DRC-2011-008360 - 0901a068803b3694

DENISON
MINES
if DRC-2011-008360
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
November 14, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: Denison Mines (USA) Corp. ("DUSA") White Mesa Mill Facility Response to 2nd Quarter, 2011 DUSA
DMT Performance Standards Monitoring Report and Cell 4A and Cell 4B Performance Standards
Monitoring Report (Dated August 31, 2011): Ground Water Quality Discharge Permit UGW370004:
DRC Findings, Confirmatory Action and Notice of Enforcement Letter
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's ("DUSA's") responses to the DRC Findings, Confirmatory
Action and Notice of Enforcement Letter, dated November 7, 2011.
We have re-quoted each of DRC's Findings and Confirmatory Action items and provided below, specific
responses to each item discussed in DRC's November 7, 2011 letter.
DRC Findings:
1. Part 3.1 (b) (v) of the GWDP requires DUSA to monitor and record weekly, the depth to wastewater in the
Cell 2 slimes drain access pipe to determine maximum and minimum head before and after a pumping cycle,
respectively. This information was not included in the Report.
DUSA Response:
See response to Confirmatory Action #1. The data has been provided in attached Tab A.
As discussed during DRC's telephone conference with DUSA on October 26, 2011, DUSA currently has one
DRC-approved DMT Plan, which addresses the DMT requirements set forth in the Radioactive Materials
License ("RML"), which has no quarterly reporting requirement, as well as those set forth in the Mill's GWDP,
which requires a quarterly DMT report. The quarterly DMT reports submitted by DUSA are intended to satisfy
the requirements in the GWDP, and are not intended to include information that is required to be monitored, but
not reported, by the RML. Information required by the RML is available for inspection at the Mill.
The requirement in Section 3.1(b)(v) of the DMT Plan is a requirement of the RML and is not a DMT
performance monitoring standard required by Parts I.D.3 or I.E.7 of the GWDP and hence is not required to be
included in the routine DMT Performance Standards Monitoring Report under Part I.F.2 of the GWDP.
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DMT.doc
Letter to Mr. Rusty Lundberg
November 14, 2011
Page 2
DUSA has provided the information requested in the DRC's November 7, 2011 letter for completeness of
response. However, as discussed during the telephone conference, DUSA intends to revise the DMT Plan by
preparing two separate plans for the GWDP and RML requirements. Following approval of the plans, DUSA
proposes to continue providing quarterly DMT reports addressing the GWDP DMT requirements only. Until
such time as the separate plans are approved, DUSA will continue to include the RML-required information in
the DMT report, if required by the Executive Secretary.
2. Appendix A to the Report presents weekly water surface elevations in the tailings cells and Roberts Pond.
Data for the week of April 29,2011 does not appear in the referenced Attachment A.
DUSA Response:
See response to Confirmatory Action #2, below. The data has been provided in attached Tab B.
3. DUSA began diverting tailings to Cell 4B on February 1, 2011. No solution pool elevation measurements
were taken until May 31, 2011. This is in violation of Part 3.1(a) of the BAT Plan. DRC previously noted this
violation during its review letter for the 1st Quarter Report dated August 31, 2011. During the 2nd Quarter of
2011 DUSA discovered this violation and returned to compliance.
DUSA Response:
No response required.
4. Part 3.1(d) of the DMT/BAT requires DUSA measure the size and maximum elevation of the tailings beach in
Cells 4A and 4B monthly. This information does not appear in the Report.
DUSA Response:
Based on the facts and background information included in Tab C of the Second Quarter 2011 DMT
Addendum, beach elevation measurements are no longer required for Cell 4A per the approved DMT Plan,
Revision 11.1, dated January 2011 and approved by DRC on January 20, 2011. Measurements ceased in
February 2011, after the approval for the use of Cell 4B was received from DRC. The remaining reference to
beach elevation measurements in Cell 4A in the currently approved DMT Plan, Section 3.1(d) is a typographical
error. The intent of Section 3.1(d).b, was clearly to remove the beach elevation measurements from all tailings
cells except Cell 4B. DUSA will submit a revised DMT Plan, for DRC review and approval, to correct this error.
DUSA proposes to submit two separate revised DMT Plans to address this correction as well as the separation
of requirements discussed in response to Comment Number 1, above, by January 14, 2012.
No beach elevation measurements have been conducted to date in Cell 4B, as there are no beaches present at
this time. Future beach elevation measurements will be conducted in Cell 4B when beaches are observed.
5. Part 3.1(a) of the DMT Plan requires DUSA to monitor the leak detection system for Cells 1 and 3 weekly.
The Plan requires DUSA to report the leak detection system as dry, or to report the fluid level in the system.
Detecting fluid triggers a requirement to extract the fluid, measure the extracted volume, and compute a
leakage rate for the cell. The 2nd Quarter DMT Performance Standards Monitoring Report contains no data for
either the Cell 1 or Cell 3 leak detection systems.
DENISON
MINES
Letter to Mr. Rusty Lundberg
November 14, 2011
Page 3
DUSA Response:
The requirement in Section 3.1 (a) of the DMT Plan is a requirement of the RML and is not a DMT performance
monitoring standard required by Parts I.D.3 or I.E.7 of the GWDP and hence is not required to be included in
the routine DMT Performance Standards Monitoring Report under Part I.F.2 of the GWDP.
DUSA has provided the information requested in DRC's November 7, 2011 letter for completeness of response.
However, as discussed during the above-mentioned telephone conference, DUSA intends to revise the DMT
Plan by preparing two separate plans for the GWDP and RML requirements. Following approval of the plans,
DUSA proposes to continue providing quarterly DMT reports addressing the GWDP DMT requirements only.
Until such time as the separate plans are approved, DUSA will continue to include the RML-required
information in the DMT report, if required by the Executive Secretary.
Monitoring results for the second quarter 2011 Cell 1 and 3 leak detection systems are included in the DMT
Addendum in Tab D and are discussed in Confirmatory Action #4.
As shown in Tab D of the Second Quarter 2011 DMT Addendum, Cell 3 leak detection system was dry for the
entire quarter, but Cell 1 had fluid level detections during this period. However, no fluid extraction or sampling
was required or took place as a result of the Cell 1 fluid detections. In regard to DRC's findings above
"Detecting fluid triggers a requirement to extract the fluid, measure the extracted volume, and compute a
leakage rate forthe cell." DUSA believe this to be incorrect. Cell 1 fluid measurements throughout the quarter
were minimal detections ranging from 4 inches on April 1, 2011 to 0.1 inches on June 30, 2011, and did not
consist of sufficient fluid to allow extraction or pumping. The currently approved DMT plan, Revision 11.1,
Section 3.1 .a states, "If sufficient fluid is present in the leak detection system of any cell, the fluid shall be
pumped from the LDS, to the extent reasonably possible, and record the volume of fluid recovered. Any fluid
pumped from an LDS shall be returned to a disposal cell." DUSA believe the fluid detections in Cell 1 were
residual fluid which could not be removed from the last Cell 1 leak detection system pumping event on August
8, 2010. In an August 18, 2010 letter from DUSA to DRC, DUSA described in detail the root cause of significant
fluid levels in the leak detection system which required extraction and sampling on June 3, 2010 and August 8,
2010 to possibly be a break in the Cell 1 liner near the surface level of the cell, and included a detailed plan for
the repairs to the liner which began in September 2010 and are ongoing. The August 18, 2010 letter is included
in Tab D of the Second Quarter 2011 DMT Addendum.
6. Part 1.D.6(b) of the GWDP specifies a head-dependent allowable leakage rate through the Cell 4A flexible
membrane liner. Part 3.1 (a) of the BAT Plan reiterates this requirement. In light of the spillway between Cell 4A
and Cell 4B, the DRC removed the requirement to measure the Cell 4A solution pool elevation to demonstrate
compliance with freeboard requirements for the cell. When DUSA placed Cell 4B into service on February 1,
2011, measurement of the solution pool elevation in Cell 4A ceased. The result of terminating the Cell 4A
monitoring was a lack of data to use to calculate the allowable leakage rate through the flexible membrane liner.
This failure to monitor persisted through the end of the 2nd Quarter of 2011. DRC addressed this issue in
conjunction with the review of the 1st Quarter Report. DUSA has now returned to compliance with respect to this
monitoring requirement.
DUSA Response:
No response required.
