DRC-2010-003393 - 0901a0688018ee7b

RC-2010»0033
DENISO
MINES
May 28, 2010
VIA FEDERAL EXPRESS
Mr. Dane Finerfrock,
Co-Executive Secretary,
Utah Water Quality Board,
Utah Department of Environmental Quality,
195 North 1950 West
Salt Lake City, Utah 84114-4850
Dear Mr. Finerfrock:
Denison Mines (USA) Corp.
105017th Street, Stiite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.(lenisonmines.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the l" Quarter of 2010
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
4A BAT Performance Standards Monitoring Report for the 1^' Quarter of 2010, as required under
Parts I.F.2 and I.F.3 ofthe White Mesa Mill's State ofUtah Groundwater Discharge Permit No.
UGW3 70004. Also enclosed are two CDs, each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
OENISOJ)JJ
MINES
May 28,2010
VIA FEDERAL EXPRESS
Mr.Dane Finerfrock,
Co-Executive Secretary,
Utah Water Quality Board,
Utah Department ofEnvironmental Quality,
195 North 1950 West
Salt Lake City,Utah 84114-4850
Dear Mr.Finerfrock:
Denison Mines (USA)Corp.
1050 17th Street,Suite 950
Denver,CO S0265
USA
rei:303 62S·n98
Fax:303389...125
_.denlsonmlnes.com
Re:Transmittal of DMT Performance Standards Monitoring Report and Cell 4A BAT
Performance Standards Monitoring Report for the 1st Quarter of2010
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
4A BAT Performance Standards Monitoring Report for the 1st Quarter of 201 0,as required under
Parts I.F.2 and I.F.3 ofthe White Mesa Mill's State of Utah Groundwater Discharge Permit No.
UGW370004.Also enclosed are two CDs,each with an electronic word-searchable copy of the
enclosed Report.
If you have any questions regarding this RepOlt,please contact the undersigned at (303)389-
4132 or Mr.David Turk at [phone].
Yours very truly,
DENISON MINES (USA)CORP.
Jo Ann Tischler
Director,Compliance and Permitting
cc David C.Frydenlund
Ron F.Hochstein
Harold R.Roberts
David E.Turk
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT
1st Quarter
January through March
2010
State of Utah
Groundwater Discharge Permit No.UGW370004
Prepared By:
Denison Mines (USA)Corp.
1050 17\h Street,Suite 950
Denver,CO.80265
May 28,2010
TABLE OF CONTENTS
Page
1.lNTRODUCTION.........................................1
2.MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING
THE QUARTER....................................................................................1
3.WEEKLY TAILINGS WASTEWATER POOL ELEVATION
MONITORING..............................................................1
4.MONTHLY SLIMES DRAIN WATER LEVEL MONITORING .3
4.1 General...........................................................3
4.2 Resnlts for the Quarter.....................................................................4
4.3 Quality Assurance Evaluation and Data Validation....................................4
4.4 Graphic Comparison to Previous year..........5
5.WEEKLY WASTEWATER LEVEL MONITORING:ROBERTS POND.......5
6.WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND
INSPECTIONS OF FEEDSTOCK MATERIAL STORED OUTSIDE THE
FEEDSTOCK STORAGE AREA................................................................5
7.TAILINGS CELLS AND POND LINER SYSTEM REPAIRS....................5
8.CELL 4A BAT PERFORMANCE STANDARDS REPORT FOR THE
QUARTER..........................................................................................6
8.1 LDS Monitoring...........................................................................6
a)Operational Status ofLDS Pumping and Monitoring Equipment...................6
b)Measurement of Weekly Fluid Head at the Lowest Point in the Secondary
Membrane.......6
c)Measurement ofthe Volume ofFluids Pumpedfrom the LDS........................6
8.2 Measurement of Weekly Wastewater Fluids in Ce1l4A...........................7
8.3 Slimes Drain Recovery Head Monitoring........7
9.SIGNATURE AND CERTIFICATION .7
Attachment
A .
B ..
c...
D ..
E .
ATTACHMI~NTS
Description
Tailings Cell and Roberts Pond Wastewater Elevations
Notices Pursuant to Part I.G.3 of the Permit
Monthly Cell 2 Slimes Drain Monitoring Data for the Quarter
Graph Showing Cell 2 Slimes Drain Water Levels Over Time
Cell 4A Leak Detection System Data for the Quarter
jj
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A BAT
PERFORMANCE STANDARDS MONITORING REPORT
FOR THE 1st QUARTER OF 2010
1.INTRODUCTION
This is the routine DMT Performance Standards Monitoring Report for the Jsl quarter of 2010
(the "Quarter")prepared by Denison Mines (USA)Corp.("Denison"),as required under Part
I.F.2 of the White Mesa Mill's (the "Mill's")State of Utah Groundwater Discharge Permit No.
UGW370004 (the "Permit"),and the Routine Cell 4A BAT Performance Standards Monitoring
Report for thc Quarter,as required under Part I.F.3 of the Permit.
2.MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER
During the Quarter,the following discharge minimization technology ("DMT")monitoring was
performed or addressed,as required under Part I.E.7 of the Permit:
•Weekly tailings wastewater pool elevations for tailings Cells J and 3;
•Monthly slimes drain water levels in Cell 2;
•Weekly wastewater level measurements in Robert's Pond;
•Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside ofthe feedstock storage area;and
•Any tailings cell and pond liner system repairs.
Also during the Quarter,the following Cell 4A best available technology ("BAT")performance
standards monitoring was performed or addressed,as required by Part I.E.S of the Permit:
•Leak detection system ("LDS")monitoring for Cell 4A;and
•Weekly tailings wastewater pool elevations for tailings CeIl4A.
3.WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in Tailings Cells J,3
and 4A to ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the Mill's State of Utah Radioactive Materials License No.UT 1900479 (the
"License").These measurements were made from an elevation survey.The results of such
monitoring,reported as feet above mean sea level (fmsl),are included in Attachment A.
