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HomeMy WebLinkAboutDRC-2012-001086 - 0901a068802a7faaC- 20 12-00 108 6 January 30 2012 VIA E MAIL AND OVERNIGHT DELIVERY Mr Rusty Lundberg Department of Environmental Quality 195 North 1950 West PO Box 144850 Salt Lake City UT 84114 4850 Denison Mines (USA) Corp 105017th street Suite 950 Denver CO 80265 USA Tel 303 628 7798 Fax 303 389 4125 www denisonmines com Re State of Utah Groundwater Discharge Permit ( GWDP ) No UGW370004 Transmittal of Revised Discharge Minimization Technology Monitonng ( DMT ) Revision 11 4 dated January 2012 Dear Mr Lundberg Reference is made to the Division of Radiation Control ( DRC ) letters dated September 13 2011 December 14 2011 and December 22 2011 regarding the White Mesa Mill Tailings Management System and Discharge Minimization Technology ( DMT ) Monitonng Plans dated June 2011 (Revision 11 2) and July 2011 (Revision 11 3) This letter transmits Denison Mines (USA) Corp s ( Denison s ) proposed revisions to the White Mesa Mill DMT Plan These revisions include changes made to 1 Respond to the Request for Information ( RFI )/Confirmatory Action Letter dated September 13 2011 2 Respond to the comments provided in the December 22 2011 DRC letter and 3 Correct additional errors and inconsistencies in the June 2011 and July 2011 Revisions of the DMT Plan For ease of review we have provided both redline and clean versions of each document The attached DMT Plan Revision 11 4 has accepted all the redline changes proposed in Denison s June 23 2011 and July 11 2011 submittals as the base version in black type Changes resulting from the above referenced DRC comment letters are provided in redline/stnkeout format We have also provided below specific responses to each request in DRCs September 13 2011 and December 22 2011 letters The sections and numbenng of the remainder of this letter follow the DRC September 13 2011 and December 22 2011 letters Each DRC request is shown in italics below followed by Denison s response Letter to Mr Rusty Lundberg January 30 2012 Page 2 Responses to Comments Provided to DUSA in the September 13 2011 DRC RFI/Confirmatory Action Letter (as re transmitted in a DRC letter dated December 14 2011) DRC Comment 1 DUSA will provide the DRC the appropriate Mine Safety and Health Administration (MSHA) rule quotation(s) and citing(s) that require the use of walkways with handrails when egressing active tailings cells According to our discussion these requirements precluded DUSA from making water level elevation measurements in Cell 4B Denison Response The requested MSHA citations are as follows 1 30 CFR 56 11001 - Safe Access - Safe means of access shall be provided and maintained to all working places 2 30 CFR 56 11002-Handrails and toeboards- Crossovers elevated walkways elevated ramps and stairways shall be of substantial construction provided with handrails and maintained in good condition Where necessary toeboards shall be provided 3 Statutory Miners Rights - Right to refuse to work under conditions or practices believed to be unsafe unhealthy or illegal 4 Statutory Miners Rights - Right to protection from discnmination for exercising statutory rights Under the requirements of MSHA if there is no MSHA regulation specific to a given issue but there is one under OSHA the OSHA rule does apply That being the case Denison is also required to comply OSHAs policies for nng buoys lifesaving skiffs and other requirements as prescnbed in 1910 and 1926 (General Industry and Construction) under OSHA s policies if a walkway with handrails is not avaialble DRC Comment 2 DUSA will commit to a penod of time to construct walkways for new tailings cells after receiving authorization for use of any new tailings cell from the Executive Secretary This time period must be submitted for approval in a revised DMT Plan Denison Response It IS Denison s understanding that DRC s request for a time commitment to construct walkways in new cells IS based on the assumption that the initiation of solution level measurements in future cells will require a walkway That is Denison understands that DRC actually seeks a time commitment for initiating solution level measurement Tailmgs cell wastewater pool elevations will be monitored within 30 days of authonzation for use in accordance with the existing survey procedures specified in the DMT Plan and in accordance with Mill health and safety requirements The DMT Plan has been revised to reflect this requirement Health and safety requirements will dictate the methods such as floating walkways for providing worker access to the new cells are not discussed in the DMT Plan DRC Comment 3 DUSA will acquire a steel surveyors tape(s) of adequate length or develop other approved means to accurately measure water level elevations prior to construction of the walkway discussed in the two numbered items immediately above The procedures for this method to measure the water level elevation will be submitted by DUSA for approval in a revised DMT Plan Denison Response A steel surveyors tape will not be used to measure tailings wastewater pool elevations Consistent with the remainder of Comment 3 Denison has developed other means to accurately measure cell solution level elevations prior to construction of any walkways Therefore a descnption of procedure for use of a surveyor s tape is not necessary No changes to the text have been made DENISO MINES Mi Letter to Mr Rusty Lundberg January 30 2012 Page 3 DRC Comment 4 DUSA will revise the DMT Plan reference (c) so the point designated for the water level measurement in Cell 4B will be the southeast corner rather than the current required location Denison Response The text has been changed as requested DRC Comment 5 DUSA must acquire a longer survey elevation rod eg a 45 rod) in order to survey the water level in the subject cell at lowest depths DUSA will revise the DMT Plan to include procedures for use of this longer survey rod Denison Response Denison has purchased a longer survey elevation rod 45 feet in length The procedures for use of the longer survey elevation rod are the same as those currently descnbed in the DMT plan The longer survey elevation rod does not require any procedural changes therefore no changes were made in the DMT Plan DRC Comment 6 A revised DMT Plan proposed in reference (e) contains a new paragraph on page 10 As discussed this specific proposed new verbiage is not acceptable The DMT Plan must be revised in accordance with the above commitments and requirements Denison Response The paragraph in question has been modified to specify that tailings wastewater pool elevations in new cells will be measured within 30 days of authonzation for use of the new cell DRC Comment 7 A new revised DMT Plan containing all the necessary verbiage changes from the items above will be submitted for approval Denison Response The revised DMT Plan Revision 11 4 dated January 2012 is attached Responses to Comments Provided to Denison in the DRC letter dated December 22 2011 DMT Plan Changes Required, from the Groundwater Discharge Permit Part I H 7 DRC Comment 1 Permit Part ID 3(b) paragraphs ii and in now that the slimes dram access pipe has been extended the correspondmg measurements in the DMT Plan need to be corrected Denison Response The Cell 2 shmes dram access pipe measurements have been changed in the DMT Plan and the appropnate forms in the appendices to the Plan As a result of the changes in Cell 2 and the corrected measurements descnbed below the new depth of the Cell 2 shmes dram access pipe is 37 97 feet This modification has been made in the DMP Plan Revision 11 4 The changes to the Cell 2 slimes dram access pipe are described in more detail below Two sets of measurements are routinely collected from the Cell 2 slimes dram access pipe for compliance with the GWDP and the RML The first measurement is the quarterly recovery test which is conducted to determine the compliance with the GWDP Part I D 3 (b)2 The second set of measurements are the weekly pre and post pump head measurements required by the License Changes to Cell 2 were completed dunng the second and third quarter 2011 which affect both sets of measurements collected from the Cell 2 shmes access dram Where these changes affect the DMT Plan or inspections forms the DENISO MINES Mi Letter to Mr Rusty Lundberg January 30 2012 Page 4 Plan or forms have been revised A descnption of the changes and the effects on the measurements are as follows Summary of Changes to Cell 2 As detailed in letters to DRC dated May 27 June 17 and August 1 2011 Denison re graded the interim fill on Cell 2 in order to reduce the potential for the accumulation of stormwater on the surface of Cell 2 which could potentially infiltrate into Cell 2 This re grading required 62 000 cubic yards of cut and fill and was completed on July 30 2011 As a result of the re grading of the intenm cover and the placement of additional fill the Cell 2 slimes dram access pipe was extended to bnng it above grade relative to the new cell surface elevation The extension pipe which is the same diameter as the existing access pipe was placed on top of the previous Cell 2 slimes dram access location and was mechanically attached using metal braces and plates The seam between the existing pipe and the extension were sealed with caulking and an external covenng to prevent infiltration by dirt and debns The measunng point for the extension of the slimes dram access pipe is directly above the previous measunng point The distance from the old measunng point to the new extended measunng point was measured to an accuracy of 0 01 feet The extension to the Cell 2 shmes dram access pipe measures 6 97 feet The extension was placed July 20 2011 Quarterly Recovery Test Data As noted above the quarterly recovery test is completed in accordance with the GWDP dated July 14 2011 Part I D 3 (b)(2) The recovery test data are collected by measunng the fluid level in the shmes dram over an extended penod of time (greater than 90 hours) The measurements for the recovery test are taken by measunng the distance from the measunng point to the top of the fluid present in the Cell 2 shmes dram access pipe The total depth of the Cell 2 shmes dram access pipe is not used in any of the calculations for determination of compliance with the GWDP Compliance determinations rely on elevation data generated by subtracting depth of the fluid levels measured from the top of the Cell 2 shmes dram access pipe from the elevation of the slimes dram access pipe There will be no change in the shmes dram elevation numbers generated because both the measurements used in the subtraction are adjusted by the same factor In order to make the data collected pnor to July 20 2011 comparable to the current data for use in the graphical representations 6 97 feet was added to all of the previous recovery data to adjust for the height added with the extension to the Cell 2 shmes dram access pipe Weekly Pre and Post Pump Head Measurements As noted above weekly pre and post pump head measurements are collected as required by the RML The weekly pre and post pump head measurements are taken by measunng the distance from the measunng point to the top of the fluid present in the Cell 2 shmes access pipe Two measurements are taken the first measurement is taken before the pump is started and the second is taken after the pump has run for 15 minutes The pre and post pump head is calculated by subtracting the liquid level from the total depth of the Cell 2 slimes dram Dunng the measurements of the extension to the Cell 2 shmes dram access pipe it was noted by the field personnel that the new length of the Cell 2 shmes dram access pipe is now approximately 38 feet The previous measurement used for the pre and post pumping head measurements was also 38 feet and the discrepancy was noted An investigation into the discrepancy between the previous total depth of the Cell 2 slimes dram and the current depth of the Cell 2 slimes dram was conducted The investigation included a review of the as built drawings for Cell 2 previous pre and post pump measurements and a review of the Cell 2 shmes drain access pipe procedures The as built drawings and the results of the investigation indicate that the previous total depth of the Cell 2 slimes dram was actually 31 feet With the extension of 6 79 feet to the previous total depth of 31 feet the current depth is now approximately 38 feet Pnor to the second quarter of 2011 the pre and post pump data was not reported to DRC The pre and post pump data were reported to DRC only in the second and third quarter 2011 DMT Reports The corrected DENISO MINES Mi Letter to Mr Rusty Lundberg January 30 2012 Page 5 second and third quarter data will be included in the next quarterly DMT Report submitted on or before March 1 2012 DRC Comment 2 Part IE 7(b) paragraph (2) a professional survey of the new measurement point needs to be made Denison Response The Cell 2 slimes dram access pipe has been surveyed by a Utah certified Land Surveyor DRC Comment 3 Now that the Cell 2 slimes dram access pipe has been extended in height DUSA must state in the DMT Plan how the measurements to the water surface will be taken now and how DUSA will correlate these measurements correctly to earlier measurements Denison Response The weekly measurement procedure was not changed as a result of the extension of the Cell 2 shmes dram access pipe The head values are calculated in the same manner using the same procedures as those used prior to the extension of the Cell 2 slimes dram access pipe however the total depth to the bottom of the pipe has changed to 37 97 feet as noted to the response to DRC comment number 1 above The new total depth is now used to calculate the pre and post pumping head The new measurement is noted on the Weekly Tailings Inspection form in Attachment A of the DMT Plan Correlation and/or adjustment for the height of the Cell 2 slimes dram access pipe for the calculation of the pre and post pumping head values is not necessary The pre and post head values are calculated by subtracting the liquid level measured pre and post pumping from the total depth of the Cell 2 shmes dram access pipe The pre and post pumping head value is a calculated difference that uses the total height of the Cell 2 shmes dram access pipe As can be seen in the following example the pre and post head values are the same regardless of the height of the Cell 2 shmes dram access pipe The pre and post pumping values are stored in hardcopy at the Mill site on the Weekly Inspection forms A note to the file will be stored with all of the hardcopy forms that show the incorrect total depth of 38 feet If recalculation were necessary the correct height measurement to complete the calculation will be used Other Comments on the DMT Plan (reference (B) DRC Comment 4 On page 4 in the first sentence the items Cell 3 Cell 4A spillway should be reversed in their order in the sentence to be clearer in meaning Denison Response The text was changed as requested DRC Comment 5 In paragraph 6 35 there are several references to Cell 4A that apparently should refer to Cell 4B instead This occurs in paragraphs (c) iv vi vii and paragraph (d)iii In Appendix F of the DMT Plan this misreference appears to occur on page 56 in the second and fifth bullet line Please correct Denison Response The text corrections have been made as requested DRC Comment 6 Paragraph 6 2 needs to be revised due to the construction of Cell 4B It needs to be corrected to refer to the current exterior dikes required to have movement monitoring DENISO MINES Mi Letter to Mr Rusty Lundberg January 30 2012 Pages Denison Response The text corrections have been made as requested DRC Comment 7 Page 29 Table III Column under Dike 3 If there is visible embankment on the south dike of Cell 3 please adjust the form as appropriate Denison Response There is no visible embankment on the south dike of Cell 3 and no changes to the text were required DRC Comment 8 On page 36 paragraph 7 refers to a Contaminated Waste Dump awaiting DRC approval We are uncertain as to what this is Please clarify Denison Response The name Contaminated Waste Dump is an incorrect designation for the Designated Disposal Area for Non Tailmgs Mill waste discussed in SOP PBL 7 The form has been modified to refer to the area correctly The notation awaiting DRC approval on the form refers to an amendment request submitted to DRC by Denison in 2008 to revise the SOP to permit disposal of non tailings Mill waste in more than one cell To date DRC has not provided any response to that amendment request DRC Comment 9 Due to the installation of additional platform fill on Cell 2 slimes dram recovery elevation measurement related items in the DMT Plan need to be changed On the DMT Plan inspection form p 34 paragraph 2 the 38 foot figure appears to need adjustment Denison Response The form was changed as required Please contact me if you have any questions or require any further information Yours very truly DENISON MINES (USA) CORP 4)o Ann Tischler Director Compliance and Permitting cc David C Frydenlund Ron F Hochstein Harold R Roberts David Rupp David E Turk K Weinel Attachments White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 1 of 53 WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND DISCHARGE MINIMIZATION TECHNOLOGY (DMT) MONITOMNG PLAN TABLE OF CONTENTS Contents 1 INTRODUCTION 3 2 DAILY TAILINGS INSPECTIONS 3 2 1 Daily Comprehensive Tailmgs Inspection 3 2 2 Daily Operations Inspection 6 2 3 Daily Operations Patrol 6 2 4 Training 6 2 5 Tailings Emergencies 6 3 WEEKLY TAILINGS AND DMT INSPECTION 7 3 1 Weekly Tailings Inspections 7 Northing 12 Easting 12 3 2 Weekly Inspection of Solution Levels in Roberts Pond 14 3 3 Weekly Feedstock Storage Area Inspections 15 4 MONTHLY TAILINGS INSPECTION 15 5 QUARTERLY TAILEsfGS INSPECTION 16 6 ANNUAL EVALUATIONS 17 6 1 Annual Technical Eveiluation 17 6 2 Movement Monitors 18 6 3 Freeboard Linuts 18 6 3 1 Cell 1 19 6 3 2 Cell 2 19 6 3 3 Cell 3 19 6 3 4 Cell 4A 19 6 3 5 Cell 4B 19 6 3 6 Roberts Pond 22 6 4 Annual Leak Detection Fluid Samples 22 6 5 Annual Inspection of the Decontamination Pads 23 7 OTHER INSPECTIONS 23 N \DMT PlanNDMT Plan 01 30 12 Revision 11 4\Taibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Envu-onmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 2 of 53 8 REPORTING REQUIREMENTS 8 1 Monthly Tailings Reports 8 2 DMT Reports 8 3 TAILINGS INSPECTOR TRAEsFING 23 23 24 40 N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu:onmental Protection Manual Section 3 1 Page 3 of 53 1 INTRODUCTION This Tailings Management System and Discharge Minimization Technology Monitonng Plan (the Plan ) for the White Mesa Mill (the Mill ) provides procedures for monitoring of the tailings cell system as required under State of Utah Radioactive Matenals License No UT1900479 (the Radioactive Materials License ) as well as procedures for operating and maintenance of monitonng equipment and reporting procedures that are adequate to demonstrate DMT compliance under State of Utah Ground Water Discharge Permit No 370004 for the Mill (the GWDP ) This Plan is designed as a systematic program for constant surveillance and documentation of the integrity of the tailings impoundment system including dike stability liner integrity and transport systems as well as monitoring of water levels m Roberts Pond and feedstock storage areas at the Mill The Plan requires daily weekly quarterly monthly and annual inspections and evaluations and monthly reporting to Mill management 2 DAILY TAILINGS INSPECTIONS The following daily tailings inspections shall be performed 2 1 Dailv Comprehensive Tailings Inspection On a daily basis including weekends all areas connected with the evaporation cell (Cell 1) and thefour tailings cells (Cells 2 3 4A and 4B) will be inspected Observations will be made of the current condition of each cell noting any corrective action that needs to be taken The Radiation Safety Officer (RSO) or his designee is responsible for performing the daily tailings inspections The RSO may designate other individuals with trainmg as described in Section 2 4 below to perform the daily tailings inspection Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of which IS attached in Appendix A) The Daily Inspection Data form contains an inspection checklist which mcludes a tailings cells map and spaces to record observations especially those of immediate concem and those requiring corrective action The inspector will place a check by all inspection items that appear to be operating properly Those items where conditions of potential concem are observed should be marked with an X A note should accompany the X specifying what the concem is and what conective measures will resolve the problem This observation of concem should be noted on the form until the problem has been remedied The date that conective action was taken should be noted as well Areas to be inspected include the following Cell 1 2 3 4A and 4B Dikes 4A S 4A E and 4B N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 4 of 53 S wind movement of tailings effectiveness of dust minimization methods spray evaporation Cell 2 spillway Cell 3 spillway Cell 4A spillway Cell 3 Cell 4A and 4B liquid pools and associated liquid retum equipment and cell leak detection systems Operational features of the tailings area are checked for conditions of potential concem The following Items require visual inspection during the daily tailings inspection a) Tailmgs slurry and SX raffinate transport systems from the Mill to the active disposal cell(s) and pool retum pipeline and pumps Daily inspections of the tailings lines are required to be performed when the Mill IS operating The lines to be inspected include the tailings slurry lines from CCD to the active tailmgs cell SX raffinate lines that can discharge into Cell 1 Cell 4A or Cell 4B the pond retum line from the tailings area to the Mill and lines transporting pond solutions from one cell to another b) Cell 1 c) Cell 2 d) Cell 3 e) Cell 4A f) Cell 4B g) Dike stmctures including dikes 4A S 4A E and 4B S h) The Cell 2 spillway Cell 3 spillway Cell 4A spillway Cell 3 Cell 4A and Cell 4B liquid pools and associated liquid retum equipment i) Presence of wildlife and/or domesticated animals in the tailings area including waterfowl and bunowing animal habitations j) Spray evaporation pumps and lines k) Wind movement of tailings and dust rmniimzation Wind movement of tailings will be evaluated for conditions which may require initiation of preventative dust minimization measures for cells containing tailmgs sand During tailmgs inspection general surface conditions will be evaluated for the following 1) areas of tailings subject to blowing and/or wind movement 2) N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 5 of 53 liquid pool size 3) areas not subject to blowing and/or wind movement expressed as a percentage of the total cell area The evaluations will be reviewed on a weekly basis or more frequently if wananted and will be used to direct dust nunimization activities 1) Observation of flow and operational status of the dust control/spray evaporation