DRC-2011-006671 - 0901a0688024893a

Received
M 2011
Division of
HadiaVion Control
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
June 23, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State Of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of April 20, 2011 Regarding Movement
Monitoring SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill Movement
Monitoring SOP. This letter also responds to DRC's letter of June 13, 2011, which we received on June 15,
2011 providing DRC's proposed redlines and comments on the subject SOP. We have provided in
Attachment 1 an edited redline copy of the SOP in which Denison's modifications or additional language in
response to DRC comments are indicated in a second color, and a clean black-line copy for ease of review.
In addition, Denison has prepared a draft of changes to the Tailings Management System and Discharge
Minimization Technology ("DMT") Plan, to address:
• Changes in tailings inspection forms to correspond to this Movement Monitor SOP;
• Changes to address the startup of new cells, during which solution level cannot be surveyed or tape
measured until the solution level is high enough to be safely reached;
• Changes to reflect the removal of the freeboard limits from Cells 3 and 4A; and
• Other language changes to more correctly reflect current conditions and procedures at the tailings
system and Mill.
A redline copy and clean blackline copy of the proposed DMT changes are provided in Attachment 2.
We have provided, below, specific responses to each request in DRC's June 13, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC June 13, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General. Some new additional suggested red-line strike-out changes for the subject SOPs are
attached. Please note some sections contain more than one change of wording. Unfortunately, these
N:\SOPs and Procedures\Movement monitor SOP and comments\06.23.11 response to 06.13.11 RFI on Movement monitor
SOP\06.23.11 submittal to Rlundberg Movemt Monitors\06.23.11 Response to DEQ 06.13.11 RFI Movement Monitor
SOP.doc
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 2
changes appear in the same color as our previous suggested red-line strike out changes. However, the
most significant changes are described in more detail below:
a. Section 1.2: In the last paragraph we add the wording, "semi-annual and... "
b. Section 1.4.2: In the second sentence we add the words "near" and "but," and deleted the word
"on."
c. Section 1.5:
(1) . In the first sentence we add the phase, "of the movement monitors."
(2) . In the last sentence of the first paragraph we add "of 0.1 foot or," and delete "than 0.1
foot." This is explained further below in paragraph 1e.
(3) . In the second paragraph we add the new phasing shown to capture the semi-annual
survey and mapping reports.
d. Section 1.6:
(1) . In the first paragraph we add, "or greater" This is explained further below in paragraph
1e.
(2) . In the last paragraph, the first sentence, we add, "and submit," and "semi-annual and
annual."
(3) . In the second sentence of the last paragraph we add, "and" and delete "or"
(4) . In the fourth sentence of the last paragraph we add, "also."
e. To be consistent with paragraphs 1.4.2.2 and 1.4.2.3, regarding distances of "0.1 foot or
greater," as the actionable distance for the SOPs, some of the sentences described above
have been adjusted with suggested wording, such that any distance readings ofO. 1 foot would
not be vague as to the SOP requirements.
Denison Response: The changes have been accepted as proposed.
2. No further comment.
Denison Response: No response required.
3. No further comment.
Denison Response: No response required.
4. A monthly inspection of the movement monitors is described at the end of the first paragraph of section
1.4.2 in the subject SOPs. It appears this necessitates some corresponding additions to the monthly
tailings inspection form, for inspection of the movement monitors. Please provide the proposed
changes in the form (DMT Plan) for approval.
Denison Response: Proposed revisions to the DMT Plan, including changes to the monthly tailings
inspection form, are attached.
5. No further comment.
Denison Response: No response required.
DENISO
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 3
6. No further comment
Denison Response: No response required.
7. No further comment.
Denison Response: No response required.
The document has been reviewed for spelling and typographical errors.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Attachments
DENISO
MINES
White Mesa Mill – Standard Operating Procedures Date: 05611/20110 Revision: DUSA-21
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4

F:\WP\Division of Radiation Control\Denison Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement
Monitors\Movement Monitors\Markup of Prop Movement Monit SOPs 4-2010.docF:\WP\Division of Radiation Control\Denison
Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement Monitors\Movement Monitors\Prop Movement Monit
SOPs Nov 2010.doc

MOVEMENT (DISPLACEMENT) MONITOR

STANDARD OPERATING PROCEDURES
[DARMarkup 06-2011]

1. MOVEMENT (DISPLACEMENT) MONITOR

1.1 Purpose

This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Movement (Displacement) Monitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).

1.2 Locations and Frequency of Monitoring

Within 30 days of completion of new dike construction activities, Movement Monitors will be
installed and surveyed by a Utah Licensed Land Surveyor. The installation of these
mmMovement monitors, at a minimum, without regard to each dike longitudinal direction, will
be installed in a single straight lines for each pertinent dike. The line for the movement monitors
will change direction at each pertinent dike intersection, but will run continuous along and on top
of, all exterior exposed dikes comprising the southern boundary the exposed dike of the tailing
cells.

All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.

On an
annual basis, a Utah Licensed Professional Engineer will review, analyze, correct, and certify the
semi-annual and annual data in writing, which will be submitted as part of the ATER as required
by RML License Condition 12.3.

1.3 Design of Settlement Monitors

White Mesa Mill – Standard Operating Procedures Date: 05611/20110 Revision: DUSA-21
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4

F:\WP\Division of Radiation Control\Denison Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement
Monitors\Movement Monitors\Markup of Prop Movement Monit SOPs 4-2010.docF:\WP\Division of Radiation Control\Denison
Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement Monitors\Movement Monitors\Prop Movement Monit
SOPs Nov 2010.doc

Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.

The mMovement mMonitor placement will be established by digging a hole in the desired
location, to minimize accidental damage to the monument including, but not limited to, vehicle
and construction traffic damage.. A piece of rebar, 24 inches in length, will be driven into the
hole. The new monument will be set in -line with the other movement monitors for the given
dike. The hole will be back- filled and the top of the rebar will be at least 4X-inches below
surface grade. Each monument will be individually tagged and numbered.

1.4 Monitoring and Maintenance of Movement Devices

1.4.1 Monitoring and Documentation of Condition of Devices

The mMovement mMonitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor’s written reports and in the annual ATER.