Condition 10.3 of the License provides that freeboard limits for Cells J and 3 shall be set in
accordance with procedures that have been approved by the U.S.Nuclear Regulatory
Commission ("NRC").Under those procedures:
1
a)The freeboard limits are set as per the January 10,1990 Drainage Report for Cell I at a
liquid maximum elevation of 5,615.4 fmsl;
b)The freeboard limit for Cell 3 is determined annually using a formula set out in the
procedure.The current freeboard limit for Ccll 3 was previously calculated under this
procedure at 5,601.6 fms!.However,in a letter from the Executive Secretary of the
State of Utah Radiation Control Board (the "Executive Secretary")dated November 20,
2008,an interim variance and limit was established at 5,602.5 fmsl for Cell 3;and
c)In conjunction with the variance established under (b)above,an interim maximum
elevation for Ce1l4A was also established at 5,593.74 fms!.
In addition,Part I.D.2 of the Permit provides that under no circumstances shall the freeboard of
any tailings cell be less than three feet,as measured from the top of the flexible membrane liner
("FML").The top of the FML in Cell I is at 5,618.5 fmsl,the top of the FML in Cell 3 is at
5,608.5 fmsl and the top of the FML in Cell 4A is at 5,598.5 fms!.This means that the
maximum wastewater pool elevations in Cells 1,3 and 4A permitted under Part l.D.2 of the
Permit are 5,615.5,5,605.5 and 5,595.5 fmsl,respectively.
The waste water pool elevations in Cells 1,3 and 4A,as measured during the Quarter,are
summarized in the following Table 1.Except as indicated in Table 1,the applicable freeboard
limits were not exceeded during the Quarter.
Table 1 -Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measnred During the I'ermitted Under Elevationl'ermitted
Quarter (fmsl)License Condition Under I'art I.D.2 of
10.3 (fmsI)the I'm'mit (fmsl)
Cell I 5,613.74 5,6 I 5.4 5,615.5
Cell 3 5,603.21 *5,602.5 5,605.5
5,602.85*
5,602.53**
5,602.44***
Cell 4A 5,585.55 5,593.74+5,595.5
'These exceedances of the freeboard hmlt for Cell 3 were the subject of a Notice to the Executive Secretary under
Part I.G.3 of the Pcrmit and Utah Administrative Code ("UAC")R317-6-6.16(C),dated March 3,2010,a copy of
which Notice is included in Attachment B.
**This exceedance of the freeboard limit for Cell 3 was the subject of a Notice to the Executive Secretary under Part
I.GJ of the Permit and UAC R317-6-6.16(C),dated March 31,2010,a copy of which Notice is included in
Attachment B.
**This is the maximum wastewater elevation in Cell 3 during the Quarter,other than the exceedances that were the
subject of the Notices to the Executive Secretary under Part I.G.3 ofthe Permit and UAC R317-6-6.16(C)referred to
above.
+The freeboard limit for Cell 4A is not set out in the License.The freeboard limit of 5,593.74 for Cell 4A is set out
in a letter fro111 the Executive Secretary dated November 20,2008.
2
It should be noted that the maximum elevation of 5,593.74 fmsl for Cell 4A has been set
assuming that the total probable maximum precipitation ("PMP")volume for Cells 2,3 and 4A
will be accommodated in Cell 4A.By letter dated December I I,2008,Denison applied for an
amendment to the License to set the freeboard limit for Ce1l4A at 5,593.74 fmsl and to eliminate
the need to set a freeboard limit for Cell 3,given that the freeboard limit of 5,593.74 fmsl for
Cell 4A is adequate to accommodate the total PMP volume for Cells 2,3 and 4A.
4.MONTHLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(I)of the Permit provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable,in accordance with the White Mesa Mill Tailings Management
System and Discharge Minimization Technology (DMT)Monitoring Plan,3/10 Revision:
Denison-7 (the "DMT Plan").Part I.D.3(b)(3)of the Permit provides that for Cell 3,this
requirement shall apply after initiation of de-watering operations.Similarly,Part I.D.6(c)of the
Permit provides that,after the Permittee initiates pumping conditions in the slimes drain layer in
Cell 4A,the Permittee will provide:I)continuous declining fluid heads in the slimes drain layer,
in a manner equivalent to the requirements found in Part I.D.3(b),and 2)a maximum head of 1.0
feet in the tailings (as measured from the lowest point ofthe upper FML)in 6.4 years or less.
Part I.D.3(b)(2)of the Permit provides that the Permittee shall conduct a monthly slimes drain
recovery test at each tailings cell that meets the following minimum requirements:I)includes a
duration of at least 90-hours,as measured from the time that pumping ceases,and 2)achieves a
stable water level at the end of the test,as measured by three consecutive hourly water level
depth measurements,with no change in water level,as measured to the nearest 0.01 foot.
At this time,initiation of de-watering operations have not commenced in Cell 3 nor has the Mill
initiated pumping conditions in the slimes drain layer of Cell 4A.As a result,the requirements
in Part I.E.7(b)to monitor and record monthly the depth to wastewater in the slimes drain access
pipes as described in Part I.D.3 of the Permit apply only to Cell 2 at this time.Accordingly,this
Report is limited to slimes drain recovery head information relating to Cell 2 only.
Pursuant to Parts I.E.7(b)and I.P.2 of the Permit,Section 8.2 of the DMT Plan and
correspondence from the Utah Department of Environmental Quality,Division of Radiation
Control,dated February 7,2008,the results of monthly recovery monitoring of the slimes drain
for Cell 2 are to be recorded and included with the results of quarterly monitoring in the
quarterly White Mesa Mill DMT Pecformance Standards Monitoring Report and Cell 4A BAT
Peiformance Standards Monitoring Report (the"DMT Reports").Further,beginning in 2008,
quarterly DMT Reports must include both the eunent year monthly values and a graphic
comparison to the previous year.An annual slimes drain recovery head report,that addresses the
requirements of Part I.P.II of the Permit and Section 8.2 of the DMT Plan must be included in
the 4th quarter DMT Report.
3
4.2 Results for the Quarter
In accordance with these requirements,the individual monthly slimes drain recovery head
monitoring data for the Quarter,which includes the date and time for the start and end of the
recovery test,the initial water level,and the final depth to stable water level,is included as
Attachment C to this Report.Those data,as well as the data for the previous year,including the
slimes drain recovery elevations ("SDRE"),are summarized in the following Tables 2 and 3.
