DRC-2011-003833 - 0901a0688021e1d3

DENISO
MINES
3
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
January 28, 2011
VIA 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 Division of Radiation Control ("DRC") Reclamation Plan Revision 3.2 - Final,
Utah Radioactive Materials License UT1900479
Dear Mr. Lundberg:
Enclosed please find one copy of the White Mesa Uranium Mill Reclamation Plan Revision 3.2 - Final,
as well as one CD containing a word searchable electronic copy of the plan.
If you should have any questions regarding this plan please contact me.
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
Central files
N:\Reclamation Plan\Reclamatlon Plan Rev 3.2 -final\01.28.11 Transmittal to DRC Rec Plan rev 3.2-final.doc
OENISOJ)~~
MINES
January 28, 2011
VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: State of Utah Division of Radiation Control ("DRC") Reclamation Plan Revision 3.2 -Final,
Utah Radioactive Materials License UT1900479
Dear Mr. Lundberg:
Enclosed please find one copy of the White Mesa Uranium Mill Reclamation Plan Revision 3.2 -Final,
as well as one CD containing a word searchable electronic copy of the plan.
If you should have any questions regarding this plan please contact me.
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
Central files
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\01.2B.11 Transmittal to DRe Rec Plan rev 3.2-final.doc
OENISOJ)~~ Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
MINES Tel: 303 628·7798
Fax : [phone]
www.denlsonmines.com
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
Addendum/Changed Pages
for the
White Mesa Mill and
Tailings Management System
January 2011
State of Utah 11 e.(2) Byproduct Material License # UT1900479
Revision 3.2 -Final constitutes an Addendum to
Approved Revision 3.0 and 3. 1 of the White Mesa Mill Reclamation Plan
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: 303628·7798
Fax: [phone]
PREFACE
This document contains Revision 3.2 -Final, an Addendum to the White Mesa Mill Reclamation Plan
Rev. 3.0 and 3.1. The White Mesa Mill Reclamation Plan Revision 3.2 -Final does the following:
• Completely replaces the content of Rev. 3.1, by replacing Figures A-S.1-1, A-S.1-2 and A-S.1-3
of Rev. 3.1, which was the entire content of Rev. 3.1.
• For Rev. 3.0, replaces with revised documents the text, figures, tables, appendices, and
attachments included under this cover that correspond to the same items in existing Revision 3.0.
• Adds the new documents under this cover to the Reclamation Plan.
• Maintains the remaining balance of the contents of Approved Revision 3.0,
The contents of this Addendum, When combined with the existing approved Revision 3.0/3.1 as described
above, constitute the complete current version of the White Mesa Mill Reclamation Plan.
TABLE OF CONTENTS
UST OFTABLES
LIST OF FIGURES
Pagei
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Page No.
LIST OF ATIACHMENTS
LIST OF APPENDICES
REFERENCES
INTRODUCTION .......................................................................................................................................................................................................... 1-1
1.0 SITE CHARACTERISTICS
1.1 CLIMATE ...................................................................................................................................................................................... 1-5
1.1.1 General Influences ................................................................................................................................................ 1-5
1.1.2 Precipitation ............................................................................................................................................................. 1-6
1.1.3 Winds ........................................................................................................................................................................ 1-6
1.1.4 Storms ....................................................................................................................................................................... 1-6
1.2 TOPOGRAPHy ....................................................................................................................................................................... 1-10
1.3 ARCHEOLOGICAL RESOURCES ........................................................................................................................................ 1-10
1.3.1 Archeological Sites ............................................................................................................................................. 1-10
1.3.2 Current Status of Excavation ........................................................................................................................... 1-13
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1.4 SURFACE WATER .................................................................................................................................................................. 1-14
1.4.1 Surface Water Description ............................................................................................................................... 1-14
1.4.2 Surface Water Quality ....................................................................................................................................... 1-19
1.5 GROUNDWATER .................................................................................................................................................................. 1-23
'1.5.1 Site Description ................................................................................................................................................... 1-26
1.5.2 Ge.ologic Setting .................................................................................................................................................. 1-26
1.5.2.1 Stratigraphy ....................................................................................................................................... 1·28
1.5.2.2 Local Geologic StrucLUre ................................................................................................................ 1-28
1.5.3 Hydrogeologic 5etting ............. __ ...................................................................................................................... 1-30
1.5.3.1 Hydrosrratigraphy ........................................................................................................................... 1-36
1.5.3.2 Data Collected In 1994 ................................................................................................................... 1-47
1.5.4 Climatological Setting ....................................................................................................................................... 1-54
1.5.5 Perched Ground Water Cha.racrerisrics ........................................................................................................ 1·54
1.5.5.1 Perched Water Quality ................................................................................................................... 1·60
1.6 GEOLOGy ................................................................................................................................................................................ 1-62
1.6.1 Regional Geology ............................................................................................................................................... 1-63
1.6.1.1 PhYSiography .................................................................................................................................... 1-63
1.6.1.2 Rock Units .......................................................................................................................................... 1-64
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White Mesa Mill Reclamation plan
1.6.1.3 Structure and Tectonics ........... " ........................................................................ " .......................... 1-73
1.6.2 Blanding Site Geology ....................................................................................................................................... 1-78
1.6.2.1
1.6.2.2
1.6.2.3
1.6.2.4
1.6.2.5
Physiography and Topography; ................................................................................................... 1-78
Rock Units .......................................................................................................................................... 1-81
Structu re ............................................................................................................................................. 1-86
Relationship of Earthquakes to Tectonic Structures .............................................................. 1-90
Potential Earthquake Hazards to Project ................................................................................... 1-96
1.6.3 Seismic Risk Assessment ... ~ ............................................................................................................................ 1-98
1.6.3.1 Static Analysis ..................................................... " .. " ........................................................................ 1-99
1.6.3.2 Pseudosraric Analysis (Seismicity) .......................... """"""""""" ...... " ........................ " ............ 1-99
1.7 BIOTA ....................................................................................................................... " ............................................................ 1-100
1.7.1 Terrestrial ...................................................................................................................................................... " .... 1-100
1.7.1.1 Flora ....................................................................................................................................................... 1-100
1.7.1.2 Fauna ..................................................................................................................................................... 1-105
1.7.2 AquatiC Biota ...................................................................................................................................................... 1-107
1.8 NATURAL RADIATION ...................................................................................................................................................... 1-112
1.8.1 Background ........................................................................................................................................................ 1-112
1.8.2 Current Monitoring Data ............................................................................................................................... 1-113
1.8.2.1 Environmental Radon ....................................................................................................................... 1-113
1.8.2.2 Environmental Gamma ..................................................................................................................... 1-114
1.8.2.3 Vegeta tion Samples ....................................................................................................................... 1-114
1.8.2.4 Environmental Air Monitoringand Stack Sampling ............................................................ 1-114
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
1.8.2.5 Groundwater ................................................................................................................................... 1-115
1.8.2.6 Surface Water ................................................................................................................................. 1-116
1.8.2.7 Meteorological Monitoring ......................................................................................................... 1-116
2.0 EXISTING FACILITY
2.1 FACILITY CONSTRUCTION HiSTORy ................................................................................................................................ 2-1
2.1.1 Mill and Tailings Management Facility ........................................................................................................... 2-2
2.2 FACILITY OPERATIONS .......................................................................................................................................... _ .............. 2-3
2.2.1 Operating Periods ................................................................................................................................................. 2-3
2.2.2 Mill Circuit ............................................................................................................................................................... 2-4
2.2.3 Tailings Management Facilities ......................................................................................................................... 2-5
2.2.3.1 Tailings Managemenr ........................................................................................................................ 2-7
2.2.3.2 Liquid Management ....................... , ................................................................................................... 2-8
2.3 MONITORING PROGRAMS ............................................................... , .................................................................................... 2-9
2.3.1 Monitoring and Reporring Under the Mill's GWDP .................................................................................... 2-9
2.3.1.1
2.3.1.2
2.3.1.3
2.3.1.4
2.3.1.5
2.3.1.6
2.3.1 .7
Groundwater Monitoring ...................................................................................................... 2-9
Deep Aquifer ........................................................................................................................... 2-13
Seeps and Springs .................................................................................................................. 2-13
Discharge Minimization Technology and Best Available Technology
Standards and Moniloring ................................................................................................... 2-14
2.3.1 .4.1 General ..................................................................................................... 2-14
BAT Performance Standards for Cell 4A ......................................................................... 2-19
5tarmwater Management and Spill Control Requirements ...................................... 2-21
Tailings and Slimes Drain Sampl1ng ................................................................................. 2-22
2.3.2 Monitoring and Inspections Required Under the License ...................................................................... 2-23
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2.3.2.1
2.3.2.2
3.0 RECLAMATION PLAN
Page v
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Environmental Monitoring ..................................................................... "' .. ", .................... 2-23
Additional Monitoring and Inspections Required Under the License .................... 2-31
3.1 LOCATION AND PROPERTY DESCRIPTION ................................................................................................................... 3-1
3.2 FACILITIES TO Bf RECLAIMED ............................................................................................................................................. 3-4
3.2.1 Summary of Facilities to be Reclaimed ............................................................................................................ 3-4
3.2.2 Tailings and Evaporative Cells ............................................................................................................................. 3-7
3.2.21 Soil (over Design ................................................................................................................................ 3-7
3.2.2.2 Cell 1-1 .................................................................................................................................................... 3-9
3.2.2 .. 3 Cell 2 ........................................................................... " ....................................................................... 3-10
3.2.2.4 Cell 3, ................................................................................................................................................... 3-11
3.2.2.5 CeI14A .................................................................................................................................................. 3-11
3.2.2.6 Cell 4B ................................................................................................................................................ 3-11
3.2.3 Mill Decommissioning ...................................................................................................................................... 3-11
3.2.3.1 Mill Building and Equipmenr, and Other 11e.(2) Byproducr Material ............................. 3-11
3.2.3.2 Mill Site .................................................................................................................................................. 3-14
3.3 DESIGN CRJTERIA ................................................................................................................................................................. 3-14
3.3.1 Regulatory Criteria ............................................................................................................................................. 3-15
3.3.2 Radon Flux Attenuation .................................................................................................................................... 3-16
3.3.2.1 Predictive Analysis ........................................................................................................................... 3-17
3,3.2.2 Empirical Data .................................................................................................................................. 3-18
3.3.3 Infiltration Analysis ............................................................................................................................................ 3-19
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Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
3.3.4 Freeze/Thaw Evaluation ................................................................................................................................... 3-21
3.3.5 Soil Cover Erosion Protec:tion .......................................................................................................................... 3-22
3.3.6 Slope STabiliry Analysis ..................................................................................................................................... 3-24
3.3.6.1 Slatic Analysis ................................................................................................................................... 3-25
3.3.6.2 Pseudosratic Analysis (Seismiciry) .............................................................................................. 3-25
3.3.7 Soil Cover -Animallnrrusion ........................................................................................................................... 3-26
3.3.8 Cover Material/Cover Material Volumes ..................................................................................................... 3-26
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TABLE1 .1-·)
TABLE 1.1-2
TABLE 1.3-1
TABLE 1 -4-1
TABLE 1.5-1
USTOFTABLES
Revision 3.2 -Fi nal
Denison Mines (USA) (orp.
White Mesa Mill Reclamation plan
Page No.
Temperature Means and Extremes at Blanding, Utah ................................................................................. 1-8
(Table 2.1.1 Dames & Moore -final ES)
Precipitation Means and Extremes at Blanding, Utah ................................................................................. 1-9
(Table 2.1-2 Dames & Moore -Final ES)
Distribution of Recorded Sites According .................................................................................................... 1-12
to Temporal Position
(Table 2.3-2 Dames & Moore -Final ES)
Drainage Areas of Project Vicinity and Region ........................................................................................... 1-18
(Table 2.6-3 Dames & Moore -Final ES)
Wells Located Within a 5-Mile Radius of the
White Mesa Uranium Mill ...................................................................................................................... 1-33
(Table 1.1 Titan)
TABLE 1.5.3.1-1 Properties of the Dakota/Burro (anyon Formations,
White Mesa Uranium Mi" ...................................................................................................................... 1-39
(Table 2.1 Titan)
TABLE·I.5.3.1-2 Summary of Hydraulic Propenies, White Mesa
Uranium Mil, .............................................................................................................................................. 1-40
(Table 2.2 Titan)
TABLE"1.5.3.2-1 Summary of Borehole Tests, 1994 Drilling Program,
White Mesa Project, San Juan (ounty, Utah ...................................................................................... 1-52
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Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Miff Reclamation Plan
TABLE 1.5.3.2-2 Results of Laboratory Tests ................................................................................................................................................. 1-53
TABLE 1.5.5-1 Monitoring Well and Ground Water Elevation Data,
White Mesa. Uranium Mill................................................................................................................... 1-59
(Table 2.3 Titan)
TABLE 1.6-1 Generalized Stratigraphic Section of Subsurface Rocks
Based on Oil·Well Logs ........................................................................................................................ 1-69
(Table 2.6-1 UMETCO)
TABLE 1.6·2 Generalized Stratigraphic Section of Exposed Rocks
in the Project Vicinity ............................................................................................................................ 1-70
(Table 2.6-2 UMETCO)
TABLE 1.6·3 Modified Mercalli Scale, 1956 Version ..................................................................................................... 1-89
(Table 2.6-3 UMETCO)
TABLE 1.7-1 Community Types and Expanse Within the
Praject Site Boundary ............................................................................................................................. 1-104
(Table 2.7-1 UMETCO)
TABLE 1.7-2 GroUl,d Cover for Each community Within [he
Project Site Boundary .......................................................................................................................... 1-104
TABLE 1.7-3 Birds Observed in th e Vicinity of the White Mesa
Project ..................................................................................................................................................... 1-107
(Tab le 2.7-3 UMETCO)
TABLE 1.7-4 Threatened and Endangered Aquatic Species
Occurring in Utah ................................................................................................................................. 1-111
(Table 2.7-4UMETCO)
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TABLE 2.3-1
TABLE 2.3-2
Table 3.3-1
TABLE 5.3.2.1-1
TABLE B-1
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Groundwater Monitoring ConstilUents listed in Table 2 of the GWDP ......................................... 2-11
Operational Phase Surface Water Monitoring Program ....... . . ............. 2-33
Average Radon Flux from Tailings Cells 2004-200B .......................................................................... 3-19
Placement and Compaction Crileria Reclamalion
Cover Materials ............................................................................................................................. Page A-24
Re<Juired Repofts ....................................................................................................................................................... Page B-14
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FIGURe1-1
FIGURE 1-2
FIGURE 1.4-1
FIGURE 1.4-2
FIGURE 1.4-3
FIGURE 1.5.1
FIGURE 1.5-2
FIGURE 1.5-3
LIST OF FIGURES
Page viii
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Page No.
While MesaMll1 Regional Location Map .......................................................................................................................... 1-3
White Mesa Mill Location Map ............................................................................................................................................ 1-4
Drainage Map of the Vicinity of the White Mesa Project ........................................................................................... 1-17
(Adapted from Dames & Moore (1978b), Plate 2.6-5)
Streamflow Summary in the 8landing. Utah Vicinity .................................................................................................. 1-21
(Adapted from Dames &Moore (1978b). plate 2.6-6)
Preoperational Water Quality Sampling Stations
in the White Mesa Project Vicinity .............................................................................................. 1-21
(Adapted from Dames & Moore (1978b). Plate 2.6-10)
Colorado Plateau GeologiC Map ....................................................................................................................................... 1-27
(Titan Figure 1.1)
ApprOXimate E.levation of Top of Brushy Basin ............................................................................................................ 1-29
(Titan Figure 1.2)
Ground Water Appropriation Applications Within a
5-Mile Radius .................................................................................................................................... 1-32
(Titan Figure 1.3)
FIGURE. 1.5.3.1-1 Site Plan Map (ShOWing Cross Sections) ........................................................................................................................ 1-45
(Titan Figure 2.1)
FIGURE 1.5.3.1-2 Cross Section A-A' West to East Through White Mesa
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Westwater Creek [0 Corral Canyon ............................................................................................ 1-48
(Titan Figure 2.2)
FIGURE 1.5.3.1-3 Cross Section B-B' North to South Through White Mesa
North of Facility to Cottonwood Wash ...................................................................................... 1-49
FIGURE 1.5.5-1 Perched Ground Water Levels ........................................................................................................................................... 1-56
(Titan Figure 2.4)
FIGURE 1.5.5-2 Saturated Thickness of Perched Water......................................................................................................................... 1-57
(Titan Rgure 2.5)
FIGURE 1.5.5-3 Topography of Brushy Basin ................................................................................................................................................ 1-58
(Titan Figure 2.6)
FIGURE 1.6-1 Tectonic Index Map ........................................................................................................................................................... 1-6B
FIGURE 1.6-2 White Mesa Mil/site-Geology of Surrounding Area .................................................................................................... 1-80
FIGURE 1.6-3 Seismicity 320km Around Blanding, Utah .................................................................................................................. 1-91
FIGURE 1.6-4 Seismicity 200km Around Blanding, Utah ..................................................................................................................... 1-92
FIGURE 1.6-5 Seismicity of the Westem United States, 1950 [0 1979 ............................................................................................. 1-93
FIGURE 1.6-6 Colorado UneamenL.......................................................................................................................................................... 1-97
FIGURE 1.7-1 CommuniryTypes on the White Mesa Project Site ................................................................................................... 1-103
FIGURE 2.3-1 High Volume Air Monitoring Stations ........................................................................................................................... 2-25
FIGURU.1-1 White Mesa Mill Regional Map Showing Land Position ............................................................................................... 3-3
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FIGURE3.2-1
FIGURE 3.2.3-1
White Mesa Mill General layout Showing Access and
Page x
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation plan
Restricted Area Boundary ................................................................................................................. 3-6
Site Map locations of Buildings and Tankage .............................................................................................................. 3-13
FIGUREA-2.2.4-1 Sedimentation Basin Detail ................................................................................................................................................... A-7
FIGURE A-3.2-1 Mill Sire and Ore Pad Final Grading Plan ....................................................................................................................... A-12
FIGURE A-3.3·1 Typical Scanning Path Scoping Survey ............................................................................................................................ A-18
FIGURE A-3.3-2 Standard Sampling Pattern for Systematic Grid Survey ofSoil ................................................................................ A-19
FIGURE A-S.·1-1 Reclamation Cover Grading plan ...................................................................................................................................... A-24
FIGURE A-S.1-2 Reclamation Cover Details and Cross Secrion .............................................................................................................. A-2S
FIGURE A·S.1-3 Reclamarion Cover and Cross Secrions ........................................................................................................................... A-26
FIGURE A-S.1-4 Rock Apron ar Base of Toe of Cell OUlslopes ................................................................................................................ A-27
FIGURE B-1 Typical Flow Charrfor Consrrucrion Projecr.. ................................................................................................................ B-22
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REFERENCES
Pagei
Revision 3.2 -Final
Denison Mines (USA) Corp ..
White Mesa Mill Reclamation Plan
Abt, S. R., 1987. Engineering and Design of Waste Disposal Systems, Mini-course No.7: Riprap Design for Reclamation.
Abt, S.R., J.F., and Wittler., 199. Estimating Flow Through Riprap, Journal of Hydraulic Engineering, v. 117, no 5, pp. 670-675,
May. Advanced Terra Testing, 1996. (Cited in 3.3.2.1)
Agenbroad, L. D. et. aI., 1981. 1980 Excavations in White Mesa, San Juan County, Utah. (Cited in 1.3.2)
Aitken and Berg, 1968. (Cited in 3.3.4)
Aki, K., 1979. Characterization of Barriers on an Earthquake Fault, Journal of Geophysical Research, v. 84, pp. 6140-6148.
(Cited in 1.6.3.3)
Algermissen, S. T. and Perkins, D. M., 1976. A Probabilistic Estimate of Maximum Acceleration on Rock in the Contiguous
United States, U. S. Geological Survey Open-File Report, No. 76-416. (Cited in 1.6.3.4)
Anderson, L. W. and Miller, D. G., 1979. Quarternary Fault Map of Utah, FURGO, Inc.
Arabasz, W. J., Smith, R. B., and Richins, W. D., eds., 1979. Earthquake Studies in Utah 1850 to 1978, Special Publication of the
University of Utah Seismograph Stations, Department of Geology and Geophysics.
Bonilla, M. G., Mark, R. K., and Lienkaemper, J. J., 1984. Statistical Relations Among Earthquake Magnitude, Surface Rupture
Length, and Surface Fault Displacement, Bulletin of the Seismological Society of America, v. 74, No.6, pp. 2379-2411.
Brill, K. G. and Nuttli, O. W., 1983. Seismicity of the Colorado Lineament, Geology, v. 11, pp. 20-24. (Cited in 1.6.3.3)
Case, J. E. and Joesting, H. R., 1972. Regional Geophysical Investigations in the Central Plateau, U. S. Geological Survey
Professional Paper 736. (Cited in 1.6.3.3)
Casjens, L. A. et. aI., 1980. Archeological Excavations on White Mesa, San Juan County, Utah, 1979; Volumes I through IV;
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
June, 1980. {Cited in 1.3.2}
Page ii
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Denison Mines {USA} Corp ..
White Mesa Mill Reclamation plan
Cater, F. W., 1970. Geology of the Salt Anticline Region in Southwestern Colorado, U. S. Geological Survey, Professional Paper
637. {Cited in 1.6.3.3}
Chen and Associates, Inc., 1978. Soil Property Study, Earth Lined Tailings Retention Cells, White Mesa Uranium Project,
Blanding, Utah.
Chen and Associates, Inc., 1979. Soil Property Study, Proposed Tailings Retention Cells, White Mesa Uranium Project,
Blanding, Utah.