1.4.2 Maintenance of Monitors

The Movement Monitors will be installed in such a way to prevent damage by equipment. All
new movement monitors installed after June 2010 will be installed nearon the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The mMovement mMonitors will be installed
such that the monument is at least 4X-inches below the actual ground surface level, so the
potential for damage by equipment is further minimized. However, if a monument is disturbed,
the information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and a corrective action plan will be
created for replacement and/or repairs to the damaged movement monitor and the surveying and
documentation of any changes will be completed within 30XX calendar days of the discovery of
the damage. The general condition of the movement monitors will be evaluated on a monthly
basis and the inspection documented as a part of Monthly Tailings Inspection.

If any Movement Monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
30XX calendar-days of the discovery of the damage. The replacement device will be placed in
the same excavated hole from which the damaged device was removed. Data from the new
device will be correlated to data from the removed damaged device as follows:

1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.

White Mesa Mill – Standard Operating Procedures Date: 05611/20110 Revision: DUSA-21
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 4

F:\WP\Division of Radiation Control\Denison Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement
Monitors\Movement Monitors\Markup of Prop Movement Monit SOPs 4-2010.docF:\WP\Division of Radiation Control\Denison
Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement Monitors\Movement Monitors\Prop Movement Monit
SOPs Nov 2010.doc

2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamagedadjacent devices, it will be assumed that no damage had
occurred to the adjacent devices and no adjustment will be made to the survey data of the
new device will be installed at the vertical and horizontal coordinates of the device prior
to the damage.

3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the undamagedadjacent devices, the procedures in
section 1.6 will be implemented. survey results for the new device will be adjusted by
the average change observed in the two adjacent devices. This adjustment will be
documented in the Utah-Licensed Land Surveyors report and in the annual ATER.

1.5 Documentation

The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater than 0.1 foot
will be evaluated according to the procedure described in section 1.6

The list of records generated as a result of this SOP includes:
• Utah Licensed Surveyor’s Semi-Annual and Annual Survey and Mapping Reports
• Annual Technical Evaluation Report
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report

All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.

1.6 Performance Criteria and Data Validation

The data will be reviewed for any errors and or major changes in the vertical or
horizontalvertical movement on the movement monitors. If there is a difference of 0.1 foot or
greater between two consecutive measuremenmtsonths,, then the corrective actions will be taken
as follows:

11. Resurvey the movement monitor that shows vertical or horizontalvertical movement of
0.1 foot or more, within 30XX days of discovery of the problem..
22. Document site conditions.
33. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
44. Report this information to the Executive Secretary within a timely manner45XX calendar
days for approval and include in that notification the investigation steps, movement
evaluation and corrective actions stepstaken. This report will be also be maintained
White Mesa Mill – Standard Operating Procedures Date: 05611/20110 Revision: DUSA-21
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4

F:\WP\Division of Radiation Control\Denison Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement
Monitors\Movement Monitors\Markup of Prop Movement Monit SOPs 4-2010.docF:\WP\Division of Radiation Control\Denison
Mines, DUSA\ATER-Annual Tech Eval Reports\Movement & Settlement Monitors\Movement Monitors\Prop Movement Monit
SOPs Nov 2010.doc

within the Environmental Department records and will be submitted as part of the ATER
as required by RML Condition 12.3.

Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods or horizontal movement of 0.X foot or greater for two
consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a
manner approved by the Executive Secretary.

On an annual basis, a Utah Licensed Professional Engineer will review, analyze, correct, and
certify and submit the semi-annual and annual data in writing, including an explanation of the
methods and basis used for the review, analysis, and corrections including ongoing graphical
updates for the Movement Monitors. Movement data will be presented in a tabular format,
showing all previous annual or and semi-annual data, for ease in evaluating the total record of
movement measurements. Data from all previous measurements will be compared against the
current measurement and an evaluation made as to any long- term trends which may be apparent.
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah Registered Professional Engineer. which This
information will be maintained within the Environmental Department records and will be
submitted as part of the ATER as required by RML License Condition 12.3, along with a
description of any corrective actions performed.

White Mesa Mill – Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4

MOVEMENT (DISPLACEMENT) MONITOR

STANDARD OPERATING PROCEDURES

1. MOVEMENT (DISPLACEMENT) MONITOR

1.1 Purpose

This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Movement (Displacement) Monitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).

1.2 Locations and Frequency of Monitoring

Within 30 days of completion of new dike construction activities, Movement Monitors will be
installed and surveyed by a Utah Licensed Land Surveyor. movement onitors, at a minimum,
without regard to each dike longitudinal direction, will be installed in single straight lines for
each pertinent dike. The line for the movement monitors will change direction at each pertinent
dike intersection, but will run continuous along and on top of, all exterior exposed dikes
comprising the southern boundary of the tailing cells.

All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.

On an annual basis, a Utah Licensed Professional Engineer will review, analyze, correct, and
certify the semi-annual and annual data in writing, which will be submitted as part of the ATER
as required by RML License Condition 12.3.

1.3 Design of Settlement Monitors

Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.

The movement monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument including, but not limited to, vehicle and
construction traffic damage. A piece of rebar, 24 inches in length, will be driven into the hole.
The new monument will be set in line with the other movement monitors for the given dike. The
White Mesa Mill – Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4

hole will be back-filled and the top of the rebar will be at least 4-inches below surface grade.
Each monument will be individually tagged and numbered.

1.4 Monitoring and Maintenance of Movement Devices

1.4.1 Monitoring and Documentation of Condition of Devices

The movement monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented in the surveyor’s written reports and in the annual ATER.

1.4.2 Maintenance of Monitors

The Movement Monitors will be installed in such a way to prevent damage by equipment. All
new movement monitors installed after June 2010 will be installed near the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The movement monitors will be installed such
that the monument is at least 4-inches below the actual ground surface level, so the potential for
damage by equipment is further minimized. However, if a monument is disturbed, the
information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and replacement and/or repairs to the
damaged movement monitor and the surveying and documentation of changes will be completed
within 30 calendar days of the discovery of the damage. The general condition of the movement
monitors will be evaluated on a monthly basis and the inspection documented as a part of
Monthly Tailings Inspection.

If any Movement Monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
30 calendar-days of the discovery of the damage. The replacement device will be placed in the
same excavated hole from which the damaged device was removed. Data from the new device
will be correlated to data from the removed damaged device as follows:

1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.

