.1 Page 2 of 57
concern and those requiring correcfive acfion. The inspector will place a check by all inspecfion
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, 4A and 4B, Dikes 1, 2, 3, 4A-S, 4A-WE,
and 4B-S. and 4B-W wind movement of tailings, effectiveness of dust minimization methods, spray
evaporation, Cell 2 spillway. Cell 3 spillway. Cell 3, Cell 4A spillway. Cell 4A and 48 liquid pools
and associated liquid retum equipment, and cell leak detection systems, and the wildlife ponds.
Operational features ofthe tailings area are checked for condifions of potential concem. The
following items require visual inspecfion during the daily tailings inspecfion:
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 1, Cell 3,
Cell 4A or Cell 48; the pond retum line from the tailings area to the Mill; and,
lines transporting pond solutions from one cell to another.
b) Cell 1.
c) Cell 2.
d) Cell 3.
e) Cell 4A.
f) Cell 48.
g) Dike stmctures including dikes 1,2,3,1A-S, 4A-EW, and 4B-S and 18 W.
h) The Cell 2 spillway, Cell 3 spillway. Cell 4A spillway. Cell 3, Cell 4A and Cell
48 liquid pools and associated liquid retum equipment.
i) Presence of wildlife and/or domesficated animals in the tailings area, including
waterfowl and burrowing animal habitations.
N:\SOPs and Procedures^JVlovement monitor SOP and comments\06.23.11 response to 06.13.11 RFI on Movement monitor SOP\Tailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:\Cell 'IBUonuorv 2011 Suhmittnlr. nnd Rovinionr. for Cell 4B\DMT Plan 01.101 l\Tailing3
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1—Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.2+
Book 11: Environmental Protection Manual, Section 3.1 Page 3 of 57
j) Spray evaporafion pumps and lines.
k) 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.
1) Observation of flow and operational status of the dust control/spray evaporation
system (s).
m) Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
4A, and 48.
n) 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.
o) An esfimate of flow for acfive tailings slurry and SX line(s).
p) An estimate of flow in the solution retum line(s).
q) 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 detecfion systems is a gain of more than 12 inches in 24 hours. The
solufion level in Cell 4A or 48 leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner (Cell
4A FML elevafion is 5555.14 amsl and with the addition of the 1.0 foot of
solufion the solution elevation is 5556.14 feet amsl. For Cell 48 the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solufion the
solufion elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to nofify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
N:\SOPs and ProceduresVMovement monitor SOP and comments\06.23. I I response to 06.13 11 RFI on Movement monitor SOP\Tailinps Mgnt
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 4 of 57
be adhered to when the solution level trigger for Cell 4A or 48 has been
exceeded.
Whenever the leak detecfion system pump is operating and the fiow 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
Condifion 11.3.8 through 11.3.E ofthe Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
ofthe License Conditions.
F) An esfimate of the percentage of the tailings beach surface area and solution pool
area is made, including esfimates of solutions, cover areas, and tailings sands for
Cello 3, IA and IB.
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 operafion, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiafion 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. Observafions 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 inspecfions 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 nofify the Radiation Safety Officer
("RSQ") 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 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix 8. 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, indicafing that training
N:\SOPs and ProceduresVMovement monitor SOP and comments\06 23.11 response to 06.13.11 RFI on Movement monitor SOP\Tailings Mgnt
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 5 of 57
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will nofify 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
Radiafion 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 nofify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then nofify 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 Radiafion Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly (as well as
daily) 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 syotcm which will
indicatedual-probe system that senses the presence of solutions in the LDS
system (comparable to the systems in Cells 4A and 48) and indicates the
presence of solufion with a waming light. The Cell 4A and 48 leak detection
systems are 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 and the information is stored for later retrieval. The
water levels are measured to the nearest 0.10 inch. The data collector is currenfiy
programmed to store 7 days of water level information. The number of days of
stored data can be increased beyond 7 days if needed. For Cells 1 and 3. the
water level data is recorded on the Daily Tailings Inspection Form. For Cells 4A
and 48, tThe water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring databasestorage,
N:\SOPs and ProceduresVMovement monitor SOP and comments\06.23.11 response to 06.13.11 RFI on Movement monitor SOP\Tailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VCcll 4BUanuarv 2011 Submittals and RcNisions for Coll 1BVDMT Plan 01 10.1 IVTgilings
Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Rodline.doc
White Mesa Mill - Standard Operating Procedures ^06/11 Revision: Denison 11.24
Book 11: Environmental Protection Manual, Section 3.1 Page 6 of 57
and into the files for weekly inspection reports ofthe tailings cell leak detection
systems
NASOPs and ProceduresVMovement monitor -SOP and comment.s\06 73 11 response tn 06 13.11 RFI on Movement monitor SnP\Tailings Mgnt
^y!'!*^.^!"^! ^.°"/.'f" -'""^ ' ^'^^ ^ " '^"'-^f"^^" ID'Jgnuu., 2011 Submittals and Rcvi.ions for Cell 1B'J)MT Plan 01.10 1 IVTail.n^ Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doc "
g^06/n Revision: DemsonlU+
Book \ \. Environmental f roiecuuu
disposal cell.
