DRC-2011-007624 - 0901a0688028f7f3

Stateof Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Govemor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
October 13,2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
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RE: contingent SOP Approval / DR
stl
Cit
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE
Denver, Co 80265
950
PS Form 3800, August.2006 See Reverse for Instr-uctions
SUBJECT: June 21, 2011 DUSA Response and Transmittal Letter regarding DRC Comment Letter of
. June 2, 2011: Settlement Monitoring Statidard Operating Procedures [SOPs] 06/2011
Revision: DUSA-2; December 1, 2010 DUSA Original Transmittal Letter for Three
Separate Draft SOPs; Contingent SOP Approval
We have received the subject June 21, 2011 DUSA response letter, which transmits the subject proposed
DUSA Settlement Monitoring Standard Operating Procedures [SOPs] 06/2011 Revision: DUSA-2, in
response to the DRC comment letter of June 2, 2011.
We have reviewed this information, and approve the subject SOP with a stipulation that Figure 1,
referenced in Section 1.3 ofthe subject SOP, refers to the attached drawing titled Settlement Monitor
Fabrication last revised by DUSA on 05-11. This drawing was submitted eariier by DUSA in a transmittal
on the subject dated May 4, 2011. This drawing must be included by DUSA with all copies ofthis SOP.
If you-have any questions on the above, please contact Mr. Rupp of DRC.
UTAH RADL^TION CONTROL BOARD
Rusty Lundberg, Executive Secretary
RL:DAR:dr
Attachment: Referenced Drawing
F:\License\Move & Settle Monitors\Settlement Monitor SOP Approval.doc
195 North 1950 West • Salt Uke City, UT
Maihng Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Primed on 100% recycled paper '
3" THREADED NIPPLE
5'2"
E& COUPLINGS)
3" THREADED PIPE CAP
- rPIPECOUPLINO
3"PIPECOUPLINa
r DIAMETBR RISER PIPE
3" DIAMETER GUARD PIPE
(installed araund 1" ria«r pqM in die field)
COUPLINO
2'
1/4* STEEL
BASE PLATE 2'
XTMIN.
MATERIALS
DESCRIPTION OUANTTTY DIMENSION
r SCH 40 COUPLINO 2 EACH
r !;CH 4U rUKUADEU PIFH
(BLACK) IBACH 5*0-
3" SCH 40 THREADED CAP lEACH
3" SCH 40 THREADED
nmmjNO 1 EACH
3" X 6* SCH 40 THREADED
NIPPf.P. lEACH
3" SCH 40 GUARD PIPE IBACH 3'4"
1/4" STEEL BASE PLATE lEACH 2'0"X 2^0"
1/4" STEEL BASE PLATE lEACH 6"X<"
NOTES:
1. ALL STEEL TO BE PAINTED WITH TWO COATS OF RED
EPOXY PAINT.
2. NO GALVANIZED PIPE OR PIPE FrmNGS ARB TO BB USED
SQUARE 1/4'PLATB
OtJAltDnnBASB
HAnDBTAIL
3"
SMALL BASK ITATB ATTACHBD TO lAtf or OUAXDmV
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Denison Mines (USA) Corp DENISONOJ i
MINES
REVISIONS ^-^s Wfiitelifesa Mill
Data Couily: San Juan 1 ur
OS-11 GM Lncanav
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SETfLEMENT MONITOR
FABRICATION
FIGURE 1
UNKNOWN 1flAH 09-M-38
State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
m
TJepartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
June 2, 2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
2011-0062
SLTBJECT: May 4, 2011 DUSA Response Letter to DRC Letter of April 4, 2011; December 1, 2010
DUSA Transmittal Letter for Three Separate Draft SOP's; Settlement Monitoring Standard
Operafm^Procet/wre^ [SOPs] 045/2011 Revision: DUSA-2; .Request for Information
We have received the subject May 4, 2011 DUSA response letter, which transmits the proposed DUSA
Settlement Monitoring Standard Operating Procedures [SOPs] 045/2011 Revision: DUSA-2, in response
to the subject DRC comment letter of April 4, 2011. We have reviewed this information, and have the
following comments. Our current comments use the same numerical order as the original comments in our
letter of April 4, 2011:
1. No further comment.
2. No further comment.
3. No further comment. •
4. Figure 1, a drawing n\.\e6 Settlement Monitor Fabrication originally dated 09-14-96 and last
revised 05-11, was provided by DUSA to support the description of the design of the SeUlement
Monitors found in Section 1.3 of the subject SOPs.
5. No further comment.
6. No further comment.
7. No further comment.
8. As previously stated and requested in our leuer of April 4, 2011, Section 1.5.2 in the subject SOPs
is vague in its intent and needed clarifying. After some revision by DUSA, this section still, seems
rather complex and unclear. To help clarify the apparent intent of this section, some additional
red-line strike-out verbiage attached, is suggested for Section 1.5.2.
9. No further comment.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] •T.D.D. [phone]
www.deq.uioh.f>ov
Primed on 100% rccycJed piipei
Page 2
10. Per License Condition 1 L7K, we requested that the subject SOPs, "Include a list of records that
will be prepared for documenting settlement data for each seulement monitoring device and related
site observations and activities..." In this regard, we request that the annual report of the
Settlement Monitor data by a Utah Licensed Professional Engineer, as described in Section 1.6, be
added to the list of records of documents shown in Section 1.5.1 of the subject SOPs.
11. Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage for the subject
SOPs to provide that results and records of settlement monitoring be submitted annually as part of
the ATER. It appears the addition of the word "subniit" to Section 1.6 is appropriate in this regard.
This addition is suggested as attached, in the red-line strike-out verbiage for Section J.6, in the
second to last paragraph of that section.
