DRC-2011-007562 - 0901a0688028b44f

DENISO
MINES
November 1,2011
Denison~Mirf&s (USA) ^p.*:
105017th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : [phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utaii Groundwater Discliarge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of October 17, 2011 Regarding Movement
Monitoring SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill Movement
Monitoring SOP. This letter also responds to DRC's letter of October 17, 2011, which we received on
October 21, 2011 providing DRC's comments on the subject SOP. We have provided in Attachment 1 an
edited redline copy of the SOP in which Denison's modifications in response to DRC comments are indicated
in color, and a clean copy for ease of review.
We have provided, below, specific responses to each request in DRC's October 17, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC October 17, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. We have reviewed the subject Movement Monitor SOPs, and have the following comments:
As requested in comments no. 1 and 8 in our previous letter of June 13, 2011, the
subject SOPs need to be corrected for spelling and typographical errors. Such errors
have somehow perpetuated in the subject SOPs, and need to be corrected in the final
copy.
Denison Response: The Movement Monitoring SOP has been edited and typographical and spelling errors
have been corrected.
/ also suggest the title, and paragraph line 1, be changed to "Movement (Displacement)
Monitoring", rather than "Movement (Displacement) Monitor."
Denison Response: The requested change has been made.
N:\SOPs ahd Procedures\Movement monitor SOP and commentsM 1.01.11 response to 10.17.11 RFI on Movement
Monitoring SOP\11.01.11 Response to DEQ 10.17.11 RFI Movement MonitorSOP.doc
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
November 1, 2011
Page 2
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
Harold R. Roberts
David E. Turk
K. Weinel
Attachments
DENISO
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
November 3, 2011
Page 3
ATTACHMENT 1
Revised Movement Monitor SOP
DENISO
MINES
White Mesa Mill - Standard Operating Procedures Date: 11/2011 Revision: DUSA-2.1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
1. MOVEMENT (DISPLACEMENT) MONITORING
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. Movement monitors, at a minimum,
without regard to each dike longitudinal direction, will be installed in 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 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 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
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The movement monitor 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. 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
White Mesa Mill - Standard Operating Procedures Date: 11/2011 Revision: DUSA-2.1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4
hole will be back-filled and the top of the rebar will be at least 4-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 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 near 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 movement monitors will be installed such
that the monument is at least 4-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 replacement and/or repairs to the
damaged movement monitor and the surveying and documentation of changes will be completed
within 30 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
30 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.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and 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 adjacent devices, the procedures in Section 1.6
will be implemented.
White Mesa Mill - Standard Operating Procedures Date: 11/2011 Revision: DUSA-2.1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 4
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 will be
evaluated according to the procedure described in section 1.6
The list of records generated as a result of this SOP includes:
• Utah-Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• ATER
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation will 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 horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:
1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
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 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with 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 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, 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 format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
White Mesa Mill - Standard Operating Procedures Date: 11/2011 Revision: DUSA-2.1
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4
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. This information
will be maintained with the Environmental Department 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.
White Mesa Mill - Standard Operating Procedures Date: 0611/2011 Revision: DUSA-2J.
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
1. MOVEMENT (DISPLACEMENT) MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Mmovement (©displacement) Mmonitors 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. mMovement monitors, at a
minimum, without regard to each dike longitudinal direction, will be installed in 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 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 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
Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The movement monitor 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. 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
White Mesa Mill - Standard Operating Procedures Date: 0611/2011 Revision: DUSA-2J.
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 4
hole will be back-filled and the top of the rebar will be at least 4-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 in the surveyor's written reports and in the annual ATER.
1.4.2 Maintenance of Monitors
The Mmovement Mmonitors will be installed in such a way to prevent damage by equipment.
All new movement monitors installed after June 2010 will be installed near the edge of the dike
crest, but off the horizontal road surface. Movement monitors in this location will be out ofthe
pathway for maintenance activities and traffic. The movement monitors will be installed such
that the monument is at least 4-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 replacement and/or repairs to the
damaged movement monitor and the surveying and documentation of changes will be completed
within 30 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 Mmovement Mmonitoring 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 30 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.
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the adjacent devices, it will be assumed that no damage had occurred to
the adjacent devices and -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 adjacent devices, the procedures in sSection 1.6
will be implemented.
White Mesa Mill - Standard Operating Procedures Date: 0611/2011 Revision: DUSA-2J.
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 4
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 will be
evaluated according to the procedure described in section 1.6
The list of records generated as a result of this SOP includes:
• Utah-^Licensed Surveyor's Semi-Annual and Annual Survey and Mapping Reports
• Annual Technical Evaluation ReportATER
• Observations, if there are any to be noted, on the monthly Tailings Inspection Report
All documentation will 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 horizontal
movement on the movement monitors. If there is a difference of 0.1 foot or greater between two
consecutive measurements, then the corrective actions will be taken as follows:
1. Resurvey the movement monitor that shows vertical or horizontal movement of 0.1 foot
or more, within 30 days of discovery of the problem.
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 45 calendar days for approval
and include in that notification the investigation steps, movement evaluation and
corrective actions taken. This report will be also be maintained with 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 -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, 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 Mmovement Mmonitors. Movement data will be presented in a tabular format, showing all
previous annual and semi-annual data, for ease in evaluating the total record of movement
measurements. Data from all previous measurements will be compared against the current
measurement and an evaluation made as to any long-term trends which may be apparent.
White Mesa Mill - Standard Operating Procedures Date: 0611/2011 Revision: DUSA-2 J
Book #11: Environmental Protection Manual, SOP Section 5.1 Page 4 of 4
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. This information
will be maintained with the Environmental Department 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.