T n<i the flow rate shall oe
^^^^,f fluid is pumped fr^^^^^^
,„eefluid«asl« or"^^^
whichever is the more receni.
weekly inspection.
fluid from an LUs, a nui'J
the Radioacfive Materials License.
detection system sump -"-^fMaximum Allowable Dady
tower flexible —ne mer To detem ^^^^^^ ^ t,,
LDS Flow Rates m the ^f'a weekly basis shall be
volume of all ^''^ P^P"^^""; * a tat infonnation will be used to
recovered from the ^^ta day. Under no circumstances shall
co^pafed against the —f ;'rA;pe„a E, to determine the
Cell 4A and 48.
b) Slimes Drain Water Level Monitoring
fit d Cell 2 is partially
„ cell 3 is nearly full and will —^ ^rfiU Ea* cell has a slimes drain
cr\o\T!>iUnes MsSt
White Mesa Mill - Standard Operating Procedures O406/11 Revision: Denisonl 1.2+
Book 11: Environmental Protection Manual, Section 3.1 Page 8 of 57
FML in Cell 2, which, based on constmction 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 acfivated and deactivated 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 tums 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. The average wastewater head in the
Cell 2 slimes drain is therefore less than 5 feet and is below the phreatic surface of
tailings Cell 2, 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 in this
manner is satisfactory and is as low as reasonably achievable.
(iv) The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working 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 fluid head before and after a
pumping cycle, respecfively. 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 Inspecfion 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;
(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) 8ecause Cell 3 and Cell 4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell 48 slimes drain will be
authorized once it is put into service and while it is active. Prior to initiation of
tailings dewatering operafions for Cell 3, Cell 4A, or Cell 48, a similar procedure
will be developed for ensuring that average head elevations in the Cell 3 and Cell 4A
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White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 9 of 57
slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell 4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
c) Wind Movement of TaiHngs
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) TaiHngs Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 14A, and 48 and Roberts Pond are to be taken by
survey on a weekly basis, and the beach area in Cell 4A and 48 with the maximum
elevation is to be taken by survey on a monthly basis, as follows:
(i) The survey will be performed by the Mill's Radiafion 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 Instmment")
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 Rfeference Points (tho "Reference Points") for Cells 14A5 and 48, 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 ofthe metal disk (the
"Reference Point Elevafion") for Cell 1 and Roberts Pond is at 5,623.14 feet
above mean sea level ("FMSL"). For Cell 3 Cell 4A, and Cell 18, 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 4A and
483) is at 5,607.83 FMSL. For Cell 4A and 48. the Reference Point is a piece of
stamped metal monument located next to the transformer on the south side of Cell
4A and 48. The elevation at the top of this piece of rebar (the Reference Point
Elevafion for Cell 4A and 48) is 5600.49 fmsl. 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 1/Roberts Pond Reference Point. For Cell 4A and Cell 48, this is
typically on the road on the Cell 3 dike approximately 100 foot oast of the Cell 3
Reference Pointsouth side of Cell 4A and 48;
(iv) Once in locafion, the Surveyor will ensure that the Survey Instmment is level by
centering the bubble in the level gauge on the Survey Instmment;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1/Roberts Pond Reference Point on the top ofthe rebar on
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24
Page 10 of57
the Cell 4A and 48 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;
(vi) 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 Instrument is reading above the
Reference Point;
(vii) 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 1, Cell IA, Cell 48,
or Roberts Pond, or the area of the beach in Cell 4A or Cell 48 with the highest
elevation, 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:
iyii) For a newly-constmcted cell, when the cell is first placed into operafion. the solution level
is typically zero feet above the FML or a minimal elevafion above the FML due to natural
precipitation. For newly-constructed cells, solution level measurement will not be required until
the solufion level is high enough that it can be reached safely by personnel with a measuring tape
along the side of the FML. Solutions levels will be measured by this method beginning when the
solution level is high enough to be reached safely, as determined by the RSO. Surveying of
solution levels will not be required unfil solution levels are high enough that they can effecfively
be measured by survey instmment from the appropriate surveying point.
-{ToriTiatted: No bullets or numbering
_Pond Surface Measurements
AT
—Cell IA
Formatted: Indent: Left: 1.54", No bullets or
numbering
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Sur\i'oy Rod at the liquid level.
Hvl. Cell 48
The Assistant will walk down the slope in the northwest comer of Cell 48 and
place the Survey Rod at the liquid level.