Please review the above comments, and respond in writing, submitting an appropriately revised SeUlement
Monitoring Standard Operating Procedures document, with a unique version number, for Executive
Secretary approval. Per my email of May 31, 2011, you committed that DUSA would fully respond to this
letter within 30 calendar days of receipt. If you have any questions on the above, piease contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
Attachment:
Red-line strike-out copy of the subject SOPs (including latest DRC Comments) labeled at the top as [Prop
Cmt2 SMSOP markups June 2011]
F;\License\Move & Settle MonitorsXSettlemenl Monitor Cmt2 June 2011 .doc
White Mesa Mill - Standard Operating Procedures Date: 04544/201.10 Revision: DySA-24-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
[Prop Cmt2 SMSOP markups June 20111
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
Ll Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the SeUlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Execuiive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
L2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings ceils and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010>, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement • .
Monitors, will be preidesignated by the Mill Engineer on the latest DUSA ^ett[ement Monitor_,, - \ Formatted: Font: italic
Points map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within calendar days of completion of the intennediate cover at the designated locations.
The Settlement Monitor Points map will be updated as part of the installation of new monitors.
As stated above, Settlement Monitors will be pioc-ed on the tailing ceils when tcmporar)^ cover is
being advanced on the-placed tailings. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to further disposal pursuant to RML condition s
10.5.A. Settiement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the cornpletion of each ISL disposal area, and then annually after that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
F:\VVT\Di^ ision of Radiorion rontrohPoniMn Mine's. DUSAVMER Annugi Tech Eva) RoporLn'-Mosemoni & Scttl<?mwt
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Sciilemcm-Moniloring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 2011^, the required
settlement stands wili be placed and the initial elevation suK'ey completed prior to June 1,
20U0.
13 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Fi.gure I detailin.g the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented > and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and a corrective action pinn will he created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within 30^^ calendar
days of the discovery of the damage to the Settlement Monitor.
L4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surveyor") wilh the assistance of another Mill
worker (the "Assistant");
(ii) The survey will be performed using a survey instrument accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
F:'A\')>-Division ol Raciiaiion-gontiQi\Deni.wri Mineu. DDSA'xATbR Annual Toch Eval RcDono\MoveiTienl & Soilienu-m
NUiniioiL- SoiilenKTii Monitoi !-.'.Piop SLnilomoni Monii SOP MorKup 03 :OIO.docC-;U;iois\)n5chler.Du'!ilaop\Soction s 0
Setilemem MoniioriiT' SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/2011^ Revisioii: DUSA-24
Book #11: Environmentai Protection Manual, SOP Section 5.0 Page 3 of 5
(v) Once in location, the surveyor will ensure that the survey instrument is
level by centering the bubble in the leyel gauge on the survey instrument;
(vi) The assistant will place the survey rod vertically on the 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;
(vii) 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;
(viii) The assistant will then move to a designaled settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" iiuier pipe. A few of the original settlement monitors
do not have an irmer pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
. (ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 ofthe Environmental Protection
Manual.
L5 Monitoring and Maintenance of Settlement Monitors
LS.l Monitoring and Documentation of Condition of Devices
The Movement Settlement Monitors will be maintained so that the monuments remain in
reliable, good working condition. Conditions at and in the vicinity of the monitoring devices
wil! be inspected monthly by Environmental Department staff. Any observations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
F:^WP'.Di^ ision of Radiaiion C ontrol'Dtfniwn Mjnei, PUSA'.ATER Annual Toch Eval Reporl!.MMovi.MTicnt & Sotdemew
.Monitorr'iSeuleTnonl Moniiorg'.Prop Sctllomcnl Monit SOP MorliupOj 2010.docC:\U5eri>\itischle»^'iDoslitop'.Sco»on 5 0
Settlement Monnortni: SOP;doc
White Mesa Mill - Standard Operatiiig Procedures
Book#l J: Enviromnental Protection Manual, SOP Seclion 5.0
Date: ()4544./20110 Revision: DUSA-2+
Page 4 of 5
The following records and documents will be maintained bv the Environmental Department
staff:
a) Monthly tailings inspection forms
b) Data files of monthly and annual survev infonnation
c) Records of initial installation and sun ev data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
Formatted: Outline numbered +
Level: 5 + Numbering Style: a, b, c,
... + Start at: 1 +. Alignment: Left +
Aligned at: 0.5" + Tab after: 0.75"
+ Indent at: 0.5"
L5.2 Maintenance of Monitors
If any settlement monitoring device is ineparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device.
Based on the last monthly sur\^ey, prior to the damage, tThe replacement device will be placed as
near as practical at the same elevation and in the same location 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 two nearest (undamaged) devices
adjacent to on either side ofthe new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change since the last
montly survey in the elevation location of the undamaged devices, no adjustment will be
made to the survey data of the new device.
3. If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Sun'eyors report and in the annual ATER.
3T4. Also, based on the last monthly survev, prior to the damage, jif the elevation of*
the new device is greater than +/- 0.1 foot from that of the damaged devic^^e. then the
replacement devictrc will be designated with a new nuinber (such as "Cell 2W'2-R". as the
replacement for damaged devic^e "Cell 2W2"). Elevation data for the new devicfe. and
the date of installation of the new device, will be recorded in the data file adiacent to the
information from the damaged devicse. with a notation that this devicse is a replacement
for the damaged devic^^e.
Formatted: List Paragraph, Left, No
bullets or numbering
~ Formatted; Bullets arxl Numbering
F:\WP\Di yt Radiation CunirolrD^HW 444 DUS.V.'STER Annual Toch Eval ReporLrAMox onmni & Seitlcn>em
Mr • Seiilem«?nl Moiiil SOP Markup OJ 20IO.docC:-L)'.-.CT.'-Mitirchloi'.Pur.lai.ip\$ociion 5 0
Soitlcmcni Moniioiinn SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/2011^ Revision: DUSA-24
Book #11: Environmentar Protection Manual, SOP Section 5.0 Page 5 of 5
L6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or rriajor changes in the vertical movement on the settlement monitors. ^ If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible the >
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7jQ{ days of discovery of the problem.r
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
e.xpected settlement of the tailings sands, man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30j4X calendar days for
approval a - timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-steps taken, if needed. This report will be
also be maintained within the Environmental Department records and will be submitted
annually as part of the ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ aad-analyze. correct (as ' '
needed), ^submit the data and thgn-certiiy the annual data in writing—, including an explanation _ . - -(Formatted! Font color: p\um
of the methods and basis used for the review, analysis, and corrections including ongoing
graphical updates for the Settlement Monitors. For movements attributed to expected settlement
of the tailings sands, the review will include comments on the graphical presentation of the data. -
and an evaluation ofthe previous, cunent and expected rates of ongoing settlement.
