DRC-2011-003329 - 0901a06880218adf

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
April 4, 2011
CERTIFIED MALL
(Return Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
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RE: 4/4/11; 12/1/11 transmittal letter RFI/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
pS;:F6riri,380d._Aijgust 2006' •Sec Royef;sG;lbi' 111siViit;11oiis='
SUBJECT: December 1, 2010 Transmittal Letter for Three Separate Draft SOP's; Settlement
Monitonng Standard Operating Procedures [SOPs] 11/2010 Revision: DUSA-1;
Comments and Request for Information
We have received the subject December 1, 2010 letter which transmitted three separate Standard Operating
Procedures (SOPs). The subject of this letter is our review of one of the SOPs, i.e. the Settlement
Monitoring Standard Operating Procedures [SOPs]. DRC review of the other transmitted SOPs will be
discussed in separate letters. The subject SOPs were submitted by DUSA to comply with the requirements
of License Condition 11.7. We have reviewed this item, and have the following comments:
1. General. Some suggested red-line strike-out changes for the subject SOPs are attached. The
majority of these suggestions were derived from our review of the License Conditions. Please note
that some sections of the red-line strike-out copy of the subject SOPs may contain several changes
which were obtained from the numerous License Conditions.
License Condition 11.7, first paragraph, states that, ".. .The proposed SOP shall describe methods
for.. .comparing such data to previous data to track potential settlement. All data collected by the
Licensee for these purposes shall be included in an annual report to be submitted to the Executive
Secretary, pursuant to License Condition 12.3..."
DRC Findings: It appears that the subject submitted SOPs do not address this condition
completely. License Condition 11.7 applies to more than error correction, but overall
evaluation of vertical movement of the Settlement Monitors. Please add detailed
procedures to the subject SOPs to address this license condition completely.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850 '
Telephone [phone] vFax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on ]00% recycled paper
Page 2
3. License Condition 11.7A directs DUSA in the subject SOPs to, "Require that settlement monitors
(e.g., settlement stands) be promptly installed following placement of temporary cover over placed
tailings;"
DRC Findings: It appears the submitted SOPs do not address this condition. Some red-
line strike-out verbiage attached is suggested in Section 1.2 ofthe subject SOPs to address
this license condition. We request DUSA propose a definite maximum time, in place of
the "XX calendar days" shown in the red-line text in the attachment.
License Condition 11.7D directs DUSA in the subject SOPs to, "Include provisions to prevent —
man-caused damage to settlement monitoring devices, including, but not limited to vehicle and
construction traffic damage. Such measures will include: 1) all equipment, procedures, and
provisions needed to protect said settlement 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: It appears the submitted SOPs do not completely address this condition, as
follows:
a. The design of the Settlement Monitors, provided in Section 1.3 of the subject SOPs, is
vague with respect to the design height of the 1-inch center pipe, and the height of the
3-inch casing above the temporary cover. The description is also vague regarding the
height, depth, spacing between and location of the barrier posts bounding the
Settlement Monitors. Please provide engineering drawings with dimensions to address
this comment.
b. The last phrase in License Condition 11.7D requires the SOPs to include, "corrective
actions taken or to be taken.. .to replace or repair said devices." This condition
requires corrective actions taken or to be taken to be in the SOPs. Some red-line
strike-out verbiage attached is suggested in the last paragraph in Section 1.3 ofthe
subject SOPs for DUSA to address this license condition. We request DUSA propose
a definite maximum time in place of the "XX calendar days" shown in this regard.
5. License Condition 11.7E directs DUSA in the subject SOPs to, "Indicate that.. .Review of the data
and an analysis shall be performed and certified by a Utah Licensed Professional Engineer and
submitted annually as part of the ATER required by License Condition 12.3;"
DRC Findings: Some red-line strike-out verbiage is suggested in the last paragraph in
Section 1.6 of the subject SOPs for DUSA to improve the SOPs with respect to this license
condition. Please revise the SOP in this regard.
License Condition 11 •7F directs DUSA in the subject SOPs to, "Include procedures requiring that
such settlement monitors be placed, surveyed, mapped, and maintained; that corrective action and
maintenance activities be performed to maintain existing monitoring devices in a reliable, good
working condition, as needed; that the addition, surveying and mapping of new settlement
monitoring devices installed be documented; and that records be made of observations of site
conditions as they relate to the conditions at and in the vicinity of the installed monitoring
devices;"
Page 3
DRC Findings: It appears that the subject submitted SOPs does not address this condition
completely. Some red-line strike-out verbiage attached is suggested in Sections 1.2, 1.3,
and 1.6 of the subject SOPs to address this license condition. Please revise the SOP in this
regard.
License Condition 11.7G directs DUSA in the subject SOPs to, "Provide quantitative performance
criteria and describe how such criteria will be used to evaluate vertical movement;"
DRC Findings: It appears that the subject submitted SOPs does not address this condition
completely. This License Condition applies to more than error correcfion, but overall
evaluation of vertical movement of the Settlement Monitors. This License Condition is
related to item 2 in this letter. Please add detailed procedures to the subject SOPs to
address this license condition completely.
