DRC-2011-007810 - 0901a068802a761f

DENISO
MINES
November 1,2011
Mr. Rusty Lundberg
Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Denlson Mines (USA) O&rp.t
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax:[phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY ^^C"20ll 007
Re: State of Utah Groundwater Discharge 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.
I also suggest the title, and paragraph line 1, be changed to "Movement (Displacement)
Monitoring", rather than "Movement (Displacement) MonitorZ
Denison Response: The requested change has been made.
N:\SOPs and Procedures\Movement monitor SOP and commentsMI.OI.II response to 10.17.11 RFI:on Movement
Monitoring S0P\11.01.11 Response to DEQ 10.17.11 RFIMovementMonitorSOP.doc
Letter to Mr. Rusty Lundber
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 Lundbe^l^
Movement Monitor SOP RFI Response
November 3, 2011
Page 3
ATTACHMENT 1
Revised Movement Monitor SOP
DENISO
MINES
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
1.
1.1
MOVEMENT (DISPLACEMENT) MONITORING
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 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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
Page 2 of4
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
1.4.1
Monitoring and Maintenance of Movement Devices
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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 11/2011 Revision: DUSA-2.1
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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUSA-2a
Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITORING
STANDARD OPERATING PROCEDURES
I 1.
1.1
MOVEMENT (DISPLACEMENT) MONITORING
Purpose
This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and
horizontal movement of Mmovement (Misplacement) 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. fHMovement 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
constmction 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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUSA-2J.
Page 2 of4
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
1.4.1
Monitoring and Maintenance of Movement Devices
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 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 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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUSA-2a
Page 3 of4
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 Report 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 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
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0611/2011 Revision: DUSA-2J.
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.
DENISO
MINES
CM
y
JUM 2011
Division of
Radiation Control
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
7
June 23, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of April 20, 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 June 13, 2011, which we received on June 15,
2011 providing DRC's proposed red lines and comments on the subject SOP. We have provided in
Attachment 1 an edited redline copy of the SOP in which Denison's modifications or additional language in
response to DRC comments are indicated in a second color, and a clean black-line copy for ease of review.
In addition, Denison has prepared a draft of changes to the Tailings Management System and Discharge
Minimization Technology ("DMT") Plan, to address:
• Changes in tailings inspection forms to correspond to this Movement Monitor SOP;
• Changes to address the startup of new cells, during which solution level cannot be surveyed or tape
measured until the solution level is high enough to be safely reached;
• Changes to reflect the removal of the freeboard limits from Cells 3 and 4A; and
• Other language changes to more correctly reflect current conditions and procedures at the tailings
system and Mill.
A redline copy and clean blackline copy of the proposed DMT changes are provided in Attachment 2.
We have provided, below, specific responses to each request in DRC's June 13, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC June 13, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General. 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
N:\SOPs and Procedures\Movement monitor SOP and comments\06.23.11 response to 06.13.11 RFI on Movement monitor
SOP\06.23.11 submittal to Rlundberg Movemt Monitors\06.23.11 Response to DEQ 06.13.11 RFI Movement Monitor
SOP.doc
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 2
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..Z
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 0.1 foot or," and delete "than 0.1
foot." 777/s is explained further below in paragraph 1e.
(3) . In the second paragraph we add the new phasing shown to capture the semi-annual
survey and mapping reports.
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, "alsoZ
e. To be consistent with paragraphs 1.4.2.2 and 1.4.2.3, regarding distances of "0.1 foot or
greaterZ as the actionable distance for the SOPs, some ofthe 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.
Denison Response: The changes have been accepted as proposed.
2. No further comment.
Denison Response: No response required:
3. No further comment.
Denison Response: No response required.
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 ofthe movement monitors. Please provide the proposed
changes in the form (DMT Plan) for approval.
Denison Response: Proposed revisions to the DMT Plan, including changes to the monthly tailings
inspection form, are attached.
5. No further comment.
Denison Response: No response required.
DENISO
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 3
6. No further comment
Denison Response: No response required.
7. No further comment.
Denison Response: No response required.
The document has been reviewed for spelling and typographical errors.
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
June 23, 2011
Page 4
ATTACHMENT 1
Revised Movement Monitor SOP
DENISO
MINES
White Mesa Mill - Standard Operating Procedures
Book #11; Environmental Protection Manual, SOP Section 5.1
Date: 01644/20110 Revision: DUSA-24-
Page 1 of 4
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
IDARMarlcup 06 20111
1.
1.1
MOVEMENT (DISPLACEMENT) MONITOR
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. Tho installation of these
mmMovement monitors^ 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 southem boundary tho oxposod 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
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:\WP\Division of Radiation CoiitroiVDenison Mines. DUSAVATER Annual Tooh Eval Roports'Movemont & Sottteflwat
MonitorsVMovement Monitors\Markup of Prop Movement Monit SOPs A 2010.docF:\WP\Division of Radiation ControriDenisbn
Mines, DUSAVATER Annual Tech Eval Reports'Movement & Settlement Monitors\Movement MonitorsXProp Movomcnt Monit
SOPs Nov2010.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0^644/20110 Revision: DUSA-24-
Page 2 of4
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 constmction traffic damage.7 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
1.4.1
Monitoring and Maintenance of Movement Devices
Monitoring and Documentation of Condition of Devices
The mMovement mMonitors 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 jiearen the gdg^e 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 atvy-changes will be completed within 30XX 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
30XX calendar-days ofthe 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.
FormattBd: Font color: Auto
F:\WP\Division of Radiation ControlVDenison Mines. DUSAVATER Annual Tech Eval RcDortsVMovoment & Sottloment
MonitorsVMovemont MonitorsVNIarlcup of Prop Movement Monit SOPs 1 2010.docF:\WP'Division of Radiation Control\DGnison
Mines, DUSA\ATER Annual Tech Eval Reports\Movement & Settlement MonitorsVMovcment MonitorsVProp Movement Monit
SOPs Nov 2010.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date: 0^644/20110 Revision: DUSA-24-
Page 3 of 4
2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in
the location of the undamagcdadjacent devices, it will be assumed that no damage had
occurred to the adjacent devices and no adjustment will be made to the survey 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 undamagedadjacent devices, the procedures in
section 1.6 will be implemented, survey results for tho new dcvico will be adjusted by
the average change obscrvod in the two adjacent doviccs.—This adjustment will be
documented in the Utah Liconscd Land Surveyors report and in the annual Al ER.
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 foet
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 Report
• 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
horizontalvertical movement on the movement monitors. If there is a difference of 0.1 foot -or
greater between two consecutive measuremenmtsenths^, then the corrective actions will be taken
as follows:
4-1. Resurvey the movement monitor that shows vertical or horizontalvertical movement of*^
0.1 foot or more, within 30XX days of discovery of the problem.T
22. Document site conditions.
3^3. Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
man-caused contact, environmental stresses, dike movement, or burrowing animals, etc.).