' • I, •
whiefe-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
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Scttlcmtint Moniiorinii SOP.doc
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lE SUBJECT: MAY4, 2011 / DR
Ms. Jo Ann Tischler
^ Director, Compliance and Permitting
^' Denison Mines (USA) Corp. (DUSA)
11050 Seventeenth Street, Suite 950
c Denver, CO 80265
PS: Fonm .ilSOOAugtir.t'^OOD Seo Fl^L-verso for .lnf.li uclioiis',
Nf-V..„
State of Utah
GARY R. HERBERT
Goverttor
GREG BELL
Lieutenant Governor
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
April 4, 2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: December 1, 2010 Transmittal Letter for Three Separate Draft SOP's; Settlement
Monitoring Standard Operating Procedures [SOPs] 11/2010 Revision: DUSA-1;
Comments and Request for Information
We have received the subject December 1, 2010 letter which transmitted three separate Standard Operating
Procedures (SOPs). The subject of this letter is our review of one of the SOPs, i.e. the Settlement
Monitoring Standard Operating Procedures [SOPs]. DRC review of the other transmitted SOPs will be
discussed in separate letters. The subject SOPs were submitted by DUSA to comply with the requirements
of License Condition 11.7. We have reviewed this item, and have the following comments:
1. General. Some suggested red-line strike-out changes for the subject SOPs are attached. The
majority of these suggestions were derived from our review of the License Conditions. Please note
that some sections of the red-line strike-out copy of the subject SOPs may contain several changes
which were obtained from the numerous License Conditions.
License Condition 11.7, first paragraph, states that, "...The proposed SOP shall describe methods
for.. .comparing such data to previous data to track potential settlement. All data collected by the
Licensee for these purposes shall be included in an annual report to be submitted to the Executive
Secretary, pursuant to License Condition 12.3..."
DRC Findings: It appears that the subject submitted SOPs do not address this condition
completely. License Condition 11.7 applies to more than error correction, but overall
evaluation of vertical movement of the Settlement Monitors. Please add detailed
procedures to the subject SOPs to address this license condition completely.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephonic [phone] • Fax (801) 5,13-40'-)7 • T.D.D. [phone]
www.deq. ulali.v.(n
Primed on 100'Y' recvcled p;\per
Page 4
11. License Condition 11 •7L directs DUSA in the subject SOPs to, "Indicate that results and records of
settlement monitoring shall be submitted annually as part of the ATER required by License
Condition 12.3."
DRC Findings: It appears that the subject submitted SOPs may not address this condition
completely. Some red-line strike-out verbiage attached is suggested in the subject SOPs to
address this license condition. Please revise the SOP in this regard.
Please review the above comments, and respond in writing, submitting an appropriately revised Settlement
Monitoring Standard Operating Procedures document with a unique version number. Per our telephone
conversation on March 31, 2011 you committed that DUSA would fully respond to this letter within 30
calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
Attachment: Red-line strike-out copy of the subject SOPs (DRC Comments)
F:\License\Move & Settle Monitors\Settlement Monitor Cmtl April 201 l.doc
C-Zolo-13'i-
4 Vo>C
-pu
June 21, 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
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax : [phone]
www.denisonmines.com
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 June 2, 2011 Regarding Settlement Monitoring
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Settlement Monitoring SOP. This
letter also responds to DRC's letter of June 2, 2011, which we received on June 6, 2011 providing DRC's
proposed redlines and comments on the subject SOP. We have attached an edited redline copy of the SOP
in which DRC's proposed changes remain in violet-red and Denison's modifications or additional language
are indicated in other colors.
We have provided, below, specific responses to each request in UDEQ's June 2, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC June 2, 2011 letter. Each DRC request is shown
in italics, below, followed by Denison's response.
DRC Comments and Responses
1. No further comment.
Denison Response: No response required.
2. No further comment.
Denison Response: No response required.
3. No further comment.
Denison Response: No response required.
4. Figure 1, a drawing titled Settlement Monitor Fabrication originally dated 09-14-96 and last revised 05-
11, was provided by DUSA to support the description ofthe design ofthe Settlement Monitors found in
Section 1.3 ofthe subject SOPs.
Denison Response: No response required.
N:\SOPs and Procedures\Settlement Monitor SOP and commentsVResponse to RFI and Settlement SOP to DRC
06.21.11\06.21.11ResponsetoDEQ06.02.11 RFISettlementSOP.doc
Letter to Mr. Rusty Lundberg^
June 21, 2011
Page 2
5. No further comment.
Denison Response: No response required.
6. No further comment.
Denison Response: No response required.
7. No further comment.
Denison Response: No response required.
8. As previously stated and requested in our letter of April 4, 2011, Section 1.5.2 in the subject SOPs is
vague in its intent and needed clarifying. After some revision by DUSA, this section still seems rather
complex and unclear. To help clarify the apparent intent of this section, some additional red-line strike-
out verbiage attached, is suggested for Section 1.5.2.
Denison Response: The change has been accepted as proposed.
9. No further comment.
Denison Response: No response required.
10. Per License Condition 11.7K, we requested that the subject SOPs, "Include a list of records that will be
prepared for documenting settlement data for each settlement monitoring device and related site
observations and activities..." In this regard, we request that the annual review of the Settlement
Monitors by a Utah Licensed Professional Engineer be added to the list of records of documents shown
in Section 1.5.1 ofthe subject SOPs.