Table 2 -Cell 2 Slimes Drain Recovery Head and SDRE Values for 2009
Elevation of Reported Final Depth to SDRE Values Reported
2009 Test Closin2 Date Measurement Point Stable Water Level as fmsl
1/3012009 5,614.83 11.25 5,603.58
2/2712009 5,614.83 9.35 5,605.48
312812009 5,614.83 8.84 5,605.99
412712009 5,614.83 11.98 5,602.85
5120/2009 5,614.83 10.28 5,604.55
612212009 5,614.83 13 5,601.83
7/3012009 5,614.83 13 5,601.83
813112009 5,614.83 11.04 5,603.79
9128/2009 5,614.83 11.46 5,603.37
10/3012009 5,614.83 13.35 5,601.48
11/2312009 5,614.83 12.49 5,602.34
1211412009 5,614.83 13.12 5,601.71
Table 3 --Cell 2 Slimes Drain Recovery Head and SDRE Values for 2010
Elevation of Reported Final Depth to SDRE Values Reported
2010 Test Closin2 Date Measurement Point Stable Water Level as fmsl
111512010 5,614.83 13.96 5,600.87
2/2112010 5,614.83 12.5 5,602.33
3/1512010 5,614.83 11.04 5,603.79
4.3 Quality Assurance Evaluation and Data Validation
Denison management has evaluated all slimes drain data collected,data collection methods,and
all related calculations required by the Permit,and have verified the accuracy and reliability of
both the data and calculations reported.
As a result of its quality assurance evaluation and data validation review,Denison has concluded
that all of the ]st Quarter 2010 and all of the 2009 monthly slimes drain tailings fluid elevation
measurements set out in Tables 2 and 3 meet the test performance standards found in Part
I.D.3(b)(2)of thc Permit and can be used for purposes of determining compliance with the
requirements of Part I.D.3(b)(2)of the Permit.
4
4.4 Graphic Comparison to Previous Yeal'
A graph showing the final depth to stable water level readings for each month in 2010 and 2009,
for which validated data is available (see Section 4.3 above),is included as Attachment D,which
shows a graphic comparison of this Quarter's data to data for the previous year.
5.WEEKLY WASTEWATER LEVEL MONITORING:ROBERTS POND
During the Quarter,Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part J.D.3(e)of the
Permit.Part J.D.3(e)of the Permit provides that the water level in Robert's Pond shall not
exceed an elevation of 5,624 fms!.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5,622.21
fmsl,which did not exceed the maximum permitted elevation of 5,624 fms!.The results of such
monitoring are included in Attachment A.
6.WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE Ii'EEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department,to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the Permit and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part J.D.II
of the Permit.The results of these inspections are recorded on the Weekly Mill Inspection
forms,which are available at the Mill for inspection.No variance in stored materials from these
requirements was observed during the inspections.
7.TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells I,2 and 3 were inspected on a daily basis pursuant to the requirements
of Sections 2.1 and 2.2 of the Mill's DMT Plan.The results of those inspections are recorded on
the Mill's Daily Inspection Data sheets,which are available at the Mill for inspection.A visual
inspection of Roberts Pond was performed on a weekly basis.The results of those inspections
are recorded on the Weekly Mill Inspection forms,which are available at the Mill for inspection.
In accordance with Part J.E.7(f)of the Permit,in the event that any liner defect or damage is
identified during a liner system inspection,the Mill shall immediately implement the currently
approved Liner Maintenance Provisions.Further,Part J.F.2 of the Permit provides that when a
liner repair is performed at any tailings cell or at Roberts Pond,a Repair Report shall be prepared
and included WitJl the next quarterly DMT report.
During the Quarter,no liner repairs were performed at any of the Mill's tailings cells or at
Roberts Pond.
5
8.CELL 4A BAT PERFORMANCE STANDARDS REPORT FOR THE QUARTER
This Section constitutes the routine Cell 4A BAT Performance Standards Monitoring Report for
the Quarter,as required under Part l.F.3 of the Permit.
8.1 LDS Monitoring
a)Operational Status (!f LDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment,including,but not limited to,the submersible
pump,pump controller,head monitoring,and flow meter equipment operated continuously
during the Quarter.
During the Quarter,there were no failures of any pumping or monitoring equipment not repaired
and made fully operational within 24-hours of discovery,as contemplated by Part l.E.8(a)(l)of
the Permit.
However,due to adverse weather conditions and excessive snow on the tailings cells and tailings
dikes,the LDS was not able to be accessed for monitoring during the week of January 22,20 I0,
for safety reasons,and was not monitored during that week.
b)Measurement o.fWeekly Fluid Head At the Lowest Point in the Secondary Membrane
The readings pertaining to the fluid head above the lowest point in the secondary FML are
provided in Attachment E.As can be seen from a review of Attachment E,at no point in the
Quarter did the fluid head in the Cell 4A LDS sump cxceed a I-foot level above the lowest point
in the lower FML on thc Cell floor (where for purposes of compliance monitoring this I-foot
distance equates to 2.28 feet above thc LDS system transducer),as stipulated by Part l.E.8(a)(2)
of thc Permit.During the Quarter,the fluid head in the Cell 4A LDS sump did not excecd 12.7
inches above the LDS transducer.
c)Measurement o.fthe Volume ofFluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment E.As can
be seen from a review of Attachment E,during the Quarter,the average daily LDS flow volume
did not exceed 24,160 gallons/day,as stipulated by Part l.E.8(a)(3)of the Permit (based on the
maximum head recorded on the FML during the Quarter of about 30 feet,the allowable leakage
rate would actually be approximately 21,750 gallons per day,as determined under the Mill's Cell
4A BAT Operations and Maintenance Plan).For the Quarter,a total of 3,295 gallons were
pumped,which equates to approximately 37 gallons per day.
6
8.2 Measurement of Weekly Wastewater Fluids in Cell4A
Weekly fluid elevations for Cell 4A are provided in Attachment A along with elevations for
Cells 1 and 3 and Roberts Pond.During the Quarter,the Mill operated and maintained
wastewater levels in Cell 4A to provide the minimum ve11ical freeboard as required by Part
LE.8(a)(4)of the Permit.See the discussion in Section 3 above.