44. Report this information to the Executive Secretary within a timely mannor45j4X calendar
days for approval and include in that notificafion the investigation steps, movement
evaluation and corrective actions -stepstaken. This report will be also be maintained
Formatted: Numt)ered + Level: 1 +
Numbering Style: 1, 2, 3,... + Start at: 1 +
Alignment: t^eft + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Bullets and Numbering
F:\WP\Division of Radiation ControlVDenison Mines. DUS AVATER Annual Tech Eval ReportsVMovement & SettlemeHt
MonitorsVMovement Monitors'Jvlarkup of Prop Movement Monit SOPs i 2010.docF:VWPVDivision of Radiation ControlVDenison
Mines, DUSAVATER Annual Tech Eval ReportsVMovetnent & Settlement Monitors'iMovement MonitorsVProp Movement Monit
SOPs Nov 201Q.doo
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 5
ATTACHMENT 2
Revised Discharge Minimization Technology Plan
DENISO
MINES
Letter to Mr. Rusty Lundberg
Movement Monitor SOP RFI Response
June 23, 2011
Page 5
ATTACHMENT 2
Revised Discharge Minimization Technology Plan
DENISO
MINES
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
04-06/11 Revision: Denison 11.24
Page 1 of57
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioacfive Materials License No. UT 1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation ofthe
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the few-five tailings cells will be
inspected. Observations will be made of the current condition of each cell, nofing any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4 below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map, and spaces to record observations, especially those of immediate
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailinps Mgnt
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Mgnt Syotem and DMT Mon Plan Nov 2010 Rv 11.1—Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Oi06/11 Revision: Denison 11.24-
Page 2 of 57
concern and those requiring corrective acfion. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concem are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concem is and what corrective measures will resolve the problem. This observation of concem
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2, 3, 4A and 4B, Dikes 1, 2, 3,1A-S, 4A-WE,
and 4B-S, and 4B W wind movement of tailings, effectiveness of dust minimization methods, spray
evaporafion. Cell 2 spillway. Cell 3 spillway. Cell 3, Cell 4A spillway. Cell 4A and 43 liquid pools
and associated liquid retum equipment, and cell leak detection systems, and tho wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concem. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool retum pipeline and pumps.
Daily inspecfions of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell 3,
Cell 4A or Cell 4B; the pond retum line fi-om the tailings area to the Mill; and,
lines transporting pond solutions from one cell to another.
b) Cell 1.
c) Cell 2.
d) Cell 3.
e) CelUA.
f) Cell 4B.
g) Dike stmctures including dikes 1, 2, 3, 4A-S, 4A-EW, and 4B-S and IB W.
h) The Cell 2 spillway. Cell 3 spillway, Cell 4A spillway. Cell 3, Cell 4A and Cell
4B liquid pools and associated liquid retum equipment.
i) Presence of wildlife and/or domesficated animals in the tailings area, including
waterfowl and burrowing animal habitations.
N:VS0Ps and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Mgnt
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^'te Mesa Mill
J)
Revision-n ^•cvjijon. Denison 11.2-3-Page 3 of 57
1)
m)
n)
0)
P)
q)
^P-y evaporation pumps and lines.
^'•"'i movement of tailings anH w
"^'^^^"^^'"inimization.
'^'nd movement of f«'r
'"c used to direct dust
Locations of sluny and SXH- .
An estimate offlow in the so/„r
"'^^ ^«^«t'on return hne(s).
^^''y measurements fn fh .
7'"»«>n the solution efev . the Sdi ''"^^(CeU eievation is 5557 , *™ 5556.14 feL 7 , ""^ ""e 1.0 foo, „f
'^^ollZJS^aemnisa^^ '^^"^"^ge Permit must
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Qi06/\ 1 Revision: Denisonl 1.24-
Page 4 of 57
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
r) —An estimate of the percentage of the tailings boach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Colls 3, 4A and 4B.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attenfion for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addifion to the inspecfions described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operafional issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
("RSO") and/or Mill management in the event that during their inspection they discover that an
abnormal condition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Secfions 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Mgnt
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
04-06/11 Revision: Denisonl 1.24-
Page 5 of 5 7
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will nofify the Radiafion Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, nofify your supervisor and the Mill Manager immediately. The
Mill Manager will then nofify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted bythe Radiafion Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detecfion system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1 and Cell 3 the leak detection system is
measured by use of a pipe that is removed from tho system which will
indicatedual-probe system that senses the presence of solufions in the LDS
system (comparable to the systems in Cells 4A and 4B) and indicates the
presence of solution with a waming light. The Cell 4A and 4B leak detecfion
systems are monitored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector. The pressure
transducer is calibrated for fluid with a specific gravity of 1.0. The water levels
are measured every hour and the information is stored for later retrieval. The
water levels are measured to the nearest 0.10 inch. The data collector is currently
programmed to store 7 days of water level informafion. The number of days of
stored data can be increased beyond 7 days if needed. For Cells 1 and 3. the
water level data is recorded on the Daily Tailings Inspection Form. For Cells 4A
and 4B. tThe water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill's environmental monitoring databasestorage,
NiVSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
04€6/l 1 Revision: Denison 11.24-
Page 6 of 57
and into the files for weekly inspecfion reports of the tailings cell leak detection
systems
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mant
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll 4BUanuarv 2011 Submittals and Revisions for Cell 1BVDMT Plan 01.10.1 IVToilingg
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlino doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Oi06/11 Revision: Denison 11.24-
Page 7 of 57
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be retumed to a
disposal cell.
For Cells 1 and 3. ijf fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed time
since fluid was last pumped or increases in the LDS fluid levels were recorded,
whichever is the more recent. This calculation shall be documented as part of the
weekly inspection.
For Cells 1 and 3. utjpon the initial pumping of fluid fi-om an LDS, a fluid
sample shall be collected and analyzed in accordance with paragraph 11.3 C. of
the Radioactive Materials License.
For Cell 4A and 4B, under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in the
lower flexible membrane liner. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and 4B leak detection systems, the total
volume of all fluids pumped from the LDS on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day. Under no circumstances shall
the daily LDS flow volume exceed 24,160 gallons/day for Cell 4A or
26,I45gallons/day for Cell 4B. The maximum daily LDS flow volume will be
compared against the measured cell solufion levels detailed on Table 1A and
IB (for Cells 4A and 4B, respectively) in Appendix E, to determine the
maximum daily allowable LDS flow volume for varying head condifions in
Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly fiill and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken fi^om actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom ofthe slimes
drain pool and the location of the pump are one foot above the lowest point of the
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
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Mgnt System and DNfT Mon Plan Nov 2010 Rv 11.1 Rcdline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denison 11.24-
Page 8 of 57
FML in Cell 2, which, based on constmction reports, is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float mechanism
and water level probe system. When the water level reaches the level ofthe float
mechanism the pump is activated. Pumping then occurs until the water level reaches
the lower probe which tums the pump off. The lower probe is located one foot above
the bottom of the slimes drain standpipe, and the float valve is located at five feet
above the bottom of the slimes drain standpipe. The average wastewater head in the
Cell 2 slimes drain is therefore less than 5 feet and is below the phreafic surface of
tailings Cell 2, about 20 feet below the water level measuring point on the slimes
drain access pipe. As a result, there is a continuous flow of wastewater from Cell 2
into the slimes drain collection system. Mill management considers that the avet'age
allowable wastewater head in the Cell 2 slimes drain resulting from pumping in this
manner is satisfactory and is as low as reasonably achievable.