system(s) m) Observations of any abnormal variations in tailings pond elevations in Cells 1 3 4A and4B n) Locations of slurry and SX discharge within the active cells Slurry and SX discharge points need to be indicated on the tailings cells map included m the Daily Inspection Data form o) An estimate of flow for active tailings slurry and SX line(s) p) An estimate of flow in the solution retum line(s) q) Daily measurements m the leak detection system sumps of the tailmgs cells will be made when warranted by changes in the solution level of the respective leak detection system The trigger for further action when evaluating the measurements in the Cell 1 and Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours The solution level m Cell 4A or 4B leak detection system is not allowed to be more than 1 0 foot above the lowest point on the bottom flexible membrane liner (FML) (Cell 4A FML elevation is 5555 14 amsl and with the addition of the 1 0 foot of solution the solution elevation is 5556 14 feet amsl For Cell 4B the FML elevation is 5557 50 amsl and with the addition of the 1 0 foot of solution the solution elevation is 5558 50 feet amsl) If any of these observations are made the Mill Manager should be notified immediately and the leak detection system pump started In addition the requirement to notify the Executive Secretary in accordance with Parts ID 6 and IG 3 of the Groundwater Discharge Permit must be adhered to when the solution level trigger for Cell 4A or 4B has been exceeded Whenever the leak detection system pump is operating and the flow meter totalizer is recording a notation of the date and the time will be recorded on the Daily Inspection Data form This data will be used in accordance with License Condition 11 3 B through 11 3 E of the Mill s Radioactive Materials License to determine whether or not the flow rate into the leak detection system is in excess N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denison 11 4 Book 11 Environmental Protection Manual Section 3 1 Page 6 of 53 of the License Conditions Items (a) (m) (n) and (o) are to be done only when the Mill is operating When the Mill is down these Items cannot be performed 2 2 Dailv Operations Inspection Dunng Mill operation the Shift Foreman or other person with the training specified in Section 2 4 below designated by the Radiation Safety Officer will perform an inspection of the tailings line and tailings area at least once per shift paying close attention for potentisd leaks and to the discharges from the pipelines Observations by the Inspector will be recorded on the appropriate line on the Operating Foreman s Daily Inspection form 2 3 Dailv Operations Patrol In addition to the inspections described in Sections 2 1 and 2 2 above a Mill employee will patrol the tailings area at least twice per shift during Mill operations to ensure that there are no obvious safety or operational issues such as leaking pipes or unusual wildlife activity or incidences No record of these patrols need be made but the inspectors will notify the RSO and/or Mill management in the event that during their inspection they discover that an abnormal condition or tailings emergency has occuned 2 4 Training All individuals performing inspections described in Sections 2 1 and 2 2 above must have Tailings Management System training as set out m the Tailings Inspection Training procedure which is attached as Appendix B This training will include a training pack explaining the procedure for performing the inspection and addressing inspection items to be observed In addition each individual after reviewing the training pack will sign a certification form indicating that training has been received relative to his/her duties as an inspector 2 5 Tailings Emergencies Inspectors will notify the RSO and/or Mill management immediately if dunng their inspection they discover that an abnormal condition exists or an event has occuned that could cause a tailings emergency Until relieved by the Environmental or Technician or RSO inspectors will have the authority to direct resources during tailings emergencies Any major catastrophic events or conditions pertaining to the tailmgs area should be reported immediately to the Mill Manager or the RSO one of whom will notify Corporate Management If N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 7 of 53 dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSHA (303 231 5465) and the State of Utah Division of Dam Safety (801 538 7200) 3 WEEKLY TAILINGS AND DMT INSPECTION 3 1 Weeklv Tailings Inspections Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the following a) Leak Detection Systems Each tailings cell s leak detection system shall be checked weekly (as well as daily) to determine whether it is wet or dry If marked wet the liquid levels need to be measured and reported In Cell 1 and Cell 3 the leak detection system is measured by use of a dual probe system that senses the presence of solutions in the LDS system (comparable to the systems m Cells 4A and 4B) and indicates the presence of solution with a warning light The Cell 4A and 4B leak detection systems are monitored on a continuous basis by use of a pressure transducer that feeds water level information to an electronic data collector The pressure transducer is calibrated for fluid with a specific gravity of 1 0 The water levels are measured every hour and the information is stored for later retrieval The water levels are measured to the nearest 0 10 inch The data collector is cunently programmed to store 7 days of water level information The number of days of stored data can be increased beyond 7 days if needed For Cells 1 and 3 the water level data is recorded on the Daily Tailings Inspection Form For Cells 4A and 4B the water level data is downloaded to a laptop computer periodically and incorporated into the Mill s environmental monitoring data storage and into the files for weekly inspection reports of the tailings cell leak detection systems If sufficient fluid is present in the leak detection system of any cell the fluid shall be pumped from the LDS to the extent reasonably possible and record the volume of fluid recovered Any fluid pumped from an LDS shall be retumed to a disposal cell For Cells 1 and 3 if fluid is pumped from an LDS the flow rate shall be calculated by dividing the recorded volume of fluid recovered by the elapsed time since fluid was last pumped or increases in the LDS fluid levels were recorded whichever is the more recent This calculation shall be documented as part of the weekly inspection N \DMT PlanVDMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu-onmental Protection Manual SecUon 3 1 Page 8 of 53 For Cells 1 and 3 upon the initial pumping of fluid from an LDS a fluid sample shall be collected and analyzed m accordance with paragraph 11 3 C of the Radioactive Matenals License For Cell 4A and 4B under no circumstance shall fluid head in the leak detection system sump exceed a 1 foot level above the lowest point in the lower flexible membrane liner To determine the Maximum Allowable Daily LDS Flow Rates in the Cell 4A and 4B leak detection systems the total volume of all fluids pumped from the LDS on a weekly basis shall be recovered from the data collector and that information will be used to calculate an average volume pumped per day Under no circumstances shall the daily LDS flow volume exceed 24 160 gallons/day for Cell 4A or 26 145 gallons/day for Cell 4B The maximum daily LDS flow volume will be compared against the measured cell solution levels detailed on Table 1A and IB (for Cells 4A and 4B respectively) m Appendix E to determine the maximum daily allowable LDS flow volume for varying head conditions in Cell 4A and 4B b) Slimes Drain Water Level Monitoring (i) Cell 3 IS nearly full and will commence closure when filled Cell 2 is partially reclaimed with the surface covered by platform fill Each cell has a shmes drain system which aids in dewatering the shmes and sands placed m the cell (ll) Denison re graded the interim fill on Cell 2 in order to reduce the potential for the accumulation of stormwater on the surface of Cell 2 As a result of the re grading of the interim cover and the placement of an additional 62 000 cubic yards of fill material on Cell 2 the shmes drain access pipe was extended 6 97 feet The extension pipe is 6 97 feet in length and therefore the new measuring point is 37 97 feet from the bottom of the shmes dram The measuring point on the extension pipe was surveyed by a Utah Certified Land Surveyor For the quarterly recovery test descnbed in section vi below this extension has no effect on the data measurement procedures Cell 2 has a pump placed inside of the shmes dram access pipe at the bottom of the shmes dram As taken from actual measurements the bottom of the shmes drain is 37 97 feet below a water level measunng point which is a notch on the side of the Cell 2 shmes drain access pipe This means that the bottom of the slimes drain pool and the location of the pump are one foot above the lowest point of the FML in Cell 2 which based on constmction reports is at a depth of 38 97 feet below the water level measuring point on the slimes drain access pipe for Cell 2 (ill) The shmes drain pump in Cell 2 is activated and deactivated by a float mechanism and water level probe system When the water level reaches the level of N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailmgs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 9 of 53 the float mechanism the pump is activated Pumping then occurs until the water level reaches the lower probe which tums the pump off The lower probe is located one foot above the bottom of the slimes drain standpipe and the float valve is located at three feet above the bottom of the slimes drain standpipe The average wastewater head in the Cell 2 shmes drain is therefore less than 3 feet and is below the phreatic surface of tailmgs Cell 2 about 27 feet below the water level measuring point on the shmes drain access pipe As a result there is a continuous flow of wastewater from Cell 2 mto the shmes drain collection system Mill management considers that the average allowable wastewater head in the Cell 2 shmes drain resulting from pumping in this manner is satisfactory and is as low as reasonably achievable (iv) The Cell 2 shmes drain pump is checked weekly to observe that it is operating and that the water level probe and float mechanism are working properly which is noted on the Weekly Tailmgs Inspection Form If at any time the pump is observed to be not working properly it will be fixed or replaced withm 15 days (v) Depth to wastewater in the Cell 2 shmes drain access pipe shall be monitored and recorded weekly to determine maximum and nunimum fluid head before and after a pumping cycle respectively The extension of the Cell 2 shmes drain access pipe did not require any changes to the measurement procedure The surveyed measuring point on the extended pipe is used as required The head measurements are calculated in the same manner using the same procedures as those used prior to the extension of the Cell 2 slimes dram access pipe however the total depth to the bottom ofthe pipe is now 37 97 feet as noted on the conected form in Attachment A All head measurements must be made from the same measuring point (the notch at the north side of the access pipe) and made to the nearest 0 01 foot The results will be recorded as depth in pipe measurements on the Weekly Tailings Inspection Form The extension of the Cell 2 shmes access pipe has not changed the method of calculation of the pre and post pump head calculations only the constant (Cell 2 shmes drain access pipe height) used in the calculation has changed The head is calculated by subtracting the depth to liquid fi"om 37 97 feet rather than from the previous measurement of 38 feet The weekly Tailings Inspection form included in Attachment A has been changed to reflect the extension height (vi) Effective July 11 2011 on a quarterly basis the shmes drain pump will be tumed off and the wastewater in the shmes drain access pipe will be allowed to stabilize for at least 90 hours Once the water level has stabilized (based on no change in water level for three (3) successive readings taken no less than one (1) hour apart) the water level ofthe wastewater will be measured and recorded as a depth in pipe measurement on Quarterly Data form by measuring the depth to water below the water level measuring point on the slimes drain access pipe (vn) No process liquids shall be allowed to be discharged into Cell 2 (vill) If at any time the most recent average annual head in the Cell 2 shmes drain is found to have increased above the average head for the previous calendar year the Licensee will comply with the requirements of Part IG 3 of the GWDP including the N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailmgs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 10 of 53 requirement to provide notification to the Executive Secretary orally within 24 hours followed by written notification (ix)Because Cell 3 and Cell 4A are cunently active no pumping from the Cell 3 or Cell 4A shmes drain is authorized No pumping from the Cell 4B slimes drain will be authorized once it is put into service and while it is active Prior to initiation of tailings dewatering operations for Cell 3 Cell 4A or Cell 4B a similar procedure will be developed for ensuring that average head elevations in the Cell 3 and Cell 4A slimes drains are kept as low as reasonably achievable and that the Cell 3 Cell 4A and Cell 4 slimes drains are inspected and the results reported in accordance with the requirements of the permit c) Wind Movement of Tailings An evaluation of wind movement of tailings or dusting and control measures shall be taken if needed d) Tailings Wastewater Pool Elevation Monitoring Solution elevation measurements m Cells 1 4A and 4B and Roberts Pond are to be taken by survey on a weekly basis The beach area in Cell 4B with the maximum elevation is to be taken by survey on a monthly basis when beaches are first observed as follows (i) The survey will be performed by the Mill s Radiation Safety Officer or designee (the Surveyor ) with the assistance of another Mill worker (the Assistant ) (ll) The survey will be perfonned using a survey instmment (the Survey Instmment ) accurate to 0 01 feet such as a Sokkai No B21 or equivalent together with a survey rod (the Survey Rod ) having a visible scale in 0 01 foot increments (iii)The Reference Points for Cells 1 Cell 4A and 4B and Roberts Pond are known points established by professional survey For Cell 1 and Roberts Pond the Reference Point is a wooden stake with a metal disk on it located on the southeast comer of Cell 1 The elevation of the metal disk (the Reference Point Elevation ) for Cell 1 and Roberts Pond is at 5 623 14 feet above mean sea level ( FMSL ) For Cell 4A and 4B the Reference Point is a piece of stamped metal monument located next to the transformer on the south side of Cell 4A and 4B The elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A and 4B) is 5600 49 fmsl The Surveyor will set up the Survey Instmment in a location where both the applicable Reference Point and pond surface are visible For Cell 1 and Roberts Pond this is typically on the road on the Cell 1 south dike between Cell 1 and Roberts Pond approximately 100 feet east of the Cell 1/Roberts Pond Reference Point For Cell 4A and Cell 4B this is typically on the south side of Cell 4A and 4B N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 11 of 53 (iv) Once in location the Surveyor will ensure that the Survey Instmment is level by centering the bubble in the level gauge on the Survey Instmment (v) The Assistant will place the Survey Rod vertically on the Reference Point (on the metal disk on the Cell 1/Roberts Pond Reference Point on the top of the rebar on the Cell 4A and 4B Reference Point The Assistant will ensure that the Survey Rod IS vertical by gently rocking the rod back and forth until the Surveyor has established a level reading (vi) The Surveyor will focus the cross hairs of the Survey Instmment on the scale on the Survey Rod and record the number (the Reference Point Reading ) which represents the number of feet the Survey Instmment is reading above the Reference Point (vii) The Assistant will then move to a designated location where the Survey Rod can be placed on the surface of the main solution pond in the Cell 1 Cell 4A Cell 4B or Roberts Pond or the area of the beach in Cell 4B with the highest elevation as the case may be These designated locations and the methods to be used by the Assistant to consistently use the same locations are as follows For a newly constmcted cell when the cell is first placed into operation the solution level is typically zero feet above the FML or a nunimal elevation above the FML due to natural precipitation For newly constmcted cells measurement of solution level will commence within 30 days of authorization for use Measurements will be conducted consistent with the procedures in this DMT Plan and consistent with cunent Mill health and safety procedures The measurements will be completed using survey equipment and the appropriate length survey rod (either 25 or 45 ) A Pond Surface Measurements I Cell 4A The Assistant will walk down the slope in the northeast comer of Cell 4A and place the Survey Rod at the liquid level n Cell 4B The Assistant will walk down the slope in the southeast comer of Cell 4B and place the Survey Rod at the liquid level m Cell 1 A mark has been painted on the north side of the ramp going to the pump platform in Cell 1 The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface and N \DMT PIan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonl 1 4 Page 12 of 53 IV Roberts Pond A mark has been painted on the railing of the pump stand in Roberts Pond The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface Based on the foregoing methods the approximate coordinate locations for the measuring points for Roberts Pond and the Cells are Northing Easting Roberts Pond 323 041 2 579 697 Cell 1 322 196 2 579 277 Cell 4A 320 300 2 579 360 Cell 4B 320 690 2 576 200 These coordinate locations may vary somewhat depending on solution elevations in the Pond and Cells B Cell 4B Beach Elevation Beach elevations in Cell 4B will commence when beaches are first observed The Assistant will place the Survey Rod at the point on the beach area of Cell 4B that has the highest elevation If it is not clear which area of the beach has the highest elevation then multiple points on the beach area will be surveyed until the Surveyor is satisfied that the point on the Cell 4B beach area with the highest elevation has been surveyed If it is clear that all points on the Cell 4B beach area are below 5 593 FMSL then the Surveyor may rely on one survey point (vill) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod just touching the pond surface The Assistant will ensure that the Survey Rod IS vertical by gently rocking the rod back and forth until the Surveyor has established a level reading (ix)The Surveyor will focus the cross hairs of the Survey Instmment on the scale on the Survey Rod and record the number (the Pond Surface Reading ) which represents the number of feet the Survey Instmment is reading above the pond surface level The Surveyor will calculate the elevation of the pond surface as FSML by adding the Reference Point Reading for the Cell or Roberts Pond as the case may be to the Reference Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for the Cell or Roberts Pond and will record the number accurate to 0 01 feet N \DMT PlanXDMT Plan 01 30 12 Revision 11 4\Taibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 13 of 53 e) Decontamination Pads (i) New Decontamination Pad The New Decontamination Pad is located m the southeast comer of the ore pad near the Mill s scale house A In order to ensure that the primary containment of the New Decontamination Pad water collection system has not been compronused and to provide an inspection capability to detect leakage from the pnmary containment vertical inspection portals have been installed between the pnmary and secondary containments B These portals will be visually observed on a weekly basis as a means of detecting any leakage from the primary containment into the void between the pnmary and secondary containment The depth to water in each portal will be measured weekly by physically measunng the depth to water with an electrical sounding tape/device All measurements must be made from the same measuring point and be made to the nearest 0 01 foot C These inspections will be recorded on the Weekly Tailings Inspection form D The water level shall not exceed 0 10 foot above the concrete floor in any standpipe at any time This will be determined by subtracting the weekly depth to water measurement from the distance from the measuring point in the standpipe to the dry concrete floor The depth to water from the top (elevation 5589 8 feet amsl) of any of the three (3) observation ports to the standing water shall be no less than 6 2 feet Depths less than 6 2 feet shall indicate more that 0 1 foot of standing water above the concrete floor (elev 5583 5 feet amsl) and shall indicate a leak in the primary containment E Any observation of fluid between the primary and secondary containments will be reported to the Radiation Safety Officer (RSO) F In addition to inspection of the water levels in the standpipes the New Decontamination Pad including the concrete integrity of the exposed surfaces of the pad will be inspected on a weekly basis Any soil and debris will be removed from the New Decontaimnation Pad N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 14 of 53 immediately prior to inspection of the concrete wash pad for cracking Observations will be made of the cunent condition of the New Decontamination Pad Any abnormalities relating to the pad and any damage to the concrete wash surface of the pad will be noted on the Weekly Tailings Inspection form If there are any cracks greater than 1/8 inch separation (width) the RSO must be contacted The RSO will have the responsibility to cease activities and have the cracks repaired (ll) Existing Decontamination Pad The Existing Decontamination Pad is located between the northwest comer of the Mill s maintenance shop and the ore feeding grizzly A The Existing Decontaimnation Pad will be inspected on a weekly basis Any soil and debris will be removed from the Existing Decontanunation Pad immediately prior to inspection of the concrete wash pad for cracking Observations will be made of the cunent condition of the Existing Decontamination Pad including the concrete integrity of the exposed surfaces of the pad Any abnormalities relating to the pad and any damage or cracks on the concrete wash surface of the pad will be noted on the Weekly Tailmgs Inspection form If there are any cracks greater than 1/8 inch separation (width) the RSO must be contacted The RSO will have the responsibility to cease activities and have the cracks repaired /) Summary In addition the weekly inspection should summarize all activities conceming the tailings