DRC-2012-001657 - 0901a068802eebc8

2012-001657
Denison Mines (USA) Corp
105017th Street, Suite 950
Denver, CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
DENISO
MINES
Sent VIA Federal Express
July 13, 2012
Mr Rusty Lundberg
Director of the Utah Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P O Box 144820
Salt Lake City, UT 84114-4820
Re: Transmittal of revised Renewal Application State of Utah Groundwater Quality
Discharge Permit UGW370004 White Mesa Uranium Mill
Dear Mr Lundberg
In September 2009 Denison submitted a Renewal Apphcation, State of Utah Groundwater Quality
Discharge Permit UGW370004 for the White Mesa Uranium Mill DRC requested m e-mail
correspondence dated March 22, 2012 that Denison submit an updated version of the September 1,
2009 renewal application In response to the DRC request, Denison is submitting this updated version
of the September 1, 2009 Renewal Application
Pursuant to DRC e-mail correspondence dated May 15, 2012, the revised Renewal Application is due
to DRC on Monday July 16, 2012 Two hardcopies and 2 word searchable CDs have been sent via
overnight carrier as required
If you should have any questions regarding this report please contact me
Yours very truly.
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Perimtting
CC David C Frydenlund
Harold R Roberts
David E Turk
Kathenne A Weinel
OENISOJ)~~
MINES
Sent VIA Federal Express
July 13, 2012
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-4820
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Re: Transmittal of revised Renewal Application State of Utah Groundwater Quality
Discharge Permit UGW370004 White Mesa Uranium Mill
Dear Mr. Lundberg:
In September 2009 Denison submitted a Renewal Application, State of Utah Groundwater Quality
Discharge Permit UGW370004 for the White Mesa Uranium Mill. DRC requested in e-mail
correspondence dated March 22, 2012 that Denison submit an updated version of the September 1,
2009 renewal application. In response to the DRC request, Denison is submitting this updated version
of the September 1, 2009 Renewal Application.
Pursuant to DRC e-mail correspondence dated May 15,2012, the revised Renewal Application is due
to DRC on Monday July 16, 2012. Two hardcopies and 2 word searchable CDs have been sent via
overnight carrier as required.
If you should have any questions regarding this report please contact me.
~'~
DENISON MINES (USA) CORP.
JoAnn Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Katherine A. Weinel
WHITE MESA URANIUM MILL
RENEWAL APPLICATION
STATE OF UTAH GROUND WATER DISCHARGE
PERMIT No. UGW370004
July 2012
OENISOJ)~~
MINES
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
1.0 INTRODUCTION 5
1.1 Background 5
1.2 Applicable Standards for Review and Approval of this Application 5
1.3 Background Groundwater Reports and Re-opening of Permit 6
1.4 Documents Referenced in This Application 9
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION 13
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A) 13
2.2 Legal Location of the Facility (R317-6-6.3B) 14
2.3 Name and Type of Facility (R317-6-6.3.C) 14
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well,
Drinking Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages,
And Man-Made Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)15
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317 -6-
6.3.E) 15
2.5.1 Groundwater Characteristics 15
2.5.1.1 Geologic Setting 15
2.5.1.2 Hydrogeologic Setting 16
2.5.1.3 Perched Zone Hydrogeology 16
2.5.1.4 Perched Groundwater Flow 20
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The Tailings Cells 21
2.5.2 Groundwater Quality 22
2.5.2.1 Entrada/Navajo Aquifer 22
2.5.2.2 Perched Groundwater Zone 22
2.5.3 Springs and Seeps 23
2.5.4 Topography 24
2.5.5 Soils 24
2.5.6 Bedrock 24
2.5.7 Agricultural and Land Use Description of the Area 25
2.5.8 Well Logs 25
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of
the Effluent or Leachate to be Discharged (R317-6-6.3.F) 26
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate
Into or Adversely Affect the Quality of any Other Waters of the State (R317-6-6.3.G) 27
2.7.1 General 27
1
2.7.2 Cells 1, 2 and 3
2.7.2.1 Design and Construction of Cells 1, 2 and 3
2.7.2.2 Improved Groundwater Monitoring
2.7.2.3 Operational Changes and Improved Operations Monitoring
2.7.2.4 Evaluation of Tailings Cell Cover System Design
2.7.3 Ce1l4A
2.7.4 Ce1l4B
2.7.5 Future Additional Tailings Cells
2.7.6 Roberts Pond
2.7.7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
2.7.7.2 Mill Site Reagent Storage
2.7.7.3 New Construction
2.7.7.4 Other
2.7.8 Surface Waters
2.7.9 Alternate Concentration Limits
27
27
28
29
29
29
32
35
35
35
35
35
36
36
36
36
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information
of the Quality of the Receiving Ground Water (R317-6-6.3.H) 36
2.8.1 Existing Wells at the Time of Original Permit Issuance 37
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit 37
2.9 Sampling and Analysis Monitoring Plan (R317 -6-6.3.1)
2.9.1 Ground Water Monitoring to Determine Ground Water Flow Direction and Gradient,
Background Quality at the Site, and the Quality of Ground Water at the Compliance
38
Monitoring Point 38
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit 38
2.9.1.2 Issuance of the Permit 39
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit 39
2.9.1.4 Groundwater Flow Direction and Gradient 40
2.9.1.5 Background Quality at the Site 40
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point 41
2.9.2 Installation, Use and Maintenance of Monitoring Devices 42
2.9.2.1 Compliance Well Monitoring 42
2.9.2.2 Leak Detection System in Ce1l4A 42
2.9.2.3 Leak Detection System in Cell 4B 42
2.9.2.4 Other DMT Monitoring Requirements 43
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Points 43
2.9.4 Monitoring of the Vadose Zone 44
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring 44
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
44
2.9.5.2 Post-Operational Monitoring
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2
44
44
2.9.6.1 Monitoring Well Construction 44
2.9.6.2 Ground Water Sampling 48
2.9.7 Description and Justification of Parameters to be Monitored 48
2.9.8 Quality Assurance and Control Provisions for Monitoring Data 49
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of
Discharge Systems (R317-6-6.3.J) 49
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-
6-6.3.K) 50
2.11.1 General 50
2.11.2 Background Ground Water Quality in the Perched Aquifer 51
2.11.3 Quality of Ground Water at the Compliance Monitoring Point 57
2.12 Compliance Sampling Plan (R317-6-6.3.L) 57
2.12.1 Tailings Cell Wastewater Quality Sampling Plan 57
2.12.2 White Mesa Seeps and Springs Sampling Plan 58
2.12.3 Monitoring of Deep Wells 59
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M) 59
2.13.1 Surface Water Characteristics 59
2.13.2 Flood Protection Measures 60
2.14 Contingency Plan (R317-6-6.3.N) 60
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting
Failure of the System (R317-6-6.3.0) 60
2.15.1 Existing Tailings Cell Operation 61
2.15.2 Existing Facility DMT Performance Standards 61
2.15.2.1 DMT Monitoring Wells at Cells 1,2 and 3 61
2.15.2.2 Slimes Drain Monitoring 61
2.15.2.3 Maximum Tailings Waste Solids Elevation 62
2.15.2.4 Wastewater Elevation in Roberts Pond 62
2.15.2.5 Inspection of Feedstock Storage Area 62
2.15.2.6 Monitor and Maintain Inventory of Chemicals 63
2.15.3 BAT Performance Standards for Cell4A 63
2.15.3.1 BAT Operations and Maintenance Plan 63
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan 64
2.15.4 BAT Performance Standards for Cell4B 64
2.15.4.1 BAT Operations and Maintenance Plan 64
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan 65
2.15.4.3 Implementation of Monitoring Requirements Under the BAT Operations and
Maintenance Plan 66
2.15.5 Stormwater Management and Spill Control Requirements 67
2.15.6 Tailings and Slimes Drain Sampling 67
3
2.15.7 Additional Monitoring and Inspections Required Under the Mill License
2.15.7.1 Daily Inspections
2.15.7.2 Wee1dy Inspections
2.15.7.3 Monthly Reports
2.15.7.4 Quarterly Tailings Inspections
2.15.7.5 Annual Evaluations
67
68
68
69
69
69
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to
Remedy any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P) 70
2.16.1 Chloroform Investigation 71
2.16.2 Nitrate Investigation 73
2.17 Other Information Required by the Director (R317-6-6.3.Q)
2.17.1 Chemical Inventory Report
2.17.2 Southwest Hydrogeological Investigation
75
75
76
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-
6.3.R) 76
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent
Ground Water Contamination During the Closure and Post Closure Phases of Operation
(R17-6-6.3.S) 76
2.19.1 Regulatory Requirements for Uranium Mills 76
2.19.1.1 Long Term Custodian · 76
2.19.1.2 Responsibility For And Manner Of Clean Up 77
2.19.1.3 Surface 77
2.19.1.4 Groundwater 77
2.19.1.5 License Termination 78
2.19.2 Current Reclamation Plan 78
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan 79
2.19.4 Post-Operational Monitoring 80
3.0 CONCLUSIONS 80
4.0 SIGNATURE AND CERTIFICATIONS 81
5.0 REFERENCES 82
4
Figure No.
1 ....................... .
2 ....................... .
3 ....................... .
4 ....................... .
5 ....................... .
6 ....................... .
7 ....................... .
8 ....................... .
9 ....................... .
10 ....................... .
11 ....................... .
INDEX OF FIGURES
Description
White Mesa Mill Location Map
White Mesa Mill Land Map
Generalized Stratigraphy of White Mesa Mill
Approximate Elevation of Top of Brushy
Basin
Kriged 1st Quarter, 2012 Water Levels White
Mesa Site
Seeps and Springs on USGS Topographic
Base White Mesa
1 st Quarter, 2012 Depths to Perched Water,
White Mesa Site
1 st Quarter, 2012 Perched Water Saturated
Thickness White Mesa Site
Groundwater (Well and Spring) Sampling
Stations in the White Mesa Vicinity
White Mesa Mill Site Plan Showing
Locations of Perched Wells and Piezometers
Mill Site Layout
12...... ........... ....... Drainage Map of the Vicinity of the White
Mesa Mill
13........................ Streamflow Summary Blanding, UT Vicinity
Table No.
2.4-1 .............. .
2.S.2.1-1 ......... .
2.S.3-1 ........... .
2.S.3-2 ........... .
2.S.3-3 ........... .
2.S.3-4 ........... .
2.S.3-S ........... .
2.9.1.3-1 ......... .
2.13.1-1 ........... .
INDEX OF TABLES
Description
Permit Monitoring Wells (Depth and Purpose)
Water Quality of Groundwater in the Mill Vicinity
Results of Quarterly Sampling Ruin Spring (2003-2004)
Results of Annual Sampling Ruin Spring (2009-2011)
Results of Annual Sampling Cottonwood Seep (2009-2011)
Results of Annual Sampling Westwater Seep (2009-2011)
Results of Annual Sampling Entrance Spring (2009-2011)
Groundwater Monitoring Constituents Listed in Table 2 of the
Permit
Drainage Areas of Mill Vicinity and Region
INDEX OF APPENDICES
Appendix Description
A............... ...... San Juan County Plat Maps with Well
Locations
B..................... Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill,
Revision: 0, March 17, 2009
C. . . . . . . . . . . . . . . . . . . . . Results of Soil Analysis at Mill Site
D. . . . . . . . . . . . . . . . . . . . . Tables: Chemical and Radiological
Characteristics of Tailings Solutions, Leak
Detection Systems and Slimes Drains
E............ ......... Cell 4A and 4B BAT Monitoring, Operations
and Maintenance Plan 07111 Revision Denison
2.3
F..................... Stormwater Best Management Practices Plan,
Revision 1.4: October 2011
G..................... White Mesa Mill Tailings Management System
and Discharge Minimization Technology
(DMT) Monitoring Plan, 2/2012, Revision:
Denison-11.5
H...................... White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP)
Date 6/6/2012 Revision 7.2
I...... ......... ........ Tailings and Slimes Drain Sampling Program,
Revision 0, November 20,2008
J..................... ... Contingency Plan, 12/11 Revision: DUSA-4
K....................... White Mesa Mill Containerized Alternate
Feedstock Material Storage Procedure, PBL-
19, Rev.: R-O June 19,2008
L ....................... . Mill Chemical Inventory
1.0 INTRODUCTION
1.1 Background
Denison Mines (USA) Corp. ("Denison,,)1 operates the White Mesa Uranium Mill (the "Mill"),
located approximately six miles south of Blanding, Utah, under State of Utah Ground Water
Discharge Permit No. UGW 370004 (the "Permit"). The Permit was originally issued by the Co-
Executive Secretary of the Utah Water Quality Board on March 8, 2005, for 5 years, expiring on
March 8, 2010, and was up for timely renewal in accordance with Utah Administrative Code
("U AC") R317 -6-6. 7. A renewal application was submitted September 1, 2009. At the request
of the Director of the Utah Division of Radiation Control, Denison is submitting this updated
version of the September 1, 2009 renewal application.
Prior to July 1, 2012, the Director of the Utah Division of Radiation Control ("Director") was
referred to as the Executive Secretary of the Utah Radiation Control and Board Co-Executive
Secretary of the Utah Water Quality Board. Documents referenced in this Application,
published prior to that date, refer to the Director, by one or both of these previous titles.
In accordance with R317 -6-6. 7, this is an updated application (the "Application") to the Director
for renewal of the Permit for another 5-years under R313-6-6.7. In this Application, Denison is
not proposing any modifications to the terms and conditions of the Permit.
The Mill is also subject to State of Utah Radioactive Materials License No. UT 1900479 (the
"Mill License"), which was issued on March 31, 19972 for 10-years and is currently in the
process of timely renewal under R313-22-363, and State of Utah Air Quality Approval Order
DAQE-ANOI12050018-11 (the "Air Approval Order") which was re-issued on March 2, 2011
and is not up for renewal at this time. While the Mill License is referred to in this Application
from time to time in order to allow the Director to better understand Mill operations and
compliance with applicable regulatory requirements, this is not an application for renewal of the
Mill License or Air Approval Order.
1.2 Applicable Standards for Review and Approval of this Application
In accordance with discussions between Denison management and State of Utah Division of
Radiation Control ("DRC") staff on March 12, 2009, this Application includes the information
required under R313-6-6.3.
1 Prior to December 16, 2006, Denison was named "International Uranium (USA) Corporation."
2 The Mill License was originally issued by the United States Nuclear Regulatory Commission ("NRC") as a source
material license under 10 CFR Part 40 on March 31, 1980. It was renewed by NRC in 1987 and again in 1997.
After the State of Utah became an Agreement State for uranium mills in August 2004, the Mill License was re-
issued by the Executive Secretary as a State of Utah Radioactive materials license on February 16,2005, but the
remaining term of the Mill License did not change.
3 A Mill License renewal application was submitted to the Executive Secretary on February 28, 2007, pursuant to
R313-22-36.
5
In accordance with R313-6-6.4C, the Director may issue (or renew) a ground water discharge
permit for an existing facility, such as the Mill, provided:
a) The applicant demonstrates that the applicable class total dissolved solids ("TDS")
limits, ground water quality standards and protection levels will be met;
b) The monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
c) The applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by
facilities that produce similar products or services with similar production process
technology; and
d) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
Since this is an application for renewal of the existing Permit, this Application will focus on any
changes to currently permitted activities since the original date of issuance of the Permit, and on
demonstrating how existing facilities continue to meet applicable regulatory criteria.
Although Denison is not proposing any significant changes to the original Permit, this
Application has nevertheless been performed under the direction, and bears the seal, of a
professional engineer qualified to practice engineering before the public in the state of Utah and
professionally registered as required under the Professional Engineers and Professional Land
Surveyors Licensing Act rules (UAC 156-22).
1.3 Background Groundwater Reports and Re-opening of Permit
In the December 1, 2004 Statement of Basis (the "2004 Statement of Basis") prepared by DRC
in connection with the original issuance of the Permit, three monitoring wells (MW-14, MW-15,
and MW -17) located downgradient of the Mill's tailings cells were found to have long-term
increasing concentration trends for total uranium. These three wells and downgradient well
MW-3, had total uranium concentrations above the Utah Ground Water Quality Standard
("GWQS"), found in UAC R317-6-2 (see the 2004 Statement of Basis, pp. 6-7). These findings
were of concern to the DRC because they appeared to indicate that the tailings cells had possibly
discharged wastewater into the underlying shallow aquifer.
To resolve this concern, the Director required Denison to evaluate groundwater quality data from
the thirteen existing wells on site, and submit a Background Ground Water Quality Report for
Director approval. The existing wells are those wells which were installed prior to the issuance
of the original GWDP on March 8, 2005 and include: MW-1, MW-2, MW-3, MW-5, MW-11,
MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26 (formerly called TW4-15 and
installed as part of the chloroform corrective action order), and MW-32 (formerly called TW4-17
and installed as part of the chloroform corrective action order). It is important to note that MW-4
was installed prior to the issuance of the original permit; however, MW-4 is monitored under the
chloroform program and was not included in the Existing Background Report. GWCLs have not
been established for this well, and MW-4 is not a POC well under the GWDP. One of the
purposes of that report was to provide a critical evaluation of historic groundwater quality data
from the facility, and determine representative background quality conditions and reliable
6
groundwater compliance limits ("GWCLs") for the Permit.
As required, Denison submitted the following reports:
• Revised Background Groundwater Quality Report: Existing Wells For Denison Mines
(USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, October 2007, prepared by
INTERA, Inc. (the "Existing Well Background Report"); and
• Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, November
16,2007, prepared by INTERA, Inc. (the "Regional Background Report").
The Existing Well Background Report and the Regional Background Report included a detailed
quality assurance evaluation of all existing groundwater quality data collected prior to the date of
issuance for the thirteen exiting wells, in accordance with criteria established by DRC and
United States Environmental Protection Agency ("EPA") guidance. This resulted in a data base
suitable for statistical and other analyses. Based on an analysis of this updated data base, the
Existing Well Background Report and Regional Background Report concluded that there have
been no impacts to groundwater from Mill activities, based on a number of factors, including the
following:
• There are a number of exceedances of GWQSs in upgradient and far downgradient wells
at the site, which cannot be considered to have been impacted by Mill operations to date.
Exceedances of GWQSs in monitoring wells nearer to the site itself are therefore
consistent with natural background in the area.
• There are numerous cases of both increasing and decreasing trends in constituents in
upgradient, far downgradient, and Mill site wells, which provide evidence that there are
natural forces at work that are impacting groundwater quality across the entire site.
• In almost all cases where there are increasing trends in constituents in wells at the site,
there are increasing trends in those constituents in upgradient wells. Furthermore, in no
case is there any evidence in the wells in question of increasing trends in chloride, which
is very mobile and a good indicator of potential tailings cell leakage at the site.
See Section 2.11.2 below for a more detailed discussion of the Existing Well Background Report
and Regional Background Report and their conclusions.
The Permit also required nine new monitoring wells to be installed around tailings Cells 1 and 2,
followed by groundwater sampling and analysis, and later submittal of another Background
Ground Water Quality Report to determine reliable background conditions and groundwater
compliance limits for the new wells. The new wells are those wells which were installed after the
issuance of the original GWDP on March 8, 2005 and include: MW-3A, MW-23, MW-24, MW-
25, MW-27, MW-28, MW-29, MW-30, and MW-31. In response to this requirement, Denison
installed the nine new wells, and submitted to the Director a Revised Addendum: --Background
Groundwater Quality Report: New Wells For Denison Mines (USA) Corp. 's White Mesa Mill
7
Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. (the "New Well
Background Report"), and together with the Existing Well Background Report and the Regional
Background Report, are referred to as the "Background Reports").
The New Well Background Report concluded that the sampling results for the new wells confirm
that the groundwater at the Mill site and in the region is highly variable naturally and has not
been impacted by Mill operations and that varying concentrations of constituents at the site are
consistent with natural background variation in the area. See Section 2.11.2 below for a more
detailed discussion of the New Well Background Report and its conclusions.
During the course of discussions with Denison staff, and further DRC review, DRC decided to
supplement the analysis provided in the Background Reports by commissioning the University of
Utah to perform a geochemical and isotopic groundwater study at White Mesa. This resulted in
the University of Utah completing a study entitled Summary of work completed, data results,
interpretations and recommendations for the July 2007 Sampling Event at the Denison Mines,
USA, White Mesa Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and
D. Kip Solomon, Department of Geophysics, University of Utah (the "University of Utah
Study"). The purpose of the University of Utah Study was to determine if the increasing and
elevated trace metal concentrations (such as uranium) found in the monitoring wells at the Mill
were due to potential leakage from the on-site tailings cells. To investigate this potential
problem, the study examined groundwater flow, chemical composition, noble gas and isotopic
composition, and age of the on-site groundwater. Similar evaluations were also made on
samples of the tailings wastewater and nearby surface water stored in the northern wildlife ponds
at the facility. Fieldwork for the University of Utah Study was conducted July 17 -26 of 2007.
The conclusions in the University of Utah Study supported Denison's conclusions in the
Background Reports
As stated above, DUSA prepared Background Reports that evaluated all historic data for the
thirteen existing wells and nine new wells for the purposes of establishing background
groundwater quality at the site and developing GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in these Background Reports, the GWCLs were set on an interim
basis in the GWDP. The interim limits were established as fractions of the state GWQSs for
drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the conclusions and
analysis in the Background Reports. It should be noted, however, that, because the GWCLs have
been set at the mean plus second standard deviation, or the equivalent, un-impacted groundwater
would normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
In addition to the thirteen existing wells and the nine new wells there are an additional 7
monitoring wells at the site which are included in the routine groundwater monitoring program.
Those 7 wells are: MW-20, MW-22, MW-33, MW-34, MW-35, MW-36, and MW-37.
The GWDP dated January 20, 2010 required the completion of eight consecutive quarters of
8
groundwater sampling and analysis of MW-20 and MW-22, and later submittal of another
Background Report to determine if wells MW -20 and MW -22 should be added as point of
compliance (POC) monitoring wells. Data from MW-20 and MW-22 were analyzed in the pre-
operational and regional background addendum (INTERA 2007a); however there was not a
complete data set at the time. Although wells MW-20 and MW-22 were installed in 1994, they
were not sampled regularly until the second quarter of 2008. The eighth full round of sampling
was completed during the first quarter of 2010, and Denison submitted to the Director the
Background Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines
(USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, June 1, 2010, prepared by
INTERA, Inc. (the "MW-20 and MW-22 Background Report"). DRC classified MW-20 and
MW-22 as general monitoring wells, and no GWCLs have been calculated. MW-20 and MW-22
are sampled semiannually.
The GWDP dated June 17, 2012, Part I.R.6 required the installation of three hydraulically
downgradient wells adjacent to Tailings Cell 4B (MW-33, MW-34, and MW-35) prior to
placement of any potential tailings and wastewater in Cell 4B. The purpose of these monitoring
wells was to provide early detection of tailings cell contamination of shallow groundwater from
Tailings Cell 4B. Denison installed MW-33, MW-34, and MW-35 as required. Of these three
wells installed near tailings Ce1l4B, only MW-35 was hydraulically acceptable, with five feet or
more of saturated thickness. MW-35 has been sampled quarterly since fourth quarter 2010 to
collect eight consecutive quarters of data for the completion of the Background Report and
calculation of GWCLs. MW-33 and MW-34 had insufficient water for sampling, with saturated
thicknesses less than five feet. MW-33 is completely dry, and no samples or depth to
measurements are collected from this well. Quarterly depth to water is measured in MW -34, but
no sampling or analysis is required.
Part I.RA of the February 15, 2011 GWDP required the installation of two wells hydraulically
downgradient of Tailings Cell 4B as replacements for MW-33 and MW-34. Denison installed
MW-36 and MW-37 as required. MW-36 and MW-37 have been sampled quarterly since third
quarter 2011 to collect eight consecutive quarters of data for the completion of the Background
Report and calculation of GWCLs.
1.4 Documents Referenced in This Application
The following documents are referenced in this Application and are a part of this Application:
a) The following Permits, Licenses, Statement of Basis, Plans and Related Reports:
(i) State of Utah Ground Water Discharge Permit No. UGW370004 (the "Permit")
dated July 14, 2011;
(ii) State of Utah Radioactive Materials License No. UT 1900479 (the "Mill
License");
(iii) Statement of Basis For a Uranium Milling Facility at White Mesa, South of
Blanding, Utah, Owned and Operated by International Uranium (USA)
9
Corporation, December 1, 2004, prepared by the State of Utah Division of
Radiation Control (the "2004 Statement of Basis");
(iv) Reclamation Plan White Mesa Mill Blanding, Utah, Source Material License No.
SUA-1358 Docket No. 40-8681 Revision 4.0, November 2009 (the "Reclamation
Plan"); and
(v) UMETCO Minerals Corporation: White Mesa Mill Drainage Report for
Submittal to NRC, January 1990;
b) The following Background Groundwater Quality Reports and Related Studies:
(i) Revised Background Groundwater Quality Report: Existing Wells For Denison
Mines (USA) Corp.' s White Mesa Mill Site, San Juan County, Utah, October
2007, prepared by INTERA, Inc. (the "Existing Well Background Report");
(ii) Revised Addendum: --Evaluation of Available Pre-Operational and Regional
Background Data, Background Groundwater Quality Report: Existing Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah,
November 16, 2007, prepared by INTERA, Inc. (the "Regional Background
Report");
(iii) Revised Addendum: --Background Groundwater Quality Report: New Wells For
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah,
April 30, 2008, prepared by INTERA, Inc. (the "New Well Background Report"
and together with the Existing Well Background Report and the Regional
Background Report, the "Background Reports"); and
(iv) Summary of work completed, data results, interpretations and recommendations
for the July 2007 Sampling Event at the Denison Mines, USA, White Mesa
Uranium Mill Near Blanding Utah, May 2008, prepared by T. Grant Hurst and D.
Kip Solomon, Department of Geophysics, University of Utah (the "University of
Utah Study");
(v) Background Groundwater Quality Report for Wells MW-20 and MW-22 for
Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah, June
1, 2010, prepared by INTERA, Inc. (the "MW-20 and MW-22 Background
Report")
c) The following environmental reports and analyses:
(i) Environmental Report, White Mesa Uranium Project San Juan County, Utah,
January 30, 1978, prepared by Dames & Moore (the "1978 ER"); and
10
(ii) Final Environmental Statement related to operation of White Mesa Uranium
Project Energy Fuels Nuclear, Inc., May 1979, Docket No. 40-8681, prepared by
the United States Nuclear Regulatory Commission (the "FES");
d) The following engineering, geological and hydrogeological reports:
(i) Umetco Groundwater Study, White Mesa Facilities, Blanding, Utah, 1993,
prepared by Umetco Minerals Corporation and Peel Environmental Services;
(ii) Hydrogeological Evaluation of White Mesa Uranium Mill, July 1994, prepared by
Titan Environmental Corporation (the "1994 Titan Report");
(iii) Evaluation of Potential for Tailings Cell Discharge -White Mesa Mill, November
23, 1998, prepared by Knight-Piesold LLC;
(iv) Update to report Investigation of Elevated chloroform concentrations in Perched
Groundwater at the White Mesa Uranium Mill Near Blanding, Utah, 2001,
prepared by Hydro Geo Chem, Inc.;
(v) Hydraulic Testing at the White Mesa Uranium Mill Near Blanding, Utah During
July 2002, August 22,2002, prepared by Hydro Geo Chem, Inc.;
(vi) Letter Report dated August 29,2002, prepared by Hydro Geo Chem, Inc.;
(vii) Perched Monitoring Well Installation and Testing at the White Mesa Uranium
Mill April Through June 2005, August 3, 2005, prepared by Hydro Geo Chem,
Inc.;
(viii) Site Hydrogeology and Estimation of Groundwater Travel Times In The Perched
Zone White Mesa Uranium Mill Site Near Blanding, Utah, August 27, 2009,
prepared by Hydro Geo Chem, Inc.;
(ix) Site Hydrogeology and Estimation of Groundwater Travel Times in the Perched
Zone White Mesa Uranium Mill Site Near Blanding, Utah, May 8, 2012, prepared
by Hydro Geo Chem, Inc.;
(x) Hydrogeology of the Perched Groundwater Zone and Associated Seeps and
Springs Near the White Mesa Uranium Mill Site, Blanding Utah, November 12,
2010, prepared by Hydro Geo Chem, Inc.; and
(xi) Hydrogeology of the Perched Groundwater Zone and Associated Seeps and
Springs Near the White Mesa Uranium Mill Site, Blanding Utah, January 12,
2012, prepared by Hydro Geo Chem, Inc.
e) The following plans and specifications relating to construction and operation of the
Mill's tailings cells:
11
(i) Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
(ii) Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by
D' Appolonia Consulting Engineers, Inc.;
(iii) Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia
Consulting Engineers, Inc.;
(iv) Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc.;
(v) Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation;
(vi) Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by Denison (then named
International Uranium (USA) Corporation);
(vii) Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants;
(viii) Cell 4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah,
July 2008, prepared by Geosyntec consultants (disk only);
(ix) Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007,
prepared by Geosyntec Consultants; and
(x) Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants.
t) The following documents relating to the chloroform investigation at the site:
(i) Preliminary Corrective Action Plan, White Mesa Mill Near Blanding, Utah,
August 20,2007, prepared by Hydro Geo Chern, Inc.; and
(ii) Preliminary Contamination Investigation Report, White Mesa Mill Near
Blanding, Utah, November 20, 2007, prepared by Hydro Geo Chern, Inc.
g) The following documents relating to the nitrate and pH/Out of Compliance
investigations at the site:
(i) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
12
and Time Schedule Under part J.G.4 (d) for Violations of Part J.G.2 for
Constituents in the First, Second, Third and Fourth Quarters of 2010 and First
Quarter 2011, June 13,2011;
(ii) White Mesa Mill State of Utah Groundwater Discharge Permit UGW370004 Plan
and Time Schedule Under part J.G.4 (d) for Violations of Part J.G.2 for
Constituents in the Second Quarter of 2011, September 7, 2011;
(iii) Plan and Time Schedule for Assessment of pH Under Groundwater Discharge
Permit UGW370004, April 13, 2012 prepared by Hydro Geo Chern, Inc;
(iv) Stipulated Consent Agreement Docket No. UGW12-03 between Denison Mines
(USA) Corp. and the Director of the Division of Radiation Control, July 12, 2012.
(v) Revised Tolling Agreement, Revision 3, between DUSA and the Director,
Revision 2, dated August 21, 2011.
(vi) Revised Phase 1 (A through C) Work Plan and Schedule for Phase 1 A - C
Investigation, May 11,2011, prepared by INTERA, Inc;
(vii) Revised Phase 2 through 5 Work Plan and Schedule, June 3, 2011, prepared by
INTERA, Inc;
(viii) Revised Phase 2 QAP and Work Plan, Revision 2.0, July 12,2011; and
(ix) Nitrate Corrective Action Plan, May 7,2012, prepared by Hydro Geo Chern, Inc;.
2.0 INFORMATION PROVIDED IN SUPPORT OF THE APPLICATION
2.1 Name and Address of Applicant and Owner (R317-6-6.3.A)
The Applicant is Denison Mines (USA) Corp. ("Denison"). Denison is the current holder of the
Permit. The Mill is owned by Denison's affiliate, Denison White Mesa LLC ("DWM").
The address for both Denison and DWM is:
1050 1 i h St. Suite 950
Denver, CO 80265
Telephone: [phone]
Fax: [phone]
Contacts at Denison, all located at the foregoing office:
Harold R. Roberts, Executive Vice President, US Operations.
Direct telephone: [phone]
hroberts @denisonmines.com
13
David C. Frydenlund
Vice President, Regulatory Affairs and General Counsel
Direct telephone: [phone]
[e-mail]
JoAnn Tischler
Director, Compliance and Permitting
Direct telephone: [phone]
[e-mail]
2.2 Legal Location of the Facility (R317-6-6.3B)
The Mill is regionally located in central San Juan County, Utah, approximately 6 miles (9.5 km)
south of the city of Blanding. The Mill can be reached by taking a private road for
approximately 0.5 miles west of Utah State Highway 191. See Figure 1.
Within San Juan County, the Mill is located on fee land and mill site claims, covering
approximately 5,415 acres, encompassing all or part of Sections 21, 22, 27, 28, 29, 32, and 33 of
T37S, R22E, and Sections 4, 5, 6, 8, 9, and 16 of T38S, R22E, Salt Lake Base and Meridian.
See Figure 2.
All operations authorized by the Mill License are conducted within the confines of the existing
site boundary. The milling facility currently occupies approximately 50 acres, and the tailings
disposal cells encompass another 250 acres. See Figure 2.
2.3 Name and Type of Facility (R317-6-6.3.C)
The name of the facility is the White Mesa Uranium Mill. The facility is a uranium milling and
tailings disposal facility, which operates under a Radioactive Materials License issued by the
Director of the Utah Division of Radiation Control under UAC R313-24. In addition to uranium
in the form of U30 8, the Mill also produces vanadium, in the form of vanadium pentoxide
(V20 S), ammonia metavanadate (AMV) and vanadium pregnant liquor (VPL) , from certain
conventional ores and has produced other metals from certain alternate feed materials. Alternate
feed materials are uranium bearing materials other than conventionally mined ores.
Construction of the Mill was completed and first operations commenced in May 1980. The Mill
does not have a set operating life, and can operate indefinitely, subject to available tailings
capacity and license and permit renewals. The conceptual and permitted total capacity is for the
quantity of Mill tailings produced from a 15-year operating period at a rate of 2,000 tons per day,
operating 340 days per year. Since it commenced operations in 1980, the Mill has operated on a
campaign basis, processing conventional ores and alternate feed materials as they become
available and as economic conditions warrant.
14
2.4 A Plat Map Showing All Water Wells, Including The Status And Use Of Each Well, Drinking
Water Source Protection Zones, Topography, Springs, Water Bodies, Drainages, And Man-Made
Structures Within A One-Mile Radius Of The Discharge. (R317-6-6.3.D)
There are five deep wells within a one mile radius of the Mill, two of which supply the Mill
facility. There are no Drinking Water Source Protection Zones or ordinances within this radius.
Routine groundwater monitoring wells have been established for monitoring under the Permit.
These monitoring wells are depicted on Figure 4 and have been plotted on San Juan County,
Utah plat maps in Appendix A to this Application. The depth and purpose of each of these
wells is as shown in Table 2.4-1.
See Section 2.9.1.3 below for a detailed description of the Mill's groundwater monitoring
program.
The surface topography within this one mile zone is relatively flat, and man-made structures are
limited to the Mill facilities. See Sections 2.5.4 and 2.5.7 below for a more detailed discussion
on local topography and land use.
The Mill area has several dry drainages, and the only nearby natural water bodies within one
mile are Westwater Creek, Corral Creek and Cottonwood Creek. In addition to these are Ruin
Spring and several other springs and seeps located within a 1.5 mile radius of the Mill. See
Sections 2.5.3 and 2.13 below for discussions relating to seeps and springs in the vicinity of the
site and to surface water and drainages, respectively.
2.5 Geologic, Hydrologic, and Agricultural Description of the Geographic Area (R317-6-6.3.E)
2.5.1 Groundwater Characteristics
This Section is excerpted from the Report entitled: Site Hydrogeology and Estimation of
Groundwater Travel Times In The Perched Zone White Mesa Uranium Mill Site Near Blanding,
Utah, July 10, 2012, prepared by Hydro Geo Chern, Inc. ("HGC") (the "2012 HGC Report"
referred to as HGC, 20 12b), a copy of which accompanies this Application.
2.5.1.1 Geologic Setting
The Mill is located within the Blanding Basin of the Colorado Plateau physiographic province.
Typical of large portions of the Colorado Plateau province, the rocks underlying the site are
relatively undeformed. The average elevation of the site is approximately 5,600 ft (1,707 m)
above mean sea level (amsl).
The site is underlain by unconsolidated alluvium and indurated sedimentary rocks consisting
primarily of sandstone and shale. The indurated rocks are relatively flat lying with dips generally
less than 3°. The alluvial materials consist mostly of aeolian silts and fine-grained aeolian sands
with a thickness varying from negligible to as much · as 25 to 30 feet across the site. In some
portions of the site the alluvium is underlain by a few feet to as much as 30 feet of Mancos
Shale. In other areas, the Mancos Shale is absent. The alluvium and Mancos (where present) are
underlain by the Dakota Sandstone and Burro Canyon Formation, which are sandstones having a
combined total thickness ranging from approximately 55 to 140 feet (17 to 43 m). Beneath the
Burro Canyon Formation lies the Morrison Formation, consisting, in descending order, of the
15
Brushy Basin Member, the Westwater Canyon Member, the Recapture Member, and the Salt
Wash Member. The Brushy Basin and Recapture Members of the Morrison Formation, classified
as shales, are very fine-grained and have a very low permeability. The Brushy Basin Member is
primarily composed of bentonitic mudstone, siltstone, and claystone. The Westwater Canyon and
Salt Wash Members are primarily sandstones but are expected to have a low average vertical
permeability due to the presence of interbedded shales. See Figure 3 for a generalized
stratigraphic column for the region.
Beneath the Morrison Formation lies the Summerville Formation, an argillaceous sandstone with
interbedded shales, and the Entrada Sandstone. Beneath the Entrada lies the Navajo Sandstone.
The Navajo and Entrada Sandstones constitute the primary aquifer in the area of the site. The
Entrada and Navajo Sandstones are separated from the Burro Canyon Formation by
approximately 1,000 to 1,100 feet (305 to 355 m) of materials having a low average vertical
permeability. Groundwater within this system is under artesian pressure in the vicinity of the site,
is of generally good quality, and is used as a secondary source of water at the site.
2.5.1.2 Hydrogeologic Setting
The site is located within a region that has a dry to arid continental climate, with average annual
precipitation of approximately 13.3 inches, and an average annual lake evaporation rate of
approximately 47.6 inches. Recharge to the principal aquifers (such as the NavajolEntrada)
occurs primarily along the mountain fronts (for example, the Henry, Abajo, and La Sal
Mountains), and along the flanks of folds such as Comb Ridge Monocline.
Although the water quality and productivity of the NavajolEntrada aquifer are generally good,
the depth of the aquifer (approximately 1,200 feet below land surface [ft bls]) makes access
difficult. The NavajolEntrada aquifer is capable of yielding significant quantities of water to
wells (hundreds of gallons per minute [gpm]). Water in on-site wells completed within the
NavajolEntrada rises approximately 800 feet above the base of the overlying Summerville
Formation.
The shallowest groundwater beneath the site consists of perched water hosted primarily by the
Burro Canyon Formation. Perched water is used on a limited basis to the north (up gradient) of
the site because it is much shallower and more easily accessible than the deep NavajolEntrada
aquifer.
2.5.1.3 Perched Zone Hydrogeology
Perched groundwater originates mainly from precipitation and local recharge sources such as
unlined reservoirs (Kirby, 2008) and is supported within the Burro Canyon Formation by the
underlying, fine-grained Brushy Basin Member. Perched groundwater at the site has a generally
low quality due to high total dissolved solids (TDS) in the range of approximately 1,100 to 7,900
milligrams per liter (mg/L). Generally poor quality is one reason that perched water is used
primarily for stock watering and irrigation in areas up gradient (north) of the site. Figure 4 is a
contour map showing the approximate elevation of the contact of the Burro Canyon Formation
with the Brushy Basin Member, which essentially forms the base of the perched water zone at
the site. Based on Figure 4, the Burro Canyon Formation/Brushy Basin Member contact
generally dips to the south/southwest beneath the site.
16
Figure 5 is a perched groundwater elevation contour map for the first quarter, 2012. Based on the
contoured water levels, groundwater within the perched zone flows generally south to southwest
beneath the site. Beneath the tailings cells, perched groundwater flow is generally to the
southwest.
Perched groundwater discharges from outcrops of the Burro Canyon Formation in seeps and
springs along Westwater Creek Canyon and Cottonwood Canyon (to the west-southwest of the
millsite and tailings cells) and along Corral Canyon (to the east and northeast of the mill site and
tailings cells). Known discharge points include all seeps and springs shown in Figure 5 except
Cottonwood Seep.
As discussed in HGC (20 12b), Cottonwood Seep is located more than 1,500 feet west of White
Mesa in an area where the Dakota Sandstone and Burro Canyon Formation (which hosts the
perched water system) are absent due to erosion, and at an elevation approximately 230 feet
below the base of the perched zone defined by the contact between the Burro Canyon Formation
and the underlying Brushy Basin Member. Cottonwood Seep occurs near the contact between the
slope-forming Brushy Basin Member and the underlying Westwater Canyon (sandstone)
Member.
Contact elevations shown in Figure 4 are based on perched monitoring well drilling and
geophysical logs and surveyed land surface elevations, and the surveyed elevations of Westwater
Seep and Ruin Spring. The elevations of Westwater Seep and Ruin Spring are included because
they occur at the contact between the Burro Canyon Formation and the underlying Brushy Basin
Member (HGC, 2012a).
Groundwater elevations shown in Figure 5 include the surveyed elevations of all seeps and
springs except Cottonwood Seep. As discussed above, no evidence exists to connect Cottonwood
Seep to the perched water system. Although Cottonwood Seep may potentially receive some
contribution from perched water, its occurrence near the contact between the Brushy Basin
Member and the underlying Westwater Canyon Member indicates that its elevation is not
representative of the perched water system.
The permeabilities of the Dakota Sandstone and Burro Canyon Formation at the site are
generally low. No significant joints or fractures within the Dakota Sandstone or Burro Canyon
Formation have been documented in any wells or borings installed across the site (Knight
Piesold, 1998). Any fractures observed in cores collected from site borings are typically
cemented, showing no open space.
Porosities and water contents of the Dakota Sandstone have been measured in samples collected
during installation of former well MW -16 and well MW-17 (Figure 5). MW -16 was located
immediately downgradient of tailings Cell 3 and MW -17 is located south of tailings Cell 4A at a
location primarily cross-gradient with respect to perched water flow. Porosities of the Dakota
Sandstone range from 13.4% to 26%, averaging 20%, and water saturations range from 3.7% to
27.2%, averaging 13.5%. The average volumetric water content is approximately 3%. The
hydraulic conductivity of the Dakota Sandstone based on packer tests in borings installed at the
17
site prior to 1994 ranges from 2.71 x 10-6 centimeters per second (cmls) to 9.12 x 10-4 cmls, with
a geometric average of 3.89 x 10-5 cmls (TITAN, 1994).
The average porosity of the Burro Canyon Formation is similar to that of the Dakota Sandstone.
Based on samples collected from the Burro Canyon Formation at former well MW -16 porosity
ranges from 2% to 29.1 %, averaging 18.3%, and water saturations of unsaturated materials range
from 0.6% to 77.2%, averaging 23.4% (TITAN, 1994).
Extensive hydrogeologic characterization of the saturated Burro Canyon Formation has occurred
through hydraulic testing of perched monitoring wells and borings at the site. Hydraulic testing
of MW-series wells located upgradient, cross-gradient, downgradient, and within the millsite and
tailings cell complex, TW 4-series wells located cross-gradient to upgradient of the mill site and
tailings cells, TWN-series wells located primarily up gradient of the millsite and tailings cells,
and DR-series piezometers indicate that the hydraulic conductivity of the perched zone ranges
from approximately 3 x 10-8 to 0.01 cmls.
Hydraulic testing of wells MW-1, MW-3, MW-5, MW-17, MW-18, MW-19, MW-20, MW-22,
MW-23, MW-25, MW-27, MW-28, MW-29, MW-30, MW-31, MW-32, MW-35, MW-36, and
MW -37 (Figure 5), located upgradient, cross-gradient, downgradient, and within the area of the
tailings cell complex at the site, yielded hydraulic conductivities ranging from approximately 2 x
10-7 cmls to 1 x 10-3 cmls (HGC, 2002; HGC, 2005; HGC, 2010b; and HGC, 2011a) Hydraulic
testing of MW-11 and MW-14 (located within and immediately down gradient of the tailings cell
complex) yielded hydraulic conductivities of approximately 1 x 10-3 cmls and 7 x 10-4 cmls,
respectively.
DR-series piezometers were installed in May, 2011 to investigate perched zone conditions
southwest (downgradient) of the tailings cells (Figure 5). Hydraulic testing of DR-5, DR-8, DR-
9, DR-IO, DR-II, DR-13, DR-14, DR-17, DR-19, DR-20, DR-21, DR-23, and DR-24 (Figure 5)
yielded hydraulic conductivity estimates (based on the KGS slug test analysis of automatically
logged data) ranging from approximately 3 x 10-8 cmls to 4 x 10-4 cmls with a geometric average
of approximately 1 x 10-5 cmls.
27 temporary perched zone chloroform monitoring wells (TW 4-series wells in Figure 5), and 19
temporary perched zone nitrate monitoring wells (TWN -series wells in Figure 5) have been
installed to investigate elevated nitrate concentrations detected initially in MW -4 and some of the
TW 4-series wells. TW 4-series wells are located northeast (up gradient) to east (cross-gradient) of
the tailings cells and TWN-series wells extend to the northeast (upgradient) of the mill site and
tailings cells.
Hydraulic testing of the TWN-series wells yielded hydraulic conductivities ranging from
approximately 4 x 10-7 cmls to 0.01 cmls with a geometric average of approximately 5 x 10-5
cmls (HGC, 2009). Testing of TW4-20, TW4-21, and TW4-22 (HGC, 2005) and TW4-23, TW4-
24, and TW 4-25 (HGC, 2007b) yielded hydraulic conductivities ranging from approximately 4 x
10-5 to approximately 2 x 10-4 cmls. Testing of TW4-4 yielded a hydraulic conductivity of
approximately 1.7 x 10-3 cmls, and testing of TW4-6, TW4-26, and TW4-27 (located
down gradient of TW4-4) yielded hydraulic conductivities ranging from approximately 7 x 10-7
cmls to 2 x 10-5 cmls (HGC, 2010a and HGC, 2011b). Analysis of the draw down data collected
18
during a long-term pumping test conducted at MW-4, TW4-19, and MW-26 using TW4-series
wells as observation wells yielded hydraulic conductivity estimates ranging from approximately
4 x 10-5 cmls to 1 x 10-3 cmls (HGC, 2004).
Some of the coarser-grained and conglomeratic materials encountered within the perched zone
during installation of the TW 4-series wells are believed to be partly continuous with or at least
associated with a relatively thin, relatively continuous zone of higher permeability (International
Uranium [USA] Corporation [!USA] and HGC, 2001). The higher permeability zone defined by
wells completed in the zone is generally located east to northeast of the tailings cells at the site,
and is hydraulically cross-gradient to up gradient of the tailings cells with respect to perched
groundwater flow.
Based on analyses of pumping tests at MW-4 and drilling logs from nearby temporary wells, the
hydraulic conductivity of this relatively thin coarser-grained zone was estimated to be as high as
2.5 x 10-3 cmls. Relatively high conductivities measured at MW-11, located on the southeastern
margin of the down gradient edge of tailings Cell 3, and at MW-14, located on the down gradient
edge of tailings Cell 4A, of 1.4 x 10-3 cmls and 7.5 x 10-4 cmls, respectively (UMETCO, 1993),
may indicate that this zone extends beneath the southeastern portion of the tailings cell complex.
However, based on hydraulic tests, this zone of higher permeability does not appear to exist
within the saturated zone downgradient (south-southwest) of the tailings cells nor to the south of
TW 4-4. The apparent absence of the zone south of TW 4-4 and south-southwest of the tailings
cells suggests that it "pinches out" (HGC, 2007a).
The apparent pinching out of this zone is consistent with hydraulic tests at temporary wells
TW4-6, TW4-26 and TW4-27 (located down gradient of TW4-4), and tests at DR-series
piezometers (located downgradient of the tailings cell complex). As discussed above, the
hydraulic conductivities of TW4-6, TW4-26 and TW4-27 ranged from approximately 7 x 10-7 to
2 X 10-5 cmls, approximately two to three orders of magnitude lower than the conductivity at
TW4-4 (approximately 2 x 10-3 cmls). The hydraulic conductivities of the DR-series piezometers
(based on analysis of automatically logged slug test data using the KGS solution) ranged from
approximately 3 x 10-8 to 4 X 10-4 cmls, (one to five orders of magnitude lower than at MW-11)
with a geometric average of approximately 1 x 10-5 cmls (two orders of magnitude lower than at
MW-11). The effect of this transition from higher to lower permeability is to reduce the rate of
perched water movement south of TW 4-4 and south-southwest of tailings Cell 4A.
The extensive hydraulic testing of perched zone wells at the site indicates that perched zone
permeabilities are generally low with the exception of the apparently isolated zone of higher
permeability associated with the chloroform plume east to northeast (cross-gradient to
upgradient) of the tailings cells. The geometric average hydraulic conductivity (approximately 1
x 10-5 cmls) of the DR-series piezometers which cover an area nearly half the size of the total
monitored area at White Mesa (excluding MW-22), is nearly identical to the geometric average
hydraulic conductivity of 1.01 x 10-5 cmls reported by TITAN (1994), and is within the range of
5 to 10 feet per year (ft/yr) [approximately 5 x 10-6 cmls to 1 x 10-5 cmls] reported by Dames and
Moore (1978) for the (saturated) perched zone during the initial site investigation.
19
Because of the generally low permeability of the perched zone beneath the site, well yields are
typically low (less than 0.5 gpm), although sustainable yields of as much as 4 gpm (for example,
at TW4-19, shown in Figure 5) are possible in wells intercepting the relatively large saturated
thicknesses within the higher permeability zone located east to northeast (cross-gradient to
up gradient) of the tailings cells at the site. Sufficient productivity can generally be obtained only
in areas where the saturated thickness is greater, which is one reason that the perched zone has
been used on a limited basis as a water supply to the north (up gradient) of the site.
2.5.1.4 Perched Groundwater Flow
Perched groundwater flow at the site has historically been to the south/southwest. Figure 5
groundwater elevations indicate that beneath and south of the tailings cells, in the west central