8.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Cell 4A slimes drain system at this time,
monthly recovery head tests and fluid level measurements are not required to be made at this
time pursuant to Part LE.8(b)of the Permit.
9.SIGNATURE AND CERTIFICATION
This document was prepared by Denison on May 28,2010.
By:
David .Fry,enlund
Vice President,Regulatory affairs and Counsel
CERTIFICATION:
I certify,under penalty of law,that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted.Based on my inquiry of the person or
persons who manage the system,or those persons directly responsible for gathering the
information,the information submitted is,to the best of my knowledge and belief,true,accurate
and complete.I am aware that there are significant penalties for submitting false information,
includin e po ibility of fine and imprisonment for knowing violations.
Da\l .Fry,enlund
Vice President,Regulatory affairs and Counsel
Denison Mines (USA)Corp.
7
Tab A
Tailings Pond Elevations
1st Quarter 2010
Date Cell 1 Cell 3 Roberts Pond Cell4A
1/8/2010 5613.51 5602.01 5619.76 5582.73
1/1512010 5613.32 5601.30 5620.41 5582.99
1122/2010 5613.56 *562J.I4 *
1128/2010 5613.63 5602.06 5621.53 5583.90
2/5/2010 5613.62 5600.53 5622.21 5584.40
2/1212010 5613.73 560J.I 8 5621.68 5584.50
2/1 912010 5613.74 5601.41 5620.06 5584.55
212612010 5613.39 5603.21 Dry 5584.96
3/512010 5613.39 5602.85 5619.22 5585.37
3/1212010 5613.49 5602.44 5620.98 5585.34
3/1 912010 5613.53 5601.91 5618.64 5585.48
312612010 5613.53 5602.53 5619.02 5585.55
"Unable to access ponds due to adverse weather conditions and safety issues with accessing the
tailings area.
Tab B
Denison MInes (USA)Corp.
1050 17th Streel,Suite 950
Denver,CO 60265
USA
Tel:303 628·7798
Fa,:303 389-4125
www.denlsonmlnes.com
March 3,2010
VIA PDF AND FEDERAL EXPRESS
Dane L.Finerfrock,Co·Executive Secretary
Utah Water Quality Board
Utah Depattment of Environmental Quality
168 NOlth 1950 West
P.O.Box 144810
Salt Lake City,UT 84114-4810
Deal'MI'.Finerfrock:
Rc:Statc of Utah Ground Watcr Discharge Permit No.UGW370004 White Mesa
Uraninm MiIl-Notice Pursuaut to Part I.G.3 ofthe Permit and UAC R317.6.6.16(C)
Please take notice pursuant to Patt I.G.3 of the White Mesa Mill's (the "Mill's")State of Utah
Groundwater Discharge Permit No.UGW370004 (the "Permit")and Utah Administrative Code
("UAC")R3 J3-6-6.16(C)that Denison Mines (USA)Corp.,as operator of the Mill and holder of
the Permit,failed to meet the discharge minimization technology ("DMT")standards in Part
I.D.2 of the Permit,by allowing the wastewater elevation in the Mill's tailings Cell 3 to exceed
the freeboard limit for that Cell by approximately 8.5 inches,as described in more detail below.
This exceedance was discovered at 2:45pm on Friday February 26,2010.Initial notice of this
failure to maintain DMT was given by telephone to the Utah Department of Environmental
Quality ("UDEQ")Duty Officer at 8:30am on Saturday February 27,2010 at 801-536-4123
(within 24 hours of the discovery).
1.Facts and Background Information
a)Condition 10.3 of the Mill's State of Utah Radioactive Materials License No.
UTI 900479 (the "License")provides that freeboard limits for Cells I and 3 shall be set
in accordance with procedures that have been approved by the U.S.Nuclear Regulatory
Commission ("NRC").Under those procedures:
(i)The freeboard limits are set as per the January 10,1990 Drainage Report for Cell
I at a liquid maximum elevation of 5,615.4 feet above mean sea level ("fmsl");
(ii)The freeboard limit for Cell 3 is determined annually using a formula set out in
the procedure.The current freeboard limit for Cell 3 was previously calculated
under this procedure at 5,601.6 fms!.However,in UDEQ correspondence dated
November 20,2008 an interim variance and limit was established at 5,602.5 fmsl
for Cell 3;
(iii)In conjunction with the variance established under (ii)above,an interim
maximum elevation for Ce1l4A was also established at 5,593.74 fmsl;
(iv)The maximum elevation of 5,593,74 fmsl for Cell 4A has been set assuming that
the total probable maximum precipitation ("PMP")volume for Cells 2,3 and 4A
will be accommodated in Cell 4A.By letter dated December II,2008,Denison
applied for an amendment to tJle License to set the freeboard limit for Cell 4A at
5,593.74 fmsl and to eliminate the need to set a freeboard limit for Cell 3,given
that thc freeboard limit of 5,593.74 fmsl for Cell 4A is adequate to accommodate
ilie total PMP volume for Cells 2,3 and 4A;
(v)The spillway between Cell 3 and Cell 4A is in-place and will safely pass any
excess solutions from Cell 3 to Cell 4A due to precipitation events;and
(vi)[n addition,Part I.D.2 of the Permit provides that under no circumstances shall the
freeboard of any tailings cell be less than three feet,as measured from the top of
the flexible membrane liner ("FML").The top of the FML in Cell I is at 5,618.5
fmsl,and the top of the FML in Cell 3 is at 5,608.5 fms!.This means that Part
I.D.2 of the Permit provides a secondary requirement that the maximum
wastewater pool elevations in Cells I and 3 can not exceed 5,615.5 and 5,605,5
fmsl,respectively.
b)During the weekly tailings inspection performed at approximately 2:30pm on February
26,2010,Cell 3 was observed visually to be high in elevation compared to the previous
week.When the elevation survey was performed at 2:45pm on February 26,2010,this
observation was confirmed,The survey was repeated to verify the rcsults of the first
survey.The verified survey results indicated a wastewater pool elevation of 5,603.21
fmsl,compared to the cutTent frceboard limit for Cell 3 of 5,602.5 fmsl,representing
an exceedance of0.71 feet,or 8.52 inches.
