DRC-2009-006790 - 0901a06880152853

\:^^--;iccri-f.c)Cr'r[0
White Mesii Mill
Ground Water Module 65
Storm Water Mantigemetit
Page J of 12
Utah Division of Radiation Control (DRC)
Ground Wuier Module 65, Memorandum
Denison Mines. White Mesa Uranium Mill
DRC Annual Storm Water Inspection
Ground Water Permit UGW370004
To: File
Throush: Loren Morion, P.G., Manaoer
From:
Dale: December 10. 2009
Tom Rushing. P.G. ^^ l^' (^ ^^^ '/T ^ ^ /^ 110/0^=^
Subject: 2009 Ground Water Module 65 Inspection. Storm Water Best
Managemenl Practices Plan (SWBMPP) Inspection
General Inspection Information
Inspection Year: 2009
lnspecli(^n Date: 10/19/2009
Currently Approved Siorm Wjiter Best Management Practices Plan (SWBMPP): Revision, June,
2008
DRC Staff Present: Tom Rushing
Denison Mines Staff Present: David Turk (RSO)
Section 1 - Document Review
Vtolations/Non-Compliance Noted in Previous lnspec[i(m Cycle
The pievious storm v\ater inspection was held at the facility on November 5, 200S
(follow up to a May 21. 2008 inspection). Per the findings during those inspections, a
"confuniatory action letter (CALC was sent to Denison Minos (DUSA) on January 22,
2009. The CAL listed one required follow up action:
I. .\ "swamp"' area existed, located on the south side of the sulfuric acid tanks
which needed tenioval (in violation of pail 4.1.4 ofthe SWBMPP.
Per agreement between f^enisnii Mines and DRC thi*^ acli(in was lo he completed by June
30, 2000.
No tiihet" correspondence or dncunicnts were developed oi" sent to DUSA. Per discussu>n
behuv the "swamp" area wu.-^ ins|)ccied to in.sure thai all issues have been resolved.
White Mesa Mil!
Groimd Water Module 65
Storm Water Management
Page 2 of I 2
SWBMPP (Documentation Requirements):
Pan 4.1.4. - Diversion ditches, drainage channels and surface water controi structures in
and around the Mill area will be inspected at least weekly. Areas requiring maintenance
or repair, such as excessive vegetative growth channel erosion or pooling of surtace water
runoff, will be reponed to appropriate depariments and all follow up actions are U) be
documented.
Findings: Per DRC findings the White Mesa Standard Operating Procedures, Book 11:
Environmental Protection Manual, Section 3.1 includes forms for Daily Inspections.
Weekly tailings Inspections, and Monthly Inspections. DRC noted that the diversion
Ditches and Beiras are included on the Monthly inspection form (not weekly as included
as Pan 4.1.4. ofthe SWBMPP). Thus this interval does not conform to the current
SWBMPP requirements, DUSA will be notified that the inspections must occur on a
weekly basis or lhat the SWBMPP need to be revised as appropriate. DRC requested a
copy of a daily form, weekly form and monihly form for records, a copy of each form is
included as attachment 1 of this inspection module.
The monthly inspection form includes a brief check list (y/n) lo check for problems
related to sloughing, erosion, undesirable vegetation, obstruction of How. stability issues
and signs of distress, for three diversion ditches and one diversion berm. DRC noted that
if problems were found they w'ere typically included in the comments section ofthe form,
however, the follow up actions were not listed on the same form and per DRC review of a
large batch of forms the follow up actions wore not consistently listed on future fonns.
DRC noted that no addilional storm water controls besides the three dilches and one berm
were listed and/or inspected.
DRC' Recommended Actions: It is recommended that Denison require the inspection of
the ditches on a weekly basis to be consistent with the SWBMPP. It is also
recommended lhat Denison conduct a facility wide survey lo determine if any other
SLiriace wuler conirol structures should be included w ilh the inspection. Additionally it is
recommended that all follow up actions regarding maintenance needs (etc.) be listed on
the same form. The issue of follow-up actions and date of completion of follow up being
documented on the same inspection form {as the one where rhe problem was identified)
was discussed with David Turk. He agreed lhat this process could be improved and
agreed lo modify the inspection form to include a section for follow up actions needed
and dales of completion.
Additionally. DRC conducted in house coordination to detennine if lhe facilily
Rndionctive MLUcrial License tf UT190047'-") (License) ret|uires a conditi(m report lo be
opened in the case of deficiencies related to ALARA etc. Per discussion with Ryan
Johnson (DRC) there is m)\ a cuiTenl requirement for DUSA to open or track corrective
actions in the cuirent License conditions.
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 3 of 12
Spill Prevention. Control, and Counteimeasures Plan (SPCC) Documentation
Requirements (SWBMPP, Appcndi.x I. dated February, 2007):
1.6.1. - Daily nionitoring of propane tanks required.
Findings: DRC noted that the fuel area is included on the "'Operating Foremans Daily
Inspection'" form, however the form does not specifically refer to the petroleum tanks
w ilhin the confines of the facility, or indicate how thorough of an inspection is
conducted.
DRC Recommendation: This is potentially a worker safety issue but due to the volatile
nature of propane il would not likely be a water quality or groundwater concern due to a
spill. Therefore, there are no additional coneclive actions or recominendations per this
inspection.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: The facility representative stated that there have been no reponable quantity
spills (as per the Community Right to Know Act, EPCRA) at the facilily. DRC
confirmed that over the period since the last inspection no reponable quantity spills (or
spills of any size) were documented.
1.9.2. Intemal Notification of incidents, spills, and significant spills.
Findings: The facility reported that there were nt> reportable quantity spills at the facility
over the past year. Reportable quantities ate listed in lhe SWBMPP as well as the SPCC
plan and were taken from the RCRA regulations 40CFR I 17, Table 117.3. DRC
questioned this and noted that there is not a process to report small quantity spills at the
sile. DRC recommended lhat a process he instituted to insure lhat employees know' who
to contact regarding small quantity spill and follow through with a process of clean-up.
DRC Recommendation: Institute a process for employee reporting and documentation
of small quantity and clean up actions.
1.10 Records and Reports.