portion of the site, perched water flow is south-southwest to southwest. Flow on the western
margin of White Mesa is generally south, approximately parallel to the mesa rim (where the
Burro Canyon Formation [and perched zone] is terminated by erosion). On the eastern side of the
site perched water flow is also generally southerly. Near the wildlife ponds, flow direction ranges
locally from westerly (west of the ponds) to easterly (east of the ponds) resulting in a generally
north-south perched water divide along a line connecting the ponds. Cones of depression result
from pumping of wells MW-4, TW4-4, TW4-19, TW4-20, and MW-26. These wells are pumped
to reduce chloroform mass in the perched zone east and northeast of the tailings cells.
In general, perched groundwater elevations have not changed significantly at most of the site
monitoring wells since installation, except in the vicinity of the wildlife ponds and the pumping
wells. For example, relatively large increases in water levels occurred between 1994 and 2002 at
MW -4 and MW -19, located in the east and northeast portions of the site, as discussed in HGC
(2007a). These water level increases in the northeastern and eastern portions of the site are the
result of seepage from wildlife ponds located near piezometers PIEZ-1 through PIEZ-5 shown in
Figure 5, which were installed in 2001 for the purpose of investigating these changes. The
mounding associated with the wildlife ponds and the general increase in water levels in the
northeastern portion of the site have resulted in a local steepening of groundwater gradients over
portions of the site. Conversely, pumping of wells MW-4, TW4-4, TW4-19, TW4-20, and MW-
26 has depressed the perched water table locally and reduced average hydraulic gradients to the
south and southwest of these wells.
As discussed above, perched water discharges in springs and seeps along Westwater Creek
Canyon and Cottonwood Canyon to the west-southwest of the site, and along Corral Canyon to
the east of the site. The known discharge points located directly down gradient of the tailings
cells are Westwater Seep and Ruin Spring. These features are located more than 2,000 feet west-
southwest and more than 9,000 feet south-southwest of the tailings cells at the site as shown in
Figure 5.
DR-8, located approximately 4,000 feet southwest of the tailings cells, is located near the mesa
rim above Cottonwood Seep along a line between the tailings cells and Cottonwood Seep.
Although there is no evidence to connect Cottonwood Seep to the perched water system, under
hypothetical conditions that Cottonwood Seep receives some contribution from perched water,
perched water passing beneath the tailings cells would presumably pass by DR-8 before
continuing on an unidentified potential pathway toward Cottonwood Seep.
20
Figure 6 shows perched water pathlines southwest of the tailings cells based on first quarter,
2012 perched water level data. Paths 1 and 3 represent the shortest pathlines to discharge points
Westwater Seep and Ruin Spring, respectively. Path 2 is the shortest pathline to DR-8, located
near the edge of the mesa above Cottonwood Seep. A potential pathline is drawn from DR-8 to
Cottonwood Seep. Westwater Seep is down gradient of tailings Cell 1 and the western portions
of Cells 2, 3, and 4B. DR-8 is down gradient of tailings Cells 2, 3 and 4B. Ruin Spring is
downgradient of CeIl4A, and the eastern portions of Cells 2,3, and 4B.
2.5.1.5 Perched Zone Hydrogeology Beneath And Downgradient Of The Tailings Cells
The perched zone hydrogeology southwest (downgradient) of the tailings cells is similar to other
areas of the site except that the saturated thicknesses are generally smaller, portions of the
perched zone are dry, and hydraulic gradients and hydraulic conductivities are relatively low.
The combination of shallow hydraulic gradients, relatively low permeabilities, and small
saturated thicknesses, results in rates of perched water movement that are among the lowest on-
site.
In the immediate vicinity of the tailings cells, perched water was encountered at depths of
approximately 51 to 115 ft below the top orcasing ("btoc") as of the first quarter of 2012 (Figure
7). Beneath tailings Cell 3, depths to water ranged from approximately 68 feet in the eastern
portion of the cell, to approximately 115 ft btoc at the southwest margin of the cell. Assuming an
average depth of the base of tailings Cell 3 of 25 feet below grade, this corresponds to perched
water depths of approximately 43 to 90 feet below the base of the cell, and an average depth of
approximately 67 feet beneath the base of the cell.
Beneath tailings Cell 4B, depths to water ranged from approximately 106 ft btoc in the
northeastern portion of the cell (at MW-5), to approximately 112 ft btoc at the southwest margin
of the cell (at MW-35). Assuming an average depth of the base of tailings Cell 4B of 25 feet
below grade, this corresponds to perched water depths of approximately 81 to 87 feet below the
base of the cell, and an average depth of approximately 84 feet beneath the base of the cell.
The saturated thickness of the perched zone in the immediate vicinity of the tailings cells as of
the first quarter of 2012 ranges from approximately 83 feet to negligible (Figure 8). Beneath
tailings Cell 3, the saturated thickness varies from approximately 59 feet in the eastern portion of
the cell to approximately 7 feet in the western portion of the cell. Beneath tailings Cell 4B, the
saturated thickness varies from approximately 21 feet in the southeastern portion of the cell to
negligible in the southwestern portion of the cell, where a dry zone, defined by MW-33 and
former (historically dry) well MW -16, is present.
Saturated thicknesses in the southwest area of the site are affected by a ridge-like high in the
Burro Canyon FormationIBrushy Basin Member contact. The influence of this paleoridge is
discussed in HOC (2012a). As shown in Figures 5 and 8 dry conditions or low saturated
thickness conditions are associated with this paleoridge.
South-southwest of the tailings cells, the saturated thickness ranges from negligible at MW-21
(historically dry) to approximately 25 feet at DR-9. Small saturated thicknesses (less than 3 feet)
near DR-6, DR-7, and DR-9 (west and southwest of Cell 4B) result from this paleoridge. The
21
average saturated thickness based on measurements at MW-37, DR-13, MW-3, MW-20, and
DR-21, which lay close to a line between the southeast portion of tailings Cell 4B and Ruin
Spring, is approximately 8 feet. The average saturated thickness based on measurements at MW-
35, DR-7, and DR-6, which are the points closest to a line between the southeast portion of
tailings Cell 3 and Westwater Seep, is approximately 5 feet.
Site-wide, perched zone hydraulic gradients as of the first quarter of 2012 range from a
maximum of approximately 0.07 feet per foot (ft/ft) east of tailings Cell 2 to approximately
0.001 ft/ft in the northeastern portion of the site (between TWN-15 and MW-1). Hydraulic
gradients in the southwest portion of the site are typically close to 0.01 ft/ft, but the gradient is
less than 0.005 ft/ft west/southwest of tailings Cell 4B, between Cell 4B and DR-8. The
hydraulic gradient between the west dike of tailings Cell 3 and Westwater Seep is approximately
0.0122 ft/ft, and between the south dike of tailings Cell 4B and Ruin Spring, approximately
0.0118 ft/ft
2.5.2 Groundwater Quality
2.5.2.1 Entrada/Navajo Aquifer
The Entrada and Navajo Sandstones are prolific aquifers beneath and in the vicinity of the site.
Water wells at the site are screened in both of these units, and therefore, for the purposes of this
discussion, they will be treated as a single aquifer. Water in the Entrada/Navajo Aquifer is under
artesian pressure, rising 800 to 900 ft above the top of the Entrada's contact with the overlying
Summervillle Formation; static water levels are 390 to 500 ft below ground surface.
Within the region, this aquifer is capable of yielding domestic quality water at rates of 150 to 225
gpm, and for that reason, it serves as a secondary source of water for the Mill. Additionally, two
domestic water supply wells drawing from the Entrada/Navajo Aquifer are located 4.5 miles
southeast of the Mill site on the Ute Mountain Ute Reservation. Although the water quality and
productivity of the NavajolEntrada aquifer are generally good, the depth of the aquifer (>1,000 ft
bls) makes access difficult.
Table 2.5.2.1-1 is a tabulation of groundwater quality of the Navajo Sandstone aquifer as
reported in the FES and subsequent sampling. TDS ranges from 244 to 1,110 mg/liter in three
samples taken over a period from January 27, 1977, to May 4, 1977. High iron (0.057 mg/liter)
concentrations are found in the Navajo Sandstone. Because the Navajo Sandstone aquifer is
isolated from the perched groundwater zone by approximately 1,000 to 1,100 ft of materials
having a low average vertical permeability, sampling of the Navajo Sandstone is not required
under the Mill's previous NRC Point of Compliance monitoring program or under the Permit.
However, samples were taken at two other deep aquifer wells (#2 and #5) on site (See Figure 9
for the locations of these wells), on June 1, 1999 and June 8, 1999, respectively, and the results
are included in Table 2.5.2.1-1.
2.5.2.2 Perched Groundwater Zone
Perched groundwater in the DakotalBurro Canyon Formation is used on a limited basis to the
north (upgradient) of the site because it is more easily accessible. The quality of the Burro
Canyon perched water beneath and down gradient from the site is poor and extremely variable.
22
The concentrations of TDS measured in water sampled from up gradient and downgradient wells
range between approximately 600 and 5,300 mg/1. Sulfate concentrations measured in three
up gradient wells varied between 670 and 1,740 mg/l (1994 Titan Report). The perched
groundwater therefore is used primarily for stock watering and irrigation. The saturated
thickness of the perched water zone generally increases to the north of the site. See the Section
2.11.2 below for a more detailed discussion of background ground water quality in the perched
aquifer.
2.5.3 Springs and Seeps
As discussed in Section 2.5.1.4, perched groundwater at the Mill site discharges in springs and
seeps along Westwater Creek Canyon and Cottonwood Canyon to the west-southwest of the site,
and along Corral Canyon to the east of the site, where the Burro Canyon Formation outcrops.
Water samples have been collected and analyzed from springs and seeps in the Mill vicinity as
part of the baseline field investigations reported in the 1978 ER (See Table 2.6-6 in the 1978
ER).
During the period 2003-2004, Denison implemented a sampling program for seeps and springs in
the vicinity of the Mill which had been sampled in 1978, prior to the Mill's construction. Four
locations were designated for sampling, which are shown on Figure 9. These are Ruin Spring
(03R), Cottonwood Seep (04R), west of Westwater Creek (05R) and Corral Canyon (OlR).
During the 2-year study period only two of the four locations were able to be sampled, Ruin
Spring and Cottonwood Canyon. The other two locations, Corral Creek and the location west of
Westwater Creek were not flowing (seeping), and samples could not be collected. With regard
to the Cottonwood seep, while water was present, the volume was not sufficient to complete all
determinations, and only organic analyses were conducted. The results of the organic analysis
did not detect any detectable organics.
Samples at Ruin Spring were analyzed for major ions, physical properties, metals, radionuclides,
volatile and semi-volatile organic compounds, herbicides and pesticides, and synthetic organic
compounds. With the exception of one chloromethane detection, all organic determinations were
at less than detectable concentrations. The detection of chloromethane is not uncommon in
groundwater and can be due to natural sources. In fact, chloromethane has been observed by
Denison at detectable concentrations in field blank samples during routine groundwater sampling
events. The results of sampling for the other parameters tested are shown in Table 2.5.3-1. The
results of the 2003/2004 sampling did not indicate the presence of mill derived groundwater
constituents and are representative of background conditions.
As required by Part I.E.6 of the Permit, the Mill has implemented a Sampling Plan for Seeps and
Springs. Per Part I.E.6 of the Permit, sampling of seeps and springs in required annually. A
copy of the approved Sampling Plan for Seeps and Springs Revision 0, dated March 17, 2009, is
included as Appendix B to this Application. Denison submitted Revision 1.0 on June 10, 2011.
Revision 1.0 is currently undergoing review by the Director. See Section 2.12.2 below for a
more detailed description of the Plan. The first sampling under the Plan was completed in
August, 2009. A summary of sampling results from the 2009, 2010, and 2011 sampling events,
performed under the approved Sampling Plan for Seeps and Springs, is provided in Table 2.5.3-2
through Table 2.5.3-5.
23
2.5.4 Topography
The Mill site is located on a gently sloping mesa that, from the air, appears similar to a
peninsula, as it is surrounded by steep canyons and washes and is connected to the Abajo
Mountains to the north by a narrow neck of land. On the mesa, the topography is relatively flat,
sloping at less than one (1) percent to the south and nearly horizontal from east to west. See also
Figure 6.
2.5.5 Soils
The majority (99%) of the soil at the Mill site consists of the Blanding soil series (1978 ER,
Section 2.10.1.1). The remaining 1 % of the site is in the Mellenthin soil series. Because the
Mellenthin soil occurs only on the eastern-central edge of the site (1978 ER, Plate 2.10-1), the
PES (Section 2.8) concluded that it should not be affected by Mill construction and operation.
The Mill and associated tailings cells are located on Blanding silt loam, a deep soil formed from
wind-blown deposits of fine sands and silts. Although soil textures are predominantly silt loam,
silty-clay-loam textures are found at some point in most profiles (See Appendix C to this
Application -Results of Soil Analysis at Mill Site). This soil generally has a 4 to 5 inch reddish-
brown, silt-loam A horizon and a reddish-brown, silt-loam to silty-clay-Ioam B horizon. The B
horizon extends downward about 12 to 16 inches where the soil then becomes calcareous silt-
loam or silty-clay-loam, signifying the C horizon. The C horizon and the underlying parent
material are also reddish-brown in color.
The A and B horizon both are non-calcareous with an average pH of about 8.0, whereas the C
horizon is calcareous with an average pH of about 8.5. Subsoil sodium levels range up to 12% in
some areas, which is close to the upper limit of acceptability for use in reclamation work (1978
ER, Sect. 2.10.1.1). Other elements, such as boron and selenium, are well below potentially
hazardous levels. Potassium and phosphorus values are high in this soil (1978 ER, Table 2.10-2)
and are generally adequate for plant growth. Nitrogen, however, is low (1978 ER, Sect. 2.10.1.1)
and may have to be provided for successful revegetation during final reclamation.
With well-drained soils, relatively flat topography (see Section 2.5.4), and limited annual
precipitation (see Section 2.5.1.2), the site generally has a low potential for water erosion.
However, the flows resulting from thunderstorm activity are nearly instantaneous and, without
the Mill's design controls, could result in substantial erosion. When these soils are barren, they
are considered to have a high potential for wind erosion. Although the soil is suitable for crops,
the low percentage of available moisture (6 to 9%) is a limiting factor for plant growth;
therefore, light irrigation may be required to establish native vegetation during reclamation.
2.5.6 Bedrock
Subsurface conditions at the Mill site area were investigated as part of the 1978 ER by drilling,
sampling, and logging a total of 28 borings which ranged in depth from 6.5 to 132.4 ft. Of these
borings, 23 were augured to bedrock to enable soil sampling and estimation of the thickness of
the soil cover. The remaining 5 borings were drilled through bedrock to below the perched water
table, with continuous in situ permeability testing where possible and selective coring in
24
bedrock. The soils encountered in the borings were classified, and a complete log for each
boring was maintained. See Appendix A of Appendix H of the 1978 ER.
Borings in the footprint of the existing tailings cells reported calcareous, red-brown sands and
silts from the surface to a depth of 15 ft, averaging over 7 ft. Borings in the general area of the
Mill site and the tailings cells reported calcareous, red-brown sands and silts from the surface to
a depth of 14 ft, averaging over 9 ft. Downgradient of the tailings cells, calcareous sands and
silts extend to a depth of 17 ft of the surface. The calcareous silts and sands of the near-surface
soils grade to weathered claystones or weathered sandstones, inter-layered with weathered
claystone and iron staining. At depth, the weathered claystone or weathered clayey sandstone
grade into sandstone with inter-layered bands of claystone, gravel, and conglomerate. Some
conglomerates are cemented with calcareous matrix.
2.5.7 Agricultural and Land Use Description of the Area
Approximately 65.8% of San Juan County is federally owned land administered by the U.S.
Bureau of Land Management, the National Park Service, and the U.S. Forest Service. Primary
land uses include livestock grazing, wildlife range, recreation, and exploration for minerals, oil,
and gas. Approximately 22% of the county is Native American land owned either by the Navajo
Nation or the Ute Mountain Ute Tribe. The area within 5 miles of the Mill site is predominantly
range land owned by residents of Blanding. The Mill site itself, including tailings cells,
encompasses approximately 300 acres.
A more detailed discussion of land use at the Mill site, in surrounding areas, and in southeastern
Utah, is presented in the PES (Section 2.5). Results of archeological studies conducted at the site
and in the surrounding areas as part of the 1978 ER are also documented in the PES (Section
2.5.2.3).
2.5.8 Well Logs
Well/boring logs for wells MW-l, MW-2, MW-3, MW-4 (not a compliance well under the
Permit), MW-5, MW-ll, MW-12, MW-14, MW-15, MW-16 (not a compliance well under the
Permit and abandoned during the construction of Tailings Ce1l4B), MW-17, MW-18, and MW-
19, are included as Appendix A to the 1994 Titan Report. A copy of the 1994 Titan Report was
previously submitted under separate cover.
Lithologic and core logs for wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-
29, MW-30 and MW-31 are included as Appendix A to the Report: Perched Monitoring Well
Installation and Testing at the White Mesa Uranium Mill April Through June 2005, August 3,
2005, prepared by Hydro Geo Chern, Inc. A copy of that Report was previously submitted under
separate cover.
Lithologic and core logs for well MW-26 (previously named TW4-15) and well MW-32
(previously named TW 4-17) are included as Appendix A to the Letter Report dated August 29,
2002, prepared by Hydro Geo Chern, Inc. and addressed to Harold Roberts.
Lithologic and core logs for well MW -33, MW -34 and well MW -35 are included as Appendix A
to the Installation and Hydraulic Testing of Perched Monitoring Wells MW-33, MW-34, and
25
MW-35 at the White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chem,
Inc. October 11, 2010. A copy of that Report was previously submitted under separate cover.
Lithologic and core logs for well MW -36 and well MW -37 are included as Appendix A to the
Installation and Hydraulic Testing of Perched Monitoring Wells MW-36 and MW-37 at the
White Mesa Uranium Mill Near Blanding Utah, prepared by Hydro Geo Chem, Inc. June 28,
2011. A copy of that Report was previously submitted under separate cover.
2.6 The Type, Source, and Chemical, Physical, Radiological, and Toxic Characteristics of the
Effluent or Leachate to be Discharged (R317-6-6.3.F)
The Mill is designed not to discharge to groundwater or surface waters. Instead, the Mill
utilizes tailings and evaporation Cells for disposal of Mill effluents as indicated below:
• Cell 1: -dedicated to evaporation of Mill waste solutions;
• Cell 2: -contains Mill tailings, has an interim cover and is closed to future tailings
disposal;
• Cell 3: -contains Mill tailings and is in the final stages of filling;
• Ce1l4A: -receives Mill tailings and is used for evaporation of Mill solutions; and
• Ce1l4B: -receives Mill tailings and is used for evaporation of Mill solutions.
See Sections 2.7.2 through 2.7.4 below for a more detailed discussion of the Mill's tailings
cells.
The projected chemical and radiological characteristics of tailings solutions were assessed by
Energy Fuels Nuclear, Inc., a predecessor operator of the Mill, and NRC in 1979 and 1980,
respectively. In addition, early samples were assessed by D' Appolonia Engineering as the Mill
started operations to further evaluate and project the character of the solutions. Samples of
tailings after the Mill was fully operational were collected by NRC (1987), DenisonlUDEQ
(2003), Denison (2007), Denison (2008) and Denison (2009). Samples collected in 2003 were
obtained under the oversight of DRC personnel. The Samples collected in 2007 and 2008 were
obtained by Denison on a voluntary basis as the then proposed Tailings and Slimes Drain
Sampling Plan (the "Tailings Sampling Plan") had not been approved by the Director at that
time. The 2009 samples were collected on August 6, 2009 under the approved Tailings
Sampling Plan. Subsequent annual sampling has been performed in August 2010 and 2011
under the approved Tailings Sampling Plan. As of this writing, Denison has submitted
Revision 2.0 of the Tailings Sampling Plan, which is currently undergoing review by the
Director.
The chemical and radiological characteristics of the solutions held in the tailings cells, based on
the sample results described above, are provided in the tables included in Appendix D, which
list the concentration of parameters measured in accordance with the Permit.
There is no active discharge from the tailings Cells; therefore, an estimation of the flow rate
(gpd) is not applicable in this instance. However, when operating at full capacity, the Mill
discharges approximately 2000 tons per day of dry tailings and approximately 600 gpm of
tailings solutions to the Mill's tailings cells.
26
2.7 Information Which Shows that the Discharge can be Controlled and Will Not Migrate Into or
Adversely Mfect the Quality of any Other Waters of the State (R317-6-6.3.G)
2.7.1 General
The Mill has been designed as a facility that does not discharge to groundwater or surface water.
All tailings and other Mill wastes are disposed of permanently into the Mill's tailings system.
Excess waters are disposed of in the tailings cells, where they are subject to evaporation, or re-
processed through the Mill circuit. See Section 2.6.
The Mill was also designed and constructed to prevent runon or runoff of storm water by a)
diverting runoff from precipitation on the Mill site to the tailings cells; and b) diverting runoff
from surrounding areas away from the Mill site.
The Permit therefore does not authorize any discharges to groundwater or surface water, but is
intended to protect against potential inadvertent or unintentional discharges, such as through
potential failure of the Mill's tailings system.
The Mill's tailings system is currently comprised of four tailings cells (Cells 2, 3 4A, and 4B)
and one evaporation pond (Cell 1). Diagrams showing the Mill facility layout, including the
existing tailings cells are included as Figures 10 and 11 to this Application. In addition, the Mill
has a lined catchment basin, used for temporary storage of Mill process upset fluids, known as
"Roberts Pond". Roberts Pond is about 0.40 acres in size, and found approximately 180 feet
west of the Mill building and about 200 feet east of the northeast comer of Cell 1.
The following sections describe the primary Discharge Minimization Technology ("DMT") and
Best Available Technology ("BAT") features of the Mill, which demonstrate that the wastes and
tailings at the Mill can be controlled so that they do not migrate into or adversely affect the
quality of any waters of the State, including groundwater and surface water.
2.7.2 Cells 1, 2 and 3
2.7.2.1 Design and Construction of Cells 1, 2 and 3
Tailings Cells 1, 2 and 3 were each constructed more than 25 years ago. Construction of Cell 2
was completed on May 3, 1980, construction of Cell 1 was completed on June 29, 1981, and
construction of Cell 3 was completed on September 15, 1982.
Each of Cells 1, 2 and 3 are constructed below grade. Each has a single 30 ml PVC flexible
membrane liner ("FML") constructed of solvent welded seams on a prepared sub-base. A
protective soil cover layer was constructed immediately over the FML with a thickness of 12-
inches on the cell floor and 18-inches on the interior sideslope. Immediately below the FML,
each Cell has a nominal 6-inch thick layer of crushed sandstone that was prepared and rolled
smooth as an FML sub-base layer. Beneath this underlay, native sandstone and other foundation
materials were graded to drain to a single low point near the upstream toe of the south cross-
valley dike. Inside this layer, is an east-west oriented pipe to gather fluids at the upstream toe of
the cross-valley dike. The crushed sandstone layer draining to the pipe at the upstream toe of the
dike of the cell was intended to be a leak detection system for each cell. However, because the
27
design of these leak detection systems does not meet current BAT standards, they are not
recognized as leak detection systems in the Permit.
Each of Cells 2 and 3 also has a slimes drain collection system immediately above the FML,
comprised of a nominal 12-inch thick protective blanket layer of soil or comparable material, on
top of which is a network of PVC perforated pipe laterals on a grid spacing interval of about 50-
feet. These pipe laterals gravity drain to a perforated PVC collector pipe which also drains
toward the south dike and is accessed from the ground surface via a non-perforated access pipe.
At cell closure, leachate head inside the pipe network will be removed via a submersible pump
installed inside the access pipe
See Part I.D.1 of the Permit for a more detailed description of the design of Cells 1, 2 and 3.
After review of the existing design and construction and consultation with the State of Utah
Division of Water Quality, the Director determined, in connection with the issuance of the
Permit in 2005, that the DMT required under the groundwater quality protection rules (UAC
R317 -6-6.4( c )(3)) for Cells 1, 2 and 3 that pre-dated those rules will be defined by the current or
existing disposal cell construction, with a few modifications that were included in the Permit (see
page 25 of the 2004 Statement of Basis). These modifications focus on changes in monitoring
requirements, and on improvements to facility closure. The goal of these improvements is to
ensure that potential wastewater losses are minimized and local groundwater quality is protected.
These modifications are described in Sections 2.7.2.2, 2.7.2.3 and 2.7.2.4 below.
2.7.2.2 Improved Groundwater Monitoring
Improvements were made to the Mill's groundwater monitoring network at the time of issuance
of the Permit, to meet the following goals:
a) Early Detection
Three monitoring wells (MW-24, MW-27 and MW-28) were added immediately adjacent to Cell
1, in order to detect a potential release as early as practicable.
b) Discrete Monitoring
In order to individually monitor each tailings cell and to be able to pinpoint the source of any
potential groundwater contamination that may be detected, the Permit required the addition of
three monitoring wells (MW-29, MW-30 and MW-31) between Cells 2 and 3, in addition to the
addition of wells MW-24, MW-27 and MW-28 immediately adjacent to CellI.
The addition of monitoring wells MW-24, MW-27 , MW-28, MW-29, MW-30 and MW-31,
together with the existing monitoring wells at the site provides a comprehensive monitoring
network to determine any potential leakage from Cells 1, 2 and 3. See Figure 4 for a map
showing the locations of the existing compliance monitoring wells for the site.
28
2.7.2.3 Operational Changes and Improved Operations Monitoring
The Permit also required changes to disposal cell operation in order to increase efforts to
minimize potential seepage losses, and thereby improve protection of local groundwater quality.
Examples of these changes are:
c) Maximum Waste and Wastewater Pool Elevation
Part LD.3 of the Permit requires that Denison continue to ensure that impounded wastes and
wastewaters for all of the Mill's tailings Cells and Roberts Pond are held within an FML.
d) Slimes Drain Maximum Allowable Head
Part LD.3(b) of the Permit requires that the Mill provide constant pumping efforts to minimize
the accumulation of leachates over the FML in Cell 2, and upon commencement of dewatering
activities, in Cell 3, and thereby minimize potential FML leakage to the foundation and
groundwater. See the discussion in Section 2.15.2.2 below.
2.7.2.4 Evaluation of Tailings Cell Cover System Design
Denison submitted an Infiltration and Contaminant Transport Modeling ("ICTM") Report,
White Mesa Mill Site, Blanding, Utah, prepared by MWH Americas, Inc., to the Director for
review in November, 2007, in order to fulfill the requirements of Part LH.11 of the Permit. That
report has been reviewed by the Director, and comments were provided to Denison. Denison
addressed those comments and prepared a revised version of the report submitted to the Director
for review in March 2010. As of 2011, the Director had not provided comments on the revised
version of the ICTM report. In 2011, Denison agreed to fund the Director's use of a consulting
firm to review and comment on the revised ICTM Report. Denison received a first round of
interrogatory comments from the Director in March 2012. Denison provided a partial response
to the first round of comments in June 2012. The need for additional sampling, resulting from
the first round of interrogatory comments, required that a portion of the responses be delayed for
submittal after the receipt of additional data. The remainder of the responses to the first round
of interrogatories will be submitted on August 15,2012.
See Section 2.19 below for a more detailed discussion of post-closure requirements for the Mill.
2.7.3 Cell 4A
Construction of Cell 4A was completed on or about November 1989. Cell 4A was used for a
short period of time after its construction for the disposal of raffinates from the Mill's vanadium
circuit. No tailings waste or wastewater had been disposed of in Cell 4A since the early 1990s.
This lack of waste disposal, and exposure of the FML to the elements, caused Cell 4A to fall into
disrepair over the years.
Although the original design of Cell4A was an improvement over the design of Cells 1, 2 and 3
(it had a one-foot thick clay liner under a 40 ml high density polyethylene ("HDPE") FML, with
29
a more elaborate leak detection system), it was constructed in 1989 and did not meet today's
BAT standards.
Cell 4A was re-lined in 2007-2008 and was re-authorized for use in November 2008. With the
reconstruction of Cell 4A, BAT was required, as mandated by Part ID.4 of the Permit and as
stipulated by the Utah Ground Water Quality Regulations at UAC R317-6-6.4(A). With BAT
for Cell 4A, there are also new performance standards that require daily leak detection system
monitoring, weekly wastewater level monitoring, and slimes drain recovery head monitoring.
The BAT monitoring results are required to be reported and summarized in the Routine DMT
and BAT Performance Standard Monitoring Reports. See Section 2.15.3 below for a more
detailed discussion relating to the BAT performance standards and monitoring requirements for
CeIl4A.
Tailings Cell 4A Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part ID.5 of the Permit and consist of
the following:
e) Dikes -consisting of existing earthen embankments of compacted soil, constructed by
a previous Mill operator between 1989-1990, and composed of four dikes, each
including a IS-foot wide road at the top (minimum). On the north, east, and south
margins these dikes have slopes of 3H to IV. The west dike has a slope of 2H to IV.
Width of these dikes varies. Each has a minimum crest width of at least 15 feet to
support an access road. Base width also varies from 89-feet on the east dike (with no
exterior embankment), to 211-feet at the west dike.
f) Foundation -including existing sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cell4A has an average
slope of 1 % that grades from the northeast to the southwest corners.
g) Tailings Capacity -the floor and inside slopes of Cell 4A encompass about 40 acres
and have a maximum capacity of about 1.6 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
h) Liner and Leak Detection Systems -including the following layers, in descending
order:
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell 4A floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System -includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4 A, and drains to a leak
detection sump in the southwest corner. Access to the leak detection sump is via
an 18-inch inside diameter (ID) HDPE pipe placed down the inside slope, located
between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 10 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
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an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML -consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
entire Cell 4A floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
(GCL) composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
i) Slimes Drain Collection System -including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell 4A that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated two-part geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southwesterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ill Schedule 40 perforated PVC slimes drain collection (SDC)
pipe found at the down gradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southwest corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) Slimes Drain Access Pipe -consisting of an I8-inch ill Schedule 40 PVC pipe
placed down the inside slope of Cell 4A at the southwest corner, above the
primary FML. Said pipe then merges with another horizontal pipe of equivalent
diameter and material, where it is enveloped by gravel and woven geotextile that
serves as a cushion to protect the primary FML. A reducer connects the
horizontal I8-inch pipe with the 4-inch SDC pipe. At some future time, a pump
will be set in this I8-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
j) North Dike Splash Pads -three 20-foot wide splash pads have been constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads consist of an extra layer of 60 mil HDPE membrane that has been installed
in the anchor trench and placed down the inside slope of Cell 4A, from the top of the
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dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
k) Emergency Spillway - a concrete lined spillway has been constructed near the
southwestern comer of the west dike to allow emergency runoff from Cell 4A to Cell
4B. At this time, all stormwater runoff and tailings wastewaters not retained in Cells
2, 3, and 4A will be managed and contained in Cell 4B, including the Probable
Maximum Precipitation and flood event.
1) BAT Performance Standards for Tailings Cell4A -Denison shall operate and maintain
Tailings Cell 4A so as to prevent release of wastewater to groundwater and the
environment in accordance with an Operations and Maintenance Plan, as currently
approved by the Director, pursuant to Part I.H.19. At a minimum these performance
standards shall include:
(i) Maximum Allowable Daily Head -on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer,
(iv) Maximum Daily Wastewater Level -to ensure compliance with the minimum
freeboard requirements for Cell 4A, and prevent discharge of wastewaters via
overtopping.
See Part lD.5 of the Permit for a more detailed discussion of the design of Cell 4A. A copy of
the Mill's Cell 4A BAT Monitoring, Operations and Maintenance Plan is attached as Appendix
E to this Application.
2.7.4 Cell 4B
Construction of Cell4B was completed in November 2011.
Tailings Cell 4B Design and Construction was approved by the Director as meeting BAT
requirements. The major design elements are set out in Part lD.12 of the Permit and consist of
the following:
a) Dikes -consisting of newly constructed dikes on the south and west side of the cell,
each including a 20-foot wide road at the top (minimum). The exterior slopes of the
southern and western dikes have slopes of 3H to IV. The interior dikes have slopes of
2H to IV. Limited portions of the Cell 4B interior sidelopes in the northwest corner
and southeast corner of the cell (where the slimes drain and leak detection sump are
located) have a slope of 3H to IV. Width of these dikes varies. The base width of the
southern dike varies from approximately 92 feet at the western end to approximately
190 feet at the eastern end of the dike, with no exterior embankment present on any
other side of the cell.
b) Foundation -including existing sub grade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. The floor of Cell4B has an average
slope of 1 % that grades from the northwest to the southeast corner.
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c) Tailings Capacity -the floor and inside slopes of Cell 4B encompass about 40 acres
and the cell has a maximum capacity 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -including the following layers, in descending
order:
(i) Primary FML -consisting of an impermeable 60 mil HDPE membrane that
extends across both the entire cell floor and the inside side-slopes, and is anchored
in a trench at the top of the dikes on all four sides. The primary FML is in direct
physical contact with the tailings material over most of the Cell 4 B floor area. In
other locations, the primary FML is in contact with the slimes drain collection
system (discussed below).
(ii) Leak Detection System -includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4 B, and drains to a leak
detection sump in the southeast corner. Access to the leak detection sump is via
an I8-inch inside diameter (ID) HDPE pipe placed down the inside slope, located
between the primary and secondary FML liners. At its base this pipe is
surrounded with a gravel filter set in the leak detection sump, having dimensions
of 15 feet by 10 feet by 2 feet deep. In turn, the gravel filter layer is enclosed in
an envelope of geotextile fabric. The purpose of both the gravel and geotextile
fabric is to serve as a filter.
(iii) Secondary FML -consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. This FML also extends across the
entire Cell 4B floor, up the inside side-slopes and is also anchored in a trench at
the top of all four dikes.
(iv) Geosynthetic Clay Liner -consisting of a manufactured geosynthetic clay liner
(GCL) composed of 0.2-inch of low permeability bentonite clay centered and
stitched between two layers of geotextile.
e) Slimes Drain Collection System -including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
(i) Horizontal Strip Drain System -is installed in a herringbone pattern across the
floor of Cell 4B that drains to a "backbone" of perforated collection pipes. These
strip drains are made of a prefabricated two-part geo-composite drain material
(solid polymer drainage strip) core surrounded by an envelope of non-woven
geotextile filter fabric. The strip drains are placed immediately over the primary
FML on 50-foot centers, where they conduct fluids downgradient in a
southeasterly direction to a physical and hydraulic connection to the perforated
slimes drain collection pipe. A series of continuous sand bags, filled with filter
sand cover the strip drains. The sand bags are composed of a woven polyester
fabric filled with well graded filter sand to protect the drainage system from
plugging.
(ii) Horizontal Slimes Drain Collection Pipe System -includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC)
pipe found at the down gradient end of the strip drain lines. This pipe is in turn
overlain by a berm of gravel that runs the entire diagonal length of the cell,
surrounded by a geotextile fabric cushion in immediate contact with the primary
33
FML. In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as the
"backbone" to the slimes drain system and runs from the far northeast corner
downhill to the far southeast corner of Cell 4A where it joins the slimes drain
access pipe.
(iii) Slimes Drain Access Pipe -consisting of an l8-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell4B at the southeast corner, above the primary
FML. Said pipe then merges with another horizontal pipe of equivalent diameter
and material, where it is enveloped by gravel and woven geotextile that serves as
a cushion to protect the primary FML. A reducer connects the horizontal l8-inch
pipe with the 4-inch SDC pipe. At some future time, a pump will be set in this
l8-inch pipe and used to remove tailings wastewaters for purposes of de-watering
the tailings cell.
t) North and East Dike Splash Pads -nine 20-foot wide splash pads have been
constructed on the north and east dikes to protect the primary FML from abrasion and
scouring by tailings slurry. These pads consist of an extra layer of 60 mil HDPE
membrane that has been installed in the anchor trench and placed down the inside slope
of CeIl4B, from the top of the dike, under the inlet pipe, and down the inside slope to a
point 5-feet beyond the toe of the slope.
g) Emergency Spillway - a concrete lined spillway has been constructed near the
southeastern corner of the east dike to allow emergency runoff from Cell 4A into Cell
4B. This spillway is limited to a 6-inch reinforced concrete slab, with a welded wire
fabric installed within its midsection, set directly atop a cushion geotextile placed
directly over the primary FML in a 4-foot deep trapezoidal channel. A 100-foot wide,
60-mil HDPE membrane splash pad is installed beneath the emergency spillway. No
other spillway or overflow structure will be constructed at Cell 4Bunless and until the
construction of Cells 5A and 5B. At this time, all stormwater runoff and tailings
wastewaters not retained in Cells 2, 3, and 4A will be managed and contained in Cell
4B, including the Probable Maximum Precipitation and flood event.
h) BAT Performance Standards for Tailings Cell4B -Denison shall operate and maintain
Tailings Cell 4B so as to prevent release of wastewater to groundwater and the
environment in accordance with the currently-approved Cell 4B BAT, Monitoring,
Operations and Maintenance Plan. At a minimum these performance standards shall
include:
(i) Maximum Allowable Daily Head -on the secondary FML,
(ii) Maximum Allowable Daily Leak Detection System Flow Rate
(iii) Slimes Drain Monthly and Annual Average Recovery Head Criteria -to be
applied after the Mill initiates pumping conditions in the slimes drain layer,
(iv) Maximum Daily Wastewater Level -to ensure compliance with the minimum
freeboard requirements for Cell 4B, and prevent discharge of wastewaters via
overtopping.
See Part I.D.12 of the Permit for a more detailed discussion of the design of CeIl4B. A copy of
the Mill's Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan is attached as
Appendix E to this Application.
34
2.7.5 Future Additional Tailings Cells
Future additional tailings cells at the Mill will require Director approval prior to construction and
operation. All future tailings cells at the Mill will be required to satisfy BAT standards at the
time of construction.
2.7.6 Roberts Pond
Roberts Pond receives periodic floor drainage and other wastewaters from Mill process upsets, is
frequently empty, and was re-lined with a new FML in May, 2002.
In order to minimize any potential seepage release from Roberts Pond, the Director has
determined that an appropriate DMT operations standard would be two-fold, as required by Part
LD.3( e) of the Permit:
(i) A stipulation that the Mill maintain a minimal wastewater head in this pond based on a
2-foot freeboard limit and a I-foot additional operating limit; and
(ii) At the time of Mill site closure, Denison will excavate and remove the liner, berms,
and all contaminated subsoils in compliance with an approved final reclamation plan
under the Mill License.
2.7.7 Other Facilities and Protections
2.7.7.1 Feedstock Storage
In order to constrain and minimize potential generation of contaminated stormwater or leachates,
Part LD.11 of the Permit requires the Mill to continue its existing practice of limiting open air
storage of feedstock materials to the historical storage area found along the eastern margin of the
Mill site (as defined by the survey coordinates found in Permit Table 4); and one of the
following three practices: 1) Store feedstock materials in water-tight contains, or 2) Place
feedstock containers in water-tight overpack containers, or 3) place feedstock containers on a
hardened surface that conforms to the requirements spelled out in the permit part LD.11d) 1
through 5.
2.7.7.2 Mill Site Reagent Storage
In order to prevent potential reagent tank spills or leaks that could release contaminants to site
soils or groundwater, and to provide proper spill prevention and control, Part LD.3(g) of the
Permit requires the Mill to demonstrate that it has adequate provisions for spill response,
cleanup, and reporting for reagent storage facilities, and to include these in a Stormwater Best
Management Practices Plan. Contents of this plan are stipulated in Part LD.8 of the Permit, and
submittal and approval of the plan is required under Part LH.17 of the Permit. For existing
facilities at the Mill, secondary containment is required, although such containment may be
earthen lined. For new facilities constructed at the Mill, or reconstruction of existing facilities,
Part LD.3( e) requires the higher standard of secondary containment that would prevent contact of
any potential spill with the ground surface.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision 1.3: June 12, 2008
is attached as Appendix F to this Application.
35
2.7.7.3 New Construction
Part I.D.4 of the Permit ensures that all construction, modification, or operation of waste or
wastewater disposal, treatment, or storage facilities requires submittal of engineering plans and
specifications and prior Director approval. In these plans and specifications, the Mill is required
to demonstrate how BAT requirements of the Groundwater Quality Protection Rules have been
met. After Director Approval, a construction permit may be issued, and the Permit modified.
2.7.7.4 Other
The White Mesa Mill Tailings Management System and Discharge Minimization Technology
(DMT) Monitoring Plan, 2/12 Revision: Denison-l1.5 (the "DMT Plan"), a copy of which is
attached as Appendix G to this Application, is designed as a systematic program for constant
surveillance and documentation of the integrity of the tailings system including monitoring the
leak detection systems. The Plan requires daily, weekly, quarterly, monthly and annual
inspections and evaluations and monthly reporting to Mill management. See Section 2.15.2
below for a more detailed discussion of the requirements of the DMT Plan.
2.7.8 Surface Waters
The Mill has been designed as a facility that does not discharge to surface waters. All tailings
and other Mill wastes are disposed of permanently into the Mill's tailings system. Further, as
mentioned above, the Mill was designed and constructed to prevent runon or runoff of storm
water by a) diverting runoff from precipitation on the Mill site to the tailings cells; and b)
diverting runoff from surrounding areas away from the Mill site. As a result, there is no pathway
for liquid effluents from Mill operations to impact surface waters.
Under the Mill License, the Mill is required to periodically sample local surface waters to
determine if Mill activities may have impacted those waters. The primary pathway would be
from air particulate from Mill operations that may have landed on or near surface waters, or that
may have accumulated in drainage areas that could feed into surface waters. Sampling results
since inception of Mill operations show no trends or other impacts of Mill operations on local
surface waters. See the Mill's Semi-Annual Effluent Reportfor the period July1 to December 31,
2011, a copy of which has previously been provided to the Director.
2.7.9 Alternate Concentration Limits
The Mill does not discharge to groundwater or surface water, nor is it designed to do so.
Therefore, no alternate concentration limits are currently applicable to the site.
2.8 For Areas Where the Groundwater Has Not Been Classified by the Board, Information of the
Quality of the Receiving Ground Water (R317-6-6.3.H)
Groundwater classification was assigned by the Director in the Permit on a well-by-well basis
after review of groundwater quality characteristics for the perched aquifer at the Mill site. A
well-by-well approach was selected by the Director in order to acknowledge the spatial
variability of groundwater quality at the Mill, and afford the most protection to those portions of
36
the perched aquifer that exhibited the highest quality groundwater. These groundwater
classifications are set out in Part I.A and Table 1 of the Permit.
The primary element used by the Director in determining the groundwater classification of each
monitoring well at the site, is the TDS content of the groundwater, as outlined in UAC 317-6-3.
Groundwater quality data collected by the Mill show the shallow aquifer at the Mill has a highly
variable TDS content, with TDS averages ranging from about 1100 to over 7900 mglL. Another
key element in determination of groundwater class is the presence of naturally occurring
contaminants in concentrations that exceed their respective GWQS. In such cases, the Director
has cause to downgrade aquifer classification from Class II to Class III (see UAC R317-6-3.6).
Using all available TDS data and background data, for 24 of the POC and general monitoring
wells the Director determined that 4 of those wells exhibit Class II drinking water quality
groundwater. The remaining 20 wells exhibited Class III or limited use groundwater at the site.
The Director determined that MW-35 will be classified as having Class II drinking water quality
groundwater until sufficient background data have been collected and the applicable Background
Report is submitted. Wells MW-36 and MW-37 have not been classified at this time.
2.8.1 Existing Wells at the Time of Original Permit Issuance
The Director required Denison to evaluate groundwater quality data from the thirteen existing
wells on site, and submit a Background Ground Water Quality Report for Director approval.
One of the purposes of that report was to provide a critical evaluation of historic groundwater
quality data from the facility, and determine representative background quality conditions and
reliable GWCLs for the Permit.
DUSA prepared the Existing Well Background Report that evaluated all historic data for the
thirteen existing wells for the purposes of establishing background groundwater quality at the
site and developing groundwater compliance limits GWCLs under the GWDP. Prior to review
and acceptance of the conclusions in the Existing Well Background Report, the GWCLs were set
on an interim basis in the GWDP. The interim limits were established as fractions of the state
GWQSs for drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality for the
thirteen existing wells, based primarily on the analysis performed in the Existing Wellis Background
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus
second standard deviation, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.8.2 New Wells Installed After the Date of Original Issuance of the Permit
Because the Permit called for installation of nine new monitoring wells around the tailings cells,
background groundwater quality had to be determined for those monitoring points. To this end,
the Permit required the Mill to collect at least eight quarters of groundwater quality data, and
submit the New Well Background Report for Director approval to establish background
groundwater quality for those wells.
37
DUSA prepared the New Well Background Report that evaluated all historic data for the nine
new wells for the purposes of establishing background groundwater quality at the site and
developing groundwater compliance limits GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in the New Well Background Report, the GWCLs were set on an
interim basis in the GWDP. The interim limits were established as fractions of the state GWQSs
for drinking water, depending on the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed in the New Well background
Report. It should be noted, however, that, because the GWCLs have been set at the mean plus
second standard deviation, or the equivalent, un-impacted groundwater would normally be
expected to exceed the GWCLs approximately 2.5% of the time. Therefore, exceedances are
expected in approximately 2.5% of all sample results, and do not necessarily represent impacts to
groundwater from Mill operations.
2.9 Sampling and Analysis Monitoring Plan (R317-6-6.3.I)
The groundwater monitoring plan is set out in the Permit. All groundwater monitoring at the site
is in the perched aquifer. The following sections summarize the key components of the Mill's
sampling and analysis plan.
2.9.1 Ground Water Monitoring to Determine Ground Water Flow Direction and Gradient,
Background Quality at the Site, and the Quality of Ground Water at the Compliance Monitoring
Point
2.9.1.1 Groundwater Monitoring at the Mill Prior to Issuance of the Permit
At the time of renewal of the Mill license by NRC in March, 1997 and up until issuance of the
Permit in March 2005, the Mill implemented a groundwater detection monitoring program to