Denison Response: The change has been made as requested. The review by the Utah-Licensed Professional
Engineer has been added to the list of documents in Section 1.5.1.
11. Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage forthe subject SOPs
to provide that results and records of settlement monitoring be submitted annually as part ofthe ATER.
It appears the addition ofthe word "submit" to Section 1.6 is appropriate in this regard. This addition is
suggested as attached, in the red-line strike-out verbiage for Section 1.6, in the second to last
paragraph of that section.
Denison Response: The change has been accepted as proposed.
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
DENISOl
MINES
Letter to Mr. Rusty Lundben
June 21, 2011
Page 3
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
Attachment
MINES
fiooit^t!'?'W*.S,_
Piston:
Pa.
1.
1.1
of5
1.2
"Within
One
^^^^^ yarw
5,000
specific
White Mesa Mill - Standard Operating Procedures Date: 04644/20110 Revision: DUSA-2-1-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20nO, the required
settlement stands will be placed and the Initial elevation survey completed prior to June 1,
20110.
L3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the infonnation will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and a corrective action plan will be created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within 30XX calendar
days ofthe discovery of the damage to the Settlement Monitor.
1.4 Monthly Surveying
(i) The monthly 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 accurate to 0.1
feet, such as a Sokkai No. B2t, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
F:\WP\Division of Radiation ControI'Denison Mines. DUSA\ATER Annual Teoh Eval Reports\Movement & Settlement
Monitors\Settlomcnt Monitors\Prop Settlement Monit SOP Markup 03 2010.docC:\Usors\itischler\Desktop\Soction 5 0
Settlement Monitoring SOP.doc
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Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(v) 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;
(vi) The assistant will place the survey rod vertically on the 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;
(vii) 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;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Movement Settlement 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 monthly by Environmental Department staff. Any observations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
F:\WP\Division of Radiation Control\Denison Mines. DUSA\ATER Annual Tech Eval Reports^Movement &-^ettl«tReHt
MQnitors\Settiement Monitors\Prop Settlement Monit SOP Markup 03 -201Q:dQcC:\User5\iti5ohler\Desktop\Section 5 0
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04644/20110 Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
The following records and documents will be maintained by the Environmental Department
staff:
a) Monthlv tailings inspection forms
b) Data files of monthly and annual survev information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
el Annual photographs documenting site condifions at each settlement monitor
f) Annual Review of Settlement Monitors by tJtah Licensed Professional Engineer
1.5.2 Maintenance of Monitors
If any settlement 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.
Based on the last monthly survey, prior to the damage, tThe replacement device will be placed as
near as practical at the same elevation and in the same location 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 two nearest (undamaged) devices
adiacent to on either side of the new device.
2. Ifthe survey indicates there has been less than 0.1 foot of vertical change since the last
monthly survev in the elevation location of the undamaged devices, no adjustment will be
made to the survey data of the new device.
3; If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
obsen'ed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
i-A. Also, based on the last monthly survey, prior to the damage, tif the elevafion of
the new device is greater than +/- O.I foot from that of the damaged devicse. then the
replacement devicse will be designated with a new number (such as "Cell 2W2-R". as the
replacement for damaged devicse "Cell 2W2"). Elevafion data for the new devicse, and
the date of installafion of the new device, will be recorded in the data file adjacent to the
informafion from the damaged devicse, with a notation that this devicse is a replacement
for the damaged devicse.
F:\WP\Division of Radiation Control\Denison Mines. DUSA\ATER Annual Tech Eval ReportDVMovement & Settlement
Monitors\Settlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:\Users\jtischler\Desktop\Section 5 0
Settlement Monitoring SOP.doc
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Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible the
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7XX days of discovery ofthe problem.T
2 Document site condifions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Execufive Secretary within 30XX calendar days for
approval a timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-steps taken, if needed. This report will be
also be maintained within the Environmental Department records and will be submitted
annually as part ofthe ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ end-analyze, correct (as
needed), submit the data and then-certify the annual data in wrifing—, including an explanation
of the methods and basis used for the review, analysis, and corrections including ongoing
graphical updates for the Setfiement Monitors. For movements attributed to expected settlement
ofthe tailings sands, the review will include comments on the graphical presentation of the data,
and an evaluafion ofthe previous, current and expected rates Of ongoing setfiement.
whieh-This informafion will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
F:\WP\Division of Radiation ControlVDenison Mines. DUSA\.\TER Annual Teoh Eval Reports\Movoment & Settlement
Monitors\Settlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:\Users\itischler\Desktop\Scotion 5 0
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.0
Date: 06/2011 Revision: DUSA-2
Page 1 of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Statidard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. 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 Monitormg
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010), within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor
Points map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within 60 calendar days of completion of the intermediate cover at the designated locations. The
Settlement Monitor Points map will be updated as part of the installation of new monitors.
Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been
closed to further disposal pursuant to RML condition 10.5.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of
each ISL disposal area, and then annually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These
monuments will be uniquely labeled to identify the specific ISL material.
For ISL source disposal areas or trenches completed before April 1, 2011, the required settlement
stands will be placed and the initial elevation survey completed prior to June 1, 2011.
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
1.3 Design of Settiement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure I detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director. Replacement and/or repairs to the damaged Settlement Monitor
and the surveying and documentation of changes due to the Settlement Monitor damage will be
completed within within 30 calendar days of the discovery of the damage to the Settlement
Monitor.
1.4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surveyor") with the assistance of another Mill
worker (the "Assistanf);
(ii) The survey will be performed using a survey instrument accurate to O.l
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
(v) 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;
(vi) The assistant will place the survey rod vertically on the 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;
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(vii) 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;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an irmer pipe. For original settlement monitors without a I"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 ofthe Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Settlement 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
monthly by Environmental Department staff Any observations will be recorded on the monthly
tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
The following records and documents will be maintained by the Environmental Department
staff:
a) Monthly tailings inspection forms
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
b) Data files of monthly and annual survey information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
f) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer
1.5.2 Maintenance of Monitors
If any settlement 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.
