DRC-2012-001195 - 0901a068802b2d2e

DRC-20l2-00il95
DENISO
MINES
February 29 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
Demson Mines (USA) Corp
105017th street Suite 950
Denver CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
Re State of Utah Groundwater Discharge Permit ( GWDP ) No UGW370004
Transmittal of Revised Discharge Minimization Technology Monitonng ( DMT ) Revision 11 5
dated February 2012
DearMr Lundberg
Reference is made to the Division of Radiation Control ( DRC ) letters dated September 13 2011
December 14 2011 December 22 2011 and February 15 2012 regarding the White Mesa Mill
Tailings Management System and Discharge Minimization Technology ( DMT ) Monitonng Plans dated
June 2011 (Revision 11 2) July 2011 (Revision 11 3) and January 2012 (Revision 11 4)
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 DRC Letter dated February 15 2011 which incorporated specific comments
from the DRC letters dated September 13 2011 December 14 2011 December 22 2011
2 Correct additional errors and inconsistencies in the January 2012 Revision 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 5 has accepted all the redline changes proposed in Denison s
January 2012 submittal as the base version in black type Changes resulting from the above referenced
DRC comment letter are provided in redline/stnkeout format
We have also provided below specific responses to each request in DRC s February 15 2011 letter
The sections and numbenng of the remainder of this letter follow the DRC February 15 2011 letter
Each DRC request is shown in italics below followed by Denison s response
Responses to Comments Provided to DUSA in the September 13 2011 DRC RFI/Confirmatory
Action Letter (as re transmitted in a DRC letter dated February 15 2011)
DRC Comment
The comment shown immediately below corresponds to comment number three (3) in the subject
September 13 2011 DRC CAL
DUSA states that Denison has developed other means to accurately measure cell solution level
elevations prior to construction ofany walkways However the CAL states that The procedures
Letter to Mr Rusty Lundberg
February 29 2012
Page 2
for this method to measure the water level elevation will be submitted by DUSA for approval in a
revised DMT Plan
Please propose the other means to measure the water level as discussed above It is not
apparent in the DMT plan what the other means to measure the solution elevation are
Denison Response
As previously stated in Denison s January 30 2012 response letter tailings 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 text refernng to other methods was removed from the DMT Plan Revision 11 4 submitted in
January 2012 The tailings cell wastewater pool elevations will be measured using the standard survey
procedures as descnbed in the DMT Plan No further descnptions of additional procedures are needed
because the procedures are already descnbed in Section 3 1 d) of the DMT Plan Additional text has
been added clarifying that for newly constructed cells the same procedure will be used
DRC Comment
The comment numbers below correspond to the comment numbers in the subject December 22 2011
DRC Letter
3 Part ID 3(b)(3) of the Permit states that Annual Slimes Dram Compliance - shall be achieved
when the average annual wastewater recovery elevation in the slimes dram access pipe as
determined pursuant to the currently approved DMT Monitoring Plan meets the conditions in
Equation 1 below
Thus the DMT Plan needs to state how the slimes dram recovery elevations are to be calculated A
DUSA letter dated January 27 2012^ shows DUSA s current method of calculating the slimes dram
recovery elevation as well as the annual average slimes dram recovery elevation This method is
clarified in the second full paragraph on page 2 of that letter One may call the current DUSA method of
calculating recovery elevations a relative elevation method
Although this method is valid for comparison purposes it appears correct elevations with respect to the
true elevation above mean sea level (fmsl) are not being used As mentioned in the January 27 2012
letter the standpipe elevation was re surveyed in 2011 which indicated that the elevation of the
measurement point of 5614 83 fmsl reported to date was 3 07 feet higher than the 2011 sun/ey result
of 5611 76 fmsl
To avoid the complex adjustments to calculate relative elevations and to avoid future errors DUSA must
convert to using actual fmsl elevations not relative elevations in all of its slimes dram recovery elevation
determinations and calculations DUSA s method to do this must be stated in the DMT Plan
Notwithstanding the above the DMT Plan needs to state how the slimes dram recovery elevations are to
be calculated
Denison Response
The current correct elevation of the measunng point as surveyed by a Utah Licensed surveyor has been
added to the DMT Plan The calculation of the Cell 2 slimes dram elevation (SDRE) has been added to
Section 3 1 b)(v) showing how the elevation of the fluid is calculated relative to the surveyed measunng
point on the Cell 2 slimes dram access pipe
' January 27 2012 DUSA response letter on Failure to Meet Affirmative Defense Requirements on Cell 2 Slimes
Drain Recovery Elevation
DENISO MINES
Letter to Mr Rusty Lundberg
February 29 2012
Page 3
As we discussed with DRC on February 14 2012 the elevation of the Cell 2 slimes dram access pipe of
5611 76 fmsl is a correct value representing the elevation prior to the addition in 2011 of the 6 97 foot
extension All entnes and calculations (for every penod from 1/25/2008 through 12/19/2011) in the table
in Attachment 3 of Denison s January 17 2012 letter using this value are correct
The surveyed elevation of the slimes dram access pipe of 5618 73 fmsl used in Attachment 3 of
Denison s January 27 2012 letter is a correct value sun/eyed by a Utah Licensed surveyor after the
installation of the 6 97 foot extension to the slimes dram access pipe The entry and calculations for
12/19/2011 in the table in Attachment 3 based on this value are also correct The plots of slimes dram
elevation based on these values and measured depths to slimes dram solution as provided in the DMT
reports to date are also correct As we agreed on February 14 2012 since the elevations in fmsl are
correct there is no need to further revise any of the table entries or the plots and as the calculations
indicate the Cell 2 slimes dram recovery is in compliance with Part I D 3(b)(3) of the Groundwater
Discharge Permit
As we discussed on February 14 2012 the value of 5614 83 fmsl which was identified in Denison s
January 27 2012 letter is not a correct value This entnes and calculations in the table in Attachment 3
of the letter and the data used to prepare the slimes dram elevation plots in the DMT reports were based
on the correct values discussed above not on the incorrect value Therefore as we agreed on February
14 2012 smce the elevations used are correct there is no need to further revise any of the table entnes
or the plots
As we discussed on February 14 2012 all calculation are based on the subtraction of an actual surveyed
value in fmsl for the slimes dram access pipe elevation and an actual measured depth to fluid for the
slimes dram solution and are not based on relative elevations The text in Section 3 1 b)(v) has been
revised to include a descnption of the process
DRC Comment
5 In Appendix F of the DMT Plan additionally the first bullet line should refer to Cell 4B instead of Cell
4A Please make this correction
Denison Response
The text has been changed as requested
DRC Comment
6 The previous comment was 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
However DUSA s response that The text corrections have been made as requested is incorrect as no
changes were made
It appears dikes 4A E 4A S and 4B S are the current dikes exposed exterior dikes subject to movement
monitoring Please indicate such in this paragraph of the plan
Denison Response
The text has been changed as requested
DRC Comment
7 See Appendix A page 28 Table III Since the freeboard in Cell 1 is always exposed and the water
level IS often changing all the dikes in Cell 1 become visible from time to time Columns need to be
made available so inspection entries can be made for all the dikes of Cell 1
Similarly all the dikes of Cells 4A and 43 need to be included in the table
Denison Response
Per Denison s discussion with DRC on February 14 2012 Denison understands the need to include in
the Daily Inspection Form a place to record observations from inspections of the intenor walls of all four
DENISO MINES
Letter to Mr Rusty Lundberg
February 29 2012
Page 4
dikes of Cells 1 4A and 4B Consistent with our discussion with DRC Denison has revised Table II of
the Daily Inspection Form to include space for these observations The title of Table II has been modified
to clanfy that it addresses inspection of the intenor conditions and issues at Cells 1 4A and 4B
As we discussed the contents of Table III which addressed inspection of geotechnical components of
the extenor of visible dikes have not been changed The notes inside Table III have been edited to
clarify that the table addresses extenor dikes
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
Ron F Hochstein
Harold R Roberts
David E Turk
Kathy A Wemel
Attachments
DENISO
MINES
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND
DISCHARGE MINIMUMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
Revision 11 5
February 2012
Prepared by
Denison Mines (USA) Corp
1050 17* Street, Suite 950
Denver, CO 80265
White Mesa Mill - Standard Operating Procedures 2/12 Revision Denison 11 5
Book 11 Environmental Protection Manual Section 3 1 Page 2 of 55
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
Contents
1 INTRODUCTION 4
2 DAILY TAILINGS INSPECTIONS 4
2 1 Daily Comprehensive Tailings Inspection 4
2 2 Daily Operations Inspection 7
2 3 Daily Operations Patrol 7
2 4 Training 7
2 5 Tailings Emergencies 7
3 WEEKLY TAILINGS AND DMT INSPECTION 8
3 1 Weekly Tilings Inspections 8
Northing 13
Easting 13
3 2 Weekly Inspection of Solution Levels m Roberts Pond 16
3 3 Weekly Feedstock Storage Area Inspections 16
4 MONTHLY TAILINGS MSPECTION 16
5 QUARTERLY TAILINGS INSPECTION 17
6 ANNUAL EVALUATIONS 18
6 1 Annual Technical Evaluation 18
6 2 Movement Monitors 19
6 3 Freeboard Linuts 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 4B 21
6 3 6 Roberts Pond 23
6 4 Annual Leak Detection Fluid Samples 24
6 5 Annual Inspection of the Decontamination Pads 24
7 OTHER INSPECTIONS 24
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8 REPORTING REQUIREMENTS
8 1 Monthly Tailings Reports
8 2 DMT Reports
8 3 TAILINGS INSPECTOR TRAINING
24
25
25
42
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Book 11 Envu-onmental Protection Manual Section 3 1 Page 4 of 55
1 INTRODUCTION
This Tailings Management System and Discharge Minmuzation Teclmology Monitoring Plan (the
Plan ) for the White Mesa Mill (the Mill ) provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No UTl900479 (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 Penrnt 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 lmer integrity and transport
systems as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill The Plan requires daily weekly quarterly monthly and annual inspections and evaluations and
monthly reporting to Mill management
2 DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed
2 1 Daily Comprehensive Tailings Inspection
On a daily basis including weekends all areas connected with the evaporation cell (Cell 1) and
thefour tailmgs 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 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 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 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 corrective 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
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S wmd movement of tailings effectiveness of dust minmuzation 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 durmg 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 tailings lines are required to be performed when the Mill
IS operating The lines to be inspected include the tailings slurry lines from CCD
to the active tailings cell SX raffinate lines that can discharge into Cell 1 Cell
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 m the tailings area including
waterfowl and burrowing animal habitations
j) Spray evaporation pumps and lines
k) Wind movement of tailings and dust minmuzation
Wmd movement of tailmgs will be evaluated for conditions which may require
initiation of preventative dust mimrmzation measures for cells containing tailings
sand During tailings inspection general surface conditions will be evaluated for
the following 1) areas of tailings subject to blowing and/or wind movement 2)