ensure compliance to 10 CFR Part 40, Appendix A, in accordance with the provisions of then
Mill License condition 11.3A. The detection monitoring program was in accordance with the
report entitled, Points of Compliance, White Mesa Uranium Mill, prepared by Titan
Environmental Corporation, submitted by letter to the NRC dated October 5, 1994. Under that
program, the Mill sampled monitoring wells MW-5, MW-11, MW-12, MW-14, MW-15 and
MW -17, on a quarterly basis. Samples were analyzed for chloride, potassium, nickel and
uranium, and the results of such sampling were included in the Mill's Semi-Annual Effluent
Monitoring Reports that were filed with the NRC up until August 2004 and with the DRC
subsequent thereto.
Between 1979 and 1997, the Mill monitored up to 20 constituents in up to 13 wells. That
program was changed to the Points of Compliance Program in 1997 because NRC had concluded
that:
• The Mill and tailings system had produced no impacts to the perched zone or deep
aquifer; and
38
• The most dependable indicators of water quality and potential cell failure were
considered to be chloride, nickel, potassium and natural uranium.
2.9.1.2 Issuance of the Permit
On March 8, 200S, the Director issued the Permit, which includes a groundwater monitoring
program that superseded and replaced the groundwater monitoring requirements set out in Mill
License Condition 11.3A. Condition 11.3A has since been removed from the Mill License.
Groundwater monitoring under the Permit commenced in March 200S, the results of which are
included in the Mill's Quarterly Groundwater Monitoring Reports that are filed with the
Director.
On September 1, 2009, Denison filed a Groundwater Discharge Permit Renewal Application.
This document is an amendment and update of the Renewal Application, which is being
submitted at the request of the Director. The Permit remains in timely renewal status awaiting
completion of review of the Renewal Application by the Director.
2.9.1.3 Current Ground Water Monitoring Program at the Mill Under the Permit
The current groundwater monitoring program at the Mill under the Permit, which is used to
determine ground water flow direction and gradient, and quality of the ground water at the
compliance monitoring points, consists of monitoring at 2S point of compliance monitoring
wells: MW-1, MW-2, MW-3, MW-3A, MW-S, MW-11, MW-12, MW-14, MW-1S, MW-17,
MW-18,MW-19,MW-23,MW-24,MW-2S,MW-26,MW-27, MW-28, MW-29, MW-30, MW-
31, MW-32, MW-3S, MW-36, and MW-37. The locations of these wells are indicated on Figure
4. Depth to water is measured quarterly in MW-34, but due to limited water is not sampled for
POC compliance. MW-33 is completely dry and is not sampled for POC compliance.
Part I.E. 1. (d) of the Permit requires that each point of compliance well must be sampled for the
constituents listed in Table 2.9.1.3-1.
Further, Part I.E.1.(d)l) of the Permit, requires that, in addition to pH, the following field
parameters must also be monitored:
• Depth to groundwater
• Temperature
• Specific conductance,
and that, in addition to chloride and sulfate, the following general organics must also be
monitored:
• Carbonate, bicarbonate, sodium, potassium, magnesium, calcium, and total anions and
cations.
Sample frequency depends on the speed of ground water flow in the vicinity of each well. Parts
I.E. 1 (b) and (c) provide that quarterly monitoring is required for all wells where local
groundwater average linear velocity has been found by the Director to be equal to or greater than
39
10 feet/year, and semi-annual monitoring is required where the local groundwater average linear
velocity has been found by the Director to be less than 10 feet/year.
Based on these criteria, quarterly monitoring is required at MW-11, MW-14, MW-25, MW-26
and MW-30, and MW-31, and semi-annual monitoring is required at MW-1, MW-2, MW-3,
MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-24, MW-27, MW-
28, MW-29 and MW-32.
Wells MW-35, MW-36 and MW-37 are also currently being sampled quarterly, to collect eight
consecutive quarters of background data, to enable the Director to establish groundwater
compliance levels for those wells and to determine their frequency of sampling
Prior to the February 15 2011 revision of the GWDP, Denison collected quarterly groundwater
samples from MW-20 and MW-22 for development of background values and potential GWCLs.
Part I.E.1.c).3) in the currently approved July 2011 revision of the GWDP now requires that
MW-20 and MW-22 be monitored on a semi-annual basis as "General Monitoring Wells," but
not subject to GWCLs.
2.9.1.4 Groundwater Flow Direction and Gradient
Part I.E.3 of the Permit requires that, on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1 and described in Section 2.9.1.3 above, the Mill
shall measure depth to groundwater in the following wells and/or piezometers:
i) The point of compliance wells identified in Table 2 of the Permit, as described in
Section 2.9.1.3 above;
j) Piezometers: P-1, P-2, P-3, P-4 and P-5;
k) Existing monitoring wells: MW-20, MW-22, and MW-34;
1) Contaminant investigation wells: any well required by the Director as a part of a
contaminant investigation or groundwater corrective action (at this time this includes
all chloroform and nitrate investigation wells); and
m) Any other wells or piezometers required by the Director.
While it is not a requirement of the GWDP, Denison also measures depth to water in the DR piezometers
which were installed during the Southwest Hydrogeologic Investigation. As a result of these
measurements, the Mill prepares groundwater isocontour maps each quarter that show the
groundwater flow direction and gradient. The isocontour map for the first quarter of 2012 is
attached as Figure 5.
2.9.1.5 Background Quality at the Site
A significant amount of historic groundwater quality data had been collected by Denison and
previous operators of the Mill for many wells at the facility. In some cases these data extend
back more than 30 years to September 1979. A brief summary of some of the various studies
that had been performed prior to the original issuance of the Permit is set out in Section 2.0 of
the Regional Background Report.
40
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. Such an examination needed to include such things as justification of any zero
concentration values reported, adequacy of minimum detection limits provided (particularly with
respect to the corresponding GWQS), adequacy of laboratory and analytical methods used,
consistency of laboratory units or reporting, internal consistency between specific and composite
types of analysis (e.g., major ions and TDS), identification and justification of concentration
outliers, and implications of concentration trends (both temporal and spatial).
As discussed in Section 2.11.2 below, the Director also noted several groundwater quality issues
that needed to be resolved prior to a determination of background groundwater quality at the site.
These were: 1) a number of constituents exceeded their respective GWQS (including nitrate in
one well and manganese, selenium and uranium each in several wells); 2) long term trends in
uranium in downgradient wells MW-14, MW-15 and MW-17; and 3) a spatial high of uranium in
those three down gradient wells. See pages 5-8 of the 2004 Statement of Basis for a more
detailed discussion of these points.
As a result of the foregoing, the Director required that the Background Reports be prepared to
address and resolve these issues.
Further, because background groundwater quality at the Mill site had not yet been approved at
the time of original Permit issuance, the Director was not able to determine if any contaminant is
naturally occurring and therefore detectable or undetectable for purpose of selecting GWCLs in
each well. Consequently, the Director initially assigned GWCLs as if they were "undetectable"
(i.e., assuming that all natural background concentrations were less than a fraction of the
respective GWQS).
As discussed in Section 1.3 above and 2.11.2 below, Denison submitted the Background Reports
to the Director. Both the Existing Well Background Report and the New Well Background
Report provided GWCLs for all of the constituents in the existing wells and new wells,
respectively, based on a statistical intra-well approach. The Director has approved the
Background Reports.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells and the nine new wells based primarily on the analysis performed
in the Background Reports. It should be noted, however, that, because the GWCLs have been set
at the mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
2.9.1.6 Quality of Ground Water at the Compliance Monitoring Point
There are over 30 years of data for some constituents in some wells at the site, but not for all
constituents in any wells. However, with the exception of tin, which was added as a monitoring
constituent in 2007, all currently required monitoring constituents have been sampled in all wells
that were in existence on the date of the original issuance of the Permit commencing with the
41
first quarter of 2005. Further, all constituents in all new compliance monitoring wells have been
sampled upon installation of those wells, commencing either in the second or third quarters of
2005.
All of the analytical results from this sampling are reported quarterly in Groundwater Monitoring
Reports, which are filed with the Director pursuant to Part I.F.l of the Permit.
2.9.2 Installation, Use and Maintenance of Monitoring Devices
Compliance monitoring at the Mill site is accomplished in three ways: the compliance well
monitoring program; monitoring the leak detection system in Cells 4A and 4B; and various DMT
monitoring requirements. Each of these are discussed below.
2.9.2.1 Compliance Well Monitoring
Compliance for tailings Cells 1, 2 and 3 and the remainder of the Mill site, other than Cells 4A
and 4B, is accomplished by quarterly or semi-annual sampling of the network of compliance
monitoring wells at the site. See Figure 4 for a map that shows the compliance monitoring well
locations, and Section 2.9.1.3 for a description of the monitoring program.
2.9.2.2 Leak Detection System in Cell 4A
With the reconstruction of Cell 4A, BAT was required, as mandated in Part I.DA of the Permit
and as stipulated by UAC R317-6-6A(a). Because tailings Cells 1, 2 and 3 were constructed
more than 25 years ago, and after review of the existing design and construction, the Director
determined that DMT rather than BAT is required for Cells 1, 2 and 3 (see the discussion in
Section 2.7.2 above).
BAT for Ce1l4A included the construction of a modern leak detection system. See Section 2.7.3
above for a description of the key design elements of Cell 4A, including its leak detection
system. With BAT for Cell 4A, there are new performance standards in the Permit that require
daily leak detection system monitoring, weekly wastewater level monitoring, and slimes drain
recovery head monitoring. The BAT monitoring results are required to be reported and
summarized in the Routine DMT and BAT Performance Standard Monitoring Reports. See
Section 2.15.3 below for a more detailed discussion of the BAT monitoring requirements for Cell
4A.
Because Ce1l4A has a modern leak detection system that meets BAT standards and is monitored
daily, the leak detection system in Cell 4A can be considered to be a point of compliance
monitoring device.
2.9.2.3 Leak Detection System in Cell4B
BAT was required for Ce1l4B, as mandated in Part I.DA of the Permit and as stipulated by UAC
R317-6-6A(a).
42
See Section 2.7.4 above for a description of the key design elements of Cell 4B, including its
leak detection system. Performance standards for Cell 4B in the Permit require daily leak
detection system monitoring, weekly wastewater level monitoring, and slimes drain recovery
head monitoring. The BAT monitoring results are required to be reported and summarized in the
Routine DMT and BAT Performance Standard Monitoring Reports. See Section 2.15.4 below
for a more detailed discussion of the BAT monitoring requirements for Ce1l4B.
Because Ce1l4B has a modern leak detection system that meets BAT standards and is monitored
daily, the leak detection system in Cell 4B can be considered to be a point of compliance
monitoring device.
2.9.2.4 Other DMT Monitoring Requirements
In addition to the foregoing, the additional DMT performance standard monitoring discussed in
detail in Section 2.15 below is required to be performed under the Permit
2.9.3 Description of the Compliance Monitoring Area Defined by the Compliance Monitoring
Points
The compliance monitoring area at the site is the area covered by the groundwater compliance
monitoring wells. Figure 4 shows the most current locations of the compliance groundwater
monitoring wells at the site.
At the time of original Permit issuance, the Director reviewed the then recent water table contour
maps of the perched aquifer. Those maps identified a significant western component to
groundwater flow at the Mill site, which the Director concluded appeared to be the result of
wildlife pond seepage and groundwater mounding (see page 23 of the 2004 Statement of Basis).
As a consequence, new groundwater monitoring wells were required, particularly along the
western margin of the tailings cells, in addition to the monitoring wells already in existence at
that time. The Director also concluded that new wells were also needed for DMT purposes and
to provide discrete monitoring of each tailings cell. This resulted in the addition of the following
compliance monitoring wells to the then existing monitoring well network: MW-23, MW-24,
MW-25, MW-26 (which was then existing chloroform investigation well TW4-15), MW-27 ,
MW-28, MW-29, MW-30, MW-31 MW-32 (which was then existing chloroform investigation
well TW4-17), MW-35, MW-36, and MW-37. As previously stated MW-33, and MW-34 were
installed but are not currently sampled due to limited water and saturated thickness. MW-20 and
MW-22 are not POC wells but are general monitoring wells and are sampled semiannually for
information purposes only.
Based on groundwater flow direction and velocity, the compliance monitoring network, with the
foregoing additional new wells, was considered to be adequate for compliance monitoring in the
perched aquifer at the site.
Further, as mentioned in Section 2.9.2.2 and 2.9.2.3 above, the leak detection systems in Ce1l4A
and 4B can also be considered to be compliance monitoring areas for these cells.
43
2.9.4 Monitoring of the Vadose Zone
Monitoring is not performed in the vadose zone at the site, and there are no current intentions to
perform any future monitoring in the vadose zone at the site.
2.9.5 Measures to Prevent Ground Water Contamination After the Cessation of Operation,
Including Post-Operational Monitoring
2.9.5.1 Measures to Prevent Ground Water Contamination After the Cessation of Operation
Please see Section 2.19 below for a detailed discussion of the measures to prevent ground water
contamination after the cessation of operations.
2.9.5.2 Post-Operational Monitoring
Groundwater monitoring will continue during the post-operational phase through final closure
until the Permit is terminated. Denison understands that the final closure will take place and the
Permit will be terminated upon termination of the Mill License and transfer of the reclaimed
tailings cells to the United States Department of Energy pursuant to U.S.C. 2113. See Section
2.19.1.1 below.
2.9.6 Monitoring Well Construction and Ground Water Sampling Which Conform Where
Applicable to Specified Guidance
2.9.6.1 Monitoring Well Construction
a) New Wells
All new compliance monitoring wells installed after the original issuance of the Permit were
installed in accordance with the requirements of Part LEA of the Permit. Part LEA requires that
all new groundwater monitoring wells installed at the facility shall comply with the following
design and construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other
potential origin of groundwater pollution;
b) Screened and completed in the shallow aquifer;
c) Designed and constructed in compliance with U AC R317 -6-6.3(1)( 6), including
the EPA RCRA Ground Water Monitoring Technical Enforcement Guidance
Document, 1986, OSWER-9950.1 (the "EPA RCRA TEGD"); and
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
As-built reports for all new groundwater monitoring wells were submitted to the Director for his
approval, in accordance with Part LF.6 of the Permit. Part LF.6 requires those reports to include
the following information:
44
a) Geologic logs that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs were prepared by a
Professional Geologist licensed by the State of Utah or otherwise approved
beforehand by the Director;
b) A well completion diagram that details all physical attributes of the well
construction, including:
1) Total depth and diameters of boring;
2) Depth, type, diameter, and physical properties of well casing and screen,
including well screen slot size;
3) Depth intervals, type and physical properties of annular filterpack and seal
materials used;
4) Design, type, diameter, and construction of protective surface casing; and
5) Survey coordinates prepared by a State of Utah licensed engineer or land
surveyor, including horizontal coordinates and elevation of water level
measuring point, as measured to the nearest 0.01 foot; and
c) Aquifer permeability data, including field data, data analysis, and interpretation of
slug test, aquifer pump test or other hydraulic analysis to determine local aquifer
hydraulic conductivity in each well.
Between April and June 2005, Denison installed wells MW-23, MW-24, MW-25, MW-27, MW-
28, MW-29, MW-30, and MW-31. On August 23, 2005, Denison submitted a Perched
Monitoring Well Installation and Testing at the White Mesa Uranium Mill April through June
2005 Report, prepared by Hydro Geo Chern, Inc., that documented how these wells had been
installed in accordance with requirements of the Permit. A copy of that Report was previously
submitted under separate cover.
Between August 30 and September 2,2010, Denison installed wells MW-33, MW-34, and MW-
35. On October 11, 2010, Denison submitted Installation and Hydraulic Testing of Perched
Monitoring Wells MW-33, MW-34, and MW-35 at the White Mesa Uranium Mill Near Blanding
Utah, prepared by Hydro Geo Chern, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover. During the week of April 25, 2011, Denison installed wells MW-36, and
MW-37. On June 28, 2011, Denison submitted Installation and Hydraulic Testing of Perched
Monitoring Wells MW-36, and MW-37 at the White Mesa Uranium Mill Near Blanding Utah,
prepared by Hydro Geo Chern, Inc. that documented how these wells had been installed in
accordance with requirements of the Permit. A copy of that Report was previously submitted
under separate cover.
b) Existing Wells
The Existing Wells, MW-1, MW-2, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-
18, MW-19, MW-26 and MW-32 as well as wells MW-16, MW-20 and MW-22, which are not
compliance monitoring wells, and piezometers P-1, P-2, P-3, P-4 and P-5, were all constructed
and installed prior to original issuance of the Permit. Some of those wells date back to 1979.
During several site visits and four split groundwater sampling events between May 1999 and the
date of original issuance of the Permit, and a review of available as built information, DRC staff
45
noted the need for remedial construction, maintenance, or repair at several of these wells,
including:
(i)
(ii)
16 of the eXIstIng monitoring wells failed to produce clear groundwater in
conformance with the EPA RCRA TEGD, apparently due to incomplete well
development. Consequently, the Permit required that MW-S, MW-ll, MW-18,
MW-19, MW-26, TW4-16, and MW-32 be developed to ensure that groundwater
clarity conforms to the EPA RCRA TEGD to the extent reasonably achievable;
The Permit required the Mill to install protective steel surface casings to protect
the exposed PVC well and piezometer casings for piezometers P-l, P-2, P-3, P-4,
and P-S and wells MW-26 and MW-32; and
(iii)
A.
Several problems were observed with the construction of MW-3, including:
A review of the MW-3 well as-built diagram showed that no geologic log was
provided at the time of well installation. Consequently, the Director was not
able to ascertain if the screened interval was adequately located across the base
of the shallow aquifer;
B.
C.
D.
MW -3 was constructed without any filter media or sand pack across the
screened interval;
An excessively long casing sump (a 9 or 10 foot long non-perforated section of
well casing), was constructed at the bottom of the well; and
The well screen appeared to be poorly positioned, based on the low
productivity of the well, and there is no geologic log to verify proper
positioning.
As a result, the Permit, required Denison to verify the depth to the upper contact of
the Brushy Basin Member of the Morrison Formation in the immediate vicinity of
well MW -3. The Permit also required that, in the event that the Director determined
the well screen has been inadequately constructed, the Mill shall retrofit, reconstruct,
or replace monitoring well MW -3.
The Mill developed the wells as required and installed the protective casings required. The
Director concluded that Denison had fulfilled the requirements and sent Denison a Closeout
Letter on August S, 2008.
With respect to the concerns raised about MW-3, the Mill installed MW-3A approximately 10
feet southeast of MW-3, in order to verify the depth to the upper contact of the Brushy Basin
Member of the Morrison Formation (the "UCBM"). After installation, the Director reviewed the
geologic log for MW-3 and the as-built reports for both MW-3 and MW-3A and concluded that
the well screen for MW-3A is 2.S feet below the UCBM and the well screen for MW-3 is 4.S
feet above the UCBM. Therefore MW-3 is a partially penetrating well; whereas MW-3A is fully
penetrating. The Director concluded that semiannual sampling must continue in both wells until
sufficient data is available and the DRC can make a conclusion regarding the effects of partial
well penetration and screen length. As a result, the GWDP was modified to require that MW -3A
be completed with a permanent surface well completion according to EP A RCRA TEGD. Both
MW-3 and MW-3A are currently sampled semiannually.
46
Denison completed MW-3A as required, and on August 5, 2008 the DRC sent Denison a
Closeout Letter.
Subsequent to original Permit issuance, on January 6, 2006, DRC staff performed an inspection
of the compliance groundwater monitoring wells at the Mill. During the inspection, well MW-5
was found to have a broken PVC surface casing. The repair of MW -5 was added to the Permit
compliance schedule to require the Mill to repair the broken PV C casing to meet the
requirements of the Permit.
The Permit required Denison to submit an As-Built report for the repairs of monitoring well
MW-5 on or before May 1,2008. Denison submitted the required report, and on August 5,2008
the DRC sent Denison a Closeout Letter.
The groundwater monitoring program at the Mill has historically had numerous wells with
elevated turbidity, turbidity levels which could not stabilize to within 10% Relative Percent
Difference (10% RPD) or both. Identification of equipment problems and improvements to field
sampling practices did not result in improvements to measured turbidities. Ongoing turbidity
issues were the result of monitoring requirements which were most likely ill-suited to the site
geology. It is suspected that many wells at the Mill might not be capable of attaining a turbidity
of 5 NTU due to the natural conditions in the formation hosting the perched monitoring wells
(the Burro Canyon Formation and Dakota Sandstone). Clay interbeds occur in both the Burro
Canyon Formation and Dakota Sandstone, and friable materials occur within the Burro Canyon
Formation. Saturated clays and friable materials will likely continue to be mobilized using
standard purging techniques currently in use for the sampling program at the Mill. Mobilized
kaolinite (a cementing material within the formation) is expected to be an additional continuing
source of turbidity in perched wells. Denison discussed the turbidity issues with DRC, and,
despite the fact that the available evidence demonstrated that turbidity issues are caused by the
formation, Denison agreed to complete a redevelopment program for the appropriate wells at the
Mill in a "good-faith" effort. Surging, bailing, and overpumping were determined to be the
preferred well development techniques. The rationale for using surging and bailing followed by
overpumping is consistent with U.S. Environmental Protection Agency (EPA) guidance and
guidance provided in other technical papers and publications.
Select, nonpumping, chloroform, nitrate and groundwater POC, wells were redeveloped during
the period from fall 2010 to spring 2011 by surging and bailing followed by overpumping.
The results of the redevelopment are provided in the Report entitled:Redevelopment of Existing
Perched Monitoring Wells White Mesa Uranium Mill, Near Blanding Utah, prepared by Hydro
Geo Chem, Inc. September 30, 2011 (the "Redevelopment Report"). The Redevelopment Report
provides a qualitative description of turbidity behavior before and after redevelopment and
provides a number of conclusions and recommendations. A copy of the Redevelopment Report
was previously submitted under separate cover. The Redevelopment Report is currently under
review by the Director.
47
As described above, all eXIstIng wells have been reviewed by the Director, and repaIrS,
modifications, retrofits, etc. have been made as required to conform those wells to the
requirements of Part I.EA of the Permit, to the extent reasonably practicable.
2.9.6.2 Ground Water Sampling
Ground water sampling is performed in accordance with the requirements of Part I.E.5 of the
Permit, which requires that all monitoring shall be conducted in conformance with the following
procedures:
a) Grab samples shall be taken of the groundwater, only after adequate removal or
purging of standing water within the well casing has been performed;
b) All sampling shall be conducted to ensure collection of representative samples, and
reliability and validity of groundwater monitoring data. All groundwater sampling
shall be conducted in accordance with the currently approved Groundwater Monitoring
Quality Assurance Plan;
c) All analyses shall be performed by a laboratory certified by the State of Utah to
perform the tests required;
d) If any monitor well is damaged or is otherwise rendered inadequate for its intended
purpose, Denison shall notify the Director in writing within five days of the discovery;
and
e) Immediately prior to each monitoring event, Denison shall calibrate all field
monitoring equipment in accordance with the respective manufacturer's procedures
and guidelines. Denison shall make and preserve on-site written records of such
equipment calibration in accordance with Part fl.G and H of the Permit. Said records
shall identify the manufacturer's and model number of each piece of field equipment
used and calibration.
In accordance with the requirements of Part I.E.1(a) of the Permit, all groundwater sampling at
the Mill is performed in accordance with the White Mesa Uranium Mill Ground Water
Monitoring Quality Assurance Plan (QAP) (the "QAP"), which has been approved by the
Director. The QAP complies with UAC R317-6-6.3(1) and (L) and by reference incorporates the
relevant requirements of the Handbook of Suggested Practices for Design and Installation of
Ground-Water Monitoring Wells (EPAl600/4-89/034, March 1991), ASTM Standards on Ground
Water and Vadose Investigations (1996), Practical Guide for Ground Water Sampling
EPAl600/2-85/104, (November 1985) and RCRA Ground Water Monitoring Technical
Enforcement Guidance Document (1986), unless otherwise specified or approved by the
Director, by virtue of his approving the QAP. A copy of the current version of the QAP, Date: 6-
06-12 Revision 7.2, is included as Appendix H.
2.9.7 Description and Justification of Parameters to be Monitored
The groundwater parameters to be monitored are described in Table 2.9.1.3-1. The process of
selecting the groundwater quality monitoring parameters for the original Permit included
examination of several technical factors. Each of these is discussed in detail in Section 4 on
pages 9-19 of the 2004 Statement of Basis, and include the following:
48
a) The number and types of contaminants that might occur in feedstock materials
processed at the Mill;
b) Mill process reagents as a source of contaminants;
c) Source term abundance in the Mill's tailings cell solutions, based on limited historic
wastewater quality sampling and analysis that had been done at the Mill's tailings cells;
and
d) A consideration of contaminant mobility in a groundwater environment, based on site
specific ~ information where available and lowest ~ values in the literature where
site specific ~ information is not available.
Please see Section 4, pages 9-19, of the 2004 Statement of Basis for a more detailed discussion
of the description and justification of parameters to be monitored.
One additional parameter, tin, was added to the list of groundwater monitoring constituents in
2007. Tin was not originally a required groundwater monitoring parameter in the Permit, and
was omitted from the original Permit due to non-detectable concentrations reported by Denison
in three tailings leachate samples (2004 Statement of Basis, Table 5). With the addition of the
alternate feed material from Fansteel Inc., tin was expected to experience an estimated increase
in the tailings inventory from 9 to 248 tons. The Director concluded that, with an estimated ~
of 2.5 to 5, tin is not as mobile in the groundwater environment as other metals; however, with
the high acid conditions in the tailings wastewater, tin could stay in solution and not partition on
aquifer materials. As a result, tin was added as a monitoring constituent to Table 2 of the Permit.
2.9.8 Quality Assurance and Control Provisions for Monitoring Data
Part I.E. 1 (d) of the Permit sets out some special conditions for groundwater monitoring. Under
those conditions, the Mill must ensure that all groundwater monitoring conducted and reported
complies with the following:
a) Depth to groundwater measurements shall always be made to the nearest 0.01 foot;
b) All groundwater quality analyses reported shall have a minimum detection limit or
reporting limit that is less than its respective GWCL concentration defined in Table 2
of the Permit; and
c) all gross alpha analysis reported with an activity equal to or greater than the GWCL
shall have a counting variance that is equal to or less than 20% of the reported activity
concentration. An error term may be greater than 20% of the reported activity
concentration when the sum of the activity concentration and error term is less than or
equal to the GWCL.
As mentioned in Section 2.9.6.2 above, Part I.E. 1 (a) of the Permit requires that all groundwater
sampling shall be conducted in accordance with the currently approved QAP. The detailed
quality assurance and control provisions for monitoring data are set out in the QAP, a copy of
which is attached as Appendix H to this Application.
2.10 Plans and Specifications Relating to Construction, Modification, and Operation of Discharge
Systems (R317 -6-6.3.J)
49
As discussed in Section 2.7.1 above, the Mill has been designed as a facility that does not
discharge to groundwater or surface water. All tailings and other wastes associated with Mill
operations are designed to be permanently disposed of in the Mill's tailings cells. The Mill's
tailings cells can therefore be considered the Mill's discharge system in that they permanently
dispose of discharges from the Mill's process circuits and all other Mill tailings and wastes.
The following plans and specifications and as built reports relating to tailings Cells 1, 2, 3, 4A
and 4B are referenced in this Application and were previously submitted on the dates noted
below under separate cover:
a. Engineers Report: Tailings Management System, White Mesa Uranium Project
Blanding, Utah, June 1979, prepared by D' Appolonia Consulting Engineers, Inc.;
b. Engineer's Report: Second Phase Design -Cell 3 Tailings Management System,
White Mesa Uranium Project Blanding, Utah, May 1981, prepared by D' Appolonia
Consulting Engineers, Inc.;
c. Construction Report: Initial Phase -Tailings Management System, White Mesa
Uranium Project Blanding, Utah, February 1982, prepared by D' Appolonia Consulting
Engineers, Inc.;
d. Construction Report: Second Phase Tailings Management System, White Mesa
Uranium Project, March 1983, prepared by Energy Fuels Nuclear, Inc.;
e. Cell 4 Design, White Mesa Project Blanding, Utah, April 10, 1989, prepared by
Umetco Minerals Corporation;
f. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System, August 2000, prepared by Denison (then named International
Uranium (USA) Corporation);
g. Cell 4A Lining System Design Report For The White Mesa Mill Blanding, Utah,
January 2006, prepared by GeoSyntec Consultants; and
h. Ce1l4A Construction Quality Assurance Report, White Mesa Mill Blanding, Utah, July
2008 prepared by Geosyntec consultants (disk only).
1. Cell 4B Design Report, White Mesa Mill, Blanding, Utah, December 8, 2007, prepared
by Geosyntec Consultants
J. Cell 4B Construction Quality Assurance Report, Volumes 1-3, November 2010,
prepared by Geosyntec Consultants
2.11 Description of the Ground Water Most Likely to be Affected by the Discharge (R317-6-6.3.K)
2.11.1 General
The ground water most likely to be affected by a potential discharge from Mill activities is the
perched aquifer.
The deep confined aquifer under White Mesa is found in the Entrada and underlying Navajo
Sandstones, is hydraulically isolated from the perched aquifer, and is therefore extremely
unlikely to be affected by any such potential discharges. The top of the Entrada Sandstone at the
site is found at a depth of approximately 1,200 feet below land surface (see the discussion in
Sections 2.5.1.1 and 2.5.1.2 above). This deep aquifer is hydraulically isolated from the shallow
perched aquifer by at last two shale members of the Morrison Formation, including the Brushy
50
Basin (approximately 295 feet thick) and the Recapture (approximately 120 feet thick) Members.
Other formations are also found between the perched and deep confined aquifers, that also
include many layers of thin shale interbeds that contribute to hydraulic isolation of these two
groundwater systems, including: the Morrison Formation Westwater canyon (approximately 60
feet thick), and Salt Wash (approximately 105 feet thick) Members, and the Summerville
Formation (approximately 100 feet thick). Artesion groundwater conditions found in the deep
EntradaIN avajo Sandstone aquifer also reinforce this concept of hydraulic isolation from the
shallow perched system. See the discussion on page 2 of the 2004 Statement of Basis.
2.11.2 Background Ground Water Quality in the Perched Aquifer
This Section describes the groundwater quality in the perched aquifer. See Sections 2.5.1.3,
2.5.1.4 and 2.5.1.5 above for a more detailed description of the perched aquifer itself, the depth
to ground water, the saturated thickness, flow direction, porosity, hydraulic conductivity -and
flow system characteristics of the perched aquifer.
As mentioned in Section 2.9.1.5 above, a significant amount of historic groundwater quality data
had been collected by Denison and previous operators of the Mill for many wells at the facility.
However, at the time of original issuance of the Permit, the Director had not yet completed an
evaluation of the historic data, particularly with regard to data quality, and quality assurance
issues. The Director also noted several groundwater quality issues that needed to be resolved
prior to a determination of background groundwater quality at the site, such as a number of
constituents that exceeded their respective GWQS and long term trends in uranium in
down gradient wells MW-14, MW-15 and MW-17, and a spatial high of uranium in those three
downgradient wells.
As a result of the foregoing, the Director required that the Existing Well Background Report be
prepared to address and resolve these issues. DUSA prepared the Existing Well Background
Report that evaluated all historic data for the thirteen existing wells for the purposes of
establishing background groundwater quality at the site and developing groundwater compliance
limits GWCLs under the GWDP. Prior to review and acceptance of the conclusions in the
Existing Well Background Report, the GWCLs were set on an interim basis in the GWDP. The
interim limits were established as fractions of the state GWQSs for drinking water, depending on
the quality of water in each monitoring well at the site.
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the thirteen existing wells based primarily on the analysis performed in the Existing Well
background Report. It should be noted, however, that, because the GWCLs have been set at the
mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
As required by the Permit, the Existing Well Background Report addressed all available historic
data, which includes pre-operational and operational data, for the compliance monitoring wells
under the Permit that were in existence at the date of issuance of the Permit. The Regional
Background Report focuses on all pre-operational site data and all available regional data to
51
develop the best available set of background data that could not conceivably have been
influenced by Mill operations. The New Well Background Report, which was required by the
Permit, analyzed the data collected from the new wells, which were installed in 2005, to
determine background concentrations for constituents listed in the Permit for each new well.
The purpose of the Existing Well Background Report and the New Well Background Report was
to satisfy several objectives: first, in the case of the Existing Well Background Report, to
perform a quality assurance evaluation and data validation of the existing and historical on-site
groundwater quality data in accordance with the requirements of the Permit, and to develop a
database consisting of historical groundwater monitoring data for "existing" wells and
constituents.
Second, in the case of the New Well Background Report, to compile a database consisting of
monitoring results for new wells, which were collected subsequent to issuance of the Permit, in
accordance with the Mill's QAP data quality objectives.
Third, to perform a statistical, temporal and spatial evaluation of the existing well and new well
data bases to determine if there have been any impacts to groundwater from Mill activities.
Since the Mill is an existing facility that has been in operation since 1980, such an analysis of
historic groundwater monitoring data was required in order to ensure that the monitoring results
to be used to determine background groundwater quality at the site and GWCLs have not been
impacted by Mill activities.
Finally, since the analysis demonstrates that groundwater has not been impacted by Mill
activities, to develop a GWCL for each constituent in each well.
The Regional Background Report was prepared as a supplement to the Existing Well
Background Report to provide further support to the conclusion that Mill activities have not
impacted groundwater.
In evaluating the historic data for the existing wells, INTERA used the following approach:
• If historic data for a constituent in a well do not demonstrate a statistically significant
upward trend, then the proposed GWCL for that constituent is accepted as representative
of background, regardless of whether or not the proposed GWCL exceeds the GWQS for
that constituent. This is because the monitoring results for the constituent can be
considered to have been consistently representative since commencement of Mill
activities or installation of the well; and
• If historic data for a constituent in a monitoring well represent a statistically significant
upward trend or downward trend in the case of pH, then the data is further evaluated to
determine whether the trend is the result of natural causes or Mill activities. If it is
concluded that the trend results from natural causes, then the GWCL proposed in the
Existing Well Background Report will be appropriate.
After applying the foregoing approach, INTER A concluded that, other than some detected
chloroform and related organic contamination at the Mill site, which is the subject of a separate
52
investigation and remedial action, and that is the result of pre-Mill activities, and some elevated
nitrate concentrations in certain wells which were considered to be associated with the
chloroform plume, there have been no impacts to groundwater from Mill activities (See Section
2.16.1 below relating to the chloroform contamination and Section 2.16.2 relating to the nitrate
contamination).
In reaching this conclusion, INTERA noted that, even though there are a number of increasing
trends in various constituents at the site, none of the trends are caused by Mill activities, for the
following reasons:
• Chloride is unquestionably the best indicator parameter, and there are no significant
trends in chloride in any of the wells;
• There are no noteworthy correlations between chloride and uranium in wells with
increasing trends in uranium, other than in upgradient wells MW -19 and MW -18, which
INTERA concluded are not related to any potential tailings seepage. INTERA noted that
it is inconceivable to have an increasing trend in any other parameter caused by seepage
from the Mill tailings without a corresponding increase in chloride;
• There are significant increasing trends up gradient in MW-l, MW-18 or MW-19 in
uranium, sulfate, TDS iron, selenium, thallium, ammonia and fluoride and far
downgradient in MW-3 in uranium and selenium, sulfate, TDS and pH (decreasing
trend). INTERA concluded that this provides very strong evidence that natural forces at
the site are causing increasing trends in these constituents (decreasing in pH) in other
wells and supports the conclusion that natural forces are also causing increasing trends in
other constituents as well; and
• On a review of the spatial distribution of constituents, it is quite apparent that the
constituents of concern are dispersed across the site and not located in any systematic
manner that would suggest a tailings plume.
INTERA concluded that, after extensive analysis of the data, and given the conclusion that there
have been no impacts to groundwater from Mill activities, the GWCLs set out in Table 16 of the
Existing Well Background Report are appropriate, and are indicative of background ground
water quality. INTERA did advise, however, that proposed GWCLs for all the trending
constituents should be re-evaluated upon Permit renewal to determine if they are still appropriate
at the time of renewal. See Table 16 of the Existing Well Background Report for INTERA's
calculation of background ground water quality as represented by the proposed GWCLs. See
Section 6.0 of the Existing Well Background Report for a discussion of the statistical manner
used to calculate each proposed GWCL.
In evaluating the new well data, INTERA used the same approach in the New Well Background
Report that was used in the Existing Well Background Report for existing well data. In addition,
INTERA compared the groundwater monitoring results for the new wells to the results for the
existing wells analyzed in the Existing Well Background Report and to the pre-operational and
regional results analyzed in the Regional Background Report. This was particularly important
for the new wells because there is no historic data for any constituents in those wells that goes
back to commencement of Mill operations. A long-term trend in a constituent may not be
evident from the available data for the new wells. By comparing the means for the constituents
53
in the new wells to the results for the existing wells and regional background data, INTERA was
able to determine if the concentrations of any constituents in the new wells are consistent with
background at the site.
INTERA concluded that after applying the foregoing approach, there have been no impacts to
groundwater in the new monitoring wells from Mill activities. INTERA concluded that the
groundwater monitoring results for the new wells are consistent with the results for the existing
wells analyzed in the Existing Well Background Report and for the pre-operational and regional
wells, seeps and springs analyzed in the Regional Background Report. INTERA noted that there
were some detections of chloroform and related organic contamination and degradation products
and nitrate and nitrite in the new wells, which are now the subject of two separate investigations
(see Sections 2.16.1 and 2.16.2), but that such contamination was the result of pre-Mill activities.
As a result, given its conclusion that there have been no impacts to groundwater from Mill
activities, INTERA concluded that the calculated GWCLs for new wells set out in Table 10 of
the New Well Background Report are appropriate, and are indicative of background ground
water quality. Again, INTERA noted that GWCLs for trending constituents should be re-
evaluated upon Permit renewal to determine if they are still appropriate at the time of renewal.
See Table 10 of the New Well Background Report for INTERA's calculation of background
ground water quality as represented by the proposed GWCLs. See Section 2.2 of the New Well
Background Report for a discussion of the statistical manner used to calculate each proposed
GWCL.
As a result of the foregoing, the Director required that the New Well Background Report be
prepared to address and resolve these issues. DUSA prepared the New Well Background Report
that evaluated all historic data for the nine new wells for the purposes of establishing background
groundwater quality at the site and developing GWCLs under the GWDP. Prior to review and
acceptance of the conclusions in the New Well Background Report, the GWCLs were set on an
interim basis in the GWDP. The interim limits were established as fractions of the state GWQSs
for drinking water, depending on the quality of water in each monitoring well at the site.
The University of Utah Study confirmed INTERA's conclusions in the Background Reports that
groundwater at the site has not been impacted by Mill operations (see the discussion in Section
1.3 above).
The January 20, 2010 GWDP established GWCLs that reflect background groundwater quality
for the nine new wells based primarily on the analysis performed during the New Well
Background Report. It should be noted, however, that, because the GWCLs have been set at the
mean plus second standard deviation, or the equivalent, un-impacted groundwater would
normally be expected to exceed the GWCLs approximately 2.5% of the time. Therefore,
exceedances are expected in approximately 2.5% of all sample results, and do not necessarily
represent impacts to groundwater from Mill operations.
Part I.G.2 of the Permit provides that out-of-compliance status exists when the concentration of a
pollutant in two consecutive samples from a compliance monitoring point exceeds a GWCL in
Table 2 of the Permit. Per the requirements of Part I.G.4(c) of the Permit, Denison is required to
prepare and submit written plans and time schedules, for Director approval, to fully comply with
54
the requirements of Part LG.4(c) of the Permit relating to any such out-of-compliance situation,
including, but not limited to:
(i) submittal of a written assessment of the source(s);
(ii) submittal of a written evaluation of the extent and potential dispersion of said
groundwater contamination; and
(iii) submittal of a written evaluation of any and all potential remedial actions to restore and
maintain ground water quality at the facility, for the point of compliance wells and
contaminants in question, to ensure that: 1) shallow groundwater quality at the facility
will be restored and 2) the contaminant concentrations in said point of compliance wells
will be returned to and maintained in compliance with their respective GWCLs.
Two plans and time schedules have been submitted to address consecutive exceedances which
have been noted in wells since the establishment of the GWCLs in the January 20,2010 GWDP.
The Plans and time schedules are the Initial Plan and Schedule and the Q2 2011 Plan and
Schedule to address analytes other than pH in out-of-compliance status. Those plans were
submitted June 13, and September 7, 2011, respectively. Those plans will be implemented
concurrent with the pH investigation described below and described in the pH plan and Time
schedule submitted to the Director on April 13, 2012. The plans were previously submitted
under separate cover.
On July 12, 2012, Denison and the Director entered into a Stipulated Consent Agreement relating
to the implementation of these plans and schedules.
Given the varied background groundwater quality at the site, previously identified rising trends
in some wells and other factors, it cannot be assumed that consecutive exceedances of a
constituent in a monitoring well means that contamination has been introduced to groundwater in
that well. The exceedances may very well be the result of background influences. The approach
in these Plans therefore is to first determine if the recent exceedances are the result of
background influences. If they are determined to be the result of background influences, then no
remedial actions are required. If, however, they are determined to not be the result of natural
background influences, then further analyses will be required.
Based on the information available at this time, Denison believes that the exceedances observed
are the result of natural influences and reflect the need to adjust some of the GWCLs for the site.
During the completion of the 4th Quarter 2010 Quarterly Groundwater Monitoring Report,
Denison noted eleven perched groundwater monitoring wells with pH measurements below the
GWCLs. These wells are located up gradient, cross-gradient, and down gradient of the Mill and
tailings cells. Investigation into the eleven pH GWCLs in question indicated that the GWCLs for
groundwater pH in all wells established in the January 20, 2010 GWDP were erroneously based
on historic laboratory results instead of field measurements as contemplated by Table 2 of the
GWDP. Denison notified DRC that the existing GWCLs for groundwater pH were incorrectly
based on laboratory results rather than field measurements and proposed to submit revised
55
descriptive statistics for field pH to be used as revised pH GWCLs by the end of the second
quarter 2011.
Denison received approval from DRC to proceed with the revision of the pH GWCLs based on
field measurements. The data processing and statistical assessments necessary to revise the
GWCLs based on historic field pH data were completed. The data processing and statistical
assessments completed were based on the DRC-approved methods in the logic flow diagram
included as Figure 17 of the New Well Background Report. Following the statistical evaluation
of pH data, Denison compared the Mill's groundwater pH data from the 2nd Quarter of 2011,
including accelerated sampling results through June 2011, and noted that all of the June 2011
groundwater results, and many of the other results from the 2nd Quarter, were already outside
the revised GWCLs to be proposed based on the logic flow diagram.
It was noted that the historical trend of decreasing pH, which was addressed in the Background
Study Reports, appeared to be present in nearly all wells throughout the Mill site area, including
upgradient, downgradient, and cross-gradient wells in the groundwater monitoring program. As
of June 2011, all groundwater monitoring wells demonstrated a downward trend in the field pH
data over time.
Denison notified DRC that the 2nd Quarter 2011 data exceeded the recalculated GWCLs.
Denison advised DRC that, as a result of these findings, Denison did not believe it was
appropriate to continue with its efforts to reset the GWCLs for pH based on field pH data, as
originally planned, but instead it appeared that it would be more appropriate to undertake a study
to determine whether the decreasing trends in pH are due to natural influences and, if so, to
determine a more appropriate way to determine GWCLs.
Denison and DRC have agreed on further investigations to be completed, as well as the steps and
milestone dates to be incorporated into a pH Plan. The investigation into the decreasing site-
wide pH trends is documented in the Plan to Investigate pH Exceedances in Perched
Groundwater Monitoring Wells White Mesa Uranium Mill Blanding, Utah, Prepared by Hydro
Geo Chern, Inc, April 13, 2012 (the "pH Plan"). The pH Plan describes the pH investigation to
pursuant to the July 12, 2012a Stipulated Consent Agreement referred to above. The pH Plan
was previously submitted under separate cover.
The primary conclusion from the activities conducted to date is that the historical trend of
decreasing pH, which was addressed in the Background Reports, appears to be present in nearly
all wells throughout the Mill site area, including up gradient , downgradient, and cross gradient
wells in the groundwater monitoring program, and there seems to be no abatement of the trend.
The wide-spread nature of the decrease in pH in up gradient , downgradient and crossgradient
wells, suggests that the pH decrease results from a natural phenomenon unrelated to Mill
operations.
In an effort to determine if these trends may have resulted in whole or in part, from increasing
water levels attributed to the Wildlife ponds at the Mill, Denison has committed to stop
recharging the two most northern of these ponds, commencing in March 2012.
56
2.11.3 Quality of Ground Water at the Compliance Monitoring Point
All of the analytical results from groundwater sampling are reported quarterly in Groundwater
Monitoring Reports, which are filed with the Director pursuant to Part I.F.1 of the Permit.
2.12 Compliance Sampling Plan (R317-6-6.3.L)
The Mill's plan for sampling groundwater compliance monitoring points is discussed in detail in
Section 2.9.1.3 above, and the plan for sampling the leak detection systems in Cells 4A and 4B is
