DRC-2011-006289 - 0901a0688023a070

DENISO
MINES
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 60265
USA
Tel: [phone]
Fax:[phone]
www.denteonm I nes.com
May 31, 2011
Sent VIA Federal Express
Mr. Rusty Lundberg
Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Re: Transmittal of DMT Performance Standards Monitoring Report and CeU 4A and
CeU 4B BAT Performance Standards Monitoring Report for the 1st Quarter of 2011
Dear Mr. Lundberg:
Enclosed please fmd two copies of the DMT Performance Standards Monitoring Report and Cell
4A and CeU 4B BAT Performance Standards Monitoring Report for the 1st Quarter of 2011, as
required under Parts I.F.2 and I.F.3 of the White Mesa MiU's State of Utah Groundwater
Discharge Permit No. UGW370004. Also enclosed are two CDs, each with an electronic word-
searchable copy of the enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc David C. Frydenlund
Ron F, Hochstein
Harold R. Roberts
David E.Turk
Kathy Weinel
OENISOJ)~~
MINES
May 31,2011
Sent VIA Federal Express
Mr. Rusty Lundberg
Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: Transmittal of DMT Performance Standards Monitoring Report and Cell 4A and
Cell4B BAT Performance Standards Monitoring Report for the 1st Quarter of2011
Dear Mr. Lundberg:
Enclosed please find two copies of the DMT Performance Standards Monitoring Report and Cell
4A and Cell 4B BAT Performance Standards Monitoring Report for the 1 st Quarter of 2011, as
required under Parts I.F.2 and I.F.3 of the White Mesa Mill's State of Utah Groundwater
Discharge Permit No. UGW370004. Also enclosed are two CDs, each with an electronic word-
searchable copy of the enclosed Report.
If you have any questions regarding this Report, please contact the undersigned at (303) 389-
4132 or Mr. David Turk at [phone].
Yours very truly,
~ Cs (USAl CORPo
JoAnn Tischler
Director, Compliance and Permitting
cc David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Kathy Weinel
WHITE MESA URANIDM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A and
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
lst Quarter
January through March
2011
State of Utah
Groundwater Discharge Pennit No. UGW370004
Prepared By:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO. 80265
May 31,2011
TABLE OF CONTENTS
1.0 INTRODUCTION .............................................................................................................. 1
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER ......................................................................................................................... 1
3.0 WEEKLY TAILINGS WASTEWATER POOL ELEVATION MONITORING ..... 2
4.0 MONTHLY SLIMES DRAIN WATER LEVEL MONITORING .............................. 4
4.1 GENERAL .......................................................................................................................... 4
4.2 RESULTS FOR THE QUARTER ............................................................................................. 5
4.3 QUALITY ASSURANCE EVALUATION AND DATA VALIDATION .......................................... 6
4.4 GRAPHIC COMPARISON TO PREVIOUS YEAR ..................................................................... 6
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND ............... 6
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK
STO RAGE AREA ............................................................................................................. 6
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS ................................... 7
8.0 DECONTAMINATION PADS ........................................................................................ 8
8.1 SUMMARY OF WEEKLY INSPECTIONS ................................................................................ 8
8.2 ANNUAL INSPECTION OF EXISTING DECONTAMINATION PAD ........................................... 9
8.3 ANNUAL INSPECTION OF NEW DECONTAMINATION PAD ................................................... 9
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR
THE QUARTER ............................................................................................................. 10
9.1 LDS MONITORING .......................................................................................................... 10
9.1.1 Operational Status ofLDS Pumping and Monitoring Equipment .............................. 10
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary Membrane
10
9.1.3 Measurement of the Volume of Fluids Pumped from the LDS ................................... 11
9.2 MEASUREMENT OF WEEKLY WASTEWATER FLUIDS IN CELL 4A .................................... 11
9.3 SLIMES DRAIN RECOVERY HEAD MONITORING .............................................................. 11
10.0 ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2011 ............................................................................................... 12
11.0 SIGNATURE AND CERTIFICATION ....................................................................... 13
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LIST OF TABLES
Table 1-Summary of Waste Water Pool Elevations
Table 2 -New Decontamination Pad Inspection Portal Level for the First Quarter 2011
ATTACHMENTS
A Tailings Cell and Roberts Pond Wastewater Elevations
B Notices Pursuant to Part I.G.3 of the Pennit
C Monthly Cell 2 Slimes Drain Monitoring Data
D Graph ofCe112 Slimes Drain Water Levels Over Time
E Cell Liner Repair Reports and Notices
F Cell4A and Cell4B Leak Detection System Data for the Quarter and BAt O&M Plan
Table 1A
G Annual Inspection Forms for Existing and New Decontamination Pads (part I.F.12)
ii
WHITE MESA URANIUM MILL
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
FOR THE lst QUARTER OF 2011
1.0 INTRODUCTION
This is the routine Discharge Minimization Technology ("DMT") Perfonnance Standards
Monitoring Report for the 1st quarter of2011 (the "Quarter") prepared by Denison Mines (USA)
Corp. ("Denison"), as required under Part I.F.2 of the White Mesa Mill's (the "Mill's") State of
Utah Groundwater Discharge Pennit No. UGW370004 (the "Pennit"), and the Routine Cell 4A
and Ce1l4B Best Available Technology ("BAT") Perfonnance Standards Monitoring Reports for
the Quarter, as required under Part I.F.3 ofthe Pennit.
2.0 MEASUREMENTS TAKEN AND MONITORING PERFORMED DURING THE
QUARTER
During the Quarter, the following DMT monitoring was perfonned or addressed, as required
under Part I.D.3, I.E.7, and I.F.11 of the Pennit:
• Weekly tailings wastewater pool elevations for tailings Cells 1 and 3 (Part
I.E.7(a));
• Monthly slimes drain water levels in Cell 2 (Part I.D.3(b)(1) and (2»;
• Annual Slimes Drain Compliance (Part I.D.3 (b) and I.F.11);
• Weekly wastewater level measurements in Roberts Pond (part I.D.3(e) and Part
I.E.7(a));
• Weekly feedstock storage area inspections and inspections of feedstock materials
stored outside of the feedstock storage area (Part I.D.3(f) and Parts I.E.7(d) and
(e);
• Any tailings cell and pond liner system repairs (Part I.E.7 (f) and Part I.E.(8)(c));
• Weekly New Decontamination Pad Inspection (Part I.E.7 (g» and
• Annual Decontamination Pad Concrete Inspection (Part I.F.11) (not required this
reporting period)
Also during the Quarter, the following Cell 4A and 4B BAT perfonnance standards monitoring
was perfonned, or addressed, as applicable and as required by Parts I.E.8 and I.E.12 of the
Pennit:
• Leak detection system ("LDS") monitoring for Cell 4A (Part I.E.8.(a)) and Cell
4B (Part I.E.12 (a»); and
• Weekly tailings wastewater pool elevations for tailings Cell 4A (Part I.E.8 (a))
and Ce1l4B (Part I.E.12 (a)).
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3.0 WEEKL Y TAILINGS WASTEWATER POOL ELEVATION MONITORING
Mill personnel monitored and recorded weekly the elevation of wastewater in Tailings Cells 1,3,
and 4A, during the first quarter 2011 as noted below, to ensure compliance with the maximum
wastewater elevation criteria mandated by Condition 10.3 of the Mill's State of Utah Radioactive
Materials License No. UT 1900479 (the "License"). The requirements to monitor and record the
wastewater pool elevations for Cell 3 and Cell 4A were removed by the Executive Secretary of
the State of Utah Radiation Control Board (the "Executive Secretary") during the first quarter
2011 as detailed below. All of the wastewater measurements reported herein were made from an
elevation survey. The results of such monitoring, reported as feet above mean sea level (finsl),
are included in Attachment A. It is important to note that wastewater pool elevation surveys
were not conducted for Cell 4B because the fluid levels were too low to measure, that is, below
the level at which the survey can be conducted from the bank of Cell 4B. However, during the
quarter the Cell 4B fluid did not exceed the 5581.10 finsl elevation based on a survey taken May
31,2011.
Condition 10.3 of the License provides that the freeboard limit for Cell 1 shall be set in
accordance with procedures that have been approved by the U.S. Nuclear Regulatory
Commission ("NRC"). Under those procedures the freeboard limit for Cell 1 is set as per the
January 10, 1990 Drainage Report for CellI at a liquid maximum elevation of5,615.4 fins!'
Condition 10.3 of the License also provides that the freeboard limit for Cells 3, 4A and 4B shall
be recalculated annually in accordance with the procedures approved by the Executive Secretary.