Daily Tailings Inspection Data: Daily inspection of tailings sluiry transport system,
operational systems (water level, beach, liticr and cover), dikes and embankments,
physical inspcciion ofthe sluny lines, dust control and leak detection was implemented
and documented on an inspection form. See attachment I (Daily Inspection Form). DRC
reviewed nil of the forms for the first quarter of calendar year 2009 (January J, 20O9
through March 31, 2009). This quartei was picketl al random. DRC noted lhat each
t|uatler of repons was organized in a separate hard copy file. All of the reports (daily.
weekly, monthly) were on file foi-ihc icvicwcd t|uarier (DRC did note thai there was no
quarterly report and it was reported lhat inspections ret|uirecl quarterly were included on
White Mesa Mill
("irtmnd Water Module 65
Storm Water Management
Paoe4of 12
repons at a higher frequency). This represents about 25% of the files reviewed this
inspection which were generated since the last DRC inspection (2008). DRC did note
lhat follovv up actions (resolution of noted problems) are nol documemed on the actual
daily fonn. DRC. recommended that the follow up be documented on the daily form.
The issue of follow-up actions and dale of completion of follovv up being documented on
the same inspection form (as lhe one where the problem was identified) was discussed
wilh David Turk. He agreed lhat this process could be improved and agreed lo modify
the inspection form to include a seciion for follow up actions needed and dates of
completion.
DRC Recommendation: Implemenl a process lo include follow up actions on the daily
inspection form. The cuiTcnt process only includes the action required and depends on
follow up actitms to be noted on future reports. The issue o\' foliow'-up actions and date of
completion of follow up being documented on the same inspection form (as the one
where the problem was identified) was discussed with David Turk. He agreed that Ihis
process could be improved and agreed to modify the inspection form to include a section
for follow up actions needed and dales of completion.
Weekly Tailings Inspections and Survey: The weekly tailings inspection was done and
documented on a weekly tailings inspection form. The form includes sections to
document pond elevations (solution elevation, FML bottom elevation, and depth of water
above FML) for cell I, 3, 4A and Robert Pond, as well as slimes drain liquid levels in cell
2. The form also includes infonnation regarding the leak detection systems for cells I, 2,
and 3 and 4A as well as potential blowing of tailings. DRC had no comments regarding
the weekly tailings inspection. (See attachment I)
Monthly Tailings Inspection, Pipeline Thickness: The monthly inspection report
includes a summary of the slurry pipeline condition and measurement of pipe thickness.
It was noted lhat the March 21, 2009 monthly repoil did not include a measurement of
pipe thickness due lo the mill being in non-operational status. The monthly report
additionally contains inspection protocols and observations related to the diversion
ditches and berms, sedimentation pond, dust control, settlement monitors and slimes
drain static head measurements for cell 2. DRC noted that on the reviewed report it was
noted that the overspray dust minimization pump was broken: however, there was no area
on the fonn where follow-up actions could be documented. DRC will recommend thai a
conectivc actions/date of action field be added to the inspection fonn.
DRC Recommendation: Include a field on the monthly inspection fomi lo log
coneclive actions taken anti the date of such actions. The issue of follow tip actions and
dale of completion of follow up being documented on the satiie inspection fonn (as the
one where the problctn was identified) was discussed with David Turk. He agreed that
Ihis process could be improved and agreed to modify the inspection form to include a
section for follow up actions needed and dates of completion.
While Mesa Mill
Ground Water Module 65
Storm Walei Management
Page 5 of 12
Quarterly Tailings Inspection: Per DRC review there w as not a form for quarterly
tailings inspections. DRC will request claritication regarding the language in the SPCC.
DRC does note that it appears lhat lhe c]uarterly inspection requirements are covered with
the daily inspection form. Since il appears that the quarterly inspection criteria are
covered on a daily basis DRC will request clarification only and not pursue formal
enforcement activity. DRC informed David Turk of the discrepancy, however, there was
no explanation given at the time of the inspection.
DRC Request for Information: Provide an explanation of the quarterly inspecticm
requiremenls and lack of a Denison Mines form (Per DRC review). Clarify whether
quarterly inspections (stand alone inspeciins) are cun'ently undertaken at the mill or if
Ihis is a redundant item.
Tank to soil poientiai measurements: It was unclear whether this item was being covered
during the in.spection. Additional clarification of the inspection requirement and facilily
actions are needed. DRC docs nol understand the facilities intention in taking these
measurements. At the lime of the inspection the facility thcaight lhat this item refeired to
the amouni of headspace in the tanks and may be poorly worded. The records for
headspace vvere provided in response to the DRC concems.
DRC Request for Information: Provide clarification regarding the "Tank to Soil
Potential Measurements'" inspection protocols and intent of the inspection.
Annual hulk oil and fuel tank visual inspections: Per DRC review tank condition is nol
specifically checked by the mill. DRC did note thai a general inspection of the tank area
is conducted (listed as fuel area) and documented on the operating foremans daily
inspcciion log, however, this does not comprehensively address the conditions of each
tank at the facility. DRC also noted thai daily volume measurements are recorded for the
fuel tanks, but. again, tbe tank condition is nol taken into account.
Tank and pipeline thickness tests: Per DRC review the only thickness tesl noted was the
sknry pipeline thickness and this is only taken during limes when the Mill is operating.
DRC v\ill request additional infonnation and clarification regarding this inspection
aciivity. DRC does realize that leaks should be able to be recognized through the
foremans inspection.
DRC Request for Information: Provide additional infonnaiion and ckinficati(m