discussed in Section 2.15.3 below. This Section 2.12 will address other sampling required under
the Permit. As the Mill is designed not to discharge to ground water, there are no flow
monitoring requirements in the Permit.
2.12.1 Tailings Cell Wastewater Quality Sampling Plan
Part I.E. 10 of the Permit requires that, on an annual basis, Denison must collect wastewater
quality samples from each wastewater source at each tailings cell at the facility, including
surface impounded wastewaters, and slimes drain wastewaters. All such sampling must be
conducted in August of each calendar year in compliance with an approved plan. The Tailings
SAP (dated November 21, 2008) was approved by the Director on March 3, 2009. A copy of the
approved Tailings and Slimes Drain Sampling Program, Revision 0, November 20, 2008 is
attached as Appendix H to this Application. As of this writing, Denison has submitted Revision
2.1, which is undergoing review by the Director.
The purpose of the Tailings SAP is to characterize the source term quality of all tailings cell
wastewaters, including impounded wastewaters or process waters in the tailings cells, and
wastewater or leachates collected by internal slimes drains. The Revision O,Tailings SAP
requires:
• Collection of samples from the pond area of each active cell and the slimes drain of each
cell that has commenced de-watering activities;
• Samples of tailings and slimes drain material will be analyzed at an offsite contract
laboratory and subjected to the analytical parameters included in Table 2 of the Permit
and general inorganics listed in Part I.E. 1 (d)(2)(ii) of the Permit, as well as semi-volatile
organic compounds;
• A detailed description of all sampling methods and sample preservation techniques to be
employed;
• The procedures utilized to conduct these analyses will be standard analytical methods
utilized for groundwater sampling and as shown in Section 8.2 of the QAP;
• The contracted laboratory will be certified by the State of Utah in accordance with UAC
R317-6-6.12A; and
• 30-day advance notice of each annual sampling event must be given, to allow the
Director to collect split samples of all tailings cell wastewater sources.
The tailings and slimes drain sampling events will be subject to the currently approved QAP,
unless otherwise specifically modified by the Tailings SAP to meet the specific needs of this type
of sampling. The QAP has been approved by the Director and satisfies the most appropriate
57
requirements of the following references, unless otherwise specified by the Director through his
approval of the Tailings SAP:
• Standard Methods for the Examination of Water and Wastewater, twentieth edition,
1998; Library of Congress catalogue number: ISBN: 0-87553-235-7;
• E.P.A. Methods for Chemical Analysis of Water and Wastes, 1983; Stock Number EPA-
600/4-79-020;
• Techniques of Water Resource Investigations of the U.S. Geological Survey, (1998);
Book 9;
• Monitoring requirements in 40 CFR parts 141 and 142, 2000 ed., Primary Drinking
Water Regulations and 40 CFR parts 264 and 270,2000 ed.; and
• National Handbook of Recommended Methods for Water-Data Acquisition, GSA-GS
edition; Book 85 AD-2777, U.S. Government Printing Office Stock Number 024-001-
03489-1.
The currently approved Tailings SAP is attached to this Application. As previously stated,
Denison has submitted Revision 2.1, which is undergoing review by the Director.
2.12.2 White Mesa Seeps and Springs Sampling Plan
The initial Permit required Denison to submit a plan for groundwater sampling and analysis of
all seeps and springs ("SSSP") found downgradient or lateral gradient from the tailings cells for
Director review and approval. The Director approved the plan on on March 17, 2009. A copy of
the Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa Uranium Mill,
Revision: 0, March 17, 2009, is attached as Appendix B to this Application. As of this writing,
Denison has submitted Revision 1.0, which is undergoing review by the Director.
Under the SSSP, seeps and springs sampling will be conducted on an annual basis between May
1 and July 15 of each year, to the extent sufficient water is available for sampling, at six
identified seeps and springs near the Mill. The sampling locations were selected to correspond
with those seeps and springs sampled for the initial Mill site characterization performed in the
1978 ER, plus additional sites located by Denison, the United States Bureau of Land
Management and Ute Mountain Ute Indian Tribe representatives.
Samples will be analyzed for all ground water monitoring parameters found in Table 2 of the
Permit. The laboratory procedures utilized to conduct the analyses of parameters listed in Table
2 will be those utilized for groundwater sampling and as shown in Section 8.2 of the QAP. In
addition to tht1se laboratory parameters, the pH, temperature and conductivity of each sample
will be measured and recorded in the field. Laboratories selected by Denison to perform
analyses of seeps and springs samples will be required to be certified by the State of Utah in
accordance with UAC R317-6-6.12.A.
The seeps and springs sampling events will be subject to the currently approved QAP, unless
otherwise specifically modified by the SSSP to meet the specific needs of this type of sampling.
The QAP has been approved by the Director and satisfies the most appropriate requirements of
the references listed in Section 2.12.1 above, unless otherwise specified by the Director through
his approval of the SSSP.
58
Please, see the attached copy of the SSSP for further details.
2.12.3 Monitoring of Deep Wells
Due to the fact that the deep confined aquifer at the site is hydraulically isolated from the
shallow perched aquifer (see the discussion in Section 2.11.1 above) no monitoring of the deep
aquifer is required under the Permit.
2.13 Description of the Flooding Potential of the Discharge Site (R317-6-6.3.M)
2.13.1 Surface Water Characteristics
As discussed above, the Mill site is located on White Mesa, a gently sloping (1 % SSW) plateau
that is physically defined by the adjacent drainages which have cut deeply into regional
sandstone formations. There is a small drainage area of approximately 62 acres (25 ha) above
the site that could yield surface runoff to the site. Runoff from the mesa is conveyed by the
general surface topography to either Westwater Creek, Corral Creek, or to the south into an
unnamed branch of Cottonwood Wash. Local porous soil conditions, topography and low
average annual rainfall of 13.3 inches (reported as 11.8 by Dames and Moore in historic reports)
cause these streams to be intermittently active, responding to spring snowmelt and local
rainstorms (particularly thunderstorms). Surface runoff from approximately 624 acres of the
Mill drains westward and is collected by Westwater Creek, and runoff from another 384 acres
drains east into Corral Creek. The remaining 4,500 acres of the southern and southwestern
portions of the site drain indirectly into Cottonwood Wash (1978 ER, p. 2-143). The site and
vicinity drainages carry water only on an intermittent basis. The major drainages in the vicinity
of the Mill are depicted in Figure 12 and tabulated in Table 2.13.1-1. Total runoff from the mesa
(total yield per watershed area) is estimated to be less than 0.5 inch annually (1978 ER, p. 2-
143).
There are no perennial surface waters on or in the vicinity of the Mill site. This is due to the
gentle slope of the mesa on which the site is located, the low average annual rainfall of 13.3
(reported as 11.8 by Dames and Moore in historic reports) inches per year at Blanding, local soil
characteristics and the porous nature of local stream channels. Prior to construction, three small
ephemeral catch basins were present on the site to the northwest and northeast of the Mill site.
Corral Creek is an intermittent tributary to Recapture Creek. The drainage area of that portion of
Corral Creek above and including drainage from the eastern portion of the site is about 5 square
miles. Westwater Creek is also an intermittent tributary of Cottonwood Wash. The Westwater
Creek drainage basin covers nearly 27 square miles at its confluence with Cottonwood Wash 1.5
miles west of the Mill site. Both Recapture Creek and Cottonwood Wash are similarly
intermittently active, although they carry water more often and for longer periods of time due to
their larger watershed areas. They both drain to the south and are tributaries of the San Juan
River. The confluences of Recapture Creek and Cottonwood Wash with the San Juan River are
approximately 18 miles south of the Mill site. The San Juan River, a major tributary for the
upper Colorado River, has a drainage of 23,000 square miles measured at the USGS gauge to the
west of Bluff, Utah (1978 ER, p. 2-130).
59
Storm runoff in these streams is characterized by a rapid rise in flow rates, followed by rapid
recession primarily due to the small storage capacity of the surface soils in the area. For
example, on August 1, 1968, a flow of 20,500 cubic feet per second was recorded in Cottonwood
Wash near Blanding. The average flow for that day, however, was only 4,340 cfs. By August 4,
the flow had returned to 16 cfs (1978 ER, p. 2-135). Monthly streamflow summaries as updated
from Figure 2.4 of the FES are presented in Figure 13 for Cottonwood Wash, Recapture Creek
and Spring Creek. Flow data are not available for the two smaller water courses closest to the
Mill site, Corral Creek and Westwater Creek, because these streams carry water infrequently and
only in response to local heavy rainfall and snowmelt, which occurs primarily in the months of
April, August, and October. Flow typically ceases in Corral Creek and Westwater Creek within
6 to 48 hours after precipitation or snowmelt ends.
2.13.2 Flood Protection Measures
As mentioned above, the Mill was designed and constructed to prevent run on or runoff of storm
water by a) diverting runoff from precipitation on the Mill site to the tailings cells; and b)
diverting runoff from surrounding areas away from the Mill site via three drainage ditches that
have been constructed north (upslope) of the Mill facility.
See the UMETCO Minerals Corporation: White Mesa Mill Drainage Report for Submittal to
NRC, January 1990, a copy of which accompanies this Application, for a more detailed
description of the flooding potential of the site, including the 6-hour probable maximum
precipitation (which is more conservative than the 100-year flood plain), and applicable flood
protection measures.
In addition to the foregoing designed control features, the facility has developed a Stormwater
Best Management Practices Control Plan which includes a description of the site drainage
features and the best management practices employed to ensure appropriate control and routing
of stormwater. A copy of the Mill's Stormwater Best Management Practices Plan is included as
Appendix F to this Application.
2.14 Contingency Plan (R317-6-6.3.N)
As required by Part LR.15 of the Permit, the Mill currently has a Contingency Plan for regaining
and maintaining compliance with the Permit limits and for re-establishing best available
technology as defined in the Permit. A copy of the most current approved version of the Mill's
Contingency Plan is included as Appendix J to this Application.
2.15 Methods and Procedures for Inspections of the Facility Operations and for Detecting Failure
of the System (R317-6-6.3.0)
Part LD. of the Permit sets out a number of DMT and BAT standards that must be followed. Part
I.E. of the Permit sets out the Ground Water Compliance and Technology Performance
Monitoring requirements, to ensure that the DMT and BAT standards are met. These provisions
of the Permit, along with the DMT Plan, Cell 4A BAT Monitoring Operations and Maintenance
Plan and other plans and programs developed pursuant to these Parts, set out the methods and
procedures for inspections of the facility operations and for detecting failure of the system.
60
In addition to the programs discussed above, the following additional DMT and BAT
performance standards and associated monitoring are required under Parts I.D and I.E. of the
Permit
2.15.1 Existing Tailings Cell Operation
Part I.D.2 of the Permit provides that authorized operation and maximum disposal capacity in
each of the existing tailings Cells, 1, 2 and 3 shall not exceed the levels authorized by the Mill
License and that under no circumstances shall the freeboard be less than three feet, as measured
from the top of the FML. Part I.E.7(a) of the Permit requires that the wastewater pool elevations
in Cells 1 and 3 must be monitored weekly to ensure compliance with the maximum wastewater
elevation criteria mandated by Condition 10.3 of the Mill License.
Part I.D.2 further provides that any modifications by Denison to any approved engineering
design parameter at these existing tailings cells requires prior Director approval, modification of
the Permit and issuance of a construction permit.
2.15.2 Existing Facility DMT Performance Standards
Part I.D.3 of the Permit requires Denison to operate and maintain certain Mill site facilities and
the existing tailings disposal cells to minimize the potential for wastewater release to
groundwater and the environment, including, but not limited to the following additional DMT
measures:
2.15.2.1 DMT Monitoring Wells at Cells 1, 2 and 3
Parts I.D.3 (a) and (d) require that at all times Denison must operate and maintain Cells 1, 2 and
3 to prevent groundwater quality conditions in any nearby monitoring wells from exceeding the
GWCLs in Table 2 of the Permit. This is monitored for detecting failure of the system through
the ground water compliance monitoring program described in detail in Section 2.9.1.3 above.
2.15.2.2 Slimes Drain Monitoring
Part I.D.3(b)(l) of the Permit requires that Denison must at all times maintain the average
wastewater head in the slimes drain access pipe to be as low as reasonably achievable (ALARA)
in each tailings disposal cell, in accordance with the approved DMT Plan. Compliance will be
achieved when the average annual wastewater recovery elevation in the slimes drain access pipe,
determined pursuant to the currently approved DMT Plan meets the conditions in Equation 1
specified in Part I.D.3(b )(3) of the Permit.
Part I.E.7(b) of the Permit requires that Denison must monitor and record quarterly the depth to
wastewater in the slimes drain access pipes as described in the currently approved DMT Plan at
Cell 2, and upon commencement of de-watering activities, at Cell 3, in order to ensure
compliance with Part I.D.3(b )(3) of the Permit.
61
2.15.2.3 Maximum Tailings Waste Solids Elevation
Part I.D.3( c) of the Permit requires that upon closure of any tailings cell, Denison must ensure
that the maximum elevation of the tailings waste solids does not exceed the top of the FML liner.
2.15.2.4 Wastewater Elevation in Roberts Pond
Part I.D.3(e) of the Permit requires that Roberts Pond be operated so as to provide a minimum 2-
foot freeboard at all times, and that under no circumstances will the water level in the pond
exceed an elevation of 5,624 feet above mean sea level. Part I.D.3(e) also provides that in the
event the wastewater elevation exceeds this maximum level, Denison must remove the excess
wastewater and place it into containment in CellI within 72 hours of discovery.
Part I.E.7(c) of the Permit requires that the wastewater level in Roberts Pond must be monitored
and recorded weekly, in accordance with the currently approved DMT Plan, to determine
compliance with the DMT operations standard in Part I.D.3(e) of the Permit;
2.15.2.5 Inspection of Feedstock Storage Area
Part I.D.3(f) of the Permit requires that open-air or bulk storage of all feedstock materials at the
Mill facility awaiting Mill processing must be limited to the eastern portion of the Mill site (the
"ore pad") described by the coordinates set out in that Part of the Permit, and that storage of
feedstock materials at the facility outside of this defined area, must meet the requirements of Part
I.D.II of the Permit. Part I.D.II requires that Denison must store and manage feedstock
materials outside the defined ore storage pad in accordance with an approved Feedstock
Management Plan. On June 20, 2008, Denison submitted a White Mesa Mill Containerized
Alternate Feedstock Material Storage Procedure for Director review and approval. A copy of
that procedure is included as Appendix K to this Application. The Director is currently
reviewing that procedure.
Part I.E.7(d) of the Permit requires that Denison inspect the feedstock storage areas weekly to:
a) Confirm that the bulk feedstock materials are maintained within approved feedstock
storage defined by Table 4; and
b) Verify that all alternate feedstock materials located outside the feedstock storage area
defined in Table 4 are stored in accordance with the requirements found in Part I.D.II.
Part I.E. 7 (d) further provides that Denison must implement the Feedstock Material Storage
Procedure immediately upon Director approval.
The Mill's Standard Operating Procedure under the Mill License for inspection of the Mill's ore
pad is contained in Section 3.3 of the DMT Plan, a copy of which is attached as Appendix G to
this Application.
62
2.15.2.6 Monitor and Maintain Inventory of Chemicals
Part I.D.3(g) of the Permit requires that for all chemical reagents stored at existing storage
facilities and held for use in the milling process, Denison must provide secondary containment to
capture and contain all volumes of reagent(s) that might be released at any individual storage
area. Response to spills, cleanup thereof, and required reporting must comply with the
provisions of an approved Emergency Response Plan as found in an approved Stormwater Best
Management Practices Plan, stipulated by Parts I.D.10 and I.D.3(g)of the Permit. Part I.D.3(g)
further provides that for any new construction of reagent storage facilities, such secondary
containment and control must prevent any contact of the spilled or otherwise released reagent or
product with the ground surface.
Part I.E.9 of the Permit requires that Denison must monitor and maintain a current inventory of
all chemicals used at the facility at rates equal to or greater than 100 kg/yr. This inventory must
be maintained on-site, and must include:
(i) Identification of chemicals used in the milling process and the on-site laboratory;
and
(ii) Determination of volume and mass of each raw chemical currently held in storage
at the facility.
A copy of the Mill's chemical Inventory is attached as Appendix L to this Application.
A copy of the Mill's Stormwater Best Management Practices Plan, Revision 1.4; October 2011
is attached as Appendix F to this Application.
2.15.3 BAT Performance Standards for Cell 4A
2.15.3.1 BAT Operations and Maintenance Plan
Part I.D.6 provides that Denison must operate and maintain Cell 4A so as to prevent release of
wastewater to groundwater and the environment in accordance with a BAT Operations and
Maintenance Plan, as approved by the Director, pursuant to Part I.H.19 of the Permit, and that at
a minimum such plan must include the following performance standards:
a) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
b) The leak detection system maximum allowable daily leak rate shall not exceed 24,160
gallons/day;
c) After Denison initiates pumping conditions in the slimes drain layer in Cell 4A,
Denison will provide continuous declining fluid heads in the slimes drain layer, in a
manner equivalent to the requirements found in Part I.D.3(b) for Cells 2 and 3; and
d) Under no circumstances shall the freeboard be less than 3-feet in Ce1l4A, as measured
from the top of the FML.
The BAT Operations and Maintenance Plan required under Part I.H.19 was submitted on
September 16, 2008 and approved by the Director on September 17, 2008. A copy of the most
63
currently-approved BAT Operations and Maintenance Plan Revision 2.3 dated July 2011, is
included as Appendix E to this Application.
2.15.3.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.8 of the Permit provides that, after Director approval of the Tailings Ce1l4A Operations
and Maintenance Plan, required by Part I.H.19 of the Permit, Denison must immediately
implement all monitoring and recordkeeping requirements contained in the plan. At a minimum,
such BAT monitoring shall include:
a) Weekly Leak Detection System (LDS) Monitoring -including:
(i) Denison must provide continuous operation of the leak detection system pumping
and monitoring equipment, including, but not limited to, the submersible pump,
pump controller, head monitoring, and flow meter equipment approved by the
Director. Failure of any pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT and
a violation of the Permit;
(ii) Denison must measure the fluid head above the lowest point on the secondary
FML by the use of procedures and equipment approved by the Director. Under
no circumstance shall fluid head in the leak detection system sump exceed a 1-
foot level above the lowest point in the lower FML on the cell floor. For purposes
of compliance monitoring this I-foot distance shall equate to 2.28 feet above the
leak detection system transducer;
(iii) Denison must measure the volume of all fluids pumped from the leak detection
system. Under no circumstances shall the average daily leak detection system
flow volume exceed 24,160 gallons/day; and
(iv) Denison must operate and maintain wastewater levels to provide a 3-foot
Minimum of vertical freeboard in tailings Cell 4A. Such measurements must be
made to the nearest 0.1 foot.
b) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4A slimes drain system,
monthly recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of the Permit and any plan approved by the Director.
2.15.4 BAT Performance Standards for Cell 4B
2.15.4.1 BAT Operations and Maintenance Plan
Part I.D.13 provides that Denison must operate and maintain Cell 4B so as to prevent release of
wastewater to groundwater and the environment in accordance with a BAT Operations and
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Maintenance Plan, as approved by the Director, pursuant to Part I.H.19 of the Permit, and that at
a minimum such plan must include the following performance standards:
e) The fluid head in the leak detection system shall not exceed 1 foot above the lowest
point in the lower membrane liner;
f) The leak detection system maximum allowable daily leak rate shall not exceed 26,145
gallons/day;
g) After Denison initiates pumping conditions in the slimes drain layer in Cell 4B,
Denison will provide continuous declining fluid heads in the slimes drain layer, in a
manner equivalent to the requirements found in Part I.D.3(b) for Cells 2,3 and 4A; and
h) Under no circumstances shall the freeboard be less than 3-feet in Cell 4B, as measured
from the top of the FML.
As mentioned above, the BAT Operations and Maintenance Plan was submitted on September
16,2008 and approved by the Director on September 17,2008. A copy of the most currently-
approved BAT Operations and Maintenance Plan, Revision 2.3 dated July 2011, is included as
Appendix E to this Application.
2.15.4.2 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.12 of the Permit provides that Denison must implement all monitoring and
recordkeeping requirements contained in the Tailings Cell4B BAT Operations and Maintenance
Plan. At a minimum, such BAT monitoring includes:
c) Weekly Leak Detection System (LDS) Monitoring -including:
(i) Denison must provide continuous operation of the leak detection system pumping
and monitoring equipment, including, but not limited to, the submersible pump,
pump controller, head monitoring, and flow meter equipment approved by the
Director. Failure of any pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT and
a violation of the Permit;
(ii) Denison must measure the fluid head above the lowest point on the secondary
FML by the use of procedures and equipment approved by the Director. Under
no circumstance shall fluid head in the leak detection system sump exceed a 1-
foot level above the lowest point in the lower FML on the cell floor. For purposes
of compliance monitoring this I-foot distance shall equate to 2.25 feet above the
leak detection system transducer;
(iii) Denison must measure the volume of all fluids pumped from the leak detection
system. Under no circumstances shall the average daily leak detection system
flow volume exceed 26,145 gallons/day; and
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(iv) Denison must operate and maintain wastewater levels to provide a 3-foot
Minimum of vertical freeboard in tailings Cell 4B. Such measurements must be
made to the nearest 0.1 foot.
d) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4B slimes drain system,
monthly recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts I.D.3 and I.E.7 (b) of the Permit and any plan approved by the Director.
2.15.4.3 Implementation of Monitoring Requirements Under the BAT Operations and Maintenance
Plan
Part I.E.12 of the Permit provides that, after Director approval of the Tailings Cell4B Operations
and Maintenance Plan, Denison must immediately implement all monitoring and recordkeeping
requirements contained in the plan. At a minimum, such BAT monitoring shall include:
e) Weekly Leak Detection System (LDS) Monitoring -including:
(i) Denison must provide continuous operation of the leak detection system pumping
and monitoring equipment, including, but not limited to, the submersible pump,
pump controller, head monitoring, and flow meter equipment approved by the
Director. Failure of any pumping or monitoring equipment not repaired and made
fully operational within 24-hours of discovery shall constitute failure of BAT and
a violation of the Permit;
(ii) Denison must measure the fluid head above the lowest point on the secondary
FML by the use of procedures and equipment approved by the Director. Under
no circumstance shall fluid head in the leak detection system sump exceed a 1-
foot level above the lowest point in the lower FML on the cell floor. For purposes
of compliance monitoring this I-foot distance shall equate to 2.25 feet above the
leak detection system transducer;
(iii) Denison must measure the volume of all fluids pumped from the leak detection
system. Under no circumstances shall the average daily leak detection system
flow volume exceed 26,145 gallons/day; and
(iv) Denison must operate and maintain wastewater levels to provide a 3-foot
Minimum of vertical freeboard in tailings Cell 4B. Such measurements must be
made to the nearest 0.1 foot.
f) Slimes Drain Recovery Head Monitoring
Immediately after the Mill initiates pumping conditions in the Cell 4B slimes drain system,
monthly recovery head tests and fluid level measurements will be made in accordance with the
requirements of Parts I.D.3 and I.E.7(b) of the Permit and any plan approved by the Director.
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2.15.5 Storm water Management and Spill Control Requirements
Part I.D.10 of the Permit requires that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the facility in accordance with an approved
stormwater best management practices plan. Such plan must include the following minimum
provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.4(C);
b) Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Director in accordance with
UAC 19-5-114.
The Mill's Stormwater Best Management Practices Plan dated June 12,2008, was approved by
the Director on July 1, 2008. A copy of the most recently approved Mill's Stormwater Best
Management Practices Plan Revision dated 1.4 October 2011, is included as Appendix F to this
Application.
2.15.6 Tailings and Slimes Drain Sampling
Part I.E. 1 0 of the Permit requires that on an annual basis, Denison must collect wastewater
quality samples from each wastewater source at each tailings cell at the facility, including
surface impounded wastewaters, the leak 'detection systems (if present) and slimes drain
wastewaters. All such sampling must be conducted in August of each calendar year in
compliance with the approved Tailings Cell Tailings Sampling Plan.
See Section 2.12.1 above for a more detailed description of this program.
The Mill's Tailings and Slimes Drain Sampling Program was approved by the Director. The
most recently approved version is included as Appendix I to this Application. As of this writing,
Denison has submitted Revision 2.1, which is undergoing review by the Director.
2.15.7 Additional Monitoring and Inspections Required Under the Mill License
Under the Mill License daily, weekly, and monthly inspection reporting and monitoring are
required by NRC Regulatory Guide 8.31, Information Relevant to Ensuring that Occupational
Radiation Exposures at Uranium Recovery Facilities will be As Low As is Reasonable
Achievable, Revision 1, May 2002 ("Reg Guide 8.31"), by Section 2.3 of the Mill's ALARA
Program and by the Mill's Environmental Protection Manual ("EPM"), over and above the
inspections described above that are required under the Permit.
Denison recently submitted for Director approval, a revised DMT Plan and Tailings
Management System Procedure (Section 3.1 of the EPM) to separate the RML DMT
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requirements from the GWDP DMT requirements, into two separate documents. As of this
writing, both of these plans are undergoing review by the Director.
2.15.7.1 Daily Inspections
Three types of daily inspections are performed at the Mill under the Mill License:
a) Radiation Staff Inspections
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the Mill's Radiation Safety Officer ("RSO") or
designated health physics technician should conduct a daily walk-through (visual) inspection of
all work and storage areas of the Mill to ensure proper implementation of good radiation safety
procedures, including good housekeeping that would minimize unnecessary contamination.
These inspections are required by Section 2.3.1 of the Mill's ALARA Program, and are
documented and on file in the Mill's Radiation Protection Office.
b) Operating Foreman Inspections
30 CFR Section 56.18002 of the Mine Safety and Health Administration regulations requires that
a competent person designated by the operator must examine each working place at least once
each shift for conditions which may adversely affect safety or health. These daily inspections are
documented and on file in the Mill's Radiation Protection Office.
c) Daily Tailings Inspection
Section 3.1 of the Mill's EPM requires that during Mill operation, the Shift Foreman, or other
person with the training specified in paragraph 2.4 of the Tailings Management Procedure,
designated by the RSO, will perform an inspection of the tailings line and tailings area at least
once per shift, paying close attention for potential leaks and to the discharges from the pipelines.
Observations by the Inspector are recorded on the appropriate line on the Mill's Daily Inspection
Data form.
2.15.7.2 Weekly Inspections
Three types of weekly inspections are performed at the Mill under the Mill License:
a) Weekly Inspection of the Mill Forms
Paragraph 2.3.1 of Reg. Guide 8.31 provides that the RSO and the Mill foreman should, and
Section 2.3.2 of the Mill's ALARA Program provides that the RSO and Mill foreman, or their
respective designees, shall conduct a weekly inspection of all Mill areas to observe general
radiation control practices and review required changes in procedures and equipment. Particular
attention is to be focused on areas where potential exposures to personnel might exist and in
areas of operation or locations where contamination is evident.
b) Weekly Ore Storage Pad Inspection Forms
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Paragraph 3.3 of the DMT Plan and Part I.E.7.(d of the Permit requires that weekly feedstock
storage area inspections will be performed by the Radiation Safety Department, to confirm that
the bulk feedstock materials are stored and maintained within the defined area of the ore pad and
that all alternate feed materials located outside the defined ore pad area are maintained in
accordance with the requirements of the Permit. The results of these inspections are recorded on
the Mill's Ore Storage/Sample Plant Weekly Inspection Report.
c) Weekly Tailings and DMT Inspection
Section 3.1 of the EPM requires that weekly inspections of the tailings area and DMT
requirements be performed by the radiation safety department.
2.15.7.3 Monthly Reports
Two types of monthly reports are prepared by Mill staff:
a) Monthly Radiation Safety Reports
At least monthly, the RSO reviews the results of daily and weekly inspections, including a
review of all monitoring and exposure data for the month and provides to the Mill Manager a
monthly report containing a written summary of the month's significant worker protection
activities (Section 2.3.4 of the ALARA Program).
b) Monthly Tailings Inspection Reports
Section 3.1 of the EPM, requires that a Monthly Inspection Data form be completed for the
monthly tailings inspection. This inspection is typically performed in the fourth week of each
month and is in lieu of the weekly tailings inspection for that week.
Mill staff also prepares a monthly summary of all daily, weekly, monthly and quarterly tailings
inspections.
2.15.7.4 Quarterly Tailings Inspections
Section 3.1 of the EPM requires that the RSO or his designee perform a quarterly tailings
inspection.
2.15.7.5 Annual Evaluations
The following annual evaluations are performed under the Mill License, as set out in Section 3.1
of the EPM.
a) Annual Technical Evaluation
An annual technical evaluation of the tailings management system must be performed by a
registered professional engineer (PE), who has experience and training in the area of
geotechnical aspects of retention structures. The technical evaluation includes an on-site
inspection of the tailings management system and a thorough review of all tailings records for
69
the past year. The Technical Evaluation also includes a review and summary of the annual
movement monitor survey (see Section (b) below).
All tailings cells and corresponding dikes are inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches are inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations were performed for the receipt of alternate feed
material during the year, the capacity evaluation forms and associated calculation sheets will be
reviewed to ensure that the maximum tailings capacity estimate is accurate. The amount of
tailings added to the system since the last evaluation will also be calculated to determine the
estimated capacity at the time of the evaluation.
As discussed above, tailings inspection records consist of daily, weekly, monthly, and quarterly
tailings inspections. These inspection records are evaluated to determine if any freeboard limits
are being approached. Records will also be reviewed to summarize observations of potential
concern. The evaluation also involves discussion with the Environmental and/or Radiation
Technician and the RSO regarding activities around the tailings area for the past year. During
the annual inspection, photographs of the tailings area are taken. The training of individuals is
also reviewed as a part of the Annual Technical Evaluation.
The registered engineer obtains copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These
copies are then included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 1st of every year to
the Directing Dam Safety Engineer, State of Utah, Natural Resources.
b) Annual Movement Monitor Survey
A movement monitor survey is conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes
3-S, 4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data
generated from this survey is reviewed and incorporated into the Annual Technical Evaluation
Report of the tailings management system.
c) Annual Leak Detection Fluid Samples
Annually, the leak detection system fluids in Cells 1, 2, 3, 4A and 4B will be sampled when
present as described in the Tailings Sampling Plan in Section 2.12.1.
2.16 Corrective Action Plan or Identification of Other Response Measures to be Taken to Remedy
any Violation of Applicable Ground Water Quality Standards (R317-6-6.3.P)
There are two circumstances where applicable groundwater standards have been exceeded at the
site that are not associated with natural background: chloroform contamination, and nitrate
contamination. As discussed below, none of these circumstances appear to be related to
discharges from milling activities. See Section 2.11.2 for a discussion of the current
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investigation into exceedances of GWCLs for certain constituents and decreasing pH trends at
the site, which Denison believes are associated with natural background.
2.16.1 Chloroform Investigation
In May, 1999, excess chloroform concentrations were discovered in monitoring well MW-4, in
the shallow perched aquifer along the eastern margin of the Mill site. Because these
concentrations were above the GWQS for chloroform, the Executive Secretary of the Utah Water
Quality Board initiated enforcement action against the Mill on August 23, 1999 through the
issuance of a Groundwater Corrective Action Order (UDEQ Docket No. UGO-20-01), which
required completion of: 1) a contaminant investigation report to define and bound the
contaminant plume, and 2) a groundwater corrective action plan to clean it up. Repeated
groundwater sampling by both the Mill and DRC have confirmed the presence of chloroform in
concentrations that exceed the GWQS along the eastern margin of the site in wells that are
upgradient or cross gradient from the tailings cells. Other VOC contaminants and nitrate and
nitrite have also been detected in these samples. After installation of 27 new monitoring wells at
the site, groundwater studies appear to have defined the boundaries of the chloroform plume.
Based on the location of the plume and characterization studies completed to date, the
contamination appears to have resulted from the operation of temporary laboratory facilities that
were located at the site prior to and during construction of the Mill facility, and septic drainfields
that were used for laboratory and sanitary wastes prior to construction of the Mill's tailings cells.
Interim measures have been instituted in order to contain the contamination and to pump
contaminated groundwater into the Mill's tailings cells. To that end, the Mill has equipped 5 of
the wells (MW-4, TW4-4, MW-26 (previously named TW4-15), TW4-19 and TW4-20) with
pumps to recover water impacted by chloroform and to dispose of such water in the Mill's
tailings cells.
In the 2004 Statement of Basis, DRC noted on page 3 that, while the contaminant investigation
and groundwater remediation plan are not yet complete, the DRC believes that additional time is
available to resolve these requirements based · on the following factors: 1) hydraulic isolation
found between the shallow perched aquifer in which the contamination has been detected and the
deep confined aquifers which are a source of drinking water in the area, 2) the large horizontal
distance and the long groundwater travel times between the existing groundwater contamination
on site and the seeps and springs where the shallow aquifer discharges at the edge of White
Mesa, and 3) lack of human exposure for these shallow aquifer contaminants along this travel
path.
Denison submitted a Preliminary Corrective Action Plan, White Mesa Mill Near Blanding, Utah,
August 20, 2007, prepared by Hydro Geo Chern, Inc., on August 21, 2007, and a Preliminary
Contamination Investigation Report, White Mesa Mill Near Blanding, Utah, November 20,2007,
prepared by Hydro Geo Chern, Inc., on December 21, 2007. Those documents are currently
under review by the Director.
The objectives of the proposed Corrective Action Plan include the following:
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a) Minimize or prevent further downgradient migration of the chloroform plume by a
combination of pumping and reliance on natural attenuation;
b) Prevent chloroform concentrations exceeding the action level from migrating south or
southwest of the tailings cells;
c) Monitor to track changes in concentrations within the plume and to establish whether
the plume boundaries are expanding, contracting, or stable;
d) Provide contingency plans to address potential continued expansion of the plume and
the need for additional monitoring and/or pumping points; and
e) Ultimately reduce chloroform concentrations at all monitoring locations to the action
level or below.
To achieve these objectives, the proposed Corrective Action Plan proposes a phased approach.
The first phase consists of a combination of "active" and "passive" strategies. The active
strategy consists of removing chloroform mass as rapidly as practical by pumping areas that have
(on a relative basis) both high chloroform concentrations, and high productivity. Continued
monitoring within and outside the plume is considered part of the active strategy. The passive
strategy consists of relying on natural attenuation processes to remove chloroform mass and
reduce concentrations. Reductions in concentrations would be achieved by physical processes
such as volatilization, hydrodynamic dispersion, and abiotic degradation, and through natural
biological degradation of chloroform. These are essentially the same processes that have been
relied upon in the interim action.
Natural attenuation is expected to reduce chloroform concentrations within the entire plume.
However, within upgradient portions of the plume that occur in higher permeability materials,
that are amenable to pumping, direct mass removal via pumping will be the primary means to
reduce concentrations. In down gradient portions of the plume where permeabilities are low,
chloroform migration rates are low, and mass removal by pumping is not practical because
achievable pumping rates would be very low, natural attenuation will be the primary means to
reduce concentrations.
The second phase relies on natural attenuation (without pumping) to reduce chloroform
concentrations at all monitoring locations to action levels, once concentrations during Phase 1
are judged to be sufficiently low that Phase 2 will be effective.
As part of the active strategy in the first phase of the Corrective Action Plan, Denison has
operated a chloroform capture system, referred to as the "Long-term Pump Test" continuously
since January 31, 2010. The purpose of the test is to serve as an interim action that will remove a
significant amount of chloroform-contaminated water while gathering additional data on
hydraulic properties in the area of investigation. Chloroform-contaminated water is captured by
pumping six wells located within the identified chloroform plume, and transferred via an above-
ground piping network to Tailings Cell 1 for disposal.
Effectiveness of the first phase of the Corrective Action is evaluated and documented in
quarterly reports to the Director. Denison estimates that, to date, 597 lbs. of chloroform have
been extracted through the capture system.
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2.16.2 Nitrate Investigation
During review of the New Well Background Report and other reports, a Nitrate contaminant
plume was identified by DRC staff in five monitoring wells in the Mill site area, including wells:
MW-30, MW-31, TW4-22, TW4-24, and TW4-25. TW4-25 is located up gradient of the Mill's
tailings cells. Elevated concentrations of chloride also appear to be associated with the nitrate
plume.
On September 30, 2008, the Director issued a request for a voluntary plan and schedule for
Denison to investigate and remediate this Nitrate contamination. On November 19, 2008
Denison submitted a plan and schedule prepared by INTERA, Inc., which identified a number of
potential sources for the contamination, including several potential historic and offsite sources.
On January 27, 2009, the Director and Denison signed a Stipulated Consent Agreement ("SCA")
by which Denison agreed to conduct an investigation of the Nitrate contamination, determine the
sources of pollution, and submit a report by January 4, 2010.
Denison submitted a Contaminant Investigation Report ("CIR") on December 30, 2009. On
October 5, 2010 the Director issued a Notice of Additional Required Action ("NARA") letter
that notified Denison of the Director's determination that the 2009 CIR was incomplete.
On December 20, 2010 Denison and the Director entered into Revision 0 of a Tolling Agreement
allowing a tolling period until April 30, 2011 in order to provide time for Denison to prepare a
Plan and Schedule for Director review addressing additional investigations to resolve open issues
identified in the October 5,2010 NARA, and to execute a revised SCA.
Denison submitted a Plan and Schedule on February 14, 2011 and a revised Plan and Schedule
on February 18, 2011. the Director provided his comments on the revised Plan and Schedule on
March 21, 2011. In an April 20, 2011 meeting, Denison and the Director agreed that the Plan and
Schedule to conduct additional nitrate investigations would be composed of four to five phases
of study, including geoprobe drilling and soil sampling/analysis to investigate natural nitrate salt
reservoir sources in the vadose zone beyond the Mill site, potential Mill sources, and other
potential sources; groundwater sampling and analysis of existing monitoring wells for non-
isotopic analytes; deep bedrock core sampling/analysis of possible natural nitrate reservoir and
potential nitrate source locations; stable isotopic sampling/analysis of groundwater in existing
monitoring wells; and stable isotopic sampling/analysis of soil/core samples, if needed.
On April 28, 2011, Denison and the Director entered into Revision 1 of the Tolling Agreement to
extend the Tolling Period through June 30, 2011 and adopt the agreements made on April 20,
2011. Under the Tolling Agreement Revision 1, Denison agreed to submit a Revised Phase 1 (A
through C) Work Plan on or before May 6, 2011 and a Revised Phase 2 through 5 Work Plan and
Schedule on or before June 3, 2011.
Denison submitted a May 6, 2011 Revised Phase 1 Work Plan and Schedule for the Phase 1 A -
C investigation for Director review. Denison conducted field and laboratory work for the Phase I
A-C study in May and June, 2011.
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Denison submitted a Revised Phase 2 through 5 Work Plan and Schedule for Director review on
June 3, 2011. The Director provided comments on this document on June 23, 2011 and advised
Denison that in order to revise the 2009 SCA to incorporate needed deliverables and timelines,
the Phase 2 through 5 Work Plan would need to be expanded to the same level of detail as was
provided for Phase 1 in Attachment 1 of the Revision 1 Tolling Agreement.
On June 30, 2011, Denison and the Director entered into Revision 2 of the Tolling Agreement
extending the Tolling Period to August 31, 2011, to facilitate the revision of the Phase 2 through
5 Work Plan to provide the required level of detail to construct a replacement SCA. Denison
submitted a separate July 1, 2011 detailed Revision 0 of the Work Plan and Quality Assurance
Plan ("QAP") for the Phase 2 investigation. The Director provided comments on this document
on July 7, 2011. Denison provided a July 12, 2011 Revision 1.0 to the Phase 2 QAP and Work
Plan, which DRC conditionally approved in a letter dated July 18, 2011. On August 1 and 2,
2011 Denison submitted by email preliminary laboratory results for the Phase I A-C study to the
Director.
On August 4, 2011, Denison provided a Revision 1.0 to the Phase 2 - 5 Work Plan for Director
review. The Director provided comments on the Phase 2-5 Work Plan, Revision 1.0 and the
August 1, 2011 preliminary laboratory results on August 11, 2011. Denison submitted Revision
2.0 of the Phase 2-5 Work Plan for Director review on August 11, 2011.
On August 25, 2011, the Director determined that based on review of the Revision 2.0 Phase 2-5
Work Plan, a finalized Plan and Schedule that meets the satisfaction of the Director, and which
would allow the preparation of a replacement SCA, was not possible at that time; and that the
development of a replacement SCA for continued contaminant investigation activities was not
supported.
At a meeting on August 29,2011, Denison and DRC agreed that:
1. After more than two years of investigation it has been determined that there are site
conditions that make it difficult to determine the source( s) of the contamination at the
White Mesa site;
2. As a result, resources will be better spent in developing a CAP in accordance with U AC
R317-6-6.15(D), rather than continuing with further investigations as to the source(s) of
the contamination.
In discussions during October 2011, Denison and the Director acknowledged that it has not been
possible to date to determine the source(s), cause(s), attribution, magnitudes of contribution, and
proportion(s) of the local nitrate and chloride in groundwater, and thereby cannot eliminate Mill
activities as a potential cause, either in full or in part, of the contamination. As a result, Denison
and the Director agreed that resources will be better spent in developing a Corrective Action Plan
in accordance with UAC R317-6-6.15(D), rather than continuing with further investigations.
On October 3, 2011 Denison and the Director entered into a revised Stipulated Consent
Agreement which required Denison to submit a Corrective Action Plan for Director review
which includes at least the following three phases of activity:
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Phase I -to determine the physical extent of soil contamination observed at the
Ammonium Sulfate Crystal Tanks, and provide a control measure consisting of either
removal of the areal extent of contamination down to bedrock, or a Plan and Schedule for
covering the areal extent of contamination with at least 6 inches of concrete, followed by
removal action during or before site closure.
Phase II -to include near term active remediation of the nitrate contamination by
pumping contaminated water into the Mill's tailings cells for disposal. This phase is to
include development, implementation, operation, and monitoring for a pumping well
network to contain and hydraulically control the nitrate plume; monitoring of chloride
concentrations; and any required increases to the Mill's surety for activities in this Phase.
Phase III -if necessary, to include a comprehensive long-term solution for the nitrate
contamination at the Mill Site. This Phase is to be determined after public participation
and Director approval, and may include continuation of Phase I and II activities alone or
in combination with any of the following: monitored natural attenuation, additional
remediation and monitoring, determination of additional hydrogeologic characterization,
contaminant travel times, points of exposure to public or wildlife, risk analysis,
costlbenefit analysis, and possible development and petetion of the Board for alternate
Corrective action concentration limits.
Denison submitted a Draft Corrective Action Plan on November 30, 2011. The Director
provided comments on the Draft Corrective Action Plan on January 19, 2012. Denison provided
Revision 1.0 of the Corrective Action Plan on February 27, 2012, and received comments from
the Director on March 19, 2012. Pursuant to the revised SCA, Denison provided Revision 2.0 to
the Director on May 7,2012.
The Director prepared a draft Stipulation and Consent Order and a Statement of Basis on July 5,
2012. The Statement of Basis and the Revised CAP will undergo a public review and comment
period beginning July 18, 2012. Following the Director's final approval of Corrective Action
Plan, Denison will initiate corrective actions consistent with the schedule provided in the
Stipulation and Consent Order.
2.17 Other Information Required by the Director (R317-6-6.3.Q)
2.17.1 Chemical Inventory Report
Part I.H.1 of the Permit requires that Denison complete a historical review and conduct an
inventory of all chemical compounds or reagents stored, used, or currently in use at the facility.
including the types of chemicals and the total volumes present, and historically used, as data is
available. Denison submitted a chemical inventory report on June 7, 2005, and submitted
additional related information on November 17, 2006.
Part I.H.1 requires that at the time of Permit renewal, the Permittee shall submit an updated
inventory report. Part I.E.9 requires that the inventory address chemicals used in the milling
process and the on-site laboratory. The updated inventory report is provided in Appendix L of
this Application.
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2.17.2 Southwest Hydrogeological Investigation
Part I.H.6 of the Permit required that Denison perform a detailed Southwest Hydrogeologic
Investigation to define, demonstrate and characterize: 1) the hydraulic connection and local
groundwater flow directions between the area near Tailings Cell 4B, and the westerm margin of
White Mesa, and 2) the full physical extent of the unsaturated area between former well MW -16,
MW-33 and the western margin of White Mesa.
During 2011, Denison installed 18 piezometers to demonstrate the geologic and physical extent
of the apparent unsaturated structural high between Tailings Cell 4B and the western margin of
White Mesa, and to demonstrate the location and direction of groundwater flow paths between
Tailings Cell 4B and Westwater and Cottonwood Seeps and Ruin Spring. Consistent with Part
I.H.6.c) of the Permit, Denison submitted an investigation report, the Hydrogeology of the
Perched Groundwater Zone in the Area Southwest of the Tailings Cells, White Mesa Uranium
Mill Site (the "Southwest Hydrogeology Report"), prepared by Hydrogeochem, on January 12,
2012. The Director provided comments in a conference call during May 2012, and in a letter
dated May 30, 2012. In an additional conference call following Denison's receipt of the May 30
letter, Denison and the Director agreed that Denison would respond to the letter by preparing a
revision to the Southwest Hydrogeology Report by August 3, 2012.
No other information has been specifically required by the Director to be included in this
