DRC-2011-007808 - 0901a068802a7670

State of Utah
GARY R. HERBERT
Governor
GREG BE:
Lieutenant Go
Department of
Environmental Quality
Amanda Smith
Executive Director
DrVlSION OF RADIATION CONTROL
Rusty Lundberg
Director
FILE
DRC-20W007624
2011-007808
October 13,2011
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
Deaf Ms. Tischler:
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RE: contingent SOP Approval / DR
Se
Jo Ann Tischler
Denison Mines (USA) Corp
sti 1050 Seventeenth ST, STE 950
J Denver, Co 80265
Cit
PS Form 3800. August 2006 See Reverse for Instructions
SUBJECT: June 21, 2011 DUSA Response and Transmittal Letter regarding DRC Comment Letter of
. June 2, 2011: Settlement Monitoring Standard Operating Procedures [SOPs] 06/2011
Revision: DUSA-2; December 1, 2010 DUSA Original Transmittal Letter for Three
Separate Draft SOPs; Contingent SOP Approval
We have received the subject June 21, 2011 DUSA response letter, which transmits the subject proposed
DUSA Settlement Monitoring Standard Operating Procedures [SOPs] 06/2011 Revision: DUSA-2, in
response to the DRC comment letter of June 2, 2011.
We have reviewed this information, and approve the subject SOP with a stipulation that Figure 1,
referenced in Section 1.3 ofthe subject SOP, refers to the attached drawing titled Settlement Monitor
Fabrication last revised by DUSA on 05-11. This drawing was submitted earlier by DUSA in a transmittal
on the subject dated May 4, 2011. This drawing must be included by DUSA with all copies of this SOP.
If you have any questions on the above, please contact Mr. Rupp of DRC.
UTAH RADIATION CONTROL BOARD
Rusty Lundberg, Executive Secretary
RL:DAR:dr
Attachment: Referenced Drawing
F:\License\Move.& Settle Monitors\Settlement Monitor SOP Approval.doc
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.uiah.f>ov
• Printed on 100% recycled paper
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3" SCH 40 GUARD PIPE 1 BACH 3*4"
1/4" ffTEEL BASE PLATE lEACH
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MOTES:
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Denison Mines (USA) Corp DENISONOJ Jl
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SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
SETTLEMENT MONITOR
FABRICATION
FIGURE 1
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1. Article Addressed to:
S SECTION ON DELIVERY
RE: contingent SOP Approval / DR
Jo Ann Tischler
Denisoh Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
A. Received by (Please Print Clearly) B. Q.ate pf Delivery
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PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
jJepartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
June 2, 2011
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:
SUBJECT: May 4, 2011 DUSA ResponseLettertoDRCLetter of April 4, 2011; December 1, 2010
DUSA Transmittal Letter for Three Separate Draft SOP's; Settlement Monitoring Standard
Opera/mg Procei/ur^i [SOPs] 045/2011 Revision: DUSA-2; Request for Information •
We have received the subject May 4, 2011 DUSA response letter, which transmits the proposed DUSA
Settlement Monitoring Standard Operating Procedures [SOPs] 045/2011 Revision: DUSA-2, in response
to the subject DRC comment letter of April 4, 201L We have reviewed this information, and have the
following comments. Our current comments use the same numerical order as the original comments in our
letter of April 4, 2011:
1. No further comment.
2. No further comment.
3. No further comment. ^ ^
4. Figure 1, a drawing titled Settlement Monitor Fabrication originally dated 09-14-96 and last
revised 05-11, was provided by DUSA to support the description of the design of the Settlement
Monitors found in Section 1.3 of the subject SOPs.
5. No further comment.
6. No further comment.
7. No further comment
8. As previously slated and requested in our letter of April 4, 2011, Section 1.5.2 in the subject SOPs
is vague in its intent and needed clarifying. After some revision by DUSA, this section still seems
rather complex and unclear. To help clarify the apparent intent of this section, some additional
red-line strike-out verbiage attached, is suggested for Section 1.5.2.
9. No further comment.
195 North 1950 West • Salt Lake City. UT
Mailing Address: P O. Box 144850 • Sah Lake City, UT 84114-4850
Telephone [phone] • Fax (80J) 533-4097 • T.D.D. [phone]
www.deq.Utah.grrv
Primed on 100% recycled piiper
Page 2
10. Per License Condition 11.7K, we requested that the subject SOPs, "Include a list of records that
will be prepared for documenting settlement data for each settlement monitoring device and related
site observations and activities..." In this regard, we request that the annual report of the
Settlement Monitor data by a Utah Licensed Professional Engineer, as described in Section 1.6, be
added to the list of records of documents shown in Section 1.5.1 of the subject SOPs.
11- Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage for the subject
SOPs to provide that results and records of settlement monitoring be submitted annually as part of
the ATER. It appears the addition of the word "submit" to Section 1.6 is appropriate in this regard.
This addition is suggested as attached, in the red-line strike-out verbiage for Section 1.6, in the
second to last paragraph of that section.
Please review the above comments, and respond in writing, submitting an appropriately revised Settlement
Monitoring Standard Operating Procedures document, with a unique version number, for Executive
Secretary approval. Per my email of May 31, 2011, you committed that DUSA would fully respond to this
letter within 30 calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E-
Geotechnical Services Section
DAR:dr
Attachment:
Red-line strike-out copy of the subject SOPs (including latest DRC Comments) labeled at the top as [Prop
Cmt2 SMSOP markups June 2011]
F:\License\Move & Settle MonitorsNSettlement Monitor Cmt2 June 2011 .doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 5
fProp Cmt2 SMSOP markups June 20111
SETTLEMENT MONITORING
STANDARD OPERATING PROCEDURES
1. SETTLEMENT MONITORING
1.1 Purpose
This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement
Monitors that are placed within the tailings management cell areas. This SOP will also indicate
how and where to document the findings. All data collected for these purposes, as described
below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmenlal 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 Momtor_, - - \ formatted; Font: italic
Poirtts 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,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 cellc when temporary cover is
being advanced on the-placed 4ailings. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to further disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually after that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
^r'.WP'.Dis ision of-ftadiQiion ContronDiamr.en Min«. DUSAVATER Annual Tech Eval RopQri.r\Mo\cmcnl & Setllemenl
Moni(ofr'iSettl<?mont MoniiorcVProp Sottlofnonc Monit SOR Morliup OJ 20IO.docC:\Uoorg\iiioohler\PeGklop\Seoiion 5-0
Settlement Monitoring SOP.doo
\ • • •
White Mesa Mill - Standard Operating Procedures Date: 045-44/20119 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5 0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation suiA'cy completed prior to June 1,
20110.
\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" imier 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 I detailing the construction of the Settlement Monitors,
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and n cnrrectivp actinn plnn will hn created for rReplacement
and/or repairs to the damaged Settlement Monitor and the surveying and documentation of these
changes due to the Settlement Monitor damage will be completed within within 30^0^ 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 O.l
feet, such as a Sokkai No. B21, or equivalent, together with a survey rod
having a visible scale in 0.1 foot increments;
(iii) The reference points are known points established by a professional
survey.
(iv) The surveyor will set up the survey instrument in a location where both
the applicable reference point and settlement monitor are visible.
F;'-,WP\Di\ision ol Radiotion ConiroI\Deni.wn Miiieu. DDSA'iAT-bfr Annual Tech Evol Ropono\Movement & Scitleiiu-ni
NUiniiorr.'Sonlcnn.Tt MoniioR-.'.faip Sftllcmuni Monit SOP Markup 03 20IO.dot;C:vL'i;ci.nviiischlci Dcsktop\Si3Clion 5 0
Sultlemem Moniiuriny SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 045-14/20Revision: DUSA-24
Book #M: Envirorunental 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 leyel 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 forth can be found in Section 3.1 of the Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Movement Settlement Monitors will be maintained so that the monuments rernain 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.
F:'.WP'.Division-orRadiation C ontrol'Penif-on Mineii. DUSAVXTER Annual Toch &. al Rcports'.Movcmcnt & Sottj«w«H
Moniiorg'.Settlement Monitorr-'-Prop Scttloment Monit SOP Mofkuip 0-3-2Cll0.docC:\UsergViii9chlot'.Do5litcip'.Scoiion 5 0
Sonlomcnt Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures
Book #11: Environmental Protection Manual, SOP Section 5.0
Date: 045-44.^201 \Q Revision: DUSA-24
Page 4 of 5
The following records and documents will be maintained bv the Environmental Department
staff:
a) Monthly tailings inspection forms
b) Data files of monthly and annual survey infonnation
c) Records of initial installation and suivev data
d) Records of maintenance, damage, and/or replacement of settlement monitors
e) Annual photographs documenting site conditions al each settlement monitor
Formatted: Outline numbered +
Level: 5 + Numbering Style: a, b, c,
... -f Start at: 1 + Alignment; Left -•-
Aligned at: 0.5" + Tab after. 0.75"
•f Indent at: 0.5"
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of envirormiental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent .device.