License Condition 11.7H directs DUSA in the subject SOPs to, "Indicate that any settlement
monitoring device that is irreparably damaged as a result of environmental stresses or through
man-caused contact, including but not limited to cell construction or other operational equipment,
shall be promptly replaced with an idenfical or equivalent monitoring device; and provisions
provided to guide the interpretation of data from both the former and the replacement device;"
DRC Findings: It appears that the subject SOPs Section 1.5.2 partially addresses of this
License Condition. However this secfion is vague in its complete intent. Please clarify the
intent by revising this section to address this License Condition.
Is it feasible to replace a damaged Settlement Monitor with a new device at the same
elevarion? As part of this response, we request that DUSA include in these SOPs that a
permanent notation in the data will be provided to record the date of replacement of any
Settlement Monitor.
9. License Condirion 11.71 directs DUSA in the subject SOPs to, "Indicate that where survey
evidence suggests that significant apparent movement in a settlement monitor has occurred, in
excess of the approved performance criteria, that the departure(s) will be investigated and
explained, and errors corrected and resolved in a timely manner, subject to Executive Secretary
approval;"
DRC Findings: It appears the submitted SOPs do not completely address this condition.
Some red-line strike-out verbiage attached is suggested in Section 1.6 ofthe subject SOPs
to address this license condition. We request DUSA propose definite maximum times, in
the two places of the "XX calendar days" locations shown in this regard.
10. License Condirion 11.7K directs DUSA in the subject SOPs to, "Include a list of records that will
be prepared for documenting settlement data for each setUement monitoring device and related site
observations and activities..."
DRC Findings: It appears that the subject submitted SOPs does not address this condition
completely. Please add a detailed list of records to the subject SOPs to address this license
condition completely.
Page 4
11. License Condirion 11.7L directs DUSA in the subject SOPs to, "Indicate that results and records of
settlement monitoring shall be submitted annually as part of the ATER required by License
Condirion 12.3."
DRC Findings: It appears that the subject submitted SOPs may not address this condition
completely. Some red-line strike-out verbiage attached is suggested in the subject SOPs to
address this license condirion. Please revise the SOP in this regard.
Please review the above comments, and respond in writing, submitting an appropriately revised Settlement
Monitoring Standard Operating Procedures document with a unique version number. Per our telephone
conversation on March 31, 2011 you committed that DUSA would fully respond to this letter within 30
calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E^
Geotechnical Services Section
DAR:dr
Attachment: Red-line strike-out copy of the subject SOPs (DRC Comments)
F:\License\Move & Settle Monitors\Settlement Monitor Cmtl April 2011.doc
White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010)-, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement .
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Mqmtor_ ., - { Formatted: Font: italic
Points map (oriLnnally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within XX calendar days of completion of the intermediate cover at the designated locations. The
Settlement Monitor Points map vvill be updated as part of the installation of new monitors.
Afl iitated above. Settlement Monitors will bo placed on the tailing cells when temporary cover \r<
being advanced on the placed tailing;;. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to further disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually after that point. -
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
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White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 2010, the required settlement
stands will be placed and the initial elevation survey completed prior to June 1, 2010.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The-hole will then be backfilled to within two Teet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled.. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
turned in to the RSO, or designee. The RSO, or designee, will make same dav notification to the
Corporate Compliance Director, and a coiTective action plan will be created for rRcplacement
and/or repairs to the damaged Settletnent Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within XX calendai days
of the discovery of the darnage to the Settlement Monitor.
1.4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surveyor") with the assistance of another Mill
worker (the "Assistant");
(ii) The survey will be perfonned using a survey instrument accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
(v) Once in location, the surveyor will ensure that the survey instrument is
level by centering the bubble in the level gauge on the survey instrument;
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White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book # 11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(vi) The assistant will place the survey rod vertically on the reference point.
The assistant will ensure that the survey rod is vertical, by gently rocking
the rod back and forth until the surveyor has established a level reading;
(vii) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "reference point
reading"), which represents the number of feet the survey instrument is
reading above the reference point;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a I"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
- vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Moveinent Settleinent Monitors will be maintained so that the monuments remain in
reliable, good working condition. Conditions at and in the vicinity of the monitoring devices
will be inspected monthly by Environmental Department staff Any observations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
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White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The
replacement device will be placed in the same location from which the damaged device was
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 devicev :— -
2. If the survey indicates there has been less than 0.1 foot of vertical-change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
3. If the survey indicated 0.1 foot or greater of vertical change to either 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.
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of 0.1 foot between two consecutive months, then the corrective actions will be taken
as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within XX davs of discovery of the problem.-r
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 XX calendar days for approval
a timely manner and include in that notification the investigation steps, movement
evaluation, and corrective actions-steps taken. This report will be also be maintained
within the Environmental Department records and will be submitted as part ofthe ATER
as required bv RML Condition 12,3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ aftd-analyze, correct the
data and thew-certify the annual data in vvriting,.T-including an explanation of the methods and
basis used for the review, analysis, and conections includin<i ongoing graphical tipdates for the
Settlement Monitors, which This information will be maintained within the Environmental
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White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.0
Date: 11/2010 Revision: DUSA-1
Page 5 of 5
Departipent records and will be submitted as part of the ATER as required by RML Condition
12.3.
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