regarding Ihe SPCC insi)ection protocol for tank and pipeline thickness tests.
Specitically. per DRC review the only thickness tesl noted was tor the sluny pipeline.
Qiiailerly and annual PCB transformer inspections (cuiTently PCB only): The lacility
reported that there are cun-enilv no P(!'B transformers at the site. DRC discussed lhat the
SPCC rule. 40CFR 112 has been updated lo include non-PCB oil types. Denis(m agreed
ti^ review the new language and u|)datc the SPCC plan as appiopnate. DRC will clanly
the timeline ihrough a retiuest \'c>y information.
White Mesa Mill
Gjound Walter Module 65
Storm Water Management
Pa^e6of 12
Request for Information: Per onsile discussion the EPA rules for spill prevention
conrioi and countcrmeasLires (SPCC) located at 40CFR I 12 has been amended and il
does not appear that the While Mesa plan has been updated. Provide information
regaidmg Denison U.S.A. review ofthe amended rules and actions which will be
undertaken to revise the facilily plan. Although DRC does not directly regulate the
SPCC provisions of 40CfK 112, the Ground Water Permit. Part I.D. 10(b) does require the
facility to "prevent, control and coniain spills of stored reagents or olher chemicals at the
mill ^itc.'" Since the rules of 40CFR1 12 pertain lo chemical storage and spill protocols
and since lhe facility SPCC plan is included as an appendi.x ofthe SWMPP, it is
reasonable lhat DRC refer to those requirements as part of tiie inspection. DUSA
addilionally agreed during the DRC inspection to review the EPA rules and insure lhat
the SPCC plan is up to date.
Tank supports and foundation inspections: The operating foremans daily inspection
provides a general inspection of the Fuel Area, bui docs not provide a specific inspection
of tank supports and foundation. This item is also covered in the tank condition
mspection section above. DRC noted that the inspection frequency is not noted, il was
inteipreted that this inspection relates lo a visual inspection of the integrity of tank
supports only and is likely conducted with the tanks condition repori.
Spill Incident Reports: No spill reports/incidenl reports were filled out. Denis(m
representaiive reported that there have been no spills. Also see notification language in
this memo above.
Latest revision of SPCC plan (onsile and available?): The current SPCC plan was onsite
and available during the inspection.
l.l I Personnel training and Spill Prevention Procedures (records of training required lo
he maintained in the general safety training fdes):
Findings: The personnel training log included a sign in sheet only. Per the docmnents
reviewed during the inspection there were 3 training sessions provided since summer
2008.
Regulatoiy Requirements {Ground Water PermitL'G\V370()04, Utah Administrative
Code iUAC) and Utah Code Annotated (UCA)
In ilif Ground Wafer Pcrniii:
The ground water permit requires provisions m the facilily SWMPP lo: I. Protect
groundwater qualily ov other waters by design, construction, and/or active opei"atit>nal
ineLisures that meet the requirements of Ground Water Qualily Protection Regulaiions
11.'AC R.M7-6-6..^(Ci) and R317-6-6.4(G). 2. Prevent, contiol and contain spills ol
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 7 of 12
reagents and chemicals, 3. C^'lean up spills of reagents or chemicals immediately upon
discovery
l.-.AC R317-6-6.3(G)and R317-6-6.4 refer to requirements for ground water pennil
applications and require that any discharges will be consistent with ground water class
limits, appropriate discharge minimization technology is in place etc.
(UCA) I9-5-! 14 requires that a person who spills any substance which may cause
pollution of waters ofthe State (includes groundwaters) is required to '"immediately
notify the executive secretaiy ofthe spill or discharge, any containmetit procedures
undertaken, and a proposed procedure for cleanup and disposal, in accordance with rules
of the"' water quality board.
Section ll — Site Walk-through Inspection {Includes Performance Standard Notation
PS: W'here AppUcable)
.Areas and Observations:
Ore Storage: Ore is cunently being stockpiled at the facility until a large enough quantity
is stored for an ore mn. DRC noted that a runoff drain (piped lo the tailings cells) was
C(mstructed at the southwest coiner of the ore storage area per past DRC commenis.
Although accumulations of silt/clay were within the dram it did not appear that the
integrity of the drain was impacted and that il was likely free dniining. DRC had no
additional recommendations coticeming this area. Photos 8 & 9
Reagent Yard: A new, enclosed, reagent building is currently under construction. DRC
noted that this will be a good improvement over the current reagent yard. Photo 39.
Per DRC inspection of the reagent yard it appeared that dium storage was appropriate.
No degraded or lapped drums were noted.
Shop: DRC noted that a tloor diain was located inside of the building which drains to an
outdoor sloragc tank (below gmund concrete vaults). It was reported lhat any oil
contaminaied water in these tanks was pumped to the used oil tank. DRC noted that this
creates a targe quantity of contaminated storm water and recommended that the indoor
drain be blocked and lhat indoor oil spills be cleaned prior to contaminalion of storm
water. \\ the water in the vault is determined to be uncontaminated then it is transferred lo
Roberts Pond. This was presenU'd lo ULISA as an advisory rnuling hy [)R(!' only. Photo 4
DRC noted banel storage (various liquids) in the area of ihe shop. Per DRC inspection il
appeared that the bands stored did nttt have laps or valves (were sealed) and that the
storage (without containment) was allowed per the SP(X" rules |40CFR I 12). Photo 7
Mill Processing .Areas: DRC noted that the SX building roof drainage has historically
created hill erosion which now- leads to the altematc Iced [>rocessing area. DRC has
recommended retrot"itting in the past lo insure that the roof rutioff is directed ro the SX
W'hitc Mesa Mill
Ground Water Mtidule 65
Slorm Water Managemenl
Page ^of 12
building containment thence to cell I. DRC advised Denison to inspect the effectiveness
ofthe cunent roof drainage during storm events. Photos 29. 31 dt 32
Ahernate Feed Circuit: DRC inspected the alternate feed processing area. It was noted
that dniinage within the containment area was pumped into overhead tanks. During the
inspection it was reported by David Turk that a Denison eniployee was posted at each of
the altemale feed locations 24 hours a day. 7 days a week. Photos 35 & 36
