HomeMy WebLinkAboutDRC-2011-006571 - 0901a068802415e2State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
June 13,2011
CERTIFIED MAIL
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
(Return Receipt Requested) D R C " 2 0 1 1 " 0 0 6 5 7 1
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 27, 2011 DUSA Response Letter and Transmittal oi Movement (Displacement)
Monitor Standard Operating Procedures fSOPs], 0572011 Revision: DUSA-2; April 20,
2011 DRC Request for Information Letter; December 1, 2010 DUSA Transmittal Letter of
Draft Movement Monitoring SOPs; Comments and Request for Information
We have received the subject May 27, 2011 DUSA letter which transmits the subject titled Movement
Monitor Standard Operating Procedures (SOPs). These SOPs were submitted by DUSA in response to our
subject comment letter of April 20, 2011, and to comply with the requirements of License Condition 11.8.
We have reviewed the subject latest version of the SOPs, and have several comments below. These
comments appear to be brief, and follow the same numbering sequence as in our previous comment letter
on the subject, dated April 20, 2011:
1. General. The clean copy of the subject SOPs needs to be corrected for spelling and typos. Some
new additional suggested red-line strike-out changes for the subject SOPs are attached. Please note
some sections contain more than one change of wording. Unfortunately, these changes appear in
the same color as our previous suggested red-line strike out changes. However, the most
significant changes are described in more detail below:
a. Section 1.2: In the last paragraph we add the wording, "semi-annual,and..."
b. Section 1.4.2: In the second sentence we add the words "near" and "but," and deleted the
word "on,"
c. Section 1.5:
(1) . In the first sentence we add the phase, "of the movement monitors."
(2) . In the last sentence of the first paragraph we add "of O.I foot or," and delete "than
0.1 foot." This is explained further below in paragraph le.
(3) . In the second paragraph we add the new phasing shown to capture the semi-annual
survey and mapping reports.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O Box 144850'Salt Lake Gity, UT 84114-4850
Telephone (801) 536-4250 • Fax (801) 533-4097 • T.D.D. (801)536-4414 .
www.deq.uiah.gov
Primed on 100% recycied paper /
Page 2
d. Section 1.6:
(1) . In the first paragraph we add, "or greater." This is explained further below in
paragraph le.
(2) . In the last paragraph, the first sentence, we add, "and submit," and "semi-annual
»' and annual."
(3) . In the second sentence of the last paragraph we add, "and" and delete "or."
(4) . In the fourth sentence of the last paragraph we add, "also."
e. To be consistent with paragraphs 1.4.2.2 and 1.4.2.3, regarding distances of "0.1 foot or
greater," as the actionable distance for the SOPs, some of the sentences described above
have been adjusted with suggested wording, such that any distance readings of 0.1 foot
would not be vague as to the SOP requirements.
2. No further comment.
3. No further comment.
4. A monthly inspection of the movement monitors is described at the end of the first paragraph of
section 1.4.2 in the subject SOPs. It appears this necessitates some corresponding additions to the
monthly tailings inspection form, for inspection of the movement monitors. Please provide the
proposed changes in the form (DMT Plan) for approval.
5. No further comment.
6. No further comment.
7. No further comment.
8. New comment: The subject SOPs needs to be corrected for spelling and typos.
Please review the above comments, and respond in writing, incorporating the above comments as
appropriate, and submit a revised Movement Monitoring Standard Operating Procedures document and
monthly tailings inspection form (DMT Plan) with unique version numbers. Per your email dated June 13,
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.
E. David A. Rupp, P.E.
Geotechnical Services Section
LBM:DAR:dr
Attachment: Red-line strike-out copy of the subject SOPs (DRC Comments)
F:\License\Move & Settle MonitorsXMovement Monitor Cmt2 6-2011 .doc
White Mesa Mill - Standard Operating Procedures Date: 0544/20110 Revision: DUSA-2i
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
[DARMarkup 06-20111 * ( Formatted: Centered
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 installation of these
mmMovement ffionitors^ at a minimum, without regard to each dike 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 southern boundary the exposed dike of the tailing
cells.
All new movement monitors (installed after June, 2010) will be surveyed and mapped bv 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. Ail
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
semi-annual and annual 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
F:'.\VP\Divit^ion of Radiation Conlror\Denir.Qn Miner.. DUSAVMER .•\nnual Tech Eval RcportcAMo^ oincnt & Sottlemenl
MonitorrAMovomont MoniiorrAMarkup oFProp Mcnomcnt Monit SOPr. '1 2010.docF:'AVP\Diviriion of Radiation Conti-ol\Denir.on
Minoo. DUS-MMER Annual Toch Eval RopQrip'.Movemenl & Soitlomcni MonitorrAMov omonl Monjlorr.'.Prop Movement Monit
SOPf. Nov 20Ki.doc
White Mesa Mill - Standard Operating Procedures Date: 0544/20110 Revision: DUSA-2-!-
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The mMovement mMonitor placement will be established by digging a hole in the desired
location, to minimize accidental damage to the monument including, but not limited to vehicle
and construction traffic damage.T 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 4X-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 mMovement niMonitors 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 in 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. All
new movement monitors installed after June 2010 will be installed nearen the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out of the
pathway for maintenance activities and traffic. The mMovement mMonitors will be installed
such that the monument is at least 4X-inches below the actual ground surface level, so the
potential for damage by equipment is further minimized. However, if a monument is disturbed,
the information will be immediately given to the RSO, or designee. The RSO, or designee, will
make notification to the Corporate Compliance Director and a corrective action plan will be
created for replacement and/or repairs to the damaged movement monitor and the surveying and
documentation of any-changes will be completed within 30X^4 calendar days of the discovery of
the damage. The general condition of the movement monitors will be evaluated on a monthly
basis and the inspection documented as a part of Monthly Tailings Inspection.
