DRC-2011-004769 - 0901a0688022addd

MIMiS
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
May 4, 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
Tel : [phone]
Fax: [phone]
www.denisonmines.com
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 4, 2011 Regarding Settte^
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Settlement Monitoring SOP. This
letter also responds to DRC's letter of April 4, 2011, which we received on April 8, 2011 providing DRC's
proposed redlines and comments on the subject SOP. We have attached an edited redline copy of the SOP
in which DRC's proposed changes remain in violet-red and Denison's modifications or additional language
are indicated in other colors.
We have provided, below, specific responses to each request in UDEQ's April 4, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC April 4, 2011 letter. Each DRC request is shown
in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General. Some suggested red-line strike-out changes for the subject SOPs are attached. The majority
of these suggestions were derived from our review of the License Conditions. Please note that some
sections of the red-line strike-out copy of the subject SOPs may contain several changes which were
obtained from the numerous License Conditions.
Denison Response: The changes have been made with the additions or modifications as discussed below.
As mentioned above, where Denison has added or modified DRC's proposed language, the additional
changes are indicated in different colors than DRC's edits.
2. License Condition 11.7, first Daraaraph. states that "...The proposed SOP shall describe methods
for.. comparing such data to previous data to track potentiai settlement All data collected bythe
Licensee for these purposes shall be included in an annual report to be submitted to the Executive
Secretary, pursuant to License Condition 12.3..."
It appears that the subject submitted SOPs do not address this condition compM^
License Condition applies to more than error correction, but overall evaluation of vertical
N:\SOPs and Procedures\Settlement Monitor SOP and comments\Response to RFI and Settlement SOP final to DRC
05.03.11\05.04.11 ResponsetoDEQ04.04.11 RFISettlementSOP.doc
Letter to Mr. Rusty Lundberg
May 4, 2011
Page 2
movement of the Settlement Monitors. Please add detailed procedures to the subject SOPs to
address this license condition completely.
Denison Response: The change has been made as requested. Language has been added to Sections 1.5.1
and 1.6 to supply these details.
3. License Condition 11 7A directs DUSA in the subject SOPs to. "Require that settlement monitors (e.g..
settlement stands) be promptly installed following placement of temporary cover over placed tailings;"
It appears the submitted SOPs do not address this condition. Some red-line strike-out verbiage
is suggested in Section 1.2 ofthe subject SOPs to address this license condition. We request
DUSA propose a time, in place ofthe "XX calendar days" shown in this regard.
Denison Response: DRC's recommended changes have been made to Section 1.2 as requested.
4. License Condition 11.7D directs DUSA in the subject SOPs to, "Include provisions to prevent man-
caused damage to settlement monitoring devices, including, but not limited to vehicle and construction
traffic damage. Such measures will include: 1) all equipment, procedures, and provisions needed to
protect said settlement monitoring devices, 2) schedules for rapid verbal and written reporting of any
such damage, and 3) corrective actions taken or to be taken by the Licensee to replace and/or repair
said devices;"
It appears the submitted SOPs do not completely address this condition, as follows:
a. The design of the Settlement Monitors, provided in Section 1.3 of the subject SOPs, is
vague with respect to the design height ofthe 1-inch center pipe, and the height of the 3-
inch casing above the temporary cover The description is also vague regarding the height,
depth, spacing between and location of the barrier posts bounding the Settlement Monitors.
Drawings may be useful to address this comment.
Denison Response: Figure 1 has been added to the SOP to address these details.
b. The last phrase in License Condition 11.7D requires the SOPs to include, "corrective
actions taken or to be taken...to replace or repair said devices." This condition requires
corrective actions taken or to be taken to be in the SOPs. Some red-line strike-out
verbiage is suggested in the last paragraph in Section 1.3 of the subject SOPs for DUSA to
address this license condition. We request DUSA propose a time in place ofthe "XX
calendar days" shown in this regard.
Denison Response: DRC's recommended changes have been made to Section 1.3 as requested.
5. License Condition 11.7E directs DUSA in the subject SOPs to, "Indicate that.. .Review of the data and
an analysis shall be performed and certified by a Utah Licensed Professional Engineer and submitted
annually as part of the ATER required by License Condition 12.3;
Some red-line strike-out verbiage is suggested in the last paragraph in Section 1. 6 of the
subject SOPs for DUSA to improve the SOPs with respect to this license condition.
Denison Response: DRC's recommended changes have been made to Section 1.6 with some modifications
as indicate in blue.