area for that particular week Results ofthe weekly tailmgs inspection are recorded on the Weekly Tailings and DMT Inspection form An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A 3 2 Weeklv Inspection of Solution Levels m Roberts Pond On a weekly basis solution elevations are taken on Roberts Pond in accordance with the procedures set out in Section 3 1 d) above The Weekly solution level in Roberts Pond is recorded on the Weekly Tailings and DMT Inspection form Based on historical observations the FML at the Pond Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the pond s FML If the pond solution elevation at the Pond Surface Reading area is at or below the FML N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 15 of 53 for that area the pond will be recorded as being dry 3 3 Weeklv Feedstock Storage Area Inspections Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to confirm that a) the bulk feedstock materials are stored and maintained within the defined area descnbed in the GWDP as indicated on the map attached hereto as Appendix D b) a 4 ft buffer is mainteuned at the periphery of the storage area which is absent bulk material in order to assure that the materials do not encroach upon the boundary of the storage area and c) all altemate feedstock located outside the defined Feedstock Area are maintained within water tight containers The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection Report a copy of which is contained in Appendix A Any variance in stored matenals from this requirement or observed leaking altemate feedstock dmms or other containers will be brought to the attention of Mill Management and rectified within 15 days 4 MONTHLY TAILINGS INSPECTION Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from the Radiation Safety Department and recorded on the Monthly Inspection Data form an example of which IS contained in Appendix A Monthly inspections are to be performed no sooner than 14 days since the last monthly tailings inspection and can be conducted concunently with the quarterly tailmgs inspection when applicable The following items are to be inspected a) Tailings Slurry Pipeline When the Mill is operating the slurry pipeline will be visually inspected at key locations to determine pipe wear The cntical points of the pipe include bends slope changes valves and junctions which are cntical to dike stability These locations to be monitored will be detemuned by the Radiation Safety Officer or his designee from the Radiation Safety Department during the Mill mn b) Diversion Ditches Diversion ditches 1 2 and 3 shall be monitored monthly for sloughing erosion undesirable vegetation and obstmction of flow Diversion berm 2 should be checked N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailmgs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 16 of 53 for stability and signs of distress c) Sedimentation Pond Activities around the Mill and facilities area sedimentation pond shall be summanzed for the month d) Overspray Dust Minimization The inspection shall mclude an evaluation of overspray minimization if applicable This entails ensuring that the overspray system is functioning properly In the event that overspray is earned more than 50 feet from the cell the overspray system should be immediately shut off e) Remarks A section is included on the Monthly Inspection Data form for remarks in which recommendations can be made or observations of concem can be documented f) Summary of Daily Weekly and Quarterly Inspections The monthly inspection will also summanze the daily weekly and if applicable quarterly tailings inspections for the specific month In addition settlement monitors are typically surveyed monthly and the results reported on the Monthly Inspection Data form 5 QUARTERLY TAILINGS INSPECTION The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from the Radiation Safety Department having the training specified m Section 2 4 above once per calendar quarter A quarterly inspection should be performed no sooner than 45 days since the previous quarterly inspection was performed Each quarterly inspection shall include an Embankment Inspection an Operations/Maintenance Review a Constmction Review and a Summary as follows a) Embankment Inspection The Embankment inspection involves a visual inspection of the crest slope and toe of each dike for movement seepage severe erosion subsidence shrinkage cracks and exposed Imer N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 17 of 53 b) Operations/Maintenance Review The Operations/Maintenance Review consists of reviewing Operations and Maintenance activities pertaining to the tailmgs area on a quarterly basis c) Construction Review The Constmction Review consists of reviewing any constmction changes or modifications made to the tailings area on a quarterly basis d) An estimate of the percentage of the tailmgs beach surface area and solution pool area is made including estimates of solutions cover areas and tailmgs sands for Cells 3 4Aand4B e) Summary The summary will include all major activities or observations noted around the tailmgs area on a quarterly basis If any of these conditions are noted the conditions and conective measures taken should be documented m the Quarterly Inspection Data form An example of the Quarterly Inspection Data form IS provided in Appendix A 6 ANNUAL EVALUATIONS The following annual evaluations shall be performed 6 1 Annual Technical Evaluation An annual technical evaluation of the tailings management system is performed by a registered professional engineer (PE) who has experience and training m the area of geotechnical aspects of retention stmctures The technical evaluation includes an on site inspection of the tailings management system and a thorough review of all tailings records for the past year The Technical Evaluation also includes a review and summary of the annual movement monitor survey (see Section 5 2 below) All tailings cells and conesponding dikes will be inspected for signs of erosion subsidence shnnkage and seepage The drainage ditches will be inspected to evaluate surface water control stmctures In the event tailings capacity evaluations (as per SOP PBL 3) were performed for the receipt of altemate feed material during the year the capacity evaluation forms and associated calculation N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 18 of 53 sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate The amount of tailings added to the system since the last evaluation will also be calculated to determine the estimated capacity at the time of the evaluation Tailings inspection records will consist of daily weekly monthly and quarterly tailings inspections These inspection records will be evaluated to determine if any freeboard limits are being approached Records will also be reviewed to summarize observations of potential concern The evaluation also involves discussion with the Environmental and/or Radiation Technician and the Radiation Safety Officer regarding activities around the tailings area for the past year During the annual inspection photographs of the tailings area will be taken The training of individuals will be reviewed as a part of the Annual Technical Evaluation The registered engineer will obtain copies of selected tailings inspections along with the monthly and quarterly summaries of observations of concem and the conective actions taken These copies will then be included in the Annual Technical Evaluation Report The Annual Technical Evaluation Report must be submitted by November 15'** of every year to the Executive Secretary 6 2 Movement Monitors A movement monitor survey is to be conducted by a licensed surveyor annually during the second quarter of each year The movement monitor survey consists of surveying momtors along dikes 3 S 4A W and 4A S to detect any possible settlement or movement of the dikes The data generated from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the tailings management system 6 3 Freeboard Limits The freeboard limits set out in this Section are intended to capture the Local 6 hour Probable Maximum Precipitation (PMP) event which was detemuned in the January 10 1990 Drainage Report (the Drainage Report ) for the White Mesa site to be 10 inches The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas was calculated in the Drainage Report to be 103 acre feet of water with a wave mn up factor of 0 90 feet The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas plus the adjacent drainage areas was calculated in the Drainage Report to be 123 4 acre feet of water The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage Report to be 36 acre feet of water (40 acres plus the adjacent drainage area of 3 25 acres) times N \DMT PlanNDMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 19 of 53 the PMP of 10 inches) with a wave mn up factor of 0 77 feet The flood volume from the PMP event over the Cell 4B area has been calculated to be 38 1 acre feet of water (40 acres plus the adjacent drainage area of 5 72 acres) times the PMP of 10 inches with a wave mn up factor of 0 77 feet The total pool surface area in Cell 1 is 52 9 acres in Cell 4A is 40 acres and in Cell 4B is 40 acres The top of the flexible membrane liner ( FML ) for Cell 1 is 5 618 2 FMSL for Cell 4A is 5 598 5 FMSL and for Cell 4B is 5600 4 FMSL Based on the foregoing the freeboard Imuts for the Mill s tailings cells will be set as follows 63 1 Cell 1 The freeboard limit for Cell 1 will be set at 5 615 4 FMSL This will allow Cell 1 to capture all of the PMP volume associated with Cell 1 The total volume requirement for Cell 1 is 103 acre feet divided by 52 9 acres equals 1 95 feet plus the wave mn up factor of0 90 feet equals 2 85 feet The freeboard linut is then 5 618 2 FMSL minus 2 85 feet equals 5 615 4 FMSL Under Radioactive Matenals License condition 10 3 this freeboard limit is set and is not recalculated annually 632 Cell 2 The freeboard Imut for Cell 2 is inapplicable since Cell 2 is filled with solids All of the PMP volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells) 63 3 Cell 3 The freeboard limit for Cell 3 is inapplicable since Cell 3 is close to being filled with solids and all of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future tailings cells) 634 Cell 4A The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with Cell 4A will be attributed to Cell 4B A spillway has been added to Cell 4A to allow overflow into Cell 4B 635 Cell 4B The freeboard limit for Cell 4B will be set assuming that the total PMP volume for Cells 2 3 4A and 4B of 159 4 acre feet will be accommodated in Cell 4B The procedure for calculating the freeboard limit for Cell 4B is as follows (a) When the Pool Surface Area is 40 Acres N \DMT Plan\DMT Plan 01 30 12 Revision 11 4\Taibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 20 of 53 When the pool surface area in Cell 4B is 40 acres (i e when there are no beaches) the freeboard linut for Cell 4B will be 5 594 6FMSL which is 5 7 feet below the FML This freeboard value was developed as follows PMP Flood Volume 38 1 acre feet Overflow from Cell 4A assuming no storage m Cell 3 or 4A 159 4 acre feet Sum of PMP volume and overflow volume 197 5 acre feet Depth to store PMP an overflow volume = 197 5 acre feet/40 acres 4 9 feet Wave mn up factor 0 77 feet Total required freeboard 5 7 feet (all values in the above calculation have been rounded to the nearest one tenth of afoot) (b) When the Maximum Elevation ofthe Beach Area is 5 594 FMSL or Less When the maximum elevation of the beach area in Cell 4B is 5594 FMSL or less then the freeboard limit will be 5 594 6 FMSL which is the same as m (a) above This allows for the situation where there may be beaches but these beaches are at a lower elevation than the freeboard limit established in (a) above and there is therefore ample freeboard above the beaches to hold the maximum PMP volume The maximum elevation of the beach area will be determined by monthly surveys performed by Mill personnel in accordance with the Mill s DMT Plan (c) When the Maximum Elevation of the Beach Area First Exceeds 5 594 FMSL When the maximum elevation of the beach area in Cell 4B first exceeds 5 594 FMSL then the freeboard limit for the remainder of the ensuing year (period t=0) (until the next November 1) will be calculated when that elevation is first exceeded (the Initial Calculation Date ) as follows i) The total number of dry tons of tailings that have historically been deposited into Cell 4B pnor to the Initial Calculation Date ( To ) will be determined II) The expected number of dry tons to be deposited into Cell 4B for the remainder of the ensuing year (up to the next November 1) based on production estimates for that period ( Ao* ) will be detemuned III) Ao* will be grossed up by a safety factor of 150% to allow for a potential underestimation of the number of tons that will be deposited m the cell during the remainder of the ensuing year This grossed up number can be refened to as the modeled tonnage for the period IV) The total design tailings solid storage capacity of Cell 4B will be accepted as 2 094 000 dry tons of tailings v) The available remaining space in Cell 4B for solids as at the Initial Calculation Date will be calculated as 2 094 000 dry tons minus To VI) The reduction in the pool surface area for the remainder of the ensuing year will be assumed to be directly proportional to the reduction in the available space in Cell 4B N VDMT Plan\DMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 21 of 53 for solids That is the reduced pool surface area for period t=0 ( RPAo ) after the reduction will be calculated to be (1 - (Ao* X 1 5) / (2 094 000 To)) x 40 acres = RPAo vn) The required freeboard for Cell 4B for the remainder of the period t=0 can be calculated in feet to be the wave mn up factor for Cell 4B of 0 77 feet plus the quotient of 197 5 acre feet divided by the RPAo The freeboard Imut for Cell 4B for the remainder of period t=0 would then be the elevation of the FML for Cell 4B of 5594 0 FMSL less this required freeboard amount rounded to the nearest one tenth of afoot and VIII) The foregoing calculations will be performed at the Initial Calculation Date and the resulting freeboard linut will persist until the next November 1 An example of this calculation is set out m Appendix F (d) Annual Freeboard Calculation When the Maximum Elevation ofthe Beach Area Exceeds 5 594 FMSL On November 1 of each year (the Annual Calculation Date ) the reduction in pool area for the ensuing year (refened to as period t) will be calculated by i) First calculating the Adjusted Reduced Pool Area for the previous period (ARPAt i) to reflect actual tonnages deposited in Cell 4B for the previous period (period t 1) The RPAt 1 used for the previous period was based on expected tonnages for penod t 1 grossed up by a safety factor The ARP At i is merely the RPA that would have been used for period t 1 had the actual tonnages for year t 1 been known at the outset of period t 1 and had the RPA been calculated based on the actual tonnages for penod t 1 This allows the freeboard calculations to be conected each year to take into account actual tonnages deposited m the cell as of the date of the calculation The ARP At 1 can be calculated using the following formula (1 - At 1 / (2 094 000 - Tt i)) X ARPAt 2 = ARPAt 1 Where • At 1 IS the actual number of dry tons of tailings solids deposited in Cell 4B dunng period t 1 • Tt 1 IS the actual number of dry tons of tailings solids historically deposited in Cell 4B pnor to the beginning of penod t 1 and • ARPAt 2 IS the Adjusted Reduced Pool Area for penod t 2 If period t 2 started at the Initial Calculation Date then ARPAt 2 is 40 acres 11) Once the ARPAt 1 for the previous penod (period t 1) has been calculated the RPA for the subject period (period t) can be calculated as follows (1 - (At* X 1 5) / (2 094 000 Tt)) x ARPAt 1 = RPAt N VDMT PlanVDMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu-onmental Protection Manual Section 3 1 Page 22 of 53 Where • At* IS the expected number of dry tons of tailings to be deposited into Cell 4B for the ensuing year (period t) based on production estimates for the year (as can be seen from the foregoing formula this expected number is grossed up by a safety factor of 1 5) • Tt is the actual number of dry tons of tailings solids historically deposited in Cell 4B prior to the beginning of penod t and • ARPAt 1 IS the Adjusted Reduced Pool Area for period t 1 which is the pool surface area for the previous period (penod t 1) that should have applied during that penod had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period III) The required freeboard for penod t can be calculated in feet to be the wave mn up factor for Cell 4B of 0 77 feet plus the quotient of 197 5 acre feet divided by the RPAt The freeboard limit for Cell 4B for period t would then be the elevation of the FML for Cell 4B of 5594 0 FMSL less this required freeboard amount rounded to the nearest one tenth of a foot and iv) The foregoing calculations will be performed at the Annual Calculation Date for period t and the resulting freeboard linut will persist until the next Annual Calculation Date for period t+1 An example of this calculation is set out in Appendix F (e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell When a spillway is added between Cell 4B and a new tailings cell then if an approved freeboard limit calculation method for the new cell is set to cover the entire PMP event for Cells 2 3 4A 4B and the new tailings cell the freeboard linut for Cell 4B will be inapplicable except for approved provisions to prevent storm water mnoff from overtopping dikes 6 3 6 Roberts Pond The freeboard limit for Roberts Pond is a liquid maximum elevation of 5 624 0 feet above mean sea level as specified m the GWDP 6 4 Annual Leak Detection Fluid Samples In the event solution has been detected in a leak detection system a sample will be collected on an annual basis This sample will be analyzed according to the conditions set forth in License Condition 11 3 C The results of the analysis will be reviewed to detemune the origin of the solution N \DMT PlanNDMT Plan 01 30 12 Revision 11 4\Tailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 23 of 53 6 5 Annual Inspection of the Decontamination Pads a) New Decontamination Pad During the second quarter of each year the New Decontamination Pad will be taken out of service and inspected to ensure the integrity of the wash pad s exposed concrete surface If any abnormalities are identified i e cracks in the concrete with greater than 1/8 inch separation (width) or any significant deterioration or damage of the pad surface repairs will be made pnor to resunung the use of the facility All inspection findings and any repairs required shall be documented on the Annual Decontanunation Pad Inspection form The inspection findings any repairs required and repairs completed shall be sununanzed in the 2"^ Quarter DMT Monitoring Report due September 1 of each calendar year b) Existing Decontanunation Pad During the second quarter of each year the Existing Decontanunation Pad will be taken out of service and inspected to ensure the integrity of the steel tank Once the water and any sediment present is removed from the steel tank containment the walls and bottom of the tank will be visually inspected for any areas of damage cracks or bubbling indicating conosion that may have occuned since the last mspection If any abnormalities are identified defects or damage will be reported to Mill management and repairs will be made prior to resunung the use of the facility All inspection findings and any repairs required shall be documented on the Annual Decontamination Pad Inspection form A record of the repairs will be maintained as a part of the Annual Inspection records at the Mill site The inspection findings any repairs required and repairs completed shall be summarized in the 2nd Quarter DMT Monitonng Report due September 1 of each calendar year 7 OTHER INSPECTIONS All daily weekly monthly quarterly and annual inspections and evaluations should be performed as specified m Sections 2 3 4 5 and 6 above However additional inspections should be conducted after any significant storm or significant natural or man made event occurs 8 REPORTING REQUIREMENTS In addition to the Daily Inspection Data Weekly Tailings Inspection Monthly Inspection Data and Quarterly Inspection Data forms included as Appendix A and described in Sections 2 3 4 and 5 respectively and the Operating Foreman s Daily Inspection and Weekly Mill Inspection forms described m Sections 2 and 3 respectively the following additional reports shall also be prepared 8 1 Monthlv Tailings Reports Monthly tailings reports are prepared every month and summarize the previous month s activities N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 24 of 53 around the tailings area If not prepared by the Radiation Safety Officer the report shall be submitted to the Radiation Safety Officer for review The Mill Manager will review the report as well before the report is filed m the Mill Central File The report will contain a summary of observations of concern noted on the daily and weekly tailings inspections Conective measures taken during the month will be documented along with the observations where appropriate All daily and weekly tailings inspection forms will be attached to the report A monthly inspection form will also be attached Quarterly inspection forms will accompany the report when applicable The report will be signed and dated by the preparer m addition to the Radiation Safety Officer and the Mill Manager 82 DMT Reports Quarterly reports of DMT monitonng activities which will include the following information will be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP a) On a quarterly basis all required information required by Part 1 F 2 of the GWDP relating to the inspections described in Section 3 1(b) (Shmes Dram Water Level Monitonng) 3 1(d) (Tailings Wastewater Pool and Beach Area Elevation Monitoring) 3 2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3 3 (Weekly Feedstock Storage Area Inspections) b) On a quarterly basis a summary of the weekly water level (depth) inspections for the quarter for the presence of fluid in all three vertical inspection portals for each of the three chambers in the concrete settling tank system for the New Decontanunation Pad which will include a table indicating the water level measurements in each portal dunng the quarter c) With respect to the annual inspection of the New Decontamination Pad descnbed m Section 6 5(a) the inspection findings any repairs required and repairs completed shall be summarized in the 2"^ Quarter report due September 1 of each calendar year d) With respect to the annual inspection of the Existing Decontanunation Pad described in Section 6 5(b) the inspection findings any repairs required and repairs completed shall be summarized in the 2"** Quarter report due September 1 of each calendar year and e) An annual summary and graph for each calendar year of the depth to wastewater in the Cell 2 shmes dram must be included in the fourth quarter