DRC-2011-004129 - 0901a068802227f8

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
April 20, 2011
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OFRADIATJON CONTROL
Rusty Lundberg
Director
CERTIFIED MAIL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: December 1, 2010 Transmittal Letter for Three Separate Draft SOP's; Movement
Monitoring Standard Operating Procedures [SOPs] 11/2010 Revision: DUSA-1;
Comments and Request for Information
We have received the subject December 1, 2010 letter which transmitted three separate Standard Operating
Procedures (SOPs). The subject of this letter is our review bf one of the SOPs, i.e. the Movement
Monitoring Standard Operating Procedures [SOPs]. DRC review of the other transmitted SOPs is
discussed in separate letters. The subject SOPs were submitted by DUSA to comply with the requirements
of License Condition 11.8. We have reviewed this item, and have the following comments:
1. General. Please bear in mind that since the items below pertain to License Conditions, your
response regarding them may be subject to enforcement. Therefore, complete and thorough
responses in this matter are important.
It appears that the most recent DUSA ATER report contained only vertical settlement data for
movement monitors. However, a primary function of movement monitors is to detect any
horizontal changes related to movement of the exterior southem boundary dikes. This needs to be
given more emphasis in the subject SOPs.
Some suggested red-line strike-out changes for the subject SOPs are attached. The majority of
these suggestions were derived from our review of the License Conditions. Please note that some,
sections of the red-line strike-out copy of the subject SOPs may contain several changes.
However, these shown changes are not extensive enough to meet all requirements.
195 North 1950 West • Salt Lake City, LIT
Mailing Address; P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
wnw.iieq.uiah.gov
Primed on 100% recycled paper
Page 2
License Condition 11.8, first paragraph, states that, "...The proposed SOP shall describe methods
for... monitoring potential vertical and horizontal movements in the constructed dike portions of
the tailings management cells, and for recording and documenting displacement monitoring data
and comparing such data to previous data to track potential movement (displacement). All data
collected by the Licensee for these purposes shall be included in an annual report to be submitted
to the Executive Secretary, pursuant to License Condition 12.3..."
^ DRC Findings: It appears that the subject submitted SOPs do not address horizontal
movement, and the range of time for comparing data to previous data. The scope of
comparison should be more than just the previous survey, but needs to compare movement
phenomenon from all previous years of data. License Condition 11.8 also applies tb using
the movement monitors to detect horizontal movements of the pertinent dikes. Please add
" detailed procedures to the subject SOPs to address this license condition completely.
License Condition 11.8C, directs DUSA in the subject SOPs to, "Include an obligation for the
Licensee to prevent man-caused damage to movement monuments, including, but not limited to
vehicle and construction traffic damage. Such measures will include:
1) all equipment, procedures, provisions need[ed] to protect said settlement monitoring devices,
2) schedules for rapid verbal and written reporting of any such damage, and
3) corrective actions taken or to be taken by the Licensee to replace
and/or repair said devices;"
DRC Findings: Recent history of the movement monitors shows the movement monitors
have been destroyed more than once by construction traffic. The intent of License
Condition 11.8C and 11.8.C.1 is for greater physical prevention against destruction or
damage, more than the existing configuration. Please add physical provisions for the
movement monitors, to the subject SOPs, "to prevent man-caused damage to movement
monuments, including, but not limited to vehicle and construction traffic damage."
ForLieense Conditions 11.8.C.2 and 3 above, it appears the submitted SOPs do not
address these conditions completely. This condition requires corrective actions taken or to
be taken to be provided in the subject SOPs. Some red-line strike-out verbiage attached is
suggested in Section 1.4.2 of the subject SOPs to help address these license conditions.
In the subject SOPs, Section 1.4.2, the paragraphs numbered 2 and 3 are difficult to
understand. Both paragraphs are unclear as to what frame of reference the described
actions are to be taken, such that these paragraphs may be interpreted several ways. Please
clarify these paragraphs by stating in detail the objectives and the approach methods
desired, so that DUSA's exact intent may be accomplished by the workers.