Chen and Associates, Inc., 1987. {Cited in 3.3.2.1, 3.3.6}
Cook, K. L. and Smith, R. B., 1967. Seismicity in Utah, 1850 Through June 1965, Bull. Seism. Soc. Am., v. 57, pp. 689-718.
{Cited in 1.6.3.3}
Coulter, H. W., Waldron, H. H., and Devine, J. F., 1973. Seismic and Geologic Siting Considerations for Nuclear Facilities,
Proceedings, Fifth World Conference on Earthquake Engineering, Rome, Paper 302. {Cited in 1.6.3.4}
Craig, L. c., et. aI., 1955. Stratigraphy of the Morrison and Related Formations, Colorado plateau Region, a Preliminary Report,
U. S. Geological Survey Bulletin 1009-E, pp. 125-168. {Cited in 1.6.2.2}
Dames and Moore, 1978, "Environmental Report, White Mesa Uranium Project, San Juan County, Utah." Prepared for Energy
Fuels Nuclear, Inc.,January. {Cited in 1.5, 1.5.3.1, 1.5.5, 1.7.1.1}
Dames and Moore, 1978a. Site Selection and Design Study -Tailing Retention and Mill Facilities, White Mesa Uranium
Project, January 17, 1978.
Dames and Moore, 1978b. Environmental Report, White Mesa Uranium Project, San Juan County, Utah, January 20, 1978,
revised May 15, 1978. {Cited in Section 1.0,1.4.1,1.4.2,1.6.3.4,1 .7.1.1,1.7.1.2,1.7.2, Attachment A}
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Page iii
Revision 3.2 -Final
Denison Mines (USA) Corp ..
White Mesa Mill Reclamation plan
D'Appolonia Consulting Engineers, Inc., 1979. Engineer's Report, Tailings Management System, White Mesa Uranium Project,
Blanding, Utah.
D'Appolonia Consulting Engineers, Inc., 1981, Letter Report, "Assessment of the Water Supply System, White Mesa Project,
Blanding, Utah." Prepared for Energy Fuels Nuclear, inc., February. (Cited in 1.5, 1.5.3.1)
D'Appolonia Consulting Engineers, inc., 1981a. Engineer's Report, Second Phase Design -Cell 3 Tailings Management
System, White Mesa Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, inc., 1981 b. Letter Report, Leak Detection System Evaluation, White Mesa Uranium
Project, Blanding, Utah.
D'Appolonia Consulting Engineers, inc., 1982, "Construction Report, initial Phase -Tailings Management System, White Mesa
Uranium Project, Blanding, Utah." Prepared for Energy Fuels Nuclear, inc., February. (Cited in 1.5, 1.5.3.1)
D'Appolonia Consulting Engineers, inc., 1982a. Construction Report, Initial Phase -Tailings Management System, White
Mesa Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, inc., 1982b. Monitoring Plan -initial phase -Tailings Management System -White Mesa
Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, inc., 1982c. Letter Report -Groundwater Monitoring Program-White Mesa Uranium
Project, Blanding, Utah.
D'Appolonia Consulting, Engineers, inc., 1982d. Letter Report -Additional Analysis Tailings Cover Design Revisions -White
Mesa Uranium Project, Blanding, Utah.
D'Appolonia Consulting Engineers, inc., 1984, "Engineer's Report, Geotechnical Site Evaluation, Farley Project, Garfield County,
Utah." Prepared for Atlas Minerals, Moab, Utah, June. (Cited in 1.5)
Eardly, A. J., 1958. Physiography of Southeastern Utah in intermountain Association Petroleum Geologists Guidebook, 9th
Annual Field Conference, Geology ofthe Paradox Basin, pp. 10-15. (Cited in 1.6.1.1)
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
Pageiv
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White Mesa Mill Reclamation Plan
Energy Fuels Nuclear, Inc., 1983. Construction Report -Second phase Tailings Management System, White Mesa Uranium
Project.
Energy Fuels Nuclear, Inc. Semi-annual Effluent Report, White Mesa Mill, SUA-1358, Docket No. 40-8681, (July -December
1995) and (January through June 1996). (Cited in 1.0, 1.5, 1.5.5.1,3.3.2.2)
Environmental Protection Agency, 1994. (Cited in 3.3.1, 3.3.3)
Feltis, R. D., 1966. Water from Bedrock in the Colorado Plateau of Utah, Utah State Engineer Technical Publication No. 15.
Grose, l. T., 1972. Tectonics, in Geologie Atlas of the Rocky Mountain Region Rocky Mountain Association Geologists,
Denver, Colorado, pp. 35-44. (Cited in 1.6.1.3)
Hadsell, F. A, 1968. History of Earthquakes in Colorado, in Hollister, J. S. and Weimer, R. J., eds., Geophysical and Geological
Studies of the Relationships Between the Denver Earthquakes and the Rocky Mountain Arsenal Well, Colorado School Mines
Quarterly, v. 63, No.1, pp. 57-72. (Cited in 1.6.2.3, 1.6.3.3)
Haynes, D.D., Vogel, J.D., and Wyant, D.G., 1972, "Geology, Structure and Uranium Deposits of the Cortez Quadrangle, Colorado
and Utah." U.S. Geological Survey, Miscellaneous Investigation Series, Map, 1-629, May. (Cited in 1.5.2, 1.5.3.1,1.6.2.2)
Hermann, R. B., Dewey, J. W., and Park, S. F., 1980. The Dulce, New Mexico, Earthquake of January 23, 1966, Seismological
Society of America Bulletin, v. 70, No.6, pp. 2171-2183. (Cited in 1.6)
Hite, R. J., 1975. An Unusual Northeast-trending Fracture Zone and its Relation to Basement Wrench Faulting in Northern
Paradox Basin, Utah and Colorado, Four Corners Geological Society 8th Field Conference Gu idebook, Durango, Colorado, pp.
217-223. (Cited in 1.6.3.3)
Huff, l. D., and Lesure, F. G., 1965. Geology and Uranium Deposits of Montezuma Canyon Area, San Juan County, Utah, U. S.
Geological Survey Bulletin 1190, 102 p. (Cited in 1.6.2.2)
Hunt, C. B., 1956. Cenozoic Geology of the Colorado plateau: U. S. G. S. Professional Paper, 279.
N:\Reclarnation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
Pagev
Revision 3.2 -Final
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Hydro-Engineering, 1991, "Ground Water Hydrology at the White Mesa Tailings Facility."Prepared for Umetco Minerals
Corporation, Blanding, Utah, July.
Johnson, H. 5., Jr. , and Thordarson, W., 1966. Uranium Deposits of the Moab, Monticello, White Canyon, and Monument
Valley Districts, Utah and Arizona, U. S. Geological Survey Bulletin 1222-H, 53 p. (Cited in 1.6.1.3, 1.6.2.2)
Keend, W. E., 1969. Quaternary Geology of the Grand and Battlement Mesa Area, Colorado: u.s.G.S. Professional Paper, 617.
Kelley, V. c., 1955. Regional Tectonics of the Colorado plateau and Relationship to the Origin and Distribution of Uranium,
New Mexico University Publication Geology No.5, 120 p. (Cited in 1.6.1.3)
Kelley, V. c., 1956. (Cited in 1.6.1.3)
Kelley, V.c., 1958, "Tectonics of the Region of the Paradox Basin." In Intermountain Association Petroleum Geologists
Guidebook, 9th Annual Field Conference, Geology ofthe Paradox Basin, p. 31-38.
Kirkham, R. M. and Rogers, W. P., 1981. Earthquake Potential in Colorado, A Preliminary Evaluation, Colorado Geological
Survey, Bulletin 43. (Cited in 1.6.3.3)
Krinitzsky, E. L. and Chang, F. K., 1975. State-of-the-Art for Assessing Earthquake Hazards in the United States, Earthquake
Intensity and the Selection of Ground Motions for Seismic Design, Miscellaneous Paper 5-73-1, Report 4, September 1975, U. S.
Army Engineer Waterways Experiment Station, CE, Vicksburg, Mississippi.
Larson, E. E., et. aI., 1975. Late Cenozoic Basic Volcanism in Northwestern Colorado and its Implications Concerning Tectonics
and the Colorado River System in Cenozoic History of Southern Rocky Mountains: Geological Society of America, Memoir 144.
Lawrence Livermore National Laboratory, 1994. Seismic Hazard Analysis of Title /I Reclamation Plans; U. S. Nuclear
Regulatory Commission.
Lindsay, L. M. W., 1978. Archeological Test Excavations on White Mesa, San Juan County, Southeastern Utah. (Cited in 1.3.2)
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
MITRE Software Corporation, GSLOPE Computer Software Package.
Page vi
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National Oceanic and Atmospheric Administration (NOAA), 1977. Probable Maximum Precipitation Estimates, Colorado
River and Great Basin Drainages. Hydrometerological Report (HMR) No. 49.
National Oceanic and Atmospheric Administration (NOAA), 1988. Computer Printout of Earthquake File Record for 320 km
Radius of Blanding, Utah. U. S. Department of Commerce, National Geophysical Data Center, Boulder, Colorado. (Cited in
1.6.3.4, 1.7)
Nielson, A. S., 1979. Additional Archeological Test Excavations and Inventory on White Mesa, San Juan County, Southeastern
Utah. (Cited in 1.3.2)
NUREG 1623,2002. Design of erosion Protection for Long-Term stabilization, Final Report, September.
NUREG/CR-1081, March 1980. Characterization of Uranium Tailings Cover Materials for Radon Flux Reduction.
NUREG/CR-2642, June 1982. Long-term Survivability of Riprap for Armoring Uranium Mill Tailings and Covers: A Literature
Review.
NUREG/CR-2684, August 1982. Rock Riprap Design Methods and Their Applicability to Long-term Protection of Uranium
Mill Tailings Impoundments.
NUREG/CR-3027, March 1983. Overland Erosion of Uranium Mill Tailings Impoundments Physical Processes and
Computational Methods.
NUREG/CR-3061, November 19B3. Survivability of Ancient Man-made Mounds: Implications for Uranium Mill Tailings
Impoundment.
NUREG/CR-3199, October 1983. Guidance for Disposal of Uranium Mill Tailings: Long-term Stabilization of Earthen Cover
Materials.
NUREG/CR-3397, October 1983. Design Considerations for Long-term Stabilization of Uranium Mill Tailings Impoundments.
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NUREG/CR-3533, February 1984. Radon Attenuation Handbook for Uranium Mill Tailings Cover Design.
NUREG/CR-3674, March 1984. Designing Vegetation Covers for Long-term Stabilization of Uranium Mill Tailings.
NUREG/CR-3747, May 1985. The Selection and Testing of Rock for Armoring Uranium Tailings Impoundments.
NUREG/CR-3972, December 1984. Settlement of Uranium Mill Tailings Piles.
NUREG/CR-4075, May 1985. Designing Protective Covers for Uranium Mill Tailings Piles: A Review.
NUREG/CR-4087, February, 1985. Measurements of Uranium Mill Tailings Consolidation Characteristics.
NUREG/CR-4323, January 1986. The Protection of Uranium Tailings Impoundments against Overland Erosion.
NUREG/CR-4403, November 1985. Summary of the Waste Management Programs at Uranium Recovery Facilities as They
Relate to the 40 CFR Part 192 Standards.
NUREG/CR-44BO, September 1986. Erosion Protection of Uranium Tailings Impoundment.
NUREG/CR-4504, March 1986. Long-term Surveillance and Monitoring of Decommissioned Uranium Processing Sites and
Tailings Piles.
NUREG/CR-4520, April 1986. Predictive Geochemical Modeling of Contaminant Concentrations in Laboratory Columns and
in Plumes Migrating from Uranium Mill Tailings Waste Impoundments.
NUREG/CR-4620, June, 1986. Methodologies for Evaluating Long-Term Stabilization Designs of Uranium Mill Tailings
Impoundments, J. D. Nelson, S. R. Abt., et. al. (Cited in 3.3.1, 3.5.5, Attachment A)
NUREG/CR-4651, May 1987. Development of Riprap Design Criteria by Riprap Testing in Flumes:Phase I. (Cited in 3.3.1,
3.3.5, Attachment A)
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Nuttli, O. W., 1979. State-of-the-Art for Assessing Earthquake Hazards in the United States, Part 16: The Relation of Sustained
Maximum Ground Acceleration and Velocity to Earthquake Intensity and Magnitude, with Errata Sheet of January 11,1982; U.
S. Army Engineers Waterways Experiment Station, Vicksburg, P. O. No. DACW39-78-C-0072, 67 p. with Two Appendices and 2
p. Errata.
Roger and Associates Engineering Company, 1988. Radiological Properties Letters to C. O. Sealy from R. Y. Bowser dated
March 4 and May 9, 1988. (Cited in 3.3.2.1)
Rogers and Associates, 1996. {Cited in 3.3.2.1}
Schroeder, P. R., J. M. Morgan, T. M. Walski, and A. C. Gibson, 1989, "Technical Resource Document, The Hydrologic Evaluation
of Landfill Performance (HELP) Model, Version II," U.S. Environmental Protection Agency.
Seed, H. B. And Idriss, I. M., 1982. Ground Motions and Soils Liquefaction During Earthquakes, Earthquake Engineering
Research Institute, Berkeley, California.
Shoemaker, E. M., 1954. Structural Features of Southeastern Utah and Adjacent Parts of Colorado, New Mexico, and Arizona.
Utah Geological Society Guidebook to the Geology of Utah, No.9, pp. 48-69. {Cited in 1.6.1.3}
Shoemaker, E.M., 1956, "Structural Features of the Colorado Plateau and Their Relation to Uranium Deposits." U.s. Geological
Survey Professional Paper 300, p. 155-168. {Cited in 1.6.1 .3}
Simon, R. B., 1972. Seismicity, in Mallory, W. W., and Others, eds. Geologie Atlas of the Rocky Mountain Region, Rocky
Mountain Association of Geologists, pp. 48-51.
Slemmons, D. B., 1977. State-of-the-Art for Assessing Earthquake Hazards in the United States, Part 6, Faults and Earthquake
Magnitude, with an Appendix on Geomorphic Features of Active Fault Zones, U. S. Army Engineer Waterways Experiment
Station, Vicksburg, Contract No. DACW39-76-C-0009, 129 p. plus 37 p. AppendiX.
Smith, R. B., 1978. Seismicity, Crustal Structure, and Intraplate Tectonics of the Western Cordillera, in Cenozoic Tectonics and
Regional Geophysics of the Western Cordillera. Smith, R. B. and Eaton, G. P., eds, Memoir 152, Geological Society of America,
pp.111-144. {Cited in 1.6.3.3}
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Smith, S., 1981. Long-Term Stability at Union Carbide's Tailings Piles in Uravan, Colorado.
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Stephenson, D., 1979. Rockfill in Hydraulic Engineering, Developments in Geotechnical Engineering, 27, Elsevier Scientific
Publishing Company, pp. 50-60. See NUREG 4620.
Stokes, W. L., 1954. Stratigraphy of the Southeastern Utah Uranium Region, Utah Geological Society Guidebook to the
Geology of Utah, No.9, pp. 16-47.
Stokes, W. L., 1967. A Survey of Southeastern Utah Uranium Districts, Utah Geological Society Guidebook to the Geology of
Utah, No. 21, pp. 1-11. (Cited in 1.6.2.2)
Tellco Environmental, 1995. Neshaps Radon Flux Measurement Program, White Mesa Mill, October 1995. (Cited in
Introduction)
Thompson, K. c., 1967. Structural Features of Southeastern Utah and Their Relations to Uranium Deposits, Utah Geological
Society Guidebook to the Geology of Utah, No. 21, pp. 23-31. (Cited in 1.6.1.3)
Thordarson, 1966. (Cited in 1.6.1.3,1 .6.2.2)
Titan Environmental Corporation, 1994. (Cited in 1.0)
Titan Environmental Corporation, 1994a. Hydrogeologic Evaluation of White Mesa Uranium Mill, July 1994. (Cited in
Introduction, 1.5)
Titan Environmental Corporation, 1994b. Points of Compliance, White Mesa Uranium Mill, September 1994. (Cited in
Introduction, 1.5)
Titan Environmental Corporation, 1996. Tailings Cover Design, White Mesa Mill, October 1996 (Cited in Introduction, 1.6.3)
T rifunac, M. D. and Brady, A. G. On the Correlation of Seismic Intensity Scales with the Peaks of Recorded Strong Ground
Motion, Seismological Society of America Bulletin, V. 65, Feb. 1975, pp. 139-162. (Cited in 1.6.3.4)
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
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Umetco, 1987. Umetco Minerals Corporation SUA-1358: Docket No. 40-8681, License Condition 48, White Mesa Mill, Utah,
Letter From R. K. Jones to U. S. Nuclear Regulatory Commission dated November 30, 1987.
Umetco Minerals Corporation, 1992, "Ground Water Study, White Mesa Mill, Blanding, Utah,"License SUA 1358, Docket No.
40-8681. (Cited in 1.5.3.1,1.5.5)
United States Geological Survey, 1970. (Cited in 1.6)
U.S. Department of Energy, 1988. (Cited in 3.3.1,3.3.4)
U.S. Department of Energy, 1993, "Environmental Assessment of Remedial Action at the Slick Rock Uranium Mill Tailings Sites,
Slick Rock, Colorado." UMTRA Project Office, Albuquerque, New Mexico, February. (Cited in 1.5.3)
U. S. Geological Survey. (Cited in 1.5)
U. S. Geological Survey, 1970. (Cited in 1.6.2.3)
U. S. Nuclear Regulatory Commission, 1977. Regulatory Guide 3.11, Design, Construction, and Inspection of Embankment
Retention Systems for Uranium Mills, Revision 2, 1977.
U. S. Nuclear Regulatory Commission. Regulatory Guide 3.64, Task WM 503-4, Calculation of Radon Flux Attenuation by
Earthen Uranium Mill Tailings Covers. (Cited in 3.3.2.1)
U. S. Nuclear Regulatory Commission, 1979. Final Environmental Statement-White Mesa Uranium Project, NUREG-0556.
(Cited in Section 1.0, 1.3.1, 1.4, 1.4.2)
U. S. Nuclear Regulatory Commission, 1980. (Cited in 3.3.1)
U. S. Nuclear Regulatory Commission, 1984. Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct or Source Materials. (Cited in Introduction)
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
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U. S. Nuclear Regulatory Commission, 1985. Standard Review plan for UMTRA Title I Mill Tailings -Remedial Action Plans,
Division of Waste Management.
U. S. Nuclear Regulatory Commission, 1987a. URFO:TIO, Docket No. 40-8681, 040086817405, Letter to Umetco
Minerals Corporation O. S. Hamrick) from F. F. Hawkins dated January 26, 1987.
U. S. Nuclear Regulatory Commission, 1987b. 10 CFR 40, Appendix A
U. S. Nuclear Regulatory Commission, 1987c. URFO:GRK, Docket No. 40-8681, Letter to Umetco Minerals Corporation
from E. F. Hawkins dated October 21, 1987.
U. S. Nuclear Regulatory Commission, 1988. Docket No. 40-8681 SUA-1358, Amendment No.1 O. Letter to Umetco
Minerals Corporation dated January 8, 1988, from R. Dale Smith.
U. S. Nuclear Regulatory Commission, 1989. (Cited in 3.3.1,3.3.2)
U. S. Nuclear Regulatory Commission, 1990. (Cited in 3.3.5, Attachment A)
University of Utah Seismograph Stations, 1988. Computer List of Earthquakes within 320 km of Blanding, Utah, Department
of Geology and Geophysics, University of Utah, Salt Lake City.
von Hake, C. A, 1977. Earthquake History of Utah, Earthquake Information Bulletin 9, pp. 48-51 . (Cited in 1.6.2.3)
Warner, L. A, 1978. The Colorado Lineament, A Middle Precambrian Wrench Fault System, Geological Society of America
Bulletin, v. 89, pp. 161-171. (Cited in 1.6.3.3)
Williams, P. L., 1964. Geology, Structure, and Uranium Deposits of the Moab Quadrangle, Colorado and Utah, U. S. Geologic
Survey Map, 1-360.
Witkind, I. J., 1964. Geology of the Abajo Mountains Area, San Juan County, Utah, U. S. Geological Survey, Professional Paper
453. (Cited in 1.6.1.3,1.6.2,1.6.2.2)
Woodward-Clyde Consultants, 1982. Geologic Characterization Report of the Paradox Basin Study Region, Utah Study Areas,
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\REFERENCES 3.2 -Final.docx
ONWt-290, v. 1, Prepared for Office of Nuclear Wasle Isolation, Battelle MemoriallnstilUle.
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Wong, I. G., 1981. Seismological Evaluation of the Colorado lineament in Ihe Inlermounlain Region (abs.), Earthquake Notes,
v. 53, pp. 33-34. (Cited in 1.6.3.3)
Wong. I. G., 19B4. Seismicity of the Paradox Basin and the Colorado Plateau Interior, ONWI-49Z, Prepared for the Office of
NudearWaste Isolation, Battelle Memorial lnstilUte. (Cited in 1.6.3.3)
Zoback, M. O. and Zoback, M. l .. 1980. State of Suess in the Conterminous United Stales, Journal of Geophysical Research, v.
a5, pp. 6113·6156. (Cited in 1.6.3.3)
N:\Rcclamation Plan\Rcclamation Plan Rev 3.2· final\REFERENCES 3.2 -Final.docx
OENISOJ)JJ
MINES
Introduction
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State of Utahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: [phone]
Fax: [phone]
Page I-I
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
INTRODUCTION
This reclamation Plan (the "Plan") prepared by Denison Mines(USA) Corp. ("Denison"), for
Denison's White Mesa Uranium Mill (the "Mill"), located approximately 6.0 miles south of
Blanding Utah. The Plan presents Denison's plans and estimated costs for the reclamation of the
Mill's tailings Cells 1,2,3, 4A and 4B, and for decommissioning ofthe Mill and Mill site.