Based on the last monthly survey, prior to the damage. tThe replacement device will be placed as
near as practical at the same elevation and in the same location from which the damaged device
was removed. Data from the new device will be correlated to data froni the removed damaged
device as follows:
3.
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the two nearest (undamaged) devices
adjacent to on either side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change since the last
montly survey in the elevation location of the undamaged devices, no adjustment will be
made to the survey data of the new device.
If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
3:4. Also, based on the last monthly survey, prior to the damage, Iif the elevation of-
the new device is greater than +/- 0.1 foot from that of the damaged devic^e. then the
replacement devictre 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 installation 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 replacement
for the damaged devicse.
Formatted: List Paragraph, Left, No
bullets or numbering
•f Formatted; Bullets and Numbering
F:\WT\Di T| Radiation ConiroriDtfnis
Monitori-.'SeHk
DLiSA'ATER Annual Toch Eval Rcpons'.Movemont & Seitlemem
Senlomoni Monitoring SOP.doc
\Prop Settlement Monit SOP Markup 03 2010.docr: iJ!.-.OTnMtir.chlor'.PL'f.l.top'.Soction 5 0
White Mesa Mill - Standard Operating Procedures
Book #11: Enviromnental Protection Manual, SOP Section 5.0
Date: 04544-/20110 Revision: DUSA-2+
Page 5 of 5
1.6 Performance Criteria and Data Validation
When the monthly data has been collected, the information will be reviewed for any errors
and/or major changes in the vertical movement on the settlement monitors. "^If there is a
difference of 0.1 foot between two consecutive months, then an investigation and possible the
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical, movement of O.i foot or more,
within 7j^ 'days of discovery of the problem.?
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible .causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses, w
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30XX calendar days for
approval a - timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-$teps 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^ aad-analvze. correct (as
needed), ^submit the data and^^en-certify the annua[ data in wrhing—. 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 comments on the graphical presentation ofthe data,
and an evaluation of the previous, cun ent and expected rates of ongoing settlement.
whiefe-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.
Formatted; Font color: Plum
F:\WP\Di if Radiation Contrttl'vDeni!; DUSA'v\TER Annuoi Toch Eval RoportsVMo^ cmoni & Soitkwwm
Monitofs\Soltlomcni Monitor.';\Prop Sottlcmoni Monit SOP MorkupO? 20IO.docC:MJDcrs\itHK;hlor'.Doslitop\Socti<
Scttlcmont-Monitorint; SOP.doc
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a (E, SUBJECT: MAY 4^ 2011 / DR
S Ms. Jo Ann Tischler , : ;
Director, Compliahpeai^sP^W
Denison Mines (USA) Corp, (pUSAj
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P S; F o rm.3300.'. Au q ii r. I :!0Or. rsc for iicliaii
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
jLv-epartment of
Environmental Quality
Amanda Smith
Executive Director
DP/ISION OF RADIATION CONTROL
Rusty Lundberg
Director
April 4, 2011
CERTIFIED MAIL r
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: December 1, 2010 Transmittal Letter for Three Separate Draft SOP's; Settlement
Monitoring Standard Operating Procedures [SOPs] 11/2010 Revision: DUSA-1;
Comments and Request for Information
I • • -
We have received the subject December 1, 2010 letter which transmitted three separate Standard Operating
Procedures (SOPs). The subject of this letter is our review of one of the SOPs, i.e. the Settlement
Monitoring Standard Operating Procedures [SOPs]. DRC review of the other transmitted SOPs will be
discussed in separate letters. The subject SOPs were subniitted by DUSA to comply with the requirements
of License Condition 11.7. We have reviewed this item, and have the following comments:
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 ofthe 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.
License Condition 11.7, first paragraph, states that, ".. .The proposed SOP shall describe methods
for.. .comparing such data to previous data to track potential settlement. All data collected by the
Licensee for these purposes shall be included in an annual report to be submitted to the Executive
Secretary, pursuant to License Condition 12.3..."
DRC Findings: It appears that the subject submitted SOPs do not address this condition
completely. License Condition 11.7 applies to more than error correction, but overall
evaluation of vertical movement of the Settlement Monitors. Please add detailed
procedures to the subject SOPs to address this license condition completely.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City. UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.aov
Printed on 100% recycled paper
Page 4
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 of the ATER required by License
Condition 12.3."
DRC Findings: It appears that the subject submitted SOPs may not address this condition
completely. Some red-line strike-out verbiage attached is suggested in the subject SOPs to
address this license condition. Please revise the SOP in this regard.