report After the first year and beginning in 2008 quarterly reports shall include both the cunent year monthly values and a graphic comparison to the previous year N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 25 of 53 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 26 of 53 APPENDIX A FORMS N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 27 of 53 APPENDIX A (CONT) DAILY INSPECTION DATA Inspector Date Accompanied by Time Any Item not OK must be documented A check mark = OK X = Action Required I TAILINGS SLURRY TRANSPORT SYSTEM Inspection Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B Slurry Pipehne Leaks Damage Blockage Sharp Bends Pipeline Joints Leaks Loose Connections Pipebne Supports Damage Loss of Support Valves Leaks Blocked Closed Point(s) of Discharge Improper Location or Onentation II OPERATIONAL SYSTEMS Inspection Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B Water Level Greater Than Operating Level Large Change Since Previous Inspection Beach Cracks Severe Erosion Subsidence Liner and Cover Erosion of cover Exposure of Liner Lmer Observable Liner Damage N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaihngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Envu-onmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 28 of 53 III DIKES AND EMBANKMENTS Inspection Items Conditions of Potential Dike 1 I Dike 1 Dike 2 Dike 3 Dike Dike Dike Concem lA 4AS 4AE 4B S Slopes Sloughs or Sliding Cracks No No No No Bulges Subsidence Severe visible visible visible visible Erosion Moist Areas Areas slope or slope or slope or slope or of Seepage Outbreak dike to dike to dike to dike to inspect inspect inspect inspect Crest Cracks Subsidence Severe No No No No Erosion visible visible visible visible slope or slope or slope or slope or dike to dike to dike to dike to inspect inspect inspect inspect IV FLOW RATES Slurry Line(s) Pond Retum S X Tails Sprav Svstem GPM V PHYSICAL INSPECTION OF SLURRY LINES(S) Walked to Discharge Point Observed Entire Discharge Line Yes Yes _No No VI DUST CONTROL Cell 2 Cell 3 Cell 4A Cell 4B Dusting Wind Movement of Tailings Precipitation inches liquid N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaihngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonl 1 4 Page 29 of 53 General Meteorological conditions Vn DAILY LEAK DETECTION CHECK Celll Cell 2 Cell 3 Cell 4A Cell 4B Leak Detection System Checked Checked Checked Checked Checked Checked Leak Detection System Checked Wet Drv Wet Drv Wet Drv Wet Drv Wet Drv Leak Detection System Checked Initial level Initial level Initial level Initial level Initial level Leak Detection System Checked Final level Final level Final level Final level Final level Leak Detection System Checked Gal pumped Gal pumped Gal pumped Gal pumped Gal pumped Vni OBSERVATIONS OF POTENTIAL CONCERN Action Required N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc Tailings Daily Inspection Repoit Tailmgs Sluny Dischaige Location 7-H (4-1 C O S o O 03 CELL NO 1 Dike 11 MILL SITE > ts t f c c« 2 O 1 2 2 ^3 c B D ^ PQ CELL NO 2 Filled CELL NO 4B CELL NO 4A / Date Inspectoi / .0^ N White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu-onmental Protection Manual Section 3 1 Page 31 of 53 APPENDIX A (CONT) DENISON MINES (USA) CORP WEEKLY TAILINGS INSPECTION Date Inspectors 1 Pond and Beach Cell 1 (a) Pond Solution Elevation elevations (msl ft) (b) FML Bottom Elevation 5597. (c) Depth of Water above FML ((a) (b)) Cell4A (a)Pond Solution Elevation (b) FML Bottom Elevation 5555 14_ (c) Depth of Water above FML ((a) (b)) Cell 4B (a)Pond Solution Elevation (b) FML Bottom Elevation 5557 50 (c) Depth of Water above FML ((a) (b)) (d) Elevation of Beach Area with Highest Elevation (monthly) Roberts Pond (a)Pond Solution Elevation (b) FML Bottom Elevation 5612 3. (c) Depth of Water above FML ((a) (b)) 2 Shmes Dram Liquid Levels Cell 2 Pump functioning properly _Depth to Liquid pre pump _Depth to Liquid Post pump (all measurements are depth m pipe) Pre pump head is 37 97 Depth to Liquid Pre pump = Post pump head is 37 97 -Depth to Liquid Post pump = N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 32 of 53 3 Leak Detection Systems (Same data as Daily Inspection Form Record data on daily form) Observation New Decon Pad. Portal 1 New Decon Pad, Portal 2 New Decon Pad Portal 3 Is LDS (Portal) wet or dry*^ .wet dry .wet ^dry .wet dry If wet Record liquid level Liquid Ft to Liquid Ft to Liquid Ft to If wet Report to RSO 4 Taihngs Area Inspection (Note dispersal of blowing tailings) 5 Control Methods Implemented 6 Remarks 7 Designated Disposal Area for Non Tailings Mill Waste (awaiting DRC approval) * Does Level exceed 12 inches above the lowest point on the bottom flexible membrane hner (solution elevation of 5556 14 amsl for Cell 4A and 5558 50 for Cell 4B)'? no yes If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible membrane liner (elevation 5556 14 amsl) notify supervisor or Mill manager immediately N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 33 of 53 APPENDIX A (CONT) MONTHLY INSPECTION DATA Inspector Date 1 Slurry Pipehne 2 Diversion Ditches and Diversion Berm Observation Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2 Diversion Ditches Sloughing Erosion Undesirable Vegetation Obstruction of Flow Diversion Berm Stability Issues Signs of Distress ^es_ _yes_ ^es_ _yes. .no .no no no _yes_ ^es_ _yes_ _yes_ .no .no .no no _yes. _yes_ _yes. _yes_ .no .no .no no _yes. _yes_ _no no Comments 3 Summary of Activities Around Sedimentation Pond N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 34 of 53 4 Overspray Dust Mimmization Overspray system functioning properly _yes. Overspray earned more than 50 feet from the cell If yes was system immediately shut off^ Comments no 0^es_ _yes. no no 5 Remarks 6 Settlement Monitors Cell 2 Wl Cell 2 W2 Cell 2 W3 Cell 2 W4 Cell 2W7 C Cell 2 W7N Cell2W6C Cell 4A Toe Cell 3 2C Cell 3 3S Cell 3 4N Cell 3 7C Cell 3 SC Cell 2W3 S Cell 2E1 N Cell 2E1 IS Cell 2E1 2S Cell 2 East Cell 2 W7S Cell 2 W6S Cell 2 W4S Cell 3 2S _ Cell 3 3C _ Cell 3 6N _ Cell 3 7N _ Cell 3 8N Cell 3 IN _ Cell 3 IC _ Cell 3 IS _ Cell 3 2N _ Cell 2W5 N Cell 2 W6N Cell 2 W4N Cell 2 W5C Cell 2 W5S Cell3 3N _ Cell 3 7S _ Cell 3 8S 7 Movement Monitors surfaces)'' (Is there visible damage to any movement momtor or to adjacent 8 Summary of Daily, Weekly and Quarterly Inspections N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Envu-onmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 35 of 53 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12Revision Denisonll 4 Page 36 of 53 APPENDIX A (CONT) WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM QUARTERLY INSPECTION DATA Inspector Date 1 Embankment Inspection 2 Operations/Mamtenance Review 3 Construction Activities 4 Estimated Areas Cell 3 Cell 4A Cell 4B Estimated percent of beach surface area Estimated percent of solution pool area Estimated percent of cover area Comments N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTailings Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 37 of 53 APPENDIX A (CONT) ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of through Date of Inspection Inspector Weather conditions for the week Blowing dust conditions for the week Corrective actions needed or taken for the week Are all bulk feedstock matenals stored in the area indicated on the attached diagram yes no comments Are all altemate feedstock matenals located outside the area indicated on the attached diagram maintained within water tight containers yes no comments (e g conditions of containers) Are all sumps and low lying areas free of standing solutions'^ Yes No If No how was the situation corrected supervisor contacted and correction date*^ Is there free standing water or water running off of the feedstock stockpiles'^ Yes No Comments N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Envu-onmental Protection Manual Section 3 1 01/12 Revision Denisonl 14 Page 38 of 53 Other comments N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 39 of 53 APPENDIX A (CONT) ANNUAL DECONTAMINATION PAD INSPECTION Date of Inspection Inspector New Decontamination Pad Are there any cracks on the wash pad surface greater than 1/8 inch of separation'? Yes ^No Is there any significant detenoration or damage of the pad surface*? Yes No Findings Repair Work Required Existing Decontamination Pad Were there any observed problems with the steel tank? Yes ^No Findings Repair Work Required Note For the annual inspection of the both the Existing and New Decontanunation Pads the annual inspection findings any repairs required and repairs completed along with a summary of the weekly inspections shall be discussed in the 2"^ Quarter report due September 1 of each calendar year N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operatmg Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 40 of 53 APPENDIX B 8 3 TAILINGS INSPECTOR TRAINING This document provides the traimng necessary for qualifying management designated individuals for conducting daily tailings inspections Training information is presented by the Radiation Safety Officer or designee from the Environmental Department Daily tailings inspections are conducted in accordance with the White Mesa Mill Tailings Management System and Discharge Minimization Technology (DMT) Monitoring Plan The Radiation Safety Officer or designee from the Radiation Safety Department is responsible for perfomung monthly and quarterly tailings inspections Tailings inspection forms will be included in the monthly tailings inspection reports which summarize the conditions activities and areas of concern regarding the tailmgs areas Notifications The inspector is required to record whether all inspection items are normal (satisfactory requinng no action) or that conditions of potential concem exist (requinng action) A check mark indicates no action required If conditions of potential concem exist the inspector should mark an X in the area the condition pertains to note the condition and specify the conective action to be taken If an observable concem is made it should be noted on the tailings report until the conective action is taken and the concem is remedied The dates of all conective actions should be noted on the reports as well Any major catastrophic events or conditions pertaining to the tailings area should be reported immediately to the Mill Manager or the Radiation Safety Officer one of whom will notify Corporate Management If dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSHA (303 231 5465) and the State of Utah Division of Dam Safety (801 538 7200) Inspections All areas of the tailings disposal system are routinely patrolled and visible observations are to be noted on a daily tailings inspection form Refer to Appendix A for an example of the daily tailings inspection form The inspection form consists of three pages and is summarized as follows 1 Tailings Slurry Transport System The slurry pipeline IS to be inspected for leaks damage and sharp bends The pipeline joints are to be monitored for leaks and loose connections The pipeline supports are to be inspected for damage and loss of support Valves are also to be inspected particularly for N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu-onmental Protection Manual Section 3 1 Page 4 lof 53 leaks blocked valves and closed valves Points of discharge need to be inspected for improper location and orientation Operational Systems Operating systems including water levels beach liners and covered areas are items to be inspected and noted on the daily inspection forms Sudden changes in water levels previously observed or water levels exceeding the operating level of a pond are potential areas of concem and should be noted Beach areas that are observed as having cracks severe erosion or cavities are also items that require investigation and notation on daily forms Exposed liner or absence of cover from erosion are potential items of concern for ponds and covered areas These should also be noted on the daily inspection form Cells 1 3 4A and 4B solution levels are to be monitored closely for conditions nearing maximum operating level and for large changes m the water level since the last inspection All pumping activities affecting the water level will be documented In Cells 1 and 3 the PVC liner needs to be monitored closely for exposed liner especially after storm events It is important to cover exposed liner immediately as exposure to sunlight will cause degradation of the PVC liner Small areas of exposed lmer should be covered by hand Large sections of exposed lmer will require the use of heavy equipment These conditions are considered senous and require immediate action After these conditions have been noted to the Radiation Safety Officer a work order will be written by the Radiation Safety Officer and tumed into the Maintenance Department All such repairs should be noted in the report and should contain the start and finish date of the repairs Dikes and Embankments Inspection items include the slopes and the crests of each dike For slopes areas of concem are sloughs or sliding cracks bulges subsidence severe erosion moist areas and areas of seepage outbreak For crests areas of concem are cracks subsidence and severe erosion When any of these conditions are noted an X mark should be placed in the section marked for that dike In addition the dikes m particular dikes 4A S 4A E and 4B S should be inspected closely for mice holes and more importantly for prairie dog holes as the praine dogs are likely to bunow in deep possibly to the lmer If any of these conditions exist the inspection report should be marked accordingly N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 42 of 53 4 Flow Rates Presence of all flows in and out of the cells should be noted Flow rates are to be estimated in gallons per nunute (GPM) Rates need to be detemuned for slurry lines pond retum SX tails and the spray system During non operational modes the flow rate column should be marked as 0 The same holds tme when the spray system is not utilized 5 Physical Inspection of Slurry Line(s) A physical inspection of all slurry lines has to be made every 4 hours during operation of the null If possible the inspection should include observation of the entire discharge line and discharge spill point into the cell If fill to elevation flags are m place the tailings and build up IS to be monitored and controlled so as to not cover the flags 6 Dust Control Dusting and wind movement of tailings should be noted for Cells 2 3 4A and 4B Other observations to be noted include a brief description of present weather conditions and a record of any precipitation received Any dusting or wind movement of tailings should be documented In addition an estimate should be made for wind speed at the time of the observed dusting or wind movement of tailings The Radiation Safety Department measures precipitation on a daily basis Daily measurements should be made as near to 8 00 a m as possible every day Weekend measurements will be taken by Environmental Health and Safety personnel as close to 8 00 a m as possible All snow or ice should be melted before a reading is taken 7 Observations of Potential Concern All observations of concem during the inspection should be noted in this section Conective action should follow each area of concem noted All work orders issued contacts or notifications made should be noted in this section as well It is important to document all these Items in order to assure that the tailings management system records are complete and accurate 8 Map of Tailmgs Cells The last section of the inspection involves drawing as accurately as possible the following Items where applicable N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 43 of 53 1 Cover area 2 Beach/tailing sands area 3 Solution as it exists 4 Pump lines 5 Activities around tailings cell (i e hauling trash to the dump lmer repairs etc ) 6 Slurry discharge when operating 7 Over spray system when operating 9 Safety Rules All safety mles applicable to the mill are applicable when m the tailings area These mles meet the required MSHA regulations for the tailmgs area Please pay particular notice to the following mles 1 The posted speed Imut on Cell 4A and 4B dike is 5 mph and the posted speed limit for the tailings area (other than the Cell 4 A and 4B dike) is 15 mph These limits should not be exceeded 2 No food or drink is penmtted in the area 3 All personnel entering the tailmgs area must have access to a two way radio 4 Horseplay is not pemutted at any time 5 Only those specifically authorized may operate motor vehicles m the restricted area 6 When road conditions are muddy or slick a four wheel drive vehicle is required in the area 7 Any work performed in which there is a danger of falling or slipping in the cell will require the use of a safety belt or hamess with attended life line and an approved life jacket A portable eyewash must be present on site as well 8 Anytime the boat is used to perform any work an approved life jacket and goggles must be wom at all times There must also be an approved safety watch with a two way hand held radio on shore A portable eyewash must be present on site as well 10 Preservation of Wildlife Every effort should be made to prevent wildlife and domesticated animals from entering the tailings area All wildlife observed should be reported on the Wildlife Report Worksheet during each shift Waterfowl seen near the tailings cells should be discouraged from landing by the use of noisemakers 11 Certification Following the review of this document and on site instmction on the tailings system inspection program designated individuals will be certified to perform daily tailings inspections The Radiation Safety Officer authorizes certification Refer to the Certification N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 44 of 53 Form Appendix C This form should be signed and dated only after a thorough review of the tailings information previously presented The form will then be signed by the Radiation Safety Officer and filed N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 45 of 53 APPENDIX C CERTIFICATION FORM Date . Name I have read the document titled Tailings Management System White Mesa Mill Tailings Inspector Training and have received on site instmction at the tailings system This instmction included documentation of daily tailings inspections analysis of potential problems (dike failures unusual flows) notification procedures and safety Signature I certify that the above named person is qualified to perform the daily inspection of the tailings system at the White Mesa Mill Radiation Safety Personnel/ Tailings System Supervisor N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 46 of 53 APPENDIX D FEEDSTOCK STORAGE AREA N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 47 of 53 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaihngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Envu-onmental Protection Manual Section 3 1 Page 48 of 53 APPENDIX E TABLES N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12Revision Denisonll 4 Page 49 of 53 Table lA Calculated Action leakage Rates for Vanous head Conditions Cell 4A White mesa Mill Blanding Utah Head above Liner System (feet) Calculated Action leakage Rate ( gallons / acre / day) 5 222 04 10 31401 15 384 58 20 444 08 25 496 50 30 543 88 35 587 46 37 604 01 Table IB Calculated Action leakage Rates for Various head Conditions Cell 4B White mesa Mill Blanding Utah Head above Liner System (feet) Calculated Action leakage Rate ( gallons / acre / day) 5 21140 10 317 00 15 369 90 20 422 70 25 475 60 30 528 40 35 570 00 37 581 20 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12 Revision Denisonll 4 Page 50 of 53 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 01/12Revision Denisonll 4 Page 51 of 53 APPENDIX F Example of Freeboard Calculations For Cell 4B Assumptions and Factors o Total PMP volume to be stored in Cell 4A - 159 4 acre feet o Wave mnup factor for Cell 4B - 0 77 feet o Total capacity of Cell 4B - 2 094 000 dry tons o Elevation of FML of Cell 4B - 5 600 35 FMSL o Maximum pool surface area of Cell 4B - 40 acres o Total tailings solids deposited mto Cell 4B at time beach area first exceeds 5 594 FMSL - 1 000 000 dry tons* o Date beach area first exceeds 5 594 FMSL - March 1 2012* o Expected and actual production is as set forth in the following table Time Period Expected Tailings Solids Disposition into Cell 4B Determined at the beginnmg of the period (dry tons)* Expected Tailmgs Solids Dispositio n into Cell 4B at the beginning of the period, multiplied by 150% Safety Factor (dry tons) Actual Tailings Solids Disposition mto Cell 4B determined at end of the period (dry tons)* March 1 2012 to November 1 2012 150 000 225 000 225 000 November 1 2012 to November 1 2013 300 000 450 000 275 000 November 1 2013 to November 1 2014 200 000 300 000 250 000 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 52 of 53 *These expected and actual tailings and production numbers and dates are fictional and have been assumed for illustrative purposes only Based on these assumptions and factors the freeboard liimts for Cell 4B would be calculated as follows 1 Prior to March L 2012 Prior to March 1 2012 the maximum elevation of the beach area in Cell 4B is less than or equal to 5 594 FMSL therefore the freeboard linut is set at 5 594 6 FMSL 2 March 1. 2012 to November 1. 2012 The pool surface area would be reduced to the following amount (1-225 000/ (2 094 000 - 1 000 000)) x 40 acres = 31 77 acres Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by 31 77 acres equals 6 22 feet When the wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 6 99 feet This means that the freeboard limit for Cell 4B would be reduced from 5594 6 FMSL to 5592 2 FMSL (5594 6 FMSL minus 6 22 feet rounded to the nearest one tenth of a foot) This calculation would be performed at March 1 2012 and this freeboard limit would persist until November 1 2012 3 November 1, 2012 to November 1. 2013 The pool surface area would be reduced to the following amount First recalculate the pool surface area that should have applied during the previous period had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period Since the actual tonnage of 225 000 dry tons was the same as the modeled tonnage of 225 000 dry tons the recalculated pool surface area is the same as the modeled pool surface area for the previous penod which is 31 77 acres Then calculate the modeled pool surface area to be used for the period (1-450 000/ (2 094 000 - 1 000 000 225 000)) x 31 77 acres = 15 32 acres Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by 15 32 acres equals 12 89 feet When the wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 13 66 feet This means that the freeboard limit for Cell 4B would be reduced from 5592 2 FMSL to 5586 7 FMSL (5600 35 FMSL minus 13 66 feet rounded to the nearest one tenth of a foot) This calculation would be performed at November 1 2012 and this freeboard Imut would persist until November 1 2013 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc White Mesa Mill - Standard Operating Procedures 01/12 Revision Denisonl 1 4 Book 11 Environmental Protection Manual Section 3 1 Page 53 of 53 4 November 1. 