OEN[SOJ)
MINES
2
c)It should be noted that the current freeboard limit in Cell 3 of 5,602.5 fmsl is 6 feet
below the top of the FML in Cell 3,so the exceedance of the current freeboard limit by
8.52 inches resulted in a wastewater pool elevation that was still more than five feet
below the top of the FML and more than two feet below the secondary freeboard limit
of 5,605.5 feet set out in Part I.D.2 of the Permit.As a result,there was no risk of the
wastewater in Cell 3 overflowing over the top of the Cell 3 FML.Also,as mentioned
above,since the freeboard limit in Cell 4A has been set to accommodate the PMI'
event for Cells 2,3 and 4A,there was also no risk that even if a PMI'event were to
occur there would not have been adequate freeboard available in Cell 4A.The
wastewater elevation survey for Cell 4A performed on February 26,2010 indicated a
wastewater elevation of 5,584.96 fmsl,well below the freeboard limit of 5,593.74 fmsl
for that Cell.
d)No tailings solutions or solids were being disposed of in Cells I or 3 at the time.All
Mill tailings solutions and solids had been disposed of directly into Ce1l4A for several
months before this incident.
2.Action Taken
Upon receipt of the initial survey results,the Mill's Environmental Coordinator notified the Mill
Manager at 2:50pm that day.The following plan of action was immediately put into place in
accordance with section 5.1 of the Mill's Contingency Plan:
a)The Mill Manager contacted the Mill's maintenance department and had all solutions
that were being discharged into Cell 3 divertcd to Cell 4A or stopped altogetJlcr;
b)Thc Cell 3 transfer pump was then chccked to cnsure that it was discharging Cell 3
solutions into Cell 4A to draw thc solution elevation in Cell 3 back down below the
freeboard limit;
c)The motor on the Cell 3 transfer pump was found to be running,but thc pump was not
pumping.The Mill's maintenancc department fixed the pump and it resumed
pumpmg;
d)This plan was implemented by 3:20pm on Friday February 26,2010;
e)Verbal notification was given to the Executive Secretary at 8:30am on February 27,
2010,within 24 hours of discovery.This verbal notification was followed by this
written notification within five days ofdiscovery;
OENISOJ)
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3
f)Due to inflow of snowmelt directly into Cell 3,the pump from Cell 3 to Ccll 4A has
been struggling to keep up.Water levels have gone down somewhat in Cell 3,but are
not yet at or below the freeboard limit in that Cell;and
g)Mill staff replaced the existing pump in Cell 3 on March 3,20JO,to increase the flow
rate of solutions from Ccll 3 to CeIl4A.
3.Root Cause
The root cause analysis is as follows
a)The Mill area has had unusually high levels of snowfall recently.This has resulted in
water from snowmelt directly entering each ofCell 1 and Cell 3;
b)1n an effort to manage the influx of water into the Mill's tailings system fTom
snowmelt,the Mill had been pumping solutions from Cell I into Cell 3 and from Cell 3
into Ce1l4A;
c)The survey performed on the wastewater elevation in Cell 3 during the previous week
showed the water level in Cell 3 to be more than 13 inches below the freehoard limit.
so there was no concern that the solution level in Cell 3 were close to the freeboard
limit;
d)The remaining pond area in Cell 3 is small,approximately 7 to 10 acres;and
e)Upon review of the circumstances,after the discovery of the exceedance,Mill staff
determined that the transfer pump from Cell 3 into Cell 4A was not operating at full
capacity,and that the transfer pump from Cell 1 to Cell 3 was operating at a
sufficiently higher capacity than the transfer pump from Cell 3 to Cell 4A.This alone
would likely not have caused the levels in Cell 3 to exceed the freeboard limit before
the problem could have been identified.However,the addition of water from
snowmelt directly into Cell 3 was enough to cause a relatively rapid increase in the
solution level in Cell 3,particularly given that the remaining pool area in Cell 3 is
small.These factors all taken together resulted in the rapid increase in the wastewater
elevation in Cell 3 and the exceedance of the freeboard limit in that Cell.
4.Actions That Will be Taken to Prevent a Reoccurrence ofthis Incident
The following actions will be taken to prevent a reoccurrence ofthis incident:
OENISO,.})
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4
a)The Mill will no longer pump any solutions from Cell I into Cell 3 and then from Cell
3 into Cell 4A.Rather,if it is necessary to move solutions from Cell I to Cell 4A,the
solutions will be pumped directly from Cell I to Ce1l4A;and
b)UDEQ is asked to complete its review of Denison's request for License and Permit
amendments to eliminate the freeboard limit in Cell 3,given the ample freeboard limit
set in Cell 4A.In order to accelerate the timing on closure of Cell 3,the Mill plans to
fill up the remaining capacity in Cell 3 with tailings solids begiIUling with the st311 of
conventional ore processing this month,and it is extremely difficult to manage the
freeboard in Cell 3 given the small size of the pond in that Cell.This will get
increasingly more difficult as Cell 3 reaches tailings capacity.
S.Affirmative Defense
Denison believes that the affirmative defense in Part I.G.3.c)of the Permit should be applicable
to this incident,for the following reasons:
a)Notification
By virtue of the initial oral notification given to the UDEQ Duty Officer at 8:30am on
Saturday February 27,2010 (within 24 hours of the discovery)and this written notice,
Denison has submitted notification according to UAC R317-6-6.13.
b)Failure was not Intentional or Caused by the Permittee's Negligence
The exceedance of the freeboard limit was not intentional or caused by Denison's
negligence,either in action or in failure to act.The freeboard limit in the tailings cells
is intended to handle major precipitation events such as the recent heavy snowfall at the
Mill site and the resultant snowmelt.The Mill was taking actions to manage the
freeboard requirements of all of its active tailings cells as a result of the snowmelt.
Based on a survey of the wastewater elevation in Cell 3 taken the previous week,it
appeared that there was ample freeboard in Cell 3,and,based on past Mill experience it
was not unreasonable for Mill staff to come to that conclusion.The fact that the water
level in Cell 3 increased at an unexpectedly fast rate was due in large part to the inflow
of water from snowmelt directly into Cell 3.This was contributed to by a poorly
operating pump from Cell 3 to Cell 4A.These two factors combined to result in a rapid
increase in the solution level in Cell 3 due to the limited amount of pond area in Cell 3.