Decontamination Pad(s): Two pads were observed, the new, unapproved pad located in
the area of Ihe scale house, and the existing approved pad located next lo the Grizzly.
New Deconiamination Pad - DRC noted that the recycle tanks are located on the east
side of the facilily and approximately 30 fl from the east fence line. Discharge from
these tanks could potentially flow offsite. Denison is in the process of building an
interception ditch and closed sump along the eastern margin. See photos 10, 11 & 12.
Existing Decontamination Pad - Wash water is recycled until loo dirty, the water is then
discharged to a below grade lank thence to the process water pond. It was noted that the
piping from the decontamination tanks to the overflow vault was not long enough for
direct discharge and was resulting in overland How and potential infiltration impacts.
DRC will therefore recommend thai the piping be extended to avoid contact with the
ground. Photos 15, 16 & 17
Tanks (Per Notation):
Sodium Chloride Tanks - DRC noted that the containment area was earthen. It was
reported that this was allowable due to the age of the tanks. Per discussion beiween TR
and LM it was noted that LM had a past discussion with Harold Roberts regarding the
secondary containment. An agreement was forged ihat all reagent tanks that pre-e.xisted
the Ground W ater Permit (.V05) would be acceptable as is - and that as upgrades or
replacements were installed. DUSA would work to meet BAT requirements. More detail
regarding this agreement is in the December 2004 Statement of Basis. Photo 1
Kerosene Tanks — DRC noted that the containment area was earthen, ll was reponed lhat
this was allowable due to lhe age of (he tanks as discussed in the Sodium Chloride Tank
Section above. Photo 2
Ammonia Tanks - DRC noted that the containment area was earthen. Il was reported
that ihis was allowable due to the age of the tanks as discussed in the Sodium Chloride
Tank and Kerosene Tank seclions above. Photo 3
t.'scd (.)il 1 ank - .Appeared to have appropriate secondary containment. No records
concerning visual inspections of rank integrity. Photo 6
Whire MCSLI Mill
Ground Water Module 65
Storm Water Management
Page 9 of 12
Kerosene Tank ^ Located in the same sccondaiy containment area as the used oil tank.
Facility reported that this was acceptable (by rule) as long as the coniainment was
constructed for the larges rank. Ihis criterion is c<insistenl with past inspections hy DRC
at the sile with sinular findings. Photo 6
Fuel Tanks - Above ground tanks appeared maintained and had secondary coniainment.
Photos 13& 14
Pulp Tank - Coniainment areas appeared lo be in good condition. Photo 115
Clean Water Tank -- lhe tank valves had been recently repaired. Addilionally an
underground pipe discharge was constmcted from the tank containment to alleviate
standing water and the development of the "Tamarisk Swamp."' This dram is shown in
photo 20 but note that in this photo il is not the white pipe but the black pipe which is
somewhat hidden in the vegetation, the pipe is located about 1 Vi inches to rhe right of the
while pipe in the pholo. DRC commenis are lhat the tank condition has been improved.
Photos 19(fc20
Sulfuric Acid Tank - The lank appeared in good condition. DRC noted that the discharge
fn)m the secondary c<mtainmenl was in the process of being piped lo Roberts pond to
avoid surface accumulation of water which historically created the "Tamansk Swamp."
Photos 22, 23 & 24
Propane Tank - No issLies observed. DRC noted that the valves and air quality system
was recently replaced. Area was clean. Photo 25
Caustic Soda Tank - Secondary Containment was not in good condition. Concrete was
highly degraded and appeared to have holes extending lo earthen material. DRC
recommendation is to repair or replace the secondary containmenl floor. Although lhe
effect to the penneability ofthe material could nol be detennined during the inspection, it
appeared that the concrete mav have been pitied lo the soil suriace at one or more areas.
Photos 27. 28 & 30
Soda Ash Tanks - Secondary containment floor showed cracks. DRC recommendation is
to repair or replace ihe secondary containmenl lloor (e.g. used sealant to lill ihe cracks).
Photos 33 & 34
Upland Surface fJiveision Ditches and Tailings Cells: Per DRC inspection it was noted
that the upland diversion dilches were designed for a large stonn event and w-erc
maintained. Photos 40 & 41 DRC also inspected the tailings cell areas Ina had no
comments related to storm warer management. DRC^ did not note excessive rilling or
erosion of any of the batiks.
Olher (per notaiion):
While Mesa Mill
Ground Water Module 65
Storm Water Management
Page 10 of 12
Per inspections on November 5. 200R and May 21, 2008 by Dave Rupp (DRC) il was
noted thai discharge from stonn water and the water tank was accumulating in the area lo
the south of the sulfuric acid tank. This accumulation resulted in what was known as the
"Tamarisk Swamp."" A January 22. 2009 DRC Confirmatory Action Letter required lhat
the Tamarisk Swamp be removed prior to June 30, 2009. Per this inspection il was
verified that the swamp has been removed and that Ihe drainage system for overland
tlow. hom the water tank and from the sulfuric acid tank secondary ccmiainment, has
been modified to eliminate water accumulation (ponds) in the area. (Photos 19, 20. 21
and 23) This item will therefore be closed out.
DRC Action: It is recommended that DRC close out the Januaiy 22, 2009 confinnalory
action requirement to eliminate the Tamarisk Swamp. Per discussion beiween TR and
LM on December 7. 2009. the close out will be included with the inspection ''request for
information and findings letter."'
Photos
Pholo pages are attached to this memo (Attachment 3).
Phofus S7 and .^8. addilional c<mvncnis conve.iiun^ altemalive feed wurce (feedstock) in
deleriorait'd barrels - DRC noted that the deteriorated dmm storage on ground (without
containments or impervious underiayer) does not meet the requiremenls of the updated
Pennil language. 1 he modified permit is expected to be issued effective shortly.
Specifically, the dnmi sloragc docs nol meet lhe requirements of part I.D. 11 of lhe
updated pemiit which slates:
11. ""B.AT Requirements for Feedstock Material Stored Outside the Feedstock Storage
Area - the Permittee shall store and manage feedstock materials outside the ore
storage pad in accordance with the following minimum perfoi-mance requirements:
a) Feedstock materials will be stored at all times in water tight containers, and
h) Aisle ways will be provided at all limes to allow visual inspection of each and
every feedstock container, or
c) Each and every feedstock container will be placed inside a water-tight
oveipack prior lo storage, or
d) Feedstock containers shal! be stored on a hardened surface to prevent spillage
onto subsurface soils, and that conforms with the following minimum physical
requirements:
1) .A storage area composed ofa hardened engineered surface of
asphalt or concrete, and
2) A storage area designed, constructed, and operated in accordance
v\ith engineering plans and specifications a[)proved in advance by
the Executive Secrelarv. ,AI1 such engineering platis or
specifications submitted shall denionsiraie compliance with Parr
l.D.4. and
White Mesa Mill
Ground Water Module 65
Stoim Water Management
Page I i of 12
3) ,A storage area that provides containment berms lo control
stonnwater run-on and run-off. and
4) Slomiwater drainage works approved in advance by the Executive
Secretary, or
5) Other storage facilities and means approved in advance by the
E.xecutive Secretary"
DUSA will therefore be notified that this issue needs ro be resolved and that ifthis
finding is found in the future it will mosl likely be subject to formal enforcement.
Closeout Meeting Summary:
.A close out meeting was held with David Turk immediately following the inspection.
Per discussion during the inspection, the following specific ireins were discussed during
the meeting:
1. 7 he inspections and documentation for the diversion dilches and berms need to be
conducted weekly per lhe SWBMPP requiremenls or the SWBMPP needs lo be
revised.
2. Inspections need to include an evaluation of the condition of all tanks. In
response to this. Dave Turk provided a oopy of the foremans daily report and
inspection which includes cursory review elements, this report is still not
adequate,
3. FoUovv" up actions need lo be documented on lhe same repori foim for all
inspection types, including dates that follow up actions were completed.
4. Tank lo soil measurement protocols need to be clarified.
5. Quarterly inspection protocols need to be clarified.
6. ,A process needs to be developed for small quantity spill notificarions.
Specifically ir was discussed that employees need lo understand who should be
contacted in the event of a small spill, and follow up and documentation
procedures need to be established.
7. It was discussed thai the SPCC requirement (4(_)CFR112) have been revised and
(hat DRC expectation is that the SWBMPP Appendi.x I is updated in conjunction
with the revised conditions.
8. It w\is discussed thai the floor of lhe secondary containment of the caustic soda
tank would need to be repaired or replaced.
9. It was discussed that the secondary contaiiuuent floor below the soda ash tanks
were cracked and needed repair.
10. It was discussed that the floor dniin inside t>f the shop building was probably not
appropriate and Ihe f3RC recommendation was for removal of the drain.
Additionally it was discussed lhat the storage and protocols for the baffled sumjis
outside of the shop building needed to be clarified and that uncovered stt^rage of
potential used oil was nol appropriate.
I I. ll was also discussed that several improvements rcL'aiding storm water
nianageincnt have occurred over the past two years and lhat specifically, it was
While Mesa Mill
Ground Water Module 65
Slorm Water Management
Page I2t)f 12
noted that the ""swamp" area south of the sulfuric acid lank had been removed per
the CAL and that this item would be closed-out.
Close-out Telephone Conference
DRC (Loren Morton and Tom Rushing) and Denison USA (Dave Frydenlund and Steve
Landau) had a conference call on December 10. 2009, 9:00 A.M. until approx 10:15
A.M. to discuss the findings of the inspection.
Conclusions
DRC noted several items for clarification or had recommended actions at several ofthe
areas of the White Mesa Mill as listed in the memo above. DRC additionally noted that
the "Tamarisk Swamp" area had been regraded and that drainage from the water lank and
sulfuric tank (secondary conrainmetit) had been piped to avoid discharge and
accumulation of surface water in that area.
DRC will prepare a Findings, Recommended Actions. Requesl for Information and
Confirmatory Letter Closeout, Letter regarding the stonn water inspection.
References •
Denison Mines (USA) Coip.. Slorm Water Best Managemenl Practices Plan for While
Mesa Uranium Mill. June. 2008
Appendix I - White Mesa Mill Spill Prevention, Control .And Ct>untemieasures
Plan
Appendix 2 - Denison Mines (USA) Coip., Emergency Response Plan Revision
l.l. Revised February 16,2007
L' rndM.TlMMCiN^LiriUiiurn niillsM k(^)I iTIOf.nM"^*) L)cnison Minti - While Mcbii L'MillVSKirni W.Upr
M,Tnu^CFT,cnt\MoiiMk-65MciiKiFi'>jniai dof
White Mesa Mill
Ground Water Module 65
Stomi Water Management
Attachments
Attachment 1 - Copies of Daily, Weekly and Monthly Inspection Data Logs for March,
2009
White Mesa Mill - Standard Operating Pj-ocedures
Book U: Environmental Protection Ivianual, Section 3.1
2/07 Revision; DUSA-2
Page 17 of 25
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Inspector: Ij'^A^ijf^R. POLL
Date; ^-M-acog
Accompanied by: K>/A
Time: fM36
££WHJ
Any Item not "OK" must be docirniented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Insoection Items
Slurry Pipeline
Pipeline Joints
Pipeline Supports
Valves
Point(s) of Discharge
Conditions of Potential Concem
Leaks, Damage, Blockage, Sharp Bends
Leaks, Loose Connections
Damage, Loss of Support
Leaks, Blocked, Closed
Improper Location or Orientation
Celll
y /
v^
/
V"
Cell 2
AJ l\
CeU 3
y
s/
1/
y
y
Cell
4A
'~zr~
y~ y
y
y
n. OPERATIONAL SYSTEMS
Inspection Items
Water Level
Beach
Liner and Cover
Conditions of Potential Concern
Greater Than Operating Level, Large Change
Since Previous Inspection
Cracks, Severe Erosion, Subsidence
Erosion of cover, Exposure of Liner
Celll
/
•/
L/
Cell 2
K>^h
U
Cell 3
1
/
/
/
Cell
4A
y
J "
y
ni. DIKES AND EMBANKMENTS
Inspection Items
pes
Conditions of Potential Concem
Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
Areas, Areas of Seepage Outbreak
Dike
l-I
/
Dike 1-
lA
/
Dike 2
'J/A
Dike 3
/
Dike 4A-
S
y
Dike
4A-W
/
Miite Mesa Mill - Siandard Operating Procedures
Book i 1: EnvuroiimentaJ Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 13 of 25
Crest Cracics, Subsidence, Severe Erosion 7 y 1^/1^ y L/ y
IV. FLOWRATES
GPM
Sluny Linefs"!
cS-4i> ^T^
Pond Retum