2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and the new device will be installed at the vertical and horizontal
coordinates of the device prior to the damage.

3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the adjacent devices, the procedures in section 1.6 will
be implemented.
White Mesa Mill – Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 4

1.5 Documentation

The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors in relationship to the tailings cells. A
brief summary of work and analytical data will be provided in a written report by the Utah-
Licensed Land Surveyor. Vertical or horizontal movements of 0.1 foot or greater will be
evaluated according to the procedure described in section 1.6

The list of records generated as a result of this SOP includes:
• Utah Licensed Surveyor’s Semi-Annual and Annual Survey and Mapping Reports
• Annual Technical Evaluation Report
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report

All documentation will be housed at the White Mesa Mill in the Environmental Department files
for inspection.

1.6 Performance Criteria and Data Validation

The data will be reviewed for any errors and or major changes in the vertical or horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:

1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
4. Report this information to the Executive Secretary within 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with the Environmental
Department records and will be submitted as part of the ATER as required by RML
Condition 12.3.

Movement monitors that show vertical or horizontal movement of 0.2 foot or greater for two
consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a
manner approved by the Executive Secretary.

On an annual basis, a Utah Licensed Professional Engineer will review, analyze, correct, certify
and submit the semi-annual and annual data in writing, including an explanation of the methods
and basis used for the review, analysis, and corrections including ongoing graphical updates for
the Movement Monitors. Movement data will be presented in a tabular format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
White Mesa Mill – Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4

Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah Registered Professional Engineer. This information
will be maintained with the Environmental Department records and will be submitted as part of
the ATER as required by RML License Condition 12.3, along with a description of any
corrective actions performed.

White Mesa Mill – Standard Operating Procedures 0106/11 Revision: Denison11.21
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submittal to Rlundberg Movemt Monitors\Tailings Mgnt System and DMT Mon Plan June 2011 rev 11.2.docN:\Cell 4B\January 2011 Submittals and Revisions for Cell 4B\DMT Plan 01.10.11\Tailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 - Redline.doc

WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN

1. INTRODUCTION

This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
“Plan”) for the White Mesa Mill (the “Mill”) provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
“Radioactive Materials License”), as well as procedures for operating and maintenance of
monitoring equipment and reporting procedures that are adequate to demonstrate DMT compliance
under State of Utah Ground Water Discharge Permit No. 370004 for the Mill (the “GWDP”).

This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations
and monthly reporting to Mill management.

2. DAILY TAILINGS INSPECTIONS

The following daily tailings inspections shall be performed:

2.1. Daily Comprehensive Tailings Inspection

On a daily basis, including weekends, all areas connected with the four five tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.

The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4 below, to perform the daily tailings inspection.

Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
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items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.

Areas to be inspected include the following: Cell 1, 2, 3, 4A and 4B, Dikes 1, 2, 3, 4A-S, 4A-WE,
and 4B-S, and 4B-W wind movement of tailings, effectiveness of dust minimization methods, spray
evaporation, Cell 2 spillway, Cell 3 spillway, Cell 3, Cell 4A spillway, Cell 4A and 4B liquid pools
and associated liquid return equipment, and cell leak detection systems, and the wildlife ponds.

Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:

a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.

Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from
CCD to the active tailings cell; SX raffinate lines that can discharge into Cell 1,
Cell 3, Cell 4A or Cell 4B; the pond return line from the tailings area to the Mill;
and, lines transporting pond solutions from one cell to another.

b) Cell 1.

c) Cell 2.

d) Cell 3.

e) Cell 4A.

f) Cell 4B.

g) Dike structures including dikes 1, 2, 3, 4A-S, 4A-EW, and 4B-S and 4B-W.

h) The Cell 2 spillway, Cell 3 spillway, Cell 4A spillway, Cell 3, Cell 4A and Cell
4B liquid pools and associated liquid return equipment.

i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.

j) Spray evaporation pumps and lines.
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k) Wind movement of tailings and dust minimization.

Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.

l) Observation of flow and operational status of the dust control/spray evaporation
system(s).

m) Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
4A, and 4B.

n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.

o) An estimate of flow for active tailings slurry and SX line(s).

p) An estimate of flow in the solution return line(s).

q) Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.

The trigger for further action when evaluating the measurements in the Cell 1 and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell 4A or 4B leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner (Cell
4A FML elevation is 5555.14 amsl and with the addition of the 1.0 foot of
solution the solution elevation is 5556.14 feet amsl. For Cell 4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
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exceeded.

Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill’s Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.

r) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.

Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.

2.2. Daily Operations Inspection

During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman’s Daily Inspection form.

2.3. Daily Operations Patrol

In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.

No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
(“RSO”) and/or Mill management in the event that during their inspection they discover that an
abnormal condition or tailings emergency has occurred.

2.4. Training

All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
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2.5. Tailings Emergencies

Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.

Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).

3. WEEKLY TAILINGS AND DMT INSPECTION

3.1. Weekly Tailings Inspections

Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:

a) Leak Detection Systems

Each tailings cell's leak detection system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1 and Cell 3 the leak detection system is
measured by use of a pipe that is removed from the system which will
indicatedual-probe system that senses the presence of solutions in the LDS
system (comparable to the systems in Cells 4A and 4B) and indicates the
presence of solution with a warning light. The Cell 4A and 4B leak detection
systems are monitored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector. The pressure
transducer is calibrated for fluid with a specific gravity of 1.0. The water levels
are measured every hour and the information is stored for later retrieval. The
water levels are measured to the nearest 0.10 inch. The data collector is currently
programmed to store 7 days of water level information. The number of days of
stored data can be increased beyond 7 days if needed. For Cells 1 and 3, the
water level data is recorded on the Daily Tailings Inspection Form. For Cells 4A
and 4B, tThe water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill’s environmental monitoring data
basestorage, and into the files for weekly inspection reports of the tailings cell
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leak detection systems
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If sufficient fluid is present in the leak detection system of any cell, the fluid
shall be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.

For Cells 1 and 3, iIf fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed
time since fluid was last pumped or increases in the LDS fluid levels were
recorded, whichever is the more recent. This calculation shall be documented as
part of the weekly inspection.

For Cells 1 and 3, uUpon the initial pumping of fluid from an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3 C. of
the Radioactive Materials License.