Please review the above comments, and respond in writing, submitting an appropriately revised Settlement
Monitoring Standard Operating Procedures document with a unique version number. Per our telephone
conversation on March 31, 2011 you conmiitted that DUSA would fully respond to this letter within 30
calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:dr
Attachment: Red-line strike-out copy of the subject SOPs (DRC Comments)
F:\LicenseVMove & Settle Monitors\Settlement Monitor Cmtl April 2011.doc
C-Zolo-ls-i-
DENISO
MINES
June 21, 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
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denlsonmines.com
Re: State of Utah Groundwater Discharge Pernriit
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") request for Information of June 2, 2011 Regarding Settlement Monitoring
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the Settlehient Monitoring SOP. This
letter also responds to DRC's letter of June 2, 2011, which we received on June 6, 2011 providing DRC's
proposed redlines and comments on the subject SOP. W have attached an edited redline copy ofthe SOP
in which DRC's proposed changes reniain in vioiet-red arid Denison's modifications or additional language
are indicated in other colors.
We have provided, below, specific responses to each request in UDEQ's June 2, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC June 2, 2011 letter. Each DRC request is shown
in italics, below, followed by Denison's response.
DRC Comments and Responses ;
1. No further comment.
Denison Response: No response required:
2 No furttier comment
Denison Response: No response required.
3. No further comment
Denison Response: No response required.
4. Figure 1, a drawing titled Settlement Monitor Fabrication originally dated 09-1.4-96 and last revised 05-
11, was provided by DUSA to support the description ofthe design of the Settlement Monitors found in
Section 1. 3 of the subject SOPs. .
Denison Response: No response required.
N:\SOPs and ProceduresVSettlerhent Monitor SOP and comments\Response to RFI and Settlement SOP to DRC
06.21.11\06.21.11 Response to DEQ 06.02.11 RFI Settlement SOP.doc
Letter to Mr. Rusty Lundberg
June 21, 2011
Page 2
5. No further comment
Denison Response: No response required.
6. No further comment
Denison Response: No response required.
7. No further comment
Denison Response: No response required.
8. >As previously stated and requested in our letter of April 4,2011, Section 1.5.2 in the subject SOPs is
vague in its intent and needed clarifying. After some revision by DUSA, this section still seems rather
complex and unclean To help clarify the apparent intent of this section, some additional red-line strike-
out verbiage attached, is suggested for Section 1.5.2.
Denison Response: The change has been accepted as proposed.
9. No further comment
Denison Response: No response required.
10. Per License Condition 11.7K, we requested that the subject SOPs, "Include a list of records that will be
prepared for documenting settlement data for each settlement monitoring device and related site
obsen/ations and activities..." In this regard, we request that the annual review of the Settlement
Monitors by a Utah Licensed Professional Engineer be added to the list of records of documents shown
in Section 1.5.1 ofthe subject SOPs.
Denison Response: The change has been made as requested. The review by the Utah-Licensed Professional
Engineer has been added to the list of documents in Section 1.5.1.
11. Per License Condition 11.7L, in our letter of April 4, 2011, we suggested verbiage for the subject SOPs
to provide that results and records of settlement monitoring be submitted annually as part ofthe ATER.
It appears the addition ofthe word "submit" to Section 1.6 is appropriate in this regard. This addition is
suggested as attached, in the red-line strike-out verbiage for Section 1.6, in the second to last
paragraph of that section.
Denison Response: The change has been accepted as proposed.
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
DENISO
MINES
Letter to Mr/Rtisty Lundber-q
June 21, 2011 ^
Pages
cc: PavidC./Frydenlund
Harold R.; Roberts
David E. Turk
K. Weinel
Central files f
Attachment
•ii-'is-i^:
•••^•;-^>-''i'
DENISO
^ MINES
White Mesa Mill - Standard Operating Procedures Date: 046W-/20 HO Revision: DUSA-2-1-
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 yertical 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 Eyaluation 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 MilLEngineer on the latest DUSA Settlement Monitor
Points map (originally dated 09/15/081 Settlement Monitors will be placed on the tailings cells
as the intermediate cover is advanced over tailings. New Settlement Monitors will be installed
within XX60 calendar days of completion Uf the intermediate cover at the desigriated 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 further disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then aimually 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 ControlVDenison Mines. DUSA\ATER Annual teoh Eva] ReportD\Movoment & Settlement
MonitorsVSettiement MonitorsVProp Settlement Monit SOP Marltup 03 2010.docC:\Usero\itisohler\Desktop\Section 5 0
Settlement Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures Date: 046H-/20 HO Revision: DUSAT2-4-
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate aiid 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 casiiig will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director^ and a oorreotivc acfion 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 30XX calendar
days of the discovery ofthe 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 Teoh Eval ReportsVMovement & Settlement
MonitorsVSettlement MonitorsVProp Settlement Monit SOP Markup 03 2010.docC:VUGer5VjtisohlerVDesktopVSeotion 5 0
Settlement Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures Date: 046^4-/20110 Revision: DUSA-2+
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 rodj 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 I" 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 instrumetit 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 elevafion of the settlement monitor by adding the
reference point reading to the reference point elevation and then subtracting the sttrface
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 Protecfion
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
The Movcmont 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. Addifionally, photographs will be taken following any instances of unusually
severe weather or incidents involving equipment if they result in physical damage or disturbance
to any settlement monitoring device, or significant changes to the ground areas adjacent to or
surrounding the settlement monitor.