Wrll. 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
IV. Roberts Pond Formatted: Indent: Left: 1,5", Tab stops:
1.5", Left + Not at 1.13"
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmentai Protection Manual, Section 3.1
m-06/11 Revision: Denisonl 1.24
Page 11 of 57
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 locafions for the
measuring points for Roberts Pond and the Cells are:
jNorthing Easting •
Roberts Pond 323,041 2,579,697
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
.Cell 48 320,690 2,576,200
Formatted: Font: Bold
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Formatted: Keep with next
Formatted: Keep with next
Formatted: Keep with next ID
Formatted: Not Highlight
B. Cell 48 Beach Elevation
The Assistant vvill place the Survey Rod at the point on the beach area of Cell 4B
that has the highest elevation. Ifii is not clear which area of the beach has the
highest elevation, then mulfiple points on the beach area will be surveyed unfil the
Surveyor is satisfied that the point on the Cell 48 beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 48 beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(viii) 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;
(ix) The Surveyor will focus the cross hairs of the Survey Instmment 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.
Decontamination Pads
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Book 11: Environmental Protection Manual, Section 3.1 Page 12 of 57
0) New Decontamination Pad
The New Decontamination Pad is located in the southeast comer ofthe ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspecfion of the concrete wash pad for cracking.
Observations will be made of the current condifion of the New
Decontamination Pad. Any abnormalities relating to the pad and any
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Book 11: Environmental Protection Manual, Section 3.1 Page 13 of 57
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Exisfing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontamination Pad will be inspected on a weekly
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the current
condifion of the Exisfing Deeontaminafion Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. If there are any cracks greater than 1/8 inch
separafion (width), the RSO must be contacted. The RSO will have
the responsibility to cease activities and have the cracks repaired.
f) Summary
In addition, the weekly inspecfion should summarize all acfivifies conceming the
tailings area for that particular week.
Results ofthe weekly tailings inspection are recorded on the Weekly TaiHngs and DMT Inspection
form. An example ofthe 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 Secfion 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 Inspections
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Book 11: Environmental Protection Manual, Section 3.1 Page 14 of 57
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;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all altemate feedstock located outside the defined Feedstock Area are maintained within
water fight 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
attenfion 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 Da/a 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 ofthe
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locafions to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill mn.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstrucfion of flow. Diversion berm 2 should be checked
for stability and signs of distress.
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Book 11: Environmental Protection Manual, Section 3.1 Page 15 of 57
c) Sedimentation Pond
Acfivities around the Mill and facilities area sedimentafion pond shall be summarized
for the month.
d) 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
e) Remarks
A secfion 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 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 Constmction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspecfion 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
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Book 11: Environmental Protection Manual, Section 3.1 Page 16 of 57
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance acfivities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Constmcfion Review consists of reviewing any constmcfion changes or
modifications made to the tailings area on a quarteriy basis.
d) An estimate ofthe percentage ofthe tailings beach surface area and solufion pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 48.
Formatted: Font: Italic
Formatted: Indent: Left: 1", No bullets or
numt)ering
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Book 11: Environmental Protection Manual, Section 3.1 Page 17 of 57
d}e} 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 condifions 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 stmctures. 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
Evaluafion also includes a review and summary ofthe annual movement monitor survey (see Secfion
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
stmctures.
In the event tailings capacity evaluations (as per SOP P8L-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 quarterly tailings inspecfions.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observafions 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 ofthe tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
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Book 11: Environmental Protection Manual, Section 3.1 Page 18 of 57
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 copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluafion Report must be submitted by November 15'^ 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
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.
The flood volume from the PMP event over the Cell 48 area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell 4A is 40 acres, and in Cell 48 is 40
acres. The top ofthe flexible membrane liner ("FML") for Cell 1 is 5,618.2 FMSL, for Cell 4A
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Book 11: Environmental Protection Manual, Section 3.1 Page 19 of 57
is 5,598.5 FMSL and for Cell 48 is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. Cell 1
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow Cell 1 to capture all of
the PMP volume associated with Cell I. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave mn up factor of 0.90 feet equals 2.85 feet. The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condifion 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 48 (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Cell 48. A spillway has been added to Cell 4A to allow overflow into
Cell 48.
6.3.5. Cell 48
The freeboard limit for Cell 48 will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 48 of 159.4 acre feet will be accommodated in Cell 48. The procedure for calculating the
freeboard limit for Cell 48 is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 48 is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 48 will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume 38.1 acre-feet
Overflow from Cell 4A assuming no storage in Cell 3 or 4A 159.4 acre-feet
Sum of PMP volume and overflow volume 197.5 acre-feet
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 20 of 57
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres 4.9 feet
Wave mn up factor 0.77 feet
Total required freeboard 5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth ofa foot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevafion of the beach area in Cell 48 is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows forthe situafion where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in Cell 48 first exceeds 5,594 FMSL, then the
freeboard limit for the remainder ofthe ensuing year (period t=0) (unfil the next November 1) will be
calculated when that elevation is first exceeded (the "Inifial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
48 prior to the Initial Calculation Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell 48 for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("Ao*"), will be determined;
iii) Ao* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4A will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell 48 for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus TQ;
vi) The reducfion in the pool surface area for the remainder of the ensuing year will be
assumed to be direcfiy proportional to the reduction in the available space in Cell 4A
for solids. That is, the reduced pool surface area for period t=0 ("RPAQ"), after the
reduction, will be calculated to be:
(1 - (Ao* X 1.5) / (2,094,000 - To)) x 40 acres = RPAo
vii) The required freeboard for Cell 4A for the remainder of the period t=0 can be
calculated in feet to be the wave run up factor for Cell 48 of 0.77 feet plus the
quotient of 197.5 acre feet divided by the RPAQ. The freeboard limit for Cell 48 for
the remainder of period t=0 would then be the elevation of the FML for Cell 48 of
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures O406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 21 of 57
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculafion Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculafion is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5.594 FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARPAn)
to reflect actual tonnages deposited in Cell 48 for the previous period (period t-1).