For Cell 4A and 4B, under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in the
lower flexible membrane liner. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and 4B leak detection systems, the total
volume of all fluids pumped from the LDS on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day. Under no circumstances shall
the daily LDS flow volume exceed 24,160 gallons/day for Cell 4A or
26,145gallons/day for Cell 4B. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table 1A and
1B (for Cells 4A and 4B, respectively) in Appendix E, to determine the
maximum daily allowable LDS flow volume for varying head conditions in
Cell 4A and 4B.

b) Slimes Drain Water Level Monitoring

(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell 2, which, based on construction reports, is at a depth of 39 feet below
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the water level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float
mechanism and water level probe system. When the water level reaches the level of
the float mechanism the pump is activated. Pumping then occurs until the water
level reaches the lower probe which turns the pump off. The lower probe is located
one foot above the bottom of the slimes drain standpipe, and the float valve is located
at five feet above the bottom of the slimes drain standpipe. The average wastewater
head in the Cell 2 slimes drain is therefore less than 5 feet and is below the phreatic
surface of tailings Cell 2, about 20 feet below the water level measuring point on the
slimes drain access pipe. As a result, there is a continuous flow of wastewater from
Cell 2 into the slimes drain collection system. Mill management considers that the
average allowable wastewater head in the Cell 2 slimes drain resulting from pumping
in this manner is satisfactory and is as low as reasonably achievable.
(iv) The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi) On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water
level measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain
is found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including
the requirement to provide notification to the Executive Secretary orally within 24
hours followed by written notification;
(ix) Because Cell 3 and Cell 4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell 4B slimes drain will be
authorized once it is put into service and while it is active. Prior to initiation of
tailings dewatering operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure
will be developed for ensuring that average head elevations in the Cell 3 and Cell 4A
slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell 4A,
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and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit.”

c) Wind Movement of Tailings

An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.

d) Tailings Wastewater Pool Elevation Monitoring

Solution elevation measurements in Cells 14A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis, and the beach area in Cell 4A and 4B with the maximum
elevation is to be taken by survey on a monthly basis, as follows:

(i) The survey will be performed by the Mill’s Radiation Safety Officer or designee
(the “Surveyor”) with the assistance of another Mill worker (the “Assistant”);
(ii) The survey will be performed using a survey instrument (the “Survey
Instrument”) accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent,
together with a survey rod (the “Survey Rod”) having a visible scale in 0.01 foot
increments;
(iii) The Rreference Points (the “Reference Points”) for Cells 14A, and
4B, and Roberts Pond are known points established by professional survey. For
Cell 1 and Roberts Pond, the Reference Point is a wooden stake with a metal disk
on it located on the southeast corner of Cell 1. The elevation of the metal disk
(the “Reference Point Elevation”) for Cell 1 and Roberts Pond is at 5,623.14 feet
above mean sea level (“FMSL”). For Cell 3 Cell 4A, and Cell 4B, the Reference
Point is a piece of metal rebar located on the south dike of Cell 3. The elevation
at the top of this piece of rebar (the Reference Point Elevation for Cell 4A and
4B3) is at 5,607.83 FMSL. For Cell 4A and 4B, the Reference Point is a piece of
stamped metal monument located next to the transformer on the south side of Cell
4A and 4B. The elevation at the top of this piece of rebar (the Reference Point
Elevation for Cell 4A and 4B) is 5600.49 fmsl. The Surveyor will set up the
Survey Instrument in a location where both the applicable Reference Point and
pond surface are visible. For Cell 1 and Roberts Pond, this is typically on the
road on the Cell 1 south dike between Cell 1 and Roberts Pond, approximately
100 feet east of the Cell 1/Roberts Pond Reference Point. For Cell 4A and Cell
4B, this is typically on the road on the Cell 3 dike approximately 100 feet east of
the Cell 3 Reference Pointsouth side of Cell 4A and 4B;
(iv) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1/Roberts Pond Reference Point on the top of the rebar on
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the Cell 4A and 4B Reference Point. The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(vi) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the “Reference Point Reading”), which
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(vii) The Assistant will then move to a designated location where the Survey Rod
can be placed on the surface of the main solution pond in the Cell 1, Cell 4A, Cell
4B, or Roberts Pond, or the area of the beach in Cell 4A or Cell 4B with the
highest elevation, as the case may be. These designated locations, and the
methods to be used by the Assistant to consistently use the same locations are as
follows:

(vii) For a newly-constructed cell, when the cell is first placed into operation, the solution level
is typically zero feet above the FML or a minimal elevation above the FML due to natural
precipitation. For newly-constructed cells, solution level measurement will not be required until
the solution level is high enough that it can be reached safely by personnel with a measuring tape
along the side of the FML. Solutions levels will be measured by this method beginning when the
solution level is high enough to be reached safely, as determined by the RSO. Surveying of
solution levels will not be required until solution levels are high enough that they can effectively
be measured by survey instrument from the appropriate surveying point.

A. Pond Surface Measurements
A.
I. Cell 4A

The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.

II.I. Cell 4B

The Assistant will walk down the slope in the northwest corner of Cell 4B and
place the Survey Rod at the liquid level.

III.II. Cell 1

A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and

IV. Roberts Pond
Formatted: No bullets or numbering
Formatted: Indent: Left: 1.54", No bullets ornumbering
Formatted: Indent: Left: 1.5", Tab stops: 1.5", Left + Not at 1.13"
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A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.

Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:

Northing Easting
Roberts Pond 323,041 2,579,697
Cell 1 322,196 2,579,277
Cell 4A 320,300 2,579,360
Cell 4B 320,690 2,576,200

These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;

B. Cell 4B Beach Elevation

The Assistant will place the Survey Rod at the point on the beach area of Cell 4B
that has the highest elevation. If it is not clear which area of the beach has the
highest elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;

(viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface. The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(ix) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the “Pond Surface Reading”), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.

The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.

e) Decontamination Pads
Formatted: Keep with next
Formatted: Font: Bold
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(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill’s scale house.

A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;

B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;

C. These inspections will be recorded on the Weekly Tailings Inspection
form;

D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting
the weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.

E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).