Application at this time. Denison will provide additional information as requested by the
Director
2.18 This Application Performed Under the Direction of a Professional Engineer (R317-6-6.3.R)
This Application has been performed under the direction, and bears the seal, of Harold R.
Roberts, Executive Vice President, US Operations of Denison. Mr. Roberts is a Registered
Professional Engineer in the State of Utah, No. 165838.
2.19 Closure and Post Closure Management Plan Demonstrating Measures to Prevent Ground
Water Contamination During the Closure and Post Closure Phases of Operation (R17 -6-6.3.S)
2.19.1 Regulatory Requirements for Uranium Mills
2.19.1.1 Long Term Custodian
One unique feature of the regulatory scheme for uranium mill tailings is that Section 83 of the
Atomic Energy Act of 1954, as amended by the Uranium Mill Tailings Radiation Control Act of
1978 ("UMTRCA") (the Atomic Energy Act of 1954 as so amended is referred to herein as the
"AEA,,)4 requires that, prior to license termination, title to uranium mill tailings (11e.(2)
byproduct material) must be transferred to the United States Department of Energy ("DOE") or
the State in which the activity occurred, if the State so elects, for custody and long term care. 10
CFR 40.28 provides a general license to DOE or the State for that purpose.
4 See 42 U.S.C. 2113.
76
2.19.1.2 Responsibility For And Manner Of Clean Up
UMTRCA amended the ABA to require that all Title IT facilities (i.e., active mills) will comply
with the decontamination, decommissioning, and reclamation standards prescribed by the
Commissions and to require that such facilities post reclamation bonds or surety6.
Responsibility for reclamation rests with the licensee. 10 CFR Part 40 Appendix A Criterion 6A
requires the adoption of a Director-approved reclamation plan for the site, Criterion 9 requires
that financial surety must be established to fund the cost of reclamation in accordance with such
plan, and Criterion 10 requires that each licensee include in its financial surety an amount
equivalent to $250,000 (1978 dollars) to cover the costs of long-term surveillance by the long-
term government custodian (DOE). Criteria 6, 9 and 10 have been incorporated by reference
into the Utah rules by UAC R313-24-4.
2.19.1.3 Surface
The reclamation plan adopted by the Mill at the outset, as required by 10 CFR Part 40, Appendix
A, Criterion 9, must address the decontamination and decommissioning of the Mill and Mill site
and reclamation of any tailings or waste disposal areas.
As is the case for most uranium mills, the Mill's reclamation plan must require that upon closure,
all mill buildings, unsalvageable equipment, contaminated soils (impacted by Mill operations
within the Mill site itself as well as surrounding areas that may be impacted by windblown
radioactive dusts from milling operations) etc. must be deposited in the tailings cells and the
tailings cells capped in place.
Appendix A, Criterion 6(6) sets the standard for determining when all impacted areas, other than
the tailings impoundments have been adequately cleaned up. Criterion 6(6) provides that
byproduct material containing concentrations of radionuclides other than radium in soil, and
surface activity on remaining structures, must not result in a total effective dose equivalent
(TEDE) exceeding the dose from cleanup of radium contaminated soil to the benchmark standard
of 5pCi/g concentration of radium in the surface 15 cm (6 in) and 15 pCi/g concentration of
radium in the subsurface, and must be at levels which are ALARA. If more than one residual
radionuclide is present, the sum of the ratios for each radionuclide present will not exceed "1"
(unity). Further details on the NRC's approach to evaluating reclamation plans and release
criteria for uranium mill sites, including the manner of modeling the release standard set out in
Criterion 6(6), are contained in NUREG-1620, Rev 1, Standard Review Plan for the Review of a
Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill Tailings Radiation
Control Act of 1978, Final Report, June 2003 ("NUREG-1620").
2.19.1.4 Groundwater
Each uranium mill is required to have a groundwater monitoring program. In the case of the
5 See 42 U.S.C. 2113.
6 See 42 U.S.C. 2201.
77
Mill, the Permit implements the applicable requirements of UAC R317 -6. If there is
groundwater contamination after cessation of operations, the requirements of UAC R317 -6.15
must be satisfied.
2.19.1.5 License Termination
Section 83.7 of the ABA 7 provides that material and land transferred to the long term custodian
must be transferred without cost to the long-term custodian other than administrative and legal
costs incurred in carrying out such transfer.
In order to cover the costs of long-term surveillance, Criterion 10 requires that a minimum
charge of $250,000 (1978 dollars) must be paid by each mill operator to the general treasury of
the United States or to an appropriate State agency prior to the termination of a uranium mill
license.
In most cases if there is a groundwater contamination problem, the problem must be remediated
prior to license termination, or an alternate corrective action concentration limit under R317 -6-
6.15.G must be obtained, thereby resolving the problem. In some circumstances DOE may agree
to take some additional actions after it takes title to the site, such as additional monitoring, if not
onerous and provided adequate funding is provided.
Upon the Director being satisfied that all regulatory requirements have been met and the site is
reclaimed in a manner that satisfies all applicable standards, the Mill's license will be terminated
upon transfer of the tailings to DOE. 10 CFR 40.28 provides a general license in favor of the
long-term custodian for custody of and long-term care of the tailings impoundments and any
surrounding lands transferred to it. 8 The surrounding areas not transferred to DOE would
generall y be free-released.
2.19.2 Current Reclamation Plan
The Mill's Reclamation Plan, Revision 4.0, was approved by DRC under the Mill License in
January 2011. The Reclamation Plan sets out the requirements to be met by Denison for the
final reclamation and closure of the Mill facility, including the tailings cells and all impacted
surrounding areas, in accordance with the requirements of 10 CFR Part 40, Appendix A (which
have since been incorporated by reference into UAC R313-24). A copy of the Mill's
Reclamation Plan, Revision 4.0 was previously submitted to the Director and is on file at the
DRC.
Denison submitted Revision 5.0 of the Reclamation Plan in September 2011. Denison is in the
process of responding to the one round of interrogatories received to date. Submission of
responses to all first round interrogatory questions will be completed by August 15, 2012
7 See 42 U.S.C. 2113.
8 In circumstances where the facility has a groundwater contamination plume, additional lands may be acquired by
the licensee in order to bound the plume. In these circumstances these additional lands would be transferred along
with the capped tailings impoundments, to DOE.
78
2.19.3 Provisions Included in the Permit Relating to the Mill's Reclamation Plan
The Mill License is currently in timely renewal. As part of the Mill License Renewal, DRC is
re-examining the Mill's Reclamation Plan for content and adequacy. At the time of original
issuance of the Permit the Director had not completed his review of the Mill's Reclamation Plan.
As a result, new requirements were added to the Permit to ensure that the final reclamation
design approved by the Director on his re-examination of the Reclamation Plan will provide
adequate performance criteria to protect local groundwater quality.
To this end, three requirements were included in Part I.D.8 of the Permit to ensure that the cover
system for each tailings cell will be designed and constructed to:
a) Minimize the infiltration of water into the radon barrier and underlying tailings waste;
b) Prevent the accumulation of leachates within the tailings that might create a bathtub
effect and thereby spill over the maximum elevation of the FML inside any disposal
cell; thereby causing a release of contaminants to the environment; and
c) Protect groundwater quality at the compliance monitoring wells by ensuring that
contaminant concentrations there do not exceed their respective GWQS or GWCL
defined in Part I.C.l and Table 2 of the Permit.
To provide consistency with the performance criteria stipulated by the Director at other lle.(2)
disposal operations, a 200-year minimum performance period was required for all three of these
criteria.
In addition, Part I.D.9 was included in the Permit, which provides that upon commencement of
decommissioning, Denison will reclaim the Mill site and all related facilities, stabilize the
tailings cells, and construct a cover system over the tailings cells in compliance with all
engineering design and specifications in an approved reclamation plan. Part I.D.7 also provides
that the Director reserves the right to require modifications to the Mill's Reclamation Plan for
purposes of compliance with the Utah Ground Water Quality Protection Regulations, including
but not limited to containment and control of contaminants, or discharges, or potential discharges
to waters of the State.
Finally, Part LD.9 was added to the Permit to provide the Director an opportunity to ensure that:
a) The post-closure performance requirements for the tailings cell cover system in Part
LD.8 is fully and adequately integrated into the Mill's Reclamation Plan. Part I.H.2
was also added to the Permit to require Denison to complete an infiltration and
contaminant transport model of the final tailings cell cover system to demonstrate the
long-term ability of the cover to protect nearby groundwater quality. As a part of this
cover system performance modeling required by Part I.H.2, the Director will determine
if changes to the cover system are needed to ensure compliance with the Part I.D.8
performance criteria;
b) All other facility demolition and decommissioning activities outlined in the
Reclamation Plan will be done in a manner adequate to protect local groundwater
quality. Issues or concerns to be considered and resolved include:
79
(i) Identification, isolation, and authorized disposal of any un-used chemical reagents
held in storage at the Mill site at the time of closure;
(ii) Demolition, excavation, removal, and authorized disposal of all contaminated
man-made structures, including, but not limited to: buildings, pipes, power lines,
tanks, access roads, drain fields, leach fields, fly-ash disposal ponds, feedstock
storage areas, Mill site wastewater storage ponds, solid waste disposal landfills,
and all related appurtenances; and
(iii) Excavation, removal, and authorized disposal of all contaminated soils found
anywhere outside of the tailings cells at the facility.
Through this process, the Director will be able to ensure that DMT has been adequately
established for both the final tailings cell cover system and reclamation of the facility.
Denison submitted an Infiltration and Contaminant Transport Modeling Report, White Mesa
Mill Site, Blanding, Utah, November 2007, prepared by MWH Americas, Inc., in November,
2007. Denison submitted a revised Infiltration and Contaminant Transport Modeling Report,
White Mesa Mill Site, Blanding, Utah, March 2012 in response to DRC comments. The March
2012 report is currently being reviewed in conjunction with the Reclamation Plan, Revision 5.0.
2.19.4 Post-Operational Monitoring
Monitoring will continue under the Permit after cessation of operations, during reclamation and
after reclamation has been completed until such time as the Mill License and Permit are
terminated and the reclaimed tailings impoundments are transferred to the Department of Energy
for perpetual care and maintenance.
3.0 CONCLUSIONS
This Application describes the key monitoring and DMT performance standard requirements and
other protections contained in the Permit.
Denison believes that with this Application, the accompanying Background Reports and other
documentation, the Director has been provided sufficient information to determine that:
f) Denison has demonstrated that the applicable class TDS limits, ground water quality
standards and protection levels will be met;
g) The monitoring plan, sampling and. reporting requirements are adequate to determine
compliance with applicable requirements;
h) Denison utilizes treatment and discharge minimization technology at the Mill
commensurate with plant process design capability and similar or equivalent to that
utilized by facilities that produce similar products or services with similar production
process technology; and
i) There is no current or anticipated impairment of present and future beneficial uses of
the ground water.
Denison would be pleased to provide any further information required by the Director.
80
4.0 SIGNATURE AND CERTIFICATIONS
This Application is dated July 13, 2012 and is being submitted by Denison Mines (USA) Corp.
By:
DaVIa c. Frydenlund
Vice President, Regulatory Affairs and General Counsel
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and com ete. am aware that there are significant penalties for submitting false information,
includi the ssibility of fine and imprisonment for knowing violations.
Davi C. Fry\:Ienlund
Vice President, Regulatory Affairs and General Counsel
CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER
I hereby certify that the foregoing Application has been prepared under my direction, that I have
reviewed this Application, that I am familiar with the Mill facilities, and attest that this
Application has been prepared in accordance with good engineering practices.
-Harold R. Roberts
81
5.0 REFERENCES
Dames & Moore. January 30, 1978. Environmental Report, White Mesa Uranium Project San
Juan County, Utah.
D' Appolonia Consulting Engineers, Inc. June 1979. Engineers Report: Tailings Management
System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. May 1981. Engineer's Report: Second Phase Design
-Cell 3 Tailings Management System, White Mesa Uranium Project Blanding, Utah.
D' Appolonia Consulting Engineers, Inc. February 1982. Construction Report: Initial Phase -
Tailings Management System, White Mesa Uranium Project Blanding, Utah.
Division of Radiation Control, Utah. December 1, 2004. Statement of Basis For a Uranium
Milling Facility at White Mesa, South of Blanding, Utah, Owned and Operated by
International Uranium (USA) Corporation.
Energy Fuels Nuclear, Inc. March 1983. Construction Report: Second Phase Tailings
Management System, White Mesa Uranium Project.
GeoSyntec Consultants. January 2006. Cell 4A Lining System Design Report For The White
Mesa Mill Blanding, Utah.
Geosyntec Consultants. July 2008. Cell 4A Construction Quality Assurance Report, White Mesa
Mill Blanding, Utah.
Geosyntec Consultants. November 2010. Construction Quality Assurance Report.
Geosyntec Consultants. December 8,2012, Cell4B Design Report, White Mesa Mill, Blanding
Utah
Hydro Geo Chern, Inc. 2001. Update to report: Investigation of Elevated chloroform
concentrations in Perched Groundwater at the White Mesa Uranium Mill Near Blanding,
Utah.
Hydro Geo Chern, Inc. August 22,2002. Hydraulic Testing at the White Mesa Uranium Mill
Near Blanding, Utah During July 2002.
Hydro Geo Chern, Inc. August 29,2002. Letter Report.
Hydro Geo Chern, Inc. August 3, 2005. Perched Monitoring Well Installation and Testing at
the White Mesa Uranium Mill April Through June 2005.
Hydro Geo Chern, Inc. August 20,2007. Preliminary Corrective Action Plan, White Mesa Mill
Near Blanding, Utah.
82
Hydro Geo Chern, Inc. November 20,2007. Preliminary Contamination Investigation Report,
White Mesa Mill Near Blanding, Utah.
Hydro Geo Chern, Inc. August 27,2009. Site Hydrogeology and Estimation of Groundwater
Travel Times In The Perched Zone White Mesa Uranium Mill Site Near Blanding, Utah.
Hydro Geo Chern, Inc. October 11, 2010 Installation and Hydraulic Testing of Perched
Monitoring Wells MW-33, MW-34, and MW-35 at the White Mesa Uranium Mill Near Blanding
Utah.
Hydro Geo Chern, Inc. November 12, 2010 Hydrogeology of the Perched Groundwater Zone
and Associated Seeps and Springs Near the White Mesa Uranium Mill Site, Blanding
Utah.
Hydro Geo Chern, Inc. June 28,2011 Installation and Hydraulic Testing of Perched Monitoring
Wells MW-36 and MW-37 at the White Mesa Uranium Mill Near Blanding Utah.
Hydro Geo Chern, Inc. January 12, 2012. Hydrogeology of the Perched Groundwater Zone and
Associated Seeps and Springs Near the White Mesa Uranium Mill Site, Blanding Utah
Hydro Geo Chern, Inc. May 8, 2012 Site Hydrogeology and Estimation of Groundwater Travel
Times in the Perched Zone White Mesa Uranium Mill Site Near Blanding, Utah.
INTERA, Inc. October 2007. Revised Background Groundwater Quality Report: Existing
Wells For Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah.
INTERA Inc. November 16, 2007. Revised Addendum: --Evaluation of Available Pre-
Operational and Regional Background Data, Background Groundwater Quality Report:
Existing Wells For Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan
County, Utah.
INTERA Inc. April 30, 2008. Revised Addendum: --Background Groundwater Quality Report:
New Wells For Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County,
Utah.
INTERA, Inc. December 30, 2009 Nitrate Contamination Investigation Report White Mesa
Uranium Mill Site Blanding, Utah.
International Uranium (USA) Corporation (now named Denison Mines (USA) Corp.). August
2000. Construction Report: Tailings Cell 4A, White Mesa Uranium Mill -Tailings
Management System.
INTERA, Inc. June 1, 2010 Background Groundwater Quality Report for Wells MW-20 and
MW-22 for Denison Mines (USA) Corp. 's White Mesa Mill Site, San Juan County, Utah.,
Kirby. 2008. Geologic and Hydrologic Characterization of the Dakota-Burro Canyon Aquifer
Near Blanding, San Juan County, Utah. Utah Geological Survey Special Study 123.
83
Knight-Piesold LLC. November 23, 1998. Evaluation of Potential for Tailings Cell Discharge
-White Mesa Mill.
NRC. May 1979. Final Environmental Statement related to operation of White Mesa Uranium
Project Energy Fuels Nuclear, Inc., Docket No. 40-8681.
T. Grant Hurst and D. Kip Solomon, Department of Geophysics, University of Utah. May 2008.
Summary of work completed, data results, interpretations and recommendations for the
July 2007 Sampling Event at the Denison Mines, USA, White Mesa Uranium Mill Near
Blanding Utah.
TIT AN Environmental Corporation. July 1994. Hydrogeological Evaluation of White Mesa
Uranium Mill.
Umetco Minerals Corporation. April 10, 1989. Cell 4 Design, White Mesa Project Blanding,
Utah.
Umetco Minerals Corporation. January 1990. White Mesa Mill Drainage Report for Submittal
to NRC.
Umetco Minerals Corporation and Peel Environmental Services. 1993. Groundwater Study,
White Mesa Facilities, Blanding, Utah.
84
Location Kev
ChemLab CL
Flamable Cabinet - A FA
Flamable Cabinet - B FB
Flamable Cabinet - C FC
Poison Cabinet PC
Storage Acid Cabinet SA
MET Lab MET
Mass Spec Room Mass
Perchloric Acid Vault P
Acid Fence Area A
Flammable Shed FS
Bucking Room BR
Bulk around Mill Mill
StockRoom SR
Refrigerator F
Storage ST
Scale Room SR
No Longer on Site NA
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
(F) electrade Ionalyzer
CL 0-Tolidine Dihydrochloride
I-Butanol
(l-Hydroxyethylidene) diphosphenic acid
1 PH buffer solution
CL 1,5 Diphenylcarbazone
CL 1,10 Phenanthroline
CL 1,10 Phenanthroline Ferrous Sulfate
CL 1,2-Cyclohexylene Dinitrilo Tetraacetic Acid
FB 1,4 Dioxane
1.65 PH buffer solution
SR l-Amino-2-Naphthol-4-Sulfonic Acid
F I-Butanol
l-Ethyl-2((1,4dimethyl-2-phenyl-6-
FC pyrimidinylidenemethal) Quinolinium Cholride
2-(5-Bromo-2-pyridylazo )-5-( di ethyl amino )phenol
2-(2, 4-Dinitrophenylazo )-I-Naphthol-3, 6-disulfonic
Acid Disodium Salt
2,2,4-Trimethyl pentane
CL 2,2-BiPyridine
CL 2-Butoxy ethanol
(2-Carboxy-2'-hydroxy-5'-Sulfoformazyl)
FA 2-Propanol
FS 2 PH buffer solution
Disodium
CL 3-(i-decoxy) Propanoic Acid
SR 3-(n-octoxy-n-decoxy) Propanoic Acid
3M KCL fill solution
SR 4-Amino-2-Naphthalene-Sulfonic Acid
F 4 PH buffer solution
SR 4,4,4-Trifluoro-l-(2-Thienyl)-1 ,3-Butenediane
4-amine-l-naphthalene Sulfuric Acid
CL 4-Methyl-2-Pentanone
FC 4-Methyl-2-Pentanone
5-Diphenyl Carbazone
FA 5-(4-Dimethylaminobenzylidene) Rhodamine
F 59PH4940114
A 7 PH buffer solution
SR 8-Hydroxyquinoline
SR 8-Hydroxyquinoline
CL 8-Quinolinol 8-Hydroxy Quinoline
Density
Quantity Unit glcm3
Og
3 lcm_
Volume -lmL
o ml
100 g 1.03 97.1 mL
Og
Og
Og
10 g
80 g
3,400 g
50 g
6,180 g
Og
25 g
3,321 g
0.5 g
Og
Og
Og
10 g
38lb
Og
98,086 g
4,000 g
Og
Og
25 g
3,500 g
50 g
Og
40 g
18,000 g
Og
10 g
3,500 g
600 g
40 g
450 g
o ml
o ml
o ml
1.19 8.4 mL
1.25 64.0 mL
1 '3,400.0 mL
1.48 33.8 mL
1.03 6,000.0 mL
o ml
1.627 15.4 mL
0.81 4,100.0 mL
* 5.0 mL
o ml
o ml
o ml
1.106 9.0 mL
0.9012 5.0 gal
o ml
0.785 15,000.0 ml
1 4,000.0 mL
o ml
Unknown 100.0 mL
Unknown 100.0 mL
o ml
1.502 16.6 mL
1 3,500.0 mL
1.415 35.3 mL
o ml
0.8 50.0 mL
0.8 22,500.0 mL
o ml
1.368
Unknown
1
1.034
1.034
1.04
7.3 mL
10.0 gal
3,500.0 mL
580.3 mL
38.7 mL
432.7 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
SR 10 PH buffer solution
12.45 PH buffer solution
SR Acetic Acid
F Acetic Anhydride
FC Acetone
MET Acetone
Acetylene
ACS Reagent
SR Adogen 2382
SR Adogen 283
SR Adogen 382
SR AF 9000
SR Ag/AgCI
FC Alamine 336
MET Alcohol, Alfol 12LE
Alcohol, n-Amyl
CL Alcohol Solvent, Denatured
SR Alcohol, Reagent
FB Alcohol, Reagent
MET Alcohol, Reagent
FS Alcohol, Reagent
BR Alcohol, Reagent
PC Aliquat 336
MET Aliquat 337
CL Alizarin Red
Alizarin Yellow
CL Alkaline Reagent
CL Aluminum 1000 mg/L
SR Aluminum Chloride
SR Aluminum Hydroxide
SR Aluminum Metal, granular
Aluminum Powder
SR Aluminum Nitrate, N onahydrate
A Aluminum Nitrate Solution
SR Aluminum Nitrate 9-hydrate
SR Aluminum Potassium Sulfate 12 Hydrate Crystal
SR Aluminum Powder
F Aluminum Reagent 2
Aluminum STD 5000 ppm
SR Aluminum Sulfate Crystal
SR Aluminum Wire
Quantity Unit
70,000 g
Og
35,404 g
1,296 g
790 g
158 g
Og
Og
179.6 g
898 g
359.2 g
Density
glcm3
1
1.049
1.08
0.79
0.79
0.898
0.898
0.898
lcm:
Volume -lmL
70,000.0 mL
o mL
33,750.0 mL
1,200.0 mL
1,000.0 mL
200.0 mL
o mL
o mL
1,800 g
1,660 g
Og
8,982 g
19.0 kg
9.5 kg
1738.0 g
12.6 kg
2.0 kg
416.24 g
0.88 kg
35 g
Og
Unknown
Unknown
0.8
200.0 mL
1,000.0 mL
400.0 mL
1,000.0 mL
65.0 mL
2,250.0 mL
2,000.0 mL
o ml
250 g
800 g
500 g
750 g
Og
43,000 g
321 gal
45,400 g
500 g
300 g
Og
250 g
400 g
0.83
0.791 11,355.0 mL
0.79 24.0 L
0.79
0.79
0.79
0.79
0.88
0.88
1.06
Unknown
1
2.44
12.0 L
2,200.0 mL
16.0 L
2.5 L
1.0 pt
1.0 L
33.0 mL
o ml
0.0 0
250.0 mL
327.9 mL
2.4 208.3 ml
2.7 277.8 mL
o ml
1.058 40,642.7 mL
1.1 35.0 gal
1.25 36,320.0 mL
1.757 284.6 mL
2.7
Unknown
1.69
2.7
111.1 mL
60.0 0
o ml
147.9 mL
148.1 mL
Location
SR
CL
CL
CL
CL
CL
SR
SR
SR
SR
SR
PC
CL
SR
PC
SR
SR
SR
SR
PC
SR
SR
F
SR
SR
SR
SR
PC
PC
CL
CL
PC
SR
SR
PC
Mass
SA
Appendix L-1
Laboratory Chemical Inventory
Chemical Name
Amberlite
AMCO Clear Turbidity 1.0 NTU
AMCO Clear Turbidity 10 NTU
AMCO Clear Turbidity 100 NTU
AMCO Clear Turbidity 1000 NTU
Amine
Ammonia Standard
Ammonium 1-Pyrrolidine Carbodithioate
Ammonium Acetate
Ammonium Bicarbonate
Ammonium Bifluoride
Ammonium Chloride
Ammonium Fluoride
Ammonium Hydrogen Difluoride
Ammonium Hydroxide
Ammonium Iodide
Ammonium Meta-Vanadate
Ammonium Meta-Vanadate
Ammonium Molybdate
Ammonium Molybdate-4-Hydrate Crystal
Ammonium Nitrate
Ammonium Oxalate
Ammonium Peroxy Disulfate
Ammonium Persulfate
Ammonium Persulfate
Ammonium Phosphate, Monobasic
Ammonium Sulfate
Ammonium Sulfate 12-hydrate
Ammonium Thiocyanate
Ammonium Vanadate
Anion Exchange Resin
Antimony Potassium Tartrate
Antimony Powder
Arsenic 1000 mg/L
Arsenic STD
Arsenic Trioxide
Arsenic Trioxide
Arsenious Oxide
Ascarite
Atomic Spectroscopy Standard
Barbituric Acid
Density
Quantity Unit glcm3
3 lcm_
Volume -lmL
500 g 1.02 490.2 mL
4,000.0 mL
4,000.0 mL
4,000.0 mL
4,000.0 mL
4,000 g 1
4,000 g 1
4,000 g 1
4,000 g 1
Og
25 g
3,000 g
11,100 g
4,536 g
5,268 g
1600 g
Og
26,940 g
4,000 g
500 g
150 g
2,500 g
50 g
11,022 g
19,300 g
3,000 g
2,000 g
100 g
Og
3,000 g
Og
20,100 g
7,000 g
450 g
500 g
5 g
353.5 g
121.2 mg
3391.114 g
1,073 g
10 g
908 g
100 g
Unknown
o ml
950.0 mL
* 75.0 mL
1.07 2,803.7 mL
1.586 6,998.7 mL
1.5 3,024.0 mL
1.52 3,465.8 mL
1.11 1,441. 4 mL
o ml
0.898 30,000.0 mL
2.51 1,593.6 mL
2.32 215.5 mL
2.32 64.7 mL
3.1 806.5 mL
2.498 20.0 mL
1.72 6,408.1 mL
1.5 12,866.7 mL
1.98 1,515.2 mL
1.98 1,010.1 mL
1.98 50.5 mL
o ml
1.77 1,694.9 mL
o ml
1.3 15,461.5 mL
2.32 3,017.2 mL
0.7 642.9 mL
2.6 192.3 mL
6.69 0.7 mL
1.01 350.0 mL
1.01 120.0 mL
3.738 32.0 oz.
3.738 287.1 mL
3.738
0.9
Unknown
1.455
2.7 mL
1,008.9 mL
0.0 0
68.7 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
CL Barium 1000 mg/L
Barium 5000 ppm STD
Barium Chloranilate
CL Barium Chloride
PC Barium Chloride
CL Barium DiPhenyl amine sulfonate
Barium Hydroxide, Monohydrate
SR Barium Nitrate
FC Barlene, 310 I
SR Bentonite
F A Benzaldehyde
F Benzoic Oxime
PC Beryllium Sulfate
PC Bismuth Powder
SR Boileezers Granules
Boran 1000 mg/L
BR Boraxo
SR Boric Acid
CL Boron 1000 mg/L
FC Brake Fluid
PC Bromine
CL Bromo Padap
CL Bromo Thymol blue
CL Bromocresol Green
CL Bromophenol blue
Bromophenol Blue, Sodium Salt
Bromothymol Blue
CL Brucine Sulfate
MET Burco LAF-6
CL Cadmium 1000 mg/mL
Cadmium 5000 ppm STD
SR Cadmium Metal
SR Cadmium Nitrate
SR Cadmium Powder
SR Calcium
CL Calcium 1000 mg/L
SR Calcium Acetate
SR Calcium Carbonate
SR Calcium Carbonate
SR Calcium Chloride Dihydrate
SR Calcium Chloride, Anhydrous
Densitv
Quantity Unit glcm3
127 g 1.013
Og
Og
2276.265 g
6,800 g
2g
Og
908 g
393.5 g
2,500 g
3,958 g
700 g
113 g
20 g
2,000 g
Og
1,000 g
10,150 g
100 g
974.38 g
5 g
10 g
5 g
110 g
Og
Og
10 g
600 g
506.5 g
Og
500 g
453.6 g
10 g
25 g
750 g
453 g
453 g
50 g
2,500 g
1500 g
1.2031
3.856
*
3.23
0.787
2.4
1.0415
1.13
2.443
9.8
4
1.73
1.435
1
1.03
Unknown
1.39
1.25
0.981
0.954
*
1
1.013
8.64
2.455
8.64
1.54
1
1.5
2.93
2.93
1.71
1.086
lcm:
Volume -lmL
125.0 mL
o ml
o ml
2.0 qt
1,763.5 mL
25.0 mL
o ml
281.1 mL
500.0 mL
1,041.7 mL
3,800.0 mL
619.5 mL
46.3 mL
2.0 mL
500.0 mL
o ml
578.0 mL
7,073.2 mL
100.0 mL
946.0 mL
0.0 0
3.6 mL
8.0 mL
5.1 mL
115.3 mL
o ml
o ml
40.0 mL
600.0 g
500.0 g
o ml
57.9 mL
184.8 mL
1.2 mL
16.2 mL
750.0 mL
302.0 mL
154.6 mL
17.1 mL
1,462.0 mL
1,381.2 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
Densitv
Quantity Unit glcm3
lcm:
Volume -lmL
Calcium Cyanide
PC Calcium Fluoride
SR Calcium Hydroxide
SR Calcium Hydroxide
SR Calcium Nitrate
SR Calcium Nitrate, 4-Hydrate
SR Calcium Oxide
Calcium reference solution
SR Calcium Sulfite
FS Calumet 400-500 solvent
SR
SR
CL
SR
SR
SR
SR
SR
BR
PC
CL
FA
SR
CL
PC
Mass
SA
MET
SR
SR
SR
PC
F
CL
CL
SR
Carbon, Active (aqua pac)
Carbons, Granular
Carboxy methyl Guar Gum
Carminic Acid
Caustlag
Ceric Ammonium Sulfate Dihydrate
Ceric Sulfate
Cerium Oxalate
Cesium Nitrate
Chem-FAC 100
Chesterton Moisture Shield
Chloramine-T -Hydrate
Chloride standard
Chloroform
Chromerge
Chromium 5000 mg/L
Chromium 1000 mg/L
Chromium Trioxide
Chromium Cr 6 Standard
Citric Acid
Citric Acid Anhydrate
Citric Acid Anhydrous
Citric Acid Monohydrate
Co balt Chloride
Cobalt Metal
Cobalt Nitrate 6-Hydrate
Cobalt Powder
Cocoanut charcoal
Conductivity Calibration Standard, NIST Traceable
Conductivity Traceable 1 ,000 ~S
Conductivity Traceable 150,000 ~S
Og
950 g 3.18
o ml
298.7 mL
3,100 g 2.24 1,383.9 mL
357.1 mL
961.0 mL
268.8 mL
800 g 2.24
2268 g 2.36
500 g 1.86
4,268 g 3.3 1,293.3 mL
o ml
464.0 mL
1.5 L
Og
1,160 g 2.5
1245 g 0.83
350 g
Og
10 g
1300 g
2,020 g
150 g
113 g
5 g
397 g
10 g
800 g
1484 g
Og
100.0 g
550.0 g
300 g
337.5 g
Og
5,000 g
250 g
Og
25 g
600 g
500 g
5 g
Og
927 g
13000 g
1000 g
Unknown 40,942.0 qt
0.95 368.4 mL
o ml
1.87 5.3 mL
*
*
3.01
*
3.685
Unknown
0.8
2,000.0 mL
4,000.0 mL
49.8 mL
100.0 mL
1.4 mL
250.0 mL
496.3 mL
1.4 7.1 mL
1 800.0 mL
1.484 1,000.0 mL
o ml
1 100.0 mL
1 550.0 mL
2.7 111.1 mL
2.7 125.0 mL
o ml
1.542 3,242.5 mL
1.542 162.1 mL
o ml
3.35 7.5 mL
1.03 582.5 mL
1.88 266.0 mL
8.9 0.6 mL
o
1.03 900.0
1 13,000.0
1 1,000.0
ml
ml
ml
ml
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
Density
Quantity Unit glcm3
lcm:
Volume -lmL
Conostan 75 base oil for AA diluent
SR Contrad 70
CL Copper
MET Copper 1000 mg/L
MET Com Starch
MET CP 1400P
CL CP 2000P
F Crystal Violet
Crystalline silica
SR Cupferron Crystal
PC Cupric Sulfate 5-Hydrate
CL Cupric Sulfate Anhydrous
FS Curcumin Crystalline
FC Cyanex 923
FA Cyclohexane
SA Cyclohexane 98%
FC D-Gluconic Acid
D-Gluconic Acid Calcium Salt 99%
FB Decyl Alcohol 99%
FA DEHPA
SR DEHP A extractant
SR DF 53A
FB DF -57 -85-1
SR Dialkyl Methyl amine
SA Diatamacious Earth
SR Diaminocyclohexane
CL Diatomite
FB Dibenzoyl Methane 98%
FC Dibutyl phosphate
SR
CL
CL
SR
MET
CL
CL
SR
Di~utyl Butylphosphonate
mercuric sulfate)
Dimethyl Sulfoxide
Dioctylsodium Sulfosuccinate
DiPhenyl amine 4 sulfuric Acid
Diphenylamine-4-Sulfonic Acid
Diphenyl-carbazone, -s
DiPhenylThioCarbazone
Diphonix Resin
Diphonix Resin
DiPyridal
Disodium Ethylenediamine Tetraacetate
Og
15,900 g
430 g
709.8 g
454 g
100 g
50 g
25 g
Og
2,500 g
2,300 g
454 g
10 g
24.2 Kg
2723.35 g
5 gal
500 g
Og
820 g
779.2 g
38.96 g
1070 g
1,000 g
400 g
25lb
140 g
529 g
Og
Og
Og
550 g
10 g
Og
Og
5 g
800 g
300 g
5 g
500 g
o ml
1.06 15,000.0 mL
8.92 48.2 mL
1.014
0.67
*
*
1.19
*
2.284
3.603
1.279
0.88
0.7781
1.763
0.82
0.974
0.974
Unknown
Unknown
1.07
0.26
0.931
700.0 mL
677.6 mL
1,000.0 mL
500.0 mL
21.0 mL
o ml
8,000.0 mL
1,007.0 mL
126.0 mL
7.8 mL
27.5 L
3,500.0 mL
5.0 gal
283.6 mL
o ml
1,000.0 mL
800.0 mL
40.0 mL
250.0 mL
250.0 mL
1,000.0 mL
3,846.2 mL
429.6 mL
0.22 51,544.6 mL
1.138 123.0 mL
1.058 500.0 mL
o ml
o ml
o ml
1.1 500.0 mL
* 20.0 mL
o ml
o ml
1.2 4.2 mL
0.3 2,666.7 mL
0.3 1,000.0 mL
1.106 4.5 mL
1.01 495.0 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
MET d-Tartaric Acid
SR DVS4F011
SR
CL
FS
FC
FB
SR
CL
SR
SR
SR
SR
SR
SR
Mass
PC
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
Ecopol-LLDS
Electrode filling solution
Electrode storage solution
Empigen BS/FQ
Eriochrome black
Escaid 115
Ether Anhydrous
Ethyl Acetate
Ethylene Diamine Tetraacetic Acid
Ethylene Dinitrilo Tetraacetic acid
(ETHYLENEDINITRILO)-Tetraacetic Acid Disodium Sa
Ethylene Glycol Monobutyle Ether
Ferric Ammonium Sulfate Dodecahydrate
Ferric chloride 6-Hydrate
Ferric Chloride Hexahydrate
Ferrous Ammonium Sulfate
Ferrous Chloride
Ferrous Sulfate
Ferrous Sulfate Heptahydrate
Flan 6100 DRC Wash Solution
Flexane 94 liquid
Floc 912 SH
Floc 920 SH
Floc Acrylamide Homopolymer
Floc ChemTreat P-802E
Floc Ethylene Oxide Polymer WSR Coagulant (2331)
Floc Ethylene Oxide Polymer WSR 205 (2195)
Floc Hycem AF 102
Floc Hycem AF 104
Floc Hycem AF 105
Floc Hycem AF 205
Floc Hycem AF 306
Floc Hycem AF 308
Floc Hycem AF 311
Floc Hycem NF 301
Floc Hycem NF 305
Floc Hyperfloc AF 104
Floc Hyperfloc AF MG 653
Floc Hysperse 1015
Density
Ouantitv Unit g/cm3
10,300 g 1.8
1,000 g
Og
Og
35 g
20 L
3210.3 g
9471 g
1,000 g
75 g
Og
Og
1,500 g
300 g
1,500 g
11,500 g
1,000 g
o
5,900 g
500 g
908 g
150 g
150 g
50 g
40lb
250 g
250 g
20 g
20 g
20 g
20 g
20 g
20 g
20 g
20 g
20 g
25 g
50lb
100 g
Unknown
*
Unknown
1.109
0.7134
0.902
0.86
0.86
1.71
1.82
1.82
1.86
3.16
0.999
1
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
49.9
*
lcm:
Volume -lmL
5,722.2 mL
100.0 mL
1,000.0 mL
o ml
o ml
500.0 mL
31.6 mL
20.0 L
4,500.0 mL
10,500.0 mL
1,162.8 mL
87.2 mL
o ml
o ml
877.2 mL
164.8 mL
824.2 mL
6,182.8 mL
316.5 mL
5,905.9 mL
500.0 mL
1,000.0 mL
150.0 mL
150.0 mL
50.0 mL
5.0 gal
500.0 mL
500.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
454.5 mL
100.0 mL
Location
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
Chemical Name
Floc Hysperse 1016
Floc Hysperse 1018
Floc MagnaFloc 10
Floc MagnaFloc 156
Floc MagnaFloc 333
Floc MagnaFloc 336
Floc MagnaFloc 338
Floc MagnaFloc 342
Floc MagnaFloc 351
Floc MagnaFloc 358
Floc MagnaFloc 371
Floc MagnaFloc 455
Floc MagnaFloc 919
Floc MagnaFloc 1011
Floc MagnaFloc 711 7
Floc MagnaFloc 7692
Floc NEG NS 4507
Floc NEG NS 4525
Floc NEG NS 6500
Floc NEG NS 6501
Floc NEG NS 6502
Floc NEG NS 6502m
Floc NEG NS 6511
Floc NEG NS 6555
Floc Non-ionic
Floc Percol E 10
Floc Percol 156
Floc Percol333
Floc Percol336
Floc Percol 338
Floc Percol 342
Floc Percol 351
Floc Percol 352
Floc Percol 358
Floc Percol 371
Floc Percol 408
Floc Percol 455
Floc Percol 727
Floc Percol 728
Floc Percol 919
Appendix L-1
Laboratory Chemical Inventory
Density
Quantity Unit glcm3
100 g
100 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
80 g
20 g
20 g
20 g
20 g
20 g
20 g
20 g
20 g
50lb
50 g
50 g
50 g
50 g
50 g
50 g
50 g
Og
50 g
50 g
50 g
50 g
50 g
50 g
50 g
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
49.9
*
*
*
*
*
*
*
*
*
*
*
*
*
*
Floc Ucarfloc Polymer 30x B-6070 250 g *
3 lcm_
Volume -lmL
100.0 mL
100.0 mL
150.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
50.0 mL
454.5 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
o ml
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
100.0 mL
500.0 mL
Appendix L-1
Laboratory Chemical Inventory
Density lcm:
Location Chemical Name Quantity Unit glcm3 Volume -lmL
SR Floc Ucarfloc Polymer 30x B-6107
SR Floc Ucarfloc Polymer 30x C-6076
SR Floc Ucarfloc Polymer 30x C-6102
SR Floc Ucarfloc Polymer 30x H-6049
SR Floc Ucarfloc Polymer 30x R-6046
SR Floc Ucarfloc Polymer 30x S-6045
CL Floc Ucarfloc Polymer 30x Batch 155836
SR Fluoride standard solution
FC Fluoride standard solution
Fluoride 10 mg/L
SR Formaldehyde
F Fritz EP-9LMwB
CL Gallium Metal
CL Gentian Violet
SR Glacial Acetic Acid
SR Glycerin
SR Greatfloc 5410
SR Greatfloc 5413
FA Greatfloc 5420
FC Hexanes
FA Hexanes
SR Hyamine, Hydroxide
PC Hydrazine Sulfate
CL Hydrazine Sulfate
SA Hydrazine Sulfate
SR Hydrobromic acid 49%
CL Hydrochloric acid
A Hydrochloric acid
SR Hydrochloric acid
A Hydrochloride (l N)
CL Hydrochloride (IN)
F Hydroflouric Acid
SR Hydrogen Peroxide
CL Hydroiodic acid
Hydroquinane
SR Hydroquinone
CL Hydro quinone
SR Hydroxy Naphthol blue
SR Hydroxylamine Hydrochloride
FC Hydroxylamine Sulfate
SR Iodine Monochloride Solution
250 g
250 g
250 g
225 g
750 g
500 g
250 g
1,350 g
425 g
Og
1040.6 g
1 g
100 g
40,931 g
126 g
50 g
50 g
50 g
13.2 Kg
99 g
466.5 g
700 g
453 g
453 g
10,200 g
41,688 g
4,600 g
37,375 g
230 g
11,500 g
8,750 g
2,712 g
1,000 g
Og
100 g
500 g
26 g
1,600 g
1,000 g
1,060 g
*
*
*
*
*
*
*
1
1
1.1
Unknown
5.904
1.19
500.0 mL
500.0 mL
500.0 mL
500.0 mL
1,000.0 mL
1,000.0 mL
500.0 mL
1,350.0 mL
425.0 mL
o ml
946.0 mL
1,000.0 mL
0.2 mL
84.0 mL
1.0495 39,000.0 mL
1.2636 100.0 mL
* 50.0 mL
* 50.0 mL
* 50.0 mL
0.66 20.0 Kg
0.66 150.0 mL
0.933 500.0 mL
1.37 510.9 mL
1.37 330.7 mL
1.37 330.7 mL
1.49 6,845.6 mL
1.15 36,250.0 mL
1.15 4,000.0 mL
1.15 32,500.0 mL
1.15 200.0 mL
1.15 10,000.0 mL
1.25 7,000.0 mL
1.13 2,400.0 mL
1.96 510.2 mL
o ml
1.32 75.8 mL
1.32 378.8 mL
2.13 12.2 mL
1.67 958.1 mL
1.86 537.6 mL
1.06 1,000.0 mL
Location Chemical Name
PCs Iodine Solution IN
FB Iodine Sublimes
CL Ionquest 801
SR Iron 1000 mg/L
Iron 5000 ppm STD
SR Iron Chips
SR Iron Metal
SR Iron Pyrites
Iron reference solution
SR Iron Sulfate Hydrate
FC Iron Wire
FS Iso-Octane
FS Iso~Octane
FS Jet Fuel Type A
FS Kerosene
MET Kerosene, Plant
SR KP5000
CL Lanthanum Oxide
CL Lanthanum 1000 mg/L
SA L-Ascorbic Acid
PC L-Ascorbic Acid
PC Lead (II) Acetate Trihydrate
CL Lead (II) Carbonate
PC Lead 1000 /-lg/mL
PC Lead Metal
PC Lead Nitrate
CL Lead Oxide
Lead Reject
Lead Standard
Lime
PC Lithium 1000 /-lg/mL
SR Lithium Fluoride
ST Lithium M-borate
SR Lithium Meta borate
SR Lithium Meta borate
MET Lithium Tetra borate
CL LIX 984N
SR Magnesium 1000 mg/L
Magnesium Carbonate
SR Magnesium Nitrate
Appendix L-1
Laboratory Chemical Inventory
Density
Quantity Unit glcm3
500 g 1
454 g 3.835
761.25 g
Og
125 g
1,200 g
5,436 g
Og
2,500 g
180 g
7.266 Kg
22.144 Kg
16 Kg
6.075 Kg
16.2 Kg
684 g
520 g
500 g
400 g
4,150 g
500 g
500 g
581.4 g
3,400 g
454 g
2,400 g
Og
Og
Og
515 g
3,400 g
100 g
10,000 g
10,000 g
250 g
Unknown
1.015
7.86
7.86
5.1
3.097
7.86
0.692
0.692
0.8
0.81
0.81
*
6.51
1
1.954
1.954
2.55
6.14
1.02
11.34
4.53
9.53
1.03
2.64
1.4
1.4
1.4
0.25
Unknown
1.016
PC Magnesium Nitrate Hexahydrate
482.6 g
Og
200 g
1,000 g
0.889
1.63
3 lcm_
Volume -lmL
500.0 mL
118.4 mL
400.0 mL
750.0 mL
o ml
15.9 mL
152.7 mL
1,065.9 mL
o ml
807.2 mL
22.9 mL
10.5 L
32.0 L
20.0 L
7.5 L
20.0 L
1,000.0 mL
79.9 mL
500.0 mL
204.7 mL
2,123.8 -mL
196.1 mL
81.4 mL
570.0 mL
299.8 mL
100.2 mL
251.8 mL
o ml
o ml
o ml
500.0 mL
1,287.9 mL
71.4 mL
7,142.9 mL
7,142.9 mL
1,000.0 mL
1,500.0 mL
475.0 mL
o ml
225.0 mL
613.5 mL
Location Chemical Name
SR Magnesium Oxide
SR Magnesium Oxide
SR Magnesium Perchlorate
CL Magnesium Sulfate
SR Manganese 1000 ~g/ mL
Manganese 5000 ppm STD
SR Manganese Carbonate
SR Manganese Chloride
SR Manganese Dioxide
SR Manganese Flake
CL Manganese Sulfate
PC M -Cresol purple
PC Mercuric Acetate
PC Mercuric Chloride
SR Mercuric Iodide
Mercuric lithinate
SR Mercuric Nitrate (.1410 N)
PC Mercuric Nitrate Monohydrate
PC Mercuric Sulfate
CL Mercury (II) Oxide
Mercury 100 STD ppm
PC Mercury 1 000 ~g/mL
F A Mercury Metal
Appendix L-1
Laboratory Chemical Inventory
Density
QuantifY Unit glcm3
25 g 3.58
454 g 3.58
500 g 2.21
3,000 g 1.07
1,675 g 1.015
Og
2,350 g
200 g
2,650 g
50 g
340 g
25 g
100 g
250 g
150 g
3.12
2.98
5.02
7.3
3.25
1.37
3.29
5.44
6.36
lcm:
Volume -lmL
7.0 mL
126.8 mL
226.2 mL
2,803.7 mL
1,650.0 mL
o ml
753.2 mL
67.1 mL
527.9 mL
6.8 mL
104.6 mL
18.2 mL
30.4 mL
46.0 mL
23.6 mL
o ml Og
48,290 g
1500 g
113 g
100 g
Og
625 g
7.51b
4.39 11,000.0 mL
4.3 348.8 mL
6.47
11.14
1
13.54
17.5 mL
9.0 mL
o ml
625.0 mL
251.3 mL
Mass Metallo-Organic Standard 75 Base Oil 2838.75 g
98.75 g
31640 g
5537 g
Og
Og
175 g
25 g
60 g
100 g
0.75 1.0 gal
MET Methanol Blank
BR Methanol
CL Methanol
Methanol in KOH
Methyl isobutyl ketone
CL Methyl orange
CL Methyl Red Hydrochloride
CL Methyl Red Sodium Salt
CL Methyl violet
FC Methylene blue
FA Methylene Chloride
FA Methylene Chloride
CL Methyl Iso-Butyl Ketone
PC Molybdenum 1000 mg/L
Molybdenum STD 5000 ppm
SR Molybdenum Powder
SR Molybdenum Trioxide
25 g
10,544 g
5,272 g
64 g
500 g
Og
100 g
1,240 g
0.79 125.0 mL
0.791 40,000.0 mL
0.791 7,000.0 mL
o ml
o ml
0.987 177.3 mL
0.8 31.3 mL
0.791 75.9 mL
150.0 mL
1 25.0 mL
1.318 8,000.0 mL
1.318 4,000.0 mL
0.802 80.0 mL
1 500.0 mL
o ml
10.3 9.7 mL
4.692 264.3 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
FC Molybdic Anhydride
SR Monoethanol Amine
SR MS-811
CL MSA-1 (New Resin)
FC N-(lnaphthyl) ethylene Diamine Dihydrochloride
FA n-Amyl Alcohol
FC n-Butyl Acetate
FS n-Butyl-Phosphate
BR n-Butyl-Phosphate
FC n-Butyl-Phosphate
n-Decanal
PC NEA-96
SR Nesslers Reagent
CL Nickel
SR Nickel 1000 mg/L
Nickel 5000 mg/L
PC Nickel Nitrate
F Nickel Powder
CL Nitrate ISA
CL Nitrate, nitrogen STD
SR Nitrazine yellow
Mass Nitric Acid
MET Nitric Acid
CL Nitric Acid
A Nitric Acid
FA Nitric Acid
FC Nitrobenzene
Nitrous Oxide
CL NonEmulsifier 19N
Nonoxynol-4
SA N -Phenylbenzohydroxamic Acid
FC Octyl Acid Phosphate
SR Oleic Acid
SR Oleic Acid
CL 0-Phosphoric Acid
MET 0-Phosphoric Acid
A 0-Phosphoric Acid
FA 0-Phosphoric Acid
SR Orform
CL ORP Standard
CL ORP Standard
Density
Quantity Unit glcm3
lcm:
Volume -lmL
453 g 4.692 96.5 rnL
1,018 g 1.018 1,000.0 rnL
500.0 rnL
500.0 rnL
125.0 rnL
473.0 rnL
800.0 rnL
250.0 rnL
50 g
398.0768 g
720 g
Og
1217.5 g
1600 g
110 g
314.34 g
Og
3,000 g
10 g
2,489 g
1,425 g
20 g
55,025 g
3,763 g
2,840 g
4,260 g
21,300 g
13,200 g
Og
460 g
Og
300 g
1,000 g
895 g
3,000 g
36,000 g
4,160 g
2,800 g
76,000 g
200 g
950 g
Unknown
Unknown
*
0.8416
0.9
Unknown
Unknown
Unknown
2.435
1.28
8.9
1.014
2.05
8.9
1.31
1
*
48.0 L
12.0 L
o rnL
500.0 rnL
1,250.0 rnL
12.4 rnL
310.0 rnL
o rnL
1,463.4 rnL
1.1 rnL
1,900.0 rnL
1,425.0 rnL
80.0 rnL
1.42 38,750.0 rnL
1.42 2,650.0 rnL
1.42 2,000.0 rnL
1.42 3,000.0 rnL
1.42 15,000.0 rnL
1.2 11,000.0 rnL
o rnL
0.92 500.0 rnL
1.27
1
0.895
1.09
o rnL
236.2 rnL
1,000.0 rnL
1,000.0 rnL
2,752.3 rnL
1.6 22,500.0 rnL
1.6 2,600.0 rnL
1.6 1,750.0 rnL
1.6 47,500.0 rnL
Unknown
1
1
5,500.0 rnL
200.0 rnL
950.0 rnL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
SR Oxalic Acid
SR Oxicol
FS Paint, LSA057 SCC KA TEE
P-802E Flocculent
FC Pentyl Acetate
P Perchloric Acid
Phenanthroline
CL Phenol Red
CL Phenolphtalein
Phosphoric Acid
CL Phosphorus 1000 J.lg/mL
Phosphorus 5000 ppm STD
Polymer 300
Polymer 302
Polymer 304
Polyol
Polyox WSR Coagulant
Polyox WSR-205
Potassium
CL Potassium 1000 J.lg/mL
Potassium 5000 J.lg/mL
SR Potassium Acetate
SR Potassium Bicarbonate
SR Potassium Biiodate
SR Potassium Biphthalate
SR Potassium Biphthalate Buffer
SR Potassium Bromate
SR Potassium Bromide
SR Potassium Carbonate
SR Potassium Chlorate
CL Potassium Chloride solution 4 M
SR Potassium Chloride
SR Potassium Chromate
PC Potassium Cyanide
SA Potassium dichromate
SR Potassium ferricyanide
SR Potassium F errocyanide trihydrate
PC Potassium Fluoride
SR Potassium Iodate
CL Potassium Iodide-Iodate
SR Potassium Iodide
Density
Quantity Unit glcm3
lcm:
Volume -lmL
5,000 g 1.9 2,631.6 mL
100.0 mL
2.0 pt
10 g *
Og
1,000 g
29288 g
o
25 g
226 g
Og
500 g
Og
Og
Og
Og
Og
Og
Og
Og
861.05 g
Og
250 g
500 g
50 g
1,800 g
32,720 g
500 g
5,600 g
400 g
2,250 g
236.8 g
1,500 g
200 g
454 g
5,450 g
600 g
500 g
600 g
500 g
500 g
16,140 g
Unknown
o ml
0.876 1,141.6 mL
1.6736 17,500.0 mL
1.477 16.9 mL
1.299 174.0 mL
o ml
1 500.0 mL
o ml
o ml
o ml
o ml
o ml
o ml
o ml
o ml
1.013 850.0 mL
o ml
1.57 159.2 mL
2.17 230.4 mL
* 50.0 mL
1.64 1,097.6 mL
1.636 20,000.0 mL
3.27 152.9 mL
3.119 1,795.4 mL
2.43 164.6 mL
2.32 969.8 mL
1 8.0 oz
1.98 757.6 mL
2.732 73.2 mL
1.52 298.7 mL
7.14 763.3 mL
1.85 324.3 mL
1.85 270.3 mL
2.48 241.9 mL
3.93 127.2 mL
1 500.0 mL
1.32 12,227.3 mL
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
Density
Quantity Unit glcm3
lcm:
Volume -lmL
SR Potassium Nitrate
SR Potassium Nitrite
PC Potassium Oxalate
PC Potassium Oxalate Monohydrate
SR Potassium Perchlorate
PC Potassium Permanganate
SA Potassium Permanganate Solution
CL Potassium Perrhenate
CL Potassium Persulfate
SR Potassium Phosphate
SR Potassium Phosphate
SR Potassium pyrosulfate
SR Potassium Sodium Tartrate 4-Hydrate
PC Potassium Sulfate
SR Potassium Sulfate
SR Potassium Thiocyanate
FB Primene
MET Primene JM-T Amine
FS Primene JM -T Amine
MET Primene 81-R Amine
MET Primene TOA Amine
FC Professional Drain Cleaner
FC Propane ( cylinder)
Propyl ether Chloride Guar Gum
Mass Pump Oil
FB Pyridine
Pyrogallate Absorption stable solution, (Potassium
Hydroxide Solution)
SR Quinhydrone
FC Quinoline
FC Red Gaye Oil
SR Rexyn 101
SR Rexyn 300
SR SAG 101
CL Salt (kiln dried)
MET Salt, Medium
SR Sea sand
CL Selenium 1000 Jlg/mL
PC Selenium Oxide
CL Silicon 1000 mg/L
Silicon 5000 mg/L
50 g 2.109
250 g 1.92
4,500 g 2.127
2,500 g 2.127
1,000 g 2.52
9,300 g 1.01
6,000 g 1
10 g 4.887
100 g 2.47
50 g 2.564
8856.9 g 2.34
500 g 2.28
1,400 g 1.05
100 g 2.66
900 g 2.66
9,750 g 1.886
900 g
33,360 g
900 g
910 g
998 g
400 g
Og
13020.4 g
3,928 g
Unknown
0.834
0.834
0.82
0.77
1.05
0.493
0.86
0.9819
23.7 rnL
130.2 mL
2,115.7 rnL
1,175.4 rnL
396.8 rnL
9,207.9 rnL
6,000.0 rnL
2.0 rnL
40.5 mL
19.5 mL
1.0 gal
219.3 rnL
1,333.3 mL
37.6 mL
338.3 rnL
5,169.7 mL
7,150.0 rnL
1,079.1 rnL
40,000.0 rnL
1,097.6 rnL
1,181.8 rnL
950.0 mL
811.4 rnL
o ml
4.0 gal
4,000.0 rnL
Og
2,100 g
545 g
1,652 g
500 g
200 g
o ml
1.32 1,590.9 mL
1.09 500.0 mL
0.826 2,000.0 rnL
45lb
200 g
10,000 g
127.5 g
10 g
485 g
Og
1.2 416.7 rnL
1.2 166.7 rnL
Unknown 350.0 mL
1.199 17,023.9 rnL
1.199 166.8 rnL
2.6 3,846.2 mL
1.02 125.0 mL
4.81 2.1 rnL
0.97 500.0 rnL
o ml
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
Silicon Carbide
Densitv
Quantity Unit glcm3
lcm:
Volume -lmL
CL Silver 1000 Ilg/mL
Silver Chloride
PC Silver Nitrate
SR Silver Nitrate
PC Silver sulfate
CL Sodium 1000 mg/L
F Sodium Acetate
SR Sodium Acetate Anhydrous
SR Sodium Acetate trihydrate
SR Sodium Ammonium Phosphate
PC Sodium Arsenite
SR Sodium Bicarbonate
SR Sodium Bisulfate
SR Sodium Borate
SR Sodium Carbonate, Anhydrous
MET Sodium Carbonate, Anhydrous
SR Sodium Chlorate
MET Sodium Chlorate
SR Sodium Chloride
SR Sodium Chloride Solution
SR Sodium Citrate
PC Sodium Cyanide
CL Sodium Diphenylamine-4-Sulfonate
PC Sodium Fluoride
PC Sodium Hydrosulfide
SR Sodium Hydroxide
MET Sodium Hydroxide (IN)
SR Sodium Hydroxide (IN) SS264
MET Sodium Hydroxide (50%)
SR Sodium Hydroxide (50%)
SR Sodium Hydroxide pellets
SR Sodium m-Bisulfite
SR Sodium Molybdate
SR Sodium Nitrate
Sodium Nitrite
SR Sodium Oxalate
SR Sodium Peroxide
SR Sodium Persulfate
SR Sodium phosphate dec a-hydrate
SR Sodium Phosphate Tribasic
Og
125 g
Og
2,600 g
69,600 g
200 g
202.6 g
500 g
1,000 g
2,450 g
950 g
500 g
11,200 g
8,700 g
400 g
7,500 g
3,000 g
7,000 g
1,500 g
10,950 g
3,784 g
6,000 g
500 g
40 g
10,050 g
1,000 g
5791.05 g
1,560 g
11,440 g
3,060 g
10,710 g
12,000 g
17,500 g
1,000 g
17,000 g
Og
400 g
1,000 g
150 g
500 g
1,350 g
o ml
1 125.0 mL
o ml
4.35 597.7 mL
4.35 16,000.0 mL
5.45 36.7 mL
1.013
1.528
1.528
1.45
1.54
1.87
2.16
2.1
1.73
2.53
2.53
2.49
2.49
1.199
1
1.008
1.6
*
1.02
1.79
200.0 mL
327.2 mL
654.5 mL
1,689.7 mL
616.9 mL
267.4 mL
5,185.2 mL
4,142.9 mL
231.2 mL
2,964.4 mL
1,185.8 mL
2,811.2 mL
602.4 mL
mL 9,132.6
3,784.0 mL
5,952.4 mL
312.5 mL
80.0 mL
9,852.9 mL
558.7 mL
gal
1.04 1,500.0 mL
1.04 11,000.0 mL
1.53 2,000.0 mL
1.53 7,000.0 mL
1.53 1.0
1.515 7,920.8 mL
1.48 11,824.3 mL
3.78 264.6 mL
1.1 15,454.5
o
mL
ml
2.34
2.8
170.9 mL
2.4
1.82
1.62
357.1 mL
62.5 mL
274.7
833.3
mL
mL
Location
SR
CL
SR
SR
CL
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
SR
FC
SR
SR
CL
MET
SR
F
CL
SR
SR
SR
SR
SR
SA
SR
SA
SR
Appendix L-1
Laboratory Chemical Inventory
Chemical Name
Sodium Phosphate, Dibasic 12-Hydrate
Sodium Pyrophosphate Decahydrate P .A.
Sodium reconditioning solution
Sodium Salicylate
Sodium Silicate
Sodium Standard
Sodium Sulfate
Sodium Sulfate, 12-Hydrate
SQdium Sulfate, Anhydrous (granular)
Sodium Sulfate, Anhydrous (powder)
Sodium Sulfhydrate
Sodium Sulfide
Sodium Sulfite
Sodium Sulfite, Anhydrous
Sodium Sulfonate
Sodium Tartrate Dihydrate
Sodium Thiocyanate
Sodium Thiosulfate Anhydrous
Sodium tripoly phosphate
Sodium Tungstate
Sodium Tungstate, Dihydrate
Soltrol220 (Aliphatic Hydrocarbene)
Soluble Starch
Solvent Extraction Diluent
Stabilizer for STD solution
Stannous Chloride, Dihydrate
Starch, soluble potato, powder
Starch Solution
Stearic Acid
Stilbene
Strontium 1 000 ~g/mL
Strontium Carbonate
Strontium Chloride
Succinic Anhydride
Sulfa salicylic Acid Dihydrate
Sulfa Ver 4 (sulfate reagent)
Sulfamic Acid
Sulfanilamide
Sulfanilic Acid
SulfaSalicylic Acid
Sulfate Anion STD
QuantifY Unit
750 g
Og
2,850 g
400 g
600 g
120 g
2,000 g
Og
2,500 g
2,500 g
2,500 g
Og
Og
11,000 g
500 g
1,050 g
3,850 g
14,280 g
500 g
400 g
Og
401.5 g
40 g
Og
Og
2,700 g
300 g
1,000 g
25 g
5 g
125 g
450 g
250 g
250 g
2,000 g
450 g
2,250 g
100 g
100 g
700 g
Og
Density
glcm3
1.52
1
0.35
2.33
1
2.68
2.68
2.68
1.79
2.63
1
1.82
1.295
1.01
0.4
4.18
0.803
1.5
2.71
1.5
1
0.84
1.14
1
3.7
3
1.572
0.8
2.68
2.12
1.08
1.485
1.705
lcm:
Volume -lmL
493.4 mL
o ml
2,850.0 mL
1,142.9 mL
257.5 mL
120.0 mL
746.3 mL
o ml
932.8 mL
932.8 mL
1,396.6 mL
o ml
o ml
4,182.5 mL
500.0 mL
576.9 mL
2,973.0 mL
14,138.6 mL
1,250.0 mL
95.7 mL
o ml
500.0 mL
26.7 mL
o ml
o ml
996.3 mL
200.0 mL
1,000.0 mL
29.8 mL
4.4 mL
125.0 mL
121.6 mL
83.3 mL
159.0 mL
2,500.0 mL
167.9 mL
1,061.3 mL
92.6 mL
67.3 mL
410.6 mL
o ml
Location
CL
CL
CL
SR
CL
MET
A
SR
SR
SR
FB
MET
SR
CL
FB
MET
SR
SA
PC
CL
SR
CL
PC
F
CL
CL
CL
SR
SR
CL
SR
CL
FB
CL
FC
Appendix L-1
Laboratory Chemical Inventory
Chemical Name
Density
Quantity Unit glcm3
lcm:
Volume -lmL
Sulfate Reagent (Barrium Chloride Mixture)
Sulfate-S 1 000 ~g/mL
Sulfosalicylic Acid
Sulfur 1,000 ppm
Sulfur Sublimed
Sulfuric Acid
Sulfuric Acid
Sulfuric Acid
Sulfuric Acid (.IN)
Sulfuric Acid (IN)
Sulfuric Acid, Nil 0
SX diluent (Conoco)
SX Solvent Extraction Diluent
TA-I00 Sample
Tannic Acid
Tantalum 1 000 ~g/mL
TBP
TCHEM Defoamer 4110
Test Lead
Tetrasodium (salt dihydrate)
Thalic Nitrate
Thallium Nitrate
THAM (tris (Hydroxymethyl) Aminomethane) also TRIS
Tharin
ThenoylTriFluoroacetone
Thio Acetamide
ThioAcetamide
Thorium 1000 mg/L
Thorin
Thymol blue
Tin Metal
TISAB w/CDTA
TISAB II w/CDTA
TISAB III w/CDT A
Titanic Oxide
Titanium 1000 mg/L
Toluene
Trans -1,2-DiAminocydohexane Tetra Acetic Acid
Tributyl Phosphate
Tricapryl Methyl Ammonium Chloride
Og
500 g
620 g
390 g
1,000 g
2,500 g
2,750 g
37,500 g
2,000 g
31,280 g
16,770 g
Og
1,400 g
1
1.705
1
2.36
o ml
500.0 mL
363.6 mL
390.0 mL
423.7 mL
2,500.0 mL
2,750.0 mL
1 37,500.0 mL
1 2,000.0 mL
17,000.0 mL
1
1
1.84
1.29
Unknown
Unknown
2.129
Unknown
13,000.0 mL
o ml
200.0 mL
500.0 mL
657.6 mL
200.0 mL
1,964 g 0.982 2,000.0 mL
200.0 mL
2,800.0 mL
1,000.0 mL
125.0 mL
Unknown
70 lb 11.34
800 g
25 g
1 g 5.55 1.0 mL
1,000 g
Og
50 g
500 g
400 g
600 g
15 g
10 g
500 g
Og
4,055 g
80 g
500 g
150 g
10363.2 g
5 g
16,154 g
Og
1.353 739.1 mL
o ml
* 30.0 mL
1.37 365.0 mL
1.37 292.0 mL
1 600.0 mL
* 30.0 mL
* 80.0 mL
7.3 68.5 mL
o ml
1.07 3,790.0 mL
1.07 75.0 mL
4.26 117.4 mL
1 150.0 mL
0.8636 12,000.0 mL
* 10.0 mL
0.979 16,500.0 mL
o ml
Appendix L-1
Laboratory Chemical Inventory
Location Chemical Name
FC Trichloroethylene
Tridecyl Alcohol
CL Triethanolamine
SR Triethanolamine
FC Triethylamine
CL Trioctylphosphine Oxide
SR Trioctylphosphine Oxide 99%
SR Trioctylphosphine Oxide 90%
SR Tris
F Tris
Tris Hydroxy methyl amino methane
SR Turbidity Standard
CL 'Uranium 1 000 ~g/mL
F Uranium Complexant
PC . Uranium Oxide
PC Uranium Oxide Impurity Standard
. Uranium Plasma emission STD
SR Uranyl Acetate
PC Uranyl Acetate
SR Urea
SR Vaccum Pump Oil
CL
PC
PC
FA
FS
BR
SR
SR
SR
SR
SR
SR
SR
SR
SR
Vanadium
Vanadium 1000 Jlg/mL
Vanadium 5000 Jlg/mL
Vanadium Pentoxide
Vanadyl Sulfate
Varsol 110 Solvent
Varsol 110 Solvent
Victawat 12
Vinegar
WD-40
Witbreak 770
Witbreak RTC-426
Witconol DNP-45
Witconol NP-40
Witconate P-l 020Bust
YSI 3682 Zobell solution
Zinc 5000 ppm STD
Zinc Acetate
Zinc Metal
Zinc Sulfate
Density
glcm3
1.47
lcm:
Volume -lmL
5,200.0 mL
Quantity Unit
7,644 g
Og
31,640 g
27,120 g
8,760 g
500 g
500 g
500 g
o ml
1.13 28,000.0 mL
1.13 24,000.0 mL
0.73 12,000.0 mL
0.88 568.2 mL
2,510 g
1,500 g
Og
3,700 g
515 g
400 g
150 g
Og
1,816 g
50 g
7,500 g
41 lb
Og
500 g
Og
800 g
400 g
3,288 g
411 g
Og
Og
72.816 g
1,020 g
118 g
500 g
501 g
250 g
Og
700 g
1,500 g
500 g
0.88
0.88
1.353
1.353
1
1.03
Unknown
10.96
10.96
*
*
1.335
0.9
1
6.11
2.5
0.822
0.822
0.82
1.02
1.18
1.06
1.06
1.05
Unkown
1.84
7.14
1.005
568.2 mL
568.2 mL
mL 1,855.1
1,108.6 mL
o ml
3,700.0 mL
500.0 mL
0.0 0
36.5 mL
13.7 mL
o ml
1,500.0 mL
50.0 mL
5,618.0 mL
5.5 gal
o ml
500.0 mL
o ml
130.9 mL
160.0 mL
4,000.0 mL
500.0 mL
o ml
o ml
3.0 oz.
1,000.0 mL
100.0 mL
500.0 mL
501.0 mL
250.0 mL
125.0 mL
o ml
380.4 mL
210.1 mL
497.5 mL
Location Chemical Name
Zincan
CL Zincon
CL Zirconium 1000 mg/L
SR Zirconium Chloride
SR Zirconium Oxide
Notes:
Zirconium STD (1000 ppm Zr)
Zirconium Sulfate
Zirconyl Chloride
Appendix L-1
Laboratory Chemical Inventory
Quantity Unit
Og
2g
816 g
100 g
453 g
Og
Og
Og
Density
g/em3
*
1.02
2.8
5.89
lem:
Volume -lmL
o ml
20.0 mL
800.0 mL
35.7 mL
76.9 mL
o ml
o ml
o ml
Specific gravity infromatin is unavailable for some reagants and standards. Volume on site is provided.
Appendix L-2
Current Mill Chemicals Inventory
Ouantitv S1l.eciflc Gravitv A1l.12.roximate
Location Chemical Name nbs) or Bulk DensitJ!. Volume {gall
Mill Caustic 50% 71,525 1.00 sp.g 8,586
Mill Salt 117,470 2.16 sp.g 6,529
Mill Soda ash silo 61,328 0.99 sp.g 7,437
Mill East ammonia 55,554 5.15 lb/gal 10,787
Mill West ammonia 109,794 5.15 lb/gal 21,319
Mill Sulfuric Acid 94% 3,752,986 1.84 sp.g 244,858
Mill Ammonium sulfate north 53,787 65.00 lb/cu.ft 6,066
Mill Ammonium sulfate south 50,248 65.00 lb/cu.ft 5,666
Mill Ammonium Sulfate Super Sacks 18,000 65.00 lb/cu.ft 2,030
Mill Sodium chlorate 1-50% 19,825 6.13 lb/gal 3,234
Mill Sodium chlorate 2-50% 67,171 6.13 sp.g 10,958
Mill Sodium chlorate 3-50% 0 6.13 sp.g 0
Mill 1 39,600 0.80 5,942 Flocculant sp.g
Mill Alamine 336 0 0.80 sp.g 0
Mill Alamine 336 Totes 2 30,600 0.80 4,592 sp.g
Mill Hyper Floc 757 Coagulant 0 0.80 sp.g 0
Mill Liquified Natural Gas 89,425 0.40 sp.g 26,838
Mill Tri-decyl alcohol 3 23,485 0.83 sp.g 3,397
Mill Propane 23,605 0.50 sp.g 5,622
Mill Kerosene 20,545 0.82 sp.g 3,026
De-Scaler (ChemSearch 150 or
Mill equivalent) 660 1.16 sp.g 68
Mill Soda ash Super Sacks 82,000 0.99 sp.g 9,943
Mill Diatomaceous Earth Filter Aid 70,200 2.30 sp.g 3,664
Mill Perlite Filter Aid 10,623 2.30 sp.g 554
Mill Hydrogen Peroxide 50% 7,189 1.20 sp.g 722
Mill Sodium Chlorate Super Sacks 46,000 1.32 sp.g 4,199
1. The Mill uses a number of comparable polymer flocculants depending on the specific feed.
2. Current tertiary amine product name as purchased from BASF.
Alternatively, the Mill has and may continue to use other tertiary amines with comparable
chemical properties.
3. Current alcohol used as modifier. Alternatively, the Mill has and may continue to use other
secondary and tertiary alcohols, including isodecanol, among others, to improve
tertiary amine/U/kerosene solubility.
Appendix L-3
Cleaners
Location Cleaners (LABl Quantity
CL Windex 968mL
CL Dawn 5,842 Ml
CL Fantastik 946mL
CL Ajax 4,257 mL
CL Alcotabs 3,060 g
CL Baking Soda 5,235 g
CL Alconox 5,500 g
CL Mop&Glow 100mL
CL Lysol 1,500 mL
CL Palmolive 773 mL
CL Pledge 2,124 g
Jewelers Rouge Polishing
CL Compound 454 g
CL Liqui-Nox Cleaner 0
Location Cleaners (MET LABl Quantity
MET Dawn 1,242 mL
MET Baking Soda 6,351 g
MET Mop&Glow 1,892 mL
MET Lysol 1,300 mL
Appendix L-4
Historic/Formerly Used Chemicals
Chemicals Formerly Used at MilllNo Longer Used or Present on Site 1
Location of.
Storage or Time Period o[
Use Chemical Form Use TotalOuantitv Used Current Status
Several months
Dry solid in during 1997 or No more than several None on site since
Leach circuit Ammonium Bi-fluoride SuperSaks 1998 thousand Ibs. 1998
Several months
during 1997 or No more than 10,000 None on site since
Leach circuit Hydrochloric Acid Drummed liquid 1998 gallons 1998 3
Several months
during 1997 or No more than 2,000 None on site since
Uranium SX J-Mt primary amine Drummed Liquid 1998 gallons 1998
Several months
Tri octyl phosphine oxide during 1997 or No more than 2,000 None on site since
Uranium SX (''TOPO'') Drummed liquid 1998 gallons 1998
1. These reagents were used during processing of one alternate feed for 6 months in 1997/1998, and have not been used before or since.
2. Total quantities used are also the total quantities purchased over life of the alternate feed project, that is, total
on site was this quantitiy or less.
3. Unused residual consumed from 1997 to 1999 for cleaning purposes.
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WHITE MESA URANIUM MILL