Summary of Plan
The uranium and vanadium processing areas of the mill, including all equipment, structures and
support facilities will be decommissioned and disposed of in tailings or buried on site as
appropriate. All equipment, including tankage and piping; agitation; process control
instrumentation and switchgears; and contaminated structures; will be cut up, removed, and buried
in tailings prior to final cover placement. Concrete structures and foundations will be demolished
and removed or covered with soil as appropriate. These decommissioned areas would include, but
not be limited to, the following:
Coarse ore bin and associated equipment, conveyors and structures.
Grind circuit including semi-autogenous grind (SAG) mill, screens, pumps and cyclones.
Three pre-leach tanks to the east of the mill building, including all associated tankage,
agitation equipment, pumps, and piping.
Seven leach tanks inside the main mill building, including all associated agitation
equipment, pumps and piping.
Counter-current decantation (CCD) circuit including all thickeners and equipment, pumps
and piping.
Uranium precipitation circuit, including all thickeners, pumps and piping.
Two yellowcake dryers and all mechanical and electrical support equipment, including
uranium packaging equipment.
Clarifiers to the west of the mill building including the preleach thickener and claricone.
Boiler and all ancillary equipment and buildings.
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Entire vanadium precipitation, drying, and fusion circuit.
All external tankage not included in the above list including: reagent tanks for the storage
of acid, ammonia, kerosene, water, or dry chemicals; and the vanadium oxidation circuit.
Uranium and vanadium solvent extraction (SX) circuit including all SX and reagent
tankage, mixers and settlers, pumps, and piping.
SX building.
Mill building.
Office building.
Shop and warehouse building.
Sample plant building.
Alternate feed Circuit
Truck Shop.
Temporary Storage Building
The sequence of demolition would proceed so as to allow the maximum use of support areas of the
facility, such as the office and shop areas. Any uncontaminated or decontaminated equipment to
be considered for salvage will be released in accordance with the United States Nuclear
Regulatory Commission ("NRC") document,guidance and in compliance with the conditions of
the Mill's State of Utah Radioactive materials License No. UTl900479 (the "License"). As with
the equipment for disposal, any contaminated soils from the Mill and surrounding areas and any
ore or feed materials on the Mill site will be disposed of in the tailings facilities in accordance with
Section 4.0 of Attachment A, Plans and Specifications.
The estimated reclamation costs for surety are set out in Attachment C. Attachment C will be
reviewed and updated on a yearly basis.
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Plan Organization
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
General site characteristics pertinent to this Plan are contained in Section 1.0. Descriptions of
the facility construction, operations and monitoring are given in Section 2.0. The current
environmental monitoring program is described in Section 2.3. Seismic risk was assessed in
Section 1.6.3.
The Plan itself, including descriptions of facilities to be reclaimed and design criteria, is presented
in Section 3.0. Section 3.0 Attachments A through H are the Plans and Specifications, Quality
Plan for Construction Activities, Cost Estimates, and supplemental testing and design details.
Supporting documents which have been reproduced as appendices for ease of review, include:
• Semi-Annual Effluent Reports, (January through June 2008), (June through
December 2008) and (January through June 2009) for the Mill, Which have been
submitted previously on November 24, 2009;
• Site hydrogeology and Estimation of Groundwater Travel Times in the Perched
Zone White Mesa Uranium Mill Site Near Blanding, Utah, August 27, 2009,
prepared by Hydro Geo Chern, Inc. (the "2009 HGC Report), submitted previously
on November 24, 2009;
• The Mill's Stormwater Best Management Practices Plan, Revision 1.3: June 12,
2008, submitted previously on November 24, 2009;
• Tailings Cover Design, White Mesa Mill, October 1996. submitted previously on
November 24, 2009;
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• National Emissions Standards for Hazardous Air Pollutants Radon Flux
Measurement Program, White Mesa Mill Site,200S. Tellco Environmental,
submitted previously on November 24,2009; and
• Semi-Annual Monitoring Report July 1 -December 31, 2008 and Annual
Monitoring Summary for 2008, White Mesa Mill Meteorological Station, January
20, 2009 McVehil-Monnett Associates, Inc., submitted previously on November
24,2009.
As required by Part LH.II ofthe Mill's State of Utah Ground Water Discharge Permit No.
UGW370004 (the "GWDP"), Denison is in the process of completing an infiltration and
contamination transport model of the final tailings cover system to demonstrate the
long-term ability of the cover to protect nearby groundwater quality. Upon review of such
modeling, the executive Secretary of the State of Utah radiation Control Board (the
"Executive Secretary") will determine if changes to the cover system as set out in the Plan
are needed to ensure compliance with the performance criteria contained in Part LD.S of
the GWDP. Although the modeling has not been completed, modeling results to date
suggest that some changes to the final cover design as set out in the Plan will be needed.
However, as the details of such re-design have not been finalized at this time, the approved
2000 cover design and basis will continue to be used for this version of the Plan. This
Plan will be amended in the future to incorporate any changes to the design of the tailings
cover system that result from the current modeling effort.
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"ENISOJ)~~ Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
MINES Tel: [phone]
Fax: [phone]
www.denisonmines.com
Section 2.0 Existing Facility
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State ofUtahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: [phone]
Fax: [phone]
Page 2-1
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
2.0 EXISTING FACILITY
The following sections describe the construction history of the Mill; the Mill and Mill tailings
management facilities; Mill operations including the Mill circuit and tailings management; and
both operational and environmental monitoring.
2.1 Facility Construction History
The Mill is a uranium/vanadium mill that was developed in the late 1970's by Energy Fuels
Nuclear, Inc. (EFN) as an outlet for the many small mines that are located in the Colorado Plateau
and for the possibility of milling Arizona Strip ores. At the time of its construction, it was
anticipated that high uranium prices would stimulate ore production. However, prices started to
decline about the same time as Mill operations commenced.
As uranium prices fell, producers in the region were affected and mine output declined. After
about two and one-half years, the Mill ceased ore processing operations altogether, began solution
recycle, and entered a total shutdown phase. In 1984, a majority ownership interest was acquired
by Union Carbide Corporation's ("UCC") Metals Division which later became Umetco Minerals
Corporation ("Umetco"), a wholly-owned subsidiary of UCC. This partnership continued until
May 26, 1994 when EFN reassumed complete ownership. In May of 1997, Denison (then named
International Uranium (USA) Corporation) and its affiliates purchased the assets ofEFN and is the
current owner of the facility. Throughout this Plan, the names Denison and !USA are used
interchangeably.
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2.1.1 Mill and Tailings Management Facility
The Source Materials License Application for the White Mesa Mill was submitted to NRC on
February 8, 1978. Between that date and the date the first ore was fed to the mill grizzly on May
6, 1980, several actions were taken including: increasing mill design capacity, permit issuance
from the United States Environmental Protection Agency ("EPA") and the State of Utah,
archeological clearance for the Mill and tailings areas, and an NRC pre-operational inspection on
May 5,1980.
Construction on the tailings area began on August 1, 1978 with the movement of earth from the
area of Cell 2. Cell 2 was completed on May 4, 1980, Cell 1 on June 29, 1981, and Cell 3 on
September 2, 1982. In January of 1990 an additional cell, designated Ce114A, was completed and
initially used solely for solution storage and evaporation. Cell 4A was only used for a short
period of time and then taken out of service because of concerns about the synthetic lining system.
IN 2007, Cell 4A was retrofitted with a new State of Utah approved lining system and was put
back into service in October of 2008. Cell 4B construction was authorized by License
Amendment No.4, issued on June 17, 2010, and the cell is currently under construction.
The Ce1l4A and 4B design and operational details are more specifically described in the following
documents, hereby incorporated by reference:
1) Cell4A Construction Quality Assurance Report, July 2008
2) Cell4B Construction Quality Assurance Report, November 2010
3) Discharge Minimization technology Monitoring Plan, Revision 11, and Best Available
Technology Operations and Maintenance Plan revision 2, November 12, 2010 (under
review).
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2.2 Facility Operations
In the following subsections, an overview of mill operations and operating periods are followed by
descriptions ofthe operations ofthe mill circuit and tailings management facilities.
2.2.1 Operating Periods
The Mill was operated by EFN from the initial start-up date of May 6, 1980 until the cessation of
operations in 1983. Umetco, as per agreement between the parties, became the operator of record
on January 1, 1984. The Mill was shut down during all of 1984. The Mill operated at least part
of each year from 1985 through 1990. Mill operations again ceased during the years of 1991
through 1994. EFN reacquired sole ownership on May 26, 1994 and the mill operated again
during 1995 and 1996. After acquisition of the Mill by Denison and its affiliates several local
mines were restarted and the Mill processed conventional ores during 1999 and early 2000. With
the resurgence in uranium and vanadium process in 2003, Denison reopened several area mines
and again began processing uranium and vanadium ores in April of 2008. Mill operations were
suspended in 2009, and resumed in March of2010. Typical employment figures for the Mill are
110 during uranium-only operations and 140 during uranium/vanadium operations.
Commencing in the early 1990's through today, the Mill has processed alternate feed materials
from time to time when the Mill has been processing conventional ores. Alternate feed materials
are uranium-bearing materials other than conventionally-mined uranium ores. The Mill installed
an alternate feed circuit in 2009 that allows the Mill to process certain alternate feed materials
simultaneously with conventional ores.
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2.2.2 Mill Circuit
While originally designed for a capacity of 1,500 dry tons per day (dtpd.), the Mill capacity was
boosted to the present rated design of 1980 dtpd. prior to commissioning.
The mill uses an atmospheric hot acid leach followed by counter current decantation ("CCD").
This in tum is followed by a clarification stage which precedes the solvent extraction ("SX")
circuit. Kerosene containing iso-decanol and tertiary amines extract the uranium and vanadium
from the aqueous solution in the SX circuit. Salt and soda ash are then used to strip the uranium
and vanadium from the organic phase.
After extraction of the uranium values from the aqueous solution in SX, uranium is precipitated
with anhydrous ammonia, dissolved, and re-precipitated to improve product quality. The
resulting precipitate is then washed and dewatered using centrifuges to produce a final product
called "yellowcake." The yellowcake is dried in a multiple hearth dryer and packaged in drums
weighing approximately 800 to 1,000 lbs. for shipping to converters.
After the uranium values are stripped from the pregnant solution in SX, the vanadium values are
transferred to tertiary amines contained in kerosene and concentrated into an intermediate product
called vanadium product liquor ("VPL"). An intermediate product, ammonium metavanadate
("AMV"), is precipitated from the VPL using ammonium sulfate in batch precipitators. The
AMV is then filtered on a belt filter and, if necessary, dried. Normally, the AMV cake is fed to
fusion furnaces when it is converted to the mill's primary vanadium product, V 205 tech flake,
commonly called "black flake."
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The same basic process steps used for the recovery of uranium from conventional ores are used for
the recovery of uranium from alternate feed materials, with some variations depending on the
particular alternate feed material.
The mill processed 1,511,544 tons of ore and other materials from May 6, 1980 to February 4,
1983. During the second operational period from October 1, 1985 through December 7, 1987,
1,023,393 tons of conventional ore were processed. During the third operational period from July
1988 through November 1990, 1,015,032 tons of conventional ore were processed. During the
fourth operational period from August 1995 through January 1996, 203 ,317 tons of conventional
ore were processed. In the fifth operational period from May 1996 through September 1996, the
Mill processed 3,868 tons of calcium fluoride alternate feed material. From 1997 to early 1999"
the Mill processed 58,403 tons from several additional feed stocks.
With rising uranium prices in the late 1990's, company mines were reopened in 1997, and 87,250
tons of conventional ore were processed in 1999 and early 2000. In 2002 and 2003, the Mill
processed 266,690 tons of alternate feed material from government cleanup projects. An
additional 40,866 tons of alternate feed materials were processed in 2007. From April 2008
through May 2009 the Mill processed an additional 184, 795 tons of conventional ore.
Inception to date material processed through May 2009 totals 4,128,468 tons. This total is for all
processing periods combined.
2.2.3 Tailings Management Facilities
Tailings produced by the mill typically contain 30 percent moisture by weight, have an in-place
dry density of 86.3 pounds per cubic foot (Cell 2), have a size distribution with a predominant -325
mesh size fraction, and have a high acid and flocculent content. Tailings from alternate feed
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materials that are similar physically to conventional ores, which comprise most of the tons of
alternate feed materials processed to date at the Mill, are similar to the tailings for conventional
ores. Tailings from some of the higher grade, lower volume alternate feed materials may vary
somewhat from the tailings from conventional ores, primarily in moisture and density content.
The tailings facilities at White Mesa currently consist of four cells as follows:
• Cell 1, constructed with a 30-millimeter (ml) PVC earthen-covered liner, is used for the
evaporation of process solution (Cell 1 was previously referred to as Cell I-I, but is
now referred to as CellI);
• Cell 2, constructed with a 30-millimeter (ml) PVC earthen-covered liner, is used for the
storage of barren tailings sands. This Cell is full and has been partially reclaimed;
• Cell 3, constructed with a 30-millimeter (ml) PVC earthen-covered liner, is used for the
storage of barren tailings sands and solutions. This cell is partially filled and has been
partially reclaimed; and
• Ce1l4A, constructed with a geosynthetic clay liner, a 60 Millimeter (mil) HDPE liner, a
300 mil HDPE geonet drainage layer, a second 60 mil HDPE liner, and a slimes drain
network over the entire cell bottom. This cell was placed into service in October of
2008.
• Ce1l4B, will be constructed with a geosynthetic clay liner, a 60 Millimeter (mil) HDPE
liner, a 300 mil HDPE geonet drainage layer, a second 60 mil HDPE liner, and a slimes
drain network over the entire cell bottom. This cell will be constructed during the
2010 construction season.
Total estimated design capacity of Cells 2, 3, and 4A is approximately six million (mm) tons.
Figures 1.5-4 and 1.5-5 show the locations ofthe tailings cells.
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Denison has submitted an application to the Executive Secretary to amend the License and GWDP
to authorize the construction oftailings Ce1l4B, which will be located adjacent to Ce1l4A and will
provide approximately two million additional tons of tailings capacity. That application was
approved by the Executive Secretary on June 17, 2010.
2.2.3.1 Tailings Management
Constructed in shallow valleys or swale areas, the lined tailings facilities provide storage below the
existing grade and reduce potential exposure. Because the cells are separate and distinct,
individual tailings cells may be reclaimed as they are filled to capacity. This phased reclamation
approach minimizes the amount of tailings exposed at any given time and reduces potential
exposure to a minimum.
Slurry disposal has taken place in Cells 2, 3 and 4A. Tailings placement in Cell 2 and Cell 3 was
accomplished by means of the final grade method, described below.
The final grade method used in Cell 2 and Cell 3 calls for the slurry to be discharged until the
tailings surface comes up to final grade. The discharge points are set up in the east end of the cell
and the final grade surface is advanced to the slimes pool area. Coarse tailings sand from the
discharge points are graded into low areas to reach the final disposal elevation. When the slimes
pool is reached, the discharge points are then moved to the west end ofthe cell and worked back to
the middle. An advantage to using the fmal grade method is that maximum beach stability is
achieved by (1) allowing water to drain from the sands to the maximum extent, and (2) allowing
coarse sand deposition to help provide stable beaches. Another advantage is that radon release
and dust prevention measures (through the placement of the initial layer of the final cover) are
applied as expeditiously as possible.
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Slurry disposal in Cell 4A is from several pre-determined discharge points located around the
north and east sides of the cell. Slurry discharge is only allowed on skid pads, or protective
HDPE sheets, to prevent damage to the synthetic lining system. Once tailings solids have reach
the maximum elevation around the perimeter of the cell, discharge points can be moved toward the
interior ofthe cell. Slurry disposal in Ce1l4B will be conducted in the same manner as Ce1l4A.
2.2.3.2 Liquid Management
As a zero-discharge facility, the White Mesa Mill must evaporate all of the liquids utilized during
processing. This evaporation takes place in three (3) areas:
• Cell 1, which is used for solutions only;
• Cell 3, in which tailings and solutions exist;
• Ce1l4A, in which tailings and solutions exist, and
• Ce1l4B after construction is complete.
The original engineering design indicated a net water gain into the cells would occur during Mill
operations. As anticipated, this has been proven to be the case. In addition to natural
evaporation, spray systems have been used at various times to enhance evaporative rates and for
dust control. To minimize the net water gain, solutions are recycled from the active tailings cells
to the maximum extent possible. Solutions from Cells 1, 3, and 4A are brought back to the CCD
circuit where metallurgical benefit can be realized. Cell 4B will be operated in the same manner
as Ce1l4A. Recycle to other parts of the mill circuit are not feasible due to the acid content ofthe
solution.
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2.3 Monitoring Programs
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Operational monitoring is defined as those monitoring activities that take place only during
operations. This is contrasted with environmental monitoring, which is performed whether or not
the mill is in operation.
2.3.1 Monitoring and Reporting Under the Mill's GWDP
2.3.1.1 Groundwater Monitoring
a) Plugged and Excluded Wells
Wells MW-6, MW-7, and MW-8 were plugged because they were in the area of Cell 3, as was
MW-13, in the Ce1l4A area. Wells MW-9 and MW-lO are dry and have been excluded from the
monitoring program. MW -16 is dry and has been plugged as part of the tailings Cell 4B
construction.
b) Groundwater Monitoring at the Mill Prior to Issuance of the GWDP
At the time of renewal ofthe License by NRC in March, 1997 and up until issuance of the GWDP
in March 2005, the Mill implemented a groundwater detection monitoring program to ensure
compliance to 10 CFR Part 40, Appendix A, in accordance with the provisions of the License.
The detection monitoring program was in accordance with the report entitled, Points of
Compliance, White Mesa Uranium Mill, prepared by Titan Environmental Corporation, submitted
by letter to the NRC dated October 5, 1994 (Titan, 1994b). Under that program, the Mill sampled
monitoring wells MW-5, MW-ll, MW-12, MW-14, MW-15 and MW-17, on a quarterly basis.
Samples were analyzed for chloride, potassium, nickel and uranium, and the results of such
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sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports that were filed
with the NRC up until August 2004 and with the DRC subsequent thereto.
Between 1979 and 1997, the Mill monitored up to 20 constituents in up to 13 wells. That program
was changed to the Points of Compliance Program in 1997 because NRC had concluded that:
• The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
• The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
c) Issuance ofthe GWDP
On March 8, 2005, the Executive Secretary issued the GWDP, which includes a groundwater
monitoring program that supersedes and replaces the groundwater monitoring requirements set out
in the License. Groundwater monitoring under the GWDP commenced in March 2005, the
results of which are included in the Mill's Quarterly Groundwater Monitoring Reports that are
filed with the Executive Secretary.
d) Current Ground Water Monitoring Program at the Mill Under the GWDP
The current groundwater monitoring program at the Mill under the GWDP consists of monitoring
at 22 point of compliance monitoring wells: MW-l, MW-2, MW-3, MW-3A, MW-5, MW-ll,
MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24, MW-25, MW-26,
MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32. The locations of these wells are
indicated on Figure 1.5-2.
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Part I.E.l.(c) of the GWDP requires that each point of compliance well must be sampled for the
following constituents:
Table 2.3-1
Groundwater Monitoring Constituents Listed in Table 2 of the GWDP
Nutrients:
Ammonia (as N)
Nitr!J.te & Nitrite (as N)
Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc
Radiologies:
Gross Alpha
Volatile Organic Compounds:
Acetone
Benzene
2-Butanone (MEK)
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Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)
Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
TDS
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Further, Part LE.l.( c) of the GWDP, requires that, in addition to pH, the following field parameters
must also be monitored:
• Depth to groundwater
• Temperature
• Tubidity
• Specific conductance,
and that, in addition to chloride and sulfate, the following general organics must also be monitored:
• Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
Sample frequency depends on the speed of ground water flow in the vicinity of each well. Parts
LE.l(a) and (b) of the GWDP provide that quarterly monitoring is required for all wells where
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local groundwater average linear velocity has been found by the Executive Secretary to be equal to
or greater than 10 feet/year, and semi-annual monitoring is required where the local groundwater
average linear velocity has been found by the Executive Secretary to be less than 10 feet/year.
Based on these criteria, quarterly monitoring is required at MW-11, MW-14, MW-25, MW-26,
MW-30 and MW-31, and semi-annual monitoring is required at MW-1, MW-2, MW-3, MW-3A,
MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24, MW-27, MW-28 , MW-29
and MW-32.
2.3.1.2 Deep Aquifer
The culinary well (one of the supply wells) is completed in the Navajo aquifer, at a depth of
approximately 1,800 feet below the ground surface. Due to the fact that the deep confined aquifer
at the site is hydraulically isolated from the shallow perched aquifer, no monitoring of the deep
aquifer is required under the GWDP.
2.3.1.3 Seeps and Springs
Pursuant to Part I.H.8 of the GWDP, Denison has a Sampling Plan for Seeps and Springs in the
Vicinity o/the White Mesa Uranium Mill, Revision: 0, March 17,2009 (the "SSSP") that requires
the Mill to perform groundwater sampling and analysis of all seeps and springs found
downgradient or lateral gradient from the tailings cells.
Under the SSSP, seeps and springs sampling is conducted on an annual basis between May 1 and
July 15 of each year, to the extent sufficient water is available for sampling, at five identified seeps
and springs near the Mill. The sampling locations were selected to correspond with those seeps
and springs sampled for the initial Mill site characterization performed in the 1978 ER, plus
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additional sites located by Denison, the BLM and Ute Mountain Ute Indian Tribe representatives.