F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis.
Any soil and debris will be removed from the New Decontamination
Pad immediately prior to inspection of the concrete wash pad for
cracking. Observations will be made of the current condition of the
New Decontamination Pad. Any abnormalities relating to the pad
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and any damage to the concrete wash surface of the pad will be noted
on the Weekly Tailings Inspection form. If there are any cracks
greater than 1/8 inch separation (width), the RSO must be contacted.
The RSO will have the responsibility to cease activities and have the
cracks repaired.

(ii) Existing Decontamination Pad

The Existing Decontamination Pad is located between the northwest corner of the
Mill’s maintenance shop and the ore feeding grizzly.

A. The Existing Decontamination Pad will be inspected on a weekly
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the current
condition of the Existing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. If there are any cracks greater than 1/8
inch separation (width), the RSO must be contacted. The RSO will
have the responsibility to cease activities and have the cracks
repaired.

f) Summary

In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.

Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.

3.2. Weekly Inspection of Solution Levels in Roberts Pond

On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond’s FML. If the pond solution elevation at the Pond Surface Reading area is at or below the
FML for that area, the pond will be recorded as being dry.

3.3. Weekly Feedstock Storage Area Inspections
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Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:

a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;

b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and

c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.

The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.

4. MONTHLY TAILINGS INSPECTION

Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:

a) Tailings Slurry Pipeline

When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.

b) Diversion Ditches

Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be
checked for stability and signs of distress.

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c) Sedimentation Pond

Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.

d) Overspray Dust Minimization

The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.

e) Remarks

A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.

f) Summary of Daily, Weekly and Quarterly Inspections

The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.

In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.

5. QUARTERLY TAILINGS INSPECTION

The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.

Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:

a) Embankment Inspection

The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.

b) Operations/Maintenance Review
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The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.

c) Construction Review

The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.

d) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
Formatted: Font: Italic
Formatted: Indent: Left: 1", No bullets ornumbering
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d)e) Summary

The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.

If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.

6. ANNUAL EVALUATIONS

The following annual evaluations shall be performed:

6.1. Annual Technical Evaluation

An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).

All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.

In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.

Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.

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The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.

The Annual Technical Evaluation Report must be submitted by November 15th of every year to:

Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Salt Lake City, Utah 84116-3156

6.2. Movement Monitors

A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.

6.3. Freeboard Limits

The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the “Drainage Report”) for the White Mesa site to be 10 inches.

The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage
areas, was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up
factor of 0.90 feet.

The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.

The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.

The flood volume from the PMP event over the Cell 4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.

The total pool surface area in Cell 1 is 52.9 acres, in Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top of the flexible membrane liner (“FML”) for Cell 1 is 5,618.2 FMSL, for Cell 4A
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is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.

Based on the foregoing, the freeboard limits for the Mill’s tailings cells will be set as follows:

6.3.1. Cell 1
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow Cell 1 to capture all of the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 feet equals 2.85 feet. The freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2

The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).

6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with Cell 4A will be attributed to Cell 4B. A spillway has been added to Cell 4A to allow overflow into Cell 4B.
6.3.5. Cell 4B
The freeboard limit for Cell 4B will be set assuming that the total PMP volume for Cells 2, 3, 4A, and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell 4B is as follows: (a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was developed as follows: PMP Flood Volume 38.1 acre-feetOverflow from Cell 4A assuming no storage in Cell 3 or 4A 159.4 acre-feetSum of PMP volume and overflow volume 197.5 acre-feet
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Depth to store PMP an overflow volume = 197.5 acre-feet/40 acres 4.9 feetWave run up factor 0.77 feetTotal required freeboard 5.7 feet (all values in the above calculation have been rounded to the nearest one-tenth of a foot); (b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less When the maximum elevation of the beach area in Cell 4B is 5594 FMSL or less, then the freeboard limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where there may be beaches, but these beaches are at a lower elevation than the freeboard limit established in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP volume. The maximum elevation of the beach area will be determined by monthly surveys performed by Mill personnel in accordance with the Mill’s DMT Plan. (c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL When the maximum elevation of the beach area in Cell 4B first exceeds 5,594 FMSL, then the freeboard limit for the remainder of the ensuing year (period t=0) (until the next November 1) will be calculated when that elevation is first exceeded (the “Initial Calculation Date”), as follows: i) The total number of dry tons of tailings that have historically been deposited into Cell 4B prior to the Initial Calculation Date (“T0”) will be determined; ii) The expected number of dry tons to be deposited into Cell 4B for the remainder of the ensuing year (up to the next November 1), based on production estimates for that period (“Δ0*”), will be determined; iii) Δ0* will be grossed up by a safety factor of 150% to allow for a potential underestimation of the number of tons that will be deposited in the cell during the remainder of the ensuing year. This grossed up number can be referred to as the “modeled tonnage” for the period; iv) The total design tailings solid storage capacity of Cell 4A will be accepted as 2,094,000 dry tons of tailings; v) The available remaining space in Cell 4B for solids as at the Initial Calculation Date will be calculated as 2,094,000 dry tons minus T0; vi) The reduction in the pool surface area for the remainder of the ensuing year will be assumed to be directly proportional to the reduction in the available space in Cell 4A for solids. That is, the reduced pool surface area for period t=0 (“RPA0”), after the reduction, will be calculated to be: (1 – (Δ0* x 1.5) / (2,094,000 - T0)) x 40 acres = RPA0
vii) The required freeboard for Cell 4A for the remainder of the period t=0 can be calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the quotient of 197.5 acre feet divided by the RPA0. The freeboard limit for Cell 4B for the remainder of period t=0 would then be the elevation of the FML for Cell 4B of
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5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of a foot; and viii) The foregoing calculations will be performed at the Initial Calculation Date and the resulting freeboard limit will persist until the next November 1. An example of this calculation is set out in Appendix F. (d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds 5,594 FMSL On November 1 of each year (the “Annual Calculation Date”), the reduction in pool area for the ensuing year (referred to as period t) will be calculated by: i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARPAt-1) to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1). The RPAt-1 used for the previous period was based on expected tonnages for period t-1, grossed up by a safety factor. The ARPAt-1 is merely the RPA that would have been used for period t-1 had the actual tonnages for year t-1 been known at the outset of period t-1 and had the RPA been calculated based on the actual tonnages for period t-1. This allows the freeboard calculations to be corrected each year to take into account actual tonnages deposited in the cell as of the date of the calculation. The ARPAt-1 can be calculated using the following formula: (1 – Δt-1 / (2,094,000 – Tt-1)) x ARPAt-2 = ARPAt-1
Where:  Δt-1 is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;  Tt-1 is the actual number of dry tons of tailings solids historically deposited in Cell 4B prior to the beginning of period t-1; and  ARPAt-2 is the Adjusted Reduced Pool Area for period t-2. If period t-2 started at the Initial Calculation Date, then ARPAt-2 is 40 acres; ii) Once the ARPAt-1 for the previous period (period t-1) has been calculated, the RPA for the subject period (period t) can be calculated as follows: (1 – (Δt* x 1.5) / (2,094,000 - Tt)) x ARPAt-1 = RPAt Where:  Δt* is the expected number of dry tons of tailings to be deposited into Cell 4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);  Tt is the actual number of dry tons of tailings solids historically deposited in Cell 4B prior to the beginning of period t; and  ARPAt-1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-1) that should have applied
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during that period, had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period; iii) The required freeboard for period t can be calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the quotient of 197.5 acre feet divided by the RPAt. The freeboard limit for Cell 4A for period t would then be the elevation of the FML for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of a foot; and iv) The foregoing calculations will be performed at the Annual Calculation Date for period t and the resulting freeboard limit will persist until the next Annual Calculation Date for period t+1. An example of this calculation is set out in Appendix F. (e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Cell 4B and a new tailings cell then, if an approved freeboard
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2, 3, 4A, 4B
and the new tailings cell, the freeboard limit for Cell 4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.