2013 to November L 2014 The pool surface area would be reduced to the following amount First recalculate the pool surface area that should have applied during the previous period had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the period Since modeled tonnages exceeded actual tonnages the pool area was reduced too much during the previous penod and must be adjusted The recalculated pool area for the previous period is (1 - 275 000/ (2 094 000 - 1 000 000 225 000) x 31 77 acres = 21 72 acres This recalculated pool surface area will be used as the starting point for the freeboard calculation to be performed at November 1 2013 Then calculate the modeled pool surface area to be used for the penod (1-300 000/ (2 094 000 - 1 000 000 225 000 - 275 000)) x 21 72 acres 10 75 acres Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by 10 75 acres equals 18 37 feet When the wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 19 14 feet This means that the freeboard limit for Cell 4B would be reduced from 5586 7 FMSL to 5581 2 FMSL (5600 4 FMSL minus 18 4 feet rounded to the nearest one tenth of a foot) This calculation would be performed at November 1 2013 and this freeboard limit would persist until November 1 2014 N VDMT PlanVDMT Plan 01 30 12 Revision 11 4VTaibngs Mgnt System and DMT Mon Plan January 2012 rev 11 4 clean doc REDLINE i' f I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denison 11 4^ Book 11 Envu-onmental Protection Manual Section 3 1 Page 1 of 53 WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND DISCHARGE MINIMIZATION TECHNOLOGY (DMT) MONITORING PLAN TABLE OF CONTENTS Contents 1 INTRODUCTION 3 2 DAILY TAILINGS INSPECTIONS 3 2 1 Dailv Comprehensive Tailings Inspection 3 2 2 Dailv Operations Inspection 6 2 3 Dailv Operations Patrol 6 2 4 Trainmg 6 2 5 Tailmes Emergencies 6 3 WEEKLY TAILINGS AND DMT INSPECTION 7 3 1 Weeklv Tailings Inspections 7 Northing 12 Easting 12 3 2 Weeklv Inspection of Solution Levels in Roberts Pond 15 3 3 Weeklv Feedstock Storage Area Inspections 15 4 MONTHLY TAILINGS INSPECTION 15 5 QUARTERLY TAILINGS INSPECTION 16 6 ANNUAL EVALUATIONS 18 6 1 Annual Technical Evaluation 18 6 2 Movement Monitors 19 6 3 Freeboard Limits 19 6 3 1 Cell 1 20 6 3 2 Cell 2 20 6 3 3 Cell 3 20 6 3 4 Cell 4A 20 6 3 5 Cell 43 20 6 3 6 Roberts Pond 23 6 4 Annual Leak Detection Fluid Samples 23 6 5 Annual Inspection of the Decontanunation Pads 23 7 OTHER INSPECTIONS 24 N.\DMT PlanVDMT Plan 01.30.12 Revis on 11.4\Taib gs Mgnt Svstem and DMT Mo PlanJan arv 2012 rev 11.4 redl ne.docN \DMT PlanUulv 2011 DMT reviaion for pormitXToilinga Mgnt Syotem ond DMT Mon Plon JiJy 2011 rov 11 2 rodhae^ White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 2 of 53 8 REPORTING REQUIREMENTS 24 8 1 Monthlv Tailings Reports 24 8 2 DMT Reports 25 8 3 TAILINGS INSPECTOR TRAINING 40 1 INTRODUCTION ^ 3—DAILY TAILINGS INSPECTIONS ^ 3-4-—Daily Comprehensive Tailings Inspectioa- Dailv Operations Inspection 3-^—Daily Operations Pa&el- 34-—Traming 3-^—Tailings Emorgencies- 3—WEEKLY TAILINGS AND DMT INSPECTION 3-1-—Wookly Tailings Inspections 7 3 1 2 Northfflg 13 3^-^—Easting 13 3-3-—Weekly Inspection of Solution Levels in Roberts Pond 14 3-3-—Weekly Focdstock Storage Area Inspoctiens 14 4-MONTHLY TAILINGS INSPECTION OTTARTFRI Y TATI TMn9 TNI<?PFPTTnN i& 6-ANNUAL EVALUATIONS i% —Annual Technical Evaluation i% 6-3r—Movomcnt Momtors i9 6-3-—Frooboard Limits 19 6-34- 1 Coll 1 Pnll '» 30 ''n '1 CcW '-'0 fi d Prll /I A TXf '-*n fi '1 5 PPII IIR %J ^ mJ 6^-6-Roberts Pond 33 6-4-—Annual Leak Detoction Ruid Samples 33 6-§-—Annual Inspection of the Decontamination Pads 33 7 OTHER INSPECTIONS 34 ^—REPORTING REQUIREMENTS 34 —Monthlv Tailings Reports 34 «-3-—DMT Reports 3§ —TAILINGS INSPECTOR TRAINING 45 N.VDMT PlanNDMT Plan 01 30.12 Revi on 11.4\Taihngs Mgnt Sv tern and DMT Mon Plan Januarv 2012 rev 11.4 redline docN \DMT PlonMulv 2011 DMT revision for pormnVToilmga Mgnt System ond DMT Mon Plon July 2011 rev 11 2 rodlmo doo White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 3 of 53 1 INTRODUCTION This Tailings Management System and Discharge Minmuzation Technology Monitoring Plan (the Plan ) for the White Mesa Mill (the Mill ) provides procedures for monitonng of the tailings cell system as required under State of Utah Radioactive Matenals License No UT 1900479 (the Radioactive Matenals License ) as well as procedures for operating and maintenance of monitonng equipment and reporting procedures that are adequate to demonstrate DMT compliance under State of Utah Ground Water Discharge Penrnt No 370004 for the Mill (the GWDP ) This Plan is designed as a systematic program for constant surveillance and documentation of the integnty of the tailings impoundment system including dike stability liner integnty and transport systems as well as monitonng of water levels in Roberts Pond and feedstock storage areas at the Mill The Plan requires daily weekly quarterly monthly and annual inspections and evaluations and monthly reporting to Mill management 2 DAILY TAILINGS INSPECTIONS The following daily tailings inspections shall be performed 2 1 Daily Comprehensive Tailings Inspection Qn a daily basis including weekends all areas connected with the evaporation cell (Cell 1) and thefive-four tailings cells (Cells 2.3.4A. and 4B) will be inspected Observations will be made of the current condition of each cell noting any corrective action that needs to be taken The Environmental or Radiation TochmcianRadiation Safety Officer (RSO) or his designee is responsible for performing the daily tailings inspections The Radiation Safety OfficorRSO may designate other individuals with training as descnbed in Section 2 4 below to perform the daily tailings inspection Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of which IS attached m Appendix A) The Daily Inspection Data form contains an inspection checklist which includes a tailings cells map and spaces to record observations especially those of immediate concem and those requinng corrective action The inspector will place a check by all inspection Items that appear to be operating properly Those items where conditions of potential concem are observed should be marked with an X A note should accompany the X speciiymg what the concem is and what corrective measures will resolve the problem This observation of concem should be noted on the form until the problem has been remedied The date that conective action was taken should be noted as well N.\DMTPlan\DMT Plan 01.30.12 Revision 11 4\Tailmg.s Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redhne.docN \DMT PlonUulv 2011 DMT roviaion for potmitVToilinga Mgnt System ond DMT Mon Plan July 2011 rov 11 2 rodlmo doo I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 4 of 53 Areas to be inspected include the following Cell 1 2 3 4A and 4B Dikes 4A S 4A E and 4B S wind movement of tailmgs effectiveness of dust nunimization methods spray evaporation Cell 2 spillway Cell 3 spillway Cell 4A spillway,Cell 3 Cell 4A spillway Cell 4A and 4B hquid pools and associated liquid return equipment and cell leak detection systems Operational features of the tailings area are checked for conditions of potential concem The following Items require visual inspection dunng the daily tailings inspection a) Tailings slurry and SX raffinate transport systems from the Mill to the active disposal cell(s) and pool retum pipeline and pumps Daily inspections of the tailmgs lines are required to be performed when the Mill is operating The lines to be inspected include the taihngs slurry hues from CCD to the active tailings cell SX raffinate lines that can discharge mto Cell 1 Cell 4AorCell4B the pond retum line from the tailings area to the Mill and lines transporting pond solutions from one cell to another b) Cell 1 c) Cell 2 d) Cell 3 e) Cell 4A f) Cell 4B g) Dike stmctures including dikes 4A S 4A E and 4B S h) The Cell 2 spillway Cell 3 spillway Cell 4A spiUway Cell 3 Cell 4A and Cell 4B liquid pools and associated liquid return equipment i) Presence of wildlife and/or domesticated ammals in the tailings area including waterfowl and burrowing animal habitations j) Spray evaporation pumps and lines k) Wind movement of tailings and dust minmuzation Wind movement of tailings will be evaluated for conditions which may require initiation of preventative dust minimization measures for cells containing taihngs sand Durmg tailmgs inspection general surface conditions will be evaluated for N.\DMTPlan\DMT Plan 01.30.12 Rev ionll.4\Taib ps Ment Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redl ne.docN \DMT PlonVJulv 2011 DMT revision for permitVToilmga Mgnt System and DMT Mon Plon July 2011 rev 11 2 roeflifle^ I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 5 of 53 the following 1) areas of tailings subject to blowing and/or wind movement 2) liquid pool size 3) areas not subject to blowing and/or wind movement expressed as a percentage of the total cell area The evaluations will be reviewed on a weekly basis or more frequently if warranted and will be used to direct dust minimization activities 1) Observation of flow and operational status of the dust control/spray evaporation system(s) m) Observations of any abnormal vanations in tailings pond elevations in Cells 1 3 4A and4B n) Locations of slurry and SX discharge within the active cells Slurry and SX discharge pomts need to be indicated on the tailings cells map included in the Daily Inspection Data form. o) An estimate of flow for active tailings slurry and SX line(s) p) An estimate of flow m the solution retum line(s) q) Daily measurements in the leak detection system (LDS) sumps of the tailings cells will be made when warranted by changes in the solution level of the respective leak detection system The tngger for further action when evaluating the measurements m the Cell 1 and Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours The solution level in Cell 4A or 4B leak detection system is not allowed to be more than 1 0 foot above the lowest point on the bottom flexible membrane liner (FML) (Cell 4A FML elevation is 5555 14 amsl and with the addition of the 1 0 foot of solution the solution elevation is 5556 14 feet amsl For Cell 4B the FML elevation is 5557 50 amsl and with the addition of the 1 0 foot of solution the solution elevation is 5558 50 feet amsl) If any of these observations are made the Mill Manager should be notified immediately and the leak detection system pump started In addition the requirement to notify the Executive Secretary in accordance with Parts ID 6 and IG 3 of the Groundwater Discharge Permit must be adhered to when the solution level tngger for Cell 4A or 4B has been exceeded Whenever the leak detection system pump is operating and the flow meter totalizer is recording a notation of the date and the time will be recorded on the Daily Inspection Data form This data will be used in accordance with License Condition 11 3 B through 11 3 E of the Mill s Radioactive Matenals License to N\DMT PlanVDMT Plan 01.30.12 Reviso 11.4\Taili gs Mgnt Sv.stem and DMT Mon Plan Januarv 2012 te 11.4 edline docN VDMT Plon\Julv 2011 DMT roviaion for permitVToilings Mgnt System and DMT Mon Plan July 2011 rov 11 2 rodlmo doc I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Demson 11 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 6 of 53 detemune whether or not the flow rate into the leak detection system is in excess of the License Conditions Items (a) (m) (n) and (o) are to be done only when the Mill is operating When the Mill is down these Items cannot be performed 2 2 Daily Operations Inspection Dunng Mill operation the Shift Foreman or other person with the training specified in Section 2 4 below designated by the Radiation Safety Officer will perform an mspection of the tailmgs line and tailings area at least once per shift paying close attention for potential leaks and to the discharges from the pipelines Observations by the Inspector will be recorded on the appropnate line on the Operating Foreman s Daily Inspection form 2 3 Daily Operations Patrol In addition to the inspections descnbed in Sections 2 1 and 2 2 above a Mill employee will patiol the tailings area at least twice per shift dunng Mill operations to ensure that there are no obvious safety or operational issues such as leaking pipes or unusual wildlife activity or incidences No record of these patrols need be made but the inspectors will notify the Radiation Safety Officer ^RSQ-) and/or Mill management m die event that dunng their inspection they discover that an abnormal condition or tailmgs emergency has occuned 2 4 Training All individuals perfomung inspections descnbed in Sections 2 1 and 2 2 above must have Tailings Management System training as set out in the Tailmgs Inspection Training procedure which is attached as Appendix B This training will include a training pack explaining the procedure for performing the inspection and addressing inspection items to be observed In addition each individual after reviewing the training pack will sign a certification form mdicating that tiaimng has been received relative to his/her duties as an inspector 2 5 Tailings Emergencies Inspectors will notify the Radiation Safety OfficerRSO and/or Mill management immediately if dunng their inspection they discover that an abnormal condition exists or an event has occurred that could cause a tailings emergency Until relieved by the Environmental or Radiation Technician or Radiation Safety OfficorRSO inspectors will have the authonty to direct resources dunng tailings emergencies N.VDMT PlanVDMT Plan 01.30.12 Revisio 11 4VTaih gs Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redl e.docN VDMT PlonVJulv 2011 DMT revision for permitVToilings Mgnt System and DMT Mon Plan July 2011 rev 11 2 rodlme doo I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 7 of 53 Any major catasti-ophic events or conditions pertaining to the tailmgs area should be reported I immediately to the Mill Manager or the Radiation Safety OfficorRSO one of whom will notify Corporate Management If dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSHA (303 231 5465) and the State of Utah Division of Dam Safety (801 538 7200) 3 WEEKLY TAILINGS AND DMT INSPECTION 3 1 Weeklv Tailings Inspections Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the following a) Leak Detection Systems Each tailings cell s leak detection system shall be checked weekly (as well as daily) to determine whether it is wet or dry If marked wet the liquid levels need to be measured and reported In Cell 1 and Cell 3 the leak detection system is measured by use of a dual probe system that senses the presence of solutions in the LDS system (comparable to the systems in Cells 4A and 4B) and indicates the presence of solution with a waming light The Cell 4A and 4B leak detection systems are momtored on a continuous basis by use of a pressure tiansducer that feeds water level information to an electronic data collector The pressure transducer is calibrated for fluid with a specific gravity of 1 0 The water levels are measured every hour and the information is stored for later retneval The water levels are measured to the nearest 0 10 inch The data collector is currentiy programmed to store 7 days of water level information The number of days of stored data can be increased beyond 7 days if needed For Cells 1 and 3 the water level data is recorded on the Daily Tailings Inspection Form For Cells 4 A I and 4B the water level data is downloaded to a laptop computer ea-penodically and incorporated into the Mill s environmental monitonng data storage and into the files for weekly inspection reports of the tailmgs cell leak detection systems K sufficient fluid is present in the leak detection system of any cell the fluid shall be pumped from the LDS to the extent reasonably possible and record the volume of fluid recovered Any fluid pumped from an LDS shall be retumed to a disposal cell For Cells 1 and 3 if fluid is pumped from an LDS the flow rate shall be calculated by dividing the recorded volume of fluid recovered by the elapsed time since fluid was last pumped or increases m the LDS fluid levels were recorded whichever is the more recent This calculation shall be documented as part of the I N VDMT PlanVDMT Plan 01.30.12 Re so 11.4VTailmgs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redl e docN VDMT PlonVJulv I 2011 DMT revision for permitVToilings Mgnt System ond DMT Mon Plon July 2011 rov 11 2 redline doo White Mesa Mill - Standard Operating Procedures Book 11 Environmental ProtecUon Manual Section 3 1 07/U01/12 Revision Denisonl 1 43 Page 8 of 53 weekly inspection For Cells 1 and 3 upon the initial pumping of fluid from an LDS a fluid sample shall be collected and analyzed in accordance with paragraph 11 3 C of the Radioactive Matenals License For Cell 4A and 4B under no circumstance shall fluid head in the leak detection system sump exceed a 1 foot level above the lowest point in the lower flexible membrane liner To determine the Maximum Allowable Daily LDS How Rates in the Cell 4A and 4B leak detection systems the total volume of all fluids pumped from the LDS on a weekly basis shall be recovered from the data collector and that information will be used to calculate an average volume pumped per day Under no circumstances shall the daily LDS flow volume exceed 24 160 gallons/day for Cell 4A or 26 145 gallons/day for Cell 4B The maximum daily LDS flow volume will be compared against the measured cell solution levels detailed on Table 1A and IB (for Cells 4A and 4B respectively) in Appendix E to detemune the maximum daily allowable LDS flow volume for varying head conditions m Cell 4A and 4B b) Slimes Drain Water Level Monitoring (i) Cell 3 IS nearly full and will commence closure when filled Cell 2 is partially reclaimed with the surface covered by platform fill Each cell has a shmes drain system which aids in dewatenng the shmes and sands placed m the cell (ll) Denison re graded the intenm fill on Cell 2 in order to reduce the potential for the accumulation of stormwater on the surface of Cell 2 As a result of the re grading of the intenm cover and the placement of an additional 62.000 cubic yards of fill matenal on Cell 2. the slimes dram access pipe was extended 6 97 feet The extension pipe is 6 97 feet in length, and therefore the new measunng point is 37 97 feet from the t)ottom of the slimes drain The measunng point on the extension pipe was surveyed bv a Utah Certified Land Surveyor For the quarterly recoverv test descnt>ed in section vi below, this extension has no effect on the data measurement procedures ^ Cell 2 has a pump placed inside of the shmes drain access pipe at the bottom* of the shmes drain As taken from actual measurements the bottom of the shmes drain is 38-37 97 feet below a water level measunng point which is a notch on the side ofthe Cell 2 shmes drain access pipe at the centerline of the shmes drain access pipe at the ground surface level This means that the bottom of the slimes dram pool and the location of the pump are one foot above the lowest point of the FML in Cell Formatted Indent Left 1 No bullets or numbering N.VDMT PlanVDMT Plan 01.30.12 Revisio 11.4VTailings Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4redb e.docN VDMT PlonUulv 2011 DMT revision for pormuVToibngs Mgnt System and DMT Mon Plan July 2011 rev 11 2 rodlmo 40e White Mesa Mill - Standard Operating Procedures Book 11 Envu-onmental Protection Manual SecUon 3 1 07/1401/12 Revision Demsonll43 Page 9 of 53 2 which based on constmction reports is at a depth of39-^897.feet below the water level measunng point on the slimes drain access pipe for Cell 2 (iii) The shmes drain pump m Cell 2 is activated and deactivated by a float mechamsm and water level probe system When the water level reaches the level of the float mechamsm the pump is activated Pumping then occurs until the water level reaches the lower probe which tums the pump off The lower probe is located one foot above the bottom of the shmes drain standpipe and the float valve is located at five-three feet above the bottom of the slimes drain standpipe The average wastewater head m the Cell 2 shmes dram is therefore less than 5-3_feet and is below the phreatic surface of tailings Cell 2 about 30-27 feet below the water level measunng point on the slimes drain access pipe As a result there is a continuous flow of wastewater from Cell 2 into the slimes dram collection system Mill management considers that the average allowable wastewater head in the Cell 2 shmes drain resulting from pumping in this manner is satisfactory and is as low as reasonably achievable (iv) The Cell 2 shmes dram pump is checked weekly to observe that it is operating and that the water level probe and float mechanism are working properly which is noted on the Weekly Tailings Inspection Form If at any time the pump is observed to be not working properly it will be fixed or replaced within 15 days (v) Depth to wastewater m the Cell 2 shmes drain access pipe shall be monitored and recorded weekly to determine maximum and mimmum fluid head before and after a pumping cycle respectively The extension of the Cell 2 slimes dram access pipe did not require any changes to the measurement procedure The surveyed measunng point on the extended pipe is used as required The head measurements are calculated m the same manner, using the same procedures as those used pnor to the extension of the Cell 2 shmes drain access pipe, however, the total depth to the bottom of the pipe is now 37 97 feet as noted on the corrected form in Attachment A -All head measurements must be made from the same measunng point (the* notch at the north side of the access pipe) and made to the nearest 0 01 foot The results will be recorded as depth in pipe measurements on the Weekly Tailings Inspection Form The extension of the Cell 2 slimes access pipe has not changed the method of calculation of the pre and post pump head calculations, only the constant (Cell 2 shmes drain access pipe height) used m the calculation has changed The head is calculated bv subtracting the depth to liquid from 37 97 feet rather than from the previous measurement of 38 feet The weekly Tailings Inspection form included m Attachment A has been changed to reflect the extension height. •4- (vi) Effective July 11 2011 on a quarterly basis the shmes drain pump will be tumed off and the wastewater m the shmes drain access pipe will be allowed to stabilize for at least 90 hours Once the water level has stabilized (based on no change in water level for three (3) successive readings taken no less than one (1) hour apart) the water level of the wastewater will be measured and recorded as a depth in pipe measurement on -( Formatted Not H ghlight Formatted Indent Left numbering 1 No bullets or Formatted Indent Left 1 Hanging 0 5 No bullets or numbering Formatted Indent Left 0 75 number ng No bullets or N.VDMT PlanVDMT Plan 01.30.12 Revis on 114VTail gs Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redb e.docN VDMT PlonVJulv aoi 1 DMT roviaion for ponnitVToibngs Mgnt System and DMT