^W(?
S-X Tails
^3^-
Sprav Svstem
, ''i i
.-^^/k
V. PHYSICAL INSPECTION OF SLURRY
LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line y
Yes
Yes
y No
'NO
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: (^ inches Hquid
3eneral Meteorological conditions: C_,,, ^ \il:n.k,l
Cell 2
/
y
Cell 3
/
\
Cell
4A
L/
y
rajpAILV LEAK DETECTION CHECK
Celll Cell 2 Cell 3 Cell 4A
.jeak Detection System
Checked
\f Checked
Wet / Diy
y^J Checlced
J Wel Dry
Initial level
Final level
Initial tcve(_
Final level
Initial level '- ^D
Final level
Gal, pumped Gal. pumped_ Fiow Meier 7i7g^
VIU OBSERVATIONS OF POTENTLVL CONCERN Action Required
Tfdi^t\ Tu <3cV i£?M«.fh'"
bc^ & oj^ Vor .-Spf-z^^lSo
DATE: ,.^Jil^£2_-«=_
Vl^hite Mesa Mill - Standai'd Operaliiig Procedures 2/07 Revision: DUSA-2
Book II: Environmental Protection Manual, Section 3.1 Page20of25
APPENDIX A (CONT)
DENISON MINES (USA) CORF.
WEEKLY TAILINGS SSSPECTlOI^f
AjC^
^
^^
/./,f
Date: "5-^-^00*^ Inspectors: 1 ^y^e/Hollia^li « l^ar^ TL
d ^
1. Pond elevations (msl,ft) Cell I: (a) Pond Solution Elevation 5[P12.,1^ ^''- ^ ^
(b) FML Bottom Elevation 5597
(c) Depth of Water above FML ((aXb)) 1,^^ ,^ ^
Cell 3: (a)Pond Solution Elevation fSLOj.^l ^_ ¥y
(b)FML Bottom Elevation ^5570
(c)Depth of Water above FML ((aHb)) '^|.^f
Roberts
Pond: (a)Pond Solution Elevation _
(b)FML Bottom Elevation 5612.34
(c)Depth OfWater above FML ((a)-(b))
taJ^
2. Slimes Drain Liquid Levels CeU 2 Pump functioning properly . y . ^
Pump Timer set at 15min on 45 min off /^ rfpi^l^ ^y ^'^^ *^
11 .V\ ^Deptii to Liquid pre-pump
U.^l ^Deptfefto Liquid Post-pump
(all measurements are deptb-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
pump = 3.C>-7^
VtHiite Mesa Mill - Staiidard Operaring Procedures
Book il: Environmental ProlMtion Manual, Section 3.1
2/07 Revision: DUSA-2
Page 21 of 25
3. Leak Detection Systems
Observation:
Is LDS wet or dry?
If wet, Record
liquid level:
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate;
Was fluid sample
collected?
Celll
wet ^ dr^'
Ft to
Liquid
Volume -
Flow Rate -
yes y no
Cell 2
/
wet / dry
Ftl/
Liquid /
Volume /
Flow R»e
/ yes no
Cell 3
wet "^ dry
Ft to
Liquid
Volume
Flow Rate "
yes y no
Cell 4A
'
V wet dry
S 4 Ft to
Liquid
Volume
Flow Rate 7/7^;^
yes y no
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented: ku^^^tu^ hc*^? liktl J^ o-v^'-f y^//<Jp3^h/(
6. Remarks: 'IL^., i^,.U, /'L^^ A L-f / h,..K^ ^^A U^UCtJj^ A///fA J"
7. Contaminated Waste Dump: 0 It _^-_
8. CeU #4a Barge and Walkway
White Mesa Mill - Standard Operating Procedures 2/07 Revision: DUSA-2
Book 11: Environmental Protection Manual, Section 3.1 Page 22 of 25
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector: lff/)i\er //. ^ KKJ/JJ fAJ/ntr
Date: c3-<S/£/:^f
I. Slurry Pipeline: /// /M<^ /ire, irt //>^// itbM>'..^{:i^'i -^^ lie V-/ IV^rt fi^m1»^'f''<'
KL. i^^^ ^;ivf ^ ^.-^--^p--^- -
Pipe Thickness: Al f^ fTo be meisured only during periods when the Mill is operating)
2. Diversion Dlfaies and Diversion Berm:
Observation:
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches: ^ -
Sloughing yes ^ no "^ves no ^ yes no . - \ ^
Erosion yes *^ no *^es no «^ yes ^no - '
Undesirable yes no yes v^ no yes ^"^ no
Vegetation
Obstruction of Flow yes '^ no yes ^ no yes no
Diversion Berm: ^
Stabili^ Issues jcs no
Signs of DisUBss yes *^Q
Comments: b^7 t i^(\:g fkof.M.^j^ At>^ ^ /I^t.^^ * -^L^/,..'./ A. ix
v***^.
3. Summary of Activities Around Sedimentation Pond: /^.tV i^/> AJA^ Z,".^.^ir/ yLnu^i,£u.f
QU ^A^ff^'iA/ PMI. i Lf— f^
White Mesa Mill - Standard Operating Procedures 2/07 Revision: DUSA-2
Book 11: Environmental Protection Manual, Section 3.1 Page 23 of 25
4. Overspray Dust Minimization:
Overspray system functioning properly;
Overspray canied more than 50 feet from the cell: yes no
If "yes", was system immediately shut off? yes no
Comments:
5. I^marks: IflJt Iiul J /^r ^ ffohkfi i^>^\ ptmif^m Jilfff Ji/i^f< pi^/JrJ J £^r^
6. Settlement Monitors ^CC /fff^J^f^^-
Cell2Wl: ^J^fPf?'
Cell 2 W2:
Cell2W3:
Cell2W4:
Cell 2W7-C:
Cell 4A-Toe:
^ CeI12W3-S:
Cell 2E1-N:
CeU2El-lS:
CeU2El-2S:
Cell 2 East:
CeU 3-IN:
Cen3-lC;
CeU 3-lS:
CtW 3-2N:
CeU 2W5-
7. ^Sunimar3' of Daily, Weekly and Quarterly Inspections: ^ f^f^j M^ALMS ^,'H J^aStJ
Af^*^Hf^ -jm^^M /H^m/L(;} mlr^fAtf^i^U. Ai^i^-f^'^tn -r^-h /^^/;f»^^
f rJ,itrH< i.,:'if. i(^<: ^ £m.
8. Monthly SUmes Drain Static Head Measurement for CeU 2 (Depth-in-Pipe Water Level
Reading): 3'• S'f
-r.sr ^^ iL^^i/ j-^ ^ M.^^<-^j^^^ L^i^t^ /^^^ ^.^^
IAM A
Location Trans. Shot Base Applied Elevation
Cell 4A
Intitial
C2W1
C2W2
C2W3
C2W4
Initial
4.6^
7.1
3.3
1.36
4.59
5.04
9.68
• .'
2W5-C
2W4-N
2W4-S
2W5-N
2W3-S
Initial
3-1N
3-1C
3-1S
3-2N
3-2C
3-2S
4.14
3.2
6.32
3.6
5.79
4.15
0.15
4.36
2
399
3.54
5.02
5574.5
5581.6
5612.77
5612.77
5612.77
5612,77
5622.45
5623.14
5623.14
5623.14
5623.14
5623,14
5623.14
5623.14
5623.14
5623.14
5623.14
5627.28
5612.77
5612.77
5612.77
5612.77
5612.77
5617.19
5613.04
5613.04
5613.04
5613.04
5613.04
5613.04
5576.96
5619.15
5621.09
5617.86
5617.41
5623.23
5626.76
5622.23
5618.85
5621.58
5620.84
5619.24
5619.82
5617.48
5615.85
5618.31
5619.25
5616.13
5618.85
5616.66
5617.04
5612.83
5615.19
5613.2
5613.65
5612,17
Name: Tanner H., Ryan P.
Date: 3/31/2009
//^^
White Mesa Mill
(jTound Water Module 65
Storm Water Management
Attachments
Attachment 2 - Copies of Operating Foremans Daily Inspection Log, March 2009
rev. 03/19/07
OPERATIMG FOREMANS DA8LY INSPECTION
Oe^e:2lMzOl
AREAS
CHECKED
Day Shift
Time
Night ShiR
Time Comments Day Shift Comments Night Shift
Grind nhif -j^ $hrkA r.isp^ clL.cO . &e.^.Uo^ ^-3 p<C
Leach t q-?_c 0V<^/ 0^ CV<»PM 1 ftifk [ i^ATViLj-tvrS
Mill Lunch Roonn ?.^tfl Ok-faU. ^e^^ Ajt^^Ciy^
CCD ^e"g-i2i£ £t.CJ:2Sij_ii^iJ^iCi3*KiC3b,
YCPrecip & Pkg tftig. OK sietjrt ji^/i; j» ^ 3-ff'j-P^i Cn^iX^ rtai^ej'.
SX Zg^*^ flO; ^^r.'ril tff yj,/t>v mfc '-On . A,<t:JL4-sCMA/Tjr=^
Boiler -^IZ^ OO ttU -^ • -uartT^i- t«MjU L/M .
Vanadium PB-3-S O]y^ou^t\ g*^. Ki<aj< LOfl^UfiUfujY.. .
Stockpiles _£iia. t:))v -1?.ii rv\ rtF ttU.. MTVilfeii d"^*-^ '^g*^-
Water Supply 2.1'iO Oki tA.^LSV^ • •p^fl.Q.l^ Lj.Pl-<^.
Tailings K-^-a^ 0^ ^^fk i^,''\d mi- ^ *^^ MAX TViUo^ ^^>>p ^.»,
Chlorate Area vap^. ilSL CU. ^ ^^tA^.A ^llAt.p
OFRce/ l,ab Area ^ftfto niii QU., UPiitt: Mffc^^Jvx^
Fuel Area OS'PT. 2)1/ i^u .K.ttl.1^ tv-'t^Wn -a-.
Product Yard Gate \^\V ^OCWyl .^u.. f^ASTU Uakta.
Water Storage Tanks toeM-2-2M (Old.. ^XLU (AvtfJi ,.0>tlO 1-S
Mill Water Pump "'o^-|-3-xp^F c\^pa.J, m? VIo. pM^^^At-.
Acid Storage Tanks^ o>^-» OW' ^^0 /caifi r>L., Aa^-a- i^X<i_-t ^^(A.