Based on the last monthly survey, prior to the damage, the replacement device will be placed as
near as practical at the same elevation and in the same location 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 two nearest (undamaged) devices
adjacent to the new device.
2. If the survey indicates there has been less than O.l foot of vertical change since the last
monthly survey in the elevation of the undamaged devices, no adjustment will be made to
the survey data of the new device.
3. If the survey indicated O.l foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. Also, based on the last monthly survey, prior to the damage, if the elevation of the new
device is greater than +/- O.l foot from that of the damaged device, then the replacement
device will be designated with a new number (such as "Cell 2W2-R", as the replacement
for damaged device "Cell 2W2"). Elevation data for the new device, and the date of
installation of the new device, will be recorded in the data file adjacent to the information
from the damaged device, with a notation that this device is a replacement for the
damaged device.
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of O.l foot between two consecutive months, then an investigation and possible
corrective actions will be taken as follows:
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
1. Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7 days of discovery of the problem.
2. Document site conditions.
3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses,
burrowing animals, etc.).
4. Report this information to the Executive Secretary within 30 calendar days for approval
and include in that notification the investigation steps, movement evaluation, and
corrective actions taken, if needed. This report will also be maintained within the
Environmental Department records and will be submitted annually as part of the ATER
as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as
needed), submit and certify the 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 Settlement Monitors. For movements attributed to expected settlement of the tailings sands,
the review will include comments on the graphical presentation of the data, and an evaluation of
the previous, current and expected rates of ongoing settlement.
This information will be maintained within the Environmental Department records and will be
submitted annually as part of the ATER as required by RML Condition 12.3.
DENISON
MINES
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: 303 389^125
vvww.denisonmines.com
May 4, 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 4, 2011 Regarding;SettlementM6'nitorin^^^
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Settlement Monitoring SOP. This
letter also responds to DRC's letter of April 4, 2011, which we received on April 8, 2011 providing DRC's
proposed redlines and comments on the subject SOP. We have attached an edited redline copy of the SOP
in which DRC's proposed changes remain In violet-red and Denison's modifications or additional language
are indicated in other colors.
We have provided, below, specific responses to each request in UDEQ's April 4, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC April 4, 2011 letter. Each DRC request is shown
in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General. Some suggested red-line strike-out changes for the subject SOPs are attached. The majority
of these suggestions were derived from our review of the License Conditions. Please note that some
sections ofthe red-line strike-out copy ofthe subject SOPs may contain several changes which were
obtained from the numerous License Conditions.
Denison Response: The changes have been made with the additions or modifications as discussed below.
As mentioned above, where Denison has added or modified DRC's proposed language, the additional
changes are indicated in different colors than DRC's edits.
2. License Condition 11.7, first paragraph, states that, "...T^e proposed SOP shall describe methods
for.. .comparing such data to previous data to track potential settlement. All data collected by the
Licensee for these purposes shall be included in an annual report to be submitted to the Executive
Secretary, pursuant to License Condition 12.3..."
It appears that the subject submitted SOPs do not address this condition completely. This
License Condition applies to more than error correction, but overall evaluation of vertical
N:\SOPs and Procedures\Settlement Monitor SOP and commentsVResponse to RFI and Settlement SOP final to DRC
05.03.11\05.04.11 ResponsetoDEQ04.04.ilRFISettIementSOP.doc
Letter to Mr. Rusty Lundblj^
May 4, 2011
Page 2
movement of the Settlement Monitors. Please add detailed procedures to the subject SOPs to
address this license condition completely.
Denison Response: The change has been made as requested. Language has been added to Sections 1.5.1
and 1.6 to supply these details.
3. License Condition 11.7A directs DUSA in the subject SOPs to, "Require that settlement monitors (e.g..
settlement stands) be promptly installed following placement of temporary cover over placed tailings;"
It appears the submitted SOPs do not address this condition. Some red-line strike-out verbiage
is suggested in Section 1.2 of the subject SOPs to address this license condition. We request
DUSA propose a time, in place of the "XX calendar days" shown in this regard.
Denison Response: DRC's recommended changes have been made to Section 1.2 as requested,
4. License Condition 11.7D directs DUSA in the subject SOPs to, "Include provisions to prevent man-
caused damage to settlement monitoring devices, including, but not limited to vehicle and construction
traffic damage. Such measures will include: 1) all equipment, procedures, and provisions needed to
protect said settlement monitdring devices, 2) schedules for rapid verbal and written reporting of any
such damage, and 3) corrective actions taken or to be taken by the Licensee to replace and/or repair
said devices;"
It appears the submitted SOPs do not completely address this condition, as follows:
a. The design ofthe Settlement Monitors, provided in Section 1.3 ofthe subject SOPs, is
vague with respect to the design height ofthe 1-inch center pipe, and the height ofthe 3-
inch casing above the temporary cover The description is also vague regarding the height,
depth, spacing between and location of the barrier posts bounding the Settlement Monitors.
Drawings may be useful to address this comment:
Denison Response: Figure 1 has been added to the SOP to address these details.
b. The last phrase in License Condition 11.7D requires the SOPs to include, "corrective
actions taken or to be taken., .to replace or repair said devices." This condition requires
corrective actions taken or to be taken to be in the SOPs. Some red-line strike-out
verbiage is suggested in the last paragraph in Section 1.3 ofthe subject SOPs for DUSA to
address this license condition. We request DUSA propose a time in place of the "XX
calendar days" shown in this regard.
Denison Response: DRC's recommended changes have been made to Section 1.3 as requested.
5. License Condition 11.7E directs DUSA in the subject SOPs to, "Indicate that.. .Review ofthe data and
an analysis shall be performed and certified by a Utah Licensed Professional Engineer and submitted
annually as part of the ATER required by License Condition 12.3;
Some red-line strike-out verbiage is suggested in the last paragraph in Section 1.6 ofthe
subject SOPs for DUSA to improve the SOPs with respect to this license condition.