OENISO,})
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c)The Permittee has Taken Adequate Measures to Meet Permit Conditions
Denison has taken adequate measures to meet Permit conditions in a timely manner.
The provisions of the Mill's Contingency Plan were implemented immediately,and the
wastewater levels are currently being brought back to within the freeboard limits.
Future re-occurrences of this incident will be avoided by pumping solutions directly
from Cell 1 to Cell 4A rather than from Cell 1 to Cell 3 and then from Cell 3 to Cell
4A.
d)The Provisions of UCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated.There has been no
discharge of a pollutant into waters of the state.Denison has not caused pollution
which constitutes a menace to public health and welfare,or is harmful to wildlife,fish
or aquatic life,or impairs domestic,agricultural,industrial,recreational,or other
beneficial uses of water,nor has Denison placed or caused to be placed any waste in a
location where there is probable cause to believe it will cause pollution.
There was no discharge of solutions from the Mill's tailings impoundments,and there
was ample freeboard in Cell 4A to accommodate the PMP for Cells 2,3 and 4A.
Please contact the undersigned if you have any questions or require any further information.
YOU/JUlY,
J4c'tnd
Vice PresIdent,Regulatory Affairs and ounsel
cc:Ron F.Hochstein
Harold R.Roberts
Jo Ann Tischler
David ~.Turk
I>
6
OENISON
MINES
March 31,2010
VIA PDF AND UPS
Dane L.Finerfrock,Co-Executive Secretary
Utah Water Quality Board
Utah Department ofEnvironmental Quality
168 North 1950 West
P.O.Box 144810
Salt Lake City,UT 84114-4810
Dear Mr.Finerfrock:
Denison Mines (USA)Corp.
1060 17th Street,SuIte 950
Denver,eo 60266
USA
rei:303 628·7796
Fax:[phone]
www.denfsonmlnes.com
Re:State of Utah Ground Water Discharge Permit No.UGW370004 White Mesa
Uranium Mill-Notice Pursuant to Part I.G.3 of the Permit and UAC R317.6-6.16(C)
Please take notice pursuant to Part 1.G.3 of the White Mesa Mill's (the "Mill's")State of Utah
Groundwater Discharge Permit No.UGW370004 (the "Permit")and Utah Administrative Code
("UAC")R313-6-6.16(C)that Denison Mines (USA)Corp.,as operator of the Mill and holder of
the Permit,failed to meet the discharge minimization technology ("DMT")standards in Pan
1.D.2 of the Permit.by allowing the wastewater elevation in the Mill's tailings Cell 3 to exceed
the freeboard limit for that Cell by approximately 0.36 inches,as described in more detail below.
This exceedance was discovered at 1O:00am on Friday March 26,2010.Initial notice of this
failure to maintain DMT was given by telephone to the Utah Department of Environmental
Quality Duly Officer at 5:05pm on Friday March 26,2010 at 801-536-4123 (within 24 hours of
the discovery).
1.Facts and Background Information
a)Condition 10.3 of the Mill's State of Utah Radioactive Materials License No.
UT1900479 (the "License")provides that freeboard limits for Cells 1 and 3 shall be set
in accordance with procedures that have been approved by the U.S.Nuclear Regulatory
Commission ("NRC").Under those procedures:
(i)The freeboard limits are set as per the January 10,1990 Drainage Report for Cell
1 at a liquid maximum elevation of 5,615.4 feet above mean sea level ("fmsl");
(ii)The freeboard limit for Cell 3 is determined annually using a formula set out in
the procedure.The current freehoard limit for Cell 3 was previously calculated
under this procedure at 5,601.6 fms!.However,in State of Utah Department of
Environmental Quality ("UDEQ")correspondence dated November 20,2008 an
interim variance and limit was established at 5,602.5 fms!for Cell 3;
(iii)In conjunction with the variance estahlished under (ii)above,an interim
maximum elevation for Ce1l4A was also established at 5,593.74 fmsl;
(iv)The maximum elevation of 5,593.74 fmsl for Cell 4A has been set assuming that
the total probable maximum precipitation ("PMP")volume for Cells 2,3 and 4A
will be accommodated in Cell 4A.By letter dated December 11,2008,Denison
applied for an amendment to the License to set the fTeeboard limit for Cell 4A at
5,593.74 fmsl and to eliminate the need to set a freeboard limit for Cell 3,given
that the freeboard limit of 5,593.74 fmsl for Ce1l4A is adequate to accommodate
the total PMP volume for Cells 2,3 and 4A;and
(v)In addition,Part 1.D.2 ofthe Permit provides that under no circumstances shall the
freeboard of any tailings cell be less than three feet,as measured from the top of
the flexible membrane liner ("FML").The top ofthe FML in Celli is at 5,618.5
fmsl,and the top of the FML in Cell 3 is at 5,608.5 fms!.This means that Part
1.0.2 of the Permit provides a secondary requirement that the maximum
wastewater pool elevations in Cells I and 3 cannot exceed 5,615.5 and 5,605.5
fmsl,respectively.
b}During the weekly tailings inspection performed at approximately 10:OOam on March
26,2010,Cell 3 was observed visually to be high in elevation compared to the previous
week.When the elevation survey was performed at 1O:15am on March 26,2010,this
observation was confirmed.The survey results indicated a wastewater pool elevation
of 5,602.53 fmsl,compared to the current freeboard limit for Cell 3 of 5,602.50 fmsl,
representing an exceedance of 0.03 feet,or 0.36 inches.
c}It should be noted that the current freeboard limit in Cell 3 of 5,602.5 fmsl is 6 feet
below the top of the FML in Cell 3,so the exceedance of the current freeboard limit by
0.36 inches resulted in a wastewater pool elevation that was still over five feet below
the top of the FML and over two feet below the secondary freeboard limit of 5,605.5
feet set out in Part I.D.2 ofthe Permit.As a result,there was no risk of the wastewater
OENISOJ)~~
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in Cell 3 overflowing over the top of the Cell 3 FML.Also,as mentioned above,since
the freeboard limit in Cell 4A has been set to accommodate the PMP event for Cells 2,
3,and 4A,there was also no risk that even if a PMP event were to occur there would
not have been adequate freeboard available in Cell 4A.The wastewater elevation
survey for Cell 4A performed on March 26,20I 0 indicated a wastewater elevation 117
inches (9.75 feet)below the freeboard limit of 5,593.74 fms!for CeIl4A.