7. Part I.E.8(a)(1) of the GWDP requires DUSA to provide continuous operation of the Cell 4A LDS pumping
and monitoring equipment, and to make such equipment operational within 24 hours of discovery of a failure of
such equipment. On June 27, 2011 Mill personnel discovered that the LDS monitoring data logger had ceased
DENISON
MINES
Letter to Mr. Rusty Lundberg
November 14, 2011
Page 4
to record on June 7, 2011. Plant personnel rebooted the system and observed resumption of data logging.
Plant personnel checked the logger more frequently following the reboot, and repeated the system reboot on
July 1,2011. Upon discovery that rebooting the system did not correct the failure, DUSA consulted with the
equipment manufacturer for trouble shooting and repair advice. DUSA has restored the data logging equipment
to compliant operation, including installation of an upgraded version of the data management software during
July, 2011. Failure to repair a failed system and bring it to full operation within 24 hours constitutes a violation of
Part I.G.3 of the GWDP.
DUSA Response:
No response required.
DRC Confirmatory Action:
1. DUSA will provide the weekly inspection sheets and a data table summarizing the weekly maximum and
minimum fluid level in the Cell 2 Slimes Drain for the 2nd quarter of 2011 to the DRC as an addendum to the
2nd Quarter DMT Performance Standards Monitoring Report. All future DUSA DMT Performance Standards
Monitoring Reports will include weekly inspection sheets and a data table presenting the weekly maximum and
minimum fluid level in the Cell 2 Slimes Drain.
DUSA Response:
See the response to Number 1, above. As requested, the Cell 2 Slimes data for the second quarter of 2011 are
included in Tab A of the Second Quarter 2011 DMT Addendum.
2. DUSA will provide a revised Attachment A to the report that includes the weekly water surface elevations in
the tailings cells and Roberts Pond for the week of April 29, 2011.
DUSA Response:
The omission of data from the week of April 29, 2011 was an oversight. As requested, the revised weekly water
surface elevations in the tailings cells and Roberts Pond, which now include the week of April 29, 2011, are
included in Tab B of the Second Quarter 2011 DMT Addendum.
3. DUSA will provide the monthly survey data and a data table summarizing the tailings beach area and
maximum elevation for each month of the 2nd quarter of 2011. All future DUSA DMT Performance Standards
Monitoring Reports will include monthly survey data and a data table presenting the tailings beach area and
maximum elevation for each month
DUSA Response:
As explained above, no beach elevations were observed in the 2nd Quarter of 2011. Future beach elevation
measurements will be conducted and included in the Quarterly DMT reports for Cell 4B when beaches are
observed.
DENISON;
MINES
Letter to Mr. Rusty Lundberg
November 14, 2011
Page 5
4. DUSA will provide the leak detection system monitoring results for Cells 1 and 3 in a table for each week of
the 2nd quarter of 2011. All future DUSA DMT Performance Standards Monitoring Reports will include leak
detection system monitoring results for Cells 1 and 3 in a table for each week of the monitoring period.
DUSA Response:
See response Number 5, above. As requested, a table including the leak detection system monitoring results
for Cells 1 and 3 is included in Tab D of the Second Quarter 2011 DMT Addendum.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISON
MINES
WHITE MESA URANIUM MILL
ADDENDUM TO 2nd Quarter 2011
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A and
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORT
Reporting Period
April through June
2011
State of Utah
Groundwater Discharge Permit No. UGW370004
Prepared By:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO. 80265
November 14, 2011
TABLE OF CONTENTS
1.0 INTRODUCTION 1
2.0 ADDENDUM ORGANIZATION AND CONTENTS 1
3.0 VERIFICATION 3
4.0 SIGNATURE AND CERTIFICATION 4
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INDEX OF TABS
Tab A - Cell 2 Slimes Drain Liquid Levels
Tab B - Tailings Pond Elevations
Tab C - Tailings Beach Elevations
Tab D - Cell 1 and Cell 3 Leak Detection Systems
Tab E - Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head
Conditions in Cells 4A and 4B
ii
WHITE MESA URANIUM MILL
ADDENDUM to 2nd Quarter 2011
DMT PERFORMANCE STANDARDS MONITORING REPORT AND CELL 4A AND
CELL 4B BAT PERFORMANCE STANDARDS MONITORING REPORTS
1.0 INTRODUCTION
This is an Addendum to the Second Quarter Discharge Minimization Technology ("DMT")
Performance Standards Monitoring Report prepared by Denison Mines (USA) Corp.
("Denison"), as required under Part I.F.2 of the White Mesa Mill's (the "Mill's") State of Utah
Groundwater Discharge Permit No. UGW370004 (the "GWDP"), and the Routine Cell 4A and
Cell 4B Best Available Technology ("BAT") Performance Standards Monitoring Reports for the
second Quarter, as required under Part LF.3 of the GWDP.
This Addendum is being prepared in response to the October 26, 2011 teleconference between
State of Utah Division of Radiation Control ("DRC") and Denison as documented in the DRC
letter dated October 27, 2011 (received by Denison on November 7, 2011). The October 27,
2011 letter transmits the DRC findings, Confirmatory Actions and Notice of Enforcement
Discretion. This Addendum provides the information requested in the aforementioned October
27, 2011 letter.
2.0 ADDENDUM ORGANIZATION AND CONTENTS
This Addendum consists of the following items:
Tab A - Tab A includes the Weekly Tailings Inspection Forms as well as a summary table of the
Cell 2 slimes drain data for second quarter 2011. The Weekly Tailings Inspection Forms are
included in response to the DRC request for the second quarter 2011 Cell 2 slimes drain liquid
level measurements. The Cell 2 slimes drain measurements are recorded in item number 2 of the
Weekly Tailings Inspection Forms.
Tab B - Tab B contains a revision to the Tailings Pond Elevations Measurement Summary
originally submitted August 31, 2011 with the routine second quarter DMT Report. The data for
the week of April 29, 2011 was inadvertently omitted from the original report submitted August
31, 2011. No changes will be made to the routine DMT report as a result of this submission
because these data are already included in the routine reports. These data are being submitted as
a correction to previously submitted report.
Tab C- Tab C includes the background documentation discussed below for beach elevation
measurements in Cells 4A and 4B.
Facts and background information regarding the measurement of beach elevations are as follows:
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a) Beach elevation measurements are required for the calculation of annual Freeboard limits as
specified in 6.3.5 of the White Mesa Mill Tailings Management System and Discharge
Minimization Technology Monitoring Plan ("DMT Plan") Revision 11.1 dated January 2011. It
is important to note that freeboard limits are only calculated for Cell 4B. The Freeboard limit for
Cell 4B is set assuming that the total PMP flood volume for Cells 2, 3, 4A, and 4B will be
accommodated in Cell 4B.
b) Beach elevation measurements for Cell 4A were completed from second quarter 2009 when
beaches were first reported, through first quarter 2011. The last measurement of beach
elevations in Cell 4A was conducted February 18, 2011 (first quarter 2011).
c) The currently approved revision of the DMT Plan is Revision 11.1 dated January 2011.
d) Approval for the DMT Plan, Revision 11.1, dated January 2011, was transmitted to Denison
via correspondence from DRC, dated January 20, 2011 (Attached in Tab C).
e) Prior to Denison receipt of the approval for the DMT Plan, Revision 11.1, dated January 20,
2011, Denison submitted several draft iterations and revisions of the DMT Plan in preparation
for placing Tailings Cell 4B into service. The draft revisions of the DMT Plan incorporated
changes required to address the newly constructed Cell 4B.
f) DRC comments in a letter dated January 6, 2011 to the Draft DMT Plan, Revision 11.0, dated
November 12, 2010, provided Denison with several options regarding the approval of the DMT
Plan with regard to the inclusion or exclusion of Cell 4A freeboard limits. Denison chose to
remove the Cell 4A freeboard requirements (including beach elevation measurements) and await
DRC approval of the DMT Plan, Revision 11.1, dated January 2011 prior to DRC authorization
for use of Cell 4B. Approval of the DMT Plan, Revision 11.1, dated January 2011 allowed the
removal of the Cell 4A Freeboard limits and the requirements to measure beach elevations
associated with the calculation of Cell 4A Freeboard limits on an annual basis. Denison's
response to DRC's comments letter is included in Tab C.
g) The DMT Plan, Revision 11.1, dated January 2011 requires the measurement of beach
elevations in Cell 4B only, as specified in Section 3.1(d).B and on the Weekly Tailings
Inspection Form included in Attachment A of the DMT Plan. The DMT Plan, Revision 11.1
reference cited in the DRC letter dated October 27, 2011 is correct in noting that Section 3.1(d)
states that beach elevations will be measured monthly in Cells 4A and 4B. The text in Section
3.1(d) which states that beach elevations in Cell 4A will be measured is a typographical error,
which will be corrected by revision of the DMT Plan.
h) Beach elevation measurements were not conducted in Cell 4B during the second quarter 2011
because there were no beaches in Cell 4B in the second quarter of 2011. It is important to note
that as of the date of this Addendum, beach elevations have not been measured in Cell 4B
because there are no beaches in Cell 4B. Currently, Cell 4B receives fluids only.