Mon Pton July 2011 rev 11 2 rodlmo doo I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 10 of 53 Quarterly Data form by measunng the depth to water below the water level measunng point on the shmes drain access pipe (vu) No process hquids shall be allowed to be discharged mto Cell 2 (vill) If at any time the most recent average annual head in the Cell 2 shmes drain is found to have increased above the average head for the previous calendar year the Licensee will comply with the requirements of Part IG 3 of the GWDP mcluding the requirement to provide notification to the Executive Secretary orally within 24 hours followed by wntten notification (ix) Because Cell 3 and Cell 4A are cunently active no pumping from the Cell 3 or Cell 4A shmes drain is authonzed No pumping from the Cell 4B shmes drain will be authonzed once it is put mto service and while it is active Pnor to initiation of tailmgs dewatenng operations for Cell 3 Cell 4A or Cell 4B a similar procedure will be developed for ensunng that average head elevations in the Cell 3 and Cell 4A shmes drains are kept as low as reasonably achievable and that the Cell 3 Cell 4A and Cell 4 shmes drains are inspected and the results reported in accordance with the requirements of the permit c) Wind Movement of Tailings An evaluation of wind movement of tailings or dusting and control measures shall be taken if needed d) Tailings Wastewater Pool Elevation Monitoring Solution elevation measurements in Cells 1^4A and 4B and Roberts Pond are to be taken by survey on a weekly basis _ aad-tThe beach area in Cell 4B with the maximum elevation is to be taken by survey on a monthly basis when beaches are first observed as follows (i) The survey will be performed by the Mill s Radiation Safety Officer or designee (the Surveyor ) with the assistance of another Mill worker (the Assistant ) (u) The survey will be performed using a survey mstmment (the Survey Instrument ) accurate to 0 01 feet such as a Sokkai No B21 or equivalent together with a survey rod (the Survey Rod ) having a visible scale m 0 01 foot increments (iii)The Reference Points for Cells 1. Cell 4A. and 4B and Roberts Pond are known points established by professional survey For Cell 1 and Roberts Pond the Reference Point is a wooden stake with a metal disk on it located on the southeast comer of Cell 1 The elevation of the metal disk (the Reference Point Elevation ) for Cell 1 and Roberts Pond is at 5 623 14 feet above mean sea level ( FMSL ) For Coll 3 tho Rcforenco Point is a piece of metal rebar located on the south dike of Cell 3 Tho elevation at the top of this pieco of rebar (tho Reference Point Elevation for Coll 3) la at 5 607 83 FMSL For Cell 4A and 4B the Reference Point is a piece of stamped metal monument located next to the N.VDMT PlanVDMT Plan 01.30.12 Re is IMVTaib gs Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redb e.docN VDMT PlonVJulv 2011 DMT revision for pomutVToibngs Mgnt System ond DMT Mon Plan July 2011 rov 11 2 rodbno doo White Mesa Mill - Standard Operating Procedures Q7/M01/12 Revision Denisonll 4^ Book 11 Environmental Protection Manual SecUon 3 1 Page 11 of 53 transformer on the south side of Cell 4A and 4B The elevation at the top of this piece of rebar (the Reference Point Elevation for Cell 4A and 4B) is 5600 49 fmsl The Surveyor will set up the Survey Instmment m a location where both the applicable Reference Point and pond surface are visible For Cell 1 and Roberts Pond this is typically on the road on the Cell 1 south dike between Cell 1 and Roberts Pond approximately 100 feet east of the Cell 1/Roberts Pond Reference Point For Cell 4A and Cell 4B this is typically on the south side of Cell 4A and 4B (iv) Qnce m location the Surveyor will ensure that the Survey Instmment is level by centenng the bubble m the level gauge on the Survey Instmment (v) The Assistant will place the Survey Rod vertically on the Reference Point (on the metal disk on the Cell 1/Roberts Pond Reference Point on the top of the rebar on the Cell 4A and 4B Reference Point The Assistant will ensure that the Survey Rod IS vertical by gentiy rocking the rod back and forth until the Surveyor has established a level reading (vi) The Surveyor will focus the cross hairs of the Survey Instmment on the scale on the Survey Rod and record the number (the Reference Point Reading ) which represents the number of feet the Survey Instmment is reading above the Reference Point (vii) The Assistant will then move to a designated location where the Survey Rod can be placed on the surface of the main solution pond in the Cell 1 Cell 4A Cell 4B or Roberts Pond or the area of the beach in Cell 4B with the highest elevation as the case may be These designated locations and the methods to be used by the Assistant to consistendy use the same locations are as follows For a newly constmcted cell when the cell is first placed into operation the solution level is typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation For newly constmcted cells solution level measurement of solution level will commence within 30 days of authonzation for use Measurements will be conducted consistent with the procedures in this DMT Plan and consistent with current Mill health and safety procedures The measurements will be completed using survey equipment and the appropnate length survey rod (either 25 or 45 ) not be required until tho solution level is high enough that it can be reached safely by personnel with a measurmg tape along the sido of the FML Solutions lovols will bo measured by this method beginning when tho solution level is high enough to be reached safely as detemuned by tho RSO Surveying of solution lovols will not bo required until solution levels aro high enough that they can offoctivoly ho measured by survey instmment from the appropnate surveying point A Pond Surface Measurements I Cell 4A N.VDMT PlanVDMT Plan 01.30.12 Re sion 11.4VTailmgs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redb e docN'VDMT PlonVJulv 2011 DMT roviaion for permitVToibngs Mgnt System ond DMT Mon Plan July 2011 rov 11 2 redline doe I White Mesa Mill - Standard Operatmg Procedures Book 11 Environmental ProtecUon Manual SecUon 3 1 07/4401/12 Revision Denisonl 143 Page 12 of 53 The Assistant will walk down the slope in the northeast comer of Cell 4A and place the Survey Rod at the liquid level n Cell 4B The Assistant will walk down the slope in the northwest southeast comer of Cell 4B and place the Survey Rod at the liquid level m Cell 1 A mark has been painted on the north side of the ramp going to the pump platform m Cell 1 The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface and IV Roberts Pond A mark has been painted on the railing of the pump stand in Roberts Pond The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface Based on the foregoing methods the approximate coordinate locations for the measunng points for Roberts Pond and the Cells are 3-1-^ Northing 3-1^ Easting Roberts Pond 323 041 2 579 697 CeU 1 322 196 2 579 277 Cell 4A 320 300 2 579 360 Cell 4B 320 690 2 576 200 -( Formatted No bullets or numbering These coordinate locations may vary somewhat depending on solution elevations m the Pond and Cells Cell 4B Beach Elevation Beach elevations m Cell 4B will commence when beaches are first observed The Assistant will place the Survey Rod at the point on the beach area of Cell 4B that has the highest elevation If it is not clear which area of the beach has the highest elevation then multiple points on the beach area will be surveyed until the Surveyor is satisfied that the point on the Cell 4B beach area with the highest elevation has been surveyed If it is clear that all points on the Cell 4B beach area are below 5 593 FMSL then the Surveyor may rely on one survey point N VDMT PlanVDMT Plan 01.30.12 Re sion 11.4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 redb e docN VDMT PlonUulv aOl 1 DMT roviaion for permitVToibnga Mgnt System ond DMT Mon Plan July 2011 rov 11 2 rodbno doo White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Demson 11 43 Book 11 Envu-onmental Protection Manual Section 3 1 Page 13 of 5 3 (vm) The Assistant will hold the Survey Rod vertically with one end of the Survey Rod just touching the pond surface The Assistant will ensure that the Survey Rod IS vertical by gently rocking the rod back and forth until the Surveyor has established a level reading (ix)The Surveyor will focus the cross hairs of the Survey Instmment on the scale on the Survey Rod and record the number (the Pond Surface Reading ) which represents the number of feet the Survey Instmment is reading above the pond surface level The Surveyor will calculate the elevation of the pond surface as FSML by adding the Reference Point Reading for the Cell or Roberts Pond as the case may be to the Reference Point Elevation for the Cell or Roberts Pond and subtracting die Pond Surface Reading for the Cell or Roberts Pond and will record the number accurate to 0 01 feet ^e} Decontamination Pads (i) New Decontamination Pad The New Decontamination Pad is located in the southeast comer of the ore pad near the Mill s scale house A In order to ensure that the pnmary containment of the New Decontamination Pad water collection system has not been compromised and to provide an inspection capability to detect leakage from the pnmary containment vertical inspection portals have been installed between the pnmary and secondary containments B These portals will be visually observed on a weekly basis as a means of detecting any leakage from the pnmary containment into the void between the pnmary and secondary containment The depth to water m each portal will be measured weekly by physically measunng the depth to water with an electncal sounding tape/device All measurements must be made from the same measunng point and be made to the nearest 0 01 foot C These inspections will be recorded on the Weekly Tailmgs Inspection form D The water level shall not exceed 0 10 foot above the concrete floor in any standpipe at any time This will be determmed by subtracting the weekly depth to water measurement from the distance from the N.VDMT PlanVDMT Plan 01.30.12 R i n 11.4VTail g Mgnt Svstem and DMT Mon Plan Januarv 2012 rev 11.4 edi ne.docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt System ond DMT Mon Plan July 2011 rev 11 2 rodbno doc White Mesa Mill - Standard Operatmg Procedures 07/1101/12 Revision Denison 11 43 Book 11 Environmental Protection Manual Secuon 3 1 Page 14 of 53 measunng point in the standpipe to the dry concrete floor The depth to water from the top (elevation 5589 8 feet amsl) of any of the three (3) observation ports to the standing water shall be no less than 6 2 feet Depths less than 6 2 feet shall indicate more that 0 1 foot of standing water above the concrete floor (elev 5583 5 feet amsl) and shall indicate a leak in the pnmary containment E Any observation of fluid between the pnmary and secondary containments will be reported to the Radiation Safety Officer (RSO) F In addition to inspection of the water levels in the standpipes the New Decontamination Pad including the concrete integnty of the exposed surfaces of the pad will be inspected on a weekly basis Any soil and debns will be removed from the New Decontamination Pad immediately pnor to inspection of the concrete wash pad for cracking Observations will be made of the current condition of the New Decontamination Pad Any abnormahties relating to the pad and any damage to the concrete wash surface of the pad will be noted on the Weekly Tailings Inspection form If there are any cracks greater than 1/8 inch separation (width) the RSO must be contacted The RSO will have the responsibility to cease activities and have the cracks repaired (ll) Existing Decontamination Pad The Existing Decontamination Pad is located between the northwest comer of the Mill s maintenance shop and the ore feeding gnzzly A The Existing Decontamination Pad will be inspected on a weekly basis Any soil and debns will be removed from the Existing Decontamination Pad immediately pnor to inspection of the concrete wash pad for cracking Observations will be made of the current condition of the Existing Decontanunation Pad including the concrete integnty of the exposed surfaces of the pad Any abnormahties relating to the pad and any damage or cracks on the concrete wash surface of the pad will be noted on the Weekly Tailings Inspection form If there are any cracks greater than 1/8 inch separation (width) the RSO must be contacted The RSO will have the responsibility to cease activities and have the cracks repaired Summary N.VDMT PlanVDMT Plan 01 30.12 Re s on II 4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 edbne.docN VDMT PlonUulv 2011 DMT revision for penmtVToibnga Mgnt System and DMT Mon Plan July 2011 rev 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures Q7/t401/12 Revision Denisonll 43 Book 11 Environmental Protection Manual Section 3 1 Page 15 of 53 In addition the weekly inspection should summanze all activities conceming the tailings area for that particular week Results ofthe weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection form An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A 3 2 Weekly Inspection of Solution Levels m Roberts Pond On a weekly basis solution elevations are taken on Roberts Pond in accordance with the procedures set out in Section 3 1 d) above The Weekly solution level m Roberts Pond is recorded on the Weekly Tailings and DMT Inspection form Based on histoncal observations the FML at the Pond Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the pond s FML If the pond solution elevation at the Pond Surface Reading area is at or below the FML for that area the pond will be recorded as being dry 3 3 Weeklv Feedstock Storage Area Inspections Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to confirm that a) the bulk feedstock matenals are stored and maintained within the defined area descnbed m the GWDP as indicated on the map attached hereto as Appendix D b) a 4 ft buffer is maintained at the penphery of the storage area which is absent bulk matenal in order to assure that the matenals do not encroach upon the boundary of the storage area and c) all altemate feedstock located outside the defined Feedstock Area are maintained within water tight contmners The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection Report a copy of which is contamed m Appendix A Any vanance in stored matenals from this requirement or observed leaking altemate feedstock dmms or other containers will be brought to the attention of Mill Management and rectified within 15 days 4 MONTHLY TAILINGS INSPECTION Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from the Radiation Safety Department and recorded on the Monthly Inspection Data form an example of which IS contained in Appendix A Monthly inspections are to be performed no sooner than 14 days since the last monthly tailmgs inspection and can be conducted concurrentiy with the quarterly N.VDMT PlanVDMT Plan 01.30.12 Revis o 11 4VTaibngs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4redb e.docN VDMT PlonUulv 2011 DMT revision for pormitVTaibnga Mgnt System ond DMT Mon Plan July 2011 rov 11 2 rodlinc doo White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Demsonll43 Book 11 Environmental Protection Manual Section 3 1 Page 16 of 53 tailings inspection when applicable The following items are to be inspected a) Tailings Slurry Pipeline When the Mill is operating the slurry pipeline will be visually inspected at key locations to determine pipe wear The cntical points of the pipe include bends slope changes valves and junctions which are cntical to dike stability These locations to be monitored will be determined by the Radiation Safety Officer or his designee from the Radiation Safety Department dunng the Mill mn b) Diversion Ditches Diversion ditches 1 2 and 3 shall be monitored monthly for sloughing erosion undesirable vegetation and obstmction of flow Diversion berm 2 should be checked for stability and signs of distress c) Sedimentation Pond Activities around the Mill and facihties area sedimentation pond shall be summanzed for the month d) Overspray Dust Minimization The inspection shall include an evaluation of overspray minmuzation if applicable This entails ensunng that the overspray system is functioning properly In the event that overspray is earned more than 50 feet from the cell the overspray system should be immediately shut off e) Remarks A section is included on the Monthly Inspection Data form for remarks in which recommendations can be made or observations of concem can be documented f) Summary of Daily Weekly and Quarterly Inspections The monthly inspection will also summanze the daily weekly and if applicable quarterly tailings inspections for the specific month In addition settlement monitors are typically surveyed monthly and the results reported on the Monthly Inspection Data form 5 QUARTERLY TAILINGS INSPECTION N.VDMT PlanVDMT Plan 01.30.12 Re lo 11.4VTaib g Mgnt Svstem and DMT Mon Plan January 2012 rev 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pomutVToihnga Mgnt System ond DMT Mon Plon July 2011 rev 11 2 redbne doo White Mesa Mill - Standard OperaUng Procedures 07/1101/12 Revision Demson 11 43 Book 11 Envnonmental Protection Manual Section 3 1 Page 17 of 53 The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from the Radiation Safety Department having the trainmg specified in Section 2 4 above once per calendar quarter A quarterly inspection should be performed no sooner than 45 days since the previous quarterly inspection was performed Each quarterly inspection shall include an Embankment Inspection an Operations/Maintenance Review a Constmction Review and a Summary as follows a) Embankment Inspection The Embankment mspection involves a visual inspection of the crest slope and toe of each dike for movement seepage severe erosion subsidence shnnkage cracks and exposed liner b) Operations/Maintenance Review The Operations/Maintenance Review consists of reviewing Operations and Maintenance activities pertaimng to the tailings area on a quarterly basis c) Construction Review The Constmction Review consists of reviewing any constmction changes or modifications made to the tailings area on a quarterly basis d) An estimate of the percentage of the tailings beach surface area and solution pool area is made including estimates of solutions cover areas and tailings sands for Cells 3 4A and 4B N.VDMT PlanVDMT Plan 01 30.12 Rev s on 11.4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 redbne.docN'VDMT PlonUulv 2011 DMT revision for permuVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 3 rodbno doo White Mesa Mill - Standard Operating Procedures 07/1401/12 Revision Demson 11 43 Book 11 Environmental Protection Manual Section 3 1 Page 18 of 53 e) Summary The summary will include all major activities or observations noted around the tailings area on a quarterly basis If any of these conditions are noted the conditions and conective measures taken should be documented in the Quarterly Inspection Data form An example of the Quarterly Inspection Data form IS provided in Appendix A 6 ANNUAL EVALUATIONS The following annual evaluations shall be performed 6 1 Annual Technical Evaluation An annual technical evaluation of the tailings management system is performed by a registered professional engineer (PE) who has expenence and traimng m the area of geotechnical aspects of retention stmcmres The technical evaluation includes an on site inspection of the tailings management system and a thorough review of all tailmgs records for the past year The Technical Evaluation also includes a review and summary of the annual movement monitor survey (see Section 5 2 below) All tailings cells and corresponding dikes will be inspected for signs of erosion subsidence shnnkage and seepage The drainage ditches wdl be inspected to evaluate surface water control stmctures In the event tailings capacity evaluations (as per SOP PBL 3) were performed for the receipt of altemate feed matenal dunng the year the capacity evaluation forms and associated calculation sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate The amount of tailings added to the system since the last evaluation will also be calculated to detemune the estimated capacity at the time of the evaluation Tailings inspection records will consist of daily weekly monthly and quarterly tailmgs inspections These inspection records will be evaluated to determine if any freeboard limits are being approached Records will also be reviewed to summanze observations of potential concem The evaluation also involves discussion with the Environmental and/or Radiation Technician and the Radiation Safety Officer regarding activities around the tailings area for the past year Dunng the aimual inspection photographs of the tailings area will be taken The training of individuals will be reviewed as a part of the Annual Technical Evaluation N.VDMT PlanVDMT Plan 01.30.12 Rev s on 11.