The RPAt-i used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt-i is merely the RPA that would have
been used for period t-1 had the actual tonnages for year t-1 been known at the outset
of period t-1 and had the RPA been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARPAt-i can be calculated using the following formula:
(1 - A,.i / (2,094,000 - Tt-i)) x ARPAt.2= ARPAt-i
Where:
• At-i is the actual number of dry tons of tailings solids deposited in Cell 48
during period t-1;
• Tt-i is the actual number of dry tons of tailings solids historically deposited in
Cell 48 prior to the beginning of period t-1; and
• ARPA,_2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARPAt-2 is 40 acres;
ii) Once the ARPAt-i for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1 - (A,* X 1.5) / (2,094,000 - T,)) x ARPA,.i = RPAt
Where:
• At* is the expected number of dry tons of tailings to be deposited into Cell 48
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Tt is the actual number of dry tons of tailings solids historically deposited in
Cell 48 prior to the beginning of period t; and
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 22 of 57
• ARPAt-i is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-i) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave mn up
factor for Cell 48 of 0.77 feet plus the quotient of 197.5 acre feet divided by the RPAt.
The freeboard limit for Cell 4A for period t would then be the elevation ofthe FML
for Cell 48 of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth ofa foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist unfil the next Annual Calculafion
Date for period t+1.
An example ofthis calculation is set out in Appendix F.
(e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New TaiHngs Cell
When a spillway is added between Cell 48 and a new tailings cell then, if an approved freeboard
limit calculafion method for the new cell is set to cover the enfire PMP event for Cells 2,3,4A, 48
and the new tailings cell, the freeboard limit for Cell 48 will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
6.3.6. 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 solufion 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
Condifion 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
6.5. Annual Inspection of the Deeontaminafion Pads
a) New Decontamination Pad
During the second quarter of each year, the New Deeontaminafion Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface, ff any
abnormalities are identified, i.e. cracks in the concrete with greaterthan 1/8 inch separation (width)
or any significant deteriorafion or damage of the pad surface, repairs will be made prior to resuming
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23 11 response to 06.13 11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl 'IBVJanuary 2011 Submittals and Revisions for Coll •1BVDMT Plan 01.10.1 IVToilings
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1 Redline doe
^06/n Revision: Denisonl 1.2+
--ofthe facility. ^^^-^ZT"^^:^^^^^
^^l^c^^pSSI^lsS
of each calendar year.
FvUfina Deeontaminafion Pad _:„atmn Pad will be taken out of
have occurred since the last ••"'P'='^"f^ Jf,^"^.*~™be made prior to resum ng
re^olmtatio^ Pad Inspection form^ A -° ^/^^Ugs, any repa^ re^u.re^ and
fe-S:aSt:ir;rnthe^ndQuartert^MTMo^^^^^
September lofeach calendar year.
7. OTHER INSPECTIONS Hntild be perfomied as
..daily,wee.y,monthlyt,uarterly—^
8 REPORTING REQUIREMENTS ^
described in Sections 2 and 3, respecuv y,
MffllthlxlMlinga^ previous month's activities
Month.ytai,inssreportsarep...dev^-n^
T'ttrtotrfaSonsXcXerfor^review^
submitted to tne Kauia' ;„ the Mill Central File. I he repon. vv „„„„tive measures «ell before the report >s fi ed m he MUI ^^.^.^^^^ inspections. Co^^«ve
be signed and dated by the preparer „,„M«,«.»Si
Manag.
^06/1 ] Revision: Denisonl 1.24
Page 24 of 57
er.