2
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In summary, based on the above facts and background information, beach elevation
measurements are no longer required for Cell 4A per the approved DMT Plan, Revision 11.1,
dated January 2011 and approved by DRC on January 20, 2011. Measurements ceased in
February 2011, after the approval for the use of Cell 4B was received from DRC. The remaining
reference to beach elevation measurements in Cell 4A in the currently approved DMT Plan,
Section 3.1(d) is a typographical error. The intent of Section 3.1(d).B, was clearly to remove the
beach elevation measurements from all tailings cells except Cell 4B. The DMT Plan will be
revised to correct this error. No beach elevation measurements have been conducted to date in
Cell 4B, as there are no beaches present at this time. Future beach elevation measurements will
be conducted in Cell 4B when beaches are observed.
Tab D - Tab D includes a summary table of the Cells 1 and 3 Leak Detection Systems ("LDS")
data for second quarter 2011. Additionally, DUSA's August 18, 2010, letter "State of Utah
Ground Water Discharge Permit ("GWDP") No. UGW370004 White Mesa Uranium Mill - Plan
and Schedule for Cell 1 Inspection and Repairs" is included to provide background information
on the Cell 1 liner repairs. The last time liquid was detected at sufficient volume to be pumped
from the LDS system was on August 8, 2010. Per the currently approved DMT Plan, "If
sufficient fluid is present in the leak detection system of any cell, the fluid shall be pumped from
the LDS, to the extent reasonably possible, and record the volume of fluid recovered. Any fluid
pumped from an LDS shall be returned to a disposal cell." (3.1.a) The fluid was pumped to the
extent reasonably possible, although a minimal level of fluid, insufficient to allow pumping,
remains in the LDS system. Minimal fluid detections were seen in the Cell 1 LDS in the second
quarter of 2011, but the detections were not sufficient to allow extraction or pumping.
Tab E - Equation/formula for maximum daily allowable LDS flow volume for varying head
conditions in the cell. Tables IA and IB from the Best Available Technology ("BAT")
Operations and Management Plan, Revision 2.2 have been included for ease of review. Tables
IA and IB are routinely provided in the quarterly DMT reports. The methods of calculation for
second quarter 2011 are also included in Tab E. Future routine DMT reports will include a copy
of the equation/formula methods, the quarterly calculations, and Tables IA and IB.
3.0 Verification
Except as set out above by this Addendum, the contents of the Second Quarter DMT
Performance Standards Monitoring Report, as submitted on August 31, 2011, remains
unchanged.
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4.0 SIGNATURE AND CERTIFICATION
This document was prepared by Denison on November 14, 2011.
Denison Mijies (LJSA) Corp.
By:
David C/Fryojenlund
Vice President, Regulatory Affairs and Counsel
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CERTIFICATION:
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant penalties for submitting false information,
including^ne possibility of fine and imprisonment for knowing violations.
Davidr C. Ffydenlund
Vice President, Regulatory affairs and Counsel
Denison Mines (USA) Corp.
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
Date: M/l/26l(
1. Pond and Beach
elevations (msl, ft)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ""fLin^r tio/f'^a^ (rofdt\ r\)mtf
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation
_5597„
U*2£L
.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 SkR-Hk
(b) FML Bottom Elevation 5612.3_
(c) Depth of Water above FML ((a)-(b)) ~7-14
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly. ii
£.HQl Depth to liquid pie-pump
^•OM Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pumpjiead is 38' -Depth to Liquid Post-
pump
lump neaa l
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump:.
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? ^ no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settings\dturk.DMC\Local SettingsXTemporary Internet Rles\Content.Outlook\VM3Y6S llNTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: H"#-U Inspectors: C^r^t-r^ QIXA\A+.&*J- ^ TA.^^^r l"Vc? 1
1. Pond and Beach Cell 1: (a) Pond Solution Elevation jg>£ £°\
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) \5.M
Cell 4A: (a)Pond Solution Elevation S^A
(b) FML Bottom Elevation 5555.14__
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation A/s^
(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 £>D 3D* 3^
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) 03
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
_Depth to Liquid pre-pump
£2-5 . 5 ^ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump = \7-~
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Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denison 11.1
Book 11: Environmental Protection Manual, Section 3.1 Page 30 of 49
7. Contaminated Waste Dump: L&Q KS £&e>Q^
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? I—^ 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.
CADocuments and Settings\dturk.DMC\Local SettingsYTemporary Internet Fiks^ontent.Outlook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline doc
White Mesa Mill 4 Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: ^ //<*/ // Inspectors: •^T^nn^r rLll'./L,^ ^.
1. Pond and Beach Cell 1: (a) Pond Solution Elevation $fclfl..£3i
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) 15
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14__
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation Bta>2D
, (b)FML Bottom Elevation 5612.3
(c)Depth of Water above FML ((a)-(b)) &*ZO
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly ^ ^t^S
_Depth to Liquid pre-pump
.Depth to Liquid Post-pump
VW\>W +0 ^cr^rpry (aU measurements are depth-in-pipe)
le&Y A,0yO ^6 (X. \jeok'./\A Pre-pump head is 38'-Depth to Liquid Pre-pump -
V Wtf^C. j FU|V\ p \ S Turncjl Post-pump head is 38' -Depth to Liquid Post-
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Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Contaminated Waste Dump: JLnok'^
01/11 Revision: Denison 11.1
Page 30 of 49
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? «^no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
0
0
CADocuments and Settings\dturk.DMC\Local Setungs\Temporary
Mon Plan Nov 2010 Rv II 1 - Redline.doc
Internet Piles\ContentOutlook\VM3Y6SlI\Tailings Mgnt System and DMT
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: t/jUL/ftDU Inspectorsi^Mtr HMMA fcuiftrx
1. Pond and Beach Cell 1: (a) Pond Solution Elevation SU^U)
elevations (msl, ft)
(b) FML Bottom Elevation 5597__
(c) Depth of Water above FML ((a)-(b)) 1^.4>
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14_
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation 5fc3.C>15
(b) FML Bottom Elevation 5612.3.
(c) Depth of Water above FML ((a)-(b)) 3 HE
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly 1 fc-S .
Depth to Liquid pre-pump
Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38* -Depth to Liquid Post-
pump =
V>*ofcL 4e> perQr>x JU
AMfcl^ Recoup TczV
C.\Documents and Settirtgs\dturk.DMC\Local SettingsYFemporary Internet Files\ContentOutIook\VM3Y6SlI\Taihngs Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redlme.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denisonll.I
Page 30 of 49
7. Contaminated Waste Dump: U«*Ks gooA]
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? ^ no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settings\dturk.DMC\Local SettingsVTemporary Internet PiIes\Content.OuUook\VM3Y6Sl lYTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: ^-Jf-jf Inspectors:^fa/>n&r Ah/J,J/iy .£^*<5>ch .er/y,*
1. Pond and Beach Cell 1: (a) Pond Solution Elevation 77
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) IS. 7*
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation 36<2 /, p3
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) ff 73
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly yp.S
£^.£5 Depth to Liquid pre-pump
3 5-.3 7 Depth to Liquid Post-pump
(all measurements are depth-in~pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump = f^.&S
CADocuments and Settings\duirfc.DMC\Local SettingsXTeraporary Internet FUes\Content.Outlook\VM3Y6SlI\Tailings Mgnt System and DMT
Moo Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump: Aceofcrs- &s>si,f) v
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settings\dturk.DMC\Local SettingsYTemporary Internet Files\ContentOutlook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv III* Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: ^/^/ZQi I Inspectors: ••j^^r HPH'/L-^ . /rhrr.Vv & W-
1. Pond and Beach Cell 1: (a) Pond Solution Elevation Sk)3>.
elevations (msl, ft)
(b) FML Bottom Elevation 5597.
(c) Depth of Water above FML ((a)-(b)) te.lA
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation ^^Q'^
(b) FML Bottom Elevation 5612.3.