Samples are analyzed for all ground water monitoring parameters found in Table 2.3-1 above.
The laboratory procedures utilized to conduct the analyses of the sampled parameters are those
utilized for groundwater sampling. In addition to these laboratory parameters, the pH,
temperature and conductivity of each sample will be measured and recorded in the field.
Laboratories selected by Denison to perform analyses of seeps and springs samples will be
required to be certified by the State of Utah in accordance with UAC R317-6-6.12.A.
The seeps and springs sampling events will be subject to the Mill's QAP, unless otherwise
specifically modified by the SSSP to meet the specific needs of this type of sampling.
2.3.1.4 Discharge Minimization Technology and Best Available Technology Standards and
Monitoring
2.3.1.4.1 General
Part I.D. of the GWDP sets out a number of Discharge Minimization Technology ("DMT") and
Best Available Technology ("BAT") standards that must be followed. Part I.E. ofthe GWDP sets
out the Ground Water Compliance and Technology Performance Monitoring requirements, to
ensure that the DMT and BAT standards are met. These provisions ofthe GWDP, along with the
White Mesa Mill Tailings Management System and Discharge Minimization (DMT) Monitoring
Plan, 9/08 Revision: Denison-6 (the "DMT Plan"), the Cell 4Aand 4B BAT Monitoring,
Operations and Maintenance Plan R.evision 2.0 (under review) and other plans and programs
deVeloped pursuant to such Parts of the GWDP, set out the methods and procedures for inspections
of the facility operations and for detecting failure of the system.
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In addition to the programs discussed above, the following additional DMT and BAT perfonnance
standards and associated monitoring are required under Parts I.D and I.E. of the GWDP
b) Tailings Cell Operation
Part I.D.2 of the GWDP provides that authorized operation and maximum disposal capacity in
each of the existing tailings Cells, 1, 2 and 3 shall not exceed the levels authorized by the License
and that under no circumstances shall the freeboard be less than three feet, as measured from the
top of the flexible membrane liner ("FML"). Part I.E.7(a) of the GWDP requires that the
wastewater pool elevations in Cells 1 and 3 must be monitored weekly to ensure compliance with
the maximum wastewater elevation criteria mandated by Condition 10.3 of the License.
Part I.D.2 further provides that any modifications by Denison to any approved engineering design
parameter at these existing tailings cells requires prior Executive Secretary approval, modification
of the GWDP and issuance of a construction pennit.
c) Slimes Drain Monitoring
Part I.D.3(b)(1) of the GWDP requires that Denison must at all times maintain the average
wastewater head in the slimes drain access pipe to be as low as reasonably achievable (ALARA) in
each tailings disposal cell, in accordance with the approved DMT Plan. Compliance will be
achieved when the average annual wastewater recovery elevation in the slimes drain access pipe,
detennined pursuant to the currently approved DMT Plan meets the conditions in Equation 1
specified in Part I.D.3(b)(1) ofthe GWDP.
Part I.E.7(b) of the GWDP requires that Denison must monitor and record monthly the depth to
wastewater in the slimes drain access pipes as described in the currently approved DMT Plan at
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Ce112, and upon commencement of de-watering activities, at Ce113, in order to ensure compliance
with Part LD.3(b)(l) of the GWDP.
d) Maximum Tailings Waste Solids Elevation
Part LD.3(c) of the GWDP requires that upon closure of any tailings cell, Denison must ensure that
the maximum elevation of the tailings waste solids does not exceed the top of the FML.
e) Wastewater Elevation in Roberts Pond
Part LD.3(e) of the GWDP requires that Roberts Pond be operated so as to provide a minimum
2-foot freeboard at all times, and that under no circumstances will the water level in the pond
exceed an elevation of 5,624 feet above mean sea level. Part LD.3(e) also provides that in the
event the wastewater elevation exceeds this maximum level, Denison must remove the excess
wastewater and place it into containment in Cell 1 within 72 hours of discovery.
Part LE.7(c) of the GWDP requires that the wastewater level in Roberts Pond must be monitored
and recorded weekly, in accordance with the currently approved DMT Plan, to determine
compliance with the DMT operations standard in Part LD.3(e) ofthe GWDP;
f) Inspection of Feedstock Storage Area
Part LD.3(f) of the GWDP requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the GWDP, and that storage of
feedstock materials at the facility outside of this defined area, must meet the requirements of Part
LD.11 of the GWDP. Part LD.l1 requires that Denison must store and manage feedstock
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materials outside the defined ore storage pad in accordance with the following minimum
performance requirements:
(i) Feedstock materials will be stored at all times in water-tight containers, and
(ii) Aisle ways will be provided at all times to allow visual inspection of each and every
feedstock container, or
(iii) Each and every feedstock container will be placed inside a water-tight overpack
prior to storage, or
(iv) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical
requirements:
A. A storage area composed of a hardened engineered surface of asphalt or
concrete, and
B. A storage area designed, constructed, and operated in accordance with
engineering plans and specifications approved in advance by the Executive
Secretary. All such engineering plans or specifications submitted shall
demonstrate compliance with Part I.DA of the GWDP, and
C. A storage area that provides containment berms to control stormwater run-on
and run-off, and
D. Stormwater drainage works approved in advance by the Executive Secretary, or
(v) Other storage facilities and means approved in advance by the Executive Secretary.
Part I.E.7(d) of the GWDP requires that Denison conduct weekly inspections of all feedstock
storage areas to:
(i) Confirm that the bulk feedstock materials are maintained within the approved
feedstock storage area specified by Part I.D.3(f) of the GWDP; and
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(ii) Verify that all alternate feedstock materials located outside the approved feedstock
storage area are stored in accordance with the requirements found in Part LD.11
oftheGWDP.
Part LE.7(f) further provides that Denison must conduct weekly inspections to verify that each
feed material container complies with the requirements of Part LD.11 ofthe GWDP.
The Mill's Standard Operating Procedure under the License for inspection ofthe Mill's ore pad is
contained in Section 3.3 of the DMT Plan.
g) Monitor and Maintain Inventory of Chemicals
Part LD.3(g) of the GWDP requires that for all chemical reagents stored at existing storage
facilities and held for use in the milling process, Denison must provide secondary containment to
capture and contain all volumes of reagent( s) that might be released at any individual storage area.
Response to spills, cleanup thereof, and required reporting must comply with the provisions of the
Mill's Emergency Response Plan, which is found in the Mill's Stormwater Best Management
Practices Plan, Revision 1.3; June 12, 2008 (a copy of which is included as Appendix C), as
stipulated by Parts I.D.10 and LH.16 of the GWDP. Part LD.3(g) further provides that for any
new construction of reagent storage facilities, such secondary containment and control must
prevent any contact of the spilled or otherwise released reagent or product with the ground surface.
Part LE.9 ofthe GWDP requires that Denison must monitor and maintain a current inventory of all
chemicals used at the facility at rates equal to or greater than 100 kg/yr. This inventory must be
maintained on-site, and must include:
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(iii) Identification of chemicals used in the milling process and the on-site laboratory;
and
(iv) Determination of volume and mass of each raw chemical currently held in storage
at the facility.
2.3.1.5 BAT Performance Standardsfor Cell4A and 4B
a) BAT Operations and Maintenance Plan
Part LD.6 and Part LD.13 of the GWDP provide that Denison must operate and maintain Cell 4A
and Cell 4B, respectively, so as to prevent release of wastewater to groundwater and the
environment in accordance with the Mill's Cell 4A and 4B BAT Monitoring, Operations and
Maintenance Plan, pursuant to Part LH.8 of the GWDP. The Mill's Cell 4A and Cell4B BAT
Monitoring, Operations and Maintenance Plan, 11/2010 Revision: Denison 2.0 (under review)
includes the following performance standards:
(i) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
(ii) The leak detection system maximum allowable daily leak rate shall not exceed
24,160 gallons/day for Ce114A or 26,145 gallons/day for Ce1l4B;
(iii) After Denison initiates pumping conditions in the slimes drain layer in Cell 4A or
CeIl4B, Denison will provide continuous declining fluid heads in the slimes drain
layer, in a manner equivalent to the requirements found in Part LD.3(b) for Cells 2
and 3; and
(iv) Under no circumstances shall the freeboard be less than 3 feet in Cell 4A or Cell
4B, as measured from the top of the FML.
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
b) Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan
The Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan also requires Denison to
perform the following monitoring and recordkeeping requirements.
(i) Weekly Leak Detection System (LDS) Monitoring -including:
A. Denison must provide continuous operation of the leak detection system
pumping and monitoring equipment, including, but not limited to, the
submersible pump, pump controller, head monitoring, and flow meter
equipment approved by the Executive Secretary. Failure of any pumping or
monitoring equipment not repaired and made fully operational within 24-hours
of discovery shall constitute failure of BAT and a violation of the GWDP;
B. Denison must measure the fluid head above the lowest point on the secondary
FML by the use of procedures and equipment approved by the Executive
Secretary. Under no circumstance shall fluid head in the leak detection system
sump exceed a I-foot level above the lowest point in the lower FML on the cell
floor. For purposes of compliance monitoring this I-foot distance shall equate
to 2.28 feet above the leak detection system transducer;
C. Denison must measure the volume of all fluids pumped from the leak detection
system. Under no circumstances shall the average daily leak detection system
flow volume exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for
CeIl4B; and
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
D. Denison must operate and maintain wastewater levels to provide a 3-foot
Minimum of vertical freeboard in tailings Cell 4A and Cell 4B. Such
measurements must be made to the nearest 0.1 foot.
(ii) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4A or Cell 4B slimes drain
system, monthly recovery head tests and fluid level measurements will be made in accordance
with the requirements of Parts J.D.3 and I.E. 7(b) of the GWDP and any plan approved by the
Executive Secretary.
2.3.1.6 Stormwater Management and Spill Control Requirements
Part J.D. 1 0 of the GWDP reqUIres that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the facility in accordance with the Mill's stormwater
best management practices plan. The Mill's Stormwater Best Management Practices Plan,
Revision 1.3: June 12,2008 (a copy of which is included as Appendix C) includes the following
provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.4(C);
b) Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Executive Secretary in
accordance with UAC 19-5-114.
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2.3.1.7 Tailings and Slimes Drain Sampling
Page 2-22
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Part I.E.8 of the GWDP requires that, on an annual basis, Denison must collect wastewater quality
samples from each wastewater source at each tailings cell at the facility, including surface
impounded wastewaters, and slimes drain wastewaters, pursuant to the Mill's Tailings and Slimes
Drain Sampling Program, Revision 0, November 20, 2008 (the "WQSP"). All such sampling
must be conducted in August of each calendar year.
The purpose of the WQSP is to characterize the source term quality of all tailings cell wastewaters,
including impounded wastewaters or process waters in the tailings cells, and wastewater or
leachates collected by internal slimes drains. The WQSP requires:
• Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
• Samples of tailings and slimes drain material will be analyzed at an offsite contract
laboratory and subjected to the analytical parameters included in Table 2 of the GWDP
(see Table 2.3-1 above) and general inorganics listed in Part I.E.l(d)(2)(ii) ofthe GWDP,
as well as semi-volatile organic compounds;
• A detailed description of all sampling methods and sample preservation techniques to be
employed;
• The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and as shown in Section 8.2 ofthe Mill's QAP;
• The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317-6-6.l2A; and
• 30-day advance notice of each annual sampling event must be gIVen, to allow the
Executive Secretary to collect split samples of all tailings cell wastewater sources.
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
The tailings and slimes drain sampling events are subject to the Mill's QAP, unless otherwise
specifically modified by the WQSP to meet the specific needs of this type of sampling.
2.3.2 Monitoring and Inspections Required Under the License
2.3.2.1 Environmental Monitoring
The environmental monitoring program is designed to assess the effect of Mill process and
disposal operations on the unrestricted environment. Delineation of specific equipment and
procedures is presented in the Mill's Environmental Protection Manual. included as Appendix A
to the 2007 License Renewal Application.
c) Ambient Air Monitoring
(i) Ambient Particulate
Airborne radionuclide particulate sampling is performed at five locations, termed BHV -1, BHV -2,
BHV-4, BHV-5 and BHV-6. With the approval of the NRC and effective November, 1995,
BHV-3 was removed from the active air particulate monitoring program. At that time, the Mill
proposed (and NRC determined) that a sufficient air monitoring data base had been compiled at
station BHV-3 to establish a representative airborne particulate radionuclide background for the
Mill. BHV -6 was installed by the Mill at the request of the White Mesa Ute Community. This
station began operation in July of 1999 and provides airborne particulate information in the
southerly direction between the Mill and the White Mesa Ute Community. Figure 2.3-1 shows
the locations of these air particulate monitoring stations.
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OENISOJ) .... MINES Denison Mines (USA) Corp.
Project
REVISIONS
Date I B'
11109 dis
1/13'11 8M
1127/11 8M
WHITE MESA MILL
County: SAN JUAN I State: UT
Location:
Figure 2.3-1
High Volume Air Monitoring Stations
Reclamation Plan Revision 3.2 -final
cale: aa ahown
Autnor: HRR
Page 2-25
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
The present sampling system consists of high volume particulate samplers utilizing mass flow
controllers to maintain an air flow rate of approximately 32 standard cubic feet per minute.
Samplers are operated continuously with a goal for on-stream operating period at ninety percent.
Filter rotation is weekly with quarterly site compo siting for particulate radionuclide analysis.
Analysis is done for U-natural, Th-230, Ra-226, and Pb-210.
See Section 3. 13.1.7(a) ofthe 2007 ER for a summary of historic monitoring results for airborne
particulate.
(ii) Ambient Radon
With the approval of the NRC, Radon-222 monitoring at the BHV stations was discontinued in
1995, due to the unreliability of monitoring equipment available at that time to detect the new 10
CFR standard of 0.1 pCi/l. From that time until the present, the Mill demonstrated compliance
with the requirements ofR313-15-301 by calculation authorized by the NRC in September 1995
and as contemplated by R313-15-302 (2) (a).
This calculation was performed by use of the MILDOS code for estimating environmental
radiation doses for uranium recovery operations (Strenge and Bender 1981) in 1991 in support of
the Mill's 1997 license renewal and more recently in 2007 in support of the 2007 License Renewal
Application, by use of the updated MILDOS AREA code (Argonne 1998). The analysis under
both the MILDOS and MILDOS AREA codes assumed the Mill to be processing high grade
Arizona Strip ores at full capacity, and calculated the concentrations of radioactive dust and radon
at individual receptor locations around the Mill. Specifically, the modeling under these codes
assumed the following conditions:
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• 730,000 tons of ore per year
• Average grade of 0.53% U30g
Page 2-26
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
• Yellowcake production of 4,380 tons ofU30g per year (8.8 million pounds U30 g per year).
Based on these conditions, the MILDOS and MILDOS AREA codes calculated the combined total
effective dose equivalent from both air particulate and radon at the current nearest residence
(approximately 1.2 miles north of the Mill), i.e., the individual member of the public likely to
receive the highest dose from Mill operations, as well as at all other receptor locations, to be below
the ALARA goal of 10 mrem/yr for air particulate alone as set out in R313-15-101(4). Mill
operations are constantly monitored to ensure that operating conditions do not exceed the
conditions assumed in the above calculations. If conditions are within those assumed above,
radon has been calculated to be within regulatory limits. If conditions exceed those assumed
above, then further evaluation will be performed in order to ensure that doses to the public
continue to be within regulatory limits. Mill operations to date have never exceeded the License
conditions assumed above.
In order to determine if detection equipment has improved since 1995, the Mill has, commencing
with the fIrst quarter of 2007, re-instituted direct measurements of radon at the fIve air particulate
monitoring locations currently utilized for air particulate sampling. The reliability of this data is
currently under review by Denison.
d) External Radiation
TLD badges, as supplied by Landauer, Inc., or equivalent, are utilized at BHV-l, BHV-2, BHV-3,
BHV-4, BHV-5 and BHV-6 to determine ambient external gamma exposures (see Figure 2.3-1).
System quality assurances are determined by placing a duplicate monitor at one site continuously.
Exchanges of TLD badges are on a quarterly basis. Badges consist of a minimum of fIve TLD
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
chips. Measurements obtained from location BHV-3 have been designated as background due to
BHV-3's remoteness from the Mill site (BHV-3 is located approximately 3.5 miles west of the
Mill site). For further procedural information see Section 4.3 of the Mill's Environmental
Protection Manual, included as Appendix A to the 2007 License Renewal Application. See
Section 3.13.1.7(c) of the 2007 ER for a summary of historic monitoring results for external
radiation.
e) Soil and Vegetation
(i) Soil Monitoring
Soil samples from the top one centimeter of surface soils are collected annually at each ofBHV-l,
BHV-2, BHV-3, BHV-4 and BHV-5 (see Figure 2.3-1). A minimum oftwo kilograms of soil is
collected per site and analyzed for U -natural and Ra-226. For further procedural information see
Section 4.1 of the Mill's Environmental Protection Manual included as Appendix A to the 2007
License Renewal Application. See Section 3.13.1.7.1 of the 2007 ER for a summary of the
historic results for soil monitoring. The 2007 ER concludes that the results of sampling are low,
less than the unrestricted release limits.
(i) Vegetation Monitoring
Forage vegetation samples are collected three times per year from animal grazing locations to the
northeast (near BHV-I (the meteorological station)), northwest (to the immediate west of the site)
and southwest (by BHV-4) of the Mill site. Samples are obtained during the grazing season, in
the late fall, early spring, and in late spring. A minimum of three kilograms of vegetation are
submitted from each site for analysis of Ra-226 and Pb-210. For further procedure information
see Section 4.2 of the Mill's Environmental Protection Manual included as Appendix A to the
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
2007 License Renewal Application. See Section 3.l3.7(d) of the 2007 ER for a summary of the
historic results for vegetation monitoring. The 2007 ER concludes that the most recent results
indicate no increase in uptake ofRa-226 and Pb-21 0 in vegetation.
d) Meteorological
Meteorological monitoring is done at a site near BHV -1. The sensor and recording equipment are
capable of monitoring wind velocity and direction, from which the stability classification is
calculated. Data integration duration is one-hour with hourly recording of mean speed, mean
wind direction, and mean wind stability (as degrees sigma theta).
The data from the meteorological station is retrieved monthly by down loading onto a Campbell
Scientific data module, or the equivalent. The data module is sent to an independent
meteorological contractor where the module is downloaded to a computer record, and the data is
correlated and presented in a Semi-Annual Meteorological Report.
Monitoring for precipitation consists of a daily log of precipitation using a standard NOAA rain
gauge, or the equivalent, installed near the administrative office, consistent with NOAA
specifications.
Windrose data is summarized in a format compatible with MILDOS and UDAD specifications for
40 CFR 190 compliance. For further procedural information see Section 1.3 of the Mill's
Environmental Protection Manual included as Appendix A to the 2007 License Renewal
Application. A windrose for the site is set out in Figure 1.1-1.
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e) Point Emissions
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Stack emission monitoring from yellowcake facilities follows EPA Method 5 procedures and
occurs on a quarterly basis, during operation of the facility. Particulate sampling is analyzed for
Unat on a quarterly basis and for Th-230, Ra-226, and Pb-210 on a semi-annual basis. Demister
and ore stack emission monitoring follows EPA Method 5 procedure on a semi-annual basis,
during operation ofthe facility. Particulate samples are analyzed for Unat, Th-230, Ra-226, and
Pb-21O. Monitored data includes scrubber system operation levels, process feed levels,
particulate emission concentrations, isokinetic conditions, and radionuclide emission
concentrations. For further procedure information see Section 1.4 of the Mill's Environmental
Protection Manual included as Appendix A to the 2007 License Renewal Application. Historic
stack emission data are summarized in Section 3.13.1.7(e) of the 2007 ER.
f) Surface Water Monitoring
Surface water monitoring is conducted at two locations adjacent to the Mill facility known as
Westwater Canyon and Cottonwood Creek. Samples are obtained annually from Westwater and
quarterly from Cottonwood using grab sampling. For Westwater Creek, samples will be of
sediments if a water sample is not available. Field monitored parameters and laboratory
monitored parameters are listed in Table 2.3-2. For further procedural information see Section
2.1 of the Mill's Environmental Protection Manual included as Appendix A to the 2007 License
Renewal Application. See Section 3.7.4 of the 2007 ER for a summary of the historic results for
surface water monitoring.
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Table 2.3-2
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater Creek and Cottonwood Creek
Field Requirements
1. Temperature C;
2. Specific Conductivity umhos at 25 C;
3. pH at 25 C;
4. Sample date;
5. Sample ID Code;
Vendor Laboratory Requirements
Semiannual * Ouarterly
One gallon Unfiltered and Raw One gallon Unfiltered and Raw
One gallon Unfiltered, Raw and preserved to One gallon Unfiltered, Raw and Preserved to
~H <2 with HN03 pH <2 with HN03
Total Dissolved Solids Total Dissolved Solids
Total Suspended Solids Total Suspended Solids
Gross Alpha
Suspended Unat
Dissolved Unat
Suspended Ra-226
Dissolved Ra-226
Suspended Th-230
Dissolved Th-230 .. *Semlannual sample must be taken a mlnlllUm of four months apart.