The current freeboard limit for Cell 3 was previously calculated under this procedure at 5,601.6
fins!' However, in a letter from the Executive Secretary dated November 20, 2008, an interim
variance and limit was established at 5,602.5 finsl for Cell 3.
Cell 3 is nearly filled and pre-closure activities are underway. As discussed in the DMT
Performance Standards Monitoring Report and Cell 4A BAT Performance Standards Monitoring
Report for the 4th Quarter of 2010, the process of filling Cell 3 with solids and the reduction of
the liquid "pool" area to a number of small "puddles" has rendered the freeboard limit
meaningless. The solids filling activities in the third quarter of 2010 resulted in two apparent
exceedances of the freeboard limit, which were the subject of a Notice to the Executive Secretary
under Part I.G.3 of the Permit and Utah Administrative Code ("UAC") R317-6-6.16(C), dated
August 4, 2010. The notice of August 4,2010 explained that it is no longer possible to manage
the Cell 3 freeboard to achieve the calculated freeboard limit during the final stages of filling
Cell 3 with solids and closing Cell 3. The continuing solids filling process during the first
quarter of 2011 resulted in all but three of the weekly fluid elevation measurements remaining
above the freeboard limit of 5,602.50 finsl as anticipated in the notice of August 4, 2010.
However, as discussed below, at no time has the fluid level exceeded the maximum wastewater
elevation of 5605.5 finsl as required under Part I.D.2 of the Permit. A letter from the Executive
Secretary dated January 27, 2011 which approved the use of Cell 4B and a subsequent letter
dated March 14, 2011, stated that authorization of the use of Cell 4B and approval of the DMT
and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated the former
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freeboard elevation requirements for tailings Cell 3. The approvals of the DMT and Cell 4A
O&M Plans also resolved previous freeboard exceedance issues discussed above and further
stated that former issues regarding the freeboard exceedances for Cell 3 are closed-out. Pursuant
to the receipt of the March 14, 2011 letter, freeboard elevation survey measurements in Cell 3
were no longer required or conducted.
During the 1 st quarter 2011, the requirements to measure the wastewater in Cell4A changed as a
result of the approval to use tailings Cell 4B. A January 6, 2011 telephone conference as
documented in a January 13, 2011 letter from the Executive Secretary, noted that rising
wastewater levels were measured in Cell 4A while Denison was awaiting DRC review of
construction of Cell 4B. The January 13, 2011 letter provided conditional approval of the
variance request for the freeboard limits for Cell 4A noting that upon approval of Cell 48, any
freeboard limit exceedance would be resolved as wastewater flows over the spillway constructed
between Cell 4A and Cell 4B. During the January 6, 2011 call, DRC agreed to exercise
enforcement discretion for a limited time regarding excess Cell 4A wastewater level conditions,
contingent upon daily reporting of wastewater levels among other conditions. Denison met the
required conditions specified in the January 13, 2011 Executive Secretary letter. Daily reporting
was completed as required and the daily reports were submitted under separate cover via
electronic mail. The daily measurements are included in Attachment B.
A letter from the Executive Secretary dated January 27,2011 which approved the use of Cell 48
and a subsequent letter dated March 15, 2011, stated approval of the DMT and Cell 4A
Operations and Maintenance ("O&M") Plans effectively eliminated the former freeboard
elevation requirements for tailings Cell 4A. The approvals of the DMT and Cell 4A and 48
O&M Plans also resolved previous freeboard exceedance issues discussed above and further
stated that former issues regarding the freeboard exceedances for Cell 4A are closed-out.
Pursuant to the receipt of the March 15, 2011 letter, freeboard elevation survey measurements in
Ce1l4A were no longer required or conducted.
In addition, Part I.D.2 of the Permit provides that under no circumstances shall the freeboard of
any tailings cell be less than three feet, as measured from the top of the flexible membrane liner
(nFMLn). The top of the FML in CellI is at 5,618.5 finsl, the top of the FML in Cell4A is at
5,598.5 finsl and the top of the FML in Cell 48 is 5600.4 finsl. This means that the maximum
wastewater pool elevations in Cells 1, 4A and 48 permitted under Part I.D.2 of the Permit are
5,615.5,5,595.5 and 5597.4 finsl, respectively.
The wastewater pool elevations in Cells 1, 3 and 4A, as measured during the Quarter are
summarized in the following Table 1. The wastewater elevation measurements for Cell 3 and
Cell 4A are for the period prior to the elimination of that requirement as documented on March
14 and 15, 2011 respectively. As previously noted the wastewater pool elevations were not
measured in Cell 48 because the fluid levels were too low to measure, that is, below the level at
which the survey can be conducted from the banks of Cell 4B. However, during the quarter the
wastewater levels in Cell 48 did not exceed 5581.10 finsl, which is the elevation surveyed on
May 31, 2011. As indicated in Table 1, the applicable freeboard limits were not exceeded
during the Quarter for Cell 1. As noted above, the freeboard limits for Cell 4A were exceeded;
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however, the DRC agreed to exercise enforcement discretion for a limited time pending their
approval for the use ofCell4B.
Table 1-Summary of Waste Water Pool Elevations
Tailings Maximum Maximum Maximum
Cell Wastewater Elevation Wastewater Elevation Wastewater
Measured During the Permitted Under Elevation Permitted
Quarter (fmsl) License Condition Under Part I.D.2 of
10.3 (fms1) the Permit (fmsl)
CellI 5614.20 5,615.40 5,615.50
Cell 3 5,604.34* No Limit No Limit
(5,602.50**) (5,605.50**)
Cell4A 5,594.21 No Limit No Limit
(5,593.74***) (5,595.50***)
Cell4B < 5581.10**** 5594.6 5597.4
*This IS the maXImum wastewater elevatIOn ill Cell 3 dunng the Quarter. The reqUIrement to morutor the Cell 3
freeboard was removed during the quarter.
** The Executive Secretary approved the removal of the Cell 3 freeboard limit and authorized the use of Cell 4B on
January 27,2011. Cell 3 is nearly full of solids, and is undergoing pre-closure steps.
*** The Executive Secretary granted a variance from the Cell 4A freeboard limit on January 13, 2011, and
approved the removal of the Cell 4A limit and authorized the use of Cell 4B on January 27, 2011. The previous
freeboard limit noted above for Cell4A was not set out in the License. The freeboard limit of 5,593.74 for Cell4A
was set out in a letter from the Executive Secretary dated November 20,2008. Denison proposed in the DMT Plan
revision dated November 12, 2010 the removal of the freeboard limit for Cell 4A to be replaced by a freeboard limit
for new Ce1l4B that will accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B.
**** Wastewater elevations in Cell 4B were not measured during the quarter because the wastewater levels were
below the level that could be measured from the bank of the cell. However, during the quarter, the wastewater
elevation in Ce1l4B did not exceed 5581.10 fmsl, which is the elevation that was surveyed on May 31,2011.
It should be noted that the Executive Secretary approved the revisions to the DMT Plan, and
authorized use of Cell 4B on January 27, 2011. Based on this approval, measurements of the
wastewater elevations in Cell 3 and Cell 4A are no longer required and will not be reported in
future DMT quarterly reports.
4.0 MONTHLY SLIMES DRAIN WATER LEVEL MONITORING
4.1 General
Part I.D.3(b)(1) of the Permit provides that the Permittee shall at all times maintain the average
wastewater recovery head in the slimes drain access pipes of each of Cells 2 and 3 to be as low
as is reasonably achievable, in accordance with the DMT Plan. Part I.D.3(b)(3) of the Permit
provides that for Cell 3, this requirement shall apply after initiation of dewatering operations.
Part I.D.6(c) of the Permit provides that, after the Permittee initiates pumping conditions in the
slimes drain layer in Cell 4A, the Permittee will provide: 1) continuous declining fluid heads in
4
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the slimes drain layer, in a manner equivalent to the requirements found in Part I.D.3(b), and 2) a
maximum head of 1.0 feet in the tailings (as measured from the lowest point of the upper FML)
in 6.4 years or less. Similarly, Part I.D.13(c) of the Permit provides that, after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4B, the Permittee will provide: 1)
continuous declining fluid heads in the slimes drain layer, in a manner equivalent to the
requirements found in Part I.D.3(b), and 2) a maximum head of 1.0 feet in the tailings (as
measured from the lowest point ofthe upper FML) in 5.5 years or less.