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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
minmuzation 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 m Cells 1 3
4A and4B
n) Locations of slurry and SX discharge within the active cells Slurry and SX
discharge pomts need to be mdicated on the tailings cells map included in the
Daily Inspection Data form
o) An estimate of flow for active tailings slurry and SX Ime(s)
p) An estimate of flow m the solution retum line(s)
q) Daily measurements in the leak detection system sumps of the tailings cells will
be made when warranted by changes in the solution level of the respective leak
detection system
The trigger for further action when evaluating the measurements in the Cell 1 and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours The
solution level in Cell 4A or 4B leak detection system is not allowed to be more
than 1 0 foot above the lowest point on the bottom flexible membrane liner
(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 Penrnt 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
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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
During Mill operation the Shift Foreman or other person with the training specified in Section 2 4
below designated by the Radiation Safety Officer will perfonn an inspection of the tailings line and
tailings area at least once per shift paying close attention for potential leaks and to the discharges
from the pipelines Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman s Daily Inspection form
2 3 Daily Operations Patrol
In addition to the inspections descnbed in Sections 2 1 and 2 2 above a Mill employee will patrol
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 RSO and/or Mill
management m the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred
2 4 Training
All individuals performing mspections described 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 indicating that training
has been received relative to his/her duties as an inspector
2 5 Tailmgs 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 occurred that could cause a tailings
emergency Until relieved by the Environmental or Technician or RSO inspectors will have the
authority to direct resources dunng tailings emergencies
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO one of whom will notify Corporate Management If
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dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager
will then notify Corporate Management MSHA (303 231 5465) and the State of Utah Division of
Dam Safety (801 538 7200)
3 WEEKLY TAILINGS AND DMT INSPECTION
3 1 Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
followmg
a) Leak Detection Systems
Each tailmgs cell s leak detection system shall be checked weekly (as well as
daily) to detemune 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 monitored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector The pressure
transducer is calibrated for fluid with a specific gravity of 1 0 The water levels
are measured every hour and the information is stored for later retrieval The
water levels are measured to the nearest 0 10 inch The data collector is currently
programmed to store 7 days of water level information The number of days of
stored data can be increased beyond 7 days if needed For Cells 1 and 3 the
water level data is recorded on the Daily Tailings Inspection Form For Cells 4A
and 4B the water level data is downloaded to a laptop computer periodically and
incorporated mto the Mill s environmental monitonng 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
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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 Materials License
For Cell 4A and 4B under no circumstance shall fluid head in the leak
detection system sump exceed a 1 foot level above the lowest pomt m the
lower flexible membrane lmer 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 detemune the
maximum daily allowable LDS flow volume for varying head conditions in
Cell 4A and4B
b) Shmes 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 intenm fill on Cell 2 m 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 m length and therefore the new measuring point is 37 97
feet from the bottom of the shmes dram The measunng point on the extension pipe
was surveyed by a Utah Certified Land Surveyor The measuring point elevation is
5618 73 fmsl For the quarterly recovery test described m 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
slimes drain As taken from actual measurements the bottom of the shmes drain is
37 97 feet below a water level measuring point which is a notch on the side of the
Cell 2 shmes drain access pipe This means that the bottom of the shmes dram 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 shmes dram 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
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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 shmes drain standpipe and the float valve is located at
three feet above the bottom of the shmes drain standpipe The average wastewater
head in the Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic
surface of tailings Cell 2 about 27 feet below the water level measunng point on the
shmes drain access pipe As a result there is a continuous flow of wastewater from
Cell 2 into the shmes 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
(ly)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 within 15 days
(v) Depth to wastewater in the Cell 2 shmes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle respectively The extension of the Cell 2 shmes dram access pipe did
not require any changes to the measurement procedure The surveyed measuring
point on the extended pipe is used as required The elevation of the measuring point
IS 5618 73 fmsl The head measurements are calculated in the same manner using
the same procedures as those used prior 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 measuring point (the notch at
the north side of the access pipe 5618 73 fmsl) and made to the nearest 0 01 foot
The results will be recorded as depth in pipe measurements on the Weekly Tailmgs
Inspection Form The equation specified in the GWDP will be used to calculate the
shmes drain recovery elevation (SDRE) To calculate the SDRE contemplated by the
GWDP the depth to wastewater in the Cell 2 shmes drain access pipe (in feet) will
be subtracted from the surveyed elevation of the measuring point The calculation is
as follows
5618 73 Depth to wastewater m the Cell 2 slimes dram access pipe = SDRE
It IS important to note that 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 dram access pipe height) used in the calculation has
changed The head is calculated by subtracting the depth to liquid from 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
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least 90 hours Once the water level has stabilized (based on no change m 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 shmes dram access pipe
(vn) No process liquids shall be allowed to be discharged into Cell 2
(vm) 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
requirement to provide notification to the Executive Secretary orally withm 24 hours
followed by written notification
(ix)Because Cell 3 and Cell 4A are currently active no pumping from the Cell 3 or Cell
4A shmes drain is authorized No pumping from the Cell 4B shmes dram will be
authorized once it is put mto service and while it is active Pnor 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
shmes drams 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 tailmgs 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 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 performed 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
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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 Pomt 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
(ly)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 Pomt (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 mam solution pond m 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 minimal elevation above the FML due to natural precipitation
For newly constmcted cells measurement of solution level will commence within 30 days of
authonzation for use Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current 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
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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
IV Roberts Pond
A mark has been painted on the railing of the pump stand m 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
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
(viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface The Assistant will ensure that the Survey
Rod IS vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading
(ix) The Surveyor will focus the cross hairs of the Survey Instmment on the scale on
the Survey Rod and record the number (the Pond Surface Reading ) which
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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 Readmg for
the Cell or Roberts Pond and will record the number accurate to 0 01 feet
e) Decontamination Pads
(i) New Decontammation Pad
The New Decontammation 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 primary 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 primary and secondary containment The depth to water
in each portal will be measured weekly by physically measuring the
depth to water with an electrical sounding tape/device All
measurements must be made from the same measuring point and be
made to the nearest 0 01 foot
C These inspections will be recorded on the Weekly Tailmgs Inspection
form
D The water level shall not exceed 0 10 foot above the concrete floor m
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 pnmary containment
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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 m the standpipes the
New Decontanunation Pad including the concrete integrity of the
exposed surfaces of the pad will be inspected on a weekly basis Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking
Observations will be made of the current condition of the New
Decontammation Pad Any abnormalities relating to the pad and any
damage to 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
(ll) Existing Decontamination Pad
The Existing Decontanunation Pad is located between the northwest comer of the
Mill s maintenance shop and the ore feeding gnzzly
A The Existing Decontanunation Pad will be inspected on a weekly
basis Any soil and debns will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the cunent
condition of the Existing Decontanunation Pad including the
concrete integnty of the exposed surfaces of the pad Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form If there are any cracks greater than 1/8 inch
separation (width) the RSO must be contacted The RSO will have
the responsibility to cease activities and have the cracks repaired
f) Summary
In addition the weekly inspection should summarize all activities 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
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3 2 Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis solution elevations are taken on Roberts Pond in accordance with the procedures
set out in Section 3 1 d) above The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form Based on historical observations the FML at the Pond
Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the
pond s FML If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area the pond will be recorded as being dry
3 3 Weekly Feedstock Storage Area Inspections
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 described m
the GWDP as indicated on the map attached hereto as Appendix D
b) a 4 ft buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area
and
c) all altemate feedstock located outside the defined Feedstock Area are maintained withm
water tight containers
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report a copy of which is contained in Appendix A Any variance in stored materials from this
requirement or observed leaking 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 tailmgs inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form an example of
which is contained in Appendix A Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable The following items are to be inspected
a) Tailings Slurry Pipeline
When the Mill is operating the slurry pipeline will be visually inspected at key
locations to determine pipe wear The critical points of the pipe include bends slope
changes valves and junctions which are critical to dike stability These locations to