8.2. DMTReEorts
b)
Quarterly reports of DMT
°"*''"'"«rly basis, ad reauir«),-„f
relating to the inspections Z^M^TT "^"'"^ ' -F-Z of the G WDP
Mon toring), 3.,(d)(Tain„g?wtrew rp'-^
Mon,,ormg), 3.2 (Weekly tospecUon "^^^^ and Beach Area Elevation
(Weekly Feedstock Stoige Z^Z!^!:';" Pond)and3.3
s:pSth:~
ofthe three ehambe,^ i„ the ^^re *?ir''''T''^'^'™ P°"^^
Decontamination Pad, which wiHdL 'Kf 'J"^'™ f"'' New
measurements in each portal du^g the quarter '""•-""S '"e water level
completed shall be summarized in thel^^ n^^ "^""^ '•"<""'"='^' repairs each calendar year; ""^ ^ Quarter report, due September I of
PrZ'i:Ct Sro'nf Decontami„a.i„„ Pad
ep^.rs completed shall be summaSnl^'o*';'"' '•^"'•^
ofeachcalendar.veanand '2eamthe2 Quarter report, due September I
--o-^valLan^dCLrm;^^^^^^^^^^^^
c)
d)
e)
White Mesa Mill - Standard Operating Procedures O406/11 Revision: Denison 11.24
Book 11: Environmental Protection Manual, Section 3.1 Page 25 of 57
APPENDIX A
FORMS
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24
Page 26 of 57
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
Inspector:
Date;
Accompanied by:
Time:
L TAILINGS SLURRY TRANSPORT SYSTEM |
Inspecfion Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connecfions
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Locafion or Orientation
II. OPERATIONAL SYSTEMS |
Insoecfion Items Conditions of Potenfial Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 48
Water Level Greater Than Operafing Level, Large Change
Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover. Exposure of Liner
Liner Observable Liner Damage
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'IBVJanunry 2011 Submittals and Revisions for Coll/IBVDMT Plon 01.10.1 IVTailings Mgnt System and DMT Mon Plan Nov 2010 Rv II.I Redlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O406/11 Revision: Denisonll.24
Page 27 of 57
IIL DIKES AND EMBANKMENTS
Inspection Items Condifions ofPotential
Concem
Dike l-I Dike I-
lA
Dike 2 Dike 3 Dike
4A-S
Dike
4A-EW
Dike
4B-S
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
Crest Cracks, Subsidence, Severe
Erosion
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
Formatted Table
IV. FLOW RATES |
Slurry Line(s) Pond Retum S-X Tails Spray System
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
Yes
No
'NO
VL DUST CONTROL
Cell 2 Cell 3 Cell 4A Cell 48
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
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4BVJanuaiy 2011 Submittals and Revisions for Cell 4BVDMT Plan 01.10.1 IVToilings Mgnt System imd DMT Mon Plan Nov 2010 Rv 11.1 Redlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
W06/11 Revision: Denisonl 1.24
Page 28 of 57
General Meteorological conditions:
VIL DAILY LEAK DETECTION CHECK | |
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detecfion
System
Checked
Checked Checked Checked Checked Checked Leak
Detecfion
System
Checked
Wet Dry Wet Dry Wet Dry Wet Dry Wet Dry
Leak
Detecfion
System
Checked
Inifial level Inifial level Inifial level Inifial level Inifial level
Leak
Detecfion
System
Checked
Final
level
Final
level
Final
level
Final
level
Final
level
Leak
Detecfion
System
Checked
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24
Page 29 of 57
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-lEVJanuary 2011 Submittals and Revisions for Cell 1BVDMT Plan Ol.lO.l lVTailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redlinc.doo
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 30 of 57
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Tailings Daily Inspection Rq)oit
Tailings; Sluny Discharge Location
/ /
CELL NO. 1
MILLSITE
._Dike.l-I„.
Q
/ /
CELL NO. 2
FiUed
o
o 1
2 .2
1'=
§ o > CQ
CELL NO. 4B
CELL NO. 4A
/
N
Date;
luspectoi:
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
^06/11 Revision: Denisonll.24
Page 32 of 57
-( Formatted: Left
M..r.P, .nH PrnceHuresVM...r..n. monitor SOP and r-.mm.n.V06 23 1. response to 06 H 11 RF. on Movement monitor •SOPVTailings Mpnt^S^^^^^^ DMT Mon Plan lune;2011 rev 11.2.docN^
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 33 of 57
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach Cell 1: (a) Pond Solution Elevation
elevations (msl, ft)
(b) FML Bottom Elevadon 5597_
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.44-
(c) DopthofWatcrabovoFML((a) (b))
Cell 48: (a)Pond Solution Elevation
(b) FML Bottom Elevafion 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation
(b) FML Bottom Elevafion _5612.3
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump fiincfioning properly
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 =
NASOPs and ProceduresVMovement monitor SOP and commentsV06 23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O406/11 Revision: Denisonl 1.24
Page 34 of 57
3. Leak Detection Systems
Observation:
Coll 'IA Colli B
Is LDS wet or -wet -wet -wet
If wet, Rooord
liquid level:
-FHe -Ftte -ft4e
Liquid Liquid Liquid Liquid
-FHe
Liquid
If sufficient
fluid is
present, record
volume of
fluid pumped
and flow rate:
Voiumo
Rate
Volume
Rate
Volume
Rate
Volume
Rate
Volume
Rate
Was fluid
s omul's
collected?
_yes_ jfes _yes_
(Same data as Daily Inspecfion Form. Record data on daily form).
Observation:
New Decon Pad,
Portal 1
New Decon Pad,
Portal 2
New Decon Pad
Portal 3
Is LDS (Portal)
wet or dry?
wet dry wet dry wet dry Is LDS (Portal)
wet or dry?