Denison Response: DRC's recommended changes have been made to Section 1.6 with some modifications
as indicate in blue.
DENISON"^^
MINES
Letter to Mr. Rusty Lundbefl^
May 4, 2011
Page 3
6. License Condition 11.7F directs DUSA in the subject SOPs to, "Include procedures requiring that such
settlement monitors be placed, surveyed, mapped, and maintained; that corrective action and
maintenance activities be performed to maintain existing monitoring devices in a reliable, good working
condition, as needed; that the addition, surveying and mapping of new settlement monitoring devices
installed be documented; and that records be made of obsen/ations of site conditions as they relate to
the conditions at and in the vicinity ofthe installed monitoring devices;
It appears that the subject submitted SOPs does not address this condition completely. Some
red-line strike-out verbiage is suggested in Sections 1.2, 1.3. and 1.6 ofthe subject SOPs to
address this license condition.
Denison Response: DRC's recommended changes have been made to Sections 1.2, 1.3 and 1.6 with some
modifications as indicate in blue.
7. License Condition 11.7G directs DUSA in the subject SOPs to, "Provide quantitative performance
criteria and describe how such criteria will be used to evaluate vertical movement;
It appears that the subject submitted SOPs does not address this condition completely. This
License Condition applies to more than error correction, but overall evaluation of vertical
movement of the Settlement Monitors. This License Condition is related to item 2 in this letter.
Please add detailed procedures to the subject SOPs to address this license condition
completely.
Denison Response: The change has been made as requested. Language has been added to Sections 1.5.1
and 1.6 to supply these details.
8. License Condition 11.7H directs DUSA in the subject SOPs to, "Indicate that any settlement monitoririg
device that is irreparably damaged as a result of environmental stresses or through man-caused
contact, including but not limited to cell construction or other operational equipment, shall be promptly
replaced with an identical or equivalent monitoring device; and provisions provided to guide the
interpretation of data from both the former and the replacement device;
It appears that the subject SOPs Section 1.5.2 partially addresses of this License Condition.
However this section is vague in its complete intent. Please clarify the intent or revise this
section to address this License Condition.
Is it feasible to replace a damaged Settlement Monitor with a new device at the same
elevation? As part ofthis response, we request that DUSA include in these SOPs that a
permanent notation in the data will be provided to record the date of replacement of any
Settlement Monitor
Denison Response: Denison will attempt to install replacement Settlement Monitors at the same elevation as
the damaged monitors; however, the elevation of the replacement devices cannot be assured. The
commitment to record the date of replacement has been added to Section 1.5.2 as requested.
9. License Condition 11.71 directs DUSA in the subject SOPs to, "Indicate that where survey evidence
suggests that significant apparent movement in a settlement monitor has occurred, in excess of the
approved pertormance criteria, that the departure(s) will be investigated and explained, and errors
corrected and resolved in a timely manner, subject to Executive Secretary approval;
DENISONO/
MINES
Letter to Mr. Rusty LundbJ|^
May 4, 2011
Page 4
It appears the submitted SOPs do not completely address this condition. Some red-line strike-
out verbiage is suggested in Section 1.6 of the subject SOPs to address this license condition.
We request DUSA propose a time, in place of the 'XX calendar days" shown in this regard.
Denison Response: The number of calendar days has been proposed In each location in the text as
requested.
10. License Condition 11.7K directs DUSA in the subject SOPs to, "Include a list of records that will be
prepared for documenting settlement data for each settlement monitoring device and related site
observations and activities..."
It appears that the subject submitted SOPs does not address this condition completely. Please
add a detailed list of records to the subject SOPs to address this license condition completely.
Denison Response: DRC's recommended changes have been made to Section 1.6.1 as requested.
11. License Condition 11.7L directs DUSA in the subject SOPs to, "Indicate that results and records of
settlement monitoring shall be submitted annually as part ofthe ATER required by License Condition
12.3.
It appears that the subject submitted SOPs may not address this condition completely. Some
red-line strike-out verbiage is suggested in the subject SOPs to address this license condition.
Denison Response: A commitment to annual reporting has been made as requested.
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
Central files
DENISO
MINES
Wiitc Mesa Mill - Standard Operating Procedures Date: (K544/20 MO Revision: r;USA-24-
Book UW: Environmental Protection Manual, SOP Section 5 0 Page 1 oi"5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. 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 ofthe Radioactive Materials License (RML).
1.2 Locations and Frequency of IVionitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department slaff and annually by a Utah Licensed Professional Eand
SuJTeyor.
For any new Settlement Monitor installed (after June, 2010)-, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new SeUlement
Monitors will be pre-designated by the Mill Engineer on Uie latest DUSA Settlement Monitor
Points map (originallv dated 09/15/08). ScitlemetU Monitors wilt bc placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors wili be installed
within j4^60 <;alendar dayi^ of cQniplctlon of th^ intermediate CQvcr at dg$tgnatcd Ipcaiions.
The SetUement Monitor Points map will be updated as p^rt ofthe Instaliation of new monitory.
A»^tated-abeve^-S€ttlimteRfMemters wilt^ plaee€L&n-the-te»Hng-^efe~when temporary covei^k
being advanoed--e<»4lie pletNgd tollfflg&r---Sett^ Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to further disposal pursuant to RML condition
10.S.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually afler that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL matenal. These monuments will be uniquely labeled to identify the specific
ISL material.
Sattlemenl Monitoring SOP.doc
•
White Mesa Mill - Standard Operating Procedures Date: 04544/20119 Revision: DUSA-24-
Book #11; Environmental Protection Manual, SOP Section 5 0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. Afler this has been
completed, the last two feet of material will be backfilled. The top of the 3"" casing will bc
threaded to allow for a cap to bc installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure \ detailing the eonstnicUon of the Settiement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day_ noti tlcation to the
Corporate Compliance Director^ aft4-a--ecH=i^tive-a6ti«»-filan-witi be created for-fReplacemgM
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of^iese
changes due to the Settlement Monitor dama&c will be completed within within 3QX^ calendar
days of the discovery of the damage to the Settlement Monitor.