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System ond DMT Mon Plon July 2011 rov 11 2 redbne doc I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 19 of 53 The registered engineer will obtain copies of selected tailings inspections along with the monthly and quarterly summanes of observations of concem and the corrective actions taken These copies will then be included in the Annual Technical Evaluation Report The Annual Techmcal Evaluation Report must be submitted by November 15* of every yearteto the Executive Secretary Directing Dam Safety Engineer State of Utah Namral Resources 1636 West North Temple Suito 220 Salt Lolto City Utah 84116 3156 6 2 Movement Monitors A movement momtor survey is to be conducted by a licensed surveyor annually dunng the second quarter of each year The movement monitor survey consists of surveying momtors along dikes 3 S 4A W and 4A S to detect any possible settiement or movement of the dikes The data generated from this survey is reviewed and incorporated mto the Annual Technical Evaluation Report of the tailmgs management system 6 3 Freeboard Lmuts The freeboard limits set out in this Section are intended to capmre the Local 6 hour Probable Maximum Precipitation (PMP) event which was detemuned in the January 10 1990 Drainage Report (the Drainage Report ) for the White Mesa site to be 10 inches The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas was calculated m the Drainage Report to be 103 acre feet of water with a wave mn up factor of 0 90 feet The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas plus the adjacent drainage areas was calculated in the Drainage Report to be 123 4 acre feet of water The flood volume from the PMP event over the Cell 4A area was calculated m the Drainage Report to be 36 acre feet of water (40 acres plus the adjacent drainage area of 3 25 acres) times the PMP of 10 inches) with a wave mn up factor of 0 77 feet The flood volume from the PMP event over the Cell 4B area has been calculated to be 38 1 acre feet of water (40 acres plus the adjacent drainage area of 5 72 acres) times the PMP of 10 inches with a wave mn up factor of 0 77 feet The total pool surface area in Cell 1 is 52 9 acres in Cell 4A is 40 acres and m Cell 4B is 40 N VDMT PlanVDMT Plan 01.30.12 Rev sion 11.4VTaihngs Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibnga Mgnt System and DMT Mon Plan July 2011 rov 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures 07/1401/12 Revision Denisonl 143 Book 11 Envnonmental Protection Manual Section 3 1 Page 20 of 53 acres The top of the flexible membrane liner ( FML ) for Cell 1 is 5 618 2 FMSL for Cell 4A IS 5 598 5 FMSL and for Cell 4B is 5600 4 FMSL Based on the foregoing the freeboard limits for the Mill s tailings cells will be set as follows 63 1 Cell 1 The freeboard limit for Cell 1 will be set at 5 615 4 FMSL This will allow Cell 1 to capmre all of the PMP volume associated with Cell 1 The total volume requirement for Cell 1 is 103 acre feet divided by 52 9 acres equals 1 95 feet plus the wave mn up factor of0 90 feet equals 2 85 feet The freeboard linut is dien 5 618 2 FMSL minus 2 85 feet equals 5 615 4 FMSL Under Radioactive Matenals License condition 10 3 this freeboard limit is set and is not recalculated annually 632 Cell 2 The freeboard limit for Cell 2 is inapplicable since Cell 2 is filled with solids All of the PMP volume associated with Cell 2 will be attnbuted to Cell 4A (and/or any future tailings cells) 633 Cell 3 The freeboard limit for Cell 3 is inapplicable since Cell 3 is close to being filled with solids and all of the PMP flood volume associated with Cell 3 will be attnbuted to Cell 4B (and/or any fumre tailings cells) 634 Cell 4A The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with Cell 4A will be attnbuted to Cell 4B A spillway has been added to Cell 4A to allow overflow into CeU 4B 635 Cell 4B The freeboard limit for Cell 4B will be set assurmng that the total PMP volume for Cells 2 3 4A and 4B of 159 4 acre feet will be accommodated in Cell 4B The procedure for calculating the freeboard limit for Cell 4B is as follows (a) When the Pool Surface Area is 40 Acres When the pool surface area in Cell 4B is 40 acres (i e when there are no beaches) the freeboard limit for Cell 4B will be 5 594 6FMSL which is 5 7 feet below die FML This freeboard value was developed as follows PMP Flood Volume 38 1 acre feet Overflow from Cell 4A assuming no storage in Cell 3 or 4A 159 4 acre feet N.VDMT PlanVDMT Plan 01.30 12 Revis on 11.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 rev 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt System ond DMT Mon Plon July 2011 rov 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonll 43 Book 11 Envu-onmental Protection Manual Section 3 1 Page 2 lof 53 Sum of PMP volume and overflow volume 197 5 acre feet Depth to store PMP an overflow volume = 197 5 acre feet/40 acres 4 9 feet Wave mn up factor 0 77 feet Total required freeboard 5 7 feet (all values in the above calculation have been rounded to the nearest one tenth of afoot) (b) When the Maximum Elevation ofthe Beach Area is 5 594 FMSL or Less When the maximum elevation of the beach area in Cell 4B is 5594 FMSL or less then the freeboard lirmt will be 5 594 6 FMSL which is the same as m (a) above This allows for the simation where there may be beaches but these beaches are at a lower elevation than the freeboard limit estabhshed in (a) above and there is therefore ample freeboard above the beaches to hold the maximum PMP volume The maximum elevation of the beach area will be detemuned by monthly surveys performed by Mill personnel in accordance with the Mill s DMT Plan (c) When the Maximum Elevation ofthe Beach Area First Exceeds 5 594 FMSL When the maximum elevation of the beach area m Cell 4B first exceeds 5 594 FMSL then the freeboard limit for the remainder of the ensuing year (penod t=0) (untU the next November 1) wiU be calculated when that elevation is first exceeded (the Initial C^culation Date ) as follows i) The total number of dry tons of tailings that have hi stoncally been deposited into CeU 4B pnor to the Initial Calculation Date ( To ) will be detenmned u) The expected number of dry tons to be deposited into Cell 4B for the remainder of the ensuing year (up to the next November 1) based on production estimates for that penod ( Ao* ) will be detemuned 111) Ao* will be grossed up by a safety factor of 150% to allow for a potential underestimation of the number of tons that wdl be deposited in the cell dunng the remainder of the ensuing year This grossed up number can be referred to as the modeled tonnage for the penod iv) The total design tailings solid storage capacity of Cell 4AB will be accepted as 2 094 000 dry tons of ladings v) The available remaining space in Cell 4B for solids as at the Initial Calculation Date will be calculated as 2 094 000 dry tons minus To vi) The reduction in the pool surface area for the remainder of the ensuing year will be assumed to be direcdy proportional to the reduction in the available space in Cell 4A 4B for solids That is the reduced pool surface area for penod t=0( RPAo ) afterthe reduction will be calculated to be (1 - (Ao* X 1 5) / (2 094 000 To)) x 40 acres = RPAQ vu) The required freeboard for Cell 4A-4B for the remainder of the penod t=0 can be calculated in feet to be the wave mn up factor for Cell 4B of 0 77 feet plus the quotient of 197 5 acre feet divided by the RPAo The freeboard Imut for Cell 4B for N.VDMT PlanVDMT Plan 01 30.12 Re i nil 4VTaibng Mgnt Svstem and DMT Mon Plan Jan arv 2012 rev 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System ond DMT Mon Plon July 2011 rov 11 2 rodbno-dee White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 22 of 53 the remainder of penod t=0 would then be the elevation of the FML for Cell 4B of 5594 0 FMSL less this required freeboard amount rounded to the nearest one tenth of afoot and Vlll) The foregoing calculations will be performed at the Imtial Calculation Date and the resulting freeboard limit will persist until the next November 1 An example of this calculation is set out in Appendix F (d) Annual Freeboard Calculation When the Maximum Elevation ofthe Beach Area Exceeds 5 594 FMSL On November 1 of each year (the Annual Calculation Date ) the reduction in pool area for the ensuing year (refened to as penod t) will be calculated by i) First calculating the Adjusted Reduced Pool Area for the previous penod (ARPAt 0 to reflect actual tonnages deposited in Cell 4B for the previous penod (penod t 1) The RPAt 1 used for the previous penod was based on expected tonnages for penod t 1 grossed up by a safety factor The ARPAt i is merely the RPA that would have been used for penod t 1 had the actual tonnages for year t I been known at die outset of penod t 1 and had the RPA been calculated based on the acmal tonnages for penod t 1 This allows the freeboard calculations to be corrected each year to take into account acmal tonnages deposited in the cell as of the date of the calculation The ARPAt 1 can be calculated using the following formula (1 - At 1 / (2 094 000 - Tt 0) x ARPAt 2 = ARPAt 1 Where • A, 1 IS the acmal number of dry tons of tailings solids deposited in Cell 4B dunng penod t 1 • Tt 1 IS the actual number of dry tons of tailings solids histoncally deposited in Cell 4B pnor to the beginmng of penod t 1 and • ARPAt 2 IS the Adjusted Reduced Pool Area for penod t 2 If penod t 2 started at the Imtial Calculation Date then ARPAt 2 is 40 acres 11) Once the ARPA, 1 for the previous penod (penod t 1) has been calculated the RPA for the subject penod (penod t) can be calculated as follows (1 - (At* X 1 5) / (2 094 000 Tt)) x ARPAt 1 = RPAt Where • A,* IS the expected number of dry tons of tailings to be deposited mto Cell 4B for the ensuing year (penod t) based on production estimates for the year (as can be seen from the foregoing formula this expected number is grossed up by a safety factor of 1 5) • Tt IS the acmal number of dry tons of tailings solids histoncally deposited in Cell 4B pnor to the beginmng of penod t and N VDMT PlanVDMT Plan 01.30.12 Re n 11.4VTaib gs Mgnt Svstem and DMT M Plan Januarv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 2 rodbno 40e White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonll 43 Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 23 of 53 • ARPAt 1 IS the Adjusted Reduced Pool Area for penod t 1 which is the pool surface area for the previous penod (penod t 1) that should have applied dunng that penod had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled acmal tonnages for the penod 111) The required freeboard for penod t can be calculated m feet to be the wave mn up factor for Cell 4B of 0 77 feet plus the quotient of 197 5 acre feet divided by die RPA, The freeboard limit for Cell 4A-4B for penod t would then be the elevation of the FML for Cell 4B of 5594 0 FMSL less this required freeboard amount rounded to the nearest one tenth of a foot and iv) The foregoing calculations will be performed at the Annual Calculation Date for penod t and the resulting freeboard limit will persist until the next Aimual Calculation Date for penod t-i-1 An example of this calculation is set out in Appendix F (e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell When a spillway is added between Cell 4B and a new taihngs cell then if an approved freeboard limit calculation method for the new cell is set to cover the entire PMP event for Cells 2 3 4A 4B and the new tailings cell the freeboard limit for Cell 4B will be inapphcable except for approved provisions to prevent storm water mnoff from overtopping dikes 6 3 6 Roberts Pond The freeboard linut for Roberts Pond is a liquid maximum elevation of 5 624 0 feet above mean sea level as specified in the GWDP 6 4 Annual Leak Detection Fluid Samples In the event solution has been detected m a leak detection system a sample will be collected on an annual basis This sample will be analyzed according to the conditions set forth m License Condition 11 3 C The results of the analysis will be reviewed to determine die ongm of the solution 6 5 Annual Inspection of the Decontamination Pads a) New Decontanunation Pad Dunng the second quarter of each year die New Decontanunation Pad will be taken out of service and inspected to ensure the integnty of the wash pad s exposed concrete surface If any abnormalities are identified i e cracks in the concrete with greater than 1/8 inch separation (width) or any significant detenoration or damage of the pad surface repairs will be made pnor to resuming N VDMT PlanVDMT Plan 01.30.12 Re lo 11.4VTaibngs Mgnt Sv t m and DMT Mon Plan Jan arv 2012 re 11.4redb .docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt Syatem and DMT Mon Plon July 2011 rov 11 2 rodbno dee White Mesa Mill - Standard Operating Procedures 07/4-401/12 Revision Denisonl 143 Book 11 Envu-onmental Protection Manual SecUon 3 1 Page 24 of 53 the use of the facility All inspection findings and any repairs required shall be documented on the Aimual Decontamination Pad Inspection form The inspection findings any repairs required and repairs completed shall be summanzed m the 2 Quarter DMT Monitonng Report due September 1 of each calendar year b) Existing Decontamination Pad Dunng the second quarter of each year the Existing Decontanunation Pad will be taken out of service and inspected to ensure the integnty of the steel tank Once the water and any sediment present is removed from the steel tank containment the walls and bottom of the tank will be visually inspected for any areas of damage cracks or bubbling indicating corrosion that may have occurred since the last inspection K any abnormalities are identified defects or damage will be reported to Mill management and repairs will be made pnor to resunung the use of the facility All inspection findings and any repairs required shall be documented on the Annual Decontamination Pad Inspection form A record of the repairs will be maintained as a part of the Annual Inspection records at the Mill site The inspection findings any repairs required and repairs completed shall be summanzed in the 2nd Quarter DMT Monitonng Report due September 1 of each calendar year 7 OTHER INSPECTIONS All daily weekly monthly quarterly and annual inspections and evaluations should be performed as specified m Sections 2 3 4 5 and 6 above However additional inspections should be conducted after any sigmficant storm or significant namral or man made event occurs 8 REPORTING REQUIREMENTS In addition to the Daily Inspection Data Weekly Tailings Inspection Monthly Inspection Data and (Quarterly Inspection Data forms included as Appendix A and descnbed in Sections 2 3 4 and 5 respectively and the Operating Foreman s Daily Inspection and Weekly Mill Inspection forms descnbed m Sections 2 and 3 respectively the following additional reports shall also be prepared 8 1 Monthly Tailings Reports Monthly tadmgs reports are prepared every month and summanze the previous month s activities around the tailings area If not prepared by the Radiation Safety Officer the report shall be submitted to the Radiation Safety Officer for review The Mill Manager will review the report as well before the report is filed in the Mill Cential File The report will contain a summary of observations of concem noted on the daily and weekly tailings inspections Corrective measures taken dunng the month will be documented along with the observations where appropnate All daily and weekly tailings inspection forms will be attached to the report A monthly inspection form will also be attached Quarterly inspection forms will accompany the report when applicable The report wdl be signed and dated by the preparer in addition to the Radiation Safety Officer and the MiU N.VDMT PlanVDMT Plan 01.30.12 Revision 11.4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redb e.docN VDMT PlonUulv 2011 DMT rovioion for permitVTodmgs Mgnt System and DMT Mon Plon July 2011 rov 11 2 rodlmo doc I White Mesa Mill - Standard Operating Procedures 07/4-401/12 Revision Denisonll 43 Book 11 Environmental Protection Manual Section 3 1 Page 25 of 53 Manager 82 DMT Reports Quarterly reports of DMT monitonng activities which will include the following mformation wiU be provided to the Executive Secretary on the schedule provided in Table 5 of die GWDP a) On a quarterly basis all required information required by Part 1 F 2 of the GWDP relating to the inspections descnbed in Section 3 1 (b) (Shmes Drain Water Level Monitonng) 3 1(d) (Taihngs Wastewater Pool and Beach Area Elevation Monitonng) 3 2 (Weekly Inspection of Solution Levels m Roberts Pond) and 3 3 (Weekly Feedstock Storage Area Inspections) b) On a quarterly basis a summary of the weekly water level (depth) inspections for the quarter for the presence of fluid m all three vertical inspection portals for each of the three chambers m the concrete settling tank system for the New Decontanunation Pad which will include a table indicating the water level measurements m each portal dunng the quarter c) With respect to the annual inspection of the New Decontamination Pad descnbed in Section 6 5(a) the inspection findings any repairs required and repairs completed shall be summanzed in the 2 Quarter report due September 1 of each calendar year d) With respect to the annual inspection of the Existing Decontamination Pad descnbed in Section 6 5(b) the inspection findings any repairs required and repairs completed shall be summanzed in the 2 Charter report due September 1 of each calendar year and e) An annual summary and graph for each calendar year of the depth to wastewater in the Cell 2 shmes drain must be included in the fourth quarter report After the first year and beginning in 2008 quarterly reports shall include both the current year monthly values and a graphic companson to the previous year N.VDMT PlanVDMT Plan 01.30.12 Revis o 11.4VTaib g Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for pormitVTodings Mgnt System and DMT Mon Plon July 2011 rev 11 2 rodlme doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 26 of 53 APPENDIX A FORMS N VDMT PlanVDMT Plan 01 30.12 Revi lo 11 4VTaib gs Mgnt Svstem and DMT M n Plan Jan arv 2012 rev 11.4 redb e docN VDMT PlonUulv 2011 DMT revision for ponmtVToibngs Mgnt System ond DMT Mon Plan July 2011 rev 11 2 redline doo 1 I White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 07/4401/12 Revision Demson 11 43 Page 27 of 53 APPENDIX A (CONT) DAILY INSPECTION DATA Inspector. Date Accompanied by, Time Any Item not OK must be documented A check mark = OK X = Action Required I TAILINGS SLURRY TRANSPORT SYSTEM Insoection Items Conditions of Potential Concem Cell 1 CeU 2 CeU 3 Cell 4A Cell 4B Slurry Pipeline Leaks Damage Blockage Sharp Bends Pipeline Joints Leaks Loose Connections Pipeline Supports Damage Loss of Support Valves Leaks Blocked Closed Point(s) of Discharge Improper Location or Onentation II OPERATIONAL SYSTEMS Inspection Items Conditions of Potential Concem Cell 1 CeU 2 CeU 3 Cell 4A Cell 4B Water Level Greater Than Operating Level Large Change Since Previous Inspection Beach Cracks Severe Erosion Subsidence Lmer and Cover Erosion of cover Exposure of Liner Liner Observable Liner Damage N VDMT Pl VDMT Plan 01 30.12 R vi 11 4VTail gs Mpit Svstem a d DMT Mo Plan Jan arv 2012 re 11 4 redl e.docN'VDMT PlonUulv 2011 DMT i DMT Mon Plon July 2011 rov 11 2 rodbne doc I for pcrmitVTnibngs Mgnt System and White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 07/4401/12 Revision Demson 11 43 Page 28 of 53 ni DIKES AND EMBANKMENTS Inspection Items Conditions of Potential Dike 1 I Dike 1 Dike 2 Dike 3 Dike Dike Dike Concem lA 4A S 4AE 4B S Slopes Sloughs or Sbding Cracks No No No No Bulges Subsidence Severe visible visible visible visible Erosion Moist Areas Areas slope or slope or slope or slope or of Seepage Outbreak dike to dike to dike to dike to inspect inspect inspect mspect Crest Cracks Subsidence Severe No No No No Erosion visible visible visible visible slope or slope or slope or slope or dike to dike to dike to dike to inspect inspect inspect inspect rv FLOW RATES Slurry Linefs) Pond Remm S X Tails Spray Svstem GPM V PHYSICAL INSPECTION OF SLURRY LINES(S) Walked to Discharge Point Observed Entire Discharge Line _Yes Yes _No No VI DUST CONTROL CeU 2 CeU 3 CeU 4A Cell 4B Dusting Wind Movement of Tailings Precipitation inches liquid N VDMT PlanVDMT Plan 01 30 12 R VI 11.4VTail e Mgnt Svstem and DMT M PlanJan arv 2012 re 11.4 redl e.docN'VDMT PlonUulv 2011 DMT i DMT Mon Plan July 2011 rov 11 2 rodbno doc I for pomutVTaibngQ Mgnt Syotom and White Mesa Mill - Standard OperaUng Procedures Book 11 Environmental Protection Manual Section 3 1 07/1401/12 Revision Demson 11 43 Page 29 of 53 General Meteorological conditions VII DAILY LEAK DETECTION CHECK | | CeU 1 CeU 2 CeU 3 Cell 4A Cell 4B Leak Detection System Checked Checked Checked Checked Checked Checked Leak Detection System Checked Wet Drv Wet Drv Wet Drv Wet Drv Wet Drv Leak Detection System Checked Initial level Initial level Initial level Initial level Initial level Leak Detection System Checked Final level Final level Final level Final level Final level Leak Detection System Checked Gal pumped Gal pumped Gal pumped Gal pumoed Gal pumped Vin OBSERVATIONS OF POTENTLVL CONCERN Action Required N VDMT PlanVDMT Plan 01 30 12 R vi 11 4VTaib g Mgnt Sv tem and DMT M Plan Januarv 2012 re 11 4 redl docN'VDMT PlonUulv 2011 DMT i DMT Mon Plon July 2011 rov 11 2 rodbno doo I for permitVTaihngs Mgnt System and Tailmgs Dail>' Inspection Report Taihngs Shiii"^ Dischaige Location o o Q (2 •5 <zi 2 1 O rri U MILL SITE CELL NO 1 CELL NO 4A / Date hispectoi White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual Section 3 1 Page 31 of 53 APPENDIX A (CONT) DENISON MINES (USA) CORP WEEKLY TAILINGS INSPECTION Date Inspectors 1 Pond and Beach CeH 1 (a) Pond SoluUon Elevation elevations (msl ft) (b) FML Bottom Elevation 5597. (c) Depth of Water above FML ((a) (b)) Cell4A (a)Pond Solution Elevation (b) FML Bottom Elevation 5555 14_ (c) Depth of Water above FML ((a) (b)) Cen4B (a)Pond Solution Elevation (b) FML Bottom Elevation 5557 50 (c) Depth of Water above FML ((a) (b)) (d) Elevation of Beach Area with Highest Elevation (monthly) Roberts Pond (a)Pond SoluUon Elevation (b) FML Bottom Elevation ^5612 3_ (c) Depth of Water above FML ((a) (b)) 2 Slimes Dram Liquid Levels Cell 2 Pump funcuoning properly. _Depth to Liquid pre pump .Depth to Liquid Post pump (all measurements are depth in pipe) Pre pump head is 38-37 97 Depth to Liquid Pre pump = Post pump head is 3&-37 97 -Depth to Liquid Post pump = N VDMT PlanVDMT Plan 01.30.12 Revi ion 11.4VTaib gs Ment Svstem and DMT Mo Plan Januarv 2012 re 11.4 edb docN VDMT PlonUulv 2011 DMT revision for permitVToibnga Mgnt System and DMT Mon Plon July 2011 rov 11 2 redhflfr^ I White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual SecUon 3 1 07/4401/12 Revision Denisonl I 43 Page 32 of 53 3 Leak Detection Systems (Same data as Daily Inspection Form Record data on daily form) Observation New Decon Pad. Portal 1 New Decon Pad. Portal 2 New Decon Pad Portal 3 Is LDS (Portal) wet or dry*^ _wet dry _wet dry _wet ^dry If wet Record bquid level Liquid Ft to Liquid Ft to Ft to Liquid If wet Report to RSO 4 Taihngs Area Inspection (Note dispersal of blowing tailings) 5 Control Methods Implemented 6 Remarks. 7 Contaminated Waste DumpDesignated Disposal Area for Non Tailings Mill Waste (awaiting DRC approval) * Does Level exceed 12 mches above the lowest point on the bottom flexible membrane liner (solution eievauon of 5556 14 amsl for Cell 4A and 5558 50 for CeU 4B)'> no yes If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible membrane liner (elevation 5556 14 amsl) notify supervisor or Mill manager immediately N.VDMT PlanVDMT Plan 01.30 12 Revi i 11.4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 edb e.docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 2 redbne dee White Mesa Mill - Standard OperaUng Procedures 07/4401/12 Revision Denisonll 43 Book 11 Environmental ProtecUon Manual Section 3 1 Page 33 of 53 APPENDIX A (CONT) MONTHLY INSPECTION DATA Inspector Date 1 Slurry Pipelme 2 Diversion Ditches and Diversion Berm Observation Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2 Diversion Ditches Sloughing yes no yes no yes no Erosion yes no yes no yes no Undesirable yes no yes no yes no VegetaUon Obstmction of Row yes no yes no yes no Diversion Berm Stability Issues yes no Signs of Distress yes no Comments 3 Summary of Activities Around Sedimentation Pond N.VDMT PlanVDMT Plan 01.30.12 Rev sion 11 4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 rev 11.4 redbne docN VDMT PknUulv 2011 DMT revision for permitVToibnga Mgnt System and DMT Mon Plan July 2011 rov 11 2 redbne doc I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 34 of 53 4 Overspray Dust Minimization Overspray system functioning properly yes no Overspray earned more than 50 feet from the cell yes no If yes was system immediately shut off yes no Comments 5 Remarks 6 Settlement Monitors Cell 2 Wl CeU 2W3 S CeU 3 IN _ Cell 2 W2 Cell 2E1 N CeU 3 IC _ Cell2W3 CeU2El IS CeU 3 IS _ Cell 2 W4 Cell 2E1 2S Cell 3 2N _ Cell 2W7 C Cell 2 East Cell 2W5 N Cell 2 W7N Cell 2 W7S Cell 2 W6N Cell2W6C Cell2W6S Cen2W4N Cell 4A Toe Cell 2 W4S Cell 2 W5C Cen3 2C Cen3 2S Cen2W5S Cell 3 3S Cell 3 3C. Cell3 3N Cell 3^N Cell 3 6N Cell 3 7S Cell 3 7C Cell 3 7N Cell 3 8S Cell 3 8C Cell 3 8N 7 Movement Monitors (Is there visible damage to any movement monitor or to adjacent surfaces)*^ 8 Summary of Dady Weekly and Quarterly Inspections NVDMTPlanVDMTPlan01.30.12Re ison 11.4VTaib gs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 edb e.