Ammonia Area TanKs lan. DV «V . tberru T/wJKX .
Scalehouse tPHC i2i^ ot^.. OevtJ^g-<T;..u>>n ICW^^.-
Wildlife Report
Day Shift
Night Shift
I have inspected the above stated areas for radiological and safety concerns.
Foreman Day Shift Foreman Night Shift
t-f(^^e ,<-M::^
OPERATING FQREMAMS DAILY INSPECTBON
i-ev. 03/19/07
Date: ^^ A/tfr. g^j
AREAS
CHECKED
Day Shift
Time
Night Shift
Time Comments Day Shift Commenta Nigfit Shift
Grind i^n? i^iTg gK:r*U.<rtit'^g ^--ftv XJAVMU^ *^^f^^
Leach |0[»a ^HC,1>^.^^.l^ gtfO^ bU ^w.. aUrJUU. Cl^arUT^..
Mill Lunch Room ^Z^T^ ^ &>U- - NJ^<>.iU ^U^^H>^JJ
CCD -^tUL. gg.e>ft..*-Mgtfty.
YCPreclp&Pkg g=^Q <i^ I i>:f..jeir "^rrrititr: FiffK
SX •^t^^r^ ^K../l£iljL.,gf.lAt/^ ic-lf t TMl-VfiT^i -iwT. ^t IfHU
toU-. -rw , UMCT^ IgwLk \/^A Boiler •^'•^^ Jfe.febTJJ 0M,<U^«t<'OFTW>l
Vanadium t^v-Jo ^211. rA.. f-i/A-rO-u^ >ZL pAe^^v^
Stockpiles • tJSlBn .2fc-aU . fttfU V.^i Aj^u^ M^*-.-».
Water Supply Z^-^o gk -jrt ^.jftL^ ua^>yt.
Tailings o4nc i* loW. JKU,a, K^IH-^ -g*-^
Chlorate Area I©ii_ SIL ct. piA*ftYft.A •^y.-f^
Office/ Lab Area Iggh coU, uttA^ /^.«^i}*A*^
Fuel Area -&^''g ^ tstf,. Afl/>^ \Z^\AA-^^HC^
Product Yanj Gate l-Svft iHC t^T q»rtL Ur^H^A
Water Slorac)e Tanks tCOA-z. OK^-^'-7 t^,-P'> }niti^(flrt*^^^l)^n irtr.
Mill Water Pump P'OP rtk t:b'fe>'f pK.-g'-^H I7g >Ui v>i-fcS-ihtfA.
Acid Storage Tanks o>^^ ^J^_.f:'w'F' o-t.*%<^d'>) c^ff, ALtrt. m.^
Ammonia Area Tanks tgZ4-cy- • i^-rtfr, T£>•*£> ,Ai «ji«f'|>y^ ak. faprm-TJj^to.
Scalehouse "^ g>'-">' (Oli f^vt-, ^IV>iVfijg LI. -^JA-
WlldUfe Report
Day Shift l^aijblT^
Night Shifl
I have inspected the above stated areas for radiological and safety concerns.
ForEman.Daf Shifl Foreman Night Shift
_3^
Date:
rav, 03/19/07
OPERATIMG FOREttfiAMS E3ABLYIMSPECT80N
^^Z^'Of
AREAS
CHECKED
Grind
Leach
Mil) Lunch Room
CCD
YCPrecip a PIcg
SX
Borier
Vanadium
Stockpiles
Water Supply
Tailings
Chlorate Area
Office/ Lab Area
Fuel Area
Product Yard Gate
Water Storage Tanks
Mil! Water Pump
Acid Storage Tanks
Ammonia Area Tanks
Scalehouse
Day Shift
Time
r7A-7^
\
Night Shift
Time
'7^-nA
\
d c^
Commenis Day Shift
CJC^
(
/
. /
/
/
/
/
/
1
Comments Wight Shifi •
^u^uU-^ < pi—*(» tl*^*'<'**4. «7)C
Ci«A*-ri •
^
ft,vs*r\
it
Ct.,0cwjv\
tV_ T»,tfVV,'*!C)n-AvC,«)Trt.,C>-*t-t-ofrV*n
*. utT5.i~-*r+-i~«.<^«n,r^ •
£*
tfU.
ev.
t-ft
tflt
•K
AL
^
Dt
<*L,
A. ^.»"M7lM'WJ««+*~'^4«r-W*lt
A.
Wildlife Report
Day Shift -er-
Night Shi' "^M^i^
I have Inspected the above stated areas for radiological and safety concerns*
Foreman Day Shift
•r9h
Foremap^ight Shift
Dale: 7'S • ^"i
rev. 03/19/07
OPERATING FOREMANS DAILY INSPECTION
AREAS
CHeCKED
Grind
Leach
Mill Lunch Room
CCD
YC Precip & Pkg
SX
Boiler
Vanadium
Stockpiles . .1
Water Supply
Tailings
Chlorate Area
Officef Lab ^vea
Fuel Area
Product YanJ Gate
Water Storaae Tanks
Mill Water Pumo
Acid Storage Tanks
Ammonia Area Tanfcs
Scalehouse
Day Shift
Time
/&#r-7<M
I .
\ 1
\
Night Shift
Time
^^P-/l^
,
/
.„
'
Comments DayShfff
^L tA
•\
r '
'
\ s
Comments Wiqhf Shift
^^ "^-r
/
/
/
/
1
/
/
/
/
/
/
/
Wildlife Report
Day Shift !ltet
Night Shift ^LP^h^
I have inspected the above stated areas for radiological and safety concerns.
Foreman Day Shift Foreman Night Shift
Date •• n-^'^
AREAS
CHECKED
Grind
rev. 03/19/07
OPERATING FOREMANS DAILY INSPECTION
Day Shift
Time
Night Shift
Time
nA'''^p f^w
Comments Day Shift Comments Night Shift
IMdl di-atf- k.W^^ uytAL^f^yy^
Leach
Mill Lunch Room
-laSi. 'Du^n
•Z.T--i^ 'Cldar^
eU. -otf. UJft.'OJa.-*^ /U**lL^.,
fck.. tJwA^ f/^^^^2.^
CCD '^^ dmdL .-<fc,,etf- , ,.-ns! iUX«nAi.l|fM<
YC Precip & Pkg <^i-7 <^nac ^flU.^ .-/X^-J^Z-^C+tW
SX 7Dy)| <dot<vi^ ick.-a>tf rt/J>v^<A-| .^•;ft^\4^>u>'^
Boiler '^^•L. i \(Luy^eOj,-\ tyc^O- hn'JK^ BU-ooyLudM-) •^Jn.TtrrrJftJ gl/^^r^
Vanadium
Stockpiles
0Z.30
tt->7:>
tftf/rn
^K
tek'etf^ i,>aAcLXx,jn .
a.U. /^;LL^ . AUJP;L.^/p,h^ujtit^O\
Water Supply •^^•a?. 1^ yg^ .^L4:j2£i^aca£Si!=£e-id:iA!:£Li=-
Tatiings £M-m-Ot^ .falJ ly, -- H WAftosley p^^ - out.
Chlorate Area i©!2L Ow cV, ^ \*>.Yn*x>u-^ ^ A^^
Office/ Lab Area
Fuel Area
Prtiduct Yard Gate
taoT. ^<^y^
ps-^^ L(X\r^td
r^^ Kl^nA^ fllgA^.-^,^
-LfeiS. SSZ fi
PU., ^fl^A. lr.fj>lAtfx -aO
felii. " g^flgn- Mn-RP^.
Water Storage TanJts co^-h idl fek . ova , InUA • At./rO IUJ;<^
Mill Water Pump
Acid Storage Tanks
Ammonia Area Tanks
fcU-S-iLKt
.^iii.
^gLg-l
A/t^ t^.t^.i fr&ir.tf
^\d. -1 U^lfa. pMA<;.ua<-
j£i£
ft:. , >.ii^A- II'^[LK^-L>.
tt»k- ^tfivt- 'inwJtiK.,
Scalehouse .Slalra. 0\^ oLi-. Lue^LKftJ^ r^ /^fcg,*--
Wildlife Report
DSY Shift
Night Shift
Trtrr-fx^^^lLc ^ ^ATt^RAJ^WP^ •. T^gflt-, ciwJ , V.':\.\ iAyeJL^ OJO^ .
I liave Inspected the above stated areas for radiological and safety concerns.
Foreman Day Shift Foreman Night Shift
(^Ojc.^ ^^^
FEV. 07/31/09
OPERATING FOREMANS DAILY rNSPECTJON
0.^.:MdM.
AREAS
CHECKED
Day Shift Night Shift
Time Time Coniments Day Shift Comments Night Shift
Grind ^4-7^ \c<^^ (hujvy i^^TJ^. vac^ *W u,v>A.U^jt.j>rt .
Leach ia^3L A-^tf-. titA^A. UiM^uUfans
Emergency Generator 'Z'£^^5^3. i=u^. ^-voU i*l,fA^u::^
CCD '2^ VI
Yellowcake Precip & Pkg iB^l-)s\ <>Wi ^IHM riA, tePl-llnIt^ '^/ TJuW)f.rt,
SX •2^0*^^ OhcT fc»^"g^£, MfftAc ujwfv^jwrt .
Boilers -i^in Oyr
tffc^«&xj/j^jgAf-\ t*-.*. u.4-4_
Vanadium OVTJ3 -^trfitLt-tiiEiSaJ^^^t^^iifiato-
Feed Stockpiles c-z-^n
Water Supply JZJLA^
Tailings Area fg'>»>0)
<j\A . AtL^ (fctf-Lj (^AavW^vf^
<e<l.^£h)^ p^AftLD La*»*fl-
to\^. ^fld ^ -^r^ '^•titoo.. U 1,1 ** f
Sodium Chlorate Area IBQ2. aat, itrp^i^fl (r*'^r^
Office/ Laboratory Area Jl^r. fc*^, kl^4£. rUft^l^AtJ( •
^ Fuel Area p^^^. <=^^ Ai;^ i(«\l^
Product Yard Gate Laii.
Water Storage Tanks
AfVr.^Vft^
^•^A-a
Mill Water Pump
J£A_I/£A
rz-^tp n^'?t.
uv;^ c^H^nu f'lrt'im^.
tok -caxj it^ ^^j;p Ja^j .*
ttti-ftj. H-g tu. (NJtLVM.4p.ff
Caustic Soda Tank _Laia. ate fck , iA|(ftit>^ k>.MjU /iMtsHJ^
Kerosane Storage Area 'gn tek: • a«> ^flAU-'^ •
Ammonium Sulfate Tanks ^\^i
Acid Storage & Propane Tanks -a.-*4-i_
cfc, - OPJ r tUfwypi^ fht^ A\JA^1
teM-- AjUh. \ -arti.
Ammonia Area Tanks V tfeTA C*^r foftTTfr T*>»X
Mill Yard
Alternate Feed Circuit
7J-S2,
|g^^
^U ^ ftAl/i^ ftf**Jt^ .
fate ^-gM AA^t.f.TUnMAr
Oxidation I'HC'"^ ».U- ^ U^Cua^jU>LAjr> .
Scalehouse JSSifL t«*^. VML^g .
Wildlife Report
Day Shift
^^lighl Shift
I have inspected the above stated areas for radiological and safety concerns.
Foreman Day Shift Foreman Night Shift
t^d^^ 'V-
While Mesa Mi 11
Ground Water Module 65
Storm Water Management
Attachments
Attachment 3 - Photo Pages
White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 1 of 21