Part I.D.3(b )(2) of the Permit provides that the Permittee shall conduct a monthly slimes drain
recovery test at each tailings cell that meets the following minimum requirements: 1) includes a
duration of at least 90-hours, as measured from the time that pumping ceases, and 2) achieves a
stable water level at the end of the test, as measured by three consecutive hourly water level
depth measurements, with no change in water level, as measured to the nearest 0.01 foot.
At this time, dewatering operations have not commenced in Cell 3 nor has the Mill initiated
pumping conditions in the slimes drain layer ofCell4A or Ce1l4B. As a result, the requirements
in Part I.E.7(b) to monitor and record monthly the depth to wastewater in the slimes drain access
pipes as described in Part I.D.3 of the Permit apply only to Cell 2 at this time. Accordingly, this
Report is limited to slimes drain recovery head information relating to Cell 2 only.
Pursuant to Parts I.E.7(b) and I.F.2 of the Permit, Section 8.2 of the DMT Plan and
correspondence from DRC, dated February 7,2008, the results of monthly recovery monitoring
of the slimes drain for Cell 2 are to be recorded and included with the results of quarterly
monitoring in the quarterly White Mesa Mill DMT Performance Standards Monitoring Report
and Cell4A and Cell4B BAT Performance Standards Monitoring Reports (the "DMT Reports").
Further, beginning in 2008, quarterly DMT Reports must include both the current year monthly
values and a graphic comparison to the previous year. An annual slimes drain recovery head
report, that addresses the requirements of Part I.F .11 of the Permit and Section 8.2 of the DMT
Plan must be included in the 4th quarter DMT Report.
4.2 Results for the Quarter
In accordance with these requirements, the individual monthly slimes drain recovery head
monitoring data for the Quarter, which includes the date and time for the start and end of the
recovery test, the initial water level, and the final depth to stable water level, is included as
Attachment C to this Report.
It should be noted that the Cell 2 slimes drain water level decreased from February to March
2011. Although not within this reporting period, the April and May 2011 water levels also
decreased. The April and May data will be reported in the second quarter 2011 DMT report
submitted on or before September 1, 2011.
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4.3 Quality Assurance Evaluation and Data Validation
Denison management has evaluated all slimes drain data collected, data collection methods, and
all related calculations required by the Permit, and have verified the accuracy and reliability of
both the data and calculations reported.
As a result of its quality assurance evaluation and data validation review, Denison has concluded
that all of the 2009, 2010 slimes drain tailings fluid elevation measurements and the 2011
monthly slimes drain tailings fluid elevation measurements to date meet the test performance
standards found in Part I.D.3(b)(2) of the Permit and can be used for purposes of determining
compliance with the requirements of Part I.D.3(b)(2) ofthe Permit.
4.4 Graphic Comparison to Previous Year
A graph showing the final depth to stable water level readings for each month in 2009 through
2011, for which validated data is available (see Section 4.3 above), is included as Attachment D,
which shows a graphic comparison of this Quarter's data to data for 2009 and 2010.
5.0 WEEKLY WASTEWATER LEVEL MONITORING: ROBERTS POND
During the Quarter, Mill personnel monitored and recorded weekly the wastewater levels at
Roberts Pond to determine compliance with the DMT operations standards in Part I.D.3(e) of the
Permit. Part I.D.3(e) of the Permit provides that the water level in Roberts Pond shall not exceed
an elevation of 5,624 finsl.
The maximum wastewater elevation measured in Robert's Pond during the quarter was 5623.70
finsl, which did not exceed the maximum permitted elevation of 5,624 finsl. The results of such
monitoring are included in Attachment A.
6.0 WEEKLY FEEDSTOCK STORAGE AREA INSPECTIONS AND INSPECTIONS
OF FEEDSTOCK MATERIAL STORED OUTSIDE THE FEEDSTOCK STORAGE
AREA
Weekly feedstock storage area inspections were performed by the Mill's Radiation Safety
Department, to confirm that the bulk feedstock materials are stored and maintained within the
defined area described in the Permit and that all alternate feedstock located outside the defined
feedstock area is maintained within containers that comply with the requirements of Part I.D.11
of the Permit. The results of these inspections are recorded on the Weekly Mill Inspection
forms, which are available at the Mill for inspection. Two items were noted during the first
quarter inspections. During the first part of the quarter there were several inspections where
there was standing frozen water on the ground near the feedstock piles due to weather
conditions. As the areas melted, the ground was graded so that the solution moved down the
sumps and out to the tailings cells. Also, during the week of March 20, 2011 the road grader hit
4 drums ofKF Alternate Feed that is stored in steel drums on the Ore Pad. The four drums were
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placed in steel over-pack drums and placed back into the stockpile. No other items were noted
during the first quarter inspections.
7.0 TAILINGS CELLS AND POND LINER SYSTEM REPAIRS
The liner systems at Cells 1, 2, and 3 were inspected on a daily basis pursuant to the
requirements of Sections 2.1 and 2.2 of the Mill's DMT Plan. The results of those inspections
are recorded on the Mill's Daily Inspection Data sheets, which are available at the Mill for
review. A visual inspection of Roberts Pond was performed on a weekly basis. The results of
those inspections are recorded on the Weekly Mill Inspection forms, which are available at the
Mill for review.
In accordance with Part I.E.7(f) of the Permit, in the event that any liner defect or damage is
identified during a liner system inspection, the Mill shall immediately implement the currently
approved Liner Maintenance Provisions. Further, Part I.F. 2 of the Permit provides that when a
liner repair is performed at any tailings cell or at Roberts Pond, a Repair Report shall be prepared
and included with the next quarterly DMT report.
Mill personnel detected an accumulation of fluid in the LDS standpipe of Cell 1 on Wednesday,
June 2,2010. Transfer of fluids from CellI to Cell4A to lower the CellI level sufficiently to
detect and repair any damage began on June 2,2010. Maintenance identified some FML damage
and performed repairs during the period when the level was lowest. Following the repairs, the
level was allowed to gradually return to its June 3 level of 5614.57 feet and the LDS remained
dry until, after a period of heavy rains in late July and early August (and an increase in the
solution in level in CellI), a recurrence of the LDS liquid level was identified on August 7,
2010. At that time, the Mill resumed pumping CellI to Cell4A to lower the solution level.
During discussions on August 12,2010, DRC personnel agreed with Denison that both the June
and August identifications of LDS solutions were part of one event. The temporary cessation of
flow into the LDS between June and August detections may have resulted from lowering the
solution level to a point below some tears or damage that were not identified during the July
repair efforts. Denison submitted to DRC a plan and schedule for inspection and repair, if
necessary, ofthe inside slope areas of the CellI FML above the 5613 foot level, on August 18,
2010, and updated plan on August 30,2010. DRC conditionally approved the updated plan in a
letter dated September 22, 2010. The updated plan commits to completion ofthe repairs by July
31,2012.
The September 22,2010 DRC letter and Part l.F.2 of the groundwater discharge permit require
that the repairs be documented in a liner repair report which shall be included with the next
quarterly DMT report, that is, in the DMT Report following completion of the repairs to be
reported. Consistent with the proposed date for completion of repairs in July 2012, Denison will
include the required repair report with the third quarter DMT report to be submitted on
December 1,2012.
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During the Quarter, no liner repairs were perfonned at any of the Mill's tailings cells other than
Cell 1. Consistent with the approved repair plan and schedule, repairs to the Cell 1 FML were
conducted during the months of September and October 2010, ceased during the months of
November and December 2010. Repairs to the Cell1liner resumed in April 2011.
8.0 DECONTAMINATION PADS
8.1 Summary of Weekly Inspections
Part I.F.7 (g) of the Permit and Section 3.1 of the DMT Plan require that a weekly inspection of
the New Decontamination Pad be perfonned, including that the vertical inspection portals on the
New Decontamination Pad which are located between the primary and secondary containments
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 containments. The BAT
perfonnance standards for the New Decontamination Pad are set out in Part I.D.l4 of the Pennit.
The New Decontamination Pad was placed into service on March 22, 2010. Use of the New
Decontamination Pad was temporarily suspended during the second quarter 2010 as a result of a
cease and desist order from DRC dated May 18, 2010. Because the New Decontamination Pad
was not in use after the second quarter 2010, the weekly inspections of the containments were
stopped for the remainder of 2010. The Executive Secretary provided authorization for use of
the New Decontamination Pad in a letter dated February 1, 2011. Use of the New
Decontamination Pad resumed in February 2011 and the weekly inspections were resumed as
required.
Table 2 below indicates the water level measurements in each portal measured during the 1 st
quarter 2011 after receipt of authorization for use from the Executive Secretary that correspond
to the usage of the New Decontamination Pad.