If wet. Record
liquid level:
Ft to Ft to Ft to If wet. Record
liquid level: Liquid Liquid Liquid
If wet. Report to
RSO
4. Tailings Area Inspecfion (Note dispersal of blowing tailings):
5. Control Methods Implemented:
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24
Page 35 of 57
6. Remarks:
7. Contaminated Waste Dump (7-awaifing DRC
approval i)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 48)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), nofify supervisor or Mill manager immediately.
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White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 36 of 57
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
1. Slurry Pipeline:
Pipe Thiclmoss: (To be moasurod 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 no
Erosion yes no yes no yes no
Undesirable yes no yes no yes no
Vegetation
Obstmction of Flow yes no yes no yes no
Diversion Berm:
Stability Issues yes no
Signs of Distress yes no
Comments:
3. Summary of Activities Around Sedimentation Pond:
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonll.24
Page 37 of 57
4. Overspray Dust Minimization:
Overspray system fiincfioning properly: yes
Overspray carried more than 50 feet from the cell:
Ifyes", was system immediately shut off?
Comments:
_yes_
_yes_
5. Remarks:
6. Settlement Monitors
CeI12 Wl:
Cell 2 W2:
Cell 2 W3:
Cell 2 W4:
Cell 2W7-C:
CeI12 W7N:
Cell2 W6C:
Cell 4A-Toe:
Cell 3-2C:
Cell 2W3-S:
Cell 2E1-N:
Cell2El-lS:
Cell 2E1-2S:
Cell 2 East:
Cell 2 W7S:
Cell 2 W6S:
Cell 2 W4S:
Cell 3-2S:
Cell 3-lN:_
Cell 3-lC:_
Cell 3-1 S:_
Cell 3-2N: _
Cell 2W5-N
Cell 2 W6N
Cell 2 W4N
Cell 2 W5C
Cell 2 W5S
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
TrS^Summary of Daily, Weekly and Quarterly Inspections:
"( Formatted: No bullets or numbering
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White Mesa Mill - Standard Operating Procedures 0W6/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 38 of 57
8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
9. Monthly Slimes Drain Static Head Measurement for Cell 3 (Depth-in-Pipe Water level) (after
Cell 3 is closed):
NASOPs and Procedure.sVMnvement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
m-06/11 Revision: Denisonll.24
Page 39 of 57
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities:
4. SummaryEstimated Areas:
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\ for Coll 4BVDMT Plon-Ol. 10r44VfatImgs Svstem and DMT Mpn Plan June 2011 rev 11.2.docNACell -IByjonuary 2011 Submittals and Rcvis
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redlinc.doo
Formatted: Outline numbered + Level: 1 + Numbering Style: 1, 2, 3,... + Start at: 1 +
Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.15", Widow/Orphan
control
/
OfS?
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 41 of 57
APPENDIX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of hispection:
Inspector:
Weather conditions for the week:
Blowing dust condifions for the week:
Corrective acfions 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 altemate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no:^
comments (e.g., condifions of containers):
Are all sumps and low lying areas free of standing solufions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water mnning off of the feedstock stockpiles?
Yes: No:
Comments:
NiVSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.1311 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11 2 docNACell 'IBUanuarv 2011 Suhmittoln and Revisions for Coll ^BVDMT Plan 01.10.1 IVTailines
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doc
. ^ . 0406/11 Revision: Denisonll.24
White Mesa Mill - Standard Operating Procedures — ^^^^
Book 11: Environmental Protection Manual, Section 3.1
Other comments:
j4„^^y5tet^m.d DMT Mon Plo.^. 2010 R. 11 1 Pedlini^^
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 43 of 57
APPENDIX A (CONT.)
ANNUAL DECONTAMINATION PAD INSPECTION
Date ofinspection:
Inspector:
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation? Yes No
Is there any significant deterioration or damage of the pad surface? Yes No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes No
Findings:
Repair Work Required:
Note For the annual inspection ofthe both the Exisfing and New Decontamination Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2"^* Quarter report, due September 1 of each
calendar year
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl 'tBVJonuorv 2011 Submittals and Revisions for Cell IB'iDMT Plon 01 .lO.nVToilings
Mgnt System ond DMT Mon Plan Nov 2010 Rv 111—Redline doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denison 11.24
Book 11: Environmental Protection Manual, Section 3.1 Page 44 of 57
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training infonnafion is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspecfions 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, activifies, and areas of concem regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (safisfactory, requiring no
action) or that condifions of potential concem exist (requiring action). A "check" mark indicates no
acfion required. If conditions of potential concem 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 condifions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom vvill notify' Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then nofify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas ofthe tailings disposal system are roufinely 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
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell IBUanuory 2011 Suhmitlnln nnd Revisions for Cell -IBVDMT Plan Ol.lO.llVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures O406/11 Revision: Denison 11.24
Book 1 \: Environmental Protection Manual, Section 3.1 Page 45 of 57
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 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 potenfial items of concem for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 48 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 activifies affecfing 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
ofthe 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 condifions
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 ofthe repairs.
3. Dikes and Embankments:
Inspection 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 concem are cracks, subsidence, and severe erosion.