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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 facilities 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
/) Summary of Daily Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily weekly and if applicable
quarterly tailings inspections for the specific month
In addition settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form
5 QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department havmg the training specified in Section 2 4 above once per
calendar quarter A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed
Each quarterly inspection shall include an Embankment Inspection an Operations/Maintenance
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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 liner
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 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
e) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis
If any of these conditions are noted the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form An example of the Quarterly Inspection Data
form IS provided in Appendix A
6 ANNUAL EVALUATIONS
The following annual evaluations shall be performed
6 1 Annual Technical Evaluation
An annual technical evaluation of the tailmgs management system is performed by a registered
professional engineer (PE) who has experience and training in the area of geotechnical aspects of
retention stmctures The technical evaluation includes an on site inspection of the tailmgs
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)
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All tailings cells and corresponding 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 tailmgs 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
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 mspection 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 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 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 engmeer will obtain copies of selected tailmgs 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 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 4A
E 4A S and 4B S to detect any possible settlement 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 Limits
The freeboard limits set out in this Section are intended to capture the Local 6 hour Probable
Maximum Precipitation (PMP) event which was determmed 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
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0 90 feet
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas plus the adjacent
dramage areas was calculated m the Drainage Report to be 123 4 acre feet of water
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre feet of water (40 acres plus the adjacent drainage area of 3 25 acres) times
the PMP of 10 inches) with a wave 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 m Cell 1 is 52 9 acres in Cell 4A is 40 acres and m 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 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 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 limit 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 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)
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 attnbuted to Cell 4B (and/or any future
tailmgs 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
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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 m Cell 4B The procedure for calculating the
freeboard Imut 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
Imut 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
Imut will be 5 594 6 FMSL which is the same as in (a) above This allows for the situation where
there may be beaches but these beaches are at a lower elevation than the freeboard linut 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 determmed by monthly surveys
performed by Mill personnel m 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 (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 histoncally been deposited into Cell
4B prior 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 in the cell durmg the
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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
for solids That is the reduced pool surface area for penod t=0 ( RPAo ) after the
reduction will be calculated to be
(1 - (Ao* X 1 5) / (2 094 000 To)) x 40 acres = RPAo
VII) 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 linut 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 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 m pool area for the
ensuing year (referred to as period t) will be calculated by
i) First calculating the Adjusted Reduced Pool Area for the previous penod (ARPAt 0
to reflect actual tonnages deposited in Cell 4B for the previous period (period 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 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 corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation The
ARPAt 1 can be calculated using the following formula
(1 - At 1 / (2 094 000 - Tt i)) x ARPAt i = ARPAt i
Where
• At 1 IS the actual number of dry tons of tailings solids deposited in Cell 4B
during period t 1
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• Tt 1 IS the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t 1 and
• ARPAt 2 IS the Adjusted Reduced Pool Area for period t 2 If penod t 2
started at the Initial Calculation Date then ARPAt 2 is 40 acres
II) Once the ARPAt 1 for the previous period (period t 1) has been calculated the RPA
for the subject period (period t) can be calculated as follows
(1 - (At* x 1 5) / (2 094 000 Tt)) x ARPAt 1 = RPAt
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 period t and
• ARPAt 1 IS the Adjusted Reduced Pool Area for period t 1 which is the pool
surface area for the previous period (penod t 1) that should have applied
during that period had modeled tonnages (1 e expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period
III) The required freeboard for period t can be calculated in feet to be the wave mn up
factor for Cell 4B of 0 77 feet plus the quotient of 197 5 acre feet divided by the RPAt
The freeboard Imut 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 limit will persist until the next Annual Calculation
Date for penod 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
linut calculation method for the new cell is set to cover the entire PMP event for Cells 2 3 4A 4B
and the new tailings cell the freeboard limit for Cell 4B will be inapplicable except for approved
provisions to prevent storm water 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 in the GWDP
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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 in License
Condition 11 3 C The results of the analysis will be reviewed to determine the origin of the
solution
6 5 Annual Inspection of the Decontamination Pads
a) New Decontammation Pad
During the second quarter of each year the 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 deterioration or damage of the pad surface 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 The inspection findings any repairs required and
repairs completed shall be summanzed in the 2"^* Quarter DMT Monitoring Report due September 1
of each calendar year
b) Existing Decontammation Pad
During the second quarter of each year the Existing Decontanunation Pad will be taken out of
service and mspected to ensure the integrity of the steel tank Once the water and any sediment
present is removed from the steel tank containment the walls and bottom of the tank will be
visually inspected for any areas of damage cracks or bubbling indicating corrosion that may
have occurred since the last inspection If any abnormalities are identified defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility All inspection findings and any repairs required shall be documented on the Annual
Decontanunation Pad Inspection form A record of the repairs will be mamtained 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 in Sections 2 3 4 5 and 6 above However additional inspections should be conducted
after any significant storm or significant natural or man made event occurs
8 REPORTING REQUIREMENTS
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In addition to the Daily Inspection Data Weekly Tailings Inspection Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described m 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 Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month s activities
around the tailings area If not prepared by the Radiation Safety Officer the report shall be
submitted to the Radiation Safety Officer for review The Mill Manager will review the report as
well before the report is filed in the Mill Central File The report will contain a summary of
observations of concem noted on the daily and weekly tailings inspections Corrective measures
taken during the month will be documented along with the observations where appropnate All daily
and weekly tailmgs inspection forms will be attached to the report A monthly inspection form will
also be attached Quarterly inspection forms will accompany the report when applicable The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager
82 DMT Reports
Quarterly reports of DMT monitoring activities which will include the following information will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP
a) On a quarterly basis all required information required by Part 1 F 2 of the GWDP
relating to the inspections described m Section 3 1(b) (Shmes Drain Water Level
Monitoring) 3 1(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring) 3 2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3 3
(Weekly Feedstock Storage Area Inspections)
b) On a quarterly basis a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers m the concrete settling tank system for the New
Decontamination Pad which will include a table indicating the water level
measurements in each portal during the quarter
c) With respect to the annual inspection of the New Decontamination Pad 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 Decontamination Pad
descnbed in Section 6 5(b) the inspection findings any repairs required and
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Book 11 Environmental Protection Manual Section 3 1 Page 26 of 55
repairs completed shall be summarized in the 2"^* Quarter report due September 1
of each calendar year sind
e) An annual summary and graph for each calendar year of the depth to wastewater
m 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
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Page 27 of 55
APPENDIX A
FORMS
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APPENDIX A (CONT)
DAILY INSPECTION DATA
Inspector
Date
Accompanied by
Time
Any Item not OK must be documented A check mark = OK X = AcUon Required
I TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell4B
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 and INTERIOR of CELLS
Inspection Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Ce 14B
N S E W N S E W N S E| W
Intenor Cell Walls
Liner Observable Liner Damage 1 Water Level Greater Than Operatmg Level Large
Change Since Previous InspecUon
Beach Cracks Severe Erosion Subsidence
Liner and Cover Erosion of cover Exposure of Liner
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Page 29 of 55
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 extenor extenor extenor extenor
of Seepage Outbreak slope or slope or slope or slope or
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
extenor extenor extenor extenor
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 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
Cell 2 Cell 3 Cell 4A Cell 4B
DusUng
Wind Movement of Tailings
Precipitation inches liquid
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Page 30 of 55
General Meteorological condiUons
VII DAILY LEAK DETECTION CHl ECK
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
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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Page 31 of 55
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Tailings Daily Inspection Repoit
Tailings Sluny Di<!chaige Location
c o
c ^
o
>
CM
c3
c
^ 2
2 o
3 <u
^
ri. C ed
2 2
^§ 2 o
-§ :s
eg c
I c
^ l-l
ea nn 1/1
^ o
^ PQ
Date
Inspectoi
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Book 11 Environmental Protection Manual Section 3 1 Page 33 of 55
APPENDIX A (CONT)
DENISON MINES (USA) CORP
WEEKLY TAILINGS INSPECTION
Date Inspectors
1 Pond and Beach Cell 1 (a) Pond SoluUon ElevaUon
elevaUons (msl ft)
(b) FML Bottom ElevaUon 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 ElevaUon
(b) FML Bottom ElevaUon 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 ElevaUon 5612 3.