**Annual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuc1ides and LLDs reported in /lCi/ml
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
2.3.2.2 Additional Monitoring and Inspections Required Under the License
Under the License daily, weekly, and monthly inspection reporting and monitoring are required by
NRC Regulatory Guide 8.31, Information Relevant to Ensuring that Occupational Radiation
Exposures at Uranium Recovery Facilities will be As Low As is Reasonable Achievable, Revision
1, May 2002 ("Reg Guide 8.31 "), by Section 2.3 of the Mill's ALARA Program and by the DMT
Plan, over and above the inspections described above that are required under the GWDP. A copy
of the Mill's ALARA Program is included as Appendix I to the 2007 License Renewal
Application.
a) Daily Inspections
Three types of daily inspections are performed at the Mill under the License:
(i) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the Mill's Radiation Safety Officer ("RSO") or
designated health physics technician should conduct a daily walk-through (visual) inspection of all
work and storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping that would minimize unnecessary contamination.
These inspections are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the Mill's Radiation Protection Office.
(ii) Operating Foreman Inspections
30 CFR Section 56.18002 of the Mine Safety and Health Administration regulations requires that a
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
competent person designated by the operator must examine each working place at least once each
shift for conditions which may adversely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
(iii) Daily Tailings Inspection
Paragraph 2.2 of the DMT Plan requires that during Mill operation, the Shift Foreman, or other
person with the training specified in paragraph 2.4 ofthe DMT Plan, designated by the RSO, will
perform an inspection of the tailings line and tailings area at least once per shift, paying close
attention for potential leaks and to the discharges from the pipelines. Observations by the
Inspector are recorded on the appropriate line on the Mill's Daily Inspection Data form.
b) Weekly Inspections
Three types of weekly inspections are performed at the Mill under the License:
(i) Weekly Inspection of the Mill Forms
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman, or their
respective designees, shall conduct a weekly inspection of all Mill areas to observe general
radiation control practices and review required changes in procedures and equipment. Particular
attention is to be focused on areas where potential exposures to personnel might exist and in areas
of operation or locations where contamination is evident.
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(ii) Weekly Ore Storage Pad Inspection Forms
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Paragraph 3.3 of the DMT Plan requires that weekly feedstock storage area inspections will be
performed by the Radiation Safety Department, to confirm that the bulk feedstock materials are
stored and maintained within the defined area of the ore pad and that all alternate feed materials
located outside the defined ore pad area are maintained within water tight containers. The results
of these inspections are recorded on the Mill's Ore Storage/Sample Plant Weekly Inspection
Report.
(iii) Weekly Tailings and DMT Inspection
Paragraphs 3.1 and 3.2 of the DMT Plan require that weekly inspections of the tailings area and
DMT requirements be performed by the radiation safety department.
c) Monthly Reports
Two types of monthly reports are prepared by Mill staff:
(i) Monthly Radiation Safety Reports
At least monthly, the RSO reviews the results of daily and weekly inspections, including a review
of all monitoring and exposure data for the month and provides to the Mill Manager a monthly
report containing a written summary of the month's significant worker protection activities
(Section 2.3.4 ofthe Mill's ALARA Program).
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(ii) Monthly Tailings Inspection Reports
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Paragraph 4 of the DMT Plan requires that a Monthly Inspection Data form be completed for the
monthly tailings inspection. This inspection is typically performed in the fourth week of each
month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
d) Quarterly Tailings Inspections
Paragraph 5 of the DMT Plan requires that the RSO or his designee perform a quarterly tailings
inspection.
e) Annual Evaluations
The following annual evaluations are performed under the License, as set out in Section 6 of the
DMTPlan.
(i) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered professional engineer (PE), who has experience and training in the area of geotechnical
aspects of retention structures. The technical evaluation includes an on-site inspection of the
tailings management system and a thorough review of all tailings records for the past year. The
Technical Evaluation also includes a review and summary ofthe annual movement monitor survey
(see paragraph (ii) below).
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
All tailings cells and corresponding dikes are inspected for signs of erosion, subsidence, shrinkage,
and seepage. The drainage ditches are inspected to evaluate surface water control structures.
In the event tailings capacity evaluations were performed for the receipt of alternate feed material
during the year, the capacity evaluation forms and associated calculation sheets will be reviewed to
ensure that the maximum tailings capacity estimate is accurate. The amount of tailings added to
the system since the last evaluation will also be calculated to determine the estimated capacity at
the time of the evaluation.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached. Records will also be reviewed to summarize observations of potential
concern. The evaluation also involves discussion with the Environmental and/or Radiation
Technician and the RSO regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area are taken. The training of individuals is also
reviewed as a part ofthe Annual Technical Evaluation.
The registered engineer obtains copies of selected tailings inspections, along with the monthly and
quarterly summaries of observations of concern and the corrective actions taken. These copies are
then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Directing Dam Safety Engineer, State of Utah, Natural Resources.
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(ii) Annual Movement Monitor Survey
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Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
A movement monitor survey is conducted by a licensed surveyor annually in accordance with
Condition 11.3 of the License, approved on June 17, 2010. The movement monitor survey
consists of surveying monitors along dikes 4A-S and 4B-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.
(iii) Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system in Cells 1, 2 or 3, a sample will be
collected on an annual basis. This sample will be analyzed according to the conditions set forth in
License Condition 11.3.C. The results ofthe analysis will be reviewed to determine the origin of
the solution.
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OENISOJ)~~ Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
MINES Tel: [phone]
Fax: [phone]
www.denisonmines.com
Section 3.0 Reclamation Plan
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State ofUtahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: [phone]
Fax: [phone]
Page 3-1
Revision 3.2 -Final
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White Mesa Mill Reclamation Plan
3.0 RECLAMATION PLAN
This section provides an overview of the Mill location and property; details the facilities to be
reclaimed; and describes the design criteria applied in this Plan. Reclamation plans and
specifications are presented in Attachment A. Attachment B presents the quality plan for
construction activities. Attachment C presents cost estimates for reclamation. Attachments D
through H present additional material test results and design calculations to support the
reclamation plan.
3.1 Location and Property Description
The White Mesa Mill is located six miles south of Blanding, Utah on US Highway 191 on a parcel
ofland encompassing all or part of Sections 21, 22, 27, 28, 29,32, and 33 ofT37S, R22E, and
Sections 4, 5, 6, 8,9, and 16 ofT38S, R22E, Salt Lake Base and Meridian described as follows
(Figure 3.1-1):
The south half of Section 21; the southeast quarter of the southeast quarter of
Section 22; the northwest quarter of the northwest quarter and lots 1 and 4 of
Section 27 all that part of the southwest quarter of the northwest quarter and the
northwest quarter southwest quarter of Section 27 lying west of Utah State
Highway 163; the northeast quarter of the northwest quarter, the south half of the
northwest quarter, the northeast quarter and the south half of Section 28; the
southeast quarter of the southeast quarter of Section 29; the east half of Section 32
and all of Section 33, Township 37 South, Range 22 East, Salt Lake Base and
Meridian. Lots 1 through 4, inclusive, the south half of the north half, the
southwest quarter, the west half of the southeast quarter, the west half of the east
half of the southeast quarter and the west half of the east half of the east half of the
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southeast quarter of Section 4; Lots 1 througb 4, inclusive, the south balf of the
north half and the south half of Section 5 (all)' Lot 1 and 2, the south half of the
northeast quarter and the south half of Section 6 (E1I2); the northeast quarter of
Section 8; all of Section 9 and all of Section 16, Township 38 South, Range 22 East
Salt Lake Base and Metidian. Additonalland is controlled by 46 Mill site claims.
Total land holdings are approximately 5,415 acres.
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White Mesa Mill Reclamation Plan
3.2 Facilities to be Reclaimed
See Figure 3.2-1 for a general layout of the mill yard and related facilities and the restricted area
boundary.
3.2.1 Summary of Facilities to be Reclaimed
The facilities to be reclaimed include the following:
• Cell 1 (evaporation). Cell 1 was previously referred to as Cell I-I . It is now referred to
as CellI;
• Cells 2 and 3, 4A and 4B (tailings);
• Mill buildings and equipment;
• On-site contaminated areas; and
• Off-site contaminated areas (i.e., potential areas affected by windblown tailings).
The reclamation of the above facilities will include the following:
• Placement of contaminated soils, crystals, and synthetic liner material and any
contaminated underlying soils from CellI into tailings Cells 4A or 4B.
• Placement of a compacted clay liner on a portion of the Cell 1 impoundment area to be
used for disposal of contaminated materials and debris from the Mill site
decommissioning. (the CellI Tailings Area)
• Placement of materials and debris from Mill Decommissioning into tailings Cells 4A or 4B
or in the Cell 1 Tailings Area;
• Placement of an engineered multi-layer cover over the entire area of Cells 2, 3, 4A and 4B
and the CellI Tailings Area.
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• Construction of runoff control and diversion channels as necessary;
• Reconditioning of Mill and ancillary areas; and
• Reclamation of borrow sources.
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3.2.2 Tailings and Evaporative Cells
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White Mesa Mill Reclamation Plan
The following subsections describe the cover design and reclamation procedures for Cells 1-I, 2, 3,
4A and 4B. Complete engineering details and text are presented in the Tailings Cover Design
report, Appendix D, previously submitted. Additional infonnation is provided in Attachments D,
E and F to this submittal.
3.2.2.1 Soil Cover Design
A six-foot thick soil cover to be placed over the uranium tailings and mill decommissioning
materials in the Cell 1-1 Tailings Area, Cell 2, Cell 2, Cell 4A and Cell 4B was designed using
on-site materials that will contain tailings and radon emissions in compliance with regulations of
the NRC, the State of Utah, and by reference, the EPA. The cover consists of a one-foot thick
layer of clay, available from within the site boundaries (Section 16 or stockpiles on site), below
two feet of random fill (frost barrier), available from stockpiles on site. The clay is underlain by
three feet (minimum) random fill soil (platfonn fill), also available on site. In addition to the soil
cover, a minimum three-inch (on the cover top) to 8-inch (on the cover slopes) layer of riprap
material will be placed over the compacted random fill to stabilize slopes and provide long-tenn
erosion resistance (see Attachments D and H for characterization of cover materials).
Uranium tailings soil cover design requirements for regulatory compliance include:
Attenuate radon flux to an acceptable level (20 picoCuries-per meter squared-per second
[pCi/m2/sec]) (NRC, 1989) and 40 CFR 61.250-61.256;
Minimize infiltration into the reclaimed tailings cells;
Maintain a design life of up to 1,000 years or to the extent reasonably achievable, and in
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any case for at least 200 years; and
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Provide long-term slope stability and geomorphic durability to withstand erosional forces
of wind, the probable maximum flood event, and a horizontal ground acceleration of 0.1 g
due to seismic events.
Several models/analyses were utilized in simulating the soil cover effectiveness: radon flux
attenuation, hydrologic evaluation of infiltration, freeze/thaw effects, soil cover erosion
protection, and static and pseudostatic slope stability analyses. These analyses and results are
discussed in detail in Sections 3.3.1 through 3.3.5, and calculations are also shown in the Tailings
Cover Design report, (Appendix D, Attachment E and Attachment F). The soil cover (from top to
the bottom) will consist of: (1) minimum of three inches of riprap material; (2) two feet of
compacted random fill; (3) one foot of compacted clay; and (4) minimum three feet of compacted
random fill soil.
The final grading plan is presented in Section 5, Figure 5.1-1. As indicated on the figures, the top
slope ofthe soil cover will be constructed at 0.2 percent and the side slopes, as well as transitional
areas between cells, will be graded to five horizontal to one vertical (5H: 1 V).
A minimum of three feet random fill is located beneath the compacted fill and clay layers (see
cross-sections on Figures 5.1-2 and 5.1-3). The purpose of the fill is to raise the base of the cover
to the desired subgrade elevation. In many areas, the required fill thickness will be much greater.
However, the models and analyses presented in the Tailings Cover Design report (Appendix D)
were performed conservatively, assuming only a three-foot layer. For modeling purposes, this
lower, random fill layer was considered as part of the soil cover for performing the radon flux
attenuation calculation, as it effectively contributes to the reduction of radon emissions (see
Section 3.3.2). The fill was also evaluated in the slope stability analysis (see Section 3.3.6).
However, it is not defined as part of the soil cover for other design calculations (infiltration,
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freeze/thaw, and cover erosion).
3.2.2.2 Cell 1-1
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Cell 1, used during mill operations solely for evaporation of process liquids, is the northernmost
existing cell and is located immediately west ofthe mill. It is also the highest cell in elevation, as
the natural topography slopes to the south. The drainage area above and including the cell is 216
acres. This includes drainage from the Mill site.
Cell 1 will be evaporated to dryness. The synthetic liner and raffinate crystals will then be
removed and placed in tailings Cells 4A or 4B. Any contaminated soils below the liner will be
removed and also placed in the tailings cells. Based on current regulatory criteria, the current
plan calls for excavation of the residual radioactive materials to be designed to ensure that the
concentration of radium-226 in land averaged over any area of 100 square meters does not exceed
the background level by more than:
• 5 pCil g, averaged over the first 15 cm of soil below the surface, and
• 15 pCil g, averaged over a 15 cm thick layer of soil more than 15 cm below the surface.
A portion of Cell 1 (i.e., the Cell 1 Tailings Area), adjacent to and running parallel to the
downstream cell dike, will be used for permanent disposal of contaminated materials and debris
from the mill site decommissioning and windblown cleanup. The actual area of Cell I-I Tailings
Area needed for storage of additional material will depend on the status of Cell 4A and 4B at the
time of final mill decommissioning. A portion of the Mill area decommissioning material may be
placed in Ce1l4A or 4B if space is available, but for purposes of the reclamation design the entire
quantity of contaminated materials from the Mill site decommissioning is assumed to be placed in
the Cell 1 Tailings Area. This results in approximately 10 acres of the Cell 1 Tailings Area and
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being utilized for pennanent tailings storage. The remaining area of Cell 1 will then be
breached and converted to a sedimentation basin. All runoff from the Cell 1-1 Tailings Area, the
Mill area and the area immediately north of Cell 1 will be routed into the sedimentation basin and
will discharge onto the natural ground via the channel located at the southwest comer of the basin.
The channel is designed to accommodate the PMF flood.
The HEC-l model was used to detennine the PMF and route the flood through the sedimentation
basin (Attachment G). The peak flow was detennined to be 1,344 cubic feet per second (cfs). A
20-foot wide channel will discharge the flow to the natural drainage. During the local stonn PMF
event, the maximum discharge through the channel will be 1,344 cfs. The entire flood volume
will pass through the discharge channel in approximately four hours.
At peak flow, the velocity in the discharge channel will be 7.45 feet per second (fps). The
maximum flow depth will be 1.45 feet. This will be a bedrock channel and the allowable velocity
for a channel ofthis type is 8-10 fps, therefore no riprap is required. A free board depth of 0.5 feet
will be maintained for the PMP event.
3.2.2.3 Cell 2
Cell 2 will be filled with tailings and covered with a multi-layered engineered cover to a minimum
cover thickness of six feet. The final cover will drain to the south at a 0.2 percent gradient.
The cover will be as described in Section 3.2.2.1 above, and will consist of a mini mum of three feet
of random fill (platfonn fill), followed by a clay radon barrier of one foot in thickness, and two feet
of upper random fill (frost barrier) for protection ofthe radon barrier. A minimum ofthree inches
of rock will be utilized as annor against erosion. Side slopes will be graded to as: 1 slope and will
have 0.67 feet (8 inches) of rock annor protection.
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3.2.2.4 Cell 3
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Cell 3 will be filled with tailings, debris and contaminated soils and covered with the same
multi-layered engineered cover as Cell 2.
3.2.2.5 Ce114L4
Cell 4A will be filled with tailings, debris and contaminated soils and covered with the same
multi-layered engineered cover as Cell 2 and Cell 3.
3.2.2.6 Ce1l4B
Cell 4B will be filled with tailings, debris and contaminated soils and covered with the same
multi-layered engineered cover as Cell 2, Cell 3 and Cell 4A.
3.2.3 Mill Decommissioning
A general layout of the mill area is shown in Figure 3.2.3-1.
3.2.3.1 Mill Building, Equipment, and Other 11e.(2) Byproduct Material
The uranium and vanadium sections, including ore reclaim, grinding, pre-leach, leach, CCD, SX,
and precipitation and drying circuits as well as the alternate feed circuit, decontamination pads,
scale house, sample plant, truck shop and all other structures on site will be decommissioned as
follows:
All equipment including instrumentation, process piping, electrical control and switchgear, and
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contaminated structures will be removed. Contaminated concrete foundations will be demolished
and removed or covered with soil as required. Uncontaminated equipment, structures and waste
materials from Mill decommissioning may be disposed of by sale, transferred to other
company-owned facilities, transferred to an appropriate off-site solid waste site, or disposed of in
one of the tailings cells. Contaminated equipment, structures and dry waste materials from Mill
decommissioning, contaminated soils underlying the Mill areas, and ancillary contaminated
materials will be disposed of in tailings Cell 4A, Cell 4B, or the Cell 1 Tailings Area. All other
11e.(2) byproduct material on site will be disposed of in Ce1l4A or Ce1l4B.
Debris and scrap will have a maximum dimension of 20 feet and a maximum volume of 30 cubic
feet. Material exceeding these limits will be reduced to within the acceptable limits by breaking,
cutting or other approved methods. Empty drums, tanks or other objects having a hollow volume
greater than five cubic feet will be reduced in volume by at least 70 percent. If volume reduction
is not feasible, openings shall be made in the object to allow soils or other approved material to
enter the object.
Debris and scrap will be spread across the designated areas to avoid nesting and to reduce the
volume of voids present in the placed mass. Stockpiled soils, and/or other approved material
shall be placed over and into the scrap in sufficient amounts to fill the voids between the large
pieces and the volume within the hollow pieces to form a coherent mass.
See also Section 3.1 of Attachment A.
The estimated reclamation costs for surety are set out in Attachment C. Attachment C will be
reviewed and updated on a yearly basis.
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3.2.3.2 Mill Site
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Contaminated areas on the Mill site will be primarily superficial and includes the ore storage area
and surface contamination of some roads. All ore will have been previously removed from the
ore stockpile area or will be transported and disposed of as contaminated material. All
contaminated materials will be excavated and be disposed in one of the tailings cells. The depth
of excavation will vary depending on the extent of contamination and will be governed by the
criteria in Attachment A, Section 3.2.
Windblown material is defined as Mill-derived contaminants dispersed by wind to surrounding
areas. Windblown contaminated material detected by a gamma survey using the criteria in
Attachment A, Section 3.2, will be excavated and disposed in one ofthe tailings cells.
Disturbed areas will be covered, graded and vegetated as required. The proposed grading plan for
the Mill site and ancillary areas is shown on Figure A-3.2-1 in Attachment A.
3.3 Design Criteria
As required by Part I.H.1 of the GWDP, Denison is in the process of completing an infiltration and
contamination transport model of the [mal tailings cover system to demonstrate the long-term
ability of the cover to protect nearby groundwater quality. Upon review of such modeling, the
executive Secretary will determine if changes to the cover systems as set outin the iPlan are needed
to ensure compliance with the performance criteria contained in part LD.8 of the GWDP.
Although the modeling has not been completed, modeling results to date suggest that some
changes to the final cover design as set out in this Plan will be needed. However, as the details of
such re-design have not been finalized at this time, the approved 2000 cover deiagn and basis will
continue to be used for this version of the Plan. This Plan will be amended in the future to
incorporate any changes to the design of the tailings cover system that result from the current
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modeling effort.
The design criteria summaries in this section are adapted from Tailings Cover Design, Mill (Titan,
1996). A copy of the Tailings Cover Design report is included in Appendix D, previously
submitted. It contains all of the calculations used in design discussed in this section. Additional
design information is included in Attachments D through H to this submittal.
3.3.1 Regulatory Criteria
Information contained in 10 CFR Part 20, Appendix A, 10 CFR Part 40, and Appendix A to 10
CFR Part 40 (which are incorporated by reference into UAC R313-24-4), and 40 CFR Part 192
was used as criteria in final designs under this Plan. In addition, the following documents also
provided guidance:
• EP A, 1994, The Hydrologic Evaluation of Landfill Performance (HELP) Model, Version
3, EPAl600/R-941168b, September;
• NRC, 1989, "Regulatory Guide 3.64 (Task WM-503-4) Calculation of Radon Flux
Attenuation by Earthen Uranium Mill Tailings Covers, March;
• NRC, 1980, Final Staff Technical Position Design of Erosion Protection Covers for
Stabilization of Uranium Mill Tailings Sites, August;
• NUREG/CR-4620, Nelson, J. D., Abt, S. R., et. aI., 1986, Methodologies for Evaluating
Long-Term Stabilization Designs of Uranium Mill Tailings Impoundments, June;
• NUREG/CR-46S1, 1987, Development of Riprap Design Criteria by Riprap Testing in
Flumes: Phase 1, May;
• U. S. Department of Energy, 1988, Effect of Freezing and Thawing on UMTRA Covers,
Albuquerque, New Mexico, October; and.
• NUREG 1620,2003, Standard Review Plan for the review ofa reclamation Plan for Mill
Tailings Sites Under Title II of the uranium Mill Tailings radiation Control Act of 1978.
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As mentioned above, the requirements set out in Part I.D.8 of the GWDP require that the cover
system for each tailings cell will be designed and constructed to meet the following minimum
requirements for a period of not less than 200 years:
• Minimize the infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barrier;
• Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML elevation internal to any disposal cell, i.e. create a
"bathtub" effect; and
• Ensure that groundwater quality at the compliance monitoring wells deosn ot exceed the
GWQSs or GWCLs specified in Part I.C.l and table 2 of the GWDP.
Upon completion of the Infiltration Analysis, this Plan will be revised as necessary to ensure
compliance with these requirements.