6.3.6. Roberts Pond

The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0 feet above mean sea
level, as specified in the GWDP.

6.4. Annual Leak Detection Fluid Samples

In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.

6.5. Annual Inspection of the Decontamination Pads

a) New Decontamination Pad

During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad’s exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
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repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.

b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility. All inspection findings and any repairs required shall be documented on the Annual
Decontamination Pad Inspection form. A record of the repairs will be maintained as a part of the
Annual Inspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.

7. OTHER INSPECTIONS

All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4, 5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.

8. REPORTING REQUIREMENTS

In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2, 3, 4 and 5
respectively, and the Operating Foreman’s Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:

8.1. Monthly Tailings Reports

Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All
daily and weekly tailings inspection forms will be attached to the report. A monthly inspection form
will also be attached. Quarterly inspection forms will accompany the report when applicable. The
report will be signed and dated by the preparer in addition to the Radiation Safety Officer and the
Mill Manager.

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8.2. DMT Reports

Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:

a) On a quarterly basis, all required information required by Part 1.F.2 of the
GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain
Water Level Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area
Elevation Monitoring), 3.2 (Weekly Inspection of Solution Levels in Roberts
Pond) and 3.3 (Weekly Feedstock Storage Area Inspections);

b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for
each of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;

c) With respect to the annual inspection of the New Decontamination Pad described
in Section 6.5(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;

d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; and

e) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.

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APPENDIX A

FORMS

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APPENDIX A (CONT.)
DAILY INSPECTION DATA

Inspector:________________
Date;___________________
Accompanied by:_________
Time:___________________

Any Item not “OK” must be documented. A check mark = OK, X = Action Required

I. TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B

Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation

II. OPERATIONAL SYSTEMS
Inspection Items Conditions of Potential Concern Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B

Water Level Greater Than Operating Level, Large Change
Since Previous Inspection

Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
Liner Observable Liner Damage

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III. DIKES AND EMBANKMENTS
Inspection Items Conditions of Potential
Concern
Dike 1-I Dike 1-
1A
Dike 2 Dike 3 Dike
4A-S
Dike
4A-EW
Dike
4B-S

Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas,
Areas of Seepage Outbreak
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect

Crest Cracks, Subsidence, Severe
Erosion
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect

IV. FLOW RATES
Slurry Line(s) Pond Return S-X Tails Spray System

GPM

V. PHYSICAL INSPECTION OF SLURRY LINES(S)

Walked to Discharge Point ____________Yes _____________No
Observed Entire Discharge Line ____________Yes _____________No

VI. DUST CONTROL
Cell 2 Cell 3 Cell 4A Cell 4B

Dusting
Wind Movement of Tailings

Precipitation: ______________________ inches liquid

Formatted Table
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General Meteorological conditions:__________________________
________________________________________________________
________________________________________________________

VII. DAILY LEAK DETECTION CHECK
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B

Leak
Detection
System
Checked
_________Checked

______Wet______Dry

Initial level__________

Final
level___________

Gal.
pumped_________
_________Checked

______Wet______Dry

Initial level__________

Final
level___________

Gal.
pumped_________
_________Checked

______Wet______Dry

Initial level__________

Final
level___________

Gal.
pumped_________
_________Checked

______Wet______Dry

Initial level__________

Final
level___________

Gal.
pumped_________
_________Checked

______Wet______Dry

Initial level__________

Final
level___________

Gal.
pumped_________

VIII OBSERVATIONS OF POTENTIAL CONCERN

Action Required
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[MAP OF
TAILINGS AREA]
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Formatted: Left
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APPENDIX A (CONT)

DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION

Date:_________________ Inspectors: ______________________________

1. Pond and Beach
elevations (msl, ft)
Cell 1: (a) Pond Solution Elevation
________________

(b) FML Bottom Elevation
______5597______
(c) Depth of Water above FML ((a)-(b)) _______________
Cell 4A: (a)Pond Solution Elevation
_______________
(b)FML Bottom Elevation ______5555.14__
(c)Depth of Water above FML ((a)-(b)) ______________

Cell 4B: (a)Pond Solution Elevation _______________

(b)FML Bottom Elevation ______5557.50
(c)Depth of Water above FML ((a)-(b)) ______________
(d)Elevation of Beach Area with Highest Elevation
(monthly) ____________
Roberts
Pond: (a)Pond Solution Elevation _______________
(b)FML Bottom Elevation ______5612.3___
(c)Depth of Water above FML ((a)-(b)) _______________

2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly ________

________________Depth to Liquid pre-pump
________________Depth to Liquid Post-pump

(all measurements are depth-in-pipe)

Pre-pump head is 38’-Depth to Liquid Pre-pump
= _______
Post-pump head is 38’ –Depth to Liquid Post-
pump = ______
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3. Leak Detection Systems

Observation:
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B

Is LDS wet or
dry?
_____wet
____dry
_____wet
____dry
_____wet
____dry
_____wet
____dry
_____wet
____dry
If wet, Record
liquid level:
_______Ft to
Liquid
_______Ft to
Liquid
_______Ft to
Liquid
_______Ft to
Liquid *
_______Ft to
Liquid *
If sufficient
fluid is
present, record
volume of
fluid pumped
and flow rate:
Volume
_______
Flow
Rate______
Volume
_______
Flow
Rate______
Volume
_______
Flow
Rate______
Volume
_______
Flow
Rate______
Volume
_______
Flow
Rate______
Was fluid
sample
collected?
____yes____no ____yes____no ____yes____no ____yes____no ____yes____no

(Same data as Daily Inspection Form. Record data on daily form).