1.4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surx'cyor") with the assistance of another Mill
worker (the "Assistant");
(ii) The survey will be performed using a survey instrument accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference poinl and settlement monitor are visible.
Settlement Monitoring 80P.doc
While Mesa Mill - Standard Operating Procedures Date: \\Q Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5 0 Page 3 of 5
(v) 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;
(vi) The assistant wilLplace the survey rod vertically on the reference point,
rhe 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;
(vii) 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;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have,an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor wil! focus the cross hairs of the survey instniment on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to O.l feet. The
elevation information will be maintained wilhin the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can bc found in Section 3.1 ofthe Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Movement Settlement Monitors will bc maintained so that the monuments remain in
reliable, good working condition. Conditions at and in the vicinity of the monitoring devices
will be inspected monthly by Environmental Dcpartmient staff. Any obsei-valions will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument wil! be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
MemHft>i^iw»tH4>tetH Miukup 0^3^-3»U>^-&:Mj5«fi^ts^iei^C)i^
Sottloment Monitoring SOP.doc
#
White Mesa Mill - Standard Operating Procedures Date: 04544/20116 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
The following records and documents will bc maintained by the Bnvironmental Department
staff:
o
a) Monthlv tailings inspection forms
b) Data files of monthly and annual survey Information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement moniturs
e) Annual photographs documenting site conditions at each settlement monitor
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be prompdy replaced with an identical or equivalent device. The
replacement device will be placed in the same location from which the damaged device was
removed. Data from the new device wil! 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 ofthe new device as well as that of the nearest (undamaged) devices on cither
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
3. [f the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
3^4: If the elevation of the; new device is greater than 4/» 0.1 foot fmrn that of the
damaged devicse. then the replacement devic#c will be designated with a new nutnber
(such as "Cell 2W2-R*\ as the replacement fbr damaged devicae **C€U 2W2"). Elevatioii
data for the new devicae. and the date of installatipn of tlic new device, will be recorded
in the data file adjacent to the information from the damaged devicse. with a notation that
this devicse is a replacement tor the damaged devicse.
1.6 Perforniance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
White Mesa Mill - Standard Operating Procedures Date: 0^t.S44/20110 Revision: DUSA-24-
Book #11; I-nvironmental Protection Manual, SOP Seclion 5 0 Page 5 of 5
difference of 0.1 foot between two consecutive months, then an investigation and possible the
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 fool or more,
within 7XX days of discovery ofthe problem.7
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement ofthe tailings sands, man-caused contact, environmental stresses, OF
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 3(}^ calendar days for
approval o timeh' manner and inciude in that notification the investigation steps,
movement evalualion, and corrective actions-at^sjakgrLtlTjiMde^^ This report will be
also te maintaingd within the l-nvironmental l>epaftment records and^^^M^^
annually as part ofthe ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ and-analyze, correct (as
needed} the dota-and thenr-certify the annual data in writlngTrr-, including an explanation of thf?
methods and basis used for iM.review, analys including ongoing graphical
updates for the Settlement Monitors. I'or movements attributed to expected settlement of the
tailings sands, the review will include commenis on the gmphipal,presentation ofthe data, and an
evaluation of the previous, current and expected rdtes of ongoing settlement.
whieh-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
Mof>ftefs\Settjew«tt4i4gffitof$i^^
Sottloment Monitoring SOP doo
White Mesa Mill - standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
L SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. 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 ofthe Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Setdement Monitor installed (after June, 2010), within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor
Points map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within 60 calendar days of completion of the intermediate cover at the designated locations. The
Settlement Monitor Points map will be updated as part of the installation of new monitors.
Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been
closed to further disposal pursuant to RML condition 10.S.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days ofthe completion of
each ISL disposal area, and then annually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These
monuments will be uniquely labeled to identify the specific ISL material.
For ISL source disposal areas or trenches completed before April 1, 2011, the required settlement
stands will be placed and the initial elevation survey completed prior to June i, 2011. .
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a I" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight dovm in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed.on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement v^ll be
boimded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director. Replacement and/or repairs to the damaged Settlement Monitor
and the surveying and documentation of changes due to the Settlement Monitor damage will be
completed within within 30 calendar days of the discovery of the damage to the Settlement
Monitor.
1.4 Monthly Surveying
(i) The monthly 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 accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
(v) 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;
(vi) The assistant will place the survey rod vertically on the 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;
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(vii) The surveyor will focus the cross hairs of the survey instrument on tlie
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;
(viii) The assistant will then move to a designated settlement monitor. Once at
, the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation infonnation will be maintained v^thin the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Settlement 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
monthly by Environmental Department staff. Any observations will be recorded on the monthly
tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
The following records and documents will be maintained by the Environmental Department
staff:
a) Monthly tailings inspection forms
WhitQ Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.0
Date: 05/2011 Revision: DUSA-2
Page 4 of5
b) Data files of monthly and annual survey information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of enviroimiental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The,
replacement device will be placed in the same location 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. Tf the survey indicates there has been less than 0.1 foot of vertical change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
3. If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. If the elevation of the new device is greater than +/- 0.1 foot from that of the damaged
device, then the replacement device will be designated wdth a new number (such as "Cell
2W2-R", as the replacement for damaged device "Cell 2W2"). Elevation data for the
new device, and the date of installation of the new device, will be recorded in the data file
adjacent to the infonnation from the damaged device, with a notation that this device is a
replacement for the damaged device.
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7 days of discovery of the problem.