(iv) The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi) On a monthly basis, the slimes drain pump will be tumed off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notificafion;
(ix) Because Cell 3 and Cell 4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell 4B slimes drain will be
authorized once it is put into service and while it is acfive. Prior to initiafion of
tailings dewatering operafions for Cell 3, Cell 4A, or Cell 4B, a similar procedure
will be developed for ensuring that average head elevations in the Cell 3 and Cell 4A
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailinps Mgnt
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
04^06/11 Revision: Denison 11.24-
Page 9 of 57
C)
slimes drains are kept as low as reasonably achievable, and that the Cell 3, Cell 4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 14A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis, and the beach area in Cell 4A and 4B with the maximum
elevation is to be taken by survey on a monthly basis, as follows:
(i) The survey will be performed by the Mill's Radiafion Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instmment (the "Survey Instmment")
accurate to 0.01 feet, such as a Sokkai No. B2I, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii) The Rfeference Points (the "Reference Points") for Cells 14A; and 4B, and
Roberts Pond are known points established by professional survey. For Cell 1 and
Roberts Pond, the Reference Point is a wooden stake with a metal disk on it
located on the southeast comer of Cell I. The elevation of the metal disk (the
"Reference Point Elevafion") for Cell 1 and Roberts Pond is at 5,623.14 feet
above mean sea level ("FMSL"). For Cell 3 Coll IA, and Coll IB, the Reference
Point is a piece of metal rebar located on the south dike of Cell 3. The elevation
at the top of this piece of rebar (the Reference Point Elevation for Cell 4A arid
4B3) is at 5,607.83 FMSL. For Cell 4A and 4B. the Reference Point is a piece of
stamped metal monument located next to the transformer on the south side of Cell
4 A and 4B. The elevation at the top of this piece of rebar (the Reference Point
Elevation for Cell 4A and 4B) is 5600.49 fmsl. The Surveyor will set up the
Survey Instmment in a location where both the applicable Reference Point and
pond surface are visible. For Cell 1 and Roberts Pond, this is typically on the road
on the Cell 1 south dike between Cell 1 and Roberts Pond, approximately 100 feet
east ofthe Cell 1/Roberts Pond Reference Point. For Cell 4A and Cell 4B, this is
typically on the road on the Cell 3 dike approximately 100 foot east ofthe Cell 3
Reference Pointsouth side of Cell 4A and 4B;
(iv) Once in location, the Surveyor will ensure that the Survey Instmment is level by
centering the bubble in the level gauge on the Survey Instmment;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 1/Roberts Pond Reference Point on the top of the rebar on
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Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0^06/11 Revision: Denisonll.2+
Page.l0of57
the Cell 4A and 4B 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;
(vi) The Surveyor will focus the cross hairs of the Survey Instmment on the scale on
the Survey Rod, and record the number (the "Reference Point Reading"), which
represents the number of feet the Survey Instmment is reading above the
Reference Point;
(vii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell 1, Coll 4 A, Cell 4B,
or Roberts Pond, or the area of the beach in Coll IA or Cell 4B with the highest
elevation, as the case may be. These designated locations, and the methods to be
used by the Assistant to consistently use the same locations are as follows:
(vii) For a newly-constmcted cell, when the cell is first placed into operafion, the solufion level
is typically zero feet above the FML or a minimal elevation above the FML due to natural
For newly-constructed cells, solution level measurement will not be required until
- - -( Formatted: No bullets or numt)erlng
precipitation.
the solufion level is high enough that it can be reached safely by personnel with a measuring tape
along the side of the FML. Solutions levels will be measured by this method beginning when the
solution level is high enough to be reached safely, as determined by the RSO. Surveying of
solution levels will not be required unfil solution levels are high enough that thev can effecfivelv
be measured by survey instmment from the appropriate surveying point.
A^ Pond Surface Measurements
AT
L Coll 4A
Formatted: Indent: Left: 1.54", No bullets or
numbering .
The Assistant will walk down the slope in tho northeast comer of Coll 1A and
place the Survey Rod at the liquid level.
fLl. Cell4B
The Assistant will walk down the slope in the northwest comer of Cell 4B and
place the Survey Rod at the liquid level.
HLll. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell I. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
IV. Roberts Pond Formatted: Indent: Left: 1.5", Tab stops:
1.5", Left + Not at 1.13"
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W06/n Revision: Demsonll.2+
— Page n 01 J'
.„.....e.pa.—^^^^^^^^^^
measuring pomts for Roberts r ^^^^^^^
^^I^ome««depen*ngo„so,utio. elevations
These coordinate locations may vary som
in the Pond and Cells;
B. Cell 4B Beach Elevation eh area of Cell 43
T,,Msistant«il. place the survey .0^^^^^^^^
are below 5,593 PMbL, ^ ^^^^^ ^^^^^
P^itablished a level readmg; ^ mstmment on the sea.
represents the number of feet tne s
surface level. ^^^^ ^^^j^g the
surveyor .ill —^^cS—^"^^^^ Reference Point ReadmgfortheCen^ ^j^^^^^^^^
rceT:;tL^srd:^^^^^^
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24-
Page 12 of 57
(i) New Decontamination Pad
The New Decontaminafion Pad is located in the southeast comer of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspecfion capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracfing the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevafion 5589.8 feet amsl) ofany of the three
(3) observafion ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).
F. In addition to inspecfion of the water levels in the standpipes, the
New Decontaminafion Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalifies relating to the pad and any
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
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damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
1/8 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease acfivities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer ofthe
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontaminafion Pad will be inspected on a weekly
basis. Any soil and debris will be removed from the Exisfing
Decontamination Pad immediately prior to inspection ofthe concrete
wash pad for cracking Observations will be made of the current
condition of the Exisfing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. If there are any cracks greater than 1/8 inch
separafion (width), the RSO must be contacted. The RSO will have
the responsibility to cease activifies and have the cracks repaired.
/) Summary
In addifion, the weekly inspecfion should summarize all acfivifies conceming the
tailings area for that particular week.
Results of the weekly tailings inspecfion are recorded on the Weekly Tailings and DMT Inspection
form. An example ofthe Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Secfion 3.1 d) above. The Weekly solufion level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solufion elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
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Book 11: Environmental Protection Manual, Section 3.1
04fl6/l 1 Revision: Denison 11.24-
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Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;
b) a 4 ft. buffer is maintained at the periphery ofthe storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary ofthe storage area;
and
c) all altemate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking altemate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Da/a form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thiclmess will be measured using an ultrasonic device by
cither the radiation safety staff or other trained designees. The critical points ofthe
pipe include bends, slope changes, valves, and juncfions, which are crifical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill mn.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstmction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
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Book 11: Environmental Protection Manual, Section 3.1
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c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concem can be documented.
J) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Constmction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspecfion of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O4-06/11 Revision: Denisonl 1.24-
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The Operations/Maintenance Review consists of reviewing Operations and
Maintenance acfivities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Constmcfion Review consists of reviewing any constmction changes or
modificafions made to the tailings area on a quarterly basis.
An estimate ofthe percentage ofthe tailings beach surface area and solufion pool
area is made, including estimates of solutions, cover areas, and tailin gs sands for
Cells 3.4A and 4B.
Formatted: Font: Italic
Formatted: Indent: Left: 1", No bullets or
numbering
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Book 11: Environmental Protection Manual, Section 3.1
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d^e) Summary
The summary will include all major acfivifies or observafions noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example ofthe Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation ofthe tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention stmctures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review ofall tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
stmctures.
In the event tailings capacity evaluafions (as per SOP PBL-3) were performed for the receipt of
altemate feed material during the year, the capacity evaluafion forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time ofthe evaluafion.
Tailings inspecfion records will consist of daily, weekly, monthly, and quarterly tailings inspecfions.
These inspecfion records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concem. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspecfion, photographs ofthe tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0406/11 Revision: Denisonl 1.24-
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The registered engineer will obtain copies of selected tailings inspecfions, along with the monthly
and quarterly summaries of observations of concem and the correcfive acfions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15* of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
Sah Lake City, Utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitafion (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell I pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave mn up factor of 0.77 feet.
The flood volume from the PMP event over the Cell 4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), fimes the PMP of 10
inches, with a wave mn up factor of 0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell 4A is 40 acres, and in Cell 4B is 40
acres. The top ofthe flexible membrane liner ("FML") for Cell 1 is 5,618.2 FMSL, for Cell 4A
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
QiQ6/\l Revision: Denisonl 1.2+
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is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. Cell 1
The freeboard limit for Cell 1 will be set at 5,615.4 FMSL. This will allow Cell 1 to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 feet equals 2.85 feet. The
fi-eeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condifion 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
ofthe PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell 4A will be attributed to Cell 4B. A spillway has been added to Cell 4A to allow overflow into
CelUB.
6.3.5. Cell 4B
The fi-eeboard limit for Cell 4B will be set assuming that the total PMP volume for Cells 2, 3,4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell 4B is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell 4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume 38.1 acre-feet
Overflow from Cell 4A assuming no storage in Cell 3 or 4A 159.4 acre-feet
Sum of PMP volume and overflow volume 197.5 acre-feet
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.24-
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Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave mn up factor
Total required freeboard
4.9 feet
0.77 feet
5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth of afoot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation ofthe beach area in Cell 4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevafion of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevafion of the beach area in Cell 4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder of the ensuing year (period t=0) (unfil the next November 1) will be
calculated when that elevafion is first exceeded (the "Initial Calculafion Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the Initial Calculafion Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell 4B for the remainder ofthe
ensuing year (up to the next November 1), based on production estimates for that
period ("Ao*"), will be determined;
iii) Ao* will be grossed up by a safety factor of 150% to allow for a potential
underesfimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4A will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell 4B for solids as at the Inifial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be direcfiy proportional to the reducfion in the available space in Cell 4A
for solids. That is, the reduced pool surface area for period t=0 ("RPAo"), after the
reduction, will be calculated to be:
(1 - (Ac* X 1.5) / (2,094,000 - To)) x 40 acres = RPAo
vii) The required freeboard for Cell 4A for the remainder of the period t=0 can be
calculated in feet to be the wave mn up factor for Cell 4B of 0.77 feet plus the
quofient of 197.5 acre feet divided by the RPAQ. The freeboard limit for Cell 4B for
the remainder of period t=0 would then be the elevafion of the FML for Cell 4B of
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White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
04-06/11 Revision: Denisonl 1.24-
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5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulfing freeboard limit will persist until the next November 1.
An example of this calculafion is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594 FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculafing the Adjusted Reduced Pool Area for the previous period (ARPAM)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-1).
The RPAt-i used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARP AM is merely the RPA that would have
been used for period t-1 had the actual tonnages for year t-1 been known at the outset
of period t-1 and had the RPA been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARPAt-i can be calculated using the following formula:
(1 - An / (2,094,000 - Tt-O) x ARPAt.2 = ARPAM
Where:
• At-i is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-1;
• Tt-i is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t-1; and
• ARPA,.2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Inifial Calculafion Date, then ARPA,.2 is 40 acres;
ii) Once the ARP An for the previous period (period t-l) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1 - (At* X 1.5) / (2,094,000 - TO) x ARP AM = RPAt
Where:
• At* is the expected number of dry tons of tailings to be deposited into Cell 4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Tt is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
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Book 11: Environmental Protection Manual, Section 3.1
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• ARPAt-i is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-I) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave mn up
factor for Cell 4B of 0.77 feet plus the quofient of 197.5 acre feet divided by the RPAt.
The freeboard limit for Cell 4A for period t would then be the elevafion of the FML
for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist unfil the next Annual Calculafion
Date for period t+1.
An example of this calculafion is set out in Appendix F.
(e) When a Spillway is Added to Cell 4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Cell 4B and a new tailings cell then, if an approved freeboard
limit calculafion method for the new cell is set to cover the entire PMP event for Cells 2,3,4A, 4B
and the new tailings cell, the freeboard limit for Cell 4B will be inapplicable, except for approved
provisions to prevent storm water mnoff from overtopping dikes.
6.3.6. Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of5,624.0 feet above mean sea
level, as specified in the GWDP.
6.4. Annual Leak Detecfion Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the condifions set forth in License
Condifion 11.3.C. The results ofthe analysis will be reviewed to determine the origin ofthe
solufion.
6.5. Annual Inspecfion of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontaminafion Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
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Book 11: Environmental Protection Manual, Section 3.1
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the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspecfion form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2"*^ Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom ofthe tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use ofthe
facility. All inspection findings and any repairs required shall be documented on the Annual
Decontamination Pad Inspecfion form. A record of the repairs will be maintained as a part ofthe
Annual Inspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3,4, 5 and 6 above. However, additional inspecfions should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Secfions 2, 3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respecfively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concem noted on the daily and weekly tailings inspections. Correcfive measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspecfion forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
NASOPs and ProceduresVMoveinent monitor SOP and commentsV06.23.11 resporise to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll IBVJanuarv 2011 Submittals and Rcisions for Cell IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Redlinc.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 24 of 5 7
Manager.