Observation:
New Decon Pad,
Portal 1
New Decon Pad,
Portal 2
New Decon Pad
Portal 3

Is LDS (Portal)
wet or dry?
_____wet____dry _____wet____dry _____wet____dry
If wet, Record
liquid level:
_______Ft to
Liquid
_______Ft to
Liquid
_______Ft to
Liquid

If wet, Report to
RSO

4. Tailings Area Inspection (Note dispersal of blowing tailings):
__________________________________________________________________________________
______________________________________________________________________

5. Control Methods Implemented:__________________________________________________
____________________________________________________________________________________
________________________________________________________________________

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6. Remarks:_________________________________________________________________________
______________________________________________________________________

7. Contaminated Waste Dump (:_awaiting DRC
approval_________________________________________)
______________________________________________
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? _____ no _____ yes

If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.

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APPENDIX A (CONT.)

MONTHLY INSPECTION DATA

Inspector: ____________________________

Date: ________________________________

1. Slurry Pipeline: __________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
Pipe Thickness:____________(To be measured only during periods when the Mill is operating)

2. Diversion Ditches and Diversion Berm:

Observation:
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing _____yes_____no _____yes_____no _____yes_____no
Erosion _____yes_____no _____yes_____no _____yes_____no
Undesirable
Vegetation
_____yes_____no _____yes_____no _____yes_____no
Obstruction of
Flow
_____yes_____no _____yes_____no _____yes_____no

Diversion Berm:
Stability Issues _____yes_____n
o
Signs of Distress _____yes_____n
o

Comments:__________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

3. Summary of Activities Around Sedimentation Pond: ____________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
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____________________________________________________________________________________
____________________________________________________________________________________

4. Overspray Dust Minimization:

Overspray system functioning properly: _______yes_______no

Overspray carried more than 50 feet from the cell: _____yes______no
If “yes”, was system immediately shut off? _____yes_____no

Comments:__________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

5. Remarks: ________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

6. Settlement Monitors

Cell 2 W1: ____________ Cell 2W3-S: ____________ Cell 3-1N: _____________
Cell 2 W2: ____________ Cell 2E1-N: ____________ Cell 3-1C: _____________
Cell 2 W3: ____________ Cell 2E1-1S: ____________ Cell 3-1S: _____________
Cell 2 W4: ____________ Cell 2E1-2S: ____________ Cell 3-2N: _____________
Cell 2W7-C: ____________ Cell 2 East: ____________ Cell 2W5-N: ___________
Cell 2 W7N: ____________ Cell 2 W7S: ____________ Cell 2 W6N: ___________
Cell 2 W6C: ____________ Cell 2 W6S: ____________ Cell 2 W4N: ___________
Cell 4A-Toe: ___________ Cell 2 W4S: ____________ Cell 2 W5C: ___________
Cell 3-2C: _____________ Cell 3-2S: _____________ Cell 2 W5S: ___________

7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

7.8. Summary of Daily, Weekly and Quarterly Inspections: __________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
Formatted: No bullets or numbering
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____________________________________________________________________________________

8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading): __________________

9. Monthly Slimes Drain Static Head Measurement for Cell 3 (Depth-in-Pipe Water level) (after
Cell 3 is closed): __________________

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APPENDIX A (CONT.)

WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM

QUARTERLY INSPECTION DATA

Inspector: ____________________________

Date: ________________________________

1. Embankment Inspection: ______________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
________________________________________________

2. Operations/Maintenance Review: _______________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
________________________________________________

3. Construction Activities: ____________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
________________________________________________

4. SummaryEstimated Areas:
___________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
________________________________________________
4.
Formatted: Outline numbered + Level: 1 +Numbering Style: 1, 2, 3, … + Start at: 1 +Alignment: Left + Aligned at: 0" + Tab after:
0.25" + Indent at: 0.15", Widow/Orphancontrol
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Cell 3 Cell 4A Cell 4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area

Comments: Formatted: Left
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APPENDIX A (CONT.)

ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT

Week of _________ through _________ Date of Inspection:_________________

Inspector:_________________________

Weather conditions for the week:
____________________________________________________________________________________
____________________________________________________________________________________
________________________________________________

Blowing dust conditions for the week:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________

Corrective actions needed or taken for the week:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________

Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:_______ no:________
comments:____________________________________________________________________________
___________________________________________________________

Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes:_______ no:_______
comments (e.g., conditions of containers):______________________________________
____________________________________________________________________________________
____________________________________________________________

Are all sumps and low lying areas free of standing solutions?
Yes: _______ No: _______
If “No”, how was the situation corrected, supervisor contacted and correction date?
____________________________________________________________________________________
____________________________________________________________________________________

Is there free standing water or water running off of the feedstock stockpiles?
Yes: ______ No: _______
Comments:___________________________________________________________________________
____________________________________________________________________________________
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____________________________________________________________________________________
_____________________________________________

Other comments:
____________________________________________________________________________________
____________________________________________________________________________________
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APPENDIX A (CONT.)

ANNUAL DECONTAMINATION PAD INSPECTION

Date of Inspection: _________________

Inspector: _________________________

New Decontamination Pad:

Are there any cracks on the wash pad surface greater than 1/8 inch of separation? __Yes ___No

Is there any significant deterioration or damage of the pad surface? ____Yes ____No

Findings:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

Repair Work Required:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

Existing Decontamination Pad:

Were there any observed problems with the steel tank? ____Yes ____No

Findings:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

Repair Work Required:
____________________________________________________________________________________
____________________________________________________________________________________
____________________________________________________________________________________

Note For the annual inspection of the both the Existing and New Decontamination Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2nd Quarter report, due September 1 of each
calendar year
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APPENDIX B

TAILINGS INSPECTOR TRAINING

This document provides the training necessary for qualifying management-designated individuals
for conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections.
Tailings inspection forms will be included in the monthly tailings inspection reports, which
summarize the conditions, activities, and areas of concern regarding the tailings areas.