(c) Depth of Water above FML ((a) (b))
2 Shmes Drain 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 37 97 Depth to Liquid Pre
pump =
Post pump head is 37 97 -Depth to Liquid Post
pump =
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3 Leak Detection Systems
(Same data as Daily InspecUon 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 taihngs)
5 Control Methods Implemented
6 Remarks
7 Designated Disposal Area for Non Taihngs Mill Waste (awaiUng DRC approval)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane lmer (solution
elevation of 5556 14 amsl for Cell 4A and 5558 50 for Cell 46)? no yes
If Cell 4A leak detectton system level exceeds 12 inches above the lowest pomt on the bottom flexible
membrane liner (elevation 5556 14 amsl) notify supervisor or Mill manager immediately
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APPENDIX A (CONT)
MONTHLY INSPECTION DATA
Inspector
Date
1 Slurry Pipehne
2 Diversion Ditches and Diversion Berm
Observation
Diversion Ditch I
Diversion Ditches
Sloughing
Erosion
Undesirable
Vegetatton
Obstmction of Flow
Diversion Berm
Stability Issues
Signs of Distress
_yes_
_yes.
_yes_
.yes.
_no
_no
.no
no
Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
.yes_
_yes_
_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
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Page 36 of 55
4 Overspray Dust Mimmization
Overspray system functioning properly .yes_
Overspray camed more than 50 feet from the cell
If yes was system immediately shut off^
Comments
no
.yes_
_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 8C
Cell 2W3 S
Cell 2E1 N
Cell2El 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
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APPENDIX A (CONT)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector
Date
1 Embankment Inspection
2 Operations/Maintenance Review
3 Construction Activities
4 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
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Book 11 Environmental Protection Manual Section 3 1 Page 39 of 55
APPENDIX A (CONT)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of InspecUon
Inspector
Weather condiUons for the week
Blowing dust conditions for the week
CorrecUve 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 mdicated on the attached diagram maintained
within water Ught contamers
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 correcUon date*?
Is there free standing water or water mnning off of the feedstock stockpiles'?
Yes No
Comments
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Page 40 of 55
Other comments
.1 ti
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Book 11 Environmental Protection Manual Section 3 1 Page 41 of 55
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 detenoratton or damage of the pad surface'? Yes ^No
Findings
Repair Work Required
Existing Decontamination Pad
Were there any observed problems with the steel tank*? Yes ^No
Findings
Repair Work Required
Note For the annual inspection of the both the Existing and New Decontamination Pads the
annual inspection findings any repairs required and repairs completed along with a summary of
the weekly inspections shall be discussed in the 2"'' Quarter report due September 1 of each
calendar year
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APPENDIXB
8 3 TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management designated individuals for
conducting daily tailings inspections Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department Daily tailmgs inspections are conducted in
accordance with the White Mesa Mill Tailmgs Management System and Discharge Minimization
Technology (DMT) Monitonng Plan The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailmgs inspections Tailmgs
inspection forms will be included m the monthly tailings inspection reports which summarize 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 (requiring 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 corrective 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 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 Tailmgs 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
mspected for damage and loss of support Valves are also to be inspected particularly for
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Book 11 Environmental Protection Manual Section 3 1 Page 43 of 55
leaks blocked valves and closed valves Points of discharge need to be inspected for
improper location and orientation
Operational Systems
i
Operating sjjstems 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 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 nearing
maximum operating level and for large changes in the water level since the last mspection
All pumping activities affecting the water level will be documented In Cells 1 and 3 the
PVC liner nieeds to be monitored closely for exposed liner especially after storm events It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner Small areas of exposed liner should be covered by hand Large sections of
exposed 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 wntten by the
Radiation Safety Officer and tumed mto 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 I 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 oiitbreak For crests areas of concem are cracks subsidence and severe erosion
When any pf these conditions are noted an X mark should be placed in the section marked
for that dike
In addition the dikes in 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 prairie dogs are likely to
burrow in|deep possibly to the liner If any of these conditions exist the inspection report
should be marked accordingly
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Book 11 Environmental Protection Manual Section 3 1 Page 44 of 55
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 nunute (GPM) Rates need to be determined for slurry lines pond retum SX
tails and the spray system Durmg 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 in place the tailings and
build up IS to be monitored and controlled so as to not cover the flags
6 Dust Control
Dusting and wmd 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 wmd 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 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 Tailmgs Cells
The last section of the inspection involves drawing as accurately as possible the following
items where applicable
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Book 11 Environmental Protection Manual Section 3 1 Page 45 of 55
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 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 4A and 4B dike) is 15 mph These linuts should not
be exceeded
2 No food or drmk is permitted m the area
3 All personnel entering the tailmgs area must have access to a two way radio
4 Horseplay is not permitted at any time
5 Only those specifically authonzed may operate motor vehicles in the restricted area
6 When road conditions are muddy or slick a four wheel dnve vehicle is required in the
area
7 Any work performed m 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 j acket 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 authonzes certification Refer to the Certification
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Form Appendix C This form should be signed and dated only after a thorough review of the
tailings mformation previously presented The form will then be signed by the Radiation
Safety Officer and filed
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Book 11 Envu-onmental Protection Manual Section 3 1 Page 47 of 55
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 mspections analysis of potential problems (dike
failures unusual fiows) notification procedures and safety
Signature
I certify that the above named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill
Radiation Safety Personnel/ Tailings System
Supervisor
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APPENDIX D
FEEDSTOCK STORAGE AREA
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DenldonMHilds (U8^ Coip
N
I caini
wHrmME^ MU.
rmr HL
FoedtitQCfe 8toni0e AiBa Map
l''»*oa^Bggow|rn-ir"hi
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APPENDIX E
TABLES
1 'i
1' If ,
!
' r
1 '1
I
1 1'
>,
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Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 222 04
10 314 01
15 384 58
20 444 08
25 496 50
30 543 88
35 587 46
37 604 01
Table 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
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Book 11 Environmental Protection Manual Section 3 I Page 52 of 55
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' 'l I-
1 V ^
4 H Vf>! V
V il •3 1
I'It
^ ^ T '^•^^ .
j; • IS-l ^
I
^ I"
it . !•
I
1 L 1
I'-'' r''h
5 f.
-iiv .11-,
4 1 3
1 1
1 '5
^1
1 .i 1
f
1
White Mesa Mill - Standard Operatmg Procedures
Book 11 Environmental Protection Manual Section 3 1
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Page 53 of 55
APPENDIX F
Example of Freeboard Calculations
For Cell 4B
Assumptions and Factors
o Total PMP volume to be stored m Cell 4B - 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 m the following table
Time Period Expected
Tailings Solids
Disposition mto
Cell 4B
Determmed at
the beginnmg of
the period (dry
tons)*
Expected
Tailings
Solids
Dispositio
n into Cell
4B at the
beginning
of the
period,
multiplied
by 150%
Safety
Factor
(dry tons)
Actual Tailings
Solids
Disposition into
Cell 4B
determmed at
end of the
period (dry
tons)*
March 1 2012
to November 1
2012
150 000 225 000 225 000
November 1
2012 to
November 1
2013
300 000 450 000 275 000
November 1
2013 to
November 1
2014
200 000 300 000 250 000
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*These expected and actual tailmgs and production numbers and dates are fictional and have
been assumed for illustrative purposes only
Based on these assumptions and factors the freeboard limits for Cell 4B would be calculated
as follows
1 Prior to March L 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 therefore the freeboard limit is set at 5 594 6 FMSL
2 March 1. 2012 to November L 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 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 L 2013
The pool surface area would be reduced to the following amount
First recalculate the pool surface area that should have applied during the previous period
had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period Since the actual tonnage of 225 000 dry tons was the same as
the modeled tonnage of 225 000 dry tons the recalculated pool surface area is the same as
the modeled pool surface area for the previous period which is 31 77 acres
Then calculate the modeled pool surface area to be used for the period
(1-450 000/(2 094 000-1 OOOOOO 225 000))x31 77acres = 15 32acres
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 linut 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
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White Mesa Mill - Standard Operating Procedures 2/12 Revision Denisonl 1 5
Book 11 Environmental Protection Manual Section 3 1 Page 55 of 55
4 November 1. 2013 to November 1. 2014
The pool surface area would be reduced to the following amount
First recalculate the pool surface area that should have applied during the previous period
had modeled tonnages (i e expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period Since modeled tonnages exceeded actual tonnages the pool
area was reduced too much during the previous period and must be adjusted The
recalculated pool area for the previous period is
(1-275 000 / (2 094 000 - 1 000 000 225 000) x 31 77 acres = 21 72 acres
This recalculated pool surface area will be used as the starting pomt for the freeboard
calculation to be performed at November 1 2013
Then calculate the modeled pool surface area to be used for the period
(1 - 300 000/ (2 094 000 - 1 000 000 225 000- 275 000)) x 21 72 acres
10 75 acres
Based on this reduced pool area the amount of freeboard would be 197 5 acre feet divided by
10 75 acres equals 18 37 feet When the wave mn up factor for Cell 4B of 0 77 feet is added
to this the total freeboard required is 19 14 feet This means that the freeboard limit for Cell
4B would be reduced from 5586 7 FMSL to 5581 2 FMSL (5600 4 FMSL minus 18 4 feet
rounded to the nearest one tenth of a foot) This calculation would be performed at
November 1 2013 and this freeboard hmit would persist until November 1 2014
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REDLINE
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WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND
DISCHARGE MINIMUMIZATION TECHNOLOGY fDMT)
MONITORING PLAN
Revision 11 5
Februarv 2012
Prepared bv
Denison Mines (USA) Corp
1050 17*** Street Suite 950
Denver. CO 80265
White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Denisonl 1 45
Book 11 Environmental Protection Manual Section 3 1 Page 2 of 55
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
Contents
1 INTRODUCTION 4^
2 DAILY TAILINGS INSPECTIONS 4^
2 1 Daily Comprehensive Tailings Inspection 4^
2 2 Daily OperaUons Inspection 76
2 3 Daily Operations Patrol 76
2 4 Trainmg 76
2 5 Tailmgs Emergencies 76
3 WEEKLY TAILINGS AND DMT D^JSPECTION 8^
3 1 Weekly Tailings Inspections 8?