(c) Depth of Water above FML ((a)-(b)) ^,0
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly te-S
23. CS Depth to Liquid pre-pump
. 3 Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
IM.3S
Post-pump head is 38* -Depth to Liquid Post-
pump = 13
C:\Documents and SeUingsWhnk.DMC\Local Settings\Temporary Internet FilesVCon(entOudook\VM3Y6StATailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 1II - Redline doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump: L^KS k*->A
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? <S 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.
C:\Documents and Settings\dturk.DMC\Local SetungsYTemporary Internet Files\Content.Outlook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 • Redline doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denisonl 1.1
Book 11: Environmental Protection Manual, Section 3.1 Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: Inspectors: ^ih\c(rr,^ Tanner HdHtfoy f ^tCMfe/rtc
1. Pond and Beach Cell 1: (a) Pond Solution Elevation £>tt>/A,37
elevations (msl, ft)
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((a)-(b)) JS>37
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14__
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts ^
Pond: (a)Pond Solution Elevation £to£l 53
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) 7.ZS
o
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly i/eS
Depth to Liquid pre-pump
o?&- 76 Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38* -Depth to Liquid Post-
pump as jifll.
o C:\Documents and Settings\dturk.DMC\Local Settings\Temporary Internet Fdes\COTtentChiac«k\VM3Y6SmTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Conteminated Waste Dump: A/XliCS ^OOc)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? {/ no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Setungs\dturic.DMC\Local SettingsYTemporary Internet Fdes\ContenLOudcwk\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - RedIine.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: jS * %Q' -I Inspectors: &&>rri+- fkl^A,g.r
1. Pond and Beach Cell 1: (a) Pond Solution Elevation £&\1M\
elevations (msl, ft)
(b) FML Bottom Elevation 5597.
(c) Depth of Water above FML ((a)-(b)) l-S-Hl
Cell 4A: (a)Pond Solution Elevation AS*
(b) FML Bottom Elevation 5555.14_
(c) Depth of Water above FML ((a)-(b)) -
Cell 4B: (a)Pond Solution Elevation >v*A
(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 5£\U.^
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) £.t£^
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly.
Depth to Liquid pre-pump
, H. Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump = _JI__
C:\Documents and Settings\dturk.DMC\Local SettingsVTemporary Internet Fiks\ContentOutlook\VM3Y6S1 lYTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denisonl 1.1
Book 11: Environmental Protection Manual, Section 3. t Page 30 of 49 , ^
7. Contaminated Waste Dump: f^&O f*t>t>A (jL**Z$\ bc^~> tf^wt^r «
is
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrape liner (solution £\ ^
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? __\y^no yes V*
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.
C:\Documents and Settings\dtmicDMC\LocalSettingsYTemporary Internet FUes\ContenLOiitlook\VM3Y6SlI\TaUings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
Date:
1. Pond and Beach
elevations (msl, ft)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ^)lr\l\fir r)o\\U*^f (raff IA fLU
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation
5597
_5555.14__
(c)Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation 3580.75
(b)FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b)) 3ff ^5
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation Sflx.&ol
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) 4>.3Sl
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly i&S
Depth to Liquid pie-pump
O . ^ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump •=
Post-pump head is 38' -Depth to Liquid Post-
pump =-J&23
C:\Documents and Settings\dnirt.DMC\LocaI SettingsYTemporary Internet FUes\Content.OutIookVVM3Y6SlI\TaiUngs Mgnt System and DMT Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denisonll.l
Page 30 of 49
7. Contaminated Waste Dump: l&t>k.s ^o&X.
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? ^ no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settings\dturk.DMC\Local SettingsVTemporary Internet FUes\ContenLOudook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: C/z/xoi\ Inspectors: -iC^ IIOU-XQAM (^M*, M<£«
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)) 15 .AO
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14.
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b))
(d)Elevation of Beach Area with Highest Elevation
(monthly) _
Roberts
Pond: (a)Pond Solution Elevation TVcy
(b) FML Bottom Elevation *~%6X23
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
£.5 45 Depth to Liquid pre-pump
g-5 . 7f> Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump =- 19»s2B
C:\Docuraents and SetUngs\dturk.DMC\Local SettingsVTemporary Internet PJJes\Content Oudook\VM3Y6SIIVraibngs Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump: Doomp LocMs G-*>h\
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? S 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.
C:\Documents and Settmgs\dturk.DMC\Local SettingsYTemporary Internet Fu«\ContentC)uUook\VM3Y6SlATaiIings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: &'\Q~\\ Inspectors: /^A^.^ flayer, T^<T *Ml
1. Pond and Beach Cell 1: (a) Pond Solution Elevation £>*4l I
elevations (msl, ft)''
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML (VaWhYl 16.1 SL
Cell 4A: (a)Pond Solution Elevation A//A
(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)) .4>l
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation b^M
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
_Depth to Liquid pre-pump
•2 3.30 Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
13. OH
Post-pump head is 38' -Depth to Liquid Post-
pump = I %. \
C:\Documents and Setnngs\dtuifcDMCVLocaJ Settings\Teraporary Internet Files\Content.Outlook\VM3Y6S1 IYTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv II1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump: t^(Stt¥\.S £?&o(\.
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? <^no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C:\Documents and Settmgs\dturk.DMC\LocaI SettingsVTemporary Internet Files\Content.OutIook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denisonll.l
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: 6>~l 7~2c>\t Inspectors: &y&<si ^nhld//r)as\ € HdiU
1. Pond and B each Cell 1: (a) Pond Solution Elevation
elevations (msl, ft)
(b) FML Bottom Elevation 5597.
(c) Depth of Water above FML ((a)-(b)) A5".
Cell 4A: (a)Pond S olution Elevation
(b) FML B ottom Elevation 5555.14.
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation £5*$ I * 5 7
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b)) 3W.Q?
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts . .j.
Pond: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b)) ^
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
0 . » . Depth to Liquid pre-pump
^IttYke^ foe fa lYlfajhly Depth to Liquid Post-pump
S J (ifY\ (an measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump =
C:\Docurnents and Settings\dturk.DMC\Local SettingsNTemporary Internet FiIes\ContentOutIook\VM3Y6SlI\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denisonl 1.1
Book 11: Environmental Protection Manual, Section 3.1 Page 30 of 49
7. Contaminated Waste Dump:. >yg>*rr (port
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? \_S 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.
C:\Documents and Settings\dtuxk.DMCVLocaI SettingsVTemporary Internet FiIes\ContenLOutlook\VM3Y6Sll\Tailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 I - Redline.doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denisonl 1.1
Book 11: Environmental Protection Manual, Section 3.1 Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: 6> ' ^XH" \\ Inspectors: /urnA. POAJ^AT-^ {LyAS^ $^z.r*^
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)) 2D. tA
Cell 4A: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5555.14_
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b)) 3*3- 37 /
(d)Elevation of Beach Area with Highest Elevation V
(monthly)
Roberts
Pond: (a)Pond Solution Elevation ^^6l3: (b) FML Bottom Elevation 5613.3.
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
Q-O- \ f? Depth to Liquid pre-pump
%3. & ~7 Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump = 2 23-Post-pump head is 38' -Depth to Liquid Post-
pump = )H»33
C:\Documeats and Settings\dturk.DMC\Local SettingsVTemporary mternetFi!es\Content.Oudook\VM3Y6Sll\Taitings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denison 11.1
Page 30 of 49
7. Contaminated Waste Dump: u^"""""' l^Otj K S> /s>(2>oeA^
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? £^no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
C.VDocuments and SettmgsVdmrk.DMaLa^Settmgs\Temporary Internet Rles\Content.OuUc<)k\VM3Y6SlI\TaiJings Mgnt System and DMT
Mon Plan Nov 2010 Rv 11 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
01/11 Revision: Denisonll.l
Page 28 of 49
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: *7- I" ii Inspectors: /^cxrt\^ P&.\AA<S-] T^^tr ffett iV^*^
1. Pond and Beach Cell 1: (a) Pond Solution Elevation 3A\\./(S
elevations (msl, ft)
(b) FML Bottom Elevation 5597,
(c) Depth of Water above FML ((a)-(b))
Cell 4A: (a)Pond Solution Elevation "~
(b) FML Bottom Elevation 5555.14__
(c) Depth of Water above FML ((a)-(b))
Cell 4B: (a)Pond Solution Elevation S$20. fiQ
(b) FML Bottom Elevation 5557.50
(c) Depth of Water above FML ((a)-(b)) £23. ? 4
(d) Elevation of Beach Area with Highest Elevation
(monthly) .//A
Roberts
Pond: (a)Pond Solution Elevation WC**/
(b) FML Bottom Elevation 5612.3
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly
_Depth to Liquid pre-pump
L3-Ji3L_Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump = _l£j#
C:\Documents and Settings\dturk.DMC\Local SettingsYXeraporary Internet Files\Content.Outlook\VM3Y6SII\TaiIings Mgnt System and DMT