OENiSO
MINES
Letter to Mr. Rusty Lundberg
May 4, 2011
Page 3
6. License Condition 11.7F directs DUSA in the subject SOPs to, "Include procedures requiring that such
settlement monitors be placed, surveyed, mapped, and maintained; that corrective action and
maintenance activities be performed to maintain existing monitoring devices in a reliable, good working
condition, as needed; that the addition, surveying and mapping of new settle^^
installed be documented; and that records be made of observations of site conditions as they relate to
the conditions at and in the vicinity of the installed monitoring devices;
It appears that the subject submitted SOPs does not address this condition CO
red-line strike-out verbiage is suggested in Sections 1.2, 1.3, and 1.6 of the subject SOPs to
address this license condition.
Denison Response: DRC's recommended changes have been made to Sections 1.2, 1.3 and 1.6 with some
modifications as indicate in blue.
7. License Condition 11.7G directs DUSA in the subject SOPs to, "Provide quantitative performance
criteria and describe how such criteria will be used to evaluate vertical movement;
It appears that the subject submitted SOPs does not address this condition completely. This
License Condition applies to more than error correction, but overall evaluation of vertical
movement of the Settlement Monitors. This License Condition is related to item 2 in this letter
Please add detailed procedures to the subject SOPs to address this license condition
completely.
Denison Response: The change has been made as requested. Language has been added to Sections 1.5.1
and 1.6 to supply these details.
8. License Condition 11.7H directs DUSA in the subject SOPs to, "Indicate that any settlement monitoring
device that is irreparably damaged as a result of environmental stresses or through man-caused
contact, including but not limited to cell construction or other operational equipment, shall be promptly
replaced with an identical or equivalent monitoring device; and provisions provicled to guide the
interpretation of data from both the former and the replacement device;
It appears thatthe subject SOPs Section 1.5.2 partially addresses of this License Condition.
However thissection is vague in its complete intent Please clarify the intent or revise this
section to address this License Condition.
Is it feasible to replace a damaged Settlement Monitor with a new device at the same
elevation? As part of this response, we request that DUSA include in these SOPs that a
permanent notation in the data will be provided to record the date of replacement ofany
Settlement Monitor
Denison Response: Denison will attempt to install replacement Settlement Monitors at the same elevation as
the damaged monitors; however, the elevation of the replacement devices cannot be assured. The
commitment to record the date of replacement has been added to Section 1.5.2 as requested.
9. License Condition 11.71 directs DUSA in the subject SOPs to, "Indicate that where survey evidence
suggests that significant apparent movement in a settlement monitor has occurred, in excess of the
approved performance criteria, that the departure(s) will be investigated and exp^^^^^^^
corrected and resolved in a timely manner, subject to Executive Secretary approval;
0ENISO
MINES
Letter to Mr. Rusty Lundberg
May 4, 2011
Page 4
It appears the submitted SOPs do not completely address this condition. Some red-line strike-
out verbiage is suggested in Section 1.6 of the subject SOPs to address this 11^^^
We request DUSA propose a time, in place of the "XX calendar days" shown in this regard.
Denison Response: The number of calendar days has been proposed in each location in the text as
requested.
10. License Condition 11.7K directs DUSA in the subject SOPs to, "Include a list of records that will be
prepared for documenting settlement data for each settlement monitoring device and related site
observations and activities..."
It appears that the subject submitted SOPs does not address this condition completely. Please
add a detailed list of records to the subject SOPs to address this license condition completely.
Denison Response: DRC's recommended changes have been made to Section 1.5.1 as requested.
11. License Condition 11.7L directs DUSA in the subject SOPs to, "Indicate that results and records of
settlement monitoring shall be submitted annually as part ofthe ATER required by License Condition
12.3.
It appears thatthe subject submitted SOPs maynot address this condition completely. Some
red-line strike-out verbiage is suggested in the subject SOPs to address this license condition.
Denison Response: A commitment to annual reporting has been made as requested.
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
Central files
MINES
White Mesa Mill - Standard Operating Procedures Date: 0454-1-/20110 Revision: DUSA-24-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page l of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010>, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer oil the latest DUSA Settlement Monitor
Points map foriginallv dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be iristalled
within XX60 calendar days of completion of the intermediate cover at the designated locations.
The Settlement Monitor Points map will be updated as part of the installation of new monitors.
As stated above. Settlement Monitors will be placed on the tailing cells when temporary cover is
being advanced on the placed tailings. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to ftirther disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually after that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
F:\WP\Division of Radiation Control\Denison Mines. DUSAVATER Annual Tech Eval ReportsVMovement & Settlement
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I For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
I 20110.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
turned in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and a corrective action plan will be created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of those
changes due to the Settlement Monitor damage will be completed within within 3 OXX calendar
days of the discovery of the damage to the Settlement Monitor.