F:VWPVDivision of Radiation ControlVDenison Mines. DUSAVATER Annual Tech Eval ReportsVMovemont & Settlement
MonitorsVSettiemont MonitorsVProp Settlement Monit SOP Marlcup 03 2010.docC:VUscrsVitiGohlerVDo5lctopVSeotion 5 0
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04644-/20110 Revision: DUSA-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
f) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device.
Based oh the last monthly survey, prior to the damage. tThe replacement device will be placed as
near as practical at the same elevation and in the same location from which the damaged device
was removed. Data from the new device will be correlated to data from the removed damaged
device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the two nearest (undamaged) devices
adjacent to oii either side of the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change since the last
monthly survey in the elevation location of the undamaged devices, no adjustment will be
made to the survey data of the new device.
3. If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
Also, based on the last monthly survey, prior to the damage, lif thie elevation of
the new device is greater than +/- 0.1 foot from that of the damaged devicse. then the
replacement devicse will be designated with a new number (such as "Cell 2W2-R". as the
replacement for damaged devicse "Cell 2W2"). Elevation data for the new devicse. and
the date of installation 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 replacement
for the damaged devicse.
F:VWPVDivisioh of Radiation ControlVDenison Mines. DUSAVATER Annual Tech Evol ReportsVMovement & Settlement
MonitorsVSettiement MonitorsVProp Settlement Monit SOP Marltup 03 2010.dooC:VUsersVitischlerVDesktopVSection 5 6
Settlement Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures Date: 04644/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page5ofi5
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 the
corrective actions will be taken as follows:
1 Resurvey the settlement monitor that shows vertical movement of 0.1 foot or more,
within 7?9^ days of discovery of the problem.T
2 Document site condifions.
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, OF
burrowing animals, etc.).
4 Report this informafion to the Executive Secretary within 30XX calendar days for
approval a timely mariner and iriclude in that notification the invesfigation steps,
movement eyaluation, 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^ md-analyze. correct (as
needed), submit the dota and then-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
ofthe tailings sands, the review will include comments on the graphical presentation of the data,
and an evaluafion of the previous, current and expected rates of ongoing settlement.
whieh-This information will be riiaintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
r:VWPVDivision of Radiation ControlVDemson Mines. DUSAVATER Annual Teoh Eval ReportsVMovomont & Settlement
MonitorsVSettiement MonitorsVProp Settlement Monit SOP Markup 03 2010.dooC:VU[sorsVjtisohlerVDosktopVSeotion 5 0
Sottlement Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-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 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
Sui^eyor.
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 further disposal pursuant to RML condition 10.5.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of
each ISL disposal area, and then annually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These
monuments will be imiquely 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: 06/2011 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 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 vithin two feet of the groimd 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 v^ll be docimiented and immediately
tumed in to the RSO, or designee. The RSO, or designee, v^U 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: 06/2011 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 wdll 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 mil 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 Envirormiental Department
staff:
a) Monthly tailings inspection forms
White Mesa Mill - Standard Operating Procedures Date: 06/2011 Revision: DUSA-2
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
b) Data files of monthly and aimual 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
f) Annual Review of Settlement Monitors by Utah Licensed Professional Engineer
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device.
Based on the last monthly survey, prior to the damage, the replacement device will be placed as
near as practical at the same elevation and in the same location fi'om which the damaged device
was removed. Data from the new device will be correlated to data from the removed damaged
device as follows:
1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the
location of the new device as well as that of the two nearest (undamaged) devices
adjacent to the new device.
2. If the survey indicates there has been less than 0.1 foot of vertical change since the last
monthly survey in the elevation of the undamaged devices, no adjustment will be made to
the survey data of the new device.