2 Document site conditions.
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses,
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30 calendar days for approval
and include in that notification the investigation steps, movement evaluation, and
conective actions taken, if needed. This report will also be maintained within the
Environmental Department records and will be submitted annually as part of the ATER
as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as
needed) and certify the 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
Settlement Monitors. For movements attributed to expected settlement of the tailings sands, the
review will include comments on the graphical presentation of the data, and an evaluation of the
previous, cunent and expected rates of ongoing settlement.
This information will be maintained within the Environmental Department records and will be
submitted annually as part of the ATER as required by RML Condition 12.3.
3" THREADED NIPPLE
E& COUPLINGS)
3" THREADED PIPE CAP
1" PIPE COUPLINO
3" PIPE COUPLING
r DL\METER RISER PIPE
3" DLVMETER GUARD PIPE
(instslled aiouod 1" TUCT pqw in the field)
2'
1/4-SraBL
BASE PLATE 2'
XrMIN.
MATERIALS
DESCRIPTION OUANTTTY DIMENSION
r SCH 40 COUPLING 2 EACH
1" SCH 40 THKUADKU PIPE
(BLACK) IBACH S'O"
3" SCH 40 THREADED CAP lEACH
3-SCH 40 THREADED
rmiPLINO lEACH
3" X 6* SCH 40 THREADED
NIPPLE lEACH
3" SCH 40 GUARD PIPE IBACH 3*4"
1/4" STEEL BASE PLATE lEACH 2 '0" X 2*0"
1/4" STEEL BASE PLATE lEACH 6"X6"
NOTES:
1. ALL STEEL TO BE PAINTED WITH TWO COATS OF RED
EPOXY PAINT.
2. NO GALVANIZED PIPE OR PIPE FrrnNGS ARB TO BE USED
e-SQUAKKl/rPLATB , 3J>IMAMBTEIlHra.l
3"
OUAROnPBBASB HATH rWrAIL SCALBS'^IV
SMAU. BA5B PLATB ATTACHBD
TO BASE OV OUARD nPB
3* oiAMnn ouASD mNar
ATTAaiBD TO IHB BASI IIAIB
Denison Mines (USA) Corp owisotF^A i
MINES
1^.1 WHlte Mesa Mill "1113^.-121
SETTLEMENT MONITOR
F/VBRICATION
FIGURE 1
White Mesa Mill - Standard Operating Procedures Date: 04544-/20HQ Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. 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
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010)-, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement . . • ' " .
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor ^ , - \ Formatted; Font: italic
Points map (originallv dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within XX60 calendar days of completion of the intermediate cover at the designated locations.
The Settlement Monitor Points map will be updated as part of the installation of new monitors.
As stated above. Settlement Monitors will be placed on the tailing cells when temporar>^ cover is
being advanced on the placed tailings. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to ftirther disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually after that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
F:\WP\Division of P.adiation Contiol\Deniiion Mines. DUSAUTER Annual Toch Eval RepoitsVMovement & Sottlomert
Monitors\SettleTnent Monitors'iProp Settlement Monit SOP Markup 03 2010.docC:\Uaorr.\itiochlcr\Dooktop\Soction 5 0
Sottloment Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 045-I4-/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
1.3 Design of Settlement Monitors
Bach Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location unfil tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director and a corrective action plan will be created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within 3QXX calendar
days ofthe discovery of the damage to the Settlement Monitor.
1.4 Monthly Surveying
(i) The monthly 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 accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
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White Mesa Mill - Standard Operating Procedures Date; 04544/20110 Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(v) 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;
(vi) The assistant will place the survey rod vertically on the 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;
(vii) 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;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Movement Settlement 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 monthly by Environmental Department staff. Any observations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.0
Date: 04544/20110 Revision: DUSA-24-
Page 4 of 5
The following records and documents will be maintained by the Environmental Depaitment
staff
a) Monthly tailings inspection forms
b) Data files of monthly and annual survey infomiation
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions al each settlement monitor
Formatted: Outline numbered +
Level: 5 + Numbering Style: a, b, c,
... + Start at: 1 + Alignment: Left +
Aligned at: 0.5"+Tab after: 0.75"
+ Indent at: 0.5"
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The
replacement device will be placed in the same location from which the damaged device was
remoyed. Data from the new device will be correlated to data from the removed damaged device
as follows:
I \. 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 change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
3. If the survey indicated 0.1 foot or greater of vertical change to either ofthe undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
^A, If the elevation of the new device is greaier lhan +/- 0.1 foot from that of Ihe*-
damaged devicse, then the replacement devicse will be designaled with a new number
(such as "Cell 2W2-R". as the replacement for damaged devicse "Cell 2W2"). Elevation
data for the new devicse, and the dale of installation of the new device, will be recorded
in the data file adiacent to the information from the damaged devicse. wilh a notation that
this devicse is a replacement for the damaged devicse.
Formatted: List Paragraph, Left, No
bullets or numbering
Formatted: Bullets and Numbering ]
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
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White Mesa Mill - Standard Operating Procedures Date: 04544-/20110 Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
difference of 0.1 foot between two consecutive months, then an investigation and possible the
corrective aciions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
wilhin 7XX days of discovery of the problem.T
2 Documenl site conditions.
3 Prepare a document to the Corporate Compliance Direclor staling possible causes (i.e.
expected settlement of the tailings sands, man-caused coniact, environmental stresses, or
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30XX calendar days for
approval a timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-steps taken, if needed. This repori will be
also be maintained within the Environmental Department records and will be submitted
annually as part of the ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ and-analyze. correct (as
needed) the dala and tfeea-certify the annual dala in writing—, including an explanation of the
meihods and basis used for the review, analysis, and corrections including ongoing graphical
updates for the Settlement Monitors. For movements attributed lo expected settlement of the
tailings sands, the review will include comments on the graphical presentation of the data, and an
evalualion ofthe previous, current and expected rates of ongoing settlement.
wh4eh-This information will be maintained within the Environmental Departmenl records and
will be submilted annually as part of the ATER as required by FLML Condition 12.3.
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