8.2. DMT Reports
Quarteriy reports of DMT monitoring acfivifies, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 ofthe GWDP:
a) On a quarteriy basis, all required information required by Part 1 .F.2 ofthe GWDP
relating to the inspecfions described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring), 3.2 (Weekly Inspecfion of Solufion Levels in Roberts Pond) and 3.3
(Weekly Feedstock Storage Area Inspecfions);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicafing the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection ofthe New Decontamination Pad described
in Secfion 6.5(a), the inspecfion findings, any repairs required, and repairs
completed shall be summarized in the 2"'' Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2"** Quarter report, due September 1
of each calendar year; and
e) An annual summary and graph for each calendar year ofthe depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell 'IBVJonuarv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01.10.1 IVTailingo
Mgnt System arid DMT Mon Plan Nov 2010 Rv 11.1 Rcdline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
^06/11 Revision: Denisonl 1.2+
Page 25 of 57
APPENDIX A
FORMS
N ASOPs and Pi-oceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13 11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll 4BVJanuQrv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01.10.1 IVTailings
Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O+06/11 Revision: Denisonll.24-
Page 26 of 57
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Inspector:
Date;
Accompanied by:
Time:
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
L TAILINGS SLURRY TRANSPORT SYSTEM |
Inspecfion Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation
IL OPERATIONAL SYSTEMS |
Inspecfion Items Conditions of Potential Concem Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Water Level Greater Than Operating Level, Large Change
Since Previous Inspecfion
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover. Exposure of Liner
Liner . Observable Liner Damage
NiVSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mpit Svstem and DMT Mon Plan June 2011 rev 11.2!docWiG<ell
4BVJQnuniy 2011 Submittals ond Revisions for Cell -IBVDMT Plan 01.10.1 IVTailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O+06/U Revision: Denisonll.24-
Page 27 of 57
IIL DIKES AND EMBANKMENTS
Inspection Items Conditions of Potential
Concem
Dike l-I Dike 1-
lA
Dike 2 Dike 3 Dike
4A-S
Dike
4A-EW
Dike
4B-S
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
Crest Cracks, Subsidence, Severe
Erosion
No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
•No
visible
slope or
dike to
inspect
No
visible
slope or
dike to
inspect
Formatted Table
IV. FLOW RATES
Slurry Linefs) Pond Retum S-X Tails Spray System
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
Yes
No
No
VL DUST CONTROL
Cell 2 Cell 3 CelUA Cell4B
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
NIVSOPS and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailinps Mgnt Svstem and DMT Mon Plan June 2011 rev :
IBVJanuniy 2011 Submittals and Revisions for Cell -IBVDMT Plan 01.10.1 IVTailings Mgnt System and DMT Men PlanNov 2010 Rv 11.1 Rcdhne.doo
.2.docNAGeB
White Mesa Mill - Standard Operating Procedures
Book 11: Enviromnental Protection Manual, Section 3.1
d+06/11 Revision: Denisonll.2+
Page 28 of 57
General Meteorological condifions:
VIL DAILY LEAK DETECTION CHECK | |
Cell 1 Cell 2 Cell 3 Cell 4A Cell 4B
Leak
Detection
System
Checked
Checked Checked Checked Checked Checked Leak
Detection
System
Checked
Wet Dry Wet Dry Wet Dry Wet Dry Wet Dry
Leak
Detection
System
Checked
Inifial level Initial level Inifial level Initial level Inifial level
Leak
Detection
System
Checked
Final
level
Final
level
Final
level
Final
level
Final
level
Leak
Detection
System
Checked
Gal. pumped Gal. pumped Gal. pumped Gal. pumped Gal. pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
NiVSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt Svstem and DMT Men Plan June 2011 rev 11.2!docNACgB
-IBVJanuflry 2011 Submittals ond Revisions for Cell /IBVDMT Plan 01.10.1 IVTailings Mgnt System tind DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1 O+06/11 Revision: Denisonl 1.24-
Page 29 of 5 7
co"^'"e"tsV06.23 J 1 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment System »nH DMT Mon Plan June 201
1BUonuflr>-20IISubmittalsflndRc>ioionoforColl.tDVDMTPlan01.10.11\TailingaMgntSyatema^^^ Redlinc.dee 1 rev 11.2;dooNACeH
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
^+06/11 Revision: Denisonl 1,24r
Page 30 of 57
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt Svstem and DMT Mon Plan June 2011 rev 11.2.docNTii€«H
-1BVJanunr>' 2011 Submittals ond Revisions for Cell 4BVDMT Plan 01.16.1 IVToilings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
3 o
(U -
2 .2
p. " 2 ° S3 "3 «
2 ">
Tailings Daily Inspection Repoit
Tailings SKiny Dischaiae Location
MILL SITE
CELL NO. 1
Dike. L-L-^...
CELL NO. 2
i / •-.. \ \ i
CELL NO. 4B
CELL NO. 4A
Date:
Inspector;
II
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental F*rotection Manual, Section 3.1
#+06/11 Revision: Denisonl 1.24-
Page 32 of 57
-[ Formatted; Left
N.VSOPs and ProceduresVMovemeht monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt Svstem and DMT Men Plan June 2011 rev 11.2!docNAGeH
-IBVJgnuory 2011 Submittals and Rcwsions for Cell IBVDMT Plan 01.10.1 IVTailings Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O+06/11 Revision: Denison 11.2-1-
Page 33 of 57
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Date: Inspectors:
1. Pond and Beach
elevations (msl, ft)
Cell 1: (a) Pond Solution Elevafion
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b)).
Coll 4A: (Q)Pond Solution Elevafion
(b)FML Bottom Elevation
(o)Dopth of Water above FML ((a) (b));
5597
5555.11
Cell 4B: (a)Ppnd Solution Elevation
(b)FML Bottom Elevation 5557.50
(c)Depth of Water above FML ((a)-(b))
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Roberts
Pond: (a)Pond Solution Elevation
(b) FML Bottom Elevation 5612.3_
(c) Depth of Water above FML ((a)-(b))
2. Slimes Drain Liquid Levels Cell 2 Pump ftinctioning properly
Depth to Liquid pre-pump
Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump
Post-pump head is 38' -Depth to Liquid Post-
pump =
N:VSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI nn Movement monitor SQPVTailinR^ Mfint
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VCcll -IBVJanuarv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2-1-
Page 34 of 57
3. Leak Detection Systems
Observation:
€eti-l-Cell IA Coll IB
Is LDS wet or
Ay?
-wet -wet _wct -wet -wet
If wet. Record
liquid level:
-ft4e -ft4e -*t4e -FHe
Liquid Liquid Liquid Liquid Liquid *
If sufficient
fluid is
present, record
volume of
fluid pumped
and flow rate:
Volume
Rate
Volumo
Rate
Volume
Rate-
Volumo
Rate-—
Volume
Rrte •
Was fluid
collected?
:yes _yes_ jfes
(Same data as Daily Inspection Form. Record data on daily form).
Observafion:
New Decon Pad,
Portal 1
New Decon Pad,
Portal 2
New Decon Pad
Portal 3
Is LDS (Portal)
wet or dry?
wet dry wet dry wet dry Is LDS (Portal)
wet or dry?