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Table 2 -New Decontamination Pad Inspection Portal Level for the First Quarter 2011
I.
2.
Portal! Portal! Portal!
Liquid Level Liquid Level Liquid Level
Date (in Feeti (in Feet) (in Feetl
1/7/2011 Not Measured2 Not Measuredz Not Measuredl
1114/2011 Not Measured~ Not Measured2 Not Measured~
112112011 Not Measured· Not Measuredz Not Measuredl
1128/2011 Not Measured' Not Measured~ Not Measured~
2/4/2011 0.00 0.00 0.00
2111/2011 0.00 0.00 0.00
2/18/2011 0.00 0.00 0.00
2/25/2011 0.00 0.00 0.00
3/4/2011 0.00 0.00 0.00
311112011 0.00 0.00 0.00
3118/2011 0.00 0.00 0.00
3/25/2011 0.00 0.00 0.00
4/1/2011 0.00 0.00 0.00
As per part I.D.14 of the Permit, the water level shall not exceed 0.10 foot above the cement floor in any LDS access
pipe at any time.
The New Decontamination Pad portals were not measured during this time because it was not in use. The Executive
Secretary letter dated February 1, 2011 authorized the use of the New Decontamination Pad.
As can be seen from the foregoing table, no fluids were observed to be present in any of the
portals during the first quarter.
Any soil and debris identified during the weekly inspections was removed from the wash pad of
the New Decontamination Pad, in accordance with part I.D.14 (a) of the Permit and Section 3.1
(e)(i)(F) of the DMT Plan. No cracks greater than 1/8" were observed during any weekly
inspections.
8.2 Annual Inspection of Existing Decontamination Pad
As required by Part I.F.12 of the Permit, annual inspections of the existing decontamination pad
will be conducted during the second quarter 2011. The documentation for the annual inspections
will be reported in the Second Quarter DMT report to be submitted on or before September 1,
2011.
8.3 Annual Inspection of New Decontamination Pad
As previously stated, the New Decontamination Pad was placed into service on March 22,2010.
Use of the New Decontamination Pad was temporarily suspended as a result ofa cease and desist
order from DRC dated May 18, 2010. DRC's approval for use of the New Decontamination Pad
was granted on February 1, 2011, following submittal of revisions to the DMT Plan and DRC
observation of hydrostatic testing of the in-ground water holding tanks. Revisions to the DMT
Plan were submitted by Denison on November 12, 2010 and reviewed by DRC. Hydrostatic
9
N:\Required Reports\DMT RepOlts\2011 DMTlQl 2011 DMT RepOlt\Ql 2011 DMT Rep011.docx
testing was re-perfonned from November 24 to 26, 2010 following a 10-day advanced notice to
DRC on November 12, 2010. The Executive Secretary provided an authorization for use of the
New Decontamination Pad in a letter dated February 1, 2011. Use of the New Decontamination
Pad resumed in February 2011.
The New Decontamination Pad was taken out of service and inspected during the second quarter
2010 to ensure integrity of the wash pad's exposed concrete surface, as required by Part I.F .12 of
the Pennit and Section 6.5 of the DMT Plan. No abnonnalities were identified. No significant
cracks (greater than 1/8 inch), deterioration or damage were identified. No repairs were required
at the time of the inspection. A few minor cracks (less than 1/8 inch) were observed. These
minor cracks were repaired to prevent additional deterioration even though the repairs are not
required by the Pennit. The 2011 annual inspection will be conducted during the second quarter
of 2011. The 2011 annual inspection will continue to monitor the items noted above which
resulted from the 2010 annual inspection.
9.0 CELL 4A AND CELL 4B BAT PERFORMANCE STANDARDS REPORT FOR
THE QUARTER
This Section constitutes the routine Cell 4A and Cell 4B BAT Performance Standards
Monitoring Report for the Quarter, as required under Part I.F.3 of the Pennit.
9.1 LDS Monitoring
9.1.1 Operational Status ofLDS Pumping and Monitoring Equipment
The LDS pumping and monitoring equipment for each of Cell4A and Cell 4B, including, but not
limited to, the submersible pump, pump controller, head monitoring, and flow meter equipment,
operated continuously during the Quarter.
During the Quarter, there were no failures of any pumping or monitoring equipment not repaired
and made fully operational within 24-hours of discovery, as contemplated by Part I.E.8(a)(I) of
the Pennit for Cell4A and as contemplated by Part I.E. 12(a)(I) of the Pennit for CeIl4B.
9.1.2 Measurement of Weekly Fluid Head at the Lowest Point in the Secondary Membrane
The readings pertaining to the fluid head above the lowest point in the secondary FML for Cell
4A and Cell4B are provided in Attachment F.
As can be seen from a review of Attachment F, at no point in the Quarter did the fluid head in the
Cell 4A LDS sump exceed a I-foot level above the lowest point in the lower FML on the Cell
floor (where for purposes of compliance monitoring this I-foot distance equates to 2.28 feet
above the LDS system transducer), as stipulated by Part 1.E.8(a)(2) of the Pennit. During the
Quarter, the fluid head in the Cell 4A LDS sump did not exceed 9.6 inches above the LDS
transducer.
10
N:\Required RepOlts\DMT RepOlts\20 11 DMT\Q 1 2011 DMT RepOlt\Q 1 2011 DMT RepOlt.docx
As can be seen from a review of Attachment F, at no point in the Quarter did the fluid head in the
Cell 4B LDS sump exceed a I-foot level above the lowest point in the lower FML on the Cell
floor, as stipulated by Part I.E.12(a)(2) of the Permit. For the purposes of compliance
monitoring this I-foot distance equates to 2.25 feet above the LDS system transducer. During
the quarter the fluid head in Ce1l4B sump did not exceed 14.7 inches above the LDS transducer.
9.1.3 Measurement of the Volume of Fluids Pumpedfrom the LDS
The readings pertaining to the volume of fluids pumped are provided in Attachment F.
As can be seen from a review of Attachment F, during the Quarter, the average daily LDS flow
volume in Cell 4A did not exceed 24,160 gallons/day, as stipulated by Part I.E.8(a)(3) of the
Permit. Based on the maximum head recorded on the FML during the Quarter of about 39 feet,
the allowable flow rate would be approximately 23,955 gallons per day, as determined under the
Mill's Cell4A BAT Operations and Maintenance Plan, Table lA (also included in Attachment F
of this report), and assuming a liner elevation of 5555.55 feet and approximately 39.66 acres of
liquid area. The average daily flow volume in Cell 4A did not exceed the calculated flow
volume of 23,955 gallons/day. During first quarter 2011, a total of 3160 gallons were pumped
from Cell 4A LDS.
As previously stated, wastewater pool elevation surveys were not conducted for Ce1l4B because
the fluid levels were too low to measure from the banks of Ce1l4B. However, during the quarter
the wastewater pool elevation in Cell 4 B did not exceed 5581.10 finsl, which is the elevation
surveyed on May 31, 2011. Based on that elevation the allowable flow rate would be 15,219
gallons/day. The average daily LDS flow volume in Ce1l4B did not exceed 15,219 gallons/day,
as stipulated by Part I.E. 12(a)(3) ofthe Permit.
9.2 Measurement of Weekly Wastewater Fluids in Ce1l4A
Weekly fluid elevations for Cell 4A and Cell 4B are provided in Attachment A along with
elevations for Cells 1 and 3 and Roberts Pond. During the Quarter, the Mill operated and
maintained wastewater levels in Cell4A and Cell 4B to provide the minimum vertical freeboard
as required by Part I.E. 12(a)(4) ofthe Permit. See the discussion in Section 3 above.
9.3 Slimes Drain Recovery Head Monitoring
As the Mill has not initiated pumping conditions in the Ce1l4A or Ce1l4B slimes drain system at
this time, monthly recovery head tests and fluid level measurements are not required to be made
at this time pursuant to Part I.E.8(b) ofthe Permit.
11
N:\Required Rep011s\DMT Reports12011 DMTlQI 2011 DMT Repolt\QI 2011 DMT Rep011.docx
10~O ANNUAL SLIMES DRAIN RECOVERY HEAD REPORT FOR THE
CALENDAR YEAR 2011
The annual slimes drain recovery head report for Cell 2 for calendar year 2011 (the "Period"), as
required under Parts 1.D.3 (b) and I.F.ll of the Pennit and Section 8.2 of the DMT Plan is
included with the 4th quarter DMT report which will be submitted on or before March 1, 2012.