When any of these condifions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes ^4A-S, 4A-WE, and 4B-S, and 4B-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.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell 'IBVJoniinry 2011 Submittals and Revisions for Cell vlBVDMT Plan 01.10.1 UToilincs
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redlinc.doo
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denison 11.24
Book 11: Environmental Protection Manual, Section 3.1 Page 46 of 57
4. Flow Rates:
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 tme 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 4 hours during operation ofthe
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:
Dusfing and wind movement of tailings should be noted for Cells 2, 3, 4A, and 48. Other
observations to be noted include a brief description of present weather condifions, 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 ShifterEnvironmental. Health and Safetv personnel as
close to 8:00 a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concem during the inspection should be noted in this section. Corrective
action should follow each area of concem noted. All work orders issued, contacts, or
notificafions 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.
8. Map of Tailings Cells:
The last section of the inspecfion involves drawing, as accurately as possible, the following
items where applicable.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VCoir'tBVJonuQry 2011 Submittals ond Revisions for CciUBVDMT Plan 01.10.1 IVToilings
Mgnt System arid DMT Mon Plon Nov 2010 Rv 11.1 Redline.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 47 of 57
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
5. Acfivities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These mles
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell 4A and 48 dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell 4A and 48 dike) is 15 mph. These limits 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 hamess 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 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.
10. 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.
11. 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 certificafion. Refer to the Certification
N ASOPs and ProceduresVMovement monitor SOP and commentsV06 23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll 'IBUonuorv 2011 Siihmittnis nnd Rnvismns for Cell -IBVOMT Plan 01 10.1 IVToilings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doe
White Mesa Mill - Standard Operating Procedures #406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 48 of 57
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.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VCell 'IBVJonuarv 2011 Submittals and Revisions for Coil '1BVDMT Plon 01 10.1 IVToilings
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1—Redlinc.doo
White Mesa Mill - Standard Operating Procedures O406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 49 of 57
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document tified "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 Personnel/ Tailings System
Supervisor
N ASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodline.doc
0406/n Revision: Denisonl U+
Page 50 of J '
APPENDIX D
FEEDSTOCK STORAGE AREA
;3 o
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Book ll: Environmental prot
APPENDIX E
TABLES
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O406/11 Revision: Denisonl 1.24
Page 53 of 57
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table 18
Calculated Action leakage Rates
for Various head Conditions
Cell 48 White mesa Mill
Blanding, Utali
Head above Liner System (feet) Calculated Acfion leakage Rate
( gallons / acre / day )
5 211.40
10 ,317.00
15 ,369.90
20 ,422.70
25 ,475.60
30 ,528.40
35 ,570.00
37 ,581.20
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NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell IBVJonuarv 2011 Submittals and Revisions for Cell IBVDMT Plan 01 10.1 IVToilings
Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 54 of 57
N:VSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2 docNACell 4BVJanuarv 2011 Submittals ond Revisions for Cell •IBVDMT Plon 01.10.1 IVTgilings
Mgnt System ond DMT Mon Plon Nov 2010 Rv 11.1 Rodline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O406/11 Revision: Denisonl 1.24
Page 55 of 57
APPENDIX F
Example of Freeboard Calculations
For Cell 4B
Assumpfions and Factors:
o Total PMP volume to be stored in Cell 4A - 159.4 acre feet
o Wave runup factor for Cell 4A - 0.77 feet
o Total capacity of Cell 48 - 2,094,000 dry tons
o Elevafion of FML of Cell 48 - 5,600.35 FMSL
o Maximum pool surface area of Cell 4A - 40 acres
o Total tailings solids deposited into Cell 48 at time beach area first exceeds 5,594
FMSL - 1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL - March 1, 2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected
Tailings Solids
Disposition into
Cell 4B
Determined at
the beginning of
the period (dry
tons)*
Expected
Tailings
Solids
Dispositio
n into Cell
48 at the
beginning
ofthe
period,
multiplied
by 150%
Safety
Factor
(dry tons)
Actual Tailings
Solids
Disposition into
Cell 43
determined at
end of the
period (dry
tons)*
March 1, 2012
to November 1,
2012
150,000 225,000 225,000
November 1,
2012 to
November 1,
2013
300,000 450,000 275,000
November 1,
2013 to
November 1,
2014
200,000 300,000 250,000
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13 11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell 'IBVJanuary 2011 Submittals and Revisions for Cell IBVDMT Plan 01.10.1 IVToilings
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1 Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 56 of 57
*These expected and actual tailings and producfion numbers and dates are ficfional and have
been assumed for illustrative purposes only.
Based on these assumpfions and factors, the freeboard limits for Cell 48 would be calculated
as follows:
1. Priorto March 1.2012
Prior to March 1,2012, the maximum elevation of the beach area in Cell 48 is less than or
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1. 2012 to November 1. 2012
The pool surface area would be reduced to the following amount
(1 - 225,000/(2,094,000 - 1,000,000)) x 40 acres = 31.77 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave mn up factor for Cell 48 of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 48 would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth ofa foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1. 2012 to November 1. 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of 225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1 - 450,000 / (2,094,000 - 1,000,000 - 225,000)) x 31.77 acres = 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factor for Cell 48 of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
48 would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2012, and this freeboard limit would persist unfil November 1, 2013.