1.4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surveyor") with the assistance of another Mill
worker (the "Assistant");
(ii) The survey will be performed using a survey instrument accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
F:\WP\Division of Radiation ControlVDenison Mines. DUSAVATER Annual Tech Eval ReportsVMovement & Settlement
MonitorsVSottlemont MonitorsVProp Settlemont Monit SOP Marlcup 03 2010.docC:VUsersVjtischler\DeslctopVSeotion 5 0
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Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(v) Once in location, the surveyor will ensure that the survey instrument is
level by centering the bubble in the level gauge on the survey instrument;
(vi) The assistant will place the survey rod vertically on the reference point.
The assistant will ensure that the survey rod is vertical by gently rocking
the rod back and forth until the surveyor has established a level reading;
(vii) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "reference point
reading"), which represents the number of feet the survey instrument is
reading above the reference point;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
I The Movement Settlement Monitors will be maintained so that the monuments remain in
reliable, good working condition. Conditions at and in the vicinity of the monitoring devices
will be inspected monthly by Environmental Department staff Any observations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
I surrounding the settlement monitor.
F:VWPVDiviGion of Radiation ControlVDenison Mines. DUSAVATER Annual Tech Eval ReportsVMovement & Settlement
MonitorsVSettlemont MonitorGVProp Settlement Monit SOP Marloip 03 2010.docC:VUsersVjtischlerVDesktopVSection 5 0
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20110 Revision: DUS A-24
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
The following records and documents will be maintained by the Environmental Department
staff:
a) Monthly tailings inspection forms
b) Data files of monthly and annual survey information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The
replacement device will be placed in the same location from which the damaged device was
removed. Data from the new device will be correlated to data from the removed damaged device
as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. Ifthe survey indicates there has been less than 0.1 foot of vertical change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
l:_If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adj acent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
3T4. If the elevation of the new device is greater than +/- 0.1 foot from that of the
damaged devicse. theri the replacement devicse will be designated with a new number
(such as "Cell 2W2-R". as the replacement for damaged devicse "Cell 2W2"). Elevation
data for the new devicse. and the date of instaiiation of the new device, will be recorded
in the data file adjacent to the information from the damaged devicse, with a notation that
this devicse is a replacemerit for the damaged devicse.
1.6 Performance Criteria and Data Validation
AVhen the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
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MonitorsVSottlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:VUsersVjtiGohlerVDesktopVSection 5 0
Settlement Monitoring SOP.doc
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Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
I difference of 0.1 foot between two consecutive months, then an investigation and possible the
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7XX days of discovery of the problem.T
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director statirig possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 3OXX calendar days for
approval a timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-steps taken, if needed. This report will be
also be maintained within the Environmental Department records and will be submitted
annually as part of the ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ ^^d-analyze, correct (as
needed) the data and theft-certify the annual data in writing—, iricluding an explanation of the
methods and basis used for the review, analysis, and corrections including ongoing graphical
updates for the Settlement Monitors. For movements attributed to expected settlement of the
tailings sands, the review will include comments on the graphical presentation of the data, and a:n
evaluation of the previous, current and expected rates of ongoing settlement.
^^\4H€h-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
F:VWPVDiviGion of Radiation ControlVDoniGon Mines. DUSAVATER Annual Tech Eval ReportoVMovement & Settlement
MonitorsVSettlomont MonitorsVProp Settlement Monit SOP Markup 03 20 lO.docCiVUsersVjtischlerVDeGlctopVSection 5 0
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUS A-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Aimual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010), within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor
Points map (originally dated 09/15/08). Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within 60 calendar days of completion of the intermediate cover at the designated locations. The
Settlement Monitor Points map will be updated as part of the installation of new monitors.
Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been
closed to fiirther disposal pursuant to RML condition 10.5.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of
each ISL disposal area, and then armually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feet or 5,000 cubic yards of ISL materiaL These
monuments will be uniquely labeled to identify the specific ISL material.
For ISL source disposal areas or trenches completed before April 1, 2011, the required settlement
stands will be placed and the initial elevation survey completed prior to June 1, 2011.
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other enviroimiental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director. Replacement and/or repairs to the damaged Settlement Monitor
and the surveying and documentation of changes due to the Settlement Monitor damage will be
completed within within 30 calendar days of the discovery of the damage to the Settlement
Monitor.
1.4 Monthly Surveying
(i) The monthly survey will be performed by the Mill's Radiation Safety
Officer or designee (the "Surveyor") with the assistance of another Mill
worker (the "Assistant");
(ii) The survey will be performed using a survey instrument accurate to 0.1
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
(v) Once in location, the surveyor will ensure that the survey instrument is
level by centering the bubble in the level gauge on the survey instrument;
(vi) The assistant will place the survey rod vertically on the reference point.