In paragraph 3 also include what, when, and how adjustments were made, to be included in
the ATER.
Page 3
License Condition 11.8E directs DUSA in the subject SOPs to, "Include procedures requiring that
such movement monuments be placed, surveyed, mapped, and maintained; that corrective action
and maintenance activities be performed to maintain existing movement monuments in a reliable,
good working condition, as needed; that the addition, surveying and mapping of new movement .
monuments installed be documented; and that records be made of observations of site conditions as
they relate to the conditions at and in the vicinity of the installed monuments;"
DRC Findings: Additional physical protective features and maintenance for movement
monitors are required by a previously mentioned License Condition 11.8C. Therefore,
more active checking and maintenance is necessary corresponding to License Condition
11.8E above. Please provide the corresponding maintenance actions and corresponding
maximum time interval basis for checking and maintenance in the subject SOPs.
After the first three years, limiting review of movement monitor condition to only a
contracted surveyor is not a prudent or a concise enough interval for damage observations
and repair opportunities to be taken for the movement monitors.
Per the License Condition above, records must "be made of observations of site conditions
as they relate tothe conditions at and in the vicinity ofthe installed monuments..."
5. License Condition 11.8F directs DUSA in the subject SOPs to, "Provide quantitative performance
criteria and describe how such criteria will be used to evaluate movements (displacements);"
DRC Findings: It appears that the subject submitted SOPs do not address this condition
completely. This License Condition applies to more than error correction, but overall
evaluation of horizontal and vertical movement data from the Movement Monitors. How
will DUSA evaluate and compare the rate of monitor movement? What rates of horizontal
and vertical movement are considered acceptable?
^Please^definethe-above by adding detailed procedures to the subject SOPs to address this
license condition completely.
License Condition 11.8G directs DUSA in the subject SOPs to, "Indicate that any movement
monument that is irreparably damaged as a result of environmental stresses or through man-caused
contact, including but not limited to cell construction or other operational equipment, shall be
promptly replaced with an identical or equivalent movement monument; and provisions provided
to guide the interpretation of data from both the former and the replacement device;"
DRC Findings: It appears that the subject submitted SOPs do not address this condition
completely. Some red-line strike-out verbiage is suggested in Section 1.4 ofthe subject
SOPs for DUSA to improve the SOPs with respect to this license condition. Please revise
the SOP in this regard.
We also request DUSA propose a definite maximum time for completion of monitor repair
and/or replacement in place of the "XX calendar days" shown in this regard.
Page 4
7. License Condition 11.8H directs DUSA in the subject SOPs to, "Include a list of records that will
be prepared for documenting movement (displacement) data for each movement monument and
related site observations and activities..."
DRC Findings: Jt appears that the subject submitted SOPs do not address this condition
completely. There is no list of records, that DUSA will create and maintain, provided in
the subject SOPs. Please revise the SOP in this regard.
Please provide a copy of the field forms that will be used to meet all the requirements of
License Condition 11.8 as outlined in this letter.
Please review the above comments, and respond in writing, submitting an appropriately revised Movement
Monitoring Standard Operating Procedures document with a unique version number. Per your email dated
April 14, 2011 you committed that DUSA would fully respond to this letter within 30 calendar days of
receipt of this letter. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
LBM:DAR:dr
Attachment: Red-line strike-oiit copy of the subject SOPs (DRC Comments)
F:\License\Move & Settle MonitorsXMovemenl Monitor Cmtl 4-2011 .doc
White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page lof 3
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
1. MOVEMENT (DISPLACEMENT) MONITOR
1.1 Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and.
horizontal movement of Movement (Displacement) Monitors that are placed along the
constructed dike portions of the tailings cells. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of new dike construction activities. Movement Monitors will be
installed and surveyed by a Utah Licensed Land Surveyor. The installalion of these inMovement
monitors^ at a miniinum. without regard to each chke longitudinal direction, will be installed in a
single straight lines for each pertinent dike. The line for the movement monitors will change
direction at each pertinent'dike intersection,-but will run continuous along and on top of all
exterior exposed dikes comprising the southem boundary the exposed dike of the tailing cells.