d)During the weekly tailings inspection on March 12,2010,the liquid level in Cell 3 was
at least I inch below the freeboard limit for that cell.As part of the plan to fill Cell 3
with tailings solids and to close Cell 3,the Mill has been pumping Cell 3 liquids into
Cell 4.In anticipation of the upcoming ore LUn,the Mill continued to pump the liquids
from Cell 3 into Cell4A and ceased all discharges of tailings solutions into Cell 3.
e)The Mill restarted on March 15,2010.
f)By the time of the weekly tailings inspection on March 19,2010,Cell 3 liquids had
been pumped to Cell 4A for over a month,and the Cell 3 liquid level was at least 7
inches below the freeboard limit.
g)Discharge of CCD solids to Cell 3 started on March 23,2010.The intention was to
discharge tailings solids into Cell 3 at a rate that,given the rate solutions were being
pumped from Cell 3 to Cell 4A,would not result in an exceedence of the freeboard
limit in Cell 3.Mill staff had replaced the existing pump in Cell 3 to increase the flow
rate of solutions from Cell 3 to Cell 4A.The new pump was in operation up until the
morning of the exceedence.
h)Cell 3 was receiving only CCD solids and solutions from the Cell 2 slimes drain,and
Ce1l4A was receiving all other tailings liquids,at the time of the exceedence.
2.Action Taken
Upon receipt of the initial survey results,the Mill's Environmental Coordinator notified the Mill
Manager at 10:30am that day.The following plan of action was immediately put into place in
accordance with section 5.1 ofthe Mill's Contingency Plan:
a)The Mill Manager had operations crews stop the discharge of CCD solids into Cell 3;
b)The Mill Manager had the Maintenance Department confirm that the transfer pump
from Cell 3 to Cell 4A was operational,although it has lost its prime and was not
operating at the time;
OENISOJ)~~
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3
c)This plan was implemented by I 1:00am on Friday March 26,2010;
d)Verbal notification was given to the Executive Secretary at 5:05pm on March 26,2010,
within 24 hours of discovery.This verbal notification was followed by this written
notification within five days ofdiscovery;
e)Solutions continued to be pumped from Cell 3 to Cell 4A in order to reduce the
solution in Cell 3;and
f)Compliance was achieved on March 30,2010,when a survey of Cell 3 indicated a
solution elevation of 560 1.91 fms!.
3.Root Cause
The root cause analysis is as follows
a)In an effort to prepare Cell 3 for closure,the Mill has been transfen'ing fTee liquids
from Cell 3 to Cell 4A for over a month.As a result of the liquid transfer,by March
19,2010,the Mill had succeeded in achieving a liquid level in Cell 3 that was 7 inches
lower than the freeboard limit,so there was no concern that solution levels in Cell 3
were close to the freeboard limit.
b)The Mill restarted on March 15,2010.Discharge of CCD solids to Cell 3 started on
March 23,2010.Cell 3 was receiving only CCD solids,and Cell 4A was receiving all
tailings liquids at the time of the exceedence.Solutions continued to be pumped from
Cell 3 to Cell 4A as solids were being introduced into Cell 3,in an effort to maintain
the solution level in Cell 3 below the freeboard limit during this process.
c)As a result offollowing the plaIlIled program of filling Cell 3 for closure,the remaining
pond area in Cell 3 is small,approximately 7 to 10 acres,and is continually being
reduced by the plaIlIled expansion of the solids beach as Cell 3 approaches its final
tailings capacity.
d)As a result of the ever-decreasing pond area,the ability to manage the freeboard level
has become increasingly difficult.
e)Upon review of the circumstances,after the discovery of the exceedance,it has become
obvious that it may no longer be possible to manage the Cell 3 freeboard to achieve the
PENISOJ)A
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4
calculated freeboard limit during the final stages of filling Cell 3 with solids and
closing Cell 3.The exceedence occurred despite the fact that monitoring and surveying
were performed at the required frequency,all pumping equipment was operating
properly,and the liquid transfer from Cell 3 to Cell 4A was occurring as planned.
4.Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a)The Mill will continue to pump liquids from Cell 3 to Cell 4A,in preparation for
dewatering and closure of Cell 3;
b)UDEQ is asked to complete its review of Denison's request for License and Permit
amendments to eliminate the freeboard limit in Cell 3.given the ample freeboard limit
set in Ce1l4A.
c)Denison will apply for an interim variance to eliminate the freeboard requirement in
Cell 3 pending UDEQ's review of the foregoing license and permit amendment
requests,on the basis that the freeboard limit in Cell 4A has been set to accommodate
the PMP event for Cells 2,3,and 4A.
5.Affirmative Defense
Denison believes that the affirmative defense in Part I.G.3.c)of the Permit should be applicable
to this incident,for the following reasons:
a)Notification
By virtue of the initial oral notification given to the UDEQ Duty Officer at 5:05pm on Friday
March 26,2010 (within 24 hours of the discovery)and this written notice,Denison has
submitted notification according to UAC R317-6-6.13.
b)Failure was not Intentional or Caused by the Permittee's Negligence
The exceedance of the freeboard limit was not intentional or caused by Denison's negligence,
either in action or in failure to act.The Mill was taking actions to manage the freeboard
requirements of all of its active tailings cells while filling Cell 3 to its final tailings solids
capacity in preparation for closure.Based on a survey of the wastewater elevation in Cell 3 taken
the previous week,it appeared that there was ample freeboard in Cell 3,and,based on past Mill
experience it was not unreasonable for Mill staff to come to that conclusion.The fact that the
OENISOJ)~~
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5
water level in Cell 3 increased at an unexpectedly fast rate was due to the planned discharge of
CCD solids into Cell 3 coupled with the issue of managing liquids in a pool of ever-decreasing
size as the solids fill the cell.This discharge,and the pool's size reduction,are necessary to
complete the filling and closure of the Cell.
c)The Pennittee has Taken Adequate Measures to Meet Permit Conditions
Denison has taken adequate measures to meet Permit conditions in a timely manner.The
provisions of the Mill's Contingency Plan were implemented immediately,and the wastewater
levels have been brought back to within the freeboard limits.
d)The Provisions ofUCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated.There has been no discharge of a
pollutant into waters of the state.Denison has not caused pollution which constitutes a menace
to public health and welfare,or is harmful to wildlife,fish or aquatic life,or impairs domestic,
agricultural,industrial,recreational,or other beneficial uses of water,nor has Denison placed or
caused to be placed any waste in a location where there is probable cause to believe it will cause
.pollution.