The assistant will ensure that the survey rod is vertical by gently rocking
the rod back and forth until the surveyor has established a level reading;
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 5
(vii) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "reference point
reading"), which represents the number of feet the survey instrument is
reading above the reference point;
(viii) The assistant will then move to a designated settlement monitor. Once at
the monitor, the assistant will remove the steel cap and place the survey
rod on top of the 1" inner pipe. A few of the original settlement monitors
do not have an inner pipe. For original settlement monitors without a 1"
inner pipe, the assistant will place the survey rod on the lip of the
settlement monitor;
(ix) The assistant will hold the rod vertically and will ensure the survey rod is
vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
(x) The surveyor will focus the cross hairs of the survey instrument on the
scale on the survey rod, and record the number (the "surface reading"),
which represents the number of feet the survey instrument is reading
above the settlement monitor.
The surveyor will calculate the elevation of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the surface
reading for the settlement monitor, and will record the number accurate to 0.1 feet. The
elevation information will be maintained within the Environmental Department records.
The monthly documentation of the readings will be recorded on the Monthly Tailings
Inspection Form. The form can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Settlement Monitors will be maintained so that the monuments remain in reliable, good
working condition. Conditions at and in the vicinity of the monitoring devices will be inspected
monthly by Environmental Department staff Any observations will be recorded on the monthly
tailings inspection report form.
On an annual basis, each monument will be photographed to document conditions at the
monitoring areas. Additionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
The following records and documents will be maintained by the Environmental Department
staff:
a) Monthly tailings inspection forms
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
b) Data files of monthly and annual survey information
c) Records of initial installation and survey data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions at each settlement monitor
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. The
replacement device will be placed in the same location from which the damaged device was
removed. Data from the new device will be correlated to data from the removed damaged device
as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the nearest (undamaged) devices on either
side of the new device.
2. Ifthe survey indicates there has been less than 0.1 foot of vertical change in the location
of the undamaged devices, no adjustment will be made to the survey data of the new
device.
3. Ifthe survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. Ifthe elevation of the new device is greater than +/- 0.1 foot from that of the damaged
device, then the replacement device will be designated with a new number (such as "Cell
2W2-R", as the replacement for damaged device "Cell 2W2"). Elevation data for the
new device, and the date of installation of the new device, will be recorded in the data file
adjacent to the information from the damaged device, with a notation that this device is a
replacement for the damaged device.
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7 days of discovery of the problem.
2 Document site conditions.
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 of 5
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses,
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30 calendar days for approval
and include in that notification the investigation steps, movement evaluation, and
corrective actions taken, if needed. This report will also be maintained within the
Environmental Department records and will be submitted annually as part of the ATER
as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as
needed) and certify the 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
Settlement Monitors. For movements attributed to expected settlement of the tailings sands, the
review will include coinments on the graphical presentation of the data, and an evaluation of the
previous, current and expected rates of ongoing settlement.
This information will be maintained within the Environmental Department records and will be
submitted annually as part of the ATER as required by RML Condition 12.3.
3"THR1ADEDM]PPLE
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r THREADED HPtCAP
r PIPE COUPLING
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r DIAMrniRRISEitP^
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(iostalled aioiiod 1" metp^ ia^ field)
E & COUPLINGS)
couniNo
WELDID to
BASE
FLAfE
MATERIALS
DESCRIPTION OUANTITY DIMENSION
1-SCH 40 COUPLING 2 EACH
1" SCH 40 I'HKMADED PIPE
BLACK) lEACH
3" SCH 40 THREADED CAP lEACH
3" SCH 40 THREADED
COUPLING lEACH
3" X 6" SCH 40 THREADED
NIPPLE lEACH
3" SCH 40 GUARD PIPE lEACH 3'4"
1/4" STEEL BASE PLATE lEACH 2*0" X 2*0"
1/4" STEEL BASEPLATE lEACH 6"X6"
NOTES;
1. ALL STEEL TO BE PAINTED WITH TWO COATS OF RED
EPOXY PAINT.
2. NO GALVANIZED PIPE OR PIPE FTTTINGS ARE TO BE USED
6" SQUARE 1/4" FLATS 2J"I»AMBTERHOLE
GUARI^raPBB^E
VLATBTXBtAIL
SCALE 3MV
SMALL BASE PLATE ATtACOSD
TO BAfflg (V GUAia>FIPe
3" umiem. GOAim mvm
ATIAC^D TO THE BAS FLATS
Denison Mines (USA) Corp DENISOIJ!^ J
MINES
REVISIONS Project: White Mesa Mill
Date By County: SanJuan | UT
05-11 GM Location:
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
Author yMKNOWN Drafted By: 09-14-98