Northing 1343
Easting 1343
3 2 Weekly Inspection of Solution Levels in Roberts Pond I6i§
3 3 Weekly Feedstock Storage Area InspecUons 16t§
4 MONTHLY TAILINGS INSPECTION 1615
5 QUARTERLY TAILINGS INSPECTION 1746
6 ANNUAL EVALUATIONS l&i^
6 1 Annual Technical Evaluation 184?
6 2 Movement Monitors 1948
6 3 Freeboard Limits 1948
6 3 1 Cell 1 20i9
6 3 2 Cell 2 2019
6 3 3 CeU 3 2019
6 3 4 CeU 4A 2019
6 3 5 Cell 4B 2130
6 3 6 Roberts Pond 2333
6 4 Annual Leak Detection Fluid Samples 2435
6 5 Annual Inspection of the Decontanunation Pads 2435
7 OTHER INSPECTIONS 2435
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I White Mesa Mill - Standard Operating Procedures
Book 11 Environmental Protection Manual Section 3 I
W/12 Revision DemsonlI45
Page 3 of 55
REPORTING REQUIREMENTS
8 1 Monthly Tailings Reports
8 2 DMT Reports
8 3 TAILINGS INSPECTOR TRAINING
2535
2534
2534
4241
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Denisonl I 45
Book 11 Environmental ProtecUon Manual Section 3 I Page 4 of 55
1 INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Momtonng 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 UTl900479 (the
Radioactive Matenals License ) as weU as procedures for operating and maintenance of momtonng
equipment and reportmg procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No 370004 for the MiU (the GWDP )
This Plan is designed as a systematic program for constant surveillance and documentation of the
integnty of the tailings impoundment system mcluding dike stability liner mtegnty 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 repomng to Mill management
2 DAILY TAILINGS INSPECTIONS
The followmg daily tailings inspections shaU be performed
2 1 Daily Comprehensive Tailings Inspection
On a daily basis mcludmg weekends all areas connected with the evaporation cell (Cell 1) and
thefour tailings cells (CeUs 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 performmg the daily tailings
inspections The RSO may designate other individuals with training as descnbed in Section 2 4
below to perform the daily tailings mspection
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 mspection checkhst
which mcludes a tailmgs cells map and spaces to record observations especiaUy those of immediate
concem and those requinng corrective action The inspector will place a check by all mspection
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 specifymg 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 corrective action
was taken should be noted as well
Areas to be inspected mclude the followmg Cell 1 2 3 4A and 4B Dikes 4A S 4A E and 4B
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I White Mesa Mill - Standard Operating Procedures 4'2/12 Revision Demson 11 45
Book 11 Environmental Protection Manual Section 3 I Page 5 of 55
S wmd movement of tailmgs effectiveness of dust minimization methods spray evaporation CeU 2
spillway Cell 3 spillway CeU 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
followmg items require visual mspection 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 tailings lines are required to be performed when the Mill
is operatmg The lines to be inspected include the tailmgs slurry lines from CCD
to the active tailings cell SX raffinate lines that can discharge into Cell 1 CeU
4AorCeU4B the pond retum lme from the tailings area to the MiU and lines
transporting pond solutions from one cell to another
b) CeU 1
c) Cell 2
d) Cell 3
e) Cell 4A
f) CeU 4B
g) Dike stmctures mcluding dikes 4A S 4A E and 4B S
h) The CeU 2 spillway CeU 3 spiUway Cell 4A spillway Cell 3 Cell 4A and CeU
4B liquid pools and associated liquid retum equipment
i) Presence of wildlife and/or domesticated animals m the tailings area including
waterfowl and burrowing animal habitations
j) Spray evaporation pumps and lines
k) Wind movement of tailings and dust minimization
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust mimmization measures for cells contammg tailmgs
sand Durmg tailings inspection general surface conditions will be evaluated for
the following 1) areas of tailings subject to blowing and/or wind movement 2)
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I White Mesa Mill - Standard Operating Procedures 4-2/12 Revision DemsonII45
Book 11 Environmental Protection Manual Section 3 I Page 6 of 55
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
minmuzation activities
1) Observation of flow and operational status of the dust contiol/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 tailmgs cells map included in the
Daily Inspection Data form
o) An estimate of flow for active taUmgs slurry and SX line(s)
p) An estimate of flow in the solution remm line(s)
q) Daily measurements in the leak detection system sumps of the tailings cells wiU
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 in the Cell 1 and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours The
solution level in CeU 4A or 4B leak detection system is not aUowed 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 MUl s Radioactive Matenals License to
detemune whether or not the flow rate into the leak detection system is in excess
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Denisonl 1 45
Book 11 Environmental Protection Manual Section 3 1 Page 7 of 55
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 inspection of the tailings lme 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 patrol
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 patiols need be made but the inspectors will notify the RSO and/or MiU
management m the event that dunng their inspection they discover that an abnormal condition or
tailings emergency has occurred
2 4 Training
All individuals performmg inspections descnbed in Sections 2 1 and 2 2 above must have Tailings
Management System training as set out in the TaUings 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 occurred that could cause a tailings
emergency Until relieved by the Environmental or Technician or RSO inspectors will have the
authonty to direct resources dunng tailings emergencies
Any major catastiophic events or conditions pertaimng to the tailings area should be reported
immediately to the Mill Manager or the RSO one of whom will notify Corporate Management If
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Demson 11 45
Book 11 Environmental Protection Manual Section 3 1 Page 8 of 55
dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager
will then notify Corporate Management MSHA (303 231 5465) and the State of Utah Division of
Dam Safety (801 538 7200)
3 WEEKLY TAILINGS AND DMT INSPECTION
3 1 Weekly Tailings Inspections
Weekly tailmgs inspections are to be conducted by the Radiation Safety Department and include the
following
a) Leak Detection Systems
Each taihngs 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 CeUs 4A and 4B) and indicates the
presence of solution with a wanung light The Cell 4A and 4B leak detection
systems are momtored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector The pressure
tiansducer is cahbrated 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 mch The data coUector is currently
programmed to store 7 days of water level information The number of days of
stored data can be increased beyond 7 days if needed For Cells 1 and 3 the
water level data is recorded on the Daily Tailings Inspection Form For CeUs 4A
and 4B the water level data is downloaded to a laptop computer penodically and
incorporated into the Mill s environmental monitonng 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
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Denisonl I 45
Book 11 Environmental Protection Manual Section 3 1 Page 9 of 55
For Cells 1 and 3 upon the imtial 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 lmer To determme 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 agamst 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
CeU4Aand4B
b) Slimes Drain Water Level Monitoring
(i) CeU 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 dram
system which aids in dewatenng the shmes and sands placed in the cell
(II) Denison re graded the intenm fiU on Cell 2 m 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 CeU 2 the shmes 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 bottom of the shmes drain The measunng point on the extension pipe
was surveyed by a Utah Certified Land Surveyor The measunng point elevation is
5618 73 fmsl 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
slimes dram As taken from actual measurements the bottom of the shmes dram is
37 97 feet below a water level measunng pomt which is a notch on the side of the
Cell 2 shmes drain access pipe This means that the bottom of the shmes dram 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 measunng point on the shmes dram access pipe for Cell 2
(ill) The slimes dram 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
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision DemsonI I 45
Book 11 Environmental Protection Manual Section 3 I Page 10 of 55
the float mechanism the pump is activated Pumping then occurs untd 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 dram standpipe and the float valve is located at
three feet above the bottom of the shmes dram standpipe The average wastewater
head in the Cell 2 shmes dram is therefore less than 3 feet and is below the phreatic
surface of tailings CeU 2 about 27 feet below the water level measunng point on the
shmes drain access pipe As a result there is a continuous flow of wastewater from
Cell 2 into the shmes dram collection system Mill management considers that the
average allowable wastewater head in the CeU 2 shmes drain resulting from pumping
in this manner is satisfactory and is as low as reasonably achievable
(iv) The CeU 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 withm 15 days
(v) Depth to wastewater in the Cell 2 shmes dram access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle respectively The extension of the CeU 2 shmes 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 elevation of the measunng point
IS 5618 73 fmsl The head measurements are calculated in the same manner using
the same procedures as those used pnor to the extension of the CeU 2 slimes dram
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 5618 73 fmsl) and made to the nearest 0 01 foot
The results wiU be recorded as depth in pipe measurements on the Weekly Tailings
Inspection Form The equation specified in the GWDP will be used to calculate the
slimes drain recoverv elevation (SDRE) To calculate the SDRE contemplated by the
GWDP. the depth to wastewater in the Cell 2 shmes drain access pipe (in feet) will
be subtracted from the surveyed elevation of the measunng point The calculation is
as foUows
5618 73 Depth to wastewater in the Cell 2 shmes dram access pipe = SDRE
It IS important to note that Tthe 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 dram access pipe height) used in the calculation has
changed The head is calculated by subtracting the depth to liquid from 37 97 feet
rather than from the previous measurement of 38 feet The weekly Taihngs
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 dram pump wiU be mmed off
and the wastewater in the shmes drain access pipe will be allowed to stabilize for at
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision DemsonI I 45
