DRC-2011-006209 - 0901a068802389a5

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Ueutenant Governor
June 2, 2011
Department of
Environmental Quality
Amanda Smith
Executive Director
DPVISION OF RADIATION CONTROL
Rusty Lundberg
Director
CERTIFffiDMAIL
(Retum 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: May 4, 2011 DUSA Response Letter to DRC Letter of April 4, 2011; December 1, 2010
DUSA Transmittal Letter for Three Separate Draft SOP's; Settlement Monitoring Standard
Operating Procedures [SOPs] 045/2011 Revision: DUSA-2; Request for Information
We have received the subject May 4, 2011 DUSA response letter, which transmits the proposed DUSA
Settlement Monitoring Standard Operating Procedures [SOPs] 045/2011 Revision: DUSA-2, in response
to the subject DRC comment letter of April 4, 2011. We have reviewed this information, and have the
following comments. Our current comments use the same numerical order as the original comments in our
letterof April 4, 2011:
1. No further comment.
2. No further comment.
3. No further comment. ; ^
4. Figure 1, a drawing titled Settlement Monitor Fabrication originally dated 09-14-96 and last
revised 05-11, was provided by DUSA to support the description of the design of the Settlement
Monitors found in Section 1.3 of the subject SOPs.
5. No further comment.
6. No further comment.
7. No further comment.
8. As previously stated and requested in our letter of April 4, 2011, Section 1.5.2 in the subject SOPs
is vague in its intent and needed clarifying. After some revision by DUSA, this section still seems
rather complex and unclear. To help clarify the apparent intent of this section, some additional
red-line strike-out verbiage attached, is suggested for Section 1.5.2.
9. No further comment.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
n-w-w.deq.utah.gov
Prinled on 100% recycled paper
Page 2
10. Per License Condition 11.7K, we requested that the subject SOPs, "Include a list of records that
will be prepared for documenting settlement data for each settlement monitoring device and related
site observations and activities..." In this regard, we request that the annual report of the
Settlement Monitor data by a Utah Licensed Professional Engineer, as described in Section 1.6, be
added to the list of records of documents shown in Section 1.5.1 of the subject SOPs.
11. Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage for the subject
SOPs to provide that results and records of settlement monitoring be submitted annually as part of
the ATER. It appears the addition of the word "submit" to Section 1.6 is appropriate in this regard.
This addition is suggested as attached, in the red-line strike-out verbiage for Section 1.6, in the
second to last paragraph of that section.
Please review the above comments, and respond in writing, submitting an appropriately revised Settlement
Monitoring Standard Operating Procedures document, with a unique version number, for Executive
Secretary approval. Per my email of May 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,
(?6
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
Attachment:
Red-line strike-out copy of the subject SOPs (including latest DRC Comments) labeled at the top as [Prop
Cmt2 SMSOP markups June 2011]
F:\License\Move & Settle MonitorsXSettlement Monitor Cmt2 June 201 l.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20116 Revision: DUSA-2+
Book #n: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
[Prop Cmt2 SMSOP markups June 20111
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 Ty\]S>A Settlement Monitor_ ^ , - \ Formatted: Font: italic
Points map (originally dated 09/15/08). Senlement Monitors will be placed on the tailings cells ^
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within calendar days of completion of the intermediate cover at the designated locations.
The Settlement Monitor Points map will be updated as part of the installation of new monitors.
As stated above. Settlement Monitors will be placed on the tailing cells when temporar>^ cover is
being advanced on' the placed tailings.—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.
F:\\VP\Di\ ision oFRadiaiion ControADenison Mines, DUSA\ATER Annual Toch Eval RoDortP\Mo\ oinonl & Sctttowmt
MonitorcASettlemont Monitoro'iProp Sottlomenl Monit S0P-\4Qrkup 03 2Q10.docC:'.Uocrs\itiochlor\Dcsktop\Soction 5 0
Sctllemcni Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544-/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
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 feet 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. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
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
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and a corrective action plan will be created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within calendar
days of the discovery of the damage 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 performed 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.