12
N;\RlXluin.>() Rcports\DMT RcpOlls\20 1 I DMTlQ I 20 t t DMT Report\QI 20 II DMT Rcpolt.docx
11.0 SIGNATURE AND CERTIFICATION
This document was prepared by Denison on May 31, 2011.
By:
Davi Fryd lund
Vice President, Regulatory Affairs and Counsel
CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the in rmation submitted is, to the best of my knowledge and belief, true, accurate
and com teo I aware that there are significant penalties for submitting false information,
includin e po lbility of fine and imprisonment for knowing violations .
. F Y enlund
Vice Presiden , Regulatory affairs and Counsel
Denison Mines (USA) Corp.
13
N :\Required Reports\DMT RepOltS\20 II DM1\Q I 20 II DMT RepOlt\Q I 20 II DMT RepOlt.docx
Attachment A
Date Cell 1
Free Board 1 5615.40
11712011 5613.96
111112011 5613.84
1114/2011 5613.84
112112011 5613.80
1128/2011 5614.20
2/412011 5613.96
2/11/2011 5613.98
2/18/2011 5613.80
2/2512011 5613.77
3/4/2011 5613.80
3/1112011 5613.59
3118/2011 5613.65
3/25/2011 5613.62
4/112011 5613.39
Tailings Pond Elevations
1 st Quarter Elevations
2011
Cell 32 Roberts Pond
5602.50 5624.00
5603.98 5623.70
5604.03 5622.68
5604.30 5620.86
5604.33 5620.32
5604.34 5622.18
5604.24 5621.20
5602.34 5622.20
5602.12 5623.17
5602.25 5621.28
No longer
required 5621.28
5619.77
5619.24
5619.46
Ce1l4A3
5593.74
5593.37
5593.84
5594.01
5594.14
5594.21
5594.13
5593.38
5592.72
5591.51
5591.51
No longer
required
CeU4B4
5594.6
*
*
*
*
*
*
*
*
*
* The wastewater elevations were not measured in Cell4B during the quarter because the fluid levels were
below the the level at which the survey can be conducted from the bank ofCell4B. However, during the
quarter, the wastewater fluid levels did not exceed 5581.10 finsl which is the elevation surveyed on May 31,
2011.
1 Freeboard as permitted under License condition 10.3 which is no longer applicable to Cell 3 or Cell4A.
2Cell 3 is nearly full of solids, is undergoing pre-closure steps, and the freeboard limit specified here is no
longer required as of the January 27 and March 14, 2011 letters from DRC.
3 The freeboard limit for Cell4A is not set out in the License. The freeboard limit of 5,593.74 for Ce1l4A is
set out in a letter from the Executive Secretary dated November 20,2008. Denison proposed in the DMT Plan
revision dated November 12, 2010 the removal of the freeboard limit for Ce1l4A to be replaced by a
freeboard limit for new Cell4B that will accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B.
The Executive Secretary granted a variance from the Cell4A freeboard limit on January 13,2011 and
approved the removal of the Cell4A limit and the use ofCell4B on January 27,2011.
4 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A
pool surface area of 40 acres is used because there are no beaches present in Cell 4B at this time.
Attachment B
January 14, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Rusty Lundberg, Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4810
Denison Minas (USA) Corp.
1050 17th Straat, Suite 1150
Denvar, CO 80265
USA
Tal: 303628·7798
Fax: [phone]
www.danisonmines.com
Re: Stat. of Utah Ground Water Discharge Permit No. UGW37DDD4 White Mesa Uranium Mil/-
Notice Pursuant to Part I.G.3 ofthe Permit and UAC R317-6-6.16(C)
Dear Mr. Lundberg:
Please take notice pursuant to Part I.G.3 of the White Mesa Mill's (the "MiII's") State of Utah Groundwater
Discharge Permit No. UGW370004 (the "Permit") and Utah Administrative Code ("UAC") R313-6-6.16(C) that
Denison Mines (USA) Corp. ("Denison"), as operator of the Mill and holder of the Permit, failed to meet the
discharge minimization technology ("DMT") standards in Part I.D.6.d) of the Permit, by allowing the
wastewater elevation in the Mill's tailings Cell 4A to exceed the freeboard limit for that Cell by approximately
0.12 inches, as described in more detail below.
This exceedance was discovered at 3:45pm on Monday January 10, 2011 . Initial notice of this failure to
maintain DMT was given by telephone to Mr. Loren Morton of the Utah Department of Environmental Quality
at 11 :40am on Tuesday January 11, 2011 at 801-536-4262 (within 24 hours of the discovery).
1. Facts and Background Information
a) Condition 10.3 of the Mill's State of Utah Radioactive Materials License No. UT1900479 (the
"License") provides that freeboard limits for Cells 1, 3 and 4A shall be set in accordance with
procedures that have been approved by the U.S. Nuclear Regulatory Commission ("NRC"). Under
those procedures:
(i) The freeboard limits are set as per the January 10, 1990 Drainage Report for Cell 1 at a liquid
maximum elevation of 5,615.4 feet above mean sea level ("fmsl");
(ii) The freeboard limit for Cell 3 is determined annually using a formula set out in the procedure.
The current freeboard limit for Cell 3 was previously calculated under this procedure at 5,601.6
fmsl. However, in State of Utah Department of Environmental Quality ("UDEQ") correspondence
dated November 20, 2008 an interim variance and limit was established at 5,602.5 fmsl for Cell 3;
N:\Notices\Cell 4A Freeboard notices\01 .14.11 Notice to RLundberg Cell 4A Freeboard.doc
Letter to Mr. Rusty Lundberg
January 14, 2011
Page 2
(iii) In conjunction with the variance established under (ii) above, an interim maximum elevation for
Cell4A was also established at 5,593.74 fmsl;
(iv) The maximum elevation of 5,593.74 fmsl for Cell 4A has been set assuming that the total
probable maximum precipitation ("PMP") volume for Cells 2, 3 and 4A will be accommodated in
Cell 4A By letter dated December 11, 2008, Denison applied for an amendment to the License
to set the freeboard limit for Cell4A at 5,593.74 fmsl and to eliminate the need to set a freeboard
limit for Cell 3, given that the freeboard limit of 5,593.74 fmsl for Cell 4A is adequate to
accommodate the total PMP volume for Cells 2, 3 and 4A; and
(v) In addition, Part I.D.2 of the Permit provides that under no circumstances shall the freeboard of
any tailings cell be less than three feet, as measured from the top of the flexible membrane liner
("FML"). The top of the FML in Cell 1 is at 5,618.5 fmsl, and the top of the FML in Cell 3 is at
5,608.5 fmsl. This means that Part I.D.2 of the Permit provides a secondary requirement that the
maximum wastewater pool elevations in Cells 1 and 3 cannot exceed 5,615.5 and 5,605.5 fmsl,
respectively.
(vi) Part I.D.6 of the Permit provides that under no circumstances shall the freeboard of Cell 4A be
less than three feet, as measured from the top of the FML. The top of the FML in Cell 4A is at
5,598.5 fmsl. This means that Part I.D.6 of the Permit provides a secondary requirement that the
maximum wastewater pool elevation in Cells 4A cannot exceed 5595.5 fmsl.
b) In a letter to Denison dated April 29, 2010, UDEQ has indicated their agreement with Denison's
position that the freeboard limit is not applicable to Cell 3, since Cell 3 is in pre-closure stages, and
the PMP flood volume of Cell 3 can be attributed to, and managed in, Cell 4A The April 29 letter
indicated that to formalize this removal of freeboard limit, three documents needed to be revised,
specifically the Mill's Radioactive Materials License ("RML"), the Discharge Minimization Technology
("DMT") Plan, and the Cell 4A Operations and Maintenance ("0&M") Plan. Denison submitted
revisions to each of those documents for UDEQ approval on August 4,2010.
c) In July, 2010, Denison received approval of a revision of the RML and Permit allowing construction of
tailings Cell 4B. Cell 4B has been constructed but has not yet been authorized for use. Denison has
submitted revisions to the Reclamation Plan, O&M Plan, DMT Plan, and Contingency Plan, on
November 11, 2010, December 20, 2010, and January 10, 2011, 2010. These plans are still
undergoing review and revision, and UDEa has not yet granted approval of the plans or authorization
for use of Cell 48.
d) The Mill has been in the process of filling Cell 3 with tailings solids and closing the cell. Cell 3 no
longer has any capacity to receive tailings liquids. In the process of filling Cell 3 with solids, the Mill
alternately discharged CCD solids to Cell 3 and transferred liquids from Cell 3 to Cell 4A, through
October 2010.