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System ond DMT Mon Plan July 2011 rev 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Demsonll43 Book 11 Environmental Protection Manual SecUon 3 1 Page 35 of 53 N.VDMT PlanVDMT Plan 01.30 12 R isio 11.4VTaib gs Ment Svstem and DMT Mo Plan Januarv 2012 re 11 4 redb e.docN VDMT PbmUulv 2011 DMT revision for pomutVToibngs Mgnt System ond DMT Mon Plon July 2011 rov 11 2 redline doc I White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 07/4401/12 Revision Denisonl 1 43 Page 36 of 53 APPENDIX A (CONT) WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM QUARTERLY INSPECTION DATA Inspector Date I Embankment Inspection 2 Operations/Maintenance Review 3 Construction Activities 4 Estimated Areas CeU 3 Cell 4A Cell 4B Estimated percent of beach surface area Estimated percent of solution pool area Estimated percent of cover area Coniments N.VDMT PlanVDMT Plan 01 30.12 Revi ion 11.4VTaib gs Mgni Svstem and DMT Mo Plan Jan arv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System and DMT Mon Plan July 2011 rev 11 2 redbne doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 143 Book 11 Envnonmental Protection Manual Section 3 1 Page 37 of 53 APPENDIX A (CONT) ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of through Date of Inspection Inspector Weather conditions for the week Blowing dust conditions for the week Corrective actions needed or taken for the week Are all bulk feedstock materials stored in the area indicated on the attached diagram yes no comments Are all alternate feedstock matenals located outside the area indicated on the attached diagram maintained within water tight containers yes no comments (e g conditions of containers). Are all sumps and low lying areas free of standing soluUons'' Yes No If No how was the situation corrected supervisor contacted and correction date"^ Is there free standing water or water mnning off of the feedstock stockpiles'^ Yes No Comments N.VDMT PlanVDMT Plan 01.30 12 Re s o 11.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pomutVToibngs Mgnt System ond DMT Mon Plon July 2011 rov 11 2 rodbno dee I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Demson 11 43 Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 38 of 53 Other comments N,\DMT PlanVDMT Plan 01.30.12 Re isi 11 4VTaib gs Mgnt Sv tem and DMT M n Plan Jan arv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 2 redbne doo White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 143 Book 11 Environmental Protection Manual Section 3 1 Page 39 of 53 APPENDIX A (CONT) ANNUAL DECONTAMINATION PAD INSPECTION Date of Inspection Inspector New Decontamination Pad Are there any cracks on the wash pad surface greater than 1/8 inch of separation'' Yes No Is there any significant deterioration or damage of the pad surface'' Yes No Findings Repair Work Required Existing Decontamination Pad Were there any observed problems with the steel tank'' Yes No Findings Repair Work Required Note For the annual inspection of die both the Existing and New Decontanunation Pads the annual inspection findings any repairs required and repairs completed along with a summary of the weekly inspections shall be discussed in the 2 Quarter report due September 1 of each calendar year N.VDMT PlanVDMT Plan 01.30.12 Revision 11 4VTaib g Mgnt Svstem and DMT Mo Plan Januarv 2012 re 11.4 redl e docN VDMT PlonUulv 2011 DMT revision for pomutVToihnga Mgnt System and DMT Mon Pbrn July 2011 rov 11 2 redline doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Demsonll43 Book 11 Environmental Protection Manual Section 3 1 Page 40 of 53 APPENDIX B 8 3 TAILINGS INSPECTOR TRAINING This document provides the tiaimng necessary for qualifying management designated individuals for conducting daily tailings inspections Training information is presented by the Radiation Safety Officer or designee from the Environmental Department Dady tailmgs mspections are conducted in accordance with the White Mesa Mill Tailings Management System and Discharge Minmuzation Technology (DMT) Monitonng Plan The Radiation Safety Officer or designee from the Radiation Safety Department is responsible for perfomung monthly and quarterly ladings inspections Tailings inspection forms will be included in the monthly tailings inspection reports which summanze the conditions activities and areas of concem regarding the tailings areas Notifications The inspector is required to record whether all inspection items are normal (satisfactory requinng no action) or that conditions of potential concem exist (requinng action) A check mark indicates no action required If conditions of potential concem exist the inspector should mark an X in the area the condition pertains to note the condition and specify the conective action to be taken If an observable concem is made it should be noted on the tailings report until the corrective action is taken and the concem is remedied The dates of all corrective actions should be noted on the reports as well Any major catastiophic events or conditions pertaimng to the tailings area should be reported immediately to the Mill Manager or the Radiation Safety Officer one of whom wdl notify Corporate Management If dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will dien notify Corporate Management MSHA (303 231 5465) and the State of Utah Division ofDam Safety (801 538 7200) Inspections All areas of the tailmgs disposal system are routinely patrolled and visible observations are to be noted on a daily tailings inspection form Refer to Appendix A for an example of the daily tailings inspection form The inspection form consists of three pages and is summanzed as follows 1 Taihngs Slurry Transport System The slurry pipeline is to be inspected for leaks damage and sharp bends The pipeline jomts are to be monitored for leaks and loose coimections The pipeline supports are to be inspected for damage and loss of support Valves are also to be mspected particularly for N.VDMT PlanVDMT Plan 01.30 12 Re ision ll.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibnga Mgnt Syatem and DMT Mon Plon July 2011 rov 11 2 rodbno doc I White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 1 43 Book 11 Environmental ProtecUon Manual Section 3 1 Page 41 of 53 leaks blocked valves and closed valves Pomts of discharge need to be mspected for improper location and onentation Operational Systems Operating systems including water levels beach liners and covered areas are items to be inspected and noted on the daily inspection forms Sudden changes in water levels previously observed or water levels exceeding the operating level of a pond are potential areas of concem and should be noted Beach areas that are observed as having cracks severe erosion or cavities are also items that require investigation and notation on daily forms Exposed lmer or absence of cover from erosion are potential items of concem for ponds and covered areas These should also be noted on the daily inspection form Cells 1 3 4A and 4B solution levels are to be monitored closely for conditions neanng maximum operating level and for large changes in the water level since the last inspection All pumping activities affecting the water level will be documented In Cells 1 and 3 the PVC liner needs to be momtored closely for exposed liner especially after storm events It is important to cover exposed liner immediately as exposure to sunlight will cause degradation of the PVC liner Small areas of exposed liner should be covered by hand Large sections of exposed liner will require the use of heavy equipment These conditions are considered senous and require immediate action After these conditions have been noted to the Radiation Safety Officer a work order will be wntten by the Radiation Safety Officer and mmed into the Maintenance Department All such repairs should be noted in the report and should contain the start and finish date of the repairs Dikes and Embankments Inspection items include the slopes and the crests of each dike For slopes areas of concem are sloughs or sliding cracks bulges subsidence severe erosion moist areas and areas of seepage outbreak For crests areas of concem are cracks subsidence and severe erosion When any of these conditions are noted an X mark should be placed m the section marked for that dike In addition the dikes in particular dikes 4A S 4A E and 4B S should be mspected closely for rmce holes and more importantly for praine dog holes as the praine dogs are likely to burrow in deep possibly to the liner If any of these conditions exist the inspection report should be marked accordingly N.VDMT PlanVDMT Plan 01.30.12 Revi lo 11.4VTaibng Mgnt Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redb e.docN VDMT PlonUulv 2011 DMT roviaion for pormitVTaibnga Mgnt Syatem ond DMT Mon Plon July 2011 rov 11 2 rodhae-dee White Mesa Mill - Standard Operating Procedures 07/4-401/12 Revision Denisonl 143 Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 42 of 53 4 Flow Rates Presence of all flows m and out of the cells should be noted Flow rates are to be estimated in gallons per minute (GPM) Rates need to be detemuned for slurry lines pond remm SX tads and the spray system Dunng non operational modes the flow rate colunm should be marked as 0 The same holds tme when the spray system is not utilized 5 Physical Inspection of Slurry Line(s) A physical inspection of all slurry lines has to be made every 4 hours dunng operation ofthe null If possible the inspection should include observation of the entire discharge line and discharge spill point mto the cell If fill to elevation flags are in place the tadmgs and build up IS to be monitored and controlled so as to not cover the flags 6 Dust Control Dusting and wind movement of tailings should be noted for Cells 2 3 4A and 4B Other observations to be noted mclude a bnef descnption of present weather conditions and a record of any precipitation received Any dusting or wind movement of tailings should be documented In addition an estimate should be made for wind speed at the time of the observed dusting or wind movement of tailmgs The Radiation Safety Department measures precipitation on a daily basis Daily measurements should be made as near to 8 00 a m as possible every day Weekend measurements will be taken by Environmental Health and Safety personnel as close to 8 00 a m as possible All snow or ice should be melted before a reading is taken 7 Observations of Potential Concern All observations of concem dunng the inspection should be noted in this section Conective action should follow each area of concem noted All work orders issued contacts or notifications made should be noted in this section as well It is important to document all these Items in order to assure that the tailings management system records are complete and accurate 8 Map of Taihngs Cells The last section of the mspection involves drawing as accurately as possible the following Items where apphcable N.VDMT PlanVDMT Plan 01.3012 Re sm 11.4VTaibng.s Mgnt Svst m and DMT Mon Plan Jan arv2012re 11.4 redbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibnga Mgnt System ond DMT Mon Plon July 2011 rov 11 2 rodlme doc White Mesa Mill - Standard Operating Procedures 07/4-401/12 Revision Denisonll 43 Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 43 of 53 1 Cover area 2 Beach/tailing sands area 3 Solution as it exists 4 Pump lines 5 Activities around tailings cell (i e hauling trash to the dump liner repairs etc ) 6 Slurry discharge when operating 7 Over spray system when operating 9 Safety Rules All safety mles applicable to the null are applicable when in the tailings area These mles meet the required MSHA regulations for the tailings area Please pay particular notice to the following mles 1 The posted speed limit on Cell 4A and 4B dike is 5 mph and the posted speed limit for the tailings area (other than the Cell 4A and 4B ddce) is 15 mph These linuts should not be exceeded 2 No food or dnnk is permitted in the area 3 All personnel entenng the ladings area must have access to a two way radio 4 Horseplay is not penmtted at any time 5 Only those specifically authonzed may operate motor vehicles in the restncted area 6 When road conditions are muddy or slick a four wheel dnve vehicle is required in the area 7 Any work performed in which there is a danger of falling or slipping in the cell will require the use of a safety belt or hamess with attended life line and an approved life jacket A portable eyewash must be present on site as well 8 Anytime the boat is used to perform any work an approved life jacket and goggles must be wom at all times There must also be an approved safety watch with a two way hand held radio on shore A portable eyewash must be present on site as well 10 Preservation of Wildhfe Every effort should be made to prevent wildlife and domesticated animals from entenng the tailings area All wildlife observed should be reported on the Wildlife Report Worksheet dunng each shift Waterfowl seen near the tailings cells should be discouraged from landing by the use of noisemakers 11 Certification Following the review of this document and on site instmction on the tailings system inspection program designated individuals will be certified to perform daily tailings inspections The Radiation Safety Officer audionzes certification Refer to the Certification N.VDMT PlanVDMT Plan 01.30 12 Re si 11.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redb e.docN VDMT PlonUulv 3011 DMT revision for pormitVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 2 redbne^ I White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonll 43 Book 11 Environmental Protection Manual Section 3 1 Page 44 of 53 Form Appendix C This form should be signed and dated only after a thorough review of the tailings information previously presented The form will then be signed by the Radiation Safety Officer and filed N VDMT PlanVDMT Plan 01.30 12 Rev si 11.4VTaibngs Mgnt Sv tem and DMT Mon Plan Januarv 2012 re 11 4 redbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt System and DMT Mon Plan July 2011 rev 11 2 rodbne doo White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 45 of 53 APPENDIX C CERTIFICATION FORM Date Name I have read the document titled Tailings Management System White Mesa Mill Tailings Inspector Training and have received on site mstmction at the tailings system This instmction included documentation of daily tailmgs inspections analysis of potential problems (dike failures unusual flows) notification procedures and safety Signamre I certify that the above named person is qualified to perform the daily inspection of the tailings system at the White Mesa Mill Radiation Safety Personnel/ Tailings System Supervisor N.VDMT PlanVDMT Plan 01.30.12 Re sion n.4VTaib gs Mgnt Svstem and DMT Mon Plan Januarv 2012 re 11.4 redb e.docN VDMT PlonUulv 2011 DMT revision for permitVToibnga Mgnt System and DMT Mon Plan July 2011 rov 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Demson 11 43 Book 11 Envnonmental ProtecUon Manual Section 3 1 Page 46 of 53 APPENDIX D FEEDSTOCK STORAGE AREA N.VDMT PlanVDMT Plan 01.30.12 Re sonlMVTaib gs Mgnt Sv tem and DMT M Plan Januarv 2012 rev 11 4 edb e.docN VDMT PlonUulv 2011 DMT revision for porrmtVToihngs Mgnt System und DMT Mon Plan July 2011 rev 11 2 rodliafrdee White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Section 3 1 07/4401/12 Revision Denisonl 143 Page 47 of 53 y,\DMT PlsnVDMTPlgn 01,30,12 ISO 11.4VTMb gs Ment Svstem and DMT Mon Plan Januarv 2012 re 11.4 edi e.docN VDMT PInnUiily 2011 DMT revision for pomutVToibngs Mgnt System and DMT Mon Plon July 2011 rov 11 2 rodlino doo I White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 ^ Page 48 of 53 APPENDDC E TABLES N.VDMT PlanVDMT Plan 01.30.12 Re si 11.4VTail ng Ment .Sv tem and DMT Mo Plan Januarv 2012 re 11.4 redb e.docN VDMT PlanUulv 2011 DMT revision for pomutVToibngs Mgnt System and DMT Mon Plon July 2011 rev 11 2 redbne doc t I White Mesa Mill - Standard Operating Procedures Book 11 Environmental Protection Manual Secuon 3 1 07/4401/12 Revision Denisonll 43 Page 49 of 53 Table lA Calculated Action leakage Rates for Vanous head Conditions Cell 4A White mesa Mill Blanding Utah Head above Lmer System (feet) Calculated Action leakage Rate (gallons / acre / day) 5 222 04 10 31401 15 384 58 20 444 08 25 496 50 30 543 88 35 587 46 37 604 01 Table IB Calculated Action leakage Rates for Vanous head Conditions Cell 4B White mesa Mill Blanding Utah Head above Liner System (feet) Calculated Action leakage Rate (gallons / acre / day ) 5 21140 10 317 00 15 369 90 20 422 70 25 475 60 30 528 40 35 570 00 37 581 20 N.VDMT PlanVDMT Plan 01 30 12 Rev sic 11.4VTaih es Ment Svstem and DMT Mo Plan Januarv 2012 rev 11.4 redb e.docN VDMT PlanUulv 2011 DMT revision for pormitVToibngs Mgnt Syatem and DMT Mon Plon July 2011 rev 11 2 rodbne doo White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Denisonl 1 43 Book 11 Environmental Protection Manual SecUon 3 1 Page 50 of 53 N.VDMT PlanVDMT Plan 01.30.12 R visio 11.4VTaib g Ment System and DMT M n Plan Januarv 2012 re 11.4 redbne docN VDMT PlonUulv 2011 DMT revision for permitVTaibngs Mgnt Syatem ond DMT Mon Plon July 2011 rov 11 2 redbne doo White Mesa Mill - Standard OperaUng Procedures Book 11 Environmental Protection Manual Section 3 1 07/4401/12 Revision Denisonll 4^ Page 51 of 53 APPENDIX F Example of Freeboard Calculations For CeU 4B Assumptions and Factors o Total PMP volume to be stored in CeU 4A - 159 4 acre feet o Wave mnup factor for CeU 4AB - 0 77 feet o Total capacity of Cell 4B - 2 094 000 dry tons o Elevation of FML of Cell 4B - 5 600 35 FMSL o Maximum pool surface area of Cell 4A-4B - 40 acres o Total tailings sohds deposited into Cell 4B at time beach area first exceeds 5 594 FMSL - 1 000 000 dry tons* o Date beach area first exceeds 5 594 FMSL - March 1 2012* o Expected and acmal production is as set forth in the following table Time Period Expected Tailings Sohds Disposition into CeU 4B Determined at the beginnmg of the penod (dry tons)* Expected Tailings Sohds Dispositio n into Cell 4B at the beginning of the penod multiplied by 150% Safety Factor (dry tons) Actual Taihngs Sohds Disposition into Cell 4B determined at end of the period (dry tons)* March 1 2012 to November 1 2012 150 000 225 000 225 000 November 1 2012 to November 1 2013 300 000 450 000 275 000 November 1 2013 to November 1 2014 200 000 300 000 250 000 N VDMT PlanVDMT Plan 01.30 12 Re so 11.4VTaibngs Mgnt Svstem and DMT Mo Plan Januarv 2012 re 114 edbne.docN VDMT PlonUulv 2011 DMT revision for permitVToibngs Mgnt System ond DMT Mon Plon July 2011 rev 11 2 rodbno doc White Mesa Mill - Standard Operating Procedures 07/1101/12 Revision Demson 11 43 Book 11 Environmental ProtecUon Manual Section 3 1 Page 52 of 53 *These expected and acmal tailings and production numbers and dates are fictional and have been assumed for illustrative purposes only Based on these assumptions and factors the freeboard limits for Cell 4B would be calculated as follows 1 Pnor to March 1.2012 Pnor to March 1 2012 the maximum elevation of the beach area in Cell 4B is less than or equal to 5 594 FMSL dierefore die freeboard limit is set at 5 594 6 FMSL 2 March 1. 2012 to November 1. 2012 The pool surface area would be reduced to the followmg amount (1-225 000 / (2 094 000 - 1 000 000)) x 40 acres = 31 77 acres Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by 31 77 acres equals 6 22 feet When die wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 6 99 feet This means that the freeboard limit for Cell 4B would be reduced from 5594 6 FMSL to 5592 2 FMSL (5594 6 FMSL nunus 6 22 feet rounded to the nearest one tenth of a foot) This calculation would be performed at March 1 2012 and this freeboard limit would persist until November 1 2012 3 November 1. 2012 to November 1. 2013 The pool surface area would be reduced to the following amount First recalculate the pool surface area that should have applied dunng the previous penod had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled actual tonnages for the penod Since the actual tonnage of 225 000 dry tons was the same as the modeled tonnage of 225 000 dry tons the recalculated pool surface area is the same as the modeled pool surface area for the previous penod which is 31 77 acres Then calculate the modeled pool surface area to be used for the penod (1 - 450 000/ (2 094 000 - 1 000 000 225 000)) x 31 77 acres = 15 32 acres Based on this reduced pool area the amount of freel)oard would be 197 5 acre feet divided by 15 32 acres equals 12 89 feet When the wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 13 66 feet This means that the freeboard limit for Cell 4B would be reduced from 5592 2 FMSL to 5586 7 FMSL (5600 35 FMSL minus 13 66 feet rounded to the nearest one tenth of a foot) This calculation would be performed at November 1 2012 and this freeboard linut would persist until November 1 2013 N.VDMT PlanVDMT Plan 01.30 12 Re si 11.4\Taibngs Ment Svstem and DMT Mo Plan Januarv 2012 re 11.4 redb e.docN VDMT PlanUulv 2011 DMT revision for ponmtVTaibngs Mgnt System ond DMT Mon Plon July 2011 rev 11 2 rodlme doc White Mesa Mill - Standard Operating Procedures 07/4401/12 Revision Denisonl 143 Book 11 Envu-onmental ProtecUon Manual Section 3 1 Page 53 of 53 4 November 1. 2013 to November 1. 2014 The pool surface area would be reduced to the following amount First recalculate the pool surface area that should have applied dunng the previous penod had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled acmal totmages for die penod Since modeled tonnages exceeded acmal tonnages the pool area was reduced too much dunng the previous penod and must be adjusted The recalculated pool area for the previous penod is (1-275 000/ (2 094 000 - 1 000 000 225 000) x 31 77 acres = 21 72 acres This recalculated pool surface area will be used as die starting point for the freeboard calculation to be performed at November 1 2013 Then calculate the modeled pool surface area to be used for the penod (1-300 000 / (2 094 000 - 1 000 000 225 000 - 275 000)) x 21 72 acres: 10 75 acres Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by 10 75 acres equals 18 37 feet When the wave mn up factor for Cell 4B of0 77 feet is added to this the total freeboard required is 19 14 feet This means that the freeboard limit for CeU 4B would be reduced from 5586 7 FMSL to 5581 2 FMSL (5600 4 FMSL minus 18 4 feet rounded to the nearest one tenth of a foot) This calculation would be performed at November 1 2013 and this freeboard limit would persist until November 1 2014 N.VDMT PlanVDMT Plan 01.30.12 Re isio 11 4VTailmgs Ment Svstem and DMT Mo Plan Januarv 2012 re 11.4 redb e docN-VDMT PlonUulv 2011 DMT revision for pormitVToibngs Mgnt Syatem and DMT Mon Plon July 2011 rev 11 2 redbno doc