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Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Rcdiine doo
White Mesa Mill - Standard Operating Procedures 0406/11 Revision: Denisonl 1.24
Book 11: Environmental Protection Manual, Section 3.1 Page 57 of 57
4. November 1. 2013 to November 1. 2014
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1 - 275,000/(2,094,000 - 1,000,000 - 225,000) x 31.77 acres = 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1, 2013.
Then, calculate the modeled pool surface area to be used for the period:
(1 - 300,000 / (2,094,000 - 1,000,000 - 225,000 - 275,000)) x 21.72 acres
10.75 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave mn up factor for Cell 48 of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculafion would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
N.VSOPs and ProceduresVMovement monitor SOP and commenlsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and PMT Mon Plan June 2011 rev 11.2.docN ACcll ^BUonuarv 2011 Submittals and Revisions for Coll 4B\DMT Plan 01.10.1 IVToilings
Mgnt System ond DMT Mon Plan Nov 20-10 Rv 11.1 Rcdlinc.doc
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Secfion 5.1
Date; n/2010 Revision: DUSA-1
Page 1 of 3
1.
1.1
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
MOVEMENT (DISPLACEMENT) MONITOR
Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Movement (Displacement) Monitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of construction activities, Movement Monitors will be installed
and surveyed by a Utah Licensed Land Surveyor. The installation of these movement monitors
will be along the exposed dike of the taihng cells.
All new movement monitors (installed after June, 2010) will be surveyed by a Utah Licensed
Land Surveyor semi-annually for the first three years. After three years, each new movement
monitor (installed after June, 2010) will be surveyed annually. All existing movement monitors
(installed prior to June 2010) will be surveyed on an annual basis.
On an annual basis, a Utah Licensed Professional Engineer will review, analyze, and certify the
data which will be submitted as part of the ATER as required by RML License Condition 12.3.
1.3 Design of Settlement Monitors
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The Movement Monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument. A piece of rebar, 24 inches in length, will be
driven into the hole. The hole will be back filled and the top of the rebar will be below surface
grade. Each monument will be individually tagged and numbered.
C:\DOCUME~l\Drupp\LOCALS~l\Temp\XPgrpwise\Seefion 5 1 Movement Monitor SOP Nov 2010.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protecfion Manual, SOP Section 5.1
Date: 11/2010 Revision: DUSA-1
Page 2 of 3
1.4
1.4.1
Monitoring and Maintenance of Movement Devices
Monitoring and Documentation of Condition of Devices
The Movement Monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The Movement Monitors will be installed in such a way to prevent damage by equipment. The
Movement Monitors will be installed such that the monument is below the actual ground surface
level, so the potential for damage by equipment is minimized. However, if a monument is
disturbed, the information will be immediately given to the RSO, or designee. The RSO, or
designee, will make notification to the Corporate Compliance Director and a corrective action
plan will be created for repairs and the surveying and documentation of any changes.
If any Movement Monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The
replacement device will be placed in the same excavated hole from which the damaged device
was removed. Data from the new device will be correlated to data from the removed damaged
device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamaged devices, no adjustment will be made to the survey data of
the new device.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change to either of the
undamaged devices, the survey results for the new device will be adjusted by the average
change observed in the two adjacent devices. This adjustment will be documented in the
Utah-Licensed Land Surveyors report and in the annual ATER.
1.5 Documentation
The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations in relationship to the tailings cells. A brief summary of work and
analytical data will be provided in a written report by the Utah-Licensed Land Surveyor.
All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.
C:\DOCUME~I\Drupp\LOCALS~I\Temp\XPgrpwise\Secfion 5 1 Movement Monitor SOP Nov 2010.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protecfion Manual, SOP Secfion 5.1
Date: 11/2010 Revision: DUSA-1
Page 3 of 3
1.6 Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical movement on the
movement monitors. If there is a difference of 0.1 foot, then the corrective actions will be taken
as follows:
1 Resurvey the movement monitor that shows vertical movement of 0.1 foot.
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, or burrowing animals, etc.).
4 Report this information to the Executive Secretary within a timely manner and include in
that notification the investigation steps, movement evaluation and corrective action steps.
Movement monitors that show vertical movement of 0.2 foot or greater for two consecutive
monitoring periods may be subject to accelerated monitoring at a frequency and in a manner
approved by the Executive Secretary.
On an annual basis, a Utah Licensed Professional Engineer will review, analyze, and certify the
data which will be submitted as part of the ATER as required by RML License Condition 12.3,
along with a description of any corrective actions performed.
C:\DOCUME~l\Drupp\LOCALS~l\Temp\XPgrpwise\Section 5 1 Movement Monitor SOP Nov 2010.doc
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