3. If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. Also, based on the last monthly survey, prior to the damage, if the 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:
bate: 06/2011 Revision: DUSA-2
^ilte Mesa Mill - Standard Operating Procedures
Book #11. Environmental Protection Manual, SOP Section 5 0
Page 5 of5
Document site conditions
burrowing animTete ) ^ "^'^^ envtonmental stresses,
corrective actions taken ff^^J ' mvestigation steps, movement evaluation, and
Environmental Dep« reTo^^^^^^^ "e matoained within the
asrequiredbyRI^KdtirnS """^
and basis used for the re^w aTyS td '^ZT'' '"V^^ an explanation of the methods
the Settlement Monitors For^Z '^t^^. T' «='"dmg ongoing graphical updates for
the review will include coirsrth™v"f ° ^'"'"'^«^ ^^'4 sands,
thep..vious,cun.ntand^::Sr:iSS~
VN - Dec- 20*' r 476^*7
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
OENISONTI/JJ -r"~"'
AAINES Tel: [phone]
Fax: [phone]
www.denisonmines.com
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
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 Settlement Monitoring
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 ofthe 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 ofthe red-line strike-out copy ofthe 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 paragraph, states that, "... The proposed SOP shall describe methods
for.. .comparing such data to previous data to track potential settlement All data collected by the
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 completely. This
License Condition applies to more than error correction, but overall evaluation of vertical
N:\SOPs and Procedures\Settlement Monitor SOP and commentsVResponse to RFI and Settlement SOP final to DRC
05.03.11\Q5.04.11 Response to DEQ 04.04.11 RFI SettlementSOP.doc
Letter to Mr. Rusty Lundbt
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 of the 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 ofany
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 ofthe subject SOPs, is
vague with respect to the design height ofthe 1-inch center pipe, and the height ofthe 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 of the "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 ofthe data and
an analysis shall be performed and certified by a Utah Licensed Professional Engineer and submitted
annually as part ofthe 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.
DENISO
MINES Mi
Letter to Mr. Rusty Lundberv^
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 settlement monitoring devices
installed be documented; and that records be made of observations of site conditions as they relate to
the conditions at and in the vicinity ofthe installed monitoring devices;
It appears that the subject submitted SOPs does not address this condition completely. Some
red-line strike-out verbiage is suggested in Sections 1.2, 1.3, and 1.6 ofthe 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 provided to guide the
interpretation of data from both the former and the replacement device;
It appears that the subject SOPs Section 1.5.2 partially addresses of this License Condition.
However this section 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 ofthe
approved performance criteria, that the departure(s) will be investigated and explained, and errors
corrected and resolved in a timely manner, subject to Executive Secretary approval;
DENISONOi
MINES
Letter to Mr. Rusty Lundbe.
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 license condition.
We request DUSA propose a time, in place ofthe "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 that the subject submitted SOPs may not 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
DENISO
MINES Mi
W-'hite Mesa Mill - Standard Operating Procedures Date: 2^14/20n0 Revision; DIJSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 ol'S
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 Eyaluation Report (ATER) to be submitted to the
Executiye Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 ofthe Radioactive Materials License (RML).
I
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 pn the latisst DUSA Settlement Monitor
Points map (ioriginallv 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
wWm calendar davs of completion of the intermediate cQver at the designated locations.
The Settlement Monitor Pointe map wil l be updated as j^it of the installation of new monitors.
Aa fltatod abeve^ Settlement Monitors will be placed on tho totting oella when temporary eovfer la
being ttdvanoed on-the placed-tatiingo. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to further disposal pursuant to RML condition
10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor
within 30 days of the completion of each ISL disposal area, and then annually after that point.
One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000
cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific
ISL material.
Settlement Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures
Book #11; tinvironmental Protection Manual, SOP Section 5,0
Date: 04544720 M6 Revision: DUSA-2+
Page 2 of5
For ISL source disposal areas or trenches completed before April 1, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the atteched 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^ ond a •oorFOotiv& ae^ft-plflft-wiH-be orcatad-for rReplaf^ment
and/or repairs to tiie damaged Settlement Monitor and the surveying and documentation of ttiese
changes due to die Settlement Monitor damage will be completed within within,lOXX talMtcter
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.
Settlement Monitoring SOP.doo
I White Mesa Mill - Standard Operating Procedures Date: fi^44/20 UO Revision: DUSA-24-
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
yertical 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 lo 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 ofthe Environmental Protection
Manual.