e) On June 3, 2010 Denison notified UDEa that an accumulation of fluid had been detected in the Cell 1
Leak Detection System ("lDS''). Following an intial series of FML repairs during June 2010, and as
a result of UDEQ's Conditional Approval and Confirmatory Action letter of September 22, 2010 and
telephone conversations and correspondence with UDEa on August 18, August 23, September 15,
and September 21, 2010, Denison committed to maintain the liquid level in Cell 1 below 5613 fmsl to
allow inspection and repair of the FML surface above 5613 fmsl. To achieve and maintain this
reduced liquid level in Cell 1, the Mill has periodically transferred fluids from Cell 1 to Cell 4A
OENISOJ) ~
MINES
Letter to Mr. Rusty Lundberg
January 14, 2011
Page 3
f} The Mill experienced heavy precipitation during the week of December 27,2010 and ongoing lesser
precipitation during the following two weeks, which also increased the liquid levels in both Cell 1 and
4A.
g) Therefore, since November 2010, Cell 4A has been the Mill's only tailings cell in full service and has
been used to manage the majority of all tailings volume in the Mill system including:
a. CCD solids,
b. all other tailings liquids,
c. tailings solutions transferred from Cell 1, and
d. precipitationlrunoff from the areas of Cells 2, 3 and 4A.
h) During the weekly inspection and survey on January 6, 2011, the survey of the tailings liquid pool
elevation indicated that Cell 4A had a pool elevation of 5593.28 fmsl resulting in 5.52 inches of
freeboard capacity (that is, was 5.52 inches below the freeboard limit). At that time, Cell 4A liquid
level was 29.28 inches below the spillway Into Cell 4B.
i) Denison alerted DRC on January 6, 2011 that Cell 4A was filling and approaching its freeboard limit.
During that discussion UDEa advised Denison that UDEa could use enforcement discretion to
temporarily waive the Cell 4A freeboard limit until Cell 4B is authorized for service, provided that i)
Denison notified UDEa when the Cell 4A freeboard limit is exceeded, and ii) Denison did not
discharge any fluids over the spillway into CeIl4B.
j) During the tailings survey measurement performed at approximately 3:45pm on January 10, 2011,
the wastewater pool elevation in Cell 4A was measured to be 5593.75 fmsl, compared to the current
freeboard limit for Cell 4A of 5593.74 fmsl, representing an exceedance of O.01feet, or 0.12 inches.
At that time, Cell 4A level was 23.64 inches below the spillway to Cell 4B.
k) Denison notified UDEa by phone call at 11 :40am on Tuesday that the Cell 4A liquid level had
exceeded the freeboard limit.
I) The Mill has been running on a 10-day on and 4-day off operating cycle.
2. Action Taken
Upon receipt of the initial survey results, the Mill's Environmental Coordinator notified the Mill Manager at
3:45pm that day. The following plan of action was immediately put into place in accordance with section 5.1
of the Mill's Contingency Plan:
a) The Mill Manager had operations crews stop the discharge of CCD solids into Cell 4A;
b) The Mill Manager order the Mill into a scheduled 4-day shutdown;
c) This plan was implemented beginning at 3:45pm on Monday January 10, 2011;
d) Verbal notification was given to the Executive Secretary at 11 :40am on January 11, 2011, within 24
hours of discovery. This verbal notification was followed by this written notification within five days of
discovery;
OENISONr;) ~
MINES
Letter to Mr. Rusty Lundberg
January 14, 2011
Page 4
e) Solutions cannot be transferred to any other cell to directly reduce the volume in Cell 4A, as no other
cell is available to receive liquids at this time.
f) On Thursday January 13, 2010, Denison formally requested that UDEQ grant a regulatory variance
from the freeboard limit in Cell 4A.
g) By email on Thursday January 13, 2010, UDEQ granted conditional approval of a regulatory variance
from the freeboard limit on Cell 4A. The conditional approval letter agreed that Cell 4A freeboard limit
exceedance will be resolved once Cell 4B is put in service and liquid is permitted to be pumped from
Cell 4A to Cell 48, and required that:
a. Discharge of any tailings solids or wastewater in Cell 4B is prohibited until Denison received
written approval from UDEQ for use of CeIl4B,
b. Denison will make and report to UDEQ daily measurement of Cell 4A wastewater level, and
c. The variance will expire on March 1, 2011 .
3. Root Cause
The root cause analysis is as follows
a) Due to the intentional filling and closure of Cell 3 and the requirement to reduce the level in Cell 1,
Cell 4A is currently the only tailings cell receiving liquids in the Mill tailings system.
b) Cell4A has received all of the following materials:
a. CCD solids,
b. all other tailings liquids,
c. tailings solutions transferred from Cell 1 , and
d. precipitation/runoff from the areas of Cells 2, 3 and 4A.
c) Heavy preCipitation during the week of December 27, 2010 and ongoing precipitation since that week,
also increased the liquid levels in both Cell 1 and 4A.
d) UDEQ authorization for use of Cell 4B has not been received as the required plans submitted by
Denison are still undergoing re-reviewand revision.
e) Upon review of the circumstances, both UDEQ and Denison agreed that that Cell 4A freeboard limit
exceedance will be resolved once Cell 4B is put in service and liquid is pumped from Cell 4A to Cell
4B . Both UDEQ and Denison agreed to the need for an interim variance from the Cell 4A freeboard
level, which has been granted by UDEQ on January 13, 2011.
4. Actions That Will be Taken to Prevent a Reoccurrence of this Incident
The following actions will be taken to prevent a reoccurrence of this incident:
a) Solutions cannot be transferred to any other cell to directly reduce the volume in Cell 4A, as no other
cell is available to receive liquids at this time.
b) On Thursday January 13, 2011, Denison formally requested that UDEQ grant a regulatory variance
from the freeboard limit in Cell 4A.
OENISONI) ~
MINES
..
Letter to Mr. Rusty Lundberg
January 14, 2011
Page 5
c) By email on Thursday January 13, 2011, UDEQ granted conditional approval of a regulatory variance
from the freeboard limit on Cell 4A.
d) Denison has already begun making daily measurements of Cell 4A liquid level and has begun
reporting them to UDEQ. Liquid level data including the weekly level reading on December 31,2010
and the daily level readings beginning on January 6, 2011 are provided in the attached Table 1.
5. Affirmative Defense
Denison believes that the affirmative defense in Part I.G.3.c) of the Permit should be applicable to this
incident, for the following reasons:
a) Notification
By virtue of the initial oral notification given to UDEQ at 11 :40am on Tuesday January 11, 2011 (within 24
hours of the discovery) and this written notice, Denison has submitted notification according to UAC R317-6-
6.13.
b) Failure was not Intentional or Caused by the Permittee's Negligence
The exceedance of the freeboard limit was not intentional or caused by Denison's negligence, either in action
or in failure to act. The Mill was taking actions to manage the freeboard requirements of all of its active
tailings cells while filling Cell 3 for closure and maintaining a reduced level of Cell 1 as committed in the Cell 1
Repair Plan.
c) The Permittee has Taken Adequate Measures to Meet Permit Conditions
f) Denison has taken adequate measures to meet Permit conditions in a timely manner.
The provisions of the Mill's Contingency Plan were implemented immediately. UDEQ was notified in advance
of the impending exceedance and upon observance of the actual exceedance. Upon review of the
Circumstances, both UDEQ and Denison agreed that that Cell 4A freeboard limit exceedance will be resolved
once Cell 4B is put in service and liquid is pumped from Cell 4A to Cell 4B. Both UDEQ and Denison agreed
to the need for an interim variance from the Cell 4A freeboard level, which has been granted by UDEQ on
January 13, 2011.
d) The Provisions of UCA 19-5-107 Have Not Been Violated
The provisions of Utah Code 19-5-107 have not been violated. There has been no discharge of a pollutant
into waters of the state. Denison has not caused pollution which constitutes a menace to public health and \
welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic, agricultural, industrial, recreational, or
other beneficial uses of water, nor has Denison placed or caused to be placed any waste in a location where
there is probable cause to believe it will cause pollution.
There was no discharge of solutions from the Mill's tailings impoundments.
Please contact the undersigned if you have any questions or require any further information.
OENISOJ) ~
MINES
Letter to Mr; Rusty Lundberg
January 14, 2011
Pagel
Yours very truly.
DENISON MINES (USA) CORP.