F:\WP-.Di\ision ol'Radiation ControiVDenison Minea. DUS,^'ATER Annual Tech Eval RoponG\,Moveinonl & SctHemeni
Moniiors'.Sottlemoni MonitoiT.'.Piop Seltlement Monit SOP Markup 03 2010.docC:\Uf.oiH\iiiGchlor.Deslaop\Soction 5 0
Settlement Monitoiin" SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04541-/20116 Revision: DUSA-2-1-
Book #H: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(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;
(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 1"
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 Movement Settlement 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.
Oh - 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.
F:',WP'.Divisionof Radiaiion Controi\Denif.on Mine.n. DUSAV\TER Annual Toch Eval Ropoi-tG\Mo\ ument & Settlemewt
Monitorf.\Scttlement Monitorc.'.Prop Settlement Monit SOP Morkup 03 201Q.docC:\Usors\itiochlei\Dosktop\Scciion 5 0
Settlement Monitorina SOP.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Enviroimiental Protection Manual, SOP Section 5.0
Date: 04544/20110 Revision: DUSA-24
Page 4 of 5
The following records and documents will be maintained bv the Environmental Depanment
staff:
a) Monthlv tailings inspection forms
b) Data files of monthly and annual survev infonnation
c) Records of initial installation and suivev data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
Formatted: Outline numbered +
Level: 5 + Numbering Style: a, b, c,
... + Start at: 1 + Alignment: Left +
Aligned at: 0.5" -i- Tab after: 0.75"
H- Indent at: 0.5"
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.
Based on the last monthly survey, prior to the damage. tThe replacement device will be placed as
near as practical at the same elevation and 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 two nearest (undamaged) devices
adiacent to on either side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change since the last
montly survey in the elevation 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.
3^4. Also, based on the last monthly survey, prior to the damage. Iif the elevation of'-
the new device is greater than +/- 0.1 foot from that of the damaged devicse. then the
replacement devicse will be designated with a new number (such as "Cell 2W2-R". as the
replacement for damaged devicse "Cell 2W2"). Elevation data for the new devicfie. and
the date of installation of the new device, will be recorded in the data file adiacent to the
infomiation from the damaged devicse. with a notation that this devicse is a replacement
for the damaged devicse.
Formatted: List Paragraph, Left, No
bullets or numbering
Formatted: Bullets and Numbering
F:\WP\Di-Radiation Contror\Dc DUSAV\TER Annual Tech Eval Ropci ts\Mo\ omeni & Sollle
Ui Moniloi-s\Piop Sottlemonl Monil SOP Markup 03 20IO.docC:'.Lk-.crf.\itinchloi-\Do5ktop'-.Sociion 5 0
Sotllemeni Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20110 Revision: DUSA-24
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
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 an investigation and possible #te
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7XX days of discovery of the problem.T
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30XX calendar davs for
approval a • timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-steps taken, if needed. This report will he
also be maintained within the Environmental Department records and will be submitted
annually as part of the ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ and-analyze, correct (as .'
needed), ^submit the data_ and 4hefl-certify the arinua[ data in writing—^ including an explanation _ ,, - -{Formatted; Font color: Pium
of the methods and basis used for the review, analysis, and corrections including ongoing
graphical updates for the Settlement Monitors. For movements attributed to expected settlement
of the tailings sands, the review will include comments on the graphical presentation ofthe data,
and an evaluation of the previous, cuiTent and expected rates of ongoing settlement.
' . . I, • - - • •
whieh-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
F:\WP\Div ision of Radiaiion Conii-ol\Denif,on Minor,. DUSA'ATER Annual Tech Eval Reports\Movcmcni & Settlenient
Monitors\Seltlemcnt MonitorrAProp Sottlemonl Monit SOP Markup 03 2010.docC:\U5orG\itiDchler\Dosklop\Scction 5 0
Settlement Monitorinti SOP.doc
U.S. Postal :Service : ^-y-y'^.M'-y-y
GERTIFIED MAILREd^
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I SUBJECT: MAY 4, 2011 / DR
For deliveiy information visit pur website at vmw.usps.com® ,
OFF 1 C i A L USE
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Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
PS.Form .3800.-Augtist 2005 See Reverse for.Instructions';