If wet. Record
liquid level:
Ft to Ft to Ft to If wet. Record
liquid level: Liquid Liquid Liquid
If wet. Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented:
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.1:1 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VColl 4BVJanunrv 2011 Submittals and Revisions for Cell -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 35 of 57
6. Remarks:
7. Contaminated Waste Dump (^^awaiting DRC
approval
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Cell 4A and 5558.50 for Cell 4B)? no yes
If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
N:VSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN:VCcll 4BVJonuarv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01 10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
m-06/11 Revision: Denisonl 1.2+
Page 36 of 57
Inspector:
Date:
1. Slurry Pipeline:
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Pipe Thickness:
2. Diversion Ditches and Diversion Berm
Observation:
(To be meoflurod only during periods when the Mill is opbmting)
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
yes no yes no yes no
yes no yes no yes no
yes no yes no yes no
yes no yes no yes no
_yes_
_yes_
no
no
Comments:
3. Summary of Activities Around Sedimentation Pond:
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACeir-1BVJnnuniy 2011 Suhmittnlr. nnH Rnvininnr. fnr rdl 4BVnMT PInn 01 10.1 IVTailings
Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O+06/11 Revision: Denisonl 1 2+
Page 37 of 57
4. Overspray Dust Minimization:
Overspray system functioning properly: jyes_
Overspray carried more than 50 feet fi-om the cell:
Ifyes", was system immediately shut ofl?
Comments:
j'es_
_yes_
5. Remarks:
6. Settlement Monitors
Cell2Wl:
Cell 2 W2:
Cell 2 W3:
Cell 2 W4:
Cell 2W7-C:"
Cell 2 W7N:"
Cell 2 W6C:"
Cell 4A-Toe:
Cell 3-2C:
Cell 2W3-S:
Cell 2EI-N:
Cell2El-lS:
Cell 2E1-2S:
Cell 2 East:
Cell 2 W7S:
Cell 2 W6S:
Cell 2 W4S:
Cell3-2S:
Cell3-1N:_
Cell 3-lC: _
Cell 3-1 S:_
Cell 3-2N: _
Cell 2W5-N
Cell 2 W6N
Cell 2 W4N
Cell 2 W5C
Cell 2 W5S
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
^S^Summary of Daily, Weekly and Quarterly Inspections:
~{ Formatted: No bullets or numbering
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2 dncNArcll 4BUimiinry 2011 Siihmittnk nnH Rnvi-iinn'-. fnr rnll iR\nMT Plnn 01 10 11VTniling-i
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 38 of 57
8. Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
9. Monthly Slimes Drain Static Head Measurement for Cell 3 (Depth-in-Pipe Water level) (after
Cell 3 is closed):
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell -IBVJanuQiy 2011 Suhmittnls nnd RRviainns fnr Cell -IBVDMT Plan 01.101 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 39 of 57
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities:
4. SummarvEstimated Areas:
4.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJnnuarv 2011 Submittals and Revisions for Coll iBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc.doo
Formatted: Outline numbered -i- Level: 1 +
Numbering Style: 1, 2, 3,... + Start at: 1 +
Alignment: Left -i- Aligned at: 0" + Tab after:
0.25" -t- Indent at: 0.15", Widow/Orphan
control
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1 2+
Page40 of 57
Cell 3 Cell 4A Cell 4B
Estimated oercent of beach surface area
Estimated percent of solution oool area
Estimated percent of cover area
Comments: - - -{ Formatted: Left
N:VSOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll 4BVJanuarv 2011 Submittals and Revisions for Cell 'IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 41 of57
APPENDIX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no:
comments:
Are all altemate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no:
comments (e.g., conditions of containers):
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No:
Comments:
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Ment
Svstem and PMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJanuarv 2011 Submittals and Revisions for Coll IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Envirorunental Protection Manual, Section 3.1
O+06/11 Revision: Denisonl 1.2+
Page 42 of 5 7
Other comments:
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl 4BVJanuarv 2011 Submittals ond Revisions for Cell -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlino doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 43 of 57
APPENDIX A (CONT.)
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection:
Inspector:
New Decontamination Pad:
Are diere any cracks on the wash pad surface greater than 1/8 inch of separation? Yes No
Is there any significant deterioration or damage of the pad surface? Yes ^No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? Yes ^No
Findings:
Repair Work Required:
Note For the annual inspection of the both the Exisfing and New Decontaminafion Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2"** Quarter report, due September 1 of each
calendar year
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl -IBVJonuniy 2011 Siihmittnlr. nnd Rnvi-iinnr. fnr Tnll 4RVnMT Plnn 01 10 1 IVTnilinga
Mgnt System ond DMT Mon Plon Nov 2010 Rv 11.1 Redlinc.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
^06/11 Revision: Denisonl 1.2+
Page 44 of 5 7
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducfing daily tailings inspecfions. Training informafion is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimizafion
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, acfivifies, and areas of concem regarding the tailings areas.
Notifications:
The inspector is requiredto record whether all inspection items are normal (safisfactory, requiring no
acfion) or that conditions of potential concem exist (requiring action). A "check" mark indicates no
acfion required. If condifions of potenfial concem exist the inspector should mark an "X" in the area
the condifion pertains to, note the condition, and specify the correcfive action to be taken. If an
observable concem is made, it should be noted on the tailings report until the correcfive acfion is
taken and the concem is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify' Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas ofthe tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 1 1.2.docNArcll -IBVJnnunTV 20] 1 SnhmiHnlr. nnH Br^wiinn.-. fnr r#.11 iR\nMT Plnn 01 in lUTnilingQ
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 45 of 57
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concem and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concem for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for Conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells I and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradafion
of the PVC liner. Small areas of exposed liner should be covered by hand. Large secfions of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these condifions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and tumed into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date ofthe repairs.
Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concem
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concem are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addhion, the dikes, in particular dikes 3T-4A-S, 4A-WE, and 4B-S, and4B W, should be
inspected closely for mice holes and more importantly for prairie dog holes, as the prairie
dogs are likely to burrow in deep, possibly to the liner. If any of these conditions exist, the
inspection report should be marked accordingly.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll IBVJanuarv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlino doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 46 of 57
Flow Rates:
Presence ofall flows in and out of the cells should be noted. Flow rates are to be esfimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond retum, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds tme when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection ofall slurry lines has to be made every 4 hours during operation ofthe
mill. If possible, the inspection should include observafion of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2, 3,4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusfing or wind movement of tailings should be
documented. In addifion, an esfimate should be made for wind speed at the fime of the
observed dusting or wind movement of tailings.
The Radiafion Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the ShifterEnvironmental. Healtii and Safetv personnel as
close to 8:00 a.m. as possible. All snow or ice should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concem during the inspection should be noted in this secfion. Corrective
action should follow each area of concem noted. All work orders issued, contacts, or
notificafions made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI nn Movement monitor SOPVTailmgs Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl -IBVJanuarv 2011 Submittals and Revisions for Coll -IBVDMT Plan 01.10.1 IVTailings
Mgnt System ond DMT Mon Plon Nov 2010 Rv 11 1 Rcdline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
O+06/11 Revision: Denisonl 1.2+
Page 47 of 57
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
5. Acfivifies around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety mles applicable to the mill are applicable when in the tailings area. These mles
meet the required MSHA regulafions for the tailings area. Please pay particular nofice to the
following mles:
1. The posted speed limit on Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell 4A and 4B dike) is 15 mph. These limits end-should
not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any fime.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road condifions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or hamess with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
11. Certification:
Following the review of this document and on-site instmction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certificafion. Refer to the Certification
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11 2.docN Vroll -IBVJnnunr^- 3011 Siihmittnl'i nnH Rn^-iiinng fnr Coll -lRVD\-n' Plan 01 10.1 IVToiling.-i
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlino doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
QiOen 1 Revision: Denisonl 1.2+
Page 48 of 57
Form, Appendix C. This form should be signed and dated only after a thorough review ofthe
tailings information previously presented. The form will then be signed by the Radiafion
Safety Officer and filed.