3.3.2 Radon Flux Attenuation
The EPA rules in 40 CFR Part 192 require that a "uranium tailings cover be designed to produce
reasonable assurance that the radon-222 release rate would not exceed 20 pCi/m2/sec for a period
of 1,000 years to the extent reasonably achievable and in any case for at least 200 years when
averaged over the disposal area over at least a one year period" (NRC, 1989). NRC regulations
presented in 10 CFR Part 40 (incorporate by reference into UAC R313-24-4) also restrict radon
flux to less than 20 pCi/m2/sec. The following sections present the analyses and design for a soil
cover which meets this requirement.
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3.3.2.1 Predictive Analysis
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The soil cover for the tailings cells at White Mesa Mill was evaluated for attenuation of radon gas
using the digital computer program, RADON, presented in the NRC's Regulatory Guide 3.64
(Task WM 503-4) entitled Calculation of Radon Flux Attenuation by Earthen Uranium Mill
Tailings Covers. The RADON model calculates radon-222 flux attenuation by multi-layered
earthen uranium mill tailings covers, and determines the minimum cover thickness required to
meet NRC and EPA standards. The RADON model uses the following soil properties in the
calculation process:
• Soil layer thickness [centimeters (cm)];
• Soil porosity (percent);
• Density [grams-per-cubic centimeter (gm/cm3)];
• Weight percent moisture (percent);
• Radium activity (PiC/g);
• Radon emanation coefficient (unitless); and
• Diffusion coefficient [square centimeters-per-second (cm2/sec)].
Physical and radiological properties for tailings and random fill were analyzed by Chen and
Associates (1987) and Rogers and Associates (1988). Clay physical data from Section 16 was
analyzed by Advanced Terra Testing (1996) and Rogers and Associates (1996). Additional
testing of cover materials was performed in April 1999. The test results are included in
Attachment D. See Appendix D, previously submitted, for additional laboratory test results.
The RADON model was performed for the following cover section (from top to bottom):
• two feet compacted random fill (frost barrier);
• one foot compacted clay; and
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• a minimum ofthree feet random fill occupying the freeboard space between the tailings
and clay layer (platform fill).
The top one foot ofthe lower random fill, clay layer and two foot upper random fill are compacted
to 95 percent maximum dry density. The top riprap layer was not included as part of the soil
cover for the radon attenuation calculation.
The most current RADON modeling is included in Attachment F.
The results of the RADON modeling exercise, based on two different compaction scenarios, show
that the uranium tailings cover configuration will attenuate radon flux emanating from the tailings
to a level of 18.2 to 19.8 pCi/m2/sec. This number was conservatively calculated as it takes into
account the freeze/thaw effect on the uppermost part (6.8 inches) of the cover (Section 3.3.4).
The soil cover and tailing parameters used to run the RADON model, in addition to the RADON
input and output data files, are presented in Appendix D as part of the Radon Calculation brief (See
Appendix B in the Tailings Cover Design report, previously submitted in its entirety as Appendix
D) and the most current model included as Attachment F to this submittal. Based on the model
results, the soil cover design of six-foot thickness will meet the requirements of 40 CFR Part 192
and 10 CFR Part 40.
3.3.2.2 Empirical Data
Radon gas flux measurements have been made at the White Mesa Mill tailings piles over Cells 2
and 3 (see Appendix D). Currently Cell 2 is fully covered and Cell 3 is partially covered with
three to four feet of random fill. During the period 2004 through 2007, ce112 was only partially
covered with such random fill. Radon flux measurements, averaged over the covered areas, were
as follows (Denison 2004-2008):
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Cell 2
Cell 3
Table 3.3-1
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Average Radon Flux from Tailings Cells 2004-2008
(pCilm2/sec)
2004 2005 2006 2007 2008
13.9 7.1 7.9 13.5 3.9
10.8 6.2 10.0 8.9 3.1
Empirical data suggest that the random fill cover, alone, is currently providing an effective barrier
to radon flux. Thus, the proposed tailings cover configuration, which is thicker, moisture
adjusted, contains a clay layer, and is compacted, is expected to attenuate the radon flux to a level
below that predicted by the RADON model. The field radon flux measurements confirm the
conservatism of the cover design. This conservatism is useful, however, to guarantee compliance
with applicable regulations under long term climatic conditions over the required design life of
200 to 1,000 years.
3.3.3 Infiltration Analysis
The tailings ponds at White Mesa Mill are lined with synthetic geomembrane liners which under
certain climatic conditions, could potentially lead to the long-term accumulation of water from
infiltration of precipitation. Therefore, the soil cover was evaluated to estimate the potential
magnitude of infiltration into the capped tailings ponds. The Hydrologic Evaluation of Landfill
Performance (HELP) model, Version 3.0 (EPA, 1994) was used for the analysis. HELP is a quasi
two-dimensional hydrologic model of water movement across, into, through, and out of capped
and lined impoundments. The model utilizes weather, soil, and engineering design data as input
to the model, to account for the effects of surface storage, snowmelt, run-off, infiltration,
evapotranspiration, vegetative growth, soil moisture storage, lateral subsurface drainage, and
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unsaturated vertical drainage on the specific design, at the specified location.
The soil cover was evaluated based on a two-foot compacted random fill layer over a one-foot
thick, compacted clay layer. The soil cover layers were modeled based on material placement at a
minimum of 95 percent of the maximum dry density, and within two percent of the optimum
moisture content per American Society for Testing and Materials (ASTM) requirements. The top
riprap layer and the bottom random fill layer were not included as part of the soil cover for
infiltration calculations. These two layers are not playing any role in controlling the infiltration
through the cover material.
The random fill will consist of clayey sands and silts with random amounts of gravel and rock-size
materials. The average hydraulic conductivity of several samples of random fill was calculated,
based on laboratory tests, to be 8.87 x 10-7 cm/sec. The hydraulic conductivity ofthe clay source
from Section 16 was measured in the laboratory to be 3.7 x 10-8 cm/sec. Geotechnical soil
properties and laboratory data are presented in Appendix D.
Key HELP model input parameters include:
Blanding, Utah, monthly temperature and precipitation data, and HELP model default
solar radiation, and evapotranspiration data from Grand Junction, Colorado. Grand
Junction is located northeast of Blanding in similar climate and elevation;
Soil cover configuration identifying the number of layers, layer types, layer thickness, and
the total covered surface area;
Individual layer material characteristics identifying saturated hydraulic conductivity,
porosity, wilting point, field capacity, and percent moisture; and
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Soil Conservation Service runoff curve numbers, evaporative zone depth, maximum leaf
area index, and anticipated vegetation quality.
Water balance results, as calculated by the HELP model, indicate that precipitation would either
run off the soil cover or be evaporated. Thus, model simulations predict zero infiltration of
surface water through the soil cover, as designed. These model results are conservative and take
into account the freeze/thaw effects on the uppermost part (6.8 inches) of the cover (See Section
1.3 of the Tailings Cover Design report, Appendix D). The HELP model input and output for the
tailings soil cover are presented in the HELP Model calculation brief included in previously
submitted Appendix D.
As mentioned above, potential infiltration into the tailings cap is currently ebing remodelined in
the Infiltration Analysis. Any changes to this Plan that are required as a result of such remodeling
will be incorporated into a subsequent revision to this Plan.
3.3.4 Freeze/Thaw Evaluation
The tailings soil cover of one foot of compacted clay covered by two feet of random fill was
evaluated for freeze/thaw impacts. Repeated freeze/thaw cycles have been shown to increase the
bulk soil permeability by breaking down the compacted soil structure.
The soil cover was evaluated for freeze/thaw effects using the modified Berggren equation as
presented in Aitken and Berg (1968) and recommended by the NRC (U.S. Department of Energy,
1988). This evaluation was based on the properties of the random fill and clay soil, and
meteorological data from both Banding, Utah and Grand Junction, Colorado.
The results of the freeze/thaw evaluation indicate that the anticipated maximum depth of frost
penetration on the soil cover would be less than 6.8 inches. Since the random fill layer is two feet
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thick, the frost depth would be confined to this layer and would not penetrate into the underlying
clay layer. The performance of the soil cover to attenuate radon gas flux below the prescribed
standards, and to prevent surface water infiltration, would not be compromised. The input data
and results of the freeze/thaw evaluation are presented in the Effects of Freezing on Tailings
Covers Calculation brief included as Appendix E in the Tailings Cover Design report, which was
previously submitted as Appendix D.
3.3.5 Soil Cover Erosion Protection
A riprap layer was designed for erosion protection of the tailings soil cover. According to NRC
guidance, the design must be adequate to protect the soil/tailings against exposure and erosion for
200 to 1,000 years (NRC, 1990). Currently, there is no standard industry practice for stabilizing
tailings for 1,000 years. However, by treating the embankment slopes as wide channels, the
hydraulic design principles and practices associated with channel design were used to design
stable slopes that will not erode. Thus, a conservative design based on NRC guidelines was
developed. Engineering details and calculations are summarized in the Erosion Protection
Calculation brief provided in Appendix F in the Tailings Cover Design report, which was
previously submitted as Appendix D.
Riprap cover specifications for the top and side slopes were determined separately as the side
slopes are much steeper than the slope of the top ofthe cover. The size and thickness ofthe riprap
on the top of the cover was calculated using the Safety Factor Method (NUREG/CR-4651, 1987),
while the Stephenson Method (NUREG/CR-4651, 1987) was used for the side slopes. These
methodologies were chosen based on NRC recommendations (1990).
By the Safety Factor Method, riprap dimensions for the top slope were calculated in order to
achieve a slope "safety factor" of 1.1. For the top ofthe soil cover, with a slope of 0.2 percent, the
Safety Factor Method indicated a median diameter (D50) riprap of 0.28 inches is required to
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stabilize the top slope. However, this dimension must be modified based on the long-term
durability ofthe specific rock type to be used in construction. The suitability of rock to be used as
a protective cover has been assessed by laboratory tests to determine the physical characteristics of
the rocks (See Attachment H). The North pit source has an over sizing factor of 9.85%. The
riprap sourced from this pit should have a D50 size of at least 0.31 inches and should have an
overall layer thickness of at least three inches on the top of the cover.
Riprap dimensions for the side slopes were calculated using Stephenson Method equations. The
side slopes ofthe cover are designed at 5H:l V. At this slope, Stephenson's Method indicated the
unmodified riprap Dso of3.24 inches is required. Again, assuming that the North pit material will
be used, the modified Dso size of the riprap should be at least 3.54 inches with an overall layer
thickness of at least 8 inches.
The potential of erosion damage due to overland flow, sheetflow, and channel scouring on the top
and side slopes of the cover, including the riprap layer, has been evaluated. Overland flow
calculations were performed using site meteorological data, cap design specifications, and
guidelines set by the NRC (NUREG/CR-4620, 1986). These calculations are included in
Appendix F of the Tailings Cover Design report (Appendix D previously submitted). According
to the guidelines, overland flow velocity estimates are to be compared to "permissible velocities,"
which have been suggested by the NRC, to determine the potential for erosion damage. When
calculated, overland flow velocity estimates exceed permissible velocities, additional cover
protection should be considered. The permissible velocity for the tailings cover (including the
riprap layer) is 5.0 to 6.0 feet-per-second (ft.lsec.) (NUREG/CR-4620). The overland flow
velocity calculated for the top of the cover is less than 2.0 ft.lsec., and the calculated velocity on
the side slopes is 4.9 ft.lsec.
The need for a filter or bedding material beneath the riprap was evaluated using methods presented
in NUREG/CR-4620. The function of the filter is to prevent stone penetration into the cover, and
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to prevent soil erosion of the cover at the riprap/soil cover interface. The likelihood of soil
erosion at the interface is evaluated by calculating the interstitial flow velocity through the riprap.
Interstitial velocities were calculated using procedures presented by Abt et al. (1991), which
updates the Leps relationship that is presented in NUREG/CR-4620. Details ofthese calculations
are presented in Attachment G. The interstitial velocities on the top slope and the toe apron are
sufficiently low that a bedding layer is not necessary. However, the interstitial velocity within the
riprap on the side slopes is within the range of values where bedding is conditionally
recommended. Because of the wide difference in grain size distributions between the riprap and
the random fill, it is recommended that a 6-inch layer of bedding material be placed between these
two materials.
A rock apron will be constructed at the toe of high slopes and in areas where runoff might be
concentrated (See Figure A-5.1-4). The design of the rock aprons is detailed in Attachment G.
3.3.6 Slope Stability Analysis
Static and pseudostatic analyses were performed to establish the stability of the side slopes ofthe
tailings soil cover. The side slopes are designed at an angle of 5H:IV. Because the side slope
along the southern section of Cell 4A is the longest and the ground elevation drops rapidly at its
base, this slope was determined to be critical and is thus the focus of the stability analyses.
The computer software package GSLOPE, developed by MITRE Software Corporation, has been
used for these analyses to determine the potential for slope failure. GSLOPE applies Bishop's
Method of slices to identify the critical failure surface and calculate a factor of safety (FOS). The
slope geometry and properties ofthe construction materials and bedrock are input into the model.
These data and drawings are included in the Stability Analysis of Side Slopes Calculation brief
included in Appendix G of the Tailings Cover Design report. For this analysis, competent
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bedrock is designated at 10 feet below the lowest point of the foundation [i.e., at a 5,540-foot
elevation above mean sea level (msl)]. This is a conservative estimate, based on the borehole logs
supplied by Chen and Associates (1979), which indicate bedrock near the surface.
3.3.6.1 Static Analysis
For the static analysis, a Factor of Safety ("FOS") of 1.5 or more was used to indicate an acceptable
level of stability. The calculated FOS is 2.91, which indicates that the slope should be stable
under static conditions. Results of the computer model simulations are included in Appendix G
of the Tailings Cover Design report.
3.3.6.2 Pseudostatic Analysis (Seismicity)
The slope stability analysis described above was repeated under pseudostatic conditions in order to
estimate a FOS for the slope when a horizontal ground acceleration ofO.10g is applied. The slope
geometry and material properties used in this analysis are identical to those used in the stability
analysis. A FOS of 1.0 or more was used to indicate an acceptable level of stability under
pseudostatic conditions. The calculated FOS is 1.903, which indicates that the slope should be
stable under dynamic conditions. Details ofthe analysis and the simulation results are included in
Appendix G ofthe Tailings Cover Design report.
In June of 1994, Lawrence Livermore National Laboratory ("LLNL") published a report entitled
Seismic Hazard Analysis of Title II Reclamation Plans, (Lawrence Livermore National
Laboratory, 1994) which included a section on seismic activity in southern Utah. In the LLNL
report, a horizontal ground acceleration of 0.12g was proposed for the White Mesa site. The
evaluations made by LLNL were conservative to account for tectonically active regions that exist,
for example, near Moab, Utah. Although, the LLNL report states that " ... [Blanding] is located in
a region known for its scarcity of recorded seismic events, II the stability of the cap design slopes
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using the LLNL factor was evaluated. The results of a sensitivity analysis reveal that when
considering a horizontal ground acceleration of 0.12g, the calculated FOS is 1.778 which is still
above the required value of 1.0, indicating adequate safety under pseudo static conditions. This
analysis is also included in Appendix G of the Tailings Cover Design report. A probabilistic
seismic risk analysis (See Attachment E) was performed in April 1999 during an evaluation of
cover stability.
3.3.7 Soil Cover-Animal Intrusion
To date, the White Mesa site has experienced only minor problems with burrowing animals. In
the long term, no measures short of continual annihilation of target animals can prevent burrowing.
However, reasonable measures will discourage burrowing including:
Total cover thickness of at least six-feet;
Compaction of the upper three feet of soil cover materials to a minimum of95 percent, and
the lower three feet to 80-90 percent, based on a standard Proctor (ASTM D-698); and
Riprap placed over the compacted random fill material.
3.3.8 Cover Material/Cover Material Volumes
Construction materials for reclamation will be obtained from on-site locations. Fill material will
be available from the stockpiles that were generated from excavation of the cells for the tailings
facility. If required, additional materials are available locally to the west of the site. A clay
material source, identified in Section 16 at the southern end of the White Mesa Mill site, will be
used to construct the one-foot compacted clay layer. Riprap material will be produced from
off-site sources.
Detailed material quantities calculations are provided in Attachment C, Cost Estimates for
Reclamation of White Mesa Mill Facilities, as part ofthe volume and costing exercise.
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OENISOJ)~~ Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
MINES
Attachment A
Tel: [phone]
Fax : [phone]
www.denisonmines.com
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
Plans and Specifications
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State of Utahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: [phone]
Fax: [phone]
ATTACHMENT A
PLANS AND SPECIFICATIONS
FOR
RECLAMATION
OF
WHITE MESA FACILITIES
BLANDING, UTAH
PREPARED BY
DENISON MINES (USA) CORP.
INDEPENDENCE PLAZA
1050 17TH STREET, SUITE 950
DENVER, CO 80265
January 2011 Revision 3.2 -Final
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TABLE OF CONTENTS
Page A-i
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Page No.
1.0 GENERAL ...................................................................................................................... A-I
2.0 CELL 1 RECLAMATION ............................................................................................. A-l
2.1 Scope ................................................................................................................... A-I
2.2 Removal of Contaminated Materials .................................................................. A-I
2.2.1 Raffinate Crystals .................................................................................... A-I
2.2.2 Synthetic Liner ........................................................................................ A-2
2.2.3 Contaminated Soils .............................................................................. '" A-2
2.3 Cell 1 Tailings Area A-3
2.3.1 General .................................................................................................... A-3
2.3.2 Materials ................................................................................................. A-3
2.3.3 Borrow Sources ....................................................................................... A-3
2.4 Liner Construction .............................................................................................. A-3
2.4.1 General .................................................................................................... A-3
2.4.2 Placement and Compaction ..................................................................... A-4
2.4.2.1 Methods ....................................................................................... A-4
2.4.2.2 Moisture and Density Control. .................................................... A-5
2.5 Sedimentation Basin ........................................................................................... A-6
3.0 MILL DECOMMISSIONING ........................................................................................ A-8
3.1 Mill ...................................................................................................................... A-8
3.2 Mill Site ............................................................................................................ A-IO
3.3 Windblown Contamination ............................................................................... A-I 0
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TABLE OF CONTENTS (continued) Page No.
3.3.1 Guidance ............................................................................................... A-13
3.3.2 General Methodology ........................................................................... A-13
3.3.3 Scoping Survey ..................................................................................... A-14
3.3.4 Characterization and Remediation Control Surveys ............................. A-16
3.3.5 Final Survey .......................................................................................... A-16
3.3.6 Employee Health and Safety ................................................................. A-16
3.3.7 Environment Monitoring ...................................................................... A-18
3.3.8 Quality Assurance ................................................................................. A-18
4.0 PLACEMENT METHODS .......................................................................................... A-20
4.1 Scrap and Debris ............................................................................................... A-21
4.2 Contaminated Soils and Raffmate Crystals ...................................................... A-22
4.3 Compaction Requirements ................................................................................ A-22
5.0 RECLAMATION CAP -CELLS .L..2, 3 , 4A, AND 4B .............................................. A-22
5.1 Earth Cover ....................................................................................................... A-22
5.2 Materials ........................................................................................................... A-23
5.2.1 Physical Properties ................................................................................ A-23
5.2.2 Borrow Sources ..................................................................................... A-28
5.3 Cover Construction ........................................................................................... A-28
5.3.1 General .................................................................................................. A-28
5.3.2 Placement and Compaction ................................................................... A-29
5.3.2.1 Methods ..................................................................................... A-29
5.3.2.2 Moisture and Density Control. .................................................. A-30
5.4 Monitoring Cover Settlement ........................................................................... A-31
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TABLE OF CONTENTS (continued) Page No.
5.4.1 Temporary Settlement Plates ................................................................ A-31
5.4.1.1 General ...................................................................................... A-31
5.4.1.2 Installation ................................................................................. A-31
5.4.1.3 Monitoring Settlement Plates .................................................... A-32
6.0 ROCK PROTECTION .................................................................................................. A-34
6.1 General .............................................................................................................. A-34
6.2 Materials ........................................................................................................... A-35
6.3 Placement .......................................................................................................... A-36
7.0 QUALITY CONTROL/QUALITY ASSURANCE ..................................................... A-36
7.1 Quality Plan ...................................................................................................... A-36
7.2 Implementation ................................................................................................. A-37
7.3 Quality Control Procedures ............................................................................... A-37
7.4 Frequency of Quality Control Tests .................................................................. A-37
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1.0 GENERAL
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The specifications presented in this section cover the reclamation of the Mill facilities.
2.0 CELL 1 RECLAMATION
2.1 Scope
The reclamation of Cell 1 (previously referred to as Cell I-I) consists of evaporating the cell to
dryness, removing raffinate crystals, synthetic liner and any contaminated soils, and constructing
a clay lined area adjacent to and parallel with the existing Cell 1 dike for permanent disposal of
contaminated material and debris from the Mill site decommissioning, referred to as the Cell 1
Tailings Area. A sedimentation basin will then be constructed and a drainage channel provided.
2.2 Removal of Contaminated Materials
2.2.1 Raffinate Crystals
Raffinate crystals will be removed from Cell 1 and transported to the tailings cells. It is
anticipated that the crystals will have a consistency similar to a granular material when brought
to the cells, with large crystal masses being broken down for transport. Placement of the crystals
will be performed as a granular fill, with care being taken to avoid nesting of large sized
material. Voids around large material will be filled with finer material or the crystal mass
broken down by the placing equipment. Actual placement procedures will be evaluated by the
QC officer during construction as crystal materials are brought and placed in the cells.
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2.2.2 Synthetic Liner
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The PVC liner will be cut up, folded (when necessary), removed from Cell 1, and transported to
the tailings cells. The liner material will be spread as flat as practical over the designated area.