CONTINGENCY PLAN

As Contemplated by Part I.G.4(d)

of

State of Utah Groundwater Discharge Permit No.UGW370004

Prepared by:

Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver CO 80265

December 2, 2010

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TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................... 3 
2.0 PURPOSE ................................................................................................................ 3 
3.0 GROUNDWATER CONTAMINATION ............................................................... 3 
3.1  Notification ........................................................................................................... 4 
3.2  Continuation of Accelerated Monitoring ............................................................. 4 
3.3 Submission of Plan and Timetable ....................................................................... 4 
3.4 Groundwater Remediation Plan ........................................................................... 5 
4.0 MILL DISCHARGE VIOLATIONS – INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS ............................................................................................................... 6 
4.1 Notifications ......................................................................................................... 6 
4.2 Field Activities ..................................................................................................... 6 
4.3 Request for Approvals and/or Waivers ................................................................ 7 
5.0 DMT VIOLATIONS ............................................................................................... 7 
5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations ....... 7 
5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems .............. 8 
5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate ............ 9 
5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate ........... 10 
5.5 Excess New Decontamination Pad Leak Detection System Fluid Head ........... 11 
5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad. ... 11 
5.7 Excess Elevation For Tailings Solids ................................................................. 12 
5.8 Roberts Pond Wastewater Elevation .................................................................. 13 
5.9 Feedstock Storage Area ...................................................................................... 13 
5.10 Mill Site Chemical Reagent Storage .............................................................. 14 
5.11 Failure to Construct as per Approval .............................................................. 15 
5.12 Failure to Comply with Stormwater Management and Spill Control
Requirements ................................................................................................................ 15 

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WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004

1.0 INTRODUCTION

The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
“GWDP”) for Denison Mines (USA) Corp.’s (“Denison’s”) White Mesa Uranium Mill
(the “Mill”). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into the underlying aquifer.