N:VS0Ps and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJanuarv 2011 Submittals and Revisions for Cell -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 49 of 5 7
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document tified "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instrucfion
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspecfion of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJanuary 2011 Submittal.--, nnd Rovi-iinns for Cell -IBVDMT Plan 01.10.1 IVTailingo
Mgnt System ond DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 50 of 57
APPENDIX D
FEEDSTOCK STORAGE AREA
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docN AColl 4BVJonuary 2011 Submittals nnd Rovinionr. for Coll -IBVDMT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 51 of 57
N
HHP m mill mi MHl m mH
s 7 t'****'** |-nirri.rr"m
1 Movement menitor iitJl'Vl ailmgs Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJanuarv 2011 Submittals and Revisions for Cell -IBVDMT Plan 01.10.1 IVTailingo
Mgnt Syotem and DMT Mon Plan Nov 2010 Rv 11.1 Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 52 of 57
APPENDIX E
TABLES
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl 4BVJanuarv 2011 Submittals and Rc\-isiono for Cell -IBVDMT Plan 01.10.1 IVTailingo
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 53 of 5 7
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day )
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
Table IB
Calculated Action leakage Rates
for Various head Condhions
Cell 4B White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Acfion leakage Rate
(gallons / acre / day )
5 ;211.40
10 ^17.00
15 ^69.90
20 ,422.70
25 ,475.60
30 ^28.40
35 ,570.00
37 ,581.20
-{ Formatted; Not Highlight
-\ Formatted:
-{ Formatted:
Not Highlight
Not Highligtit
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 resporise to 06.13.11 RFI on Movement monitor SOPVTailings Ment
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell -IBUanuaiv 2011 Submittals and Rosisions for Coll -IBVDMT Plan 01.10.1 IVTailingo
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 54 of 57
N:VS0Ps and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNAColl 4BVJanuarv 2011 Submittals and Revisions for Cell -IBVDMT Plan 01 10.1 IVToilingg
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rcdline.doc
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 55 of 5 7
APPENDIX F
Example of Freeboard Calculations
For Cell 4B
Assumpfions and Factors:
o Total PMP volume to be stored in Cell 4A-159.4 acre feet
o Wave mnup factor for Cell 4A - 0.77 feet
o Total capacity ofCelUB-2,094,000 dry tons
o Elevation ofFMLof CelUB-5,600.35 FMSL
o Maximum pool surface area of Cell 4A - 40 acres
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL - 1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL - March 1, 2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected
Tailings Solids
Disposition into
Cell 4B
Determined at
the beginning of
the period (dry
tons)*
Expected
Tailings
Solids
Dispositio
n into Cell
43 at the
beginning
ofthe
period,
multiplied
by 150%
Safety
Factor
(dry tons)
Actual Tailings
Solids
Disposition into
Cell 4B
determined at
end of the
period (dry
tons)*
March 1, 2012
to November 1,
2012
150,000 225,000 225,000
November 1,
2012 to
November 1,
2013
300,000 450,000 275,000
November I,
2013 to
November 1,
2014
200,000 300,000 250,000
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.1:1 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docN ACell -IBVJanuarv 2011 Submittals and Rcvioions for Cell IBVDMT Plan 01.10.1 IVTailingo
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1 Redline.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 56 of 57
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrafive purposes only.
Based on these assumpfions and factors, the freeboard limits for Cell 4B would be calculated
as follows:
1. Prior to March 1,2012
Prior to March 1, 2012, the maximum elevation ofthe beach area in Cell 4B is less than or
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1. 2012 to November 1. 2012
The pool surface area would be reduced to the following amount
(1 - 225,000/(2,094,000- 1,000,000)) x 40 acres = 31.77 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave mn up factor for Cell 4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell 4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1. 2012 to November 1. 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1 - 450,000 / (2,094,000 - 1,000,000 - 225,000)) x 31.77 acres = 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave mn up factor for Cell 4B of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B would be reduced fi-om 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2012, and this freeboard limit would persist until November 1, 2013.
NASOPs and ProceduresVMovement monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailines Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACell IBVJanuorv 2011 Submittals and Revisions for Cell -IBVDNtT Plan 01.10.1 IVTailings
Mgnt System and DMT Mon Plon Nov 2010 Rv 11.1 Rodlinc.doo
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
0+06/11 Revision: Denisonl 1.2+
Page 57 of 57
4. November I, 2013 to November 1. 2014
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(I -275,000/(2,094,000- 1,000,000 - 225,000) x 31.77 acres = 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1, 2013.
Then, calculate the modeled pool surface area to be used for the period:
(I - 300,000 / (2,094,000 - 1,000,000 - 225,000 - 275,000)) x 21.72 acres
10.75 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave mn up factor for Cell 4B of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
NASOPs and ProceduresVMoveinent monitor SOP and commentsV06.23.11 response to 06.13.11 RFI on Movement monitor SOPVTailings Mgnt
Svstem and DMT Mon Plan June 2011 rev 11.2.docNACcll -IBVJnnuarv 2011 Submittals and Rcvioions for Coll 4BVDMT Plan 01.10.1 IVTailingo
Mgnt System and DMT Mon Plan Nov 2010 Rv 11.1—Rcdlinc.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.1
Date:3Ty2010 Revision: DUS A-1
Page lof3
1.
1.1
MOVEMENT (DISPLACEMENT) MONITOR
STANDARD OPERATING PROCEDURES
MOVEMENT (DISPLACEMENT) MONITOR
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 ofthe Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Within 30 days of completion of construction activities, Movement Monitors will be installed
and surveyed by a Utah Licensed Land Surveyor. The installation of these movement monitors
will be along the exposed dike of the tailing cells.
All new movement monitors (installed after June, 2010) will be surveyed 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 annually. All existing movement monitors
(installed prior to June 2010) Will be surveyed on an annual basis.
On ari annual basis, a Utah Licensed Professional Engineer will review, analyze, and certify the
data 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. A piece of rebar, 24 inches in length, will be
driven into the hole. The hole will be back filled and the top of the rebar will be below surface
grade. Each monument will be individually tagged and numbered.