1.5 Monitoring and Maintenance of Settlement Monitors
1.5.1 Monitoring and Documentation of Condition of Devices
I The Movomcnt 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 obseiyations will be
recorded on the monthly tailings inspection report form.
On an annual basis, each monument will be photographed to documetit 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.
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: 04544/20 UQ Revision: DUSA-24-
Bpok #11; Environmental Protection Manual, SOP Section 5.0 Page 4 of 5
The following records and documents will be maintained bv the Environmental Department
staff:
a) Monthly tailings inspection forms
Data files of monthly and annual survey information
Records of initial instal latton and survey dafei
d) Records of maintenance, dapiage^ and/or replacement oFsettlement monitors
el Annual photographs documendng site conditioris 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. If the 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.
1, If the survey indicated 0.1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
M= If the elevation of the new device ts greater than +A OJ foot from th^ of the
damaged devicse. then the replacement device vyill be designated with a new number
(such as '^ell 2W2-R". as the replacement for damaged devicse **Cell 2W2^^. Elevattoii
data for Uie new devicse. and the date of installatipn ofthe new device, will be nscorded
in the data file adjacent to the iaformation from the damaged devicse. witii a noMion that
this devicse Is a replacement for the damaged ^eviose^
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
FAWPVDiviaion of Radiotion GentratyB^Bseff-Mmoar DUS AVVTER Anm Taoli Eval ftooortnVMovomenlA Settlemavt
Settlement Monitoring SOP.doc
White Mesa Mill - Standard Operating Procedures Date: Q4S44/20110 Revision: DUSA-2+
Book #11: Environmental Protection Manual, SOP Section 5.0 Page 5 qf 5
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 ofthe problem.T
2 Document site conditions.
3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e.
expected settlement of l^e tailings sands„ man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Executive Secretary within iOiQi calendar davs for
approval o timely manner and include in that notification the investigation steps,
movement evaluation, and corrective actions-ate|» taken. If needed. This report will be
also be maintained within the Envin>nfnent_al Department recordj^ and will be submitted
annually as part of the ATBR as it?quired by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ aad-analyze, correct (as
needed) the diata< and then-certify the annual data in writingrrr-. 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 exp^ted settlement of the
tailings sands, the mvlew will Include comments on the graphical pn^seritatlon of the data, and an
evaiuatton of the previous, current at^d expected rates of ongoing settlement.
whieh-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
Sottloment Monitoring SOP.doo
White Mesa Mill - Standard Operating Procedures Date: 05/2011 Revision: DUSA-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 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
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 Jime, 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 further disposal pursuant to RML condition 10.5.A. Settlement monitors will be
installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of
each ISL disposal area, and then annually after that point. One Settlement Monitor will be
required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These
monuments will be uniquely labeled to identify the specific ISL material.
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 Jime 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 enviromnental factors.
The design is a 2'x2' steel plate with a I" steel pipe welded tb 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 fi'om accidentally coming in
contact Avith 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 tiie 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" irmer 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 vdll 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. If the 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. If the survey indicated 0,1 foot or greater of vertical change to either of the undamaged
devices, the survey results for the new device will be adjusted by the average change
observed in the two adjacent devices. This adjustment will be documented in the Utah-
Licensed Land Surveyors report and in the annual ATER.
4. If the 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 ft"om 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 wall 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 tailmgs 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 ^n annual basis, a Utah Licensed Professional Engineer shall review, analyze, correct (as
needed) and certify the annual data in writing, including an explanation ofthe 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 an evaluation ofthe
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" THREADED NIPPLE
E& COUPLINGS)
3" THREADED PIPE CAP
rPIPECOUPUNO
3*FIPEC0UPLJN0
1" DIAMETER RISER PIPE
3" DIAMETER GUARD PIPE
(iogtaOed aroood r riser pqw in the field)
2'
1/4'SIEEL
BASE PLATS 2'
XrMIN.
MATERIALS
DESCRIPTION OUANTITY DIMENSION
r SCH 40 COUPLING 2EACH
V SCH 40 THREADED FIFE
(BLACK) lEACH 5V
3" SCH 40IHREAMD CAP lEACH
3" SCH 40 THREADED
rrtfiPtiNO 1 EACH
rX6^SCH40 THREADED
Nn»i»i.E lEACH
3" SCH 40 GUARD PIPE IBACH 3*4"
1/4" STBEL BASE PLATE lEACH itrx TV
1/4" STEEL BASE PLATE lEACH 6"X6"
NOTES:
1. ALL STEEL TO BE PAINTED WITH TWO COATS OF RED
EPOXY PAINT.