Notifications:

The inspector is required to record whether all inspection items are normal (satisfactory, requiring
no action) or that conditions of potential concern exist (requiring action). A “check” mark indicates
no action required. If conditions of potential concern exist the inspector should mark an “X” in the
area the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.

Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).

Inspections:

All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:

1. Tailings Slurry Transport System:

The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
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inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.

2. Operational Systems:

Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks,
severe erosion or cavities are also items that require investigation and notation on daily
forms. Exposed liner or absence of cover from erosion are potential items of concern for
ponds and covered areas. These should also be noted on the daily inspection form.

Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It
is important to cover exposed liner immediately as exposure to sunlight will cause
degradation of the PVC liner. Small areas of exposed liner should be covered by hand.
Large sections of exposed liner will require the use of heavy equipment

These conditions are considered serious and require immediate action. After these
conditions have been noted to the Radiation Safety Officer, a work order will be written by
the Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.

3. Dikes and Embankments:

Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an “X” mark should be placed in the section marked
for that dike.

In addition, the dikes, in particular dikes 3, 4A-S, 4A-WE, and 4B-S, and 4B-W, should be
inspected closely for mice holes and more importantly for prairie dog holes, as the prairie
dogs are likely to burrow in deep, possibly to the liner. If any of these conditions exist, the
inspection report should be marked accordingly.
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4. Flow Rates:

Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as “0”. The same holds true when the spray system is not utilized.

5. Physical Inspection of Slurry Line(s):

A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If “fill to elevation” flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.

6. Dust Control:

Dusting and wind movement of tailings should be noted for Cells 2, 3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.

The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the ShifterEnvironmental, Health and Safety personnel as
close to 8:00 a.m. as possible. All snow or ice should be melted before a reading is taken.

7. Observations of Potential Concern:

All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.

8. Map of Tailings Cells:

The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
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1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating

9. Safety Rules:

All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:

1. The posted speed limit on Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell 4A and 4B dike) is 15 mph. These limits and should
not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.

10. Preservation of Wildlife:

Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.

11. Certification:

Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
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Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
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APPENDIX C

CERTIFICATION FORM

Date: __________________________

Name: _________________________

I have read the document titled “Tailings Management System, White Mesa Mill Tailings
Inspector Training” and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.

____________________________________
Signature

I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.

____________________________________
Radiation Safety Personnel/ Tailings System
Supervisor

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APPENDIX D
FEEDSTOCK STORAGE AREA

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APPENDIX E

TABLES
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Table 1A

Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah

Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01

Table 1B

Calculated Action leakage Rates
for Various head Conditions
Cell 4B White mesa Mill
Blanding, Utah

Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20

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APPENDIX F

Example of Freeboard Calculations
For Cell 4B

Assumptions and Factors:

o Total PMP volume to be stored in Cell 4A – 159.4 acre feet
o Wave runup factor for Cell 4A – 0.77 feet
o Total capacity of Cell 4B – 2,094,000 dry tons
o Elevation of FML of Cell 4B – 5,600.35 FMSL
o Maximum pool surface area of Cell 4A – 40 acres
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL – 1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL – March 1, 2012*
o Expected and actual production is as set forth in the following table:

Time Period Expected Tailings Solids Disposition into Cell 4B Determined at
the beginning of
the period (dry
tons)*
Expected Tailings Solids Disposition into Cell
4B at the
beginning
of the
period,
multiplied
by 150%
Safety
Factor
(dry tons)
Actual TailingsSolids Disposition into Cell 4B determined at
end of the
period (dry
tons)*

March 1, 2012
to November 1,
2012
150,000 225,000 225,000
November 1, 2012 to November 1, 2013
300,000 450,000 275,000
November 1, 2013 to November 1, 2014
200,000 300,000 250,000

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*These expected and actual tailings and production numbers and dates are fictional and have been assumed for illustrative purposes only. Based on these assumptions and factors, the freeboard limits for Cell 4B would be calculated as follows: 1. Prior to March 1, 2012 Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4B is less than or equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL. 2. March 1, 2012 to November 1, 2012 The pool surface area would be reduced to the following amount (1 – 225,000 / (2,094,000 – 1,000,000)) x 40 acres = 31.77 acres Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77 acres equals 6.22 feet. When the wave run up factor for Cell 4B of 0.77 feet is added to this, the total freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B would be reduced from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit would persist until November 1, 2012. 3. November 1, 2012 to November 1, 2013 The pool surface area would be reduced to the following amount: First, recalculate the pool surface area that should have applied during the previous period, had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period. Since the actual tonnage of 225,000 dry tons was the same as the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as the modeled pool surface area for the previous period, which is 31.77 acres. Then, calculate the modeled pool surface area to be used for the period: (1 – 450,000 / (2,094,000 – 1,000,000 - 225,000)) x 31.77 acres = 15.32 acres Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 15.32 acres equals 12.89 feet. When the wave run up factor for Cell 4B of 0.77 feet is added to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell 4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66 feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at November 1, 2012, and this freeboard limit would persist until November 1, 2013.
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4. November 1, 2013 to November 1, 2014 The pool surface area would be reduced to the following amount: First, recalculate the pool surface area that should have applied during the previous period, had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool area was reduced too much during the previous period, and must be adjusted. The recalculated pool area for the previous period is: (1 – 275,000 / (2,094,000 – 1,000,000 - 225,000) x 31.77 acres = 21.72 acres. This recalculated pool surface area will be used as the starting point for the freeboard calculation to be performed at November 1, 2013. Then, calculate the modeled pool surface area to be used for the period: (1 – 300,000 / (2,094,000 – 1,000,000 - 225,000 – 275,000)) x 21.72 acres = 10.75 acres Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 10.75 acres equals 18.37 feet. When the wave run up factor for Cell 4B of 0.77 feet is added to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell 4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at November 1, 2013, and this freeboard limit would persist until November 1, 2014.