2.0 PURPOSE

This Contingency Plan (the “Plan”) provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology Plan
(“DMT”) and the Best Available Technology Plan (“BAT”) requirements defined in Parts
I.C, I.D, and I.H.4 of the GWDP. The timely execution of contingency and corrective
actions outlined in this Plan will provide Denison with the basis to exercise the
Affirmative Action Defense provision in Part I.G.3.c) of the GWDP and thereby avoid
noncompliance status and potential enforcement action1.

The contingency actions required to regain compliance with GWDP limits and DMT and
BAT requirements defined in Parts I.C, I.D, and I.H.4 of the GWDP are described below.

3.0 GROUNDWATER CONTAMINATION

Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
1 Part I.G.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison’s negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions of UCA 19-5-107 have not been violated.
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will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part I.G.2 of the GWDP.

When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:

3.1 Notification

Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.

3.2 Continuation of Accelerated Monitoring

Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part I.G.1 of the GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.

If the accelerated monitoring demonstrates that the monitoring well has returned to
compliance with respect to a parameter in a well, then, with written approval from the
Executive Secretary, Denison will cease accelerated monitoring for that parameter, and
will continue routine monitoring for that parameter.

3.3 Submission of Plan and Timetable

If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT or
BAT will be reestablished, as required under part I.G.4.c) of the GWDP. This plan will
normally include, but is not limited to:

a) The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;

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b) A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;

c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and

d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions
to restore and maintain groundwater quality to ensure that permit limits will not
be exceeded at the compliance monitoring point and that DMT and BAT will be
reestablished, as well as actions that merely allow natural attenuation to operate
and actions that involve applying for Alternate Concentration Limits (“ACLs”).
ACLs require approval of the Water Quality Board prior to becoming effective.
If groundwater remediation is required, Denison will prepare and submit for
Executive Secretary approval a Ground Water Remediation Plan, as described in
Section 3.4 below.

3.4 Groundwater Remediation Plan

If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation Plan will
normally include, but is not limited to:

a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations
approved by the Executive Secretary, by removing the contaminants, treating
them in place, or by other means as approved by the Executive Secretary;

b) A description of the remediation monitoring program to demonstrate the
effectiveness of the plan; and

c) Descriptions of how corrective action will apply to each source of the pollution.

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Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.

4.0 MILL DISCHARGE VIOLATIONS – INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS

Part I.C.2. of the GWDP provides that only 11e.(2) by-product material authorized by the
Mill’s State of Utah Radioactive Materials License No. UT-2300478 (the “Radioactive
Materials License”) shall be discharged to or disposed of in the Mill’s tailings cells.

Part I.C.3 of the GWDP provides that discharge of other compounds into the Mill’s
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as 11e.(2) material is prohibited.

In the event of any unauthorized disposal of contaminants or wastes (the “Unauthorized
Materials”) to the Mill’s tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:

4.1 Notifications

a) Upon discovery, the Mill Manager or RSO will be notified immediately; and

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery.

4.2 Field Activities

a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill’s tailings cells;

b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill
personnel will nevertheless mark or record the location of the Unauthorized
Materials in the tailings cells;

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c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from
the tailings cells; and

d) Denison will dispose of the removed Unauthorized Material under applicable
State and Federal regulations with the approval of the Executive Secretary.

4.3 Request for Approvals and/or Waivers

If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will, in accordance with a schedule to be approved by the
Executive Secretary:

a) Submit a written report to the Executive Secretary analyzing the health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill’s tailings cells;

b) Apply to the Executive Secretary for any amendments that may be required to
the GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill’s tailings cells in a
manner that is protective of health, safety and the environment; and

c) Make all applications required under the United States Nuclear Regulatory
Commission’s (“NRC’s”) Non-11e.(2) Disposal Policy (NRC Regulatory Issue
Summary 2000-23 (November 2000), Interim Guidance on Disposal of Non-
Atomic Energy Act of 1954, Section 11e.(2) Byproduct Material in Tailings
Impoundments), including obtaining approval of the Department of Energy as
the long term custodian of the Mill’s tailings, in order to obtain approval to
permanently dispose of the Unauthorized Material in the Mill’s tailings cells.

5.0 DMT VIOLATIONS

5.1 Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations

Part I.D.2 and Part I.D.6.d) of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner (“FML”).

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In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;

c) Upon discovery, Mill personnel will cease to discharge any further tailings to
the subject tailings cell, until such time as adequate freeboard capacity exists in
the subject tailings cell for the disposal of the tailings;

d) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly pump
fluids from the subject tailings cell to another tailings cell until such time as the
freeboard limit for the subject tailings cell is in compliance. If there is no room
available in another tailings cell, without violating the freeboard limit of such
other cell, then, as soon as reasonably practicable, Mill personnel will cease to
discharge any further tailings to any tailings cell until such time as adequate
freeboard capacity exists in all tailings cells;

e) If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject
tailings cell will be reduced through natural evaporation; and

f) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.

5.2 Excess Head in Tailings Cells 2, 3, 4A, and 4B Slimes Drain Systems

Part I.D.3.b)1) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accordance with the Mill’s currently approved DMT Monitoring Plan , and
that for Cell 3, this requirement shall apply only after initiation of de-watering operations.
Similarly, Part I.D.6.c) of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell 4A, Denison will provide: 1) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements
found in Part I.D.3.b); and 2) a maximum head of 1.0 feet in the tailings (as measured
from the lowest point of the upper FML) in 6.4 years or less.
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In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell 4A exceeds the levels specified in the DMT Monitoring Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary;

c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;

d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and

e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.

5.3 Excess Cell 4A Leak Detection System Fluid Head or Daily Leak Rate

Part I.D.6.a) provides that the fluid head in the Leak Detection System (“LDS”) for Cell
4A shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.6.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4A shall not exceed 24,160 gallons/day.

In the event that the fluid head in the LDS for Cell 4A exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;
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c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;

d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and

e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to remediate the exceedance and to minimize the chance of
a recurrence.

5.4 Excess Cell 4B Leak Detection System Fluid Head or Daily Leak Rate

Part I.D.13.a) provides that the fluid head in the Leak Detection System (“LDS”) for Cell
4B shall not exceed 1 foot above the lowest point in the lower membrane liner, and Part
I.D.13.b) of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4B shall not exceed 26,145 gallons/day.

In the event that the fluid head in the LDS for Cell 4B exceeds 1 foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4B LDS
exceeds 26,145 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as set forth in any notice, order, remediation plan or the equivalent,
implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Mill personnel will promptly pump the excess fluid into an active tailings cell,
or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;

c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;

d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and

If not due to an identified equipment failure, Denison will perform a root cause analysis
of the exceedance and will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.
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5.5 Excess New Decontamination Pad Leak Detection System Fluid Head

In order to ensure that the primary containment of the New Decontamination Pad water
collection system has not been compromised, and to provide an inspection capability to
detect leakage from the primary containment in each of the three settling tanks, a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.

Section 3.1(e) of the Mill’s DMT Monitoring Plan provides that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any of the three standpipes. Compliance is defined in Part I.D.14 a) of the GWDP as a
depth to standing water present in any of the LDS access pipes of more than or equal to
6.2 feet as measured from the water measuring point (top of access pipe).

In the event that the fluid head in the standpipe for a settling tank exceeds 0.10 feet above
the concrete floor in the standpipe, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;

c) Mill personnel will promptly pump the fluid from the settling tank’s LDS as
well as the fluids in the settling tank into another settling tank or into an active
tailings cell, or other appropriate containment or evaporation facility approved
by the Executive Secretary, until such time as the cause of the exceedance is
rectified or until such time as otherwise directed by the Executive Secretary; and

d) Denison will perform a root cause analysis of the exceedance and, if
appropriate, will implement new procedures or change existing procedures to
remediate the exceedance and to minimize the chance of a recurrence.

5.6 Cracks or Physical Discrepancies on New Decontamination Pad Wash Pad.

Soil and debris will be removed form the wash pad of the NDP in accordance with the
currently approved DMT Monitoring Plan. In the event that cracks of greater than 1/8
inch (width) are observed on the concrete wash pad, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
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a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) The NDP shall be taken out of service and the cracks will be repaired utilizing
industry standard materials and procedures appropriate for the defect within five
working days of discovery. Following recommended cure times, the cracks or
deficiencies will be re-inspected and, if acceptable, the NDP will be placed back
into service.

c) A record of the repairs will be maintained as a part of the inspection records at
the White Mesa Mill.

5.7 Excess Elevation For Tailings Solids

Part I.D.3.c) of the GWDP provides that upon closure of any tailings cell, Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML.

In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;

c) To the extent reasonably practicable, without causing a violation of the
freeboard limit in any other tailings cell, Mill personnel will promptly remove
tailings solids from the subject tailings cell to another tailings cell, or other
location approved by the Executive Secretary, until such time as the maximum
elevation of the tailings waste solids in the subject tailings cell does not exceed
the top of the FML; and

d) Denison will perform a root cause analysis of the exceedance and will
implement new procedures or change existing procedures to minimize the
chance of a recurrence.

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5.8 Roberts Pond Wastewater Elevation

Part I.D.3.e) of the GWDP provides that the Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.

In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell 1 within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDP.

In the event that, Denison fails to remove the excess wastewater within 72 hours of
discovery, Denison will, subject to any specific requirements of the Executive Secretary
as set forth in any notice, order, remediation plan or the equivalent, implement the
following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately; and

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.

5.9 Feedstock Storage Area

Part I.D.3.f) and Part I.D.11 of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion of the Mill site area described in Table 4 of the GWDP, and that storage
of feedstock materials at the facility outside that area shall be performed in accordance
with the provisions of Part I.D.11 of the GWDP.

In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f) and Part I.D.11 of the GWDP, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;

c) Mill personnel will:

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(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
(ii) ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in
accordance with the provisions of Part I.D.11 of the GWDP; and
(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance with the provisions of Part I.D.11 of
the GWDP, and any impacted soils will be removed and will be deposited
into the Mill’s active tailings cell; and

d) Denison will perform a root cause analysis of the non-compliant activity and
will implement new procedures or change existing procedures to minimize the
chance of a recurrence.

5.10 Mill Site Chemical Reagent Storage

Part I.D.3.g) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.

In the event that Denison fails to provide the required secondary containment required
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and

c) Denison will promptly remediate any spilled re-agent resulting from the failure
to provide the required secondary containment under Part I.D.3.g) of the
GWDP, by removal of the contaminated soil and disposal in the active tailings
cell.

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5.11 Failure to Construct as per Approval

Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.

In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately; and

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.

5.12 Failure to Comply with Stormwater Management and Spill Control Requirements

Part I.D.10 of the GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with the
currently approved Stormwater Best Management Practices Plan.

In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill’s approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:

a) Upon discovery, the Mill Manager or RSO will be notified immediately;

b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and

c) To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill’s approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
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WHITE MESA URANIUM MILL GROUNDWATER MONITORING QUALITY ASSURANCE PLAN (QAP) State of Utah Groundwater Discharge permit No. UGW370004 Denison Mines (USA) Corp. P.O. Box 809 Blanding, UT 84511
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TABLE OF CONTENTS

1.0 INTRODUCTION 6
2.0 ORGANIZATION AND RESPONSIBILITIES 6
2.1 Functional Groups 6
2.2 Overall Responsibility For the QA/QC Program 6
2.3 Data Requestors/Users 6
2.4 Data Generators 7
2.4.1 Sampling and QC Monitors 7
2.4.2 Analysis Monitor 8
2.4.3 Data Reviewers/Approvers 8
2.5 Responsibilities Of Analytical Laboratory 8
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 9
3.1 Precision 9
3.2 Accuracy 10
3.3 Representativeness 10
3.4 Completeness 10
3.5 Comparability 10
4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11
4.1 Controlling Well Contamination 11
4.2 Controlling Depth to Groundwater Measurements 11
4.3 Water Quality QC Samples 11
4.3.1 VOC Trip Blanks 11
4.3.2 Equipment Rinsate Samples 11
4.3.3 Field Duplicates 12
4.3.4 Definition of “Batch” 12
5.0 CALIBRATION 12
5.1 Depth to Groundwater Measurements 12
5.2 Water Quality 12
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6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD
PARAMETERS 12
6.1 Groundwater Head Monitoring 12
6.1.1 Location and Frequency of Groundwater Head Monitoring 13
6.1.2 Groundwater Head Monitoring Frequency 13
6.2 Ground Water Compliance Monitoring 13
6.2.1 Location and Frequency of Groundwater Compliance Monitoring 13
6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the GWDP 14
6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP 14
6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 14
6.2.5 Decontamination Procedure 15
6.2.6 Pre-Purging/ Sampling Activities 15
6.2.7 Well Purging/Measurement of Field Parameters 15
6.2.8 Samples to be taken and order of taking samples 16
7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 16
7.1 Field Data Worksheets 16
7.2 Chain-Of-Custody and Analytical Request Record 17
7.3 Record Keeping 18
8.0 ANALYTICAL PROCEDURES AND QA/QC 18
8.1 Analytical Quality Control 19
8.1.2 Spikes, Blanks and Duplicates 19
8.2 Analytical Laboratory Procedures 20
9.0 INTERNAL QUALITY CONTROL CHECKS 24
9.1 Field QC Check Procedures 24
9.1.1 Review of Compliance With the Procedures Contained in this QAP 24
9.1.2 Analyte Completeness Review 24
9.1.3 Blank Comparisons 24
9.1.4 Duplicate Sample Comparisons 25
9.2 Analytical Laboratory QA Reviews 26
9.3 QA Manager Review of Analytical Laboratory Results and Procedures 26
9.4 Analytical Data 27
10.0 CORRECTIVE ACTION 28
10.1 When Corrective Action is Required 28
10.2 Procedure for Corrective Action 28
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11.0 REPORTING 29
12.0 SYSTEM AND PERFORMANCE AUDITS 30
12.1 QA Manager to Perform System Audits and Performance Audits 30
12.2 System Audits 30
12.3 Performance Audits 31
12.4 Follow-Up Actions 31
12.5 Audit Records 31
13.0 PREVENTIVE MAINTENANCE 31
14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 32
14.1 Ongoing QA/QC Reporting 32
14.2 Periodic Reporting to Management 32
15.0 AMENDMENT 32
16.0 REFERENCES 33

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ATTACHMENTS

Attachment 1 Field and Data Forms

Attachment 1-1 Quarterly Depth to Water Data Sheet
Attachment 1-2 White Mesa Uranium Mill Field Data Work Sheet for Groundwater
Attachment 1-3 Example COC Forms
Attachment 2 Field Procedures
Attachment 2-1 Groundwater Head (Depth to Water) Measurement Procedures Attachment 2-2 Decontamination Procedures Attachment 2-3 Purging Procedures Attachment 2-4 Sample Collection Procedures Attachment 2-5 Field QC Samples APPENDICES Appendix A Chloroform Investigation Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah Appendix B Nitrate Corrective Action Monitoring Quality Assurance Program White Mesa Uranium Mill Blanding, Utah
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1.0 INTRODUCTION

This Groundwater Monitoring Quality Assurance Plan (the “QAP”) details and describes all
sampling equipment, field methods, laboratory methods, qualifications of environmental
analytical laboratories, data validation, and sampling and other corrective actions necessary
to comply with UAC R317-6-6.3(I) and (L) at the White Mesa Uranium Mill (the “Mill”), as
required under paragraph I.H.6 of State of Utah Groundwater Discharge Permit No.
UGW370004 (the “GWDP”) for the Mill. This Procedure incorporates the applicable
provisions of the United States Environmental Protection Agency (“EPA”) RCRA
Groundwater Monitoring Technical Enforcement Guidance Document (OSWER-9950.1,
September, 1986), as updated by EPA’s RCRA Ground-Water Monitoring: Draft Technical
Guidance (November 1992).

Activities in an integrated program to generate quality data can be classified as management
(i.e., quality assurance or “QA”) and as functional (i.e., quality control or “QC”). The
objective of this QAP is to ensure that monitoring data are generated at the Mill that meet the
requirements for precision, accuracy, completeness, representativeness and comparability
required for management purposes and to comply with the reporting requirements established
by applicable permits and regulations.
2.0 ORGANIZATION AND RESPONSIBILITIES

2.1 Functional Groups

This QAP specifies roles for a QA Manager as well as representatives of three different
functional groups: the data users; the data generators, and the data reviewers/approvers. The
roles and responsibilities of these representatives are described below.

2.2 Overall Responsibility For the QA/QC Program

The overall responsibility for ensuring that the QA/QC measures are properly employed is
the responsibility of the QA Manager. The QA Manager is typically not directly involved in
the data generation (i.e., sampling or analysis) activities. The QA Manager is designated by
Denison Mines (USA) Corp. (“DUSA”) corporate management.

2.3 Data Requestors/Users

The generation of data that meets the objectives of this QAP is necessary for management to
make informed decisions relating to the operation of the Mill facility, and to comply with the
reporting requirements set out in the GWDP and other permits and applicable regulations.
Accordingly, the data requesters/users (the “Data Users”) are therefore DUSA’s corporate
management and regulatory authorities through the implementation of such permits and
regulations. The data quality objectives (“DQOs”) required for any groundwater sampling
event, such as acceptable minimum detection limits, are specified in this QAP.

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2.4 Data Generators

The individuals who carry out the sampling and analysis activities at the request of the Data
Users are the data generators. For Mill activities, this involves sample collection, record
keeping and QA/QC activities conducted by one or more sampling and quality control/data
monitors (each a “Sampling and QC Monitor”). The Sampling and QC Monitors are
qualified Mill personnel as designated by the QA Manager. The Sampling and QC Monitors
perform all field sampling activities, collect all field QC samples and perform all data
recording and chain of custody activities in accordance with this QAP. Data generation at
the contract analytical laboratory (the “Analytical Laboratory”) utilized by the Mill to
analyze the environmental samples is performed by or under an employee or agent (the
“Analysis Monitor”) of the Analytical Laboratory, in accordance with specific requirements
of the Analytical Laboratory’s own QA/QC program.

The responsibilities of the data generators are as follows:

2.4.1 Sampling and QC Monitors

The Sampling and QC Monitors are responsible for field activities. These include:

a) Ensuring that samples are collected, preserved, and transported as specified in this
QAP;

b) Checking that all sample documentation (labels, field data worksheets, chain-of-
custody records,) is correct and transmitting that information, along with the
samples, to the Analytical Laboratory in accordance with this QAP;

c) Maintaining records of all samples, tracking those samples through subsequent
processing and analysis, and, ultimately, where applicable, appropriately disposing
of those samples at the conclusion of the program;

d) Preparing quality control samples for field sample collection during the sampling
event;

e) Preparing QC and sample data for review by the QA Manager; and

f) Preparing QC and sample data for reporting and entry into a computerized database,
where appropriate.
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2.4.2 Analysis Monitor

The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory.
These include:

a) Training and qualifying personnel in specified Analytical Laboratory QC and
analytical procedures, prior to receiving samples;

b) Receiving samples from the field and verifying that incoming samples correspond to
the packing list or chain-of-custody sheet; and

c) Verifying that Analytical Laboratory QC and analytical procedures are being
followed as specified in this QAP, by the Analytical Laboratory’s QA/QC program,
and in accordance with the requirements for maintaining National Environmental
Laboratory Accreditation Program (“NELAP”) certification.

2.4.3 Data Reviewers/Approvers

The QA Manager has broad authority to approve or disapprove project plans, specific
analyses and final reports. In general, the QA Manager is responsible for reviewing and
advising on all aspects of QA/QC, including:

a) Ensuring that the data produced by the data generators meet the specifications set out
in this QAP;

b) Making on-site evaluations and submitting audit samples to assist in reviewing
QA/QC procedures;

c) Determining (with the Sampling and QC Monitor and Analysis Monitor) appropriate
sampling equipment and sample containers, in accordance with this QAP, to
minimize contamination; and

d) Supervising all QA/QC measures to assure proper adherence to this QAP and
determining corrective measures to be taken when deviations from this QAP occur.

The QA Manager may delegate certain of these responsibilities to one or more Sampling and
QC Monitors or to other qualified Mill personnel.

2.5 Responsibilities Of Analytical Laboratory

Unless otherwise specified by DUSA corporate management, all environmental analysis of
groundwater sampling required by the GWDP or by other applicable permits, will be
performed by a contract Analytical Laboratory.

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The Analytical Laboratory is responsible for providing sample analyses for groundwater
monitoring and for reviewing all analytical data to assure that data are valid and of sufficient
quality. The Analytical Laboratory is also responsible for data validation in accordance with
the requirements for maintaining NELAP certification.

In addition, to the extent not otherwise required to maintain NELAP certification, the
Analytical Laboratory must adhere to U. S. EPA Guideline SW-846 and, to the extent
consistent with NELAP and EPA practices, the applicable portions of NRC Regulatory
Guide 4.14.

The Analytical Laboratory will be chosen by DUSA and must satisfy the following criteria:
(1) experience in analyzing environmental samples with detail for precision and accuracy, (2)
experience with similar matrix analyses, (3) operation of a stringent internal quality
assurance program meeting NELAP certification requirements and that satisfies the criteria
set out in Section 8 below, (4) ability to satisfy radionuclide requirements as stipulated in the
applicable portions of NRC Regulatory Guide 4.14, and (5) certified by the State of Utah for
and capable of performing the analytical methods set out in Table 1. The analytical
procedures used by the Analytical Laboratory will be in accordance with Utah
Administrative Code R317-6-6.3L.
3.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA

The objective of this QAP is to ensure that monitoring data are generated at the Mill that
meet the requirements for precision, accuracy, representativeness, completeness, and
comparability required for management purposes and to comply with the reporting
requirements established by applicable permits and regulations (the Field and Analytical QC
samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are
satisfied). Data subject to QA/QC measures are deemed more reliable than data without any
QA/QC measures.

3.1 Precision

Precision is defined as the measure of variability that exists between individual sample
measurements of the same property under identical conditions. Precision is measured
through the analysis of samples containing identical concentrations of the parameters of
concern. For duplicate measurements, precision is expressed as the relative percent
difference (“RPD”) of a data pair and will be calculated by the following equation:

RPD = [(A-B)/{(A+B) /2}] x 100

Where A (original) and B (duplicate) are the reported concentration for field duplicate
samples analyses (or, in the case of analyses performed by the Analytical Laboratory, the
percent recoveries for matrix spike and matrix spike duplicate samples) (EPA SW-846,
Chapter 1, Section 5.0, page 27 - 28).

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3.2 Accuracy

Accuracy is defined as a measure of bias in a system or as the degree of agreement between a
measured value and a known value. The accuracy of laboratory analyses is evaluated based
on analyzing standards of known concentration both before and during analysis. Accuracy
will be evaluated by the following equation:

% Recovery = (│A-B│/C) x 100

Where:

A = the concentration of analyte in a sample
B = the concentration of analyte in an unspiked sample
C = the concentration of spike added

3.3 Representativeness

Representativeness is defined as the degree to which a set of data accurately represents the
characteristics of a population, parameter, conditions at a sampling point, or an
environmental condition. Representativeness is controlled by performing all sampling in
compliance with this QAP.

3.4 Completeness

Completeness refers to the amount of valid data obtained from a measurement system in
reference to the amount that could be obtained under ideal conditions. Laboratory
completeness is a measure of the number of samples submitted for analysis compared to the
number of analyses found acceptable after review of the analytical data. Completeness will
be calculated by the following equation:

Completeness = (Number of valid data points/total number of measurements) x 100

Where the number of valid data points is the total number of valid analytical measurements
based on the precision, accuracy, and holding time evaluation. Completeness is determined
at the conclusion of the data validation.
Executive Secretary approval will be required for any completeness less than 100 percent.

3.5 Comparability

Comparability refers to the confidence with which one set of data can be compared to
another measuring the same property. Data are comparable if sampling conditions,
collection techniques, measurement procedures, methods, and reporting units are consistent
for all samples within a sample set.

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4.0 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY

4.1 Controlling Well Contamination

Well contamination from external surface factors, is controlled by installation of a cap over
the surface casing and cementing the surface section of the drill hole. Wells have surface
covers of mild steel with a lockable cap cover. Radiation Safety staff has access to the keys
locking the wells.

4.2 Controlling Depth to Groundwater Measurements

Monitoring of depth to groundwater is controlled by comparing historical field data to actual
measurement depth. This serves as a check of the field measurements.

4.3 Water Quality QC Samples

Quality assurance for groundwater monitoring consists of the following QC samples:

4.3.1 VOC Trip Blanks

Trip blanks will be used to assess contamination introduced into the sample containers by
volatile organic compounds (“VOCs”) through diffusion during sample transport and storage.
At a minimum (at least) one trip blank will be in each shipping container containing samples
to be analyzed for VOCs. Trip blanks will be prepared by the Analytical Laboratory,
transported to the sampling site, and then returned to the Analytical Laboratory for analysis
along with the samples collected during the sampling event. The trip blank will be unopened
throughout the transportation and storage processes and will accompany the technician while
sampling in the field.

4.3.2 Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples. Rinsate blanks will be
collected after decontamination and prior to subsequent use. Rinsate blank samples for a
non-dedicated pump are prepared by pumping de-ionized water into the sample containers.
Rinsate blank samples for a non-disposable or non-dedicated bailerare prepared by pouring
de-ionized water over and through the bailer and into the sample containers. Equipment
rinsate blanks will be analyzed only for the contaminants required during the monitoring
event in which they are collected.

Equipment rinsate blank sampling procedures are described in Attachments 2-2 and 2-5.
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4.3.3 Field Duplicates

Field duplicate samples are collected at a frequency of one duplicate per 20 field samples.
Field duplicates will be submitted to the Analytical Laboratory and analyzed for the same
constituents as the parent sample.

Field duplicate sampling procedures are described in Attachment 2-5.

4.3.4 Definition of “Batch”

For the purposes of this QAP, a Batch is defined as 20 or fewer samples. 5.0 CALIBRATION

A fundamental requirement for collection of valid data is the proper calibration of all sample
collection and analytical instruments. Sampling equipment shall be calibrated in accordance
with manufacturers’ recommendations, and Analytical Laboratory equipment shall be
calibrated in accordance with Analytical Laboratory procedures.

5.1 Depth to Groundwater Measurements

Equipment used in depth to groundwater measurements will be checked prior to each use as
noted in Attachment 2 to ensure that the Water Sounding Device is functional.

5.2 Water Quality

The Field Parameter Meter will be calibrated prior to each sampling event and at the
beginning of each day of the sampling event according to manufacturer’s specifications (for
example, by using two known pH solutions and one specific conductance standard.)
Temperature will be checked comparatively by using a thermometer. Calibration results will
be recorded on the Field Data Worksheet.
6.0 GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS

6.1 Groundwater Head Monitoring

Groundwater head measurements (“depth to water”) will be completed as described in
Attachment 2 using the equipment specified in Attachment 2.
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6.1.1 Location and Frequency of Groundwater Head Monitoring

Depth to groundwater shall be measured quarterly in the following wells and piezometers:

a) All Point of Compliance wells listed in the GWDP Parts I.E.1 (b) and (c) and
I.E.2;

b) Monitoring well MW-34;

c) All piezometers (P-1, P-2, P-3, P-4, P-5 and the Dry Ridge piezometers);

d) All contaminant investigation wells required by the Executive Secretary as part of
a contaminant investigation or groundwater corrective action (chloroform and nitrate
wells).

6.1.2 Groundwater Head Monitoring Frequency

Depth to groundwater is measured and recorded in any well that is being sampled for
groundwater quality prior to sampling. In addition, a depth to groundwater measurement
campaign will be completed each quarter. The data from the quarterly campaign will be used
for modeling purposes and will be completed within a 5 day period. The data from the
quarterly campaign will be recorded on a data sheet. An example of a Quarterly Depth to
Water data sheet is included Attachment 1. Data from the quarterly depth to water campaign
will be recorded by hand on hardcopy forms in the field, but may be entered into an
electronic data management system (spreadsheet or database). The data from the quarterly
depth to water measurements will be included in the quarterly groundwater report.

The depth to groundwater measured immediately prior to purging/sampling will be recorded
on data sheet for each well. An example of a Field Data Work Sheet for Groundwater is
included in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.

6.2 Ground Water Compliance Monitoring

6.2.1 Location and Frequency of Groundwater Compliance Monitoring

Groundwater quality shall be measured in the following wells at the following frequencies:

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a) Semi-annually in the following Point of Compliance wells: MW-1, MW-2, MW-
3, MW-3A, MW-5, MW-12, MW-15, MW-17, MW-18, MW-19, MW-23, MW-
24, MW-27, MW-28, MW-29, and MW-32;

b) Semi-annually in the following General Monitoring Wells: MW-20 and MW-22;

c) Quarterly in the following Point of Compliance wells: MW-11, MW-14, MW-25,
MW-26, MW-30, MW-31, MW-35, MW-36 and MW-37; and

d) Quarterly in the Chloroform Investigation and Nitrate Corrective Action wells.

In addition, quarterly or monthly sampling may be required for certain parameters in certain
wells based on the requirements specified in Parts I.G.1 or I.G.2 of the GWDP. Sampling
personnel should coordinate with the QA Manager prior to conducting any monitoring well
sampling to determine if any parameters in any wells are subject to accelerated monitoring.

6.2.2 Quarterly and Semi-Annual Sampling Required Under Parts I.E.1.b) or I.E.1.c) of the
GWDP

All quarterly and semi-annual samples collected under Parts I.E.1.b) or I.E.1.c) of the GWDP
shall be analyzed for the following parameters:

a) Field parameters – depth to groundwater, pH, temperature, specific conductance,
redox potential (Eh) and turbidity; and

b) Laboratory Parameters:

(i) All parameters specified in Table 2 of the GWDP; and

(ii) General inorganics – chloride, sulfate, carbonate, bicarbonate, sodium
potassium, magnesium, calcium, and total anions and cations.

6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP

Any quarterly or monthly accelerated sampling required under paragraphs I.G.1. or I.G.2. of
the GWDP shall be analyzed for the specific parameters as required by previous sampling
results as determined by the QA Manager.

6.2.4 Sampling Equipment for Groundwater Compliance Monitoring

All equipment used for purging and sampling of groundwater which enters the well or may
otherwise contact sampled groundwater, shall be made of inert materials.

Purging and sampling equipment is described in Attachment 2-3 of this QAP.

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Field parameters are measured by using a flow cell system that enables the measurements to
be taken on a real-time basis without exposing the water stream to the atmosphere;

6.2.5 Decontamination Procedure

Portable (non-dedicated) sampling equipment will be decontaminated prior to each sampling
event, at the beginning of each day during the sampling event, and between each sampling
location (well). Non-dedicated sampling equipment will be decontaminated using the
procedure described in Attachment 2-2.

6.2.6 Pre-Purging/ Sampling Activities

Pre-purging and sampling activities are described in Attachment 2-3. The purging and
sampling techniques used at each well will be a function of the well’s historic recovery rates,
the equipment used for purging, and the analytical suite to be completed.

6.2.7 Well Purging/Measurement of Field Parameters

The purging techniques described in Attachment 2-3 will be used for all groundwater
sampling conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging wells prior to sampling removes the stagnant water column present in the well
casing and assures that representative samples of the formation water are collected. Purging
will be completed as described in Attachment 2-3.

There are three purging strategies that will be used to remove stagnant water from the well
casing during groundwater sampling at the Mill. The three strategies are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery
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6.2.8 Samples to be taken and order of taking samples

For each quarterly or semi-annual sampling event, samples will be collected for the analyte
specified in Table 2 of the GWDP. The following is a list of the sample containers that will
be collected to provide sample aliquots to the Analytical Laboratory for the completion of the
analyses specified in Table 2 of the GWDP . The Analytical Laboratory will provide the
sampling containers and may request that certain analytes be combined into a single
container due to like sampling requirements (filtering) and/or like preservation. The
container requirements will be determined by the Analytical Laboratory and specified with
the bottles supplied to the Field Personnel. Bottle requirements may change if the Analytical
Laboratory is changed or if advances in analytical techniques allow for reduced samples
volumes. The following list is a general guideline.

a) VOCs, 3 sample containers, 40 ml each;

b) Nutrients (ammonia, nitrate and nitrite), 1 sample container, 100 ml;

c) All other non-radiologics (fluoride, general inorganics, TDS, total cations and
anions), 1 sample container, 250 ml,; and

d) Gross alpha and heavy metals, 1 sample container, 1,000 ml, filtered.
The sample collection containers and sample volumes for chloroform and nitrate program
sampling are specified in Appendices A and B to this document.

Accelerated samples will be analyzed for a limited list of analytes as determined by previous
sampling results. Only the containers for the specific list of analytes will be collected for
accelerated monitoring samples.

7.0 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING

7.1 Field Data Worksheets

Documentation of observations and data from sampling provide important information about
the sampling process and provide a permanent record for sampling activities. All
observations and field sampling data will be recorded in waterproof ink on the Field Data
Worksheets, which will be maintained on file at the Mill.

The Field Data Worksheets will contain the following information:

 Name of the site/facility
 description of sampling event
 location of sample (well name)
 sampler’s name(s) and initials(s)
 date(s) and time(s) of well purging and sample collection
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 type of well purging equipment used (pump or bailer)
 previous well sampled during the sampling event
 well depth
 depth to groundwater before purging and sampling
 field measurements (pH, specific conductance, water temperature, redox
potential, turbidity)
 calculated well casing volume
 volume of water purged before sampling
 volume of water purged when field parameters are measured
 type and condition of well pump
 description of samples taken
 sample handling, including filtration and preservation
 volume of water collected for analysis
 types of sample containers and preservatives
 weather conditions and external air temperature
 name of certified Analytical Laboratory.

The Field Data Worksheets will also contain detailed notes describing any other significant
factors noted during the sampling event, including, as applicable: condition of the well cap
and lock; water appearance, color, odor, clarity; presence of debris or solids; any variances
from this procedure; and any other relevant features or conditions. An example of a Field
Data Worksheet that incorporates this information is attached in Attachment 1.

The data sheets included herein are examples and may be changed to accommodate
additional data collection. If a change is made to a data sheet to accommodate additional
information, a copy will be provided to the Executive Secretary. Changes to field forms will
not eliminate any data collection activity without written approval of the Executive
Secretary.

7.2 Chain-Of-Custody and Analytical Request Record

A Chain-of-Custody and Analytical Request Record form (the “COC Form”), provided by
the Analytical Laboratory, will accompany the samples being shipped to the Analytical
Laboratory. Examples of the Chain of Custody Forms used are attached as Attachment 2. If
the Chain of Custody Form changes at any time, the Company shall provide a copy of the
new or revised Chain of Custody Form to the Executive Secretary and substitute the new
form for the old form in Attachment 2. Standard Chain-of-Custody protocol is initiated for
each sample set. A COC Form is to be completed for each set of samples collected in a
shipping container (cooler) and is to include the following:

 sampler’s name
 company name
 date and time of collection
 sample type (e.g., water)
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 sample location
 number of sample containers in the shipping container
 analyses requested
 signatures of persons involved in the chain of possession
 internal temperatures of the shipping container when opened at the laboratory
 remarks section to identify potential hazards or to relay other information to the
Analytical Laboratory.

Chain-of-Custody reports will be placed inside a re-sealable bag and taped to the inside lid.
Custody seals will be placed on the outside of each cooler.

The person shipping the samples to the Analytical Laboratory will sign the COC Form,
document shipment method, and send the original and the second copy of the COC Form
with the samples. Upon receipt of the samples, the person receiving the samples will sign the
COC Form and return the second copy to the Mill’s RSO.

Copies of the COC Forms and other relevant documentation will be retained at the Mill.

7.3 Record Keeping

The Field Data Worksheets are retained at the Mill.

Data from the Analytical Laboratory, showing the laboratory analytical results for the water
samples, are maintained at the Mill.

Copies of the current Utah certifications of the Analytical Laboratory or Laboratories and a
list of Utah Bureau of Laboratory Improvement approved parameters and methods used to
perform analysis during the monitoring events conducted during the quarter will be
maintained at the Mill. DUSA will ensure that the Analytical Laboratory or Laboratories
used, have certifications for each parameter and method required by Section 8.2, Table 1 of
the QAP.

Once all the data for the quarter (all wells sampled during the quarter) is completed, key data
from the Field Data Worksheets and from the data packages are managed using electronic
data management software The data management software will be managed and
administered by the QA Manager or designee. The Mill Personnel will have read-only
access to the electronic data management software.