Book 11 Envu-onmental Protection Manual Section 3 1 Page 11 of 55
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
Quarterly Data form by measunng the depth to water below the water level
measunng point on the shmes dram access pipe
(vn) No process liquids shall be allowed to be discharged into CeU 2
(vm) 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 includmg the
requirement to provide notification to the Executive Secretary orally withm 24 hours
followed by wntten notification
(IX) Because CeU 3 and Cell 4A are currentiy active no pumpmg from the CeU 3 or CeU
4A shmes dram is authonzed No pumpmg from the Cell 4B shmes dram will be
authonzed once it is put into service and while it is active Pnor to mitiation of
tailings dewatenng operations for Cell 3 Cell 4A or Cell 4B a sinular procedure
will be developed for ensunng 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 shmes drains are mspected 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 contiol measures
shall be taken if needed
d) Tailings Wastewater Pool Elevation Monitonng
Solution elevation measurements in CeUs 1 4A and 4B and Roberts Pond are to be taken by* j Formatted justified
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 )
(ii) The survey wdl be performed 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 CeU 1 The elevation of the metal disk (the Reference Point Elevation )
for Cell I 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
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision DemsonI I 45
Book 11 Environmental Protection Manual Section 3 1 Page 12 of 55
next to the transformer on the south side of CeU 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 Uiis is typically on the soutii side of CeU 4A and 4B
(iv) Once in location the Surveyor will ensure that the Survey Instmment is level by
centenng the bubble in the level gauge on the Survey Instmment
(v) The Assistant will place the Survey Rod verticaUy 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 estabhshed 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
Pomt
(vu) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the mam 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 consistentiy 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 measurement of solution level will commence within 30 days of
authonzation for use Measurements will be conducted consistent with the procedures as descnbed
above in items d) (i) through d) (vii) of this Section in this DMT Plan and consistent witii current
Mill health and safety procedures The measurements wiU be completed using survey equipment and
the appropnate 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
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White Mesa Mill - Standard Operating Procedures
Book 11 Environmental Protection Manual Section 3 1
4-2/12 Revision DemsonI I 45
Page 13 of 55
The Assistant will walk down the slope in the southeast comer of Cell 4B and
place the Survey Rod at the liquid level
m CeU 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 tiiat mark
and hold the rod vertically with one endjust touching the liquid surface and
rv 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
Northing Easting
Roberts Pond 323 041 2 579 697
CeU 1 322 196 2 579 277
CeU 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 CeUs
CeU 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 tiiat
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 pomt 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
(vm) The Assistant will hold the Survey Rod verticaUy with one end of the Survey
Rod just touching the pond surface 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
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Book 11 Environmental Protection Manual Section 3 I Page 14 of 55
(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 Readmg 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 CeU 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
Decontanunation 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
in each portal will be measured weekly by physically measunng the
depth to water with an electncal sounding tape/device AU
measurements must be made from the same measunng point and be
made to the nearest 0 01 foot
C These inspections wiU 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 detemuned by subtiactmg the
weekly depth to water measurement from the distance from the
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
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision DemsonI I 45
Book 11 Environmental Protection Manual Section 3 I Page 15 of 55
shall indicate a leak in the pnmary containment
E Any observation of fluid between tiie 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 mtegnty of the
exposed surfaces of the pad will be inspected on a weekly basis Any
soil and debns wiU be removed from the New Decontammation Pad
immediately pnor to inspection of the concrete wash pad for crackmg
Observations will be made of the current condition of the New
Decontanunation Pad Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tatiings Inspection form If there are any cracks greater than
1/8 inch separation (widtii) 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
MiU s mamtenance shop and the ore feeding gnzzly
A The Existing Decontamination Pad will be inspected on a weekly
basis Any soil and debns wiU be removed from the Existing
Decontanunation Pad immediately pnor to inspection of the concrete
wash pad for cracking Observations will be made of the current
condition of the Existing Decontamination Pad including the
concrete mtegnty 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
Taihngs Inspection form If there are any cracks greater than 1/8 inch
separation (width) the RSO must be contacted The RSO will have
the responsibility to cease activities and have the cracks repaired
f) Summary
In addition the weekly inspection should summanze all activities concermng the
tailings area for that particular week
Results of the weekly tailmgs inspection are recorded on the Weekly Tailings and DMT Inspection
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Book 11 Environmental Protection Manual Section 3 I Page 16 of 55
form An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A
3 2 Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis solution elevations are taken on Roberts Pond in accordance with the procedures
set out in Section 3 1 d) above The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form Based on 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 Readmg area is at or below the FML
for that area the pond will be recorded as being dry
3 3 Weekly Feedstock Storage Area Inspections
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 withm the defined area descnbed in
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 containers
The results ofthis inspection wiU be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report a copy of which is contained in 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 tailings inspection and can be conducted concurrently with the quarterly
tailings mspection 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
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Book 11 Environmental Protection Manual Section 3 I Page 17 of 55
locations to detemune pipe wear The cntical pomts 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 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 mmimization if applicable
This entails ensunng that the overspray system is functiomng properly In the event
that overspray is camed 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 taihngs inspections for the specific month
In addition settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form
5 QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department having the training specified in Section 2 4 above once per
calendar quarter A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed
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White Mesa Mill - Standard Operating Procedures 4-2/12 Revision Denisonl I 45
Book 11 Environmental Protection Manual Section 3 1 Page 18 of 55
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 shnnkage cracks
and exposed lmer
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaimng to tiie taihngs 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
e) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis
If any of these conditions are noted the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form An example of the Quarterly Inspection Data
form IS provided in Appendix A
6 ANNUAL EVALUATIONS
The followmg annual evaluations shall be performed
6 1 Annual Technical Evaluation
An annual technical evaluation of the taihngs management system is performed by a registered
professional engineer (PE) who has expenence and training in the area of geotechmcal aspects of
retention stmcmres 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
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Book 11 Environmental Protection Manual Section 3 I Page 19 of 55
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5 2 below)
All taihngs cells and corresponding dikes will be inspected for signs of erosion subsidence
shnnkage and seepage The drainage ditches will be inspected to evaluate surface water control
stmcmres
In the event taihngs 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 wiU be reviewed to ensure that the maximum taihngs capacity estimate is accurate The
amount of tailings added to the system since the last evaluation will also be calculated to determme
the estimated capacity at the time of the evaluation
Tailings inspection records will consist of daily weekly monthly and quarterly taihngs inspections
These inspection records will be evaluated to detemune if any freeboard linuts 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
annual inspection photographs of the tailings area will be taken The trammg of individuals will be
reviewed as a part of the Annual Techmcal Evaluation
The registered engineer wiU obtam copies of selected tailmgs 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 Aimual Techmcal Evaluation Report must be submitted by November IS**" of every year to the
Executive Secretary
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 5-S-
^ A W and 4A S 4A E. 4A S. and 4B 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 Linruts
The freeboard Imuts 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
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 20 of 55
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 CeU 2 and Cell 3 pond areas plus the adjacent
drainage areas was calculated in the Drainage Report to be 123 4 acre feet of water
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre feet of water (40 acres plus the adjacent drainage area of 3 25 acres) times
the PMP of 10 inches) with a wave mn up factor of 0 77 feet
The flood volume from the PMP event over the CeU 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 tiie PMP of 10
inches with a wave mn up factor of 0 77 feet
The total pool surface area in CeU 1 is 52 9 acres in Cell 4A is 40 acres and m 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 linuts for the Mill s tailings cells will be set as follows
63 1 CeU 1
The freeboard limit for Cell 1 will be set at 5 615 4 FMSL This wiU allow CeU 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 tiie wave mn up factor of0 90 feet equals 2 85 feet The