2. NO GALVANIZED PIPE OR FIFE FrmNOS ARB TO BB USED
(•SQUAKBIM'TtAlB -\ , ZS"IMAMBTSitHXXA
r- 3"
aUARDrffBBASB RAIBDBIAIL
SMALL BASS VLAII ATTACHED TOBAfflOf OUARDFIFB
3* nMMnn GUAJtD nn MOT
ATTACHBO TO IHB BAH FLATS
Denison Mines (USA) Corp oEUiSOtK^di
MINES
REVBiONS White Mesa Mill
Oate
05-11 GM
SETTLEMENT MONITOR
FABRICAnON
FIGURE 1
UNKNOWN |Oni««IB>:j^ 09-M-98
White Mesa Mill - Standard Operating Procedures Date: 04544/20110 Revision: DUS A-24-
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 Annual Technical Evaluation Report (ATER) to be submitted to the
Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary)
pursuant to License Condition 12.3 of the Radioactive Materials License (RML).
1.2 Locations and Frequency of Monitoring
Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly
basis by the Environmental Department staff and annually by a Utah Licensed Professional Land
Surveyor.
For any new Settlement Monitor installed (after June, 2010)-, within 30 days of the installation, a
Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement
Monitors will be pre-designated by the Mill Engineer on the latest DUSA Settlement Monitor , ^ - \ Formatted: Font: italic
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 XX60 calendar davs 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 bo placed on the tailing cells when temporar>^ cover is
being advanced on the placed tailings. Settlement Monitors are also required on In-situ leach
(ISL) source disposal areas that have been closed to 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 aimually 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.
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For ISL source disposal areas or trenches completed before April I, 20110, the required
settlement stands will be placed and the initial elevation survey completed prior to June 1,
20110.
1.3 Design of Settlement Monitors
Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing
animals and other environmental factors.
The design is a 2'x2' steel plate with a 1" steel pipe welded to the center of the plate. This steel
plate will be positioned by digging straight down in the desired location until tailing sands are
contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of
the sands. The hole will then be backfilled to within two feet of the ground surface. At this
point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been
completed, the last two feet of material will be backfilled. The top of the 3" casing will be
threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps,
lubricated on an as needed basis, to allow the cap to be removed during the survey process. See
the attached Figure 1 detailing the construction of the Settlement Monitors.
In order to protect the settlement monitors from man-caused damage, each settlement will be
bounded on three sides. This bounding will prevent equipment from accidentally coming in
contact with the settlement monitor. These devices will consist of three 3" steel pipes that will
be cemented into the ground. The interior of the pipe will also be filled with concrete. The
barriers will then be painted red as a visual reminder.
If damage, by any source, has occurred, the information will be documented and immediately
tumed in to the RSO, or designee. The RSO, or designee, will make same day notification to the
Corporate Compliance Director, and a corrective action plan will bo 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 30XX calendar
days ofthe 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.
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(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 Mo\^emont 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.
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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
Formatted: Outline numbered +
Level: 5 + Numbering Style: a, b, c,
... + Start at: 1 + Alignment: Left +
Aligned at: 0.5" + Tab after: 0.75"
+ Indent at: 0.5"
1.5.2 Maintenance of Monitors
If any settlement monitoring device is irreparably damaged as a result of environmental stresses
or man-caused contact, it will be promptly replaced with an identical or equivalent device. 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. If the 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. If the survey indicated O.l 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.
• -
iA If the elevation of the new device is greater than +/- O.l foot from that of the^
damaged devicse. then the replacement devicse will be designated with a new number
(such as "Cell 2W2-R". as the replacement for damaged devicse "Cell 2W2"). Elevation
data for the new devicse. and the date of installation 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 replacement for the damaged devicse.
Formatted: List Paragraph, Left, No
bullets or numbering
Formatted: Bullets and Numbering
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
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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 stating possible causes (i.e.
expected settlement of the tailings sands, man-caused contact, environmental stresses, er
burrowing animals, etc.).
4 Report this information to the Executive Secretary within 30XX calendar 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 he
also be maintained within the Environmental Department records and will be submitted
annually as part of the ATER as required by RML Condition 12.3.
On an annual basis, a Utah Licensed Professional Engineer shall review^ ^id-analvze, correct (as
needed) the data and tiiea-certify the annual data in writing—, including an explanation of the
methods and basis used for the review, analvsis, 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 an
evaluation of the previous, current and expected rates of ongoing settlement.
whieh-This information will be maintained within the Environmental Department records and
will be submitted annually as part of the ATER as required by RML Condition 12.3.
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