After placement, the liner will be covered as soon as possible with at least one foot of soil,
crystals or other materials for protection against wind, as approved by the QC officer.
2.2.3 Contaminated Soils
The extent of contamination of the Mill site will be determined by a scintillometer survey. If
necessary, a correlation between scintillometer readings and U-nat/Radium-226 concentrations
will be developed. Scintillometer readings can then be used to define cleanup areas and to
monitor the cleanup. Soil sampling will be conducted to confirm that the cleanup results in a
concentration of Radium-226 averaged over any area of 100 square meters that does not exceed
the background level by more than:
5 pCilg averaged over the first 15 cm of soils below the surface, and
15 pCil g averaged over a 15 cm thick layer of soils more than 15 cm below the surface
Where surveys indicate the above criteria have not been achieved, the soil will be removed to
meet the criteria. Soil removed from Cell 1 will be excavated and transported to the tailings
cells. Placement and compaction will be in accordance with Section 4.0 of these Plans and
Specifications.
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2.3 CellI Tailings Area
2.3.1 General
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A clay lined area will be constructed adjacent to and parallel with the existing Cell 1 dike for
permanent disposal of contaminated material and debris from the Mill site decommissioning (the
Cell 1 Tailings Area). The area will be lined with 12 inches of clay prior to placement of
contaminated materials and installation of the final reclamation cap.
2.3.2 Materials
Clays will have at least 40 percent passing the No. 200 sieve. The minimum liquid limit of these
soils will be 25 and the plasticity index will be 15 or greater. These soils will classify as CL, SC
or CH materials under the Unified Soil Classification System.
2.3.3 Borrow Sources
Clay will be obtaned from suitable materials stockpiled on site during cell construction or will be
imported from borrow areas located in Section 16, T38S, R22E, SLM.
2.4 Liner Construction
2.4.1 General
Placement of clay liner materials will be based on a schedule determined by the availability of
contaminated materials removed from the Mill decommissioning area in order to maintain
optimum moisture content of the clay liner prior to placing of contaminated materials
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2.4.2 Placement and Compaction
2.4.2.1 Methods
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Placement of fill will be monitored by a qualified individual with the authority to stop work and
reject material being placed. The full 12 inches of the clay liner fill will be compacted to 95%
maximum dry density per ASTM D 698.
In all layers of the clay liner will be such that the liner will, as far as practicable, be free of
lenses, pockets, streaks or layers of material differing substantially in texture, gradation or
moisture content :from the surrounding material. Oversized material will be controlled through
selective excavation of stockpiled material, observation of placement by a qualified individual
with authority to stop work and reject material being placed and by culling oversized material
:from the fill.
If the moisture content of any layer of clay liner is outside of the Allowable Placement Moisture
Content specified in Table A-5.3.2.l-1, it will be moistened and/or reworked with a harrow,
scarifier, or other suitable equipment to a sufficient depth to provide relatively uniform moisture
content and a satisfactory bonding surface before the next succeeding layer of clay material is
placed. If the compacted surface of any layer of clay liner material is too wet, due to
precipitation, for proper compaction of the earthfill material to be placed thereon, it will be
reworked with harrow, scarifier or other suitable equipment to reduce the moisture content to the
required level shown in Table A-5.3.2.1-1. It will then be recompacted to the earthfill
requirements.
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No clay material will be placed when either the materials, or the underlying material, is frozen or
when ambient temperatures do not permit the placement or compaction of the materials to the
specified density, without developing frost lenses in the fill.
2.4.2.2 Moisture and Density Control
As far as practicable, the materials will be brought to the proper moisture content before
placement, or moisture will be added to the material by sprinkling on the fill. Each layer of the
fill will be conditioned so that the moisture content is uniform throughout the layer prior to and
during compaction. The moisture content of the compacted liner material will be within the
limits of standard optimum moisture content as shown in Table A-5.3.2.1-1. Material that is too
dry or too wet to permit bonding of layers during compaction will be rejected and will be
reworked until the moisture content is within the specified limits. Reworking may include
removal, re-harrowing, reconditioning, rerolling, or combinations of these procedures.
Density control of compacted clay will be such that the compacted material represented by
samples having a dry density less than the values shown in Table A-5.3.2.1-1 will be rejected.
Such rejected material will be reworked as necessary and rerolled until a dry density equal to or
greater than the percent of its standard Proctor maximum density shown in Table A-5.3.2.1-1.
To determine that the moisture content and dry density requirements of the compacted liner
material are being met, field and laboratory tests will be made at specified intervals taken from
the compacted fills as specified in Section 7.4, "Frequency of Quality Control Tests."
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2.5 Sedimentation Basin
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Cell 1 will then be breached and constructed as a sedimentation basin. All runoff from the Mill
area and imtnediately north of the cell will be routed into the sedimentation basin and will
discharge onto the natural ground via the channel located at the southwest comer of the basin.
The channel is designed to accommodate the PMF flood.
A sedimentation basin will be constructed in CellI as shown in Figure A-2.2.4-1. Grading will
be performed to promote drainage and proper functioning of the basin. The drainage channel out
of the sedimentation basin wilJ be constructed to the lines and grades as shown.
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INSERT FIGURE A~2.2.4-1
SEDIMENTATION BASIN DETAILS
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3.0 MILL DECOMMISSIONING
The following subsections detail decommissioning plans for the Mill buildings and equipment;
the Mill site; and windblown contamination.
3.1 Mill
The uranium and vanadium processing areas of the Mill, including all equipment, structures and
support facilities, will be decommissioned and disposed of in tailings or buried on site as
appropriate. All equipment, including tankage and piping, agitation equipment, process control
instrumentation and switchgear, and contaminated structures will be cut up, removed and buried
in tailings prior to final cover placement. Concrete structures and foundations will be
demolished and removed or covered with soil as appropriate. These decommissioned areas
would include, but not be limited to the following:
Coarse ore bin and associated equipment, conveyors and structures.
Grind circuit including semi-autogeneous grind (SAG) Mill, screens, pumps and
cyclones.
The three preleach tanks to the east of the Mill building, including all tankage,
agitation equipment, pumps and piping.
The seven leach tanks inside the main Mill building, including all agitation
equipment, pumps and piping.
The counter-current decantation (CCD) circuit including all thickeners and
equipment, pumps and piping.
Uranium precipitation circuit, including all thickeners, pumps and piping.
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The two yellow cake dryers and all mechanical and electrical support equipment,
including uranium packaging equipment.
The clarifiers to the west of the Mill building including the preleach thickener
(PLT) and claricone.
The boiler and all ancillary equipment and buildings.
The entire vanadium precipitation, drying and fusion circuit.
All external tankage not included in the previous list including reagent tanks for
the storage of acid, ammonia, kerosene, water, dry chemicals, etc. and the
vanadium oxidation circuit.
The uranium and vanadium solvent extraction (SX) circuit including all SX and
reagent tankage, mixers and settlers, pumps and piping.
The SX building.
The Mill building.
The Alternate Feed processing circuit
Decontamination pads
The office building.
The shop and warehouse building.
The sample plant building.
The Reagent storage building.
The sequence of demolition would proceed so as to allow the maximum use of support areas of
the facility such as the office and shop areas. It is anticipated that all major structures and large
equipment will be demolished with the use of hydraulic shears. These will speed the process,
provide proper sizing of the materials to be placed in tailings, and reduce exposure to radiation
and other safety hazards during the demolition. Any uncontaminated or decontaminated
equipment to be considered for salvage will be released in accordance with the terms of License
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Condition 9.10. As with the equipment for disposal, any contaminated soils from the Mill area
will be disposed of in the tailings facilities in accordance with Section 4.0 of the Specifications.
3.2 Mill Site
Contaminated areas on the Mill site will be primarily superficial and include the ore storage area
and surface contamination of some roads. All ore and alternate feed materials will have been
previously removed from the ore stockpile area. All contaminated materials will be excavated
and be disposed in one of the tailings cells in accordance with Section 4.0 of these Plans and
Specifications. The depth of excavation will vary depending on the extent of contamination and
will be based on the criteria in Section 2.2.3 of these Plans and Specifications. All other 11 e.(2)
byproduct materials will be disposed of in the tailings cells.
All ancillary contaminated materials including pipelines will be removed and will be disposed of
by disposal in the tailing cells in accordance with Section 4.0 of these Plans and Specifications.
Disturbed areas will be covered, graded and vegetated as required. The proposed grading plan
for the Mill site and ancillary areas is shown on Figure A-3.2-1.
3.3 Windblown Contamination
Windblown contamination is defined as Mill derived contaminants dispersed by the wind to
surrounding areas. The potential areas affected by windblown contamination will be surveyed
using scintillometers taking into account historical operational data from the Semi-annual
Effluent Reports and other guidance such as prevailing wind direction and historical background
data. Areas covered by the existing Mill facilities and ore storage pad, the tailings cells and
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adjacent stockpiles of random fill, clay and topsoil, will be excluded from the survey. Materials
from these areas will be removed in conjunction with final reclamation and decommissioning of
the Mill and tailings cells.
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MILL SITE AND ORE PAD FINAL GRADING PLAN
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3.3.1 Guidance
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The necessity for remedial actions will be based upon an evaluation prepared by Denison, and
approved by the Executive Secretary, of the potential health hazard presented by any windblown
materials identified. The assessment will be based upon analysis of all pertinent radiometric and
past land use information and will consider the feasibility, cost-effectiveness, and environmental
impact of the proposed remedial activities and final land use. All methods utilized will be
consistent with the guidance contained in NUREG-5849: "Manual for Conducting Radiological
Surveys in Support of License Termination."
3.3.2 General Methodology
The facility currently monitors soils for the presence of Ra-226, Th-230 and natural uranium,
such results being presented in the second semi-annual effluent report for each year. Guideline
values for these materials will be determined and will form the basis for the cleanup of the Mill
site and surrounding areas. For purposes of determining possible windblown contamination,
areas used for processing of uranium ores as well as the tailings and evaporative facilities will be
excluded from the initial scoping survey, due to their proximity to the uranium recovery
operations. Those areas include:
The Mill building, including CCD, Pre-Leach Thickener area, uranium drying and
packaging, clarifying, and preleach.
The SX building, including reagent storage immediately to the east of the SX
building.
The alternate feed circuit.
The ore pad and ore feed areas.
Tailings Cells No.2, 3, 4A, and 4B.
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Evaporation Cell No.1.
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The remaining areas of the Mill will be divided up into two areas for purposes of windblown
determinations:
The restricted area, less the above areas; and,
A halo around the restricted area.
Areas within the restricted area, as shown on Figure 3.2-1 will be initially surveyed on a 30 x 30
meter grid as described below in Section 3.3.3. The halo around the suspected area of
contamination will also be initially surveyed on a 50 x 50 meter grid using methodologies
described below in Section 3.3.3. Any areas which are found to have elevated activity levels will
be further evaluated as described in Sections 3.3.4 and 3.3.5. Initial surveys of the areas
surrounding the Mill and tailings area have indicated potential windblown contamination only to
the north and east of the Mill ore storage area, and to the southwest of Cell 3, as indicated on
Figure 3.2-1.
3.3.3 Scoping Survey
Areas contaminated through process activities or windblown contamination from the tailings
areas will be remediated to meet applicable cleanup criteria for Ra-226, Th-230 and natural
uranium. Contaminated areas will be remediated such that the residual radionuclides remaining
on the site, that are distinguishable from background, will not result in a dose that is greater than
that which would result from the radium soil standard (5 pCi/gram above background).
Soil cleanup verification will be accomplished by use of several calibrated beta/gamma
instruments. Multiple instruments will be maintained and calibrated to ensure availability during
Remediation efforts.
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Initial soil samples will be chemically analyzed to detennine on-site correlation between the
gamma readings and the concentration of radium, thorium and uranium, in the samples. Samples
will be taken from areas known to be contaminated with only processed uranium materials (i.e.
tailings sand and windblown contamination) and areas in which it is suspected that unprocessed
uranium materials (i.e. ore pad and windblown areas downwind of the ore pad) are present. The
actual number of samples used will depend on the correlation of the results between gamma
readings and the Ra-226 concentration. A minimum of 35 samples of windblown tailings
material, and 15 samples of unprocessed ore materials is proposed. Adequate samples will be
taken to ensure that graphs can be developed to adequately project the linear regression lines and
the calculated upper and lower 95 percent confidence levels for each of the instruments. The 95
percent confidence limit will be used for the guideline value for correlation between gamma
readings and radium concentration. Because the unprocessed materials are expected to have
proportionally higher values of uranium in relation to the radium and thorium content, the
correlation to the beta/gamma readings are expected to be different than readings from areas
known to be contaminated with only processed materials. Areas expected to have contamination
from both processed and unprocessed materials will be evaluated on the more conservative
correlation, or will be cleaned to the radium standard which should ensure that the uranium is
removed.
Radium concentration in the samples should range from 25% of the guideline value (5 pCi/gram
above background) for the area of interest, through the anticipated upper range of radium
contamination. Background radium concentrations have been gathered over a 16 year period at
sample station BHV-3 located upwind and 5 miles west of the Mill. The radium background
concentration from this sampling is 0.93 pCi/gram. This value will be used as an interim value
for the background concentration. Prior to initiating cleanup of windblown contamination, a
systematic soil sampling program will be conducted in an area within 3 miles of the site, in
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geologically similar areas with soil types and soil chemistry similar to the areas to be cleaned, to
determine the average background radium concentration, or concentrations, to be ultimately used
for the cleanup.
An initial scoping survey for windblown contamination will be conducted based on analysis of
all pertinent radiometric and past land use information. The survey will be conducted using
calibrated beta/gamma instruments on a 30 meter by 30 meter grid. Additional surveys will be
conducted in a halo, or buffer zone, around the projected impact area. The survey in the buffer
area will be conducted on a 50 meter by 50 meter grid. Grids where no readings exceed 75% of
the guideline value (5 pCi/gram above background) will be classified as unaffected, and will not
require remediation.
The survey will be conducted by walking a path within the grid as shown in Figure A-3.3-1.
These paths will be designed so that a minimum of 10% of the area within the grid sidelines will
be scanned, using an average coverage area for the instrument of one (1) meter wide. The
instrument will be swung from side to side at an elevation of six (6) inches above ground level,
with the rate of coverage maintained within the recommended duration specified by the specific
instrument manufacturer. In no case will the scanning rate be greater than the rate of 0.5 meters
per second (m/sec) specified in NUREG/CR-5849 (NRC, 1992).
3.3.4 Characterization and Remediation Control Surveys
After the entire subarea has been classified as affected or unaffected, the affected areas will be
further scanned to identify areas of elevated activity requiring cleanup. Such areas will be
flagged and sufficient soils removed to, at a minimum, meet activity criteria. Following such
remediation, the area will be scanned again to ensure compliance with activity criteria. A
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calibrated beta/gamma instrument capable of detecting activity levels of less than or equal to 25
percent of the guideline values will be used to scan all the areas of interest.
3.3.5 Final Survey
After removal of contamination, final surveys will be taken over remediated areas. Final surveys
will be calculated and documented within specific 10 meter by 10 meter grids with sample point
locations as shown in Figure A-3.3.2. Soil samples from 10% of the surveyed grids will be
chemically analyzed to confirm the initial correlation factors utilized and confirm the success of
cleanup effort for radium, thorium and uranium. Ten (10) percent of the samples chemically
analyzed will be split, with a duplicate sent to an off site laboratory. Spikes and blanks, equal in
number to 10 percent of the samples that are chemically analyzed, will be processed with the
samples.
3.3.6 Employee Health and Safety
Programs currently in place for monitoring of exposures to employees will remain in effect
throughout the time period during which tailings cell reclamation, Mill decommissioning and
clean up of windblown contamination are conducted. This will include personal monitoring
(film badges/TLD's) and the ongoing bioassay program. Access control will be maintained at
the Restricted Area boundary to ensure employees and equipment are released from the site in
accordance with the current License conditions. In general, no changes to the existing programs
are expected and reclamation activities are not expected to increase exposure potential beyond
the current levels.
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3.3.7 Environment Monitoring
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Existing environmental monitoring programs will continue during the time period in which
reclamation and decommissioning is conducted. This includes monitoring of surface and
groundwater, airborne particulates, radon, soils and vegetation, according to the existing License
conditions. In general, no changes to the existing programs are expected and reclamation
activities are not expected to increase exposure potential beyond the current levels.
3.3.8 Quality Assurance
At least six (6) months prior to beginning of decommission activities, a detailed Quality
Assurance Plan will be submitted for Executive Secretary approval. The Plan will be in
accordance with NRC Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring
Programs. In general, the Plan will detail Denison's organizational structure and responsibilities,
qualifications of personnel, operating procedures and instructions, record keeping and document
control, and quality control in the sampling procedure and outside laboratory. The Plan will
adopt the existing quality assurance/quality control procedures utilized in compliance with the
existing License.
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4.0 PLACEMENT METHODS
4.1 Scrap and Debris
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The scrap and debris will have a maximum dimension of 20 feet and a maximum volume of 30
cubic feet. Scrap exceeding these limits will be reduced to within the acceptable limits by
breaking, cutting or other approved methods. Empty drums, tanks or other objects having a
hollow volume greater than five cubic feet will be reduced in volume by at least 70 percent. If
volume reduction is not feasible, openings will be made in the object to allow soils, tailings
and/or other approved materials to enter the object at the time of covering on the tailings cells.
The scrap, after having been reduced in dimension and volume, if required, will be placed on the
tailings cells as directed by the QC officer.
Any scrap placed will be spread across the top of the tailings cells to avoid nesting and to reduce
the volume of voids present in the disposed mass. Stockpiled soils, contaminated soils, tailings
and/or other approved materials will be placed over and into the scrap in sufficient amount to fill
the voids between the large pieces and the volume within the hollow pieces to form a coherent
mass. It is recognized that some voids will remain because of the scrap volume reduction
specified, and because of practical limitations of these procedures. Reasonable effort will be
made to fill the voids. The approval of the Site Manager or a designated representative will be
required for the use of materials other than stockpiled soils, contaminated soils or tailings for the
purpose of filling voids.
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4.2 Contaminated Soils and Raffinate Crystals
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The various materials will not be concentrated in thick deposits on top of the tailings, but will be
spread over the working surface as much as possible to provide relatively uniform settlement and
consolidation characteristics of the cleanup materials.
4.3 Compaction Requirements
The scrap, contaminated soils and other materials for the first lift will be placed over the existing
tailings surface to a depth of up to four feet thick in a bridging lift to allow access for placing and
compacting equipment. The first lift will be compacted by the tracking of heavy equipment,
such as a Caterpillar D6 Dozer (or equivalent), at least four times prior to the placement of a
subsequent lift. Subsequent layers will not exceed two feet and will be compacted to the same
requirements.
During construction, the compaction requirements for the crystals will be reevaluated based on
field conditions and modified by the Site Manager or a designated representative, with the
agreement of the Executive Secretary.
The contaminated soils and other cleanup materials after the bridging lift will be compacted to at
least 80 percent of standard Proctor maximum density (ASTM D-698).
5.0 RECLAMATION CAP -CELLS 1,2,3, 4A AND 4B
5.1 Earth Cover
A multi-layered earthen cover will be placed over tailings Cells 2,3, 4A and 4B and a portion of
Cell 1 used for disposal of contaminated materials (the CellI Tailings Area). The general
grading plan is shown on Drawing A-5.1-I. Reclamation cover cross-sections are shown on
Drawings A-5.1-2 and A-5.1-3.
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5.2 Materials
5.2.1 Physical Properties
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White Mesa Mill Reclamation Plan
The physical properties of materials for use as cover soils will meet the following:
Random Fill (Platform Fill and Frost Barrier)
These materials will be mixtures of clayey sands and silts with random amounts of gravel and
rock size material. In the initial bridging lift of the platform fill, rock sizes of up to 2/3 of the
thickness of the lift will be allowed. On all other random fill lifts, rock sizes will be limited to
2/3 of the lift thickness, with at least 30 percent of the material finer than 40 sieve. For that
portion passing the No. 40 sieve, these soils will classify as CL, SC, MC or SM materials under
the Unified Soil Classification System. Oversized material will be controlled through selective
excavation at the stockpiles and through the utilization of a grader, bulldozer or backhoe to cull
oversize from the fill.
Clay Layer Materials
Clays will have at least 40 percent passing the No. 200 sieve. The minimum liquid limit of these
soils will be 25 and the plasticity index will be 15 or greater. These soils will classify as CL, SC
or CH materials under the Unified Soil Classification System.
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Insert Figure A-5.1-2
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RECLAMATION COVER CROSS SECTIONS
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5.2.2 Borrow Sources
The sources for soils for the cover materials are as follows:
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1. Random Fill (Platform and Frost Barrier) -stockpiles from previous cell
construction activities currently located to the east and west of the tailing
facilities.
2. Clay -will be from suitable materials stockpiled on site during cell construction
or will be imported from borrow areas located in Section 16, T38S, R22E, SLM.
3. Rock Armor -will be produced through screening of alluvial gravels located in
deposits 1 mile north of Blanding, Utah; 7 miles north of the Mill site.
5.3 Cover Construction
5.3.1 General
Placement of cover materials will be based on a schedule determined by analysis of settlement
data, piezometer data and equipment mobility considerations. Settlement plates and piezometers
will be installed and monitored in accordance with Section 5.4 of these Plans and Specifications.