freeboard Imut is tiien 5 618 2 FMSL nunus 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 CeU 2
The freeboard Imut for Cell 2 is inapplicable since CeU 2 is fiUed with solids AU of the PMP
volume associated witii Cell 2 will be attnbuted to Cell 4A (and/or any fiimre tailings cells)
633 CeU 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 wiU be attnbuted to Cell 4B (and/or any fumre
tailings cells)
634 Cell 4A
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 21 of 55
The freeboard linut for Cell 4A is inapplicable since all of the PMP flood volume associated with
CeU 4A will be attnbuted to Cell 4B A spiUway has been added to Cell 4A to allow overflow into
CeU4B
635 Cell 4B
The freeboard linut for Cell 4B will be set assunung tiiat 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 Imut 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
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 assunung no storage in 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 in (a) above This allows for the simation where
there may be beaches but these beaches are at a lower elevation than the freeboard linut 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 wiU be detemuned by monthly surveys
performed by MiU 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 in Cell 4B first exceeds 5 594 FMSL then the
freeboard hmit for the remainder of the ensuing year (penod t=0) (until the next November 1) wtil be
calculated when tiiat elevation is first exceeded (the Initial Calculation Date ) as follows
i) The total number of dry tons of tailings that have histoncally been deposited mto CeU
4B pnor to the Initial Calculation Date ( To ) will be detemuned
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Book 11 Envuonmental ProtecUon Manual Section 3 1 Page 22 of 55
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
penod ( Ao* ) will be detemuned
m) AQ* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that wtil be deposited in the cell dunng the
remainder of the ensuing year This grossed up number can be refened to as the
modeled tonnage for the penod
iv) The total design tailmgs solid storage capacity of Cell 4B will be accepted as
2 094 000 dry tons of tailings
v) The available remaining space in CeU 4B for solids as at the Initial Calculation Date
will be calculated as 2 094 000 dry tons nunus To
VI) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directiy proportional to the reduction in the available space in Cell 4B
for solids That is the reduced pool surface area for penod t=0 ( RPAo ) after the
reduction will be calculated to be
(1 - (Ao* X 1 5) / (2 094 000 To)) x 40 acres = RPAo
VII) The required freeboard for Cell 4B for the remainder of the penod t=0 can be
calculated in feet to be the wave mn up factor for CeU 4B of 0 77 feet plus the
quotient of 197 5 acre feet divided by tiie RPAo The freeboard limit for Cell 4B for
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
vm) 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 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 m pool area for the
ensuing year (referred to as penod t) wiU be calculated by
i) First calculating the Adjusted Reduced Pool Area for the previous penod (ARPAt i)
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 acmal tonnages for year t 1 been known at the 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 - A, 1 / (2 094 000 - Tt 0) x ARPAt 2 = ARPAt 1
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Where
• At 1 is the acmal number of dry tons of tailings solids deposited in Cell 4B
dunng penod t 1
• Tt 1 IS the acmal number of dry tons of taihngs solids histoncally deposited m
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 i is 40 acres
ii) Once tiie ARPAt i 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 i = RPAt
Where
• At* IS the expected number of dry tons of tailings to be deposited into CeU 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)
• Ttis the acmal number of dry tons of taihngs solids histoncally deposited in
Cell 4B pnor to the begmmng of penod t and
• 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
III) The required freeboard for penod t can be calculated in feet to be the wave mn up
factor for CeU 4B of0 77 feet plus tiie quotient of 197 5 acre feet divided by tfie RPAt
The freeboard limit for CeU 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 die next Annual 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 CeU 4B and a new tailings cell then if an approved freeboard
Imut 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
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Book 11 Environmental ProtecUon Manual Section 3 I Page 24 of 55
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5 624 0 feet above mean sea
level as specified in the GWDP
6 4 Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system a sample wtil be collected on an
annual basis This sample will be analyzed according to the conditions set forth in License
Condition 11 3 C The results of the analysis will be reviewed to determine the ongin of the
solution
6 5 Annual Inspection of the Decontanunation Pads
a) New Decontamination Pad
Dunng the second quarter of each year the New Decontamination Pad will be taken out of service
and inspected to ensure the mtegnty 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
the use of the facility All mspection findings and any repairs required shaU be documented on the
Annual Decontamination Pad Inspection form The inspection findmgs any repairs required and
repairs completed shaU be summanzed in the 2 Quarter DMT Momtonng Report due September 1
of each calendar year
b) Existing Decontanunation 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 If any abnormalities are identified defects or damage
wiU 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 findmgs any repairs required and
repairs completed shall be summanzed in tiie 2nd Quarter DMT Monitonng Report due
September 1 of each calendar year
7 OTHER INSPECTIONS
AU daily weekly monthly quarterly and annual inspections and evaluations should be performed as
specified in Sections 2 3 4 5 and 6 above However additional inspections should be conducted
after any sigmficant storm or significant namral or man made event occurs
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Book 11 Environmental ProtecUon Manual SecUon 3 I Page 25 of 55
8 REPORTING REQUIREMENTS
hi 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 in Sections 2 and 3 respectively the following additional reports shall also be prepared
8 1 Monthly Tailings Reports
Montiily tailings reports are prepared every month and summanze the previous month s activities
around the taihngs area If not prepared by the Radiation Safety Officer tiie report shall be
submitted to the Radiation Safety Officer for review The Mill Manager will review the report as
well before the report is filed in the Mill Central File The report wtil 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 montiily inspection form wiU
also be attached Quarterly inspection forms will accompany the report when apphcable The report
will be signed and dated by tiie preparer in addition to tiie Radiation Safety Officer and the MiU
Manager
82 DMT Reports
CJuarterly 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 requned information required by Part 1 F 2 of tiie GWDP
relating to the inspections descnbed in Section 3 1(b) (Shmes Drain Water Level
Momtonng) 3 1(d) (Tailings 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) mspections for
the quarter for the presence of fluid in all three vertical mspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontammation Pad which will include a table indicatmg the water level
measurements in each portal dunng the quarter
c) With respect to the annual inspection of the New Decontammation 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
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 26 of 55
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 sununanzed m 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 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
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 27 of 55
APPENDIX A
FORMS
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Page 28 of 55
APPENDIX A (CONT)
DAILY INSPECTION DATA
"{ Formatted Section start New page
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 Cdl2 CeU 3 Cell 4A Cell 4B
Slurry Pipeline Leaks Damage Blockage Sharp Bends
Pipelme Joints Leaks Loose Connections
Pipelme Supports Damage Loss of Support
Valves Leaks Blocked Closed
Point(s) of Discharge Improper Location or Onentation
II OPERATIONAL SYSTEMS and INTERIOR of CELLS
Inspection Items Conditions of Potential Concem Cell 1 CeU 2 Cell 3 CeU4A Cell 4B
N S E w N S E w N S E w
Intenor Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level Large
Change Since Previous Inspection
Beach Cracks Severe Erosion Subsidence
Liner and Cover Erosion of cover Exposure of Lmer
-(Formatted Table
-(Formatted Centered
-[ Formatted Table
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Book 11 Environmental ProtecUon Manual SecUon 3 1
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Page 29 of 55
Liner Observable Lmer Damage
1 1 1 1 1 1 1 I
m 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 Sliding Cracks No No No No
Bulges Subsidence Severe visible visible visible visible
Erosion Moist Areas Areas extenor extenor extenor extenor
of Seepage Outbreak slope or slope or slope or slope or
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
extenor extenor extenor extenor
slope or slope or slope or slope or
dike to dike to dike to dike to
mspect inspect inspect mspect
IV FLOW RATES
Slurry Line(s) Pond Remm S X Tails Spray System
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 CeU 3 Cell 4A Cell 4B
Dusting
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Page 30 of 55
Wmd Movement of Tailings
Precipitation inches liquid
General Meteorological conditions
VII DAILY LEAK DETECTION CHECK | |
Cell 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 Dry 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
Fmal
level
Final
level
Leak
Detection
System
Checked
Gal pumped Gal pumped Gal pumped Gal pumped Gal pumped
vm OBSERVATIONS OF POTENTIAL CONCERN Action Required
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Page 31 of 55
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Tailings Dail>' Inspection Report
Tailing Sluny Dischaige Location
/r MILL SITE
CELL NO 1
o a
<a
Ou
«N1
T3 C/3
<a
1%
I c
=3 P
1/3
U
Dike IT,
ia "1
CELL NO 2
Filled
/, CELL NO 4A
Date
hispectoi /
s
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Book 11 Environmental ProtecUon Manual Section 3 I Page 33 of 55
APPENDIX A (CONT)
DENISON MINES (USA) CORP
WEEKLY TAILINGS INSPECTION
Date Inspectors
1 Pond and Beach Cell I (a) Pond SoluUon Elevation
elevaUons (msl ft)
(b) FML Bottom Elevation 5597.
(c) Depth ofWater above FML ((a) (b))
CelI4A (a)Pond Solution Elevation
(b) FML Bottom ElevaUon 5555 14_
(c) Depth of Water above FML ((a) (b))
CelI4B (a)Pond Solution Elevation
(b) FML Bottom Elevation 5557 50
(c) Depth ofWater above FML ((a) (b))
(d) Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond (a)Pond SoluUon ElevaUon
(b) FML Bottom Elevation 5612 3.