There was no discharge of solutions from the Mill's tailings impoundments,and there was ample
freeboard in Cell4A to accommodate the PMP for Cells 2,3,and 4A.
Please contact the undersigned if you have any questions or require allY further infonnation.
Yours truly,
9'~~
J0 Aml Tischler
Director,Compliance and Permitting
cc:David C,Frydenlund
Ron F.Hochstein
Ryan Palmer
Harold R.Roberts
David E.Turk
OENISOJ)A~
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6
Tab C
Location:
~:::,::~::=r::~~~:..;..~
Slimes Cell 1*2
3/8/2010
600
700
800
900
1000
1100 23,73
1200 23.21
1300 22.53
1400 21.80
1500 21.31
1600
Date:3/15/2010
Sanrpler:Tanner Holliday
r;;l="'~~~J=====....=v-.........._...=~,....~='=""
Ryan Palmer
3/9/2010 3/10/2010 3/11/2010 3/12/2010 3/14/2010 3/15/2010
~=1:::==n='t"""-=C "'====.......,>-orne
16.47 14.09 13.07 12.46 11.04
=-16.31 14.06 13.07 12.46 11.04===-~=""=-==16.15 14.03 13.07 12.46 11.04
16.00 13.97 13.05 12.43.............:
15.79 13.90 13.03 12.40
="'"
15.76 13.82 13.00 12.35
=-«
15.64 13.75 12.97 12.30
15.52 13.68 12.93 12.26
15.34 13.61 12.89 12.23
11.09
11.04
Comments:Three consecutive readings was obtained earlier in the week but the 90 hrs
flad not been reached,The pump remained off during the weekend,one reading was
taken on Sunday the 14th at 1730 hrs.Monday Morning we achieved three consecutive
";adings once again and by this time the 90 hr requirement was also meet.The reading
-;.t this time was 11.04 which will be the reporting number for this recovery test.--------------
Location:
Slimes Cell #:2
Date:2/21/2010
===
Sampler:Tanner Holliday
~~~=-
Ryan Palmer
~--===a:'"=':'=~=:-r-'-l=---~
2/15/2010 2/16/2010 2/17/2010 2/18/2010 2/19/2010 2/20/2010 2/21/2010
600 =:::.==-,._,-=:~-=-=.....",.~~~r.
700 17.55 15.47 14A 13.66 :1.3.05
~"'~r~=
800 17.42 15,44 14.38 13.65 13.04
:=n"""'fri'r c ==-=,-
900 24.34 17.31 15.4 14.34 13.63 13.02
...--r""""'"7rn e'
1000 23.91 17.2 15.35 14.3 13.61====0 .....~
1100 23.32 17.08 15.31 14.27 13.58---.~............-.;
1200 22.66 16.95 15.25 14.22 13.56
=-==0=.mtt'I~~~-====1300 22.06 16.81 15.19 14.18 13.54 12.5
~'=0
1400 21.65 16.7 15.12 14.15 13.48 12.5
1500 21.12 16.59 15.05 14.08 13.43 12.5
1600
12.5
Comments:The report number is 12.5 it took longer than usual to stablize I don't
know if the weather had anything to do with this or not?
f""·rt U P,[,V~3.0•0,.1[1....
Location:Date::1./15/2010====~""-~
Slimes Cell f:!:2
===~~,
Sampler;Tanner Hollidav
..........e==~.
Ryan Palmer
=~t=~=
1/11/2010 1/12/2010 1/13/2010 1/14/2010 1/15/2010-~--;.~--
600
~
700 24,75 17.53 15.41 14.42 13.96
800 24.05 17,4 15.39 14.4 13.96-
900 23.37 17.28 15.35 14·.39 13.96
='
1000 22.72 17.16 15.29 14.37 13.96
"
1100 22.23 17.03 15.25 14.35
=
1200 21.71 16.92 15.19 14.34=-1300 21.24 16.79 15.12 14.3
'"1400 20.87 16.65 15.03 14.26
1500 20.55 16.52 14.94 14.24
1600
13.96
Comments:The Reporting number is 13.96
Tab 0
0
2
ClIDo 4°ii
~c
III 6....II)-0
Do 8
~=:0 10
ClIa:l....ClI 12
ClIu..
14
16
r\
.L \A ~~V \.::-...
\./~.
~Reported Final Depth to Stable Water level
-linear (Reported Final Depth to Stable Water Level)
Cell 2 Slimes Drain -2009 &2010
Tab E
CELL 4A LEAK DETECTION SYSTEM
1ST QUARTER 2010
(Measurements in inches represent inches above the leak detection system transducer)
January 2010
Date
IIS120IO
III51201 0
II22/2010
112912010
Measurements in Inches
5.0
4.4
*
5.5
Flow Meter in Gallons
253955
253955
*
253955
Highest level for the month was 5.5 inches.Total number of gallons pumped was zero.
February 2010
Date
2/5120IO
2/12/2010
211912010
2126/2010
Measurements in Inches
7.S
11.6
12.1
12.7
Flow Meter in Gallons
253955
253955
253955
253955
Highest level for the month was 12.7 inches.Total number of gallons pumped was zero.
March 2010
Date
3/512010
3/12/2010
3/1912010
3126110
Measurements in Inches
11.5
5.1
6.9
7.1
Flow Meter in Gallons
253955
257250
257250
257250
Highest level for the month was 11.5 inches.Total number of gallons pumped was 3,295.
*Unable to access ponds due to adverse weather conditions and safety issues with accessing the
tailings area.