All new movement monitors (installed after June, 2010) will be surveyed and mapped by a Utah
Licensed Land Surveyor semi-annually for the first three years. After three years, each new
movement monitor (installed after June, 2010) will be surveyed and mapped annually. All
existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis.
On an annual basis, a Utah Licensed Professional Engineer will review, analyze, correct, and
certify the annua! data in writing, which will be submitted as part of the ATER as required by
RML License Condition 12.3.
1.3 Design of Settlement Monitors
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
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White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 3
The Movement Monitor placement will be established by digging a hole in the desired location,
to minimize accidental damage to the monument. A piece of rebar, 24 inches in length, will be
driven into the hole. The new monument will be set in-line with the other movement monitors
for the given dike. The hole will be back filled and the top of the rebar will be at least X-inches
below surface grade. Each monument will be individually tagged and numbered.
1.4 Monitoring and Maintenance of Movement Devices
1.4.1 Monitoring and Documentation of Condition of Devices
The Movement Monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section
1.2, and documented ih the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The Movement Monitors will be installed in such a way to prevent damage by equipment. The
Movement Monitors will be installed such that the monument is at least X-inches below the
actual ground surface level, so the potential for damage by equipment is minimized. However, if
a monument is disturbed, the information will be immediately given to the RSO, or designee.
The RSO, or designee, will make notificadon to the Corporate Compliance Director and a
coirective action plan vvill be created for replacement and/or repairs to the damaged movement
monitor and the surveying and documentation of am^hanges will be completed within XX
calendar davs of the discoverv of the damage.
If any Movement Monitqring^evice is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device within
XX calendar-days of the discoverv of the damage. The replacement device will be placed in the
same excavated hole from which the damaged device was removed. Data from the new device
will be correlated to data from the removed damaged device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamaged devices, no adjustment will be made to the survey data of
the new device.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change to either of the
undamaged devices, the survey results for the new device will be adjusted by the average
change observed in the two adjacent devices. This adjustment will be documented in the
Utah-Licensed Land Surveyors report and in the annual ATER.
F:\\VP\Divi.sion oi Radiation C(Mnrol\Deni,s()r) Mines, OUS.-WATER-Annuai Tech Fval Rcpor(s\Movernenl & Sctilonicni
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White Mesa Min - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 3
1.5 Documentation
The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations in relationship to the tailings cells. A brief summary of work and
analytical data will be provided in a written report by the Utah-Licensed Land Surveyor.
All documentation will be housed at the White Mesa Mill in the Environmenta] Department files
for inspection,_ _ _ _ „ _ _ „
1.6 — Performance Criteria and Data Validation
The data will be reviewed for any errors and or major changes in the vertical or vertical
movement on the movement monitors. If there is a difference of 0.1 foot between two
consecutive months., then the corrective actions will be taken as follows:
1 Resurvey the movement monitor that shows vertical or vertical movement of 0.1 foot or
more,, within XX days of discoverv of the problem.7
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, or burrowing animals, etc.).
4 Report this information to the Executive Secretary within a timely mannerXX calendar
davs for approval and include in that notification the investigation steps, movement
evaluation and corrective actions-st^p^taken. This report will be also be maintained
within the Environmenta] Department records and will be submitted as part of the ATER
as required bv RML Condition 12.3.
Movement monitors that show vertical movement of 0.2 foot or greater for two consecutive
monitoring periods or horizontal movement of O.X foot or greater for two consecutive
monitoring periods may be subject to accelerated monitoring at a frequency and in a manner
approved by the Executive Secretary.
On an annual basis, a Utah Licensed Professional Engineer will review, analyze, correct and
certify the annual data in writing, including an explanation of the methods and basis used for the
review, analysis, and conections including ongoing graphical updates tbr the Movement
Monitors. wh^^This information will be maintained within the Environmental Depanment
records and will be submitted as part of the ATER as required by RML License Condition 12.3,
along with a description of any corrective actions performed.
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SOPs No\ 2010.doe