Utah Division of Radiation Control
Storm Water Inspection
Denison Mines Corp., White Mesa Uranium Mill
Inspection Date: October 26, 2009
Photo Pages

Photo 1 – Sodium chlorate tanks and secondary containment. Water in containment is
from and adjacent wash-down area.

Photo 2 -- Kerosene tanks and soil secondary containment. Silty/clay material used for
berms.
White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 2 of 21

Photo 3 – Ammonia tanks and soil secondary containment area. Facility reported that the
tanks only required soil containment due to the age of the tanks.

Photo 4 – Shop floor drain. Note oil barrel containers behind the drain and oil residue
surrounding drain.
White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 3 of 21

Photo 5 – outdoor storage tank for shop area runoff as well as discharge from the floor
drain inside of the building. DRC noted that the water in the western most tank (photo
foreground) was extremely oily.

Photo 6 – Shop area used oil tank and Kerosene. Facility reported that the secondary
containment area is designed for the larger (used oil) tank.
White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 4 of 21

Photo 7 – Shop area barrel storage. Note that these barrels do not have open taps and
thus do not require secondary containment.

Photo 8 -- Open sump (storm water discharge point) below the ore storage pad.
Discharge is to the tailings cells. DRC noted that the sump had a large accumulation of
soil/clay inside.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 5 of 21

Photo 9 – Open sump (storm water discharge point) below the ore storage pad.
Discharge is to the tailings cells. DRC noted that the sump had a large accumulation of
soil/clay inside.

Photo 10 – Proposed new vehicle contamination facility storage tanks.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 6 of 21

Photo 11 – Diversion ditch sump, below the new proposed vehicle decontamination area.

Photo 12 – Diversion ditch below the proposed decontamination facility (vehicle wash).
HDPE was left over from cell 4A construction.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 7 of 21

Photo 13 – Fuel tank and pump area, northeast area of facility confines (close to the scale
house). Note secondary containment.

Photo 14 – Fuel tank and pump area, northeast area of facility confines (close to the scale
house).

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 8 of 21

Photo 15 – Current vehicle wash (Decontamination Pad).

Photo 16 – Washwater containment tank (Water discharged here is after recycling of the
water for truck washing/wheel washing).

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 9 of 21

Photo 17 – Wash pad discharge tank (foreground) is used after recycling of water.
Discharge is to the storm water/washwater pond.

Photo 18 – Pulp tank and secondary containment.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 10 of 21

Photo 19 – Area between sulfuric acid tank and water tank has been cleaned and graded.
This area was previously wet, due to previous water handling, and was covered in
vegetation (wetland). Work was conducted per a DRC confirmatory action letter.

Photo 20 – Water tank overflow area. A new discharge line (black PVC) was installed
(photo center partially covered by grass) to discharge directly to the storm
water/washwater pond and prevent surface water accumulations.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 11 of 21

Photo 21 – Area between sulfuric acid tank and water tank has been cleaned and graded.
This area was previously wet, due to previous water handling, and was covered in
vegetation (wetland). Work was conducted per a DRC confirmatory action letter.

Photo 22 – Sulfuric acid tank

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 12 of 21

Photo 23 – Sulfuric acid secondary containment water removal line, newly installed per
DRC comments. Discharge from sulfuric containment is to the storm water/washwater
pond.

Photo 24 – Sulfuric acid tank valves and fittings (note containment area).

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 13 of 21

Photo 25 – Propane tank controls. Denison Mines recently replaced the entire system.

Photo 26 – Storm Water/Wash Water pond (Should be predominantly uncontaminated
water)

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 14 of 21

Photo 27 – Caustic Soda tank and secondary containment.

Photo 28 – Secondary containment area for caustic soda storage. Note the highly
deteriorated concrete, DRC recommended replacement/resurfacing of cement areas.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 15 of 21

Photo 29 – SX building roof drainage. Water accumulation is pumped to the SX
building final tank (thence to cell 1).

Photo 30 – Secondary containment area for caustic soda storage. Note the highly
deteriorated concrete, DRC recommended replacement/resurfacing of cement areas.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 16 of 21

Photo 31 – SX building final tank area (blue door leads to tank). Note white trough for
roof storm water collection (right side of photo).

Photo 32 – Final tank inside of the SX building, discharge to Cell 1. Tanks receives
water from outdoor secondary containment areas surrounding the SX building.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 17 of 21

Photo 33 – Soda Ash tanks and secondary containment.

Photo 34 – Crack in secondary containment (soda ash area north of SX Building).

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 18 of 21

Photo 35 – Alternate feed circuit secondary containment and sump. Sump accumulation
is pumped vertically into the circuit tanks (note black hose in photo).

Photo 36 – Alternate feed circuit secondary containment and sump. Sump accumulation
is pumped vertically into the circuit tanks.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 19 of 21

Photo 37 – Alternate Feed Storage (note yellow over containers background and removed
barrels foreground. The barrels are highly deteriorated. Storage location is due south of
the alternate feed circuit, runoff is to the alternate feed secondary storage.

Photo 38 – Alternate Feed Storage (note yellow over containers background and
removed barrels foreground. The barrels are highly deteriorated.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 20 of 21

Photo 39 – Photo of new chemical storage building construction. A building sump will
be installed on the northeast building corner (left foreground of photo). Sump
accumulations will be manually discharged to the tailings cells.

Photo 40 – Large upland diversion ditch, north of cell 1 (outside of fenced facility
confines). Ditch was recently re-graded and is maintained regularly.

White Mesa Mill
DRC Storm Water Inspection, 10/19/2009
Page 21 of 21

Photo 41 – Large upland diversion ditch, north of cell 1 (outside of fenced facility
confines). Ditch is maintained regularly.