C:\DOCUME~l\Drupp\LOCALS~l\Temp\XPgrpwise\Seefion 5 1 Movement Monitor SOP Nov 20I0.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protecfion Manual, SOP Section 5.1
Date: 11/2010 Revision: DUS A-1
Page 2 of 3
1.4
1.4.1
Monitoring and Maintenance of Movement Devices
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. The
Movement Monitors will be installed such that the monument is 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 notification to the Corporate Compliance Director and a corrective action
plan will be created for repairs and the surveying and documentation of any changes,
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. 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.
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 Environmental Department files
for inspection.
C:\DOCUME~I\Drupp\LOCALS~l\Temp\XPgrpwise\Secfion 5 I Movement Monitor SOP Nov 2010.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Secfion 5 1
Date: 11/2010 Revision: DUSA-1
Page 3 of 3
1.6 Performance Criteria and Data Validation
The data will be reviewed for any.errors and or major changes in the vertical movement on the
movement monitors. If there is a difference of 0.1 foot, then the corrective actions will be taken
as follows:
1 Resurvey the movement monitor that shows vertical movement of 0.1 foot.
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 manner and include in
that notification the investigation steps, movement evaluation and corrective action steps.
Movement monitors that show vertical 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, and certify the
data which 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.
C:\DOCUME~l\Drupp\LOCALS~l\Temp\XPgrpwise\Secfion 5 1 Movement Monitor SOP Nov 2010.doc
^^-^^^
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieuteimnl Governor
^^artment of
Environmental Qua
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
U:S. Postal Service
CER|tt'IED MAII
(DomeH^lfa/Y Only; No Ir
IED MAIL™ RECEIPT
fa/Y Only; No Insurance Coverage Provided)
CERTIFIED MAIL
(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:
ovember 3, 2i
m cr n-
C3
xn
CD
r=l
HI
O
•
r-
For delivery Information visit our website at www.usps.coma
^««! mm m iMi i i f*'^
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivery Fee (Endorsement Renuiredl
$
Postmark
Here
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivery Fee (Endorsement Renuiredl
Postmark
Here
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivery Fee (Endorsement Renuiredl
Postmark
Here
Postage
Certified Fee
Retum Receipt Fee (Endorsement Required)
Restricted Delivery Fee (Endorsement Renuiredl
Postmark
Here
Total PostB'
Sent To
Ms. Jo Ann Tischler
Denison Mines (USA) Corp. (DUSA)
streSfrApt-N 1050 Seventeenth Street, Suite 950
Denver, CO 80265 or PO Box Nc
'cliy'siaieyzi
PS Form 3800. August 2006 See Reverse for Instructions '
SUBJECT: November 1, 2011 DUSA Response Letter and Transmittal of Movement (Displacement)
Monitoring Staiidard Operating Procedures [SOPs], 11/2011 Revision: DUSA-2.1 \
October 17, 2011 DRC Request for Information Letter; December 1, 2010 DUSA
Transmittal Letter of Draft Movement Monitoring SOPs;. Approval of Movement
(Displacement) Monitoring SOP
We have received the subject November 1, 2011 DUSA letter which transmits the subject Movement
Monitoring Standard Operating Procedures (SOPs). The subject SOPs were submitted by DUSA in
response to our comment letter of October 17, 2011, and to comply with the requirements of License
Condition 11.8.
We have reviewed this submittal, and have no further comments. Therefore, we hereby approve the
subject Movement (Displacement) Monitoring SOPs.
If you have any questions on the above, please contact Mr. Rupp of DRC.
UTAH RADL^TION CONTROL BOARD
ig WSJones, ActiHg Executive Secretary Crai
DARidr
F:\License\Move & Settle MonitorsXMovement Monitors\Mlyl SOP Apprvl 11-2011 .doc
195 North 1950 West • Sait Lake City. UT
Mailing Address: P.O.Box 144850 • Salt Uke Cily. UT 84114-4850
Telephone (80!) 5.16-4250 • Fax [phone] • T.D.D. [phone]
\v\vw.deq.utah.f{<!v
Primed on 100% recycled paper
Dave Rupp - DRC Movement Monitoring SOP Comment Letter
From: Dave Rupp
To: [e-mail]
Date: 10/31/2011 10:02 AM
Subject: DRC Movement Monitoring SOP Comment Letter
CC: [e-mail]
Attachments: RFI Letter.pdf
Atteehed is a pdf copy of the subject letter you requested. The file stamp shows it was mailed October lS,
2011. Thanks for following up on this. --
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake City, UT 84114-4850
Telephone [phone]
Fax [phone]
Email: [e-mail]
SENDER: COMPLETE THIS SECTION
Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired,
iprint your name and address on the reverse
so that we can return the card to you.
Attach this card to the back of the mailpiece,
:or on the front if space permits.
1. Article Addressed to:
z~
COMPLETE THIS SECTION ON DELIVERY
A. Received by (Please Print Clearly) B. Dat^f Del|very
C. Sign;
X • Agent
Addressee
D. Is delivery address different from item 1 ? • Yes
" '^'^•S, enter delivery address below. d No
RE: movement SOP's request for Info/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
/
/ '3. Service Type
• Certified Mail • Express Mail
• Registered • Return Receipt for Merchandise
• Insured Mail • C.O.D.
4. Restricted Delivery? {Extra Fee) • Yes
2. Article Number (Copy from service label) 7D11 DllQ 7=151 ISOb
i PSForm3811, July 1999 Domestic Return Receipt 102595-99-M-1789
file://C:\Documents and Settings\drupp\Local Settings\Temp\XPgrpwise\4EAE723FEQD.;. 10/31/2011
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
October 17,
CERTIFIEP MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
o
•
O
RE: movement SOP's request for info/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PS Form 3800. August 2006 See Reverse for Instructions
Dear Ms. Tischler:
SUBJECT: June 23, 2011 DUSA Response Letter and Transmittal of Movement
(Displacement) Monitor Standard Operating Procedures [SOPs], 06/2011
Revision: DUSA-2, and a draft DMT Plan version 06/11 Revision: Denison 11.2;
June 13, 2011 DRC Request for information Letter; December 1, 2010 DUSA
Transmittal Letter of Draft Movement Monitoring SOPs; Request for
Information
We have received the subject June 23, 2011 DUSA letter which transmits the subject Movement
Monitor Standard Operating Procedures (SOPs) and a draft DMT Plan. The draft DMT Plan will
be addressed under separate cover. The subject SOPs were submitted by DUSA in response to^
our comment letter of June 13, 2011, and to comply with the requirements of License Condition
11.8.
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.
I also suggest the title, and paragraph line 1, be changed to "Movement (Displacement)
Monitoring", rather than "Movement (Displacement) Monitor."
Please review the above comments, and respond in writing, incorporating the/above comments as
appropriate, and submit a revised Movement Monitoring Standard Operating Procedure's -
document with a unique version number. Per your email dated October 14, 2011 you committed
195 North .1950 West • Salt Lake City. IIT ,
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
t\\v\\'.(leq.utah.!foy
Printed on 100% recycled paper
Page 2
that DUSA would fully respond to this letter within 14 calendar days of receipt. If you have any
questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
F:\License\Move & Settle MonitorsVMovcment Monitor Cmt3 10-2011 .doc
m
25.