If any Movement 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 within
calendar-days of the discovery 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.
F:'.WP\DiM!;.ion ol'RQdiQlion Conirol\Dmif,on Minos. DUSAvMER Annuo! Toch Eval Ranortr.'.Mo^ umont & Scltlomcnt
MonitoiT/.Movcmcni Monitoi-s\Mai-kun orProo Movement Monit SOPr. 1 2010.docF:\\VP\Divir.ion ofRadiation Control'.Denison
Mine;v DUS.^VATER Annual Toch E\al RoportL^'-'Mo^ umunt & Soiilemont Monitor;AMovomont MonitorrAProp Movomonl Monii
SOPf. Nov 2010.doc
White Mesa Mill - Standard Operating Procedures
Book #M: Environmental Protection Manual, SOP Section 5.1
Date: 0544/20116 Revision: DUSA-2-1-
PageS of4
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamagedadjacent devices, it will be assumed that no damage had
occurred to the adjacent devices and no adjustment will be made to the suivey data of the
new device will be installed at the vertical and horizontal coordinates of the device prior
to the damage.
3. If the survey indicated 0.1 foot or greater of vertical or horizontal change, from the
previous measurement, to either of the undamaeedadjacent devices, the procedures in
section 1.6 will be implemented, suivev 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 Sur\'eyors report and in the annual ATER.
1.5 Documentation
The Utah Licensed Land Surveyor will provide a written report of their findings along with a
map depicting the locations of the movement monitors 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. Vertical or horizontal movements of 0.1 foot or greater than 0.1 feet
will be evaluated according to the procedure described in section 1.6
The list of records generated as a result of this SOP include:
• Utah Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• Annual technical Evaluation Report
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation \yill be housed at the White Mesa Mill in the Environmental 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
horizontalvertical movement on the movement monitors. If there is a difference of 0.1 foot or
greater between two consecutive measurememtsen#fe, then the corrective actions will be taken
as follows:
1 Resurvey the movement monitor that shows vertical or horizontalvertical movement of
0.1 foot or more, within 36XX 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.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
4 Report this information to the Executive Secretary within a timely mannerl 5XX calendar
days for approval and include in that notification the investigation steps, movement
evaluation and corrective actions-ste^taken. This report will be also be maintained
F:\WP\Di i ofRadiation Conirol\Deni -N4t DUS.A\ATER Annual Tech Eval RcpoffeXMe^ It & Settle
cAMovement Monitorp'..Markup of"Prop.M^ It Monit SOPr. 1 2010.docF:\WP\Division ofRadiation Control\Denison
DUSA\ATER Annua) Tech Eval RoportsyMc itifc Sottlemoni Monitorg\Mo\ omont Monilors'iProp Movement Monil
SOPs>lov :010.doc
White Mesa Mill - Standard Operating Procedures Date: 0544-/20110 Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4
within the Environmental Department records and will be submitted as part of the ATER
as required by RML Condition 12.3.
Movement monitors that show vertical or horizontal 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 and submit the semi-annual and annual data in writing, including an explanation of the
methods and basis used for the review, analysis, and corrections including ongoing graphical
updates for the Movement Monitors. Movement data will be presented in a tabular foimat.
showing all previous annual er-a.nd semi-annual data, for ease in evaluating the total record of
movement measurements. Data from all previous measurements will be compared against the
cuirent measurement and an evaluation made as to any long term trends which may be apparent.
Cumulative movements greater than 0.25 feet in one direction over a three (3) year, or longer
period, will also be evaluated by a Utah Registered Professional Engineer. which This
information will be maintained within the Environmental Departrrient 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.
Er'WP'^JDivi^.ion ofRadiation Control\Dcnic.Qn Minos. DUSAVATEK Annual Tech Eval RoDorls'J'.lovumL'nt & SoilicmGni
Moniiorri...Movomoni Monitors'.Markup of Prop Movement Monit SOPr- 1 2010.docF:\VVP\Divic.ion of Radiation Contror'vDenir.on
Mines, DUS.-\\ATER Annual Tech E\ al Ropcnr.'.Mo\cniont & Settlement MonitoiTAMovcmenl Monitorr.'.Prop Movement Monit
SOPii Nov 2010.doc