(c) Depth of Water above FML ((a) (b))
2 Slimes Drain Liquid Levels Cell 2 Pump functionmg properly.
_Depth to Liquid pre pump
.Depth to Liquid Post pump
(all measurements are depth in pipe)
Pre pump head is 37 97 Depth to Liquid Pre
pump =
Post pump head is 37 97 -Depth to Liquid Post
pump =
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Page 34 of 55
3 Leak DetecUon 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
_Ftto
Liquid
Ft to
Liquid
Ft to
If wet Report to
RSO
4 Tailmgs 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 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 mches above the lowest point on the bottom flexible
membrane liner (elevation 5556 14 amsl) notify supervisor or Mill manager immediately
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 35 of 55
APPENDIX A (CONT)
MONTHLY INSPECTION DATA
Inspector
Date
1 Slurry Pipeline
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
Vegetation
Obstruction of Flow 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
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Book 11 Environmental ProtecUon Manual SecUon 3 I Page 36 of 55
4 Overspray Dust Mmimization
Overspray system functionmg properly yes_
Overspray camed more than 50 feet from the cell ^yes_
If yes was system immediately shut off^ yes_
Comments
5 Remarks
6 Settlement Monitors
Cell 2 Wl Cell 2W3 S Cell 3 IN _
CeU 2 W2 Cell 2E1 N Cell 3 IC _
CelI2W3 CeI12El IS Cell 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 CeU2W6S Cell 2 W4N
Cell 4A Toe Cell 2 W4S Cell 2 W5C
Cell3 2C Cell3 2S CelI2W5S
Cell 3 38 Cell 3 3C CeII3 3N _
Cell 3 4N Cell 3 6N Cell 3 78 _
Cell 3 7C Cell 3 7N Cell 3 88 _
Cell 3 8C Cell 3 8N
7 Movement Monitors (Is there visible damage to any movement monitor or to adjacent
surfaces)*^
8 Summary of Daily Weekly and Quarterly Inspections
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 37 of 55
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Page 38 of 55
APPENDIX A (CONT)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector
Date
1 Embankment Inspection
2 Operations/Maintenance Review
3 Construction Activities
4 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
Comments
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Book 11 Environmental ProtecUon Manual SecUon 3 I Page 39 of 55
APPENDIX A (CONT )
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection
Inspector
Weather condiUons for the week
Blowing dust condiUons 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 mamtained
within water tight containers
yes no
comments (e g condiUons 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 mnning off of the feedstock stockpiles'^
Yes No
Comments
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Book 11 Environmental Protection Manual SecUon 3 1 Page 40 of 55
Other comments
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ll 1
I 1
•i ^ I
il
?.
i
r
, 1 I
1
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Book 11 Environmental Protection Manual Section 3 1 Page 41 of 55
APPENDIX A (CONT)
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection
Inspector
New Decontamination Pad
Are there any cracks on the wash pad surface greater than 1/8 inch of separation*^ Yes No
Is there any significant deterioration or damage of the pad surface'^ Yes No
Findings
Repair Work Required
Existing Decontamination Pad
Were there any observed problems with the steel tank*^ Yes No
Findings
Repair Work Required
Note For the annual inspection of the both the Existing and New Decontamination Pads the
annual inspection findings any repairs required and repairs completed along with a summary of
the weekly inspections shall be discussed in the 2 ^ Quarter report due September 1 of each
calendar year
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Book 11 Environmental ProtecUon Manual Section 3 1 Page 42 of 55
APPENDIX B
8 3 TAILINGS INSPECTOR TRAINING
This document provides the traimng necessary for qualifying management designated mdividuals for
conducting daily tailings inspections Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department Datiy taihngs mspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Mimmization
Technology (DMT) Monitonng Plan The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections Tailings
inspection forms will be included in the monthly tailings inspection reports which 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 Ifconditionsofpotential concem exist the inspector should mark an X m the area
the condition pertains to note the condition and specify the corrective action to be taken If an
observable concem is made it should be noted on the tailings report untti 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 catastrophic events or conditions pertaining to the tailmgs area should be reported
immediately to the Mill Manager or the Radiation Safety Officer one of whom will notify Corporate
Management Ifdam failure occurs notify your supervisor and the MiU Manager immediately The
Mill Manager will then notify Corporate Management MSHA (303 231 5465) and the State of
Utah Division ofDam Safety (801 538 7200)
Inspections
AU areas of the tailmgs disposal system are routinely patroUed and visible observations are to be
noted on a daily tailings inspection form Refer to Appendix A for an example of the daily tailmgs
inspection form The inspection form consists of three pages and is summanzed as follows
I Tailmgs 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
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Book 11 Envu-onmental ProtecUon Manual SecUon 3 1 Page 43 of 55
leaks blocked valves and closed valves Pomts of discharge need to be inspected 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 datiy forms
Exposed liner 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 mspection
All pumping activities affecting the water level will be documented In Cells 1 and 3 the
PVC lmer needs to be monitored closely for exposed lmer especially after storm events It is
important to cover exposed lmer immediately as exposure to sunlight wtil cause degradation
of the PVC liner Small areas of exposed liner 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 tiiese 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 AH 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 slidmg 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
Inaddition the dikes in particular dikes 4A S 4A E and4B S should be inspected closely
for mice 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
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Book 11 Environmental ProtecUon Manual SecUon 3 I Page 44 of 55
4 Flow Rates
Presence of all flows in and out of the cells should be noted Row rates are to be estimated
in gallons per minute (GPM) Rates need to be determined for slurry lines pond remm SX
tails and the spray system Dunng 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 dunng operation of the
null If possible the inspection should include observation of the entire discharge hne and
discharge spill point into the cell If fill to elevation flags are in place the tailings and
build up IS to be momtored and controlled so as to not cover the flags
6 Dust Control
Dusting and wind movement of tatiings should be noted for Cells 2 3 4A and 4B Otiier
observations to be noted include 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 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 wiU be taken by Environmental Health and Safety personnel as close to 8 00
a m as possible AU 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 Corrective
action should follow each area of concem noted AU 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 inspection involves drawing as accurately as possible the following
Items where applicable
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 45 of 55
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 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 linut for
the tailings area (other than the Cell 4A and 4B dike) is 15 mph These Imuts should not
be exceeded
2 No food or dnnk is permitted in tiie area
3 All personnel entenng the tailings area must have access to a two way radio
4 Horseplay is not pemutted at any time
5 Only those specifically authonzed may operate motor vehicles in the restiicted 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 j acket 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 entenng the
tailings area All wtidlife 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 taihngs system
inspection program designated individuals will be certified to perform daily tailings
inspections The Radiation Safety Officer authonzes certification Refer to the Certification
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Book 11 Envu-onmental Protection Manual SecUon 3 I Page 46 of 55
Form Appendix C This form should be signed and dated only after a thorough review ofthe
taihngs information previously presented The form will then be signed by the Radiation
Safety Officer and filed
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 47 of 55
APPENDIX C
CERTIFICATION FORM
Date
Name
I have read the document titied Tailings Management System White Mesa Mill Tailings
Inspector Traimng and have received on site mstmction at the tailings system This instmction
mcluded documentation of daily tailings inspections analysis of potential problems (dtice
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
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Book 11 Environmental Protection Manual SecUon 3 I Page 48 of 55
APPENDIX D
FEEDSTOCK STORAGE AREA
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White Mesa Mill - Standard OperaUng Procedures
Book 11 Environmental Protection Manual Section 3 1
+2/12 Revision DemsonI 1 45
Page 49 of 55
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Book 11 Environmental Protection Manual SecUon 3 I
+2/12 Revision Denisonl 1 45
Page 50 of 55
1 X
APPENDIX E
TABLES
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'^• ll
,1 I"
31! j'
^ II
I [
1 ' '
White Mesa Mill - Standard Operating Procedures
Book 11 Environmental ProtecUon Manual SecUon 3 1
+2/12 Revision DemsonI I 45
Page 51 of 55
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)
5 211 40
10 317 00
15 369 90
20 422 70
25 475 60
30 528 40
35 570 00
37 581 20
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White Mesa Mill - Standard Operating Procedures
Book 11 Envu-onmental ProtecUon Manual SecUon 3 1
+2/12 Revision DemsonI I 45
Page 52 of 55
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Page 53 of 55
APPENDIX F
Example of Freeboard Calculations
For Cell 4B
Assumptions and Factors
o Total PMP volume to be stored in CeU 4BA - 159 4 acre feet
o Wave ranup factor for CeU 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 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
Tune Penod Expected
Tailings Solids
Disposition mto
Cell 4B
Determined at
the beginmng of
the penod (dry
tons)*
Expected
Tailings
Sohds
Dispositio
n into Cell
4B at the
beginmng
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
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Book 11 Environmental ProtecUon Manual Secuon 3 1 Page 54 of 55
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only
Based on these assumptions and factors the freeboard limits for Cell 4B would be calculated
as follows
1 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 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 Imut 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
lentil of a foot) This calculation would be performed at March 1 2012 and tius freeboard linut
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 acmal 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 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 linut for CeU
4B would be reduced from 5592 2 FMSL to 5586 7 FMSL (5600 35 FMSL nunus 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
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Book 11 Environmental ProtecUon Manual SecUon 3 1 Page 55 of 55
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 tonnages for the 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 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 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 linut would persist until November 1 2014
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