~~
Jo Ann Tischler
Director, Compliance and Permitting
cc: Rtch Bartlett
David C. Frydenlund
Harold R. Roberts
DaVId E. Turk
central flies
OENI50J) J
MINES
Table 1: Cell 4A Freeboard Observation Data
liquid Pool
Elevation Freeboard elev. Inches to Elevation of Inches to
Date Time (fmsl) (fmsl) freeboard Spillway (fmsl) spillway
12/31/2010 1:20 PM 5593.13 5593.74 7.32 5595.72 31.08
1/6/2011 12:30 PM 5593.28 5593.74 5.52 5595.72 29.28
1/7/2011 8:30AM 5593.37 5593.74 4.44 5595.72 28.2
1/10/2011 3:45 PM 5593.75 5593.74 -0.12 5595.72 23.64
1/11/2011 9:05AM 5593.84 5593.74 -1.2 5595.72 22.56
1/12/2011 10:15 AM 5593.93 5593.74 -2.28 5595.72 21.48
1/13/2011· 7:45 AM 5593.97 5593.74 -2.76 5595.72 21
1/14/2011 9:30AM 5594.01 5593.74 -3.24 5595.72 20.52
·Receipt of UDEQ waiver requiring daily measurement and reporting of Cell4A level.
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Friday, January 14, 2011 3:45 PM
'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
Cell 4A Freeboard Notice Notice Pusuant to White Mesa Mill GWDP Part I.G.3
01.14.11 notice pursant to GWDP Part I.G.3 Cell4A freeboard.pdf
Enclosed please find Denison Mines (USA) Corp.'s Notice pursuant to Part I.G.3 of the White Mesa Mill's groundwater
Discharge Permit, regarding exceedance of the freeboard limit for tailings CeIl4A.
A separate hard copy has been transmitted by Federal Express.
Please contact me if you have any questions regarding this submittal.
Yours truly,
Jo Ann Tischler
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Saturday, January 15, 2011 3:27 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/15/11
Cell_ 4A_Elevation_ Observation.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Your truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
From: Jo Ann Tischler
Sent: Friday, January 14, 2011 3:45 PM
To: Rusty lundberg
Cc: Loren Mortonj Harold Robertsj David Frydenlundj David Turkj Ron Hochsteinj Kathy Weinel;
Meredith Goblej Richard Bartlett
Subject: Cell 4A Freeboard Notice Notice Pusuant to White Mesa MIll GWDP Part I.G.3
Enclosed please find Denison Mines (USA) Corp.'s Notice pursuant to Part I.G.3 of the White
Mesa Mill's groundwater Discharge Permit, regarding exceedance of the freeboard limit for
tailings Cell 4A.
A separate hard copy has been transmitted by Federal Express.
Please contact me if you have any questions regarding this submittal.
Yours truly,
Jo Ann Tischler
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Sunday, January 16, 2011 6:35 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/16/11
CeiL 4A_Elevation_Observation 01.16.11.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2e11.
Please contact me if you have any questions regarding this transmittal.
Your truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: (3e3) 389-4132 f: (3e3) 389-4125
leSe 17th Street, Suite 9Se, Denver, CO 8e26S DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
From: Jo Ann Tischler
Sent: Friday, January 14, 2e11 3:45 PM
To: Rusty Lundberg
Cc: Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
Subject: Cell 4A Freeboard Notice Notice Pusuant to White Mesa MIll GWDP Part I.G.3
Enclosed please find Denison Mines (USA) Corp.'s Notice pursuant to Part I.G.3 of the White
Mesa Mill's groundwater Discharge Permit, regarding exceedance of the freeboard limit for
tailings Cell 4A.
A separate hard copy has been transmitted by Federal Express.
Please contact me if you have any questions regarding this submittal.
Yours truly,
Jo Ann Tischler
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Monday, January 17, 2011 11: 13 AM
'Rusty Lundberg'
'Loren Morton'; David Frydenlund; Ron Hochstein; Harold Roberts; David Turk; Meredith
Goble; Richard Bartlett
Cell 4A Liquid Level daily Update -White Mesa Mill 01/17/11
Cell4A Elevation Observation.pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell4A liquid level as required by Utah Division
of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Your truly,
Jo Ann Tischler
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Tuesday, January 18,2011 5:17 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel ;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/18/11
Cell_ 4A_Elevation_Observation 01 .18.11.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Your truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
From: Jo Ann Tischler
Sent: FridaYI January 14, 2011 3 :45 PM
To: Rusty lundberg
Cc: loren Mortonj Harold Robertsj David Frydenlundj David Turkj Ron Hochsteinj Kathy Weinelj
Meredith Goblej Richard Bartlett
Subject: Cell 4A Freeboard Notice Notice Pusuant to White Mesa MIll GWDP Part I.G.3
Enclosed please find Denison Mines (USA) Corp.ls Notice pursuant to Part I.G.3 of the White
Mesa MillIs groundwater Discharge Permit, regarding exceedance of the freeboard limit for
tailings Cell 4A.
A separate hard copy has been transmitted by Federal Express.
Please contact me if you have any questions regarding this submittal.
Yours trulYI
Jo Ann Tischler
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Thursday, January 20, 2011 12:42 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/20/11
Cell4A Elevation Observation 01 20 11.pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2e11.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
leSe 17th Street, Suite 9S0, Denver, CO 8e26S DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Friday, January 21, 201112:47 PM
'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/21/11
Cell4A Elevation Observation 01 21 11.pdf
Attached please find Denison Mines (USA) Corp. 's daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2811.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] I f: [phone]
1858 17th Street, Suite 958, Denver, CO 88265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Saturday, January 22, 2011 1 :16 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/21/11
Cell_ 4A_Elevation_Observation_01_22_11.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Monday, January 24, 2011 8:44 AM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/23/11
Cell 4A Elevation Observation 01 23 11 .pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011. The
attached data for Sunday January 23, 2011 was measured, as required by the DRC letter, on
Sunday January 23, 2011 and transmitted from the Mill immediately. Due to maintenance-
related computer server shutdowns and transmission delays during the weekend, the data was
received at Denver corporate offices today, Monday January 24, 2011 and transmitted
immediately upon receipt.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Monday, January 24, 2011 4:22 PM
'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/24/11
Cell 4A Elevation Observation 01 24 11 .pdf
Attached please find Denison Mines (USA) Corp. 's daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13} 2011.
Please contact me if you have any questions regarding this transmittal.
Yours truly}
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Tuesday, January 25,2011 9:47 AM
'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01/25/11
Cell 4A Elevation Observation 01 25 11.pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2811.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1858 17th Street, Suite 958, Denver, CO 88265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Wednesday, January 26, 2011 11 :34 AM
'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level daily Update -White Mesa Mill 01126111
Cell4A Elevation Observation 01 2611.pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Thursday, January 27, 2011 1 :56 PM
Jo Ann Tischler; 'Rusty Lundberg'
'Loren Morton'; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level Daily Update -White Mesa Mill 01/27/11
Cell 4A Elevation Observation 01 27 11 (2).pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Saturday, January 29, 2011 4:22 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level Daily Update -White Mesa Mill 01/29/11
CeiL 4A_Elevation_Observation_01_29_11.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2011.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director) Compliance and Permitting
t: [phone] I f: [phone]
1050 17th Street, Suite 950, Denver, CO 80265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Sunday, January 30, 2011 2:07 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell4A Liquid Level Daily Update -White Mesa Mill 01/30/11
Cell_ 4A_Elevation_Observation_01_30_11.xlsx
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2ell.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: (3e3) 389-4132 f: (3e3) 389-4125
leSe 17th Street, Suite 9Se, Denver, CO 8e26S DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Kathy Weinel
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jo Ann Tischler
Monday, January 31, 2011 3:09 PM
Rusty Lundberg
Loren Morton; Harold Roberts; David Frydenlund; David Turk; Ron Hochstein; Kathy Weinel;
Meredith Goble; Richard Bartlett
RE: Cell 4A Liquid Level Daily Update -White Mesa Mill 01/31/11
Cell 4A Elevation Observation 01 31 11 .pdf
Attached please find Denison Mines (USA) Corp.'s daily update of the tailings Cell 4A liquid
level as required by Utah Division of Radiation Control's letter of January 13, 2811.
Please contact me if you have any questions regarding this transmittal.
Yours truly,
Jo Ann Tischler
Director, Compliance and Permitting
t: [phone] f: [phone]
1058 17th Street, Suite 950, Denver, CO 88265 DENISON MINES (USA) CORP www.denisonmines.com
This e-mail is intended for the exclusive use of the person(s) mentioned as the recipient(s).