8.0 ANALYTICAL PROCEDURES AND QA/QC

Analytical Laboratory QA provides a means for establishing consistency in the performance
of analytical procedures and assuring adherence to analytical methods utilized. Analytical
Laboratory QC programs include traceability of measurements to independent reference
materials and internal controls.

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8.1 Analytical Quality Control

Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory. In
choosing and retaining the Analytical Laboratory, DUSA shall ensure that the Analytical
Laboratory is certified by the State of Utah and by NELAP, is capable of performing the
analytical procedures specified in Section 8.2, and that the QA/QC program of the Analytical
Laboratory includes the spikes, blanks and duplicates described in Section 8.1.2.

8.1.2 Spikes, Blanks and Duplicates

Analytical Laboratory QC samples will assess the accuracy and precision of the analyses.
The following describes the type of QC samples that will be used by the Analytical
Laboratory to assess the quality of the data. The following procedures shall be performed at
least once with each analytical Batch of samples:

a) Matrix Spike/Matrix Spike Duplicate

A spiked field sample analyzed in duplicate may be analyzed with every analytical
batch (depending on the analytical method requirements and or method limitations).
Analytes stipulated by the analytical method, by applicable regulations, or by other
specific requirements may be spiked into the samples. Selection of the sample to be
spiked depends on the information required and the variety of conditions within a
typical matrix. The matrix spike sample serves as a check evaluating the effect of the
sample matrix on the accuracy of analysis. The matrix spike duplicate serves as a
check of the analytical precision.

b) Method Blanks

Each analytical batch shall be accompanied by a method blank. The method blank
shall be carried through the entire analytical procedure. Contamination detected in
analysis of method blanks will be used to evaluate any Analytical Laboratory
contamination of environmental samples which may have occurred.

c) Surrogate Compounds

Every blank, standard, and environmental sample (including matrix spike/matrix
duplicate samples) for analysis of VOCs (or other organics only) shall be spiked with
surrogate compounds prior to purging or extraction. Surrogates are organic
compounds which are similar to analytes of interest in chemical composition,
extraction, and chromatography, but which are not normally found in environmental
samples. Surrogates shall be spiked into samples according to the appropriate organic
analytical methods.
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d) Check Sample

Each analytical batch shall contain a number of check samples. For each method, the
Analytical Laboratory will normally analyze the following check samples or their
equivalents: a method blank, a laboratory control spike, a matrix spike, and a matrix
spike duplicate, or the equivalent, with relative percent difference reported.

8.2 Analytical Laboratory Procedures

The analytical procedures to be used by the Analytical Laboratory will be as specified in
Table 1, or as otherwise authorized by the Executive Secretary. With respect to Chloroform
Investigation and Nitrate Corrective Action sampling, the analytical procedures for
parameters monitored under those programs are specified in Appendix A and B respectively.

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Table 1

Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Nutrients
Ammonia (as N) A4500-
NH3 G or
E350.1
0.05 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC

Heavy Metals
Arsenic E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Beryllium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Cadmium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
Chromium E200.7 or
E200.8
25 µg/L 6 months HNO3 to pH<2 None
Cobalt E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Copper E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Iron E200.7 or
E200.7
30 µg/L 6 months HNO3 to pH<2 None
Lead E200.7 or
E200.8
1.0 µg/L 6 months HNO3 to pH<2 None
Manganese E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Mercury E 245.1 or
E200.7 or
E200.8
0.50 µg/L 28 days HNO3 to pH<2 None
Molybdenum E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Nickel E200.7 or
E200.8
20 µg/L 6 months HNO3 to pH<2 None
Selenium E200.7 or
E200.8
5 µg/L 6 months HNO3 to pH<2 None
Silver E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None
Thallium E200.7 or
E200.8
0.50 µg/L 6 months HNO3 to pH<2 None
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
Tin E200.7 or
E200.8
100 µg/L 6 months HNO3 to pH<2 None
Uranium E200.7 or
E200.8
0.30 µg/L 6 months HNO3 to pH<2 None
Vanadium E200.7 or
E200.8
15 µg/L 6 months HNO3 to pH<2 None
Zinc E200.7 or
E200.8
10 µg/L 6 months HNO3 to pH<2 None

Radiologics
Gross Alpha E 900.0 or
E900.1
1.0 pCi/L 6 months HNO3 to pH<2

None

Volatile
Organic
Compounds

Acetone SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Benzene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
2-Butanone
(MEK)
SW8260B
or
SW8260C
20 µg/L 14 days HCl to pH<2 ≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Naphthalene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Tetrahydrofuran SW8260B 1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
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Contaminant Analytical
Methods
to be Used
Reporting
Limit1
Maximum
Holding
Times
Sample
Preservation
Requirement
s
Sample
Temperature
Requirements
or
SW8260C
Toluene SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Xylenes (total) SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC

Others
Field pH (S.U.) A4500-H
B
0.01 s.u. Immediate None None
Fluoride A4500-F C
or E300.0
0.1 mg/L 28 days None None
TDS A2540 C 10 mg/L 7 days None ≤ 6oC

General
Inorganics

Chloride A4500-Cl
B or
A4500-Cl
E
or E300.0
1 mg/L 28 days None None
Sulfate A4500-
SO4 E or
E300.0
1 mg/L 28 days None ≤ 6oC
Carbonate as
CO3
A2320 B 1 mg/L 14 days None ≤ 6oC
Bicarbonate as
HCO3
A2320 B 1 mg/L 14 days None ≤ 6oC
Sodium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Potassium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Magnesium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
Calcium E200.7 0.5 mg/L 6 months HNO3 to pH<2 None
1. The Analytical Laboratory will be required to meet the reporting limits (“RLs”) in the foregoing Table,
unless the RL must be increased due to sample matrix interference (i.e., due to dilution gain), in which case the
increased RL will be used, or unless otherwise approved by the Executive Secretary.

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9.0 INTERNAL QUALITY CONTROL CHECKS

Internal quality control checks are inherent in this QAP. The QA Manager will monitor the
performance of the Sample and QC Monitors, and, to the extent practicable, the Analysis
Monitor to ensure that they are following this QAP. In addition, either the QA Manager or a
Sampling and QC Monitor will review and validate the analytical data generated by the
Analytical Laboratory to ensure that it meets the DQOs established by this QAP. Finally,
periodic system and performance audits will be performed, as detailed in Section 12 below.

9.1 Field QC Check Procedures

The QA Manager will perform the following QA/QC analysis of field procedures:

9.1.1 Review of Compliance With the Procedures Contained in this QAP

Observation of technician performance is monitored by the QA Manager on a periodic basis
to ensure compliance with this QAP.

9.1.2 Analyte Completeness Review

The QA Manager will review all Analytical Results to confirm that the analytical results are
complete (i.e., there is an analytical result for each required constituent in each well). The
QA Manager shall also identify and report all instances of non-compliance and non-
conformance (see Part I.E.1(a) of the Permit. Executive Secretary approval will be required
for any completeness (prior to QA/QC analysis) less than 100 percent. Non-conformance
will be defined as a failure to provide field parameter results and analytical results for each
parameter and for each well required in Sections 6.2.2 and 6.2.3, for the sampling event,
without prior written Executive Secretary approval.

9.1.3 Blank Comparisons

Trip blanks, method blanks, and equipment rinsate samples will be compared with original
sample results. Non-conformance conditions will exist when contaminant levels in the
samples(s) are not order of magnitude greater than the blank result. (TEGD, Field QA/QC
Program, page 119).

Corrective actions for blank comparison non-conformance shall first determine if the non-
conformance is a systematic issue which requires the procedures described in Section 10. If
the non-conformance is limited in scope and nature, the QA Manager will

1. Review the data and determine the overall effect to the data quality,
2. Notify the laboratory of the discrepancy (if it is a laboratory generated blank), and
3. Request the laboratory review all analytical results for transcription and calculation
errors, and (for laboratory generated blanks)
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4. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

If re-analysis is not possible, qualifiers may be applied to the samples associated with a
non-conforming blank. Recommendations regarding the usability of the data may be
included in the quarterly report.

9.1.4 Duplicate Sample Comparisons

The following analyses will be performed on duplicate field samples:

a) Relative Percent Difference.

RPDs will be calculated in comparisons of duplicate and original field sample results.
Non-conformance will exist when the RPD > 20%, unless the measured concentrations
are less than 5 times the required detection limit (Standard Methods, 1998) (EPA
Contract Laboratory Program National Functional Guidelines for Inorganic Data Review,
February 1994, 9240.1-05-01, p. 25).

b) Radiologics Counting Error Term

All gross alpha analyses shall be reported with an error term. All gross alpha analysis
reported with an activity equal to or greater than the GWCL, shall have a counting
variance that is equal to or less that 20% of the reported activity concentration. An error
term may be greater than 20% of the reported activity concentration when the sum of the
activity concentration and error term is less than or equal to the GWCL.

c) Radiologics, Duplicate Samples

Comparability of results between the original and duplicate radiologic samples will be
evaluated by determining compliance with the following formula:

│A-B│/(sa2+sb2)1/2 < 2

Where:

A = the first duplicate measurement
B = the second duplicate measurement
sa2 = the uncertainty of the first measurement squared
sb2 = the uncertainty of the second measurement squared

Non-conformance exists when the foregoing equation is > 2.

(EPA Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and
Procedures Quality Assurance, January 2005, EPA 815-R-05-004, p. VI-9).
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Corrective actions for duplicate deviations shall first determine if the deviation is indicative
of a systematic issue which requires the procedures described in Section 10. If the non-
conformance is limited in scope and nature, the QA Manager will:
1. Notify the laboratory,
2. Request the laboratory review all analytical results for transcription and calculation
errors, and
3. If the samples are still within holding time, the QA Manager may request the
laboratory re-analyze the affected samples.

9.2 Analytical Laboratory QA Reviews

Full validation will include recalculation of raw data for a minimum of one or more analytes
for ten percent of the samples analyzed. The remaining 90% of all data will undergo a QC
review which will include validating holding times and QC samples. Overall data
assessment will be a part of the validation process as well.

The Analysis Monitor or data validation specialist will evaluate the quality of the data based
on SW-846, the applicable portions of NRC guide 4.14 and on analytical methods used. The
reviewer will check the following:

(1) sample preparation information is correct and complete,
(2) analysis information is correct and complete,
(3) appropriate Analytical Laboratory procedures are followed,
(4) analytical results are correct and complete,
(5) QC samples are within established control limits,
(6) blanks are within QC limits,
(7) special sample preparation and analytical requirements have been met, and
(8) documentation is complete.

The Analytical Laboratory will prepare and retain full QC and analytical documentation.
The Analytical Laboratory will report the data as a group of one batch or less, along with the
QA/QC data. The Analytical Laboratory will provide the following information:
(1) cover sheet listing samples included in report with a narrative,
(2) results of compounds identified and quantified,
(3) reporting limits for all analytes, and
(4) QA/QC analytical results.

9.3 QA Manager Review of Analytical Laboratory Results and Procedures

The QA Manager shall perform the following QA reviews relating to Analytical Laboratory
procedures:

a) Reporting Limit (RL) Comparisons

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The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are
in conformance with the reporting limits set out on Table 1. Non-conformance shall be
defined as:
1) a reporting limit that violates these provisions, unless the reporting limit must be increased
due to sample matrix interference (i.e., due to dilution); or
2) a reporting limit that exceeds the respective GWQS listed in Table 2 of the GWDP unless
the reported concentration is greater than the raised reporting limit.

b) Laboratory Methods Review

The QA Manager shall confirm that the analytical methods used by the Analytical
Laboratory are those specified in Table 1, unless otherwise approved by the Executive
Secretary. Non-conformance shall be defined when the Analytical Laboratory uses
analytical methods not listed in Table 1 and not otherwise approved by the Executive
Secretary.

c) Holding Time Examination

The QA Manager will review the analytical reports to verify that the holding time for each
contaminant was not exceeded. Non-conformance shall be defined when the holding time is
exceeded.

d) Sample Temperature Examination

The QA Manager shall review the analytical reports to verify that the samples were received
by the Analytical Laboratory at a temperature no greater than the approved temperature listed
in Table 1. Non-conformance shall be defined when the sample temperature is exceeded.

9.4 Analytical Data

All QA/QC data and records required by the Analytical Laboratory’s QA/QC program shall
be retained by the Analytical Laboratory and shall be made available to DUSA as requested.

Analytical data submitted by the Analytical Laboratory should contain the date/time the
sample was collected, the date/time the sample was received by the Analytical Laboratory,
the date/time the sample was extracted (if applicable), and the date/time the sample was
analyzed.

All out-of-compliance results will be logged by the Analysis Monitor with corrective actions
described as well as the results of the corrective actions taken. All raw and reduced data will
be stored according to the Analytical Laboratory’s record keeping procedures and QA
program. All Analytical Laboratory procedures and records will be available for on-site
inspection at any time during the course of investigation.

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If re-runs occur with increasing frequency, the Analysis Monitor and the QA Manager will
be consulted to establish more appropriate analytical approaches for problem samples.

10.0 CORRECTIVE ACTION

10.1 When Corrective Action is Required

The Sampling and QC Monitors and Analytical Laboratory are responsible for following
procedures in accordance with this QAP. Corrective action should be taken for any
procedural or systematic deficiencies or deviations noted in this QAP. All deviations from
field sampling procedures will be noted on the Field Data Worksheets or other applicable
records. Any QA/QC problems that arise will be brought to the immediate attention of the
QA Manager. Analytical Laboratory deviations will be recorded by the Analysis Monitor in
a logbook as well.

When a procedural or systematic non-conformance is identified, DUSA shall:

a) When non-conformance occurs as specified in Sections 9.1.3 or 9.1.4 the data shall
be qualified to denote the problem and the QC sample-specific corrective actions in
Sections 9.1.3, 9.1.4 or 9.3 will be followed. If the non-conformance is deemed to
be systematic or procedural, DUSA shall determine the root cause, and provide
specific steps to resolve problems(s) in accordance with the procedure set forth in
Section 10.2. Any non-conformance with QAP requirements in a given quarterly
groundwater monitoring period will be corrected and reported to the Executive
Secretary on or before submittal of the next quarterly ground water monitoring
report.
b) When a sample is lost, sample container broken, or the sample or analyte was
omitted, resample within 10 days of discovery and analyze again in compliance with
all requirements of this QAP. The results for this sample(s) should be included in
the same quarterly monitoring report with other samples collected for the same
sampling event; and
c) For any other material deviation from this QAP, the procedure set forth in Section
10.2 shall be followed.

10.2 Procedure for Corrective Action

The need for corrective action for non-conformance with the requirements of this QAP, may
be identified by system or performance audits or by standard QA/QC procedures. The
procedures to be followed if the need for a corrective action is identified, are as follows:

a) Identification and definition of the problem;

b) Assignment of responsibility for investigating the problem;

c) Investigation and determination of the cause of the problem;

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d) Determination of a corrective action to eliminate the problem;

e) Assigning and accepting responsibility for implementing the corrective action;

f) Implementing the corrective action and evaluating its effectiveness; and

g) Verifying that the corrective action has eliminated the problem.

The QA Manager shall ensure that these steps are taken and that the problem which led to the
corrective action has been resolved. A memorandum explaining the steps outlined above
will be placed in the applicable monitoring files and the Mill Central Files, and the corrective
action will be documented in a Report prepared in accordance with Section 11.
11.0 REPORTING

As required under paragraph I.F.1 of the GWDP, the Mill will send a groundwater
monitoring report to the Executive Secretary on a quarterly basis. Both the Routine
Groundwater Monitoring Reports (pertinent to Part I.F.1 of the Permit) and Chloroform
Investigation and Nitrate Corrective Action Reports shall be submitted according to the
following schedule:

Quarter Period Due Date
First January – March June 1
Second April – June September 1
Third July – September December 1
Fourth October – December March 1

The Routine Groundwater Monitoring Reports (pertinent to Part I.F.1 of the Permit) will
include the following information:

 Description of monitor wells sampled
 Description of sampling methodology, equipment an decontamination
procedures to the extent they differ from those described in this QAP
 A summary data table of groundwater levels for each monitor well and
piezometer
 A summary data table showing the results of the sampling event, listing all
wells and the analytical results for all constituents and identifying any
constituents that are subject to accelerated monitoring in any particular wells
pursuant to Part I.G.1 of the GWDP or are out of compliance in any particular
wells pursuant to Part I.G.2 of the GWDP
 Copies of Field Data Worksheets
 Copies of Analytical Laboratory results
 Copies of Chain of Custody Forms (included in the data packages)
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 A Water Table Contour Map showing groundwater elevation data for the
quarter will be contemporaneous for all wells on site, not to exceed a
maximum time difference of five calendar days.
 Evaluation of groundwater levels, gradients and flow directions
 Quality assurance evaluation and data validation description (see Section 9 for
further details)
 All non-conformance with this QAP and all corrective actions taken.
 Recommendations and Conclusions.

With respect to the Chloroform Investigation and Nitrate Corrective Action reporting
requirements, these are specified in Appendix A and B to this document.

In addition, an electronic copy of all analytical results will be transmitted to the Executive
Secretary in comma separated values (CSV) format, or as otherwise advised by the Executive
Secretary.

Further reporting may be required as a result of accelerated monitoring under paragraphs
I.G.1 and I.G.2 of the GWDP. The frequency and content of these reports will be defined by
DUSA corporate management working with the Executive Secretary.
12.0 SYSTEM AND PERFORMANCE AUDITS

12.1 QA Manager to Perform System Audits and Performance Audits

DUSA shall perform such system audits and performance audits as it considers necessary in
order to ensure that data of known and defensible quality are produced during a sampling
program. The frequency and timing of system and performance audits shall be as determined
by DUSA.

12.2 System Audits

System audits are qualitative evaluations of all components of field and Analytical
Laboratory QC measurement systems. They determine if the measurement systems are being
used appropriately. System audits will review field and Analytical Laboratory operations,
including sampling equipment, laboratory equipment, sampling procedures, and equipment
calibrations, to evaluate the effectiveness of the QA program and to identify any weakness
that may exist. The audits may be carried out before all systems are operational, during the
program, or after the completion of the program. Such audits typically involve a comparison
of the activities required under this QAP with those actually scheduled or performed. A
special type of systems audit is the data management audit. This audit addresses only data
collection and management activities.
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12.3 Performance Audits

The performance audit is a quantitative evaluation of the measurement systems of a program.
It requires testing the measurement systems with samples of known composition or behavior
to evaluate precision and accuracy. With respect to performance audits of the analytical
process, either blind performance evaluation samples will be submitted to the Analytical
Laboratory for analysis, or the auditor will request that it provide results of the blind studies
that the Analytical Laboratory must provide to its NELAP accreditation agency on an annual
basis. The performance audit is carried out without the knowledge of the analysts, to the
extent practicable.

12.4 Follow-Up Actions

Response to the system audits and performance audits is required when deviations are found
and corrective action is required. Where a corrective action is required, the steps set out in
Section 10.2 will be followed.

12.5 Audit Records

Audit records for all audits conducted will be retained in Mill Central Files. These records
will contain audit reports, written records of completion for corrective actions, and any other
documents associated with the audits supporting audit findings or corrective actions.

13.0 PREVENTIVE MAINTENANCE

Preventive maintenance concerns the proper maintenance and care of field and laboratory
instruments. Preventive maintenance helps ensure that monitoring data generated will be of
sufficient quality to meet QA objectives. Both field and laboratory instruments have a set
maintenance schedule to ensure proper functioning of the instruments.

Field instruments will be maintained as per the manufacturer’s specifications and established
sampling practice. Field instruments will be checked and calibrated prior to use, in
accordance with Section 5. Batteries will be charged and checked daily when these
instruments are in use. All equipment out of service will be immediately replaced. Field
instruments will be protected from adverse weather conditions during sampling activities.
Instruments will be stored properly at the end of each working day. Calibration and
maintenance problems encountered will be recorded in the Field Data Worksheets or
logbook.

The Analytical Laboratory is responsible for the maintenance and calibration of its
instruments in accordance with Analytical Laboratory procedures and as required in order to
maintain its NELAP certifications. Preventive maintenance will be performed on a
scheduled basis to minimize downtime and the potential interruption of analytical work.

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14.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT

14.1 Ongoing QA/QC Reporting

The following reporting activities shall be undertaken on a regular basis:

a) The Sample and QC Monitors shall report to the QA Manager regularly regarding
progress of the applicable sampling program. The Sample and QC Monitors will
also brief the QA Manager on any QA/QC issues associated with such sampling
activities.

b) The Analytical Laboratory shall maintain detailed procedures for laboratory record
keeping. Each data set report submitted to the Mill’s QA Manager or his staff will
identify the analytical methods performed and all QA/QC measures not within the
established control limits. Any QA/QC problems will be brought to the QA
Manager’s attention as soon as possible; and

c) After sampling has been completed and final analyses are completed and reviewed, a
brief data evaluation summary report will be prepared by the Analytical Laboratory
for review by the QA Manager, by a Sampling and QC Monitor or by such other
qualified person as may be designated by the QA Manager. The report will be
prepared in accordance with NELAP requirements and will summarize the data
validation efforts and provide an evaluation of the data quality.

14.2 Periodic Reporting to Management

The QA Manager shall present a report to DUSA’s ALARA Committee at least once per
calendar year on the performance of the measurement system and the data quality. These
reports shall include:

a) Periodic assessment of measurement quality indicators, i.e., data accuracy, precision
and completeness;

b) Results of any performance audits, including any corrective actions;

c) Results of any system audits, including any corrective actions; and

d) Significant QA problems and recommended solutions.

15.0 AMENDMENT

This QAP may be amended from time to time by DUSA only with the approval of the
Executive Secretary.

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16.0 REFERENCES

United States Environmental Protection Agency, November 2004, Test Methods for
Evaluating Solid Waste, EPA SW-846.

United States Environmental Protection Agency, September, 1986, RCRA Ground-Water
Monitoring Technical Enforcement Guidance Document (TEGD), Office of Solid Waste and
Emergency Response, OSWER-9950.1.

United States Environmental Protection Agency, November 1992, RCRA Ground-water
Monitoring Draft Technical Guidance (DTG), Office of Solid Waste.

Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1998.
American Public Health Association, American Water Works Association, Water
Environment Federation. Washington, D.C. p. 1-7.
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ATTACHMENT 1
Field and Data Forms
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Attachment 1-1
Quarterly Depth to Water Data Sheet

NAME:   
DATE: 
TIME WELL Static level TIME WELL Static Level TIME WELL Static Level

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ATTACHMENT 1-2
WHITE MESA URANIUM MILL
FIELD DATA WORKSHEET FOR GROUNDWATER
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ATTACHMENT 1-3
EXAMPLE CHAIN OF CUSTODY
FORMS

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Sheet 1 of 1

CHAIN OF CUSTODY

Samples
Shipped to:
Contact
:

Chain of Custody/Sampling Analysis Request

Project Samplers Name Samplers Signature

Sample ID
Date
Collecte
d
Time
Collected Laboratory Analysis Requested

Please notify Tanner Holliday of Receipt temperature on these samples Immediately!
Thank you.

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

Relinquished
By:(Signature)
Date/Tim
e
Received
By:(Signature) Date/Time

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ATTACHMENT 2
Field Procedures
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Attachment 2-1
Groundwater Head (Depth to Water) Measurement Procedures

Measure and record all depth to water data to the nearest 0.01 feet.

Equipment Used For Groundwater Head Monitoring

Measurement of depth to groundwater is accomplished by using a Solinist – IT 300 or
equivalent device (the “Water Level Indicator”).

Equipment Checks

Equipment used in depth to groundwater measurements will be checked prior to each use to
ensure that the Water Sounding Device is functional.

Check the Water Sounding Device as follows:
 Turn the Water Level Indicator on.
 Test the Water Level Indicator using the test button located on the instrument.
 If the Water Level Indicator alarms using the test button it is considered operational
and can be used for depth to water measurements.

Measurement of Depth to Water

All depth to water measurements (quarterly and immediately prior to sample collection) will
be completed using the following procedure:

 For monitoring wells - Measure depth to water from the top of the inner well casing
at the designated measurement point.
 For the piezometers - Measure depth to water from the top of the casing at the
designated measurement point.
 Measurements are taken by lowering the Water Level Indicator into the casing until
the device alarms, indicating that the water surface has been reached.
 Record the depth to groundwater on the appropriate form in Attachment 1 as the
distance from the measuring point to the liquid surface as indicated by the alarm. The
distance is determined using the tape measure on the Water Level Indicator.

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Attachment 2-2
Decontamination Procedures

Non-dedicated sampling equipment will be decontaminated using the following
procedures:

Water level meter

Decontaminate the water level meter with a detergent/deionized (“DI”) water mixture
by pouring the solutions over the water level indicator.

Rinse the water level indicator with fresh DI water rinse by pouring the DI water over
the water level indicator.

Field Parameter Instrument (Hydrolab or equivalent)

Rinse the field parameter instrument probe unit with DI water prior to each
calibration.

Wash the cup of the flow through cell with a detergent/DI water mixture and rinse
with fresh DI water prior to each calibration.

Non-Dedicated Purging/Sampling Pump

Non-dedicated sampling/purging equipment will be decontaminated after each use
and prior to use at subsequent sampling locations using the following procedures:

a) submerge the pump into a 55-gallon drum of nonphosphate detergent/DI
water mixture;

b) pump the detergent/DI water solution through the pump and pump outlet lines
into the drain line connected to Cell 1;

c) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

d) submerge the pump into a 55-gallon drum of DI water;

e) pump the DI water solution through the pump and pump outlet lines into the
drain line connected to Cell 1;

f) pump as much of the detergent/DI water mixture from the drum through the
pump and outlet lines as possible;

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g) if an equipment rinsate blank is required, submerge the pump into a fresh 55-
gallon drum of DI water and pump 50% or more of the DI water through the
pump and pump outlet lines;

h) if required, collect the equipment rinsate blank directly from the pump outlet
lines into the appropriate sample containers (filtering the appropriate aliquots as
needed).

All water produced during decontamination of a non-dedicated pump will pumped to an
appropriate drain line which outlets into Cell 1.

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Attachment 2-3
Purging Procedures

The following equipment will be used for groundwater purging and sampling:

 Disposable Bailer: A bailer that is used at one specific well for one event for purging
and/or sampling. These bailers are single use and are disposed of as trash after sampling
in accordance with Mill disposal requirements for Mill-generated solid waste.
 Dedicated Pump: A pump that is dedicated to one specific well for the use of purging or
sampling. A dedicated pump remains inside the well casing suspended and secured.
 Non – Dedicated Pump: A pump that is used for purging and sampling at one or more
wells.
 Field Parameter Meter: A meter used to measure ground water quality parameters as
listed below. Field parameters shall be measured using a Hydrolab M-5 with Flow Cell
Multi-Parameter Meter system or equivalent that allows a continuous stream of water
from the pump to the meter that enables measurements to be taken on a real-time basis
without exposing the water stream to the atmosphere. The Field Parameter Meter
measures the following parameters:

 Water temperature;
 Specific conductivity;
 Turbidity;
 pH;
 Redox potential (Eh).

 Water Level Indicator: A tape measure with a water level probe on the end that
alarms when contact is made with water.
 Diesel Generator: Mobile power supply to provide power for submersible pump.
 150 psi air compressor and ancillary equipment, or equivalent to operate dedicated
“bladder” pumps.

Additional supplies for purging and sampling are as follows:

 Field Data Sheets
 45 micron in-line filters (when metals and gross alpha analyses are required)
 Calculator
 Clock, stopwatch or other timing device
 Buckets
 Sampling containers(as provided by the Analytical Laboratory)
 Field preservation chemicals (as provided by the Analytical Laboratory)
 Disposable gloves
 Appropriate health and safety equipment
 Sample labels and COCs (as provided by the Analytical Laboratory)

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Pre-Purging/ Sampling Activities

If a portable (non-dedicated) pump is to be used, prior to commencing the event’s sampling
activities,

1. check the pumping equipment to ensure that no air is leaking into the discharge line, in
order to prevent aeration of the sample;
2. decontaminate the sampling pump using the procedure described in Attachment 2-2 and
collect a equipment rinsate blank as required; and
3. Prior to leaving the Mill office, place the Trip Blank(s) into a cooler that will transport
the VOC samples. The Trip Blank(s) will accompany the groundwater (VOC) samples
throughout the monitoring event.

Well Purging

The purging techniques described below will be used for all groundwater sampling
conducted at the Mill unless otherwise stated in the program-specific QAPs for the
chloroform and nitrate investigations. The program-specific QAPs for the chloroform and
nitrate investigations are included as Appendix A and Appendix B respectively.

Purging is completed using the equipment described above. Purging is completed to remove
stagnant water from the casing and to assure that representative samples of formation water
are collected for analysis. There are three purging strategies that will be used to remove
stagnant water from the casing during groundwater sampling at the Mill. The three strategies
are as follows:

1. Purging three well casing volumes with a single measurement of field parameters
2. Purging two casing volumes with stable field parameters (within 10% RPD)
3. Purging a well to dryness and stability of a limited list of field parameters after
recovery

The groundwater in the well should recover to within at least 90% of the measured
groundwater static surface before sampling. If after 2 hours, the well has not recovered to
90% the well will be sampled as soon as sufficient water for the full analytical suite is
available.

Turbidity measurement in the water should be < 5 NTU prior to sampling unless the well is
characterized by water that has a higher turbidity.

A flow-cell needs to be used for field parameters.

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Procedure

a) Determine the appropriate purging strategy based on historic performance of the
well (3 casing volumes, 2 casing volumes and stable parameters, or purging the well
to dryness)

b) Remove the well casing cap and measure and record depth to groundwater as
described in Attachment 2-1 above;

c) Determine the casing volume (V) in gallons, where h is column height of the water
in the well (calculated by subtracting the depth to groundwater in the well from the
total depth of the well), V = 0.653*h, for a 4” casing volume and V = .367*h for a 3”
casing volume. Record the casing volume on the Field Data Worksheet;

If a portable (non-dedicated) pump is used:

 Ensure that it has been decontaminated in accordance with Attachment 2-2 since its
last use.
 Lower the pump into the well. Keep the pump at least five feet from the bottom of
the well.

If a non-dedicated pump or dedicated pump is used:

(i) Commence pumping;

(ii) Determine pump flow rate by using a stopwatch or other timing device and a
calibrated bucket by measuring the number of seconds required to fill to the
one-gallon mark. Record this in the “pumping rate” section of the Field Data
Worksheet;

(iii) Calculate the amount of time to evacuate two or three casing volumes;

(iv) Evacuate two or three casing volumes by pumping for the length of time
determined in paragraph (iii);

(v) If two casing volumes will be purged:

Take measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) during well purging, using the
Field Parameter Meter. These measurements will be recorded on the Field
Data Worksheet. Purging is completed after two casing volumes have been
removed and the field parameters pH, temperature, specific conductance,
redox potential (Eh) and turbidity have stabilized to within 10% RPD over at
least two consecutive measurements.

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(vi) If three casing volumes will be purged:

Take one set of measurements of field parameters (pH, specific conductance,
temperature, redox potential and turbidity) after three casing volumes have
been purged immediately prior to sample collection using the Field Parameter
Meter. Record these measurements on the Field Data Worksheet.

(vii) If the well is purged to dryness:

Record the number of gallons purged on the Field Data Worksheet.

The well should be sampled as soon as a sufficient volume of groundwater is
available to fill sample containers.

Upon arrival at the well after recovery or when sufficient water is available
for sampling measure depth to water and record on the Field Data Worksheet.

Take one set of measurements of field parameters for pH, specific
conductance and temperature only.

Collect the samples into the appropriate sample containers.

Take an additional set of measurements of field parameters for pH, specific
conductance and temperature after the samples have been collected.

If the field parameters of pH, specific conductance and temperature are within
10% RPD the samples can be shipped for analysis.

If the field parameters of pH, specific conductance and temperature are not
within 10% RPD, dispose of the sample aliquots, and purge the well again as
described above.

Repeat this process if necessary for three complete purging events. If after the
third purging the event, the parameters of pH, specific conductance and
temperature do not stabilize to within 10% RPD, the well is considered
sufficiently purged and collected samples can be submitted for analysis.

Purging using a disposable bailer

For wells where a pump is not effective due to shallow water columns, a disposable
bailer, made of inert materials, will be used.

When a bailer is used, the following procedure will be followed:

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(i) Use the water level meter to determine the water column and figure the
amount of water that must be evacuated.

(ii) Attach a disposable bailer to a rope and reel.

(iii) Lower the bailer into the well and listen for contact with the solution.
Once contact is made, allow the bailer to gradually sink in the well, being
careful not to allow the bailer to come in contact with the bottom sediment.

(iv) After the bailer is full, retrieve the bailer and pour the water from the bailer
into 5 gallon buckets. By doing this, one can record the number of gallons
purged.

(v) Repeat this process until either two casing volumes have been collected or
until no more water can be bailed. When the process is finished for the well,
the bailer will be disposed of.

(vi) Take field measurements from the water in the buckets.

All water produced during well purging will be containerized. Containerized water will be
disposed of into an active Tailings Cell.

After the collection of all samples, and prior to leaving the sampling site, replace the well cap
and lock the casing.
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Attachment 2-4
Sample Collection Procedures
Sample Collection Order

Regardless of the purging method employed samples will be collected in the order specified
below.

All containers and preservatives will be provided by the Analytical Laboratory. Collect the
samples in accordance with the volume, container and preservation requirements specified by
the Analytical Laboratory which should be provided with the supplied containers.

VOCs;
Nutrients (ammonia, nitrate and nitrite);
All other non-radiologics (fluoride, general inorganics, TDS, total cations and anions); and
Gross alpha and heavy metals (filtered).

Sample Filtering

When sampling for heavy metals and for gross alpha, the following procedure shall be
followed:

a) Obtain the specifically identified sample container for the type of sample to be
taken, as provided by the Analytical Laboratory;

b) Add the quantity of specified preservative provided by the Analytical Laboratory to
each sample container;

c) When using a pump to sample:

(i) Place a new 0.45 micron filter on the sample tubing;

(ii) Pump the sample through the filter, and into the sample container containing
the preservative;

(iii) The pump should be operated in a continuous manner so that it does not
produce samples that are aerated in the return tube or upon discharge;

d) When using a bailer to sample (wells with shallow water columns, i.e., where the
water column is less than five feet above the bottom of the well casing), then the
following procedure will be used to filter samples:

(i) Collect samples from the bailer into a large, unused sample jug that does not
contain any preservatives.

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(ii) Add the appropriate preservatives to the appropriate sample container provided
by the Analytical Laboratory.

(iii) Place clean unused tubing in the peristaltic pump.

(iv) Use the peristaltic pump to transfer the unpreserved sample from the large
sample jug to the sample containers through a 0.45 micron filter.

Procedures to Follow After Sampling

a) In each case, once a sample is taken, identify and label the sample container using
the labels provided by the Analytical Laboratory. The labels may include the
following information depending on the type of analysis requested:

 Sample location
 Date and time of sample
 Any preservation method utilized
 Filtered or unfiltered

b) Immediately after sample collection, place each sample in an ice-packed cooler;
and

c) Before leaving the sampling location, thoroughly document the sampling event on
the Field Data Worksheet, by recording all pertinent data.

Upon returning to the office, the samples must be stored in a refrigerator at less than or equal
to 6o C. These samples shall be received by the Analytical Laboratory at less than or equal to
6o C. Samples will then be re-packed in the plastic ice-packed cooler and transported via
these sealed plastic containers by overnight delivery services to the Analytical Laboratory.
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Attachment 2-5
Field QC Samples
Field Duplicates

Field duplicates are required to be collected at a frequency of one duplicate per every 20 field
samples. Field duplicate samples are analyzed for the same analytes as the parent sample.

Field duplicate samples should be as near to split samples as reasonably practicable.

Collection of field duplicates is completed as follows:

Fill a single VOC vial for the parent sample. Collect a second VOC vial for the duplicate
sample. Collect the second set of VOC vials for the parent immediately followed by the
duplicate sample. Fill the third set of VOC vials in the same manner. Repeat this
parent/duplicate process for the remaining analytes in the order specified in Attachment 2-4
blind to the Analytical Laboratory.

Field duplicate samples are labeled using a “false” well number such as MW-65 and MW-70.

Equipment Rinsate Samples

Where portable (non-dedicated) sampling equipment is used, a rinsate sample will be
collected at a frequency of one rinsate sample per 20 field samples.

Equipment rinsate samples are collected after the decontamination procedure in Attachment
2-2 is completed as follows:

Submerge the pump into a fresh 55-gallon drum of DI water and pump 50% or more of the
DI water through the pump and pump outlet lines;

Collect the equipment rinsate blank directly from the pump outlet lines into the appropriate
sample containers (filtering the appropriate aliquots as needed).

Equipment rinsate blanks are labeled with the name of the subsequently purged well with a
terminal letter “R” added (e.g. MW-11R).

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Appendix A
Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
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Chloroform Investigation Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah

This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Chloroform Investigation conducted pursuant to State of Utah Notice of Violation and
Groundwater Corrective Action Order (UDEQ Docket No. UGW-20-01) (the “Order”).

Specifically, the Mill will use the same sampling regimen for the Chloroform Investigation
that is utilized for groundwater sampling under its groundwater discharge permit, as set forth
in the attached groundwater discharge permit Quality Assurance Plan (QAP), except as set
forth below:

1) Dedicated Purge Pump/Sampling

Chloroform Investigation samples are collected by means of disposable bailer(s) the
day following the purging .The disposable bailer is used only for the collection of a
sample from an individual well and disposed subsequent to the sampling. The wells
are purged prior to sampling by means of a portable pump. Each quarterly purging
event begins at the location least affected by chloroform (based on the previous
quarters sampling event) and proceeds by affected concentration to the most affected
location. Although purging will generally follows this order, the sampling order may
deviate slightly from the generated list. This practice does not affect the samples for
these reasons: any wells sampled in slightly different order have either dedicated
pumps or are sampled via a disposable bailer. This practice does not affect the
quality or usability of the data as there will be no cross-contamination resulting from
sampling order. Decontamination of all sampling equipment will follow the
decontamination procedure outlined in Attachment 2-2 of the QAP.

2) Chloroform Investigation Sampling Frequency, Order and Locations

The chloroform investigation wells listed below are required to be monitored on a
quarterly basis under State of Utah Notice of Violation and Groundwater Corrective
Action Order UDEQ Docket No. UGW-20-01. Chloroform wells shall be purged
from the least contaminated to the most contaminated as based on the most recent
quarterly results.

 MW-4
 TW4-1
 TW4-2
 TW4-3
 TW4-4
 TW4-5
 TW4-6
 TW4-13
 TW4-14
 MW-26
 TW4-16
 MW-32
 TW4-18
 TW4-19
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 TW4-7
 TW4-8
 TW4-9
 TW4-10
 TW4-11
 TW4-12
 TW4-26

 TW4-20
 TW4-21
 TW4-22
 TW4-23
 TW4-24
 TW4-25
 TW4-27

Note: Wells MW-26 and MW-32 may be monitored under either the Chloroform
Investigation Program or the Groundwater Discharge Permit Monitoring Program.

3) Chloroform Investigation Sample Containers and Collection Volume

The chloroform investigation sampling program requires a specific number of
sampling containers and the collection of specific volumes of sample. Accordingly,
the following sample volumes are collected by bailer from each sampling location:

 For Volatile Organic Compounds (VOC), collect three samples into three
separate 40 ml containers.
 For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
4) Laboratory Requirements

Collected samples which are gathered for chloroform investigation purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

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Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Carbon
Tetrachloride
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloroform SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Dichloromethane
(Methylene
Chloride)
SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Chloromethane SW8260B
or
SW8260C
1.0 µg/L 14 days HCl to pH<2 ≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

5) Field Parameters

Only one set of field parameters are required to be measured prior to sampling in
chloroform pumping wells. This includes the following wells: MW-4, MW-26,
TW4-4, TW-4-19 and TW-4-20. However, if a pumping well has been out of service
for 48 hours or more, DUSA shall follow the purging requirements outlined in
Attachment 2-3 of the QAP before sample collection.

Field parameters will be measured in chloroform wells which are not continuously
pumped as described in Attachment 2-3 of the groundwater QAP.

6) Chloroform Investigation Reports

The Chloroform Investigation Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
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 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples

c) Data Interpretation

 Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
 Interpretation of all analytical results for each well, including a discussion
on: 1) a current chloroform isoconcentration map with one of the
isosconentration lines showing the 70 ug/L boundary, 2) graphs showing
chloroform concentration trends in each well through time and, 3)
analytical results for each well summarized in a data table, that includes
historic analytical results for each well.
 Calculate chloroform mass removed by pumping wells. Calculations
would include: 1) total historic chloroform mass removed, 2) total historic
chloroform mass removed for each pumping well, 3) total chloroform
mass removed for the quarter and, 4) total chloroform mass removed from
each pumping well for the quarter.

d) Conclusions and Recommendations

e) Electronic copy of all laboratory results for Chloroform Investigation
monitoring conducted during the quarter.

f) Copies of DUSA field records, laboratory reports and chain of custody forms.

Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.

Mill - Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 57 of 61

Appendix B
Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah
Mill - Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 58 of 61

Nitrate Corrective Action Monitoring
Quality Assurance Program
White Mesa Uranium Mill
Blanding, Utah

This document sets out the quality assurance plan to be used by Denison Mines (USA) Corp.
for Nitrate Corrective Action Monitoring (“Nitrate Program”) conducted pursuant to State of
Utah Stipulated Consent Agreement Docket Number UGW-09-03-A.

Specifically, the Mill will use the same sampling regimen for the Nitrate program that is
utilized for groundwater sampling under its groundwater discharge permit, as set forth in the
attached groundwater discharge permit Quality Assurance Plan (QAP), except as set forth
below:

1) Purge Pump/Sampling

The Nitrate program wells are purged and sampled by means of a portable pump. If
the well is purged to dryness the samples are collected the following day by means of
disposable bailer(s).The disposable bailer is used only for the collection of a sample
from an individual well and disposed subsequent to the sampling.

Each quarterly purging event begins at the location least affected by nitrate (based on
the previous quarters sampling event) and proceeds by affected concentration to the
most affected location. Purging and sampling follows this order if the wells are not
purged to dryness and the samples are collected immediately after purging using the
portable pump. If the well is purged to dryness and sampled with a disposable bailer,
the sampling order may deviate slightly from the generated list. This practice does
not affect the samples collected with a bailer for this reason: there is no cross-
contamination resulting from sampling order when the samples are collected with a
disposable bailer. Decontamination of all non-disposable sampling equipment will
follow the decontamination procedure outlined in Attachment 2-2 of the QAP.

2) Nitrate Program Sampling Frequency, Order and Locations

The Nitrate Program wells listed below are required to be monitored on a quarterly
basis under State of Utah Docket No. UGW-09-03-A. DUSA has submitted a