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5.3.2 Placement and Compaction
5.3.2.1 Methods
Platform Fill
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An initial lift of 3 to 4 feet of random fill will be placed over the tailings surface to form a stable
working platform for subsequent controlled fill placement. This initial lift will be placed by
pushing random fill material or contaminated materials across the tailings in increments, slowly
enough thatthe underlying tailings are displaced as little as possible. Compaction of the initial
lift will be limited to what the weight of the placement equipment provides. The maximum rock
size, as far as practicable, in the initial lift is 2/3 of the lift thickness. Placement of fill will be
monitored by a qualified individual with the authority to stop work and reject material being
placed. The top surface (top 1.0 feet) of the platform fill will be compacted to 90% maximum
dry density per ASTM D 698.
Frost Barrier Fill
Frost barrier fill will be placed above the clay cover in 12-inch lifts, with particle size limited to
2/3 of the lift thickness. Frost barrier material will come from the excavation of random fill
stockpiles, If oversized material is observed during the excavation of fill material it will be
removed as far as practicable before it is placed in the fill.
In all layers of the cover the distribution and gradation of the materials throughout each fill layer
will be such that the fill will, as far as practicable, be free of lenses, pockets, streaks or layers of
material differing substantially in texture, gradation or moisture content from the surrounding
material. Nesting of oversized material will be controlled through selective excavation of
stockpiled material, observation of placement by a qualified individual with authority to stop
work and reject material being placed and by culling oversized material from the fill utilizing a
grader. Successive loads of material will be placed on the fill so as to produce the best practical
distribution of material.
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If the compacted surface of any layer of fill is too dry or smooth to bond properly with the layer
of material to be placed thereon, it will be moistened and/or reworked with a harrow, scarifier, or
other suitable equipment to a sufficient depth to provide relatively uniform moisture content and
a satisfactory bonding surface before the next succeeding layer of earthfill is placed. If the
compacted surface of any layer of earthfill in-place is too wet, due to precipitation, for proper
compaction of the earthfill material to be placed thereon, it will be reworked with harrow,
scarifier or other suitable equipment to reduce the moisture content to the required level shown
in Table 5.3.2.1-1. It will then be recompacted to the earthfill requirements.
No material will be placed when either the materials, or the underlying material, is frozen or
when ambient temperatures do not permit the placement or compaction of the materials to the
specified density, without developing frost lenses in the fill.
5.3.2.2 Moisture and Density Control
As far as practicable, the materials will be brought to the proper moisture content before
placement on tailings, or moisture will be added to the material by sprinkling on the earthfill.
Each layer of the fill will be conditioned so that the moisture content is uniform throughout the
layer prior to and during compaction. The moisture content of the compacted fill will be within
the limits of standard optimum moisture content as shown in Table 5.3.2.1-1. Material that is too
dry or too wet to permit bonding of layers during compaction will be rejected and will be
reworked until the moisture content is within the specified limits. Reworking may include
removal, re-harrowing, reconditioning, rerolling, or combinations of these procedures.
Density control of compacted soil will be such that the compacted material represented by
samples having a dry density less than the values shown in Table 5.3.2.1-1 will be rejected.
Such rejected material will be reworked as necessary and rerolled until a dry density equal to or
greater than the percent of its standard Proctor maximum density shown in Table 5.3.2.1-1.
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To determine that the moisture content and dry density requirements of the compacted fill are
being met, field and laboratory tests will be made at specified intervals taken from the compacted
fills as specified in Section 7.4, "Frequency of Quality Control Tests."
5.4 Monitoring Cover Settlement
5.4.1 Temporary Settlement Plates
5.4.1.1 General
Temporary settlement plates will be installed in the tailings Cells. At the time of cell closure, a
monitoring program will be proposed to the Executive Secretary. Data collected will be
analyzed and the reclamation techniques and schedule adjusted accordingly.
5.4.1.2 Installation
At the time of cell closure or during the placement of interim cover temporary settlement plates
will be installed. These temporary settlement plates will consist of a corrosion resistant steel
plate 114 inch thick and two foot square to which a one inch diameter corrosion resistant monitor
pipe has been welded. The one inch monitor pipe will be surrounded by a three inch diameter
guard pipe which will not be attached to the base plate.
The installation will consist of leveling an area on the existing surface of the tailings, and placing
the base plate directly on the tailings. A minimum three feet of initial soil or tailings cover will
be placed on the base plate for a minimum radial distance of five feet from the pipe.
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5.4.1.3 Monitoring Settlement Plates
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Monitoring of settlement plates will be in accordance with the program submitted to and
approved by the DRC. Settlement observations will be made in accordance with Quality Control
Procedure QC-16-WM, "Monitoring of Temporary Settlement Plates."
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Cover Layer
Platform Fill
Clay Layer
Frost Barrier
Riprap
TABLE A~5.3.2.1-1
Placement and Compaction Criteria
Reclamation Cover Materials
Maximum
Lift Thickness
3 Feet Bridging Lift*
1 Foot
1 Foot
2 Feet
Per Cent
Compaction
80
90
95
95
Top of Tails 6 Inches
Slope 8 Inches
Note:
Allowable Plaoement
Moisture Content
from Optimum
Moisture Content
±2
o to + 3
±2
* Compaction of the bridging lift is dependent on stability offill and equipment used
Percent Compaction is based 011 standard Proctor dry density (ASTM D-698).
Optimum moisture content of a soil will be determined by ASTM D~2216 or D-4643 methods.
6.0 ROCK PROTECTION
6.1 General
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The side slopes of the reclaimed cover will be protected by rock surfacing. Drawings 5.l-1, 5.1-
2, and 5.1-3 show the location of rock protection with the size, thickness and gradation
requirements for the various side slopes.
A riprap layer was designed for erosion protection of the tailings soil cover. According to NRC
guidance, the design must be adequate to protect the soil/tailings against exposure and erosion
for 200 to 1,000 years (NRC, 1990). Currently, there is no standard industry practice for
stabilizing tailings for 1,000 years. However, by treating the embankment slopes as wide
channels, the hydraulic design principles and practices associated with channel design were used
to design stable slopes that will not erode. Thus, a conservative design based on NRC guidelines
was developed. Engineering details and calculations are summarized in the Tailings Cover
Design report (Appendix D).
Riprap cover specifications for the top and side slopes were determined separately as the side
slopes are much steeper than the slope of the top of the cover. The size and thickness of the
riprap on the top ofthe cover was calculated using the Safety Factor Method (NUREG/CR-4651,
1987), while the Stephenson Method (NUREG/CR-4651, 1987) was used for the side slopes.
These methodologies were chosen based on NRC recommendations (1990).
By the Safety Factor Method, riprap dimensions for the top slope were calculated in order to
achieve a slope "safety factor" of 1.1. For the top of the soil cover, with a slope of 0.2 percent,
the Safety Factor Method indicated a median diameter (Dso) riprap of 0.28 inches is required to
stabilize the top slope. However, this dimension must be modified based on the long-term
durability of the specific rock type to be used in construction. The suitability of rock to be used
as a protective cover has been assessed by laboratory tests to determine the physical
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characteristics of the rocks. The gravels sourced from pits located north of Blanding require an
oversizing factor of 9.35%. Therefore, riprap created from this source should have a Dso size of
at least 0.306 inches and should have an overall layer thickness of at least three inches on the top
of the cover. From a practical construction standpoint the minimum rock layer thickness may be
up to six (6) inches.
Riprap dimensions for the side slopes were calculated using Stephenson Method equations. The
side slopes of the cover are designed at 5H:1V. At this slope, Stephenson's Method indicated the
unmodified riprap Dso of 3.24 inches is required. Again assuming that the gravel from north of
Blanding will be used, the modified Dso size of the riprap should be at least 3.54 inches with an
overall layer thickness of at least 8 inches.
Riprap bedding should be placed between the random fill and the riprap on the side slopes. The
bedding should consist of medium sand, and should be placed with a minimum layer thickness of
6 inches.
6.2 Materials
Materials utilized for riprap applications will meet the following specifications:
Material Dso Size DIOO Size Layer Thickness
Top Surface Riprap 0.3" 0.6" 6"
Slope Surface No 40 Sieve 3" 6"
Bedding
Slope Surface Riprap 3.5" 7" 8"
Toe Apron Riprap 6.4' 12' 24"
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Riprap will be supplied to the project from gravel sources located north of the project site.
Riprap will be a screened product.
Riprap quality will be evaluated by methods presented in NUREG/1623 Design of Erosion
Protection for Long-Term Stabilization Size adjustment will be made in the riprap for materials
not meeting the quality criteria.
6.3 Placement
Riprap and bedding material will be hauled to the reclaimed surfaces and placed on the surfaces
using belly dump highway trucks and road graders. Riprap and bedding will be dumped by
trucks in windrows and the grader will spread the rip rap in a manner to minimize segregation of
the material. Depth of placement will be controlled through the establishment of grade stakes
placed on a 200 x 200 foot grid on the top of the cells and by a 100 x 100 foot grid on the cell
slopes. Physical checks of riprap and bedding depth will be accomplished through the use of
hand dug test pits at the center of each grid in addition to monitoring the depth indicated on the
grade stakes. Placement of the riprap and bedding will avoid accumulation of riprap or bedding
sizes less than the minimum Dso size and nesting of the larger sized rock. The riprap and
bedding layer will be compacted by at least two passes by a D-7 Dozer (or equivalent) in order to
key the rock for stability.
7.0 QUALITY CONTROL/QUALITY ASSURANCE
7.1 Quality Plan
A Quality Plan has been developed for construction activities at the Mill. The Quality Plan
includes the following:
1. QC/QA Definitions, Methodology and Activities.
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2. Organizational Structure.
3. Surveys, Inspections, Sampling and Testing.
4. Changes and Corrective Actions.
5. Documentation Requirements.
6. Quality Control Procedures.
7.2 Implementation
Page A-37
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
The Quality Plan will be implemented upon initiation of reclamation work.
7.3 Quality Control Procedures
Quality control procedures have been developed for reclamation and are presented in Attachment
B of this Reclamation Plan. Procedures will be used for all testing, sampling and inspection
functions.
7.4 Frequency ofOuality Control Tests
The frequency of the quality control tests for earthwork will be as follows:
1. The frequency of the field density and moisture tests will be not less than one test per
1,000 cubic yards (CY) of compacted contaminated material placed and one test per 500
CY of compacted random fill, radon barrier or frost barrier. A minimum of two tests will
be taken for each day that an applicable amount of fill is placed in excess of 150 CY. A
minimum of one test per lift and at least one test for every full shift of compaction
operations will be taken.
Field density/moisture tests will be performed utilizing a nuclear density gauge (ASTM
D-2922 density and ASTM D-3017 moisture content). Correlation tests will be
N:\Reclamation PIan\RecIamation Plan Rev 3.2 -finaI\ATIACHMENT A rev3.2 -FinaI.docx
Page A-38
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
performed at a rate of one for every five nuclear gauge tests for compacted contaminated
materials (one_
per 2,500 CY placed) and one for every ten nuclear gauge tests for other compacted
materials (one per 5,000 CY of material placed). Correlation tests will be sand cone tests
(ASTM D-1556) for density determination and oven drying method (ASTM D-2216) for
moisture determination.
2. Gradation and classification testing will be performed at a minimum of one test per 2,000
CY of upper platform fill and frost barrier placed. A minimum of one test will be
performed for each 1,000 CY of radon barrier material placed. For all materials other
than random fill and contaminated materials, at least one gradation test will be run for
each day of significant material placement (in excess of 150 CY).
3. Atterberg limits will be determined on materials being placed as radon barrier. Radon
barrier material will be tested at a rate of at least once each day of significant material
placement (in excess of 150 CY). Samples should be randomly selected.
4. Prior to the start of field compaction operations, appropriate laboratory compaction
curves will be obtained for the range of materials to be placed. During construction, one
point Proctor tests will be performed at a frequency of one test per every five field
density tests (one test per 2,500 CY placed). Laboratory compaction curves (based on
complete Proctor tests) will be obtained at a frequency of approximately one for every 10
to 15 field density tests (one lab Proctor test per 5,000 CY to 7,500 CY placed),
depending on the variability of materials being placed.
5. For riprap and bedding materials, each load of material will be visually checked against
standard piles for gradation prior to transport to the tailings piles.
N:\Reclamation Plan\Reclamation Plan Rev 3.2 -final\ATTACHMENT A rev3.2 -Fina1.docx
Page A-39
Revision 3.2 -Final
Denison Mines (USA) Corp.
White Mesa Mill Reclamation Plan
Prior to delivery of any riprap materials to the site rock durability tests will be performed for
each gradation to be used. Test series fot riprap durability will include specific gravity,
absorption, sodium soundness and LA abrasion. During construction
gradations will be performed for each type of riprap and bedding when approximately one-third
(1/3) and two-thirds (2/3) ofthe total volume of each type have been produced or delivered. In
addition, test series for rock durability will be performed on any riprap material at this same
time. For any type of riprap where the volume is greater than 30,000 CY, a test series and
gradations will be performed for each additional 10,000 CY of riprap produced or delivered.
N:\Reclamation Plan\Reclamati'on Plan Rev 3.2 -·final\ATIACHMENT A rev3.2 -Final.docx
I
I
I
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OENISOJ)~~
MINES
Attachment C
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: 303 628·7798
Fax: [phone]
www.denlsonmines.com
White Mesa Mill Reclamation Plan
Revision 4.4
Revised Cost Estimates
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
November 2010
State of Utahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.deniaonmlnes.com
Copy 1 State of Utah
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: 303 628·7798
Fax: [phone]
PREFACE TO ATIACHMENT C
The White Mesa Mill Reclamation Cost Estimate Revision 4.4 was submitted in its entirety under
separate cover in November 2010. This Attachment ("Attachment C") contains a summary table of the
White Mesa Mill Reclamation Costs from Revision 4.4 of the Reclamation Cost Estimate.
WHITE MESA MILL RECLAMATION COST ESTIMATE
November 2010
Revision 4.4
Mill Decommissioning $2,106,401
Cell 1 $1,711,993
Cell 2 $1,589,352
Cell 3 $2,056,143
Cell4A $1,348,393
Cell4B $1,337,266
Miscellaneous $3,295,557
Subtotal Direct Costs $13,445,107
Profit Allowance 10.00% $1,344,511
Contingency 15.00% $2,016,766
Licensing & Bonding 2.00% $268,902
UDEQ Contract Administration 4.00% $537,804
Contractors Equipment Floater $82,250
Automobile and General Liability Insurance $284,600
Long Term Care Fund $797,448
Total Reclamation $18,777,388
Revised Bond Amount $18,777,388
Denison Mines (USA) Corp.
11/1012010 ·12:02 PM· WMM Rec Plan Est October 2010 Rev 4.4 White Mesa Mill
DENISOJ)~~
MINES
Attachment G
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
Channel, Toe Apron and Rip Rap Filter
Blanket Design Calculations
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State of Utahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver, CO, USA 80265
Tel: 303 628·7798
Fax: [phone]
(DMWH TECHNICAL MEMORANDUM
.UILDING A ."T'" WD"'D
TO: Doug Oliver
DATE: January 29, 2010
FROM: Roslyn Stern
SUBJECT: Evaluation of need for filter layer on side slopes of Denison's White
Mesa Mill Tailings Cell Cover
The following evaluation was performed to evaluate the need for a filter layer under the
rock layer on the side slopes of the tailings cells cover for the White Mesa Mill.
Supporting assumptions, calculations, and discussion are provided following the
conclusions and recommendations.
Conclusions and Recommendations
The calculated interstitial velocities on the top slope and the toe apron are sufficiently
low that a bedding layer is not necessary. However, the interstitial velocity within the
erosion protection on the side slopes is within the range of values where bedding is
conditionally recommended. Because of the wide difference in grain size distribution
between the erosion protection and the random fill, it is recommended that a 6-inch layer
(for constructability) of bedding material be placed between these two materials. The
bedding material should be medium sand with the following specifications:
Sieve Size
3 inches
No.4
No. 20
No. 200
Percent Passing
100
65-100
20-70
0-5
The need for a rock layer on the sideslopes and underlying filter zone can be evaluated as
part of the detailed cover design. The rock layer on the sideslopes could be replaced with
a rock mulch (gravel-amended topsoil) that has the appropriate median size for erosion
protection. A rock mulch (gravel-amended topsoil) is being proposed for the cover
surface.
3665 JFK Parkway TEL [phone]
Suite 206 FAX [phone]
Fort Collins, Colorado 80525 www.mwhglobal.com
e MWH TECHNICAL MEMORANDUM
~-
Supporting Documentation and Discussion
Problem Statement
Evaluate the need for bedding layer between cover soils and erosion protection material
(rock) by estimating interstitial pore velocities using method proposed by Abt et al.
(1991). This evaluation is being completed for the currently permitted rock cover design.
Assumptions
• Reclamation cover, as described in Section 3.2.2 of the 2000 Reclamation Plan
(International Uranium Corp, 2000) consists of six-foot soil cover. The cover
consists, from bottom to top, of a minimum of three feet of random fill (platform
fill), one foot of clay, and two feet of random fill (frost barrier).
• Cells 2 and 3 will have final cover placed at a 0.2 percent grade, with 5H: 1 V side
slopes (Section 3.2.2.3).
• Erosion protection on the top surface of the cover will be provided by placing a
minimum of 3 inches of riprap with a median diameter (Dso) of 0.3 inches
(Section 3.3.5) and a DIOO of 0.6 inches (Section 6.2 of Attachment A -Plans and
Specifications). The overland flow velocity calculated for the top of the cover is
less than 2.0 ft/sec (Section 3.3.5).
• Erosion protection of the side slopes of the cover will be provided by placing a
minimum of 8 inches of riprap with a Dso of 3.5 inches (Section 3.3.5) and a DIOO
of 7 inches (Section 6.2 of Attachment A -Plans and Specifications). The
calculated flow velocity on the side slopes is 4.9 ft/sec (Section 3.3.5).
• Erosion protection of the toe apron will be provided by placing riprap with a Dso
of 6.4 inches (Section 3.3.5) and a DIOO of 12 inches (Section 6.2 of Attachment
A -Plans and Specifications).
• As described in Section 5.2 of Attachment A (Plans and Specifications), the
random fill used as platform fill and frost barrier protection is specified to have at
least 30 percent of the material fmer than the number 40 sieve, with a DIOO less
than 8 inches.
• The peak unit discharge from the tailings cells is 1.8 cfs/ft (Attachment 12 to
Attachment G -Channel and Toe Apron Design Calculations)
3665 JFK Parkway TEL [phone]
Suite 206 FAX [phone]
Fort Collins, Colorado 80525 www.mwhglobal.com
e MWH TECHNICAL MEMORANDUM
Discussion
NUREG-1623, Appendix D, recommends a filter or bedding layer be placed under
erosion protection if interstitial velocities are greater than 1 ft/sec, in order to prevent
erosion of the underlying soils. Bedding is not required if interstitial velocities are less
than 0.5 ft/sec, and recommended depending on the characteristics of the underlying soil
if velocities are between 0.5 and 1 ft/sec.
Interstitial velocities are calculated by procedures presented by Abt et al. (1991) as given
in the following equation. This method updates the Leps (1973) relationship that is
presented in NUREG/CR-4620 (Nelson et al. 1986):
Where:
V; = 0.23{g X DIO x S)O.5
Vi = interstitial velocities (ft/s),
G = acceleration of gravity (ft/s2),
DIO = rock diameter at which 10 percent is fmer (inches), and
S = gradient in decimal form.
The maximum DIO of the erosion protection is estimated based on D50 required for
erosion protection, assuming the erosion protection will have a coefficient of uniformity
(CU) of 6 and a band width of 5. Band width refers to the ratio of the minimum and
maximum allowed particle sizes acceptable for any given percent fmer designation.
USDA (1994) recommends CU to be a maximum of6 in order to prevent gap-grading of
filters. Table 1 summarizes the results.
T bl 1 R It f B ddin R t a e esu so e ·lg equrremen s
Location Top Cover Cover Side Slopes Toe Apron
MinimumD50 0.3 3.5 6.4
(inches)
MaximumDlO 0.35 1.24 3.73
(inches)
Slope (%) 0.2 20 1
Interstitial Velocity 0.03 0.65 0.25
(ft/s)
3665 J FK Parkway TEL [phone]
Suite 206 FAX [phone]
Fort Collins, Colorado 80525 www.mwhglobal.com
e MWH TECHNICAL MEMORANDUM
~
References
Abt, S.R., J.F. Ruff, and R.J. Wilter (1991). Estimating Flow Through Riprap, Journal of
Hydraulic Engineering, v. 117, No.5, May.
International Uranium (USA) Corp (2000). Reclamation Plan, White Mesa Mill,
Blanding, Utah, Revision 3.0, July.
Johnson, T.L. (2002). Design of Erosion Protection for Long-Term Stabilization,
NUREG-1623, U.S. Nuclear Regulatory Commission (NRC), February.
Nelson, J.D., S.R. Abt, R.L. Volpe, D. van Zyl, N.B. Hinkle, W.P. Staub (1986)
Methodologies for Evaluating Long-Term Stabilization Designs of Uranium Mill tailings
Impoundments, NUREG/CR-4620, U.S. Nuclear Regulatory Commission (NRC), June.
U.S. Department of Agriculture (USDA) (1994). Gradation Design of Sand and Gravel
Filters, National Engineering Handbook, Part 633, Chapter 26, October.
3665 JFK Parkway TEL [phone]
Suite 206 FAX [phone]
Fort Collins, Colorado 80525 www.mwhglobal.com
OENISOJ)JJ
MINES
Figures
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
White Mesa Mill Reclamation Plan
Revision 3.2 -Final
for
Reclamation
of the
White Mesa Mill and Tailings
Management System
January 2011
State of Utahlle.(2) Byproduct Material License # UT1900479
Denison Mines (USA) Corp.
www.denisonmines.com
1050 17th Street, Suite 950
Denver. CO, USA 80265
Tel: [phone]
Fax: [phone]
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