This message and any attached files with it are confidential and may contain privileged or
proprietary information. If you are not the intended recipient(s) please delete this message
and notify the sender. You may not use, distribute print or copy this message if you are not
the intended recipient(s).
1
Jo Ann Tischler
From:
Sent:
To:
Cc:
Subject:
Jo Ann Tischler
Tuesday, February 01, 2011 2:22 PM
Rusty Lundberg; Loren Morton
David Frydenlund; Harold Roberts; David Turk; Ryan Palmer
White Mesa Mill Daily Cell 4A Liquid Measurements and Variance on Cell 4A Freeboard Limit.
In response to Utah Division of Radiation Control's (ilDRe's") letter of January 13, 2011, providing conditional approval of
a variance to the Cell 4A wastewater freeboard limit, Denison Mines (USA) Corp. has been measuring and transmitting
daily to DRC the liquid pool elevation in Cell 4A. Denison has received ORe's letter of January 20,2011 approving
revisions to the Discharge Minimization Technology (DMT") Monitoring Plan contingent upon authorization to use Cell
4B, and received written authorization from DRC on January 31,2011 for use of tailings Cell 4B. As stated in the newly
approved DMT Plan, Section 6.3.4, the freeboard limit for Cell 4A is currently inapplicable since all of the PMP volume
associated with Cell 4A will be attributed to Cell 4B, which is now in service.
Denison, therefore, does not plan to send to DRC any additional daily data on the liquid pool elevation in Cell 4A, and
requests that you confirm our understanding that the daily Cell 4A liquid level data is no longer required.
Yours truly,
Jo Ann Tischler
1
Attachment C
MONTHLY HEAD MEASUREMENT TEST
January-ll
Location: Date: 1/21/2011
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer, Ryan Schierman
1/17/2011 1/18/2011 1/19/2011 1/20/2011 1/21/2011
600
700 16.15 15.10 14.13 13.74 13.15
800 16.09 15.08 14.13 13.73 13.15
900 16.03 15.06 14.12 13.73 13.15
1000 15.98 15.04 14.05 13.72
1100 15.92 15.00 14.03 13.69
1200 15.86 14.95 14.00 13.67
1300 15.79 14.89 13.96 13.64
1400 15.73 14.84 13.92 13.59
1500 15.69 14.80 13.90 13.55
1600
All measurements are in inches.
Comments: Report number is 13.15 for the month of January.
The tested started with a partialy recovered head because there was an unplanned
power loss to the tailings area over the weekend which allowed the head to recover
for a day and a half to two days before the monthly head recovery test was started.
they continue to have some problems with the power supply out on the tailings area.
We may continue to see some problems with the slimes drain on Cell 2 until these
issues are resolved.
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 2/28/2011
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
2/21/2011 2/22/2011 2/23/2011 2/24/2011 2/25/2011 2/28/2011
600
700 14.7 12.73
800 14.59 12.7 11.8 11.82
900 14.47 12.63 11.79 11.2
1000 14.35 12.6 11.77 11.18
1100 14.22 12.56 11.73 11.18
1200 14.1 12.5 11.69 11.15
1300 13.96 12.44 11.65 11.11
1400 13.87 12.38 11.63 11.03
1500 24.85 13.77 12.32 11.6 10.99
1600
All Measurements are in inches.
Comments: Test got started late on th 21st and ran over the weekend. The stable
readings were taken the following Monday morning on the 28th. The number being
used as stable head for the report is 10.42 feet.
10.42
10.42
10.42
MONTHLY HEAD MEASUREMENT TEST
Location: Date: 3/18/2011
Slimes Cell # 2
Sampler: Tanner Holliday
Garrin Palmer
3/14/2011 3/15/2011 3/16/2011 3/17/2011 3/18/2011
600
700 14.45 12.61 11.76 11.32
800 24.75 14.31 12.56 11.73 11.31
900 23.25 14.19 12.53 11.71 11.31
1000 22.31 14.05 12.50 11.69 11.31
1100 21.21 13.92 12.46 11.66
1200 20.68 13.82 12.42 11.64
1300 19.78 13.72 12.36 11.62
1400 19.25 13.61 12.30 11.60
1500 18.76 13.53 12.22 11.52
1600
All measurements are in inches.
Comments: The report number for the month of March is 11.31
Attachment D
n tD
N
'" --. 3
tD '" C .... OJ -. ~
N o o \D ..
N o ....,a. o
20
N o ....,a.
....,a.
+ V> r1) .,
~"
I-'
c:
::::l r1)
OJ ...,
Vi" ro ....
iii"
'" .!:::!
I-' en ~ I-' N
Feet Below Top of Standpipe
I-' o 00 en .j:>. N 0
1/30/2009
2/28/2009
3/31/2009
4/30/2009
-5/31/2009
6/30/2009
7/31/2009
8/31/2009
9/30/2009
10/31/2009
11/30/2009
12/31/2009
1/31/2010
2/28/2010
3/31/2010
4/30/2010
5/31/2010
6/30/2010
7/31/2010
8/31/2010
9/30/2010
10/31/2010
11/30/2010
-12/31/2010
1/31/2011
2/28/2011
3/31/2011
4/30/2011
Attachment E
This attaclunent has been deliberately left blank.
Attachment F
January 2011
Date
1/7/11
1/14/11
1/21/11
1/28/11
Cell 4A LOS Monitoring Information
Measurements in inches from
transducer at the bottom of
the LDS sump.
6.3
7.7
7.7
7.5
Flow Meter in Gallons
260850
260850
261300
261300
Highest level for the month was 8.7 inches and the lowest level for the month was 4.3 inches. Total number of
gallons pumped was 450.
February 2011
Date
2/4/11
2/11/11
2/18/11
2/25/11
Measurements in inches from
transducer at the bottom of
the LDS sump.
6.6
8.9
8.9
7.6
Flow Meter in Gallons
264010
264010
264010
264010
Highest level for the month was 9.6 inches and the lowest level for the month was 5.2 inches. Total number of
gallons pumped was 2710.
March 2011
Date
3/4/11
3/11/11
3/18/11
3/25/11
Measurements in inches from
transducer at the bottom of
the LOS sump.
6.1
4.0
4.4
5.4
Flow Meter in Gallons
264010
264010
264010
264010
Highest level for the month was 6.8 inches and the lowest level for the month was 2.2 inches. Total number of
gallons pumped was O.
For the 1st Quarter 2011, the highest level was 9.6 inches and the lowest level was 2.2 inches. A total of 3160
gallons were pumped.
January 2011
Date
1/7/11
1/14/11
1/21/11
1/28/11
Cell 48 LOS Monitoring Information
Measurements in inches from
transducer at the bottom of
the lOS sump. Flow Meter in Gallons
The Executive Secretary letter dated January 27, 2011
authorized the use of Cell 4B. The Cell 4B lOS was not
monitored until the authorization for use was received.
No measurements were taken in January 2011.
February 2011
Date
2/4/11
2/11/11
2/18/11
2/25/11
Measurements in inches from
transducer at the bottom of
the LOS sump.
3.8
11.0
10.5
6.6
Flow Meter in Gallons
o
70195
121290
195680
Highest level for the month was 14.7 inches and the lowest level for the month was 3.8 inches. Total
number of gallons pumped was 195,680.
March 2011
Date
3/4/11
3/11/11
3/18/11
3/25/11
Measurements in inches from
transducer at the bottom of
the LDS sump.
13.0
6.0
9.9
11.3
266932
293740
302087
310433
Highest level for the month was 13.8 inches and the lowest level for the month was 2.4 inches. Total
number of gallons pumped was 114,753.
For the 1st Quarter 2011, the highest level was 14.6 inches and the lowest level was 2.4 inches. A total of
310,433 gallons were pumped.
Geosyntec Consultants Table lA
Calcufated Action Laskaae Rates for Various Head CondItions
Cen 4A, White Mesa Mill
Blandin., Utah
Head Above Uner QJcUIII8d AclJon l.Hbp RIIte
System (feet) (pRant/acre/day)
5 222.04
10 314.0
15 384.58
20 444.08
25 496.5
30 543.88
35 587.5
37 604.0
Geosyntec Consultants Tible 1B
Calculated ActIon Leakage Rates for VarIous Head CondltTons
CeIl4B, White Mesa Mill
B/andln&, Utah
Head Above Uner System Circulated Action Ltafclp Rate
(f.t) (alflanl'lctll/dayt
5 211.4
10 317.0
15 369.9
20 422.7
25 475.6
30 528.4
3S 570.0
37 581.2
Attachment G
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