Mon Plan Nov 2010 Rv II 1 - Redline.doc
White Mesa Mill - Standard Operating Procedures 01/11 Revision: Denison 11.1
Book 11: Environmental Protection Manual, Section 3.1 Page 30 of 49
7. Contaminated Waste Dump: l^&O ICS h&G (K.
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? ^^-no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
CXDocuments and SettfogsVdturk.DMCVLocal SetnngsYTemporary Internet FUes\Content.Outlook\VM3Y6Sl IVTailings Mgnt System and DMT
Mon Plan Nov 2010 Rv 111 - Redline.doc
Tailings Pond Elevations
2nd Quarter Elevations
Date CelM Cell 32
Free Board1 5615.40 5602.50
4/1 /2011 5613.39 No longer required
4/8/2011 5612.69 No longer required
4/15/2011 5612.62 No longer required
4/22/2011 5612.68 No longer required
4/29/2011 5612.77 No longer required
5/6/2011 5612.52 No longer required
5/13/2011 5612.37 No longer required
5/20/2011 5612.41 No longer required
5/27/2011 5612.32 No longer required
6/3/2011 5612.20 No longer required
6/10/2011 5612.12 No longer required
6/17/2011 5612.04 No longer required
6/24/2011 5611.89 No longer required
7/1/2011 5611.65 No longer required
Roberts Pond Cell 4A
5624.00
5619.5
5620.3
5620.5
5620.8
5621.0
5621.3
5621.5
5619.0
5618.6
DRY
Dry
5619.1
Dry
Dry
5593.74
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Inadvertently
omitted
Cell 4B 4
5594.60
5580.75
**
5581.11
5581.59
5580.87
5580.69
* The wastewater elevations were not measured in Cell 4B at the beginning of the quarter because the fluid levels
were below the the level at which the survey can be conducted from the bank of Cell 4B.
** The weekly measurement for June 3, 2011 was not conducted during the construction of a platform and walkway
Measurements resumed the week of June 10, 2011.
1 Freeboard as permitted under License condition 10.3 is no longer applicable to Cell 3 or Cell 4A.
Cell 3 is nearly full of solids, is undergoing pre-closure steps, and the freeboard limit specified here is no longer
required and the weekly measurements are no longer required per the January 27 and March 14, 2011 letters from
DRC.
3 The freeboard limit for Cell 4A is not set out in the License. The freeboard limit of 5,593.74 for Cell 4A is set out
in a letter from the Executive Secretary dated November 20, 2008. Denison proposed in the DMT Plan revision
dated November 12, 2010 the removal of the freeboard limit for Cell 4A to be replaced by a freeboard limit for new
Cell 4B that will accommodate the freeboard requirements of Cells 2, 3, 4A, and 4B. The Executive Secretary
granted a variance from the Cell 4A freeboard limit on January 13, 2011 and approved the removal of the Cell 4A
limit and the use of Cell 4B on January 27, 2011. The weekly measurements are no longer required for compliance
with freeboard hmts. The measurements have resumed in Q3 2011 to complete the daily leakage rate for Cell 4A.
4 The freeboard limit listed is the value specified in the DMT plan when the pool surface area is 40 acres. A pool
surface area of 40 acres is used because there are no beaches present in Cell 4B at this time.
DENISON
MINES
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
January 10, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Re: State of Utah Ground Water Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Documents Addressing White Mesa Uranium Mill New Cell 4B and Response
to Division of Radiation Control ("DRC") Letter of January 6, 2011 Regarding Comprehensive
Comments on Proposed Revised Plans
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Tailings Management System
and Discharge Minimization Technology Monitoring ("DMT") Plan, and the Best Available Technology
Operations and Maintenance ("BAT O&M") Plan for the White Mesa Mill which are currently pending UDEQ
approval. This letter also responds to DRC's letter of January 6, 2011 requesting additional changes to
previously submitted versions of these documents. Per DRC's letter, we understand that the Contingency
Plan will be addressed separately and changes will not be tied to approval for use of Cell 4B or the New
Decontamination Pad.
DRC received the October 11, 2010 letter requesting changes to previously submitted versions of the DMT
Plan BAT O&M Plan, and Contingency Plan. To address those comments and other changes necessary for
operation of Cell 4B, Denison submitted on November 12, 2010 redline and clean copy revisions of those
documents entitled DMT Plan Revision 11, BAT O&M Plan Revision 2.0 and Contingency Plan Revision 4.0.
DRC reviewed those submittals and requested additional changes to the DMT and BAT O&M Plans in the
letter of January 6, 2011. Denison has accepted all the changes submitted on November 12, 2010 to create
new black-line copies of the DMT and BAT O&M Plans, and has prepared the additional changes, in
response to DRC's January 6, 2011 letter, as redlined markups, entitled DMT Plan 11.1 and BAT O&M Plan
Revision 2.1, These revisions have been provided, respectively, as Attachments 1 and 2 to this letter.
For ease of review, both of the revised documents have also been provided as clean file versions with all
changes accepted. Denison requests that UDEQ review and approve the versions attached to this letter,
which consolidate into one set of documents all changes submitted by Denison since September 2008, for
which Denison is awaiting DRC approval.
N:\Cell 4B\January 10 2011 Submittals and Revisions for Cell 4B\01.10.11 Transmittal to DRC Plan Revisions for Cell
4B.doc
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 2
We have also provided, below, specific responses to each request in UDEQ's January 6, 2011 letter. The
sections and numbering of the remainder of this letter follow the DRC January 6, 2011 letter. Each UDEQ
request is shown in italics, below, followed by Denison's response.
DEQ Comments and Responses
The Contingency Plan (11/2010 Revision: DUSA-4)
Please be aware that in order to expedite the Cell 4B review process, that DRC review of the Contingency
Plan will be addressed under separate cover, proceed independently, and not be tied to the use of the NDP
nor Cell 4B. The following is noted for future reference:
A. In the subject November 12, 2010 letter, DUSA provides proposed red-line and clean versions
of the Contingency Plan version noted, which include aspects regarding Cell 4B.
B. The third paragraph as well as Section 2 .a. 1ofa September ,2010 DUSA letter discusses
contingency plan comments in our May 10,2010 letter.
Denison Response: No response required.
The DMT Plan (11/2010 Revision: DUSA-11
1. We acknowledge a section of paragraph 3.1.e.i.D has been changed appropriately to read that, "...
The depth to water from the top... of any of the three (3) observation ports to the standing water
shall be no less than 6.2 feet." It appears that incorporation of this item into an approved DMT
Plan would complete the issues regarding the NDP with respect to DMT Plan adjustments.
Denison Response: No response required.
2. The DMT Plan (as well as the O&M Plan), incorporating necessary items for Cell 4B, must be approved
prior to DRC authorization of use for Cell4B. Regarding freeboard requirements, the Plans proposed by
the subject DUSA November 12, 2010 letter make the assumption that Cell 4B is currently authorized for
use, and it is not necessary to establish a freeboard for Cell 4,A. However, this is incorrect. This
approach DUSA has taken appears to necessitate one of the following:
a. That the last action prior to authorizing use of Cell 4B must be the approval of the DMT Plan (and
the O&M Plan), or
b, To obtain approval of the DMT and O&M Plans now, DUSA change the plans to establish the
freeboard for Cell 4A. to be one of the following, either:
(1) . The fixed freeboard elevation for Cell 4A, established by the DRC freeboard
variance letter of November20, 2008, or
(2) . Change the current freeboard determination verbiage proposed in these Plans be more
robust. This would include that the freeboard for Cell 4A or Cell 4B, as may be applicable, would
be established by the rigorous freeboard calculation method outlined in former proposed Plans,
but would be written such that if Cell 4B becomes approved, that the freeboard determination
method would no longer be needed for or apply to Cell 4A.
Please provide DRC your decision to us in this regard, together with any and all necessary
corresponding changes to the DMT Plan.
DENISON
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 3
Denison Response: Denison has chosen option (a.) above and will request the approval of the DMT Plan and
the O&M Plan as the last action prior to the UDEQ authorization for the use of Cell 4B. As such, the changes
requested regarding the reintroduction of Freeboard limits for Cell 4A are not necessary.
3. The following changes in DMT Plan forms, related to tailings beach elevations, are needed due to the
need to measure beach elevations in tailings Cells 4A or 4B, as applicable ( per paragraph 2 above).
This issue was brought to your attention earlier in our letter dated October 11, 2010. The freeboard for
these ponds is determined from the use of such (see paragraph 6.3 and Appendix F of the DMT Plan):
a. On page 28 of 49 in Appendix A of the submitted clean copy of the Plan:
(1) The heading numbered as one, near the left margin on that page; must state "Pond and Beach
elevations... ,"the following earlier proposed DMT Plan versions also contained this provision;
(a) . 12/08 Revision: Denison-7,
(b) . 05/09 Revision: Denison-8, and
(c) . 3/10 Revision:Denison-9.
(2) In the corresponding page of the submitted red-line version (i.e. page 33 of 56), item number
one contains sections for Cell 4A. and Cell 48. An item (d) stating "Elevation of Beach Area with
the Highest Elevation (monthly)," must be added into the sections on this page for each of
these cells, as applicable with paragraph 2 above. (Earlier proposed DMT Plan versions
contain this item (d) for Cell 4A, in the versions given in paragraph 3.a. above).
b. Section 3.l.d.vii, paragraph C should be labeled as paragraph B. The title of this paragraph should be
"Cell 4A or 4B Beach Elevation," as needed and applicable with paragraph 2 above. The body of that
paragraph should indicate that the beach elevation survey will be in Celt 4.A, or Cell 4B as applicable.
(If Cell 4B becomes approved for use, it then will be is no longer necessary to establish freeboard
elevation for Cell 4A).
Denison Response:
3.a.(1) The heading has been changed as requested.
3.a.(2) The requested text "Elevation of Beach Area with the Highest Elevation (monthly)," has been
added to Cell 4B only. As previously stated, Denison is requesting UDEQ approval of the DMT Plan as
the last action prior to the use of Cell 4B, and as such the requested change to the Cell 4A weekly
inspection is not necessary.
3.b. See response to 3.a.(2) above.
4. Please correct miscellaneous errors noted at the following locations on the subject submitted redline
DMT Plan copy:
a. The third paragraph of page 2, and in paragraph a) below it, the deletion and relocation of a
sentence is erroneous.
b. Last paragraph of page 3, the elevations listed for the lowest points on the flexible membrane liners
for Cells 4A and 4B conflict with the elevations listed in Appendix A (page 33 of the redline copy) for
Cells 4A. and 4B.
c. On page 11 heading III, (used for the Roberts Pond) should be a heading IV.
DENISON
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 4
d. In Section 6.3, the fifth paragraph, the first number in the parenthetical phase appears it should be
40 rather than 45.72.
e. On page 28 of the clean copy, corresponding to p. 33 of the red-line copy, for Cell 4A the FML
bottom elevation line needs to be right justified.
f. On page 33,paragraph number 2, the statement "Pump Timer set at 15 min on" needs to be
deleted.
g. On page 36, the asterisk footnote shown refers to an elevation which appears to apply only to Cell
4A. The footnote needs to be adjusted somehow include the elevation that applies to Cell 4B as
well.
Denison Response: These changes have been made in the attached DMT Plan Revision 11.1.
The Cell 4A & 4B O&M Plan. 11/2010 Revision Denison 2.0. of the submitted red-line copy:
I. Figure 6B does not follow the same logic as Figure 6A I.e., the lowest FML elevation above the
sump level is not 1.5-feet above the sump bottom (for the 18-inch diameter collection pipe) as in
Figure 6A. Please explain and justify this difference.
II. On page 11, in two separate paragraphs numbered I and 2, the second and the last sentence
respectively, contain a parenthetical phase that must be deleted or adjusted, as it is incorrect.
III. On page 14, in the third sentence the parenthetical phrase must be deleted or adjusted, as it is
incorrect.
IV. Also, on page 14, the second to last sentence from the bottom of the page, beginning with, "Each
pump is equipped with...," refers to distances of 2.25 feet and 9-inches. These distances appear to
not be applicable for the Cell 4B sump and respecting Figure 6B. Please revise this sentence and
or figure, to be correct for Cell 4B as well.
V. On page 15, the last sentence of the first paragraph on that page must specify what Figure it refers
to.
VI. Page 17, the third paragraph states," Condition 10.3 states that...," however, current License
Condition 10.3 does not state the verbiage quoted after that sentence. Please adjust this paragraph
with the proper references and verbiage, as applicable.
VII. Beginning on page 17, rewrite the section of the O&M Plan titled "Cell 4A Solution Freeboard
Calculation," including the title of that section. This will need to be done according to DUSA's
application of the paragraph numbered 2, under the DMT Plan comment section of this letter.
VIII. Please correct miscellaneous errors noted at the following locations on the subject red-lined copy of
the Cell 4A and 4B BAT O&M Plan:
a. On page 6, paragraph .2, add a sentence which describes that the non-woven geotextile
material is also overlain at the surface by a woven geotextile fabric, which is ballasted laterally
by sandbags on each side of the backbone gravel berm.
b. The above item also must be added to paragraph e.2 on page 3 and 4.
c. On page 6, paragraph e.3, also add a sentence which describes that the non-woven geotextile
material is also overlain at the surface by a woven geotextile fabric, which is ballasted by
sandbags.
d. The above item also must be added to paragraph e.3 on page 4.
e. Page 20, entry 11 on the Attachments list needs to be updated, and the sentence ended with
"DMT Monitoring Plan."
Denison Response:
DENISON
MINES
Letter to Mr. Rusty Lundberg
January 12, 2011
Page 5
I. Figure 6B is correct. The lowest FML above the sump level is 2.06 feet for Cell 4B.
II. The phrase has been deleted from both paragraphs as requested.
III. The phrase has been deleted as requested.
IV. The text has been corrected to reflect the actual conditions in Cell 4B as shown in Figure 6B,
which is correct.
V. Figure 5 was referenced in the previous version and no correction is required.
VI. The correct verbiage has been added.
VII. See response to 3.a.(2) above.
VIII. Items a through e have been corrected or amended as requested.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISON
MINES
or res
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
January 20,2011
CERTIFIED MAIL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp (DUSA)
1050 17th Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: January 10,2011 DUSA Letter, Transmits Revised DMT and BAT O&M Plans, which
addresses White Mesa Uranium Mill Tailings Cell 4B, etc.; January 6,2011 DRC Letter,
Review of Revised DMT and BAT O&M Plans;
Contingent Approval of the Proposed DMT Plan
We have reviewed the subject letter from DUSA dated January 10,2011, which is a response to the subject
DRC comment letter of January 6,2011. The DUSA letter proposes the two subject documents, noted
above. However, this letter only addresses the proposed DMT Plan, as revised, known as The White Mesa
Mill Tailings Management System and Discharge Minimization Technology (DMT) Monitoring Plan
(DMT Plan), 01/11 Revision: Denison-11.1.
After review of this plan, we have no further comments. Therefore, the DMT Plan as titled immediately
above, is approved, contingent upon DUSA receiving written DRC authorization to use Cell 4B.
UTAH RADIATION CONTROL BOARD
Rusty Lundberg Jbx< Rusty Lundberg, Executive Secretary
DAR: dr
Cc: Harold R. Roberts, DUSA
Phillip Goble, DRC
FNDUSAV GWDPerminDMT Plan HistoryXDMT Plan ContApproval 01-20-2011.doc
195 North 1950 West • Salt Lake City. UT
Mailing Address: P O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www deq utah.gov
Pnnted on 100% recycled paper
Cell 1 and Cell 3 LDS Monitoring Information - Second Quarter 2011
April 2011
Cell Date
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Cell Date
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Cell 1 4/1/2011 Cell 3 4/1/2011 Dry
4/8/2011 4/8/2011 Dry
4/15/2011 Dry 4/15/2011 Dry
4/22/2011 Dry 4/22/2011 Dry
4/29/2011 Dry 4/29/2011 Dry
May 2011
Cell Date
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Cell Date
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Cell 1 5/6/2011 Dry Cell 3 5/6/2011 Dry
5/13/2011 Dry 5/13/2011 Dry
5/20/2011 Dry 5/20/2011 Dry
5/27/2011 Dry 5/27/2011 Dry
June 2011
Cell
Cell 1
Date
6/3/2011
6/10/2011
6/17/2011
6/24/2011
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Dry
Dry
Dry
0.7
Cell
Cell 3
Date
6/3/2011
6/10/2011
6/17/2011
6/24/2011
Measurement in
inches from
transducer at the
bottum of the LDS
sump.
Dry
Dry
Dry
Dry
Cells 1 and 3 LDS systems put into service on July 13, 2011 per 9/8/11 letter
DENISON
MINES
Dtnison Mints (USA) Corp.
108017th Strati, Suite 950
Donvtr, CO 80265
USA
Td: 303 628-7798
Fax .[phone]
www.dtnltonminM.con)
August 18, 2010
VIA E-MAIL AND OVERNIGHT DELIVERY
Rusty Lundberg, Co-Executive Secretary
Utah Water Quality Board
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144810
Salt Lake City, UT 84114-4820
Re: State of Utah Ground Water Discharge Permit ("GWDP") No. UGW370004 White Mesa Uranium Mill -
Plan and Schedule for Cell 1 Inspection and Repairs
Dear Mr. Lundberg:
Reference is made to Denison Mines (USA) Corp's ("Denison's") notice letter of June 7, 2010 and telephone
conference with Utah Department of Environmental Quality ("UDEQ") personnel on August 12, 2010. Denison's
June 7, 2010 letter provided a notice to the Executive Secretary regarding the discovery of fluid in the Leak
Detection System ("LDS") of the White Mesa Mill's (the "Mill's") Cell 1. This letter responds to Denison's
commitment in the June 7, 2010 letter and the August 12, 2010 phone call in which Denison agreed to provide
UDEQ a written plan and schedule for:
• determination of the root cause,
• identification of the extent of damage, and
• execution and reporting of repairs to the Cell 1 liner system.
Background and Design of Cell 1
Tailings Cell 1 serves as the Mill's primary liquid evaporation basin. Cell 1 consists of the following major
design elements:
1) Cross-valley Dike and East Dike - constructed on the south side of the pond of native granular materials
with a 3:1 slope, a 20-foot crest width, and a crest elevation of about 5,620 ft above mean sea level (amsl).
A dike of similar design was constructed on the east margin of the pond, which forms a continuous earthen
structure with the south dike. The remaining interior slopes are cut-slopes at 3:1 grade.
2) Liner System - including a single 30 mil PVC flexible membrane liner (FML) constructed of solvent welded
seams on a prepared sub-base. The top elevation of the FML liner was 5,618.5 ft amsl on both the south
dike and the north cut-slope. A protective soil cover layer was constructed immediately over the FML with a
thickness of 12-inches on the cell floor and 18-inches on the interior sideslope.
Letter to Rusty Lundberg on Cell 1 Repair Plan
August 18, 2010
Page 2
3) Crushed Sandstone Underlay - immediately below the FML a nominal 6-inch thick layer of crushed
sandstone was prepared and rolled smooth as an FML sub-base layer. Beneath this underlay, native
sandstone and other foundation materials were graded to drain to a single low point near the upstream toe
of the south cross-valley dike. Inside this layer, an east-west oriented pipe was installed to gather fluids at
the upstream toe of the cross-valley dike.
As mentioned in item 2, above, Cell 1's FML is overlain by a protective soil layer. As a result, the FML, and any
tears or damage to seams or liner surfaces, are not readily visible. Thorough and complete inspection and
repair will require systematic removal of the soil cover by section, and stepwise inspection and repair of
uncovered FML sections in a phased approach, as discussed further in the proposed repair plan and schedule
below.
Regulatory Framework
Condition 11.3 of the Mill's State of Utah Radioactive Materials License No. UT1900479 (the "License") requires
that the licensee implement a leak detection monitoring system for each of the tailings cells. According to
condition 11.3:
(i) The licensee shall measure and record the "depth to fluid" in each of the tailings disposal cell
standpipes on a weekly basis. If sufficient fluid is present in the leak detection system (LDS) of
any cell, the licensee shall pump fluid from the LDS, to the extent reasonably possible, and
record the volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
(ii) If fluid is pumped from an LDS, the licensee shall calculate the flow rate 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. The licensee
shall document the results of this calculation.
(iii) Upon the initial pumping of fluid from an LDS, the licensee shall collect a fluid sample and
analyze the fluid for pH and the parameters listed in paragraph A of this license condition. The
licensee shall determine whether the LDS fluid originated from the constituents listed in
paragraph A of this license condition or has a pH level less than 5.0. If either elevated
constituent levels or a pH less than 5.0 is observed, the licensee shall assume that the disposal
cell is the origin of the fluid.
Condition 11.3 further requires the ongoing weekly measurement of depth to fluid if the calculated flow rate is
less than 1 gpm, and additional notification and mitigation requirements if the rate is greater than 1 gpm.
The above requirements have been incorporated into the Discharge Minimization Technology Plan in Section
3.1 of the Mill's Environmental Protection Manual.
Part I.E.7(f) of the Mill's GWDP requires that the Permittee shall inspect the liner system at Tailing Cells 1, 2,
and 3 on a daily basis pursuant to the requirements of Sections 2.1 and 2.2 of the currently approved DMT
Monitoring Plan. In the event that any liner defect or damage is identified during a liner system inspection, the
Permittee shall immediately. 1) report pursuant to Part I.G.3, 2) repair said defect or damage by
implementation of the currently approved Liner Maintenance Provisions, and 3) report all repairs made pursuant
to Part I.F.2.
DENISO MINES
Letter to Rusty Lundberg on Cell 1 Repair Plan
August 18, 2010
Page 3
Section 1.G.3 of the GWDP requires that in the event that the Permittee fails to maintain DMT or BAT or
otherwise fails to meet DMT or BAT standards as required by the Permit, the Permittee shall submit to the
Executive Secretary a notification and description of the failure according to R317-6-6.16(C)(1). Notification
shall be given orally within 24-hours of the Permittee's discovery of the failure of DMT or BAT, and shall be
followed up by written notification, including the information necessary to make a determination under R317-6-
6.16(C)(2), within five calendar days of the Permittee's discovery of the failure of best available technology.
UDEQ has not considered the Cell 1 liner system to meet BAT requirements and has excluded it from BAT and
DMT requirements in the Mill's GWDP. Hence, DMT reporting requirements do not specifically apply to the Cell
1 LDS. However, Denison chose to notify the Executive Secretary within 24 hours of the initial onset, by
telephone call on June 3, 2010, because the fluids in the Cell 1 LDS were assumed to represent a potential liner
defect that requires notice under Part I.E.7(f) of the GWDP. The Executive Secretary received written
notification within 5 days of the initial incident on June 7, 2010. Denison also provided a follow-up verbal
notification within 24 hours of the recurrence by phone call on August 8, 2010.
Initial Identification of Need for Repairs and Response Actions to Date
During the routine tailings inspection performed at approximately 2:50pm on June 2, 2010, the Cell 1 LDS
standpipe was observed to have accumulated approximately 7 feet 6 inches of liquid compared to the previous
day. The preceding day's recorded observation indicated that the LDS standpipe was "dry" (a measured level
of 63 feet 4 inches). Sufficient fluid had accumulated by 8:25am Thursday, June 3 to permit collection of
samples and initial pH testing to ascertain whether the fluid originated from the cell. The initial pH testing in at
8:45am on June 3, showed a pH of 2 to 3, indicating that the liquid originated from the cell. Initial notice of this
accumulation of liquid in the LDS was given by telephone to the Utah Department of Environmental Quality
Executive Secretary at 2:48pm on Thursday June 3, 2010 (within 24 hours of the discovery and within 7 hours
of determination of the origin of the fluid).
Upon receipt of the initial inspection result, the Mill's Environmental Coordinator notified the Mill Manager at
3:00pm that day. The Mill took the following steps, in accordance with License condition 11.3, the Mill's Liner
Maintenance Provisions, and Section 3.1 of the Mill's Environmental Protection Manual.
The Mill collected samples and duplicates on June 3 for analysis at Energy Laboratories and America West
Analytical Laboratories for the full suite of groundwater point of compliance analytes and parameters.
Characterization results confirmed that the source of the fluids in the LDS is tailings solutions.
Following the sampling on June 3, the Mill pumped the LDS to dryness, and began monitoring the level change
with time to estimate solution accumulation rate. The calculated rates estimated from this process indicated
that the solution accumulation rate did not exceed 1 gpm, and ranged from approximately 0.05 to 0.5 gpm.
At the time the LDS level was noted on June 3, the Cell 1 solution level was approximately 5614.57 feet amsl.
The Mill lowered the Cell 1 solution level during the month of June in order to reduce or eliminate the flow into
the LDS, and to allow inspection and repair of damage to the Cell 1 FML. The Cell 1 level was dropped to a low
of 5613.40 feet amsl during this period. Maintenance identified some FML damage and performed repairs
during the period when the level was lowest. Following the repairs, the Cell 1 liquid level was allowed to
gradually return to its June 3 level, and the LDS remained dry until a recurrence of the LDS liquid level was
identified on August 7.
The Mill experienced periodic heavy rains in late July and early August. During the August 7, 2010 tailings
inspection, the Cell liquid level had reached 5614.22 feet amsl. At that time, the Environmental Technician
3
DENISON
MINES
Letter to Rusty Lundberg on Cell 1 Repair Plan
August 18, 2010
Page 4
identified that the LDS had an observable liquid level. Liquid samples and duplicates were once again collected
and shipped for analysis, and pumping and estimation of the LDS fill rate was resumed.
At this time, Mill management took a more aggressive approach to lowering the Cell 1 solution level. Cell 1 was
pumped at maximum transfer pump rate into Cell 4A, beginning approximately August 8. At the time of this
writing, Cell 1's solution level has been reduced to 5613.91 feet amsl and the Mill continues to pump and
monitor the recovery level in the LDS.
The Mill also continues to estimate the flow rate into the LDS between pumping. Since the August 8 detection,
the flow rate into the LDS has not exceeded 1 gpm, and has ranged from 0.01 to 0.02 gpm, or approximately
one tenth to one twentieth of the rate during the June detection.
During phone discussions with UDEQ personnel on August 12, 2010, UDEQ agreed with Denison that both the
June and August identifications of LDS solutions were all part of one event. At this time, Denison has
concluded that:
• The inspection and repairs performed on the CelM FML in June and July were apparently not
successful in identifying all of the damage which required repair.
• The temporary cessation of flow into the LDS between the June and August Cell 1 LDS fluid detections
may have resulted from the lowering of the solution level to a point below the remaining tears or
damage to the FML. However, as the solution level in Cell 1 rose, it reached the elevation of one or
more remaining defects in the liner. Additional systematic inspection and repair of the FML will
therefore be required.
Plan
Denison proposes the following plan of action to:
• Identify and confirm the root cause of the observed solutions in the Cell 1 LDS.
• Locate the specific areas of the FML requiring repair.
• Conduct a systematic and orderly repair process that does not generate further damage to the FML
• Confirm that the repairs have reduced or eliminated the flow into the LDS
• Document the findings, root cause, and response actions.
This plan provides a phased approach to identification and repair of the defects in the Cell 1 liner. It is based on
the need for a stepwise schedule to systematically uncover and inspect all potentially damaged areas,
beginning with those areas with the highest potential for wear and resulting damage, and to perform the repairs
without incurring further damage to the FML during the removal of the protective soil cover. Denison does not
want to disturb any more of the soil cover, and expose more of the FML to the environment, than is necessary
in order to minimize the risk of further damage to the FML. In addition, the location of the repairs near the
tailings solution will require special safety precautions which add to the time required for repairs. Further, the
ability to perform any repairs during the winter months will be limited due to snow coverage and slippery
conditions. The key steps in the inspection and repair process will be as follows.
4
DENISON
MINES
Letter to Rusty Lundberg on Cell 1 Repair Plan
August 18, 2010
Page 5
Phase I Plan and Schedule
1. Reduce the Cell 1 solution level approximately to the level it reached during the June repairs. Solutions
from Cell 1 are currently being pumped from Cell 1 to either Cell 3 or Cell 4A. The solution level should
be down to the June elevation by approximately August 31st.
2. Identify areas in Cell 1 with highest potential for damage (where pipes enter and exit the cell, etc.). The
most obvious sections are in the southeast corner of Cell 1 and in the south central area of Cell 1 where
the pump barge is located. These areas are estimated to be approximately 200 feet of the Cell 1 bank.
3. Systematically inspect and repair the FML areas with the highest likelihood of damage first. The 200
feet of the highest risk areas will be uncovered and repaired as necessary. It is estimated that these
repairs will take approximately 10 weeks, until October 31, 2010.
4. Allow the level in the cell to recover and confirm that solutions do not reappear in the LDS. Solution
from the Mill process or from Cell 3 or Cell 4A will be pumped into the cell and the LDS sump will be
monitored. It is estimated that this step will take approximately 4 weeks, until November 30, 2010.
Phase II Plan and Schedule
5. If, after the process in steps 1 through 4 has been completed, solutions reappear in the LDS, the
solution level in Cell 1 will again be reduced in order to achieve dryness in the LDS. It is expected that
it will take some time for the Cell 1 pond solution to be reduced to the level necessary to achieve
dryness in the LDS, and for the LDS to be verified to be dry. However, this procedure is expected to be
accomplished by December 31, 2010.
6. After the solution level in Cell 1 is lowered, the next highest area of concern (likeliest area for damage)
will be uncovered, inspected, and repaired. Following the repairs, the Cell 1 solution level will be
allowed to gradually recover. The schedule for completion of this step will depend on winter conditions
and will be developed with the concurrence of the Executive Secretary.
7. If, after the process in steps 5 and 6 has been completed, solutions reappear in the LDS, the solution
level in Cell 1 will again be reduced in order to achieve dryness in the LDS. The cycle of steps 1 and 2
will be repeated, as necessary, until all the necessary repairs have been made to achieve dryness in
the LDS. The schedule of subsequent cycles of steps 5 and 6 will be developed with the concurrence
of the Executive Secretary.
Reporting
The Liner Maintenance Provisions appendix of the Mill's DMT Plan describes the types of repairs that will be
implemented following identification of solutions in the LDS, as well as requirements for a repair report
describing the nature of the damage and the repairs. As required by the Liner Maintenance Provisions, a repair
report will be submitted to the Executive Secretary following completion of repairs to the Cell 1 liner. The repair
report will contain, in addition to a root cause analysis, the following elements:
• Repair narrative describing the nature of the damage and the repair work completed to repair the
damage.
• Repair material type used to complete the repair
5
DENISON
MINES
Letter to Rusty Lundberg on Cell 1 Repair Plan
August 18, 2010
Page 6
• Repair material description
• Post repairs test specifications
• Test Methods (ASTM or other)
• Daily reports during the repair work
• Repair test results
• Quality Assurance/Quality Control Information
Data collected during the diagnostic steps, including solution accumulation rate estimations and analytical
results from characterization of LDS solution samples will also be included in the repair report.
Please contact the undersigned if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: Rich E. Bartlett
David C, Frydenlund
Ron F. Hochstein
Ryan Palmer
Harold R. Roberts
David E. Turk
6
DENISON
MINES
TabE
Calculation of Maximum Daily Allowable LDS Flow Volume for Varying Head Conditions in
Cells 4A and 4B
The equation for the calculation of maximum daily allowable flow volume in Cells 4A and 4B is
as follows:
Step 1) Elevation 1-Elevation 2 = Head (ft.)
Where: Elevation 1 is the maximum elevation in feet measured during the reporting
period.
Elevation 2 is the FML elevation in feet.
Step 2) Determine Calculated Action Leakage Rate from Table 1A (for Cell 4A) or Table
IB (for Cell 4B) using the head calculated in Step 1 above. If the head calculated
in step 1 above falls between two values in the Head Above Liner System (feet)
column, then the closer of these two values will be used to determine the
Calculated Action Leakage Rate.
Step 3) Calculate the acres of tailings cell fluids based on the area of the base of the cell,
the head, and the angle of the sideslopes of the cell.
Step 4) Action Leakage Rate (from Table 1A or IB) X Acres of Tailings Cell Fluids =
Maximum Daily Allowable Flow Volume
Max head on Cell 4A FML
Maximum Head on Cell 4A FML was not calculated during second quarter 2011. A
letter from the Executive Secretary dated January 27, 2011 which approved the use
of Cell 4B, and a subsequent letter dated March 15, 2011, stated approval of the
DMT and Cell 4A Operations and Maintenance ("O&M") Plans effectively eliminated
the former freeboard elevation requirements for tailings Cell 4A. Pursuant to the
receipt of the March 15,2011 letter, freeboard limits in Cell 4A were no longer
required. Denison corporate staff misinterpreted this waiver as meaning that the
weekly elevations no longer needed to be conducted. As a result, these
measurements were not collected during the period.
Max head on Cell 4B FML 4B - Q2 2011
Max elvation (ft.) 5581.59
FML elevation (ft.) 5557.5
Head (ft.) 24.09
From BAT O&M Table IB 475.6
Assume acres of fluid based on maximum level (acres) 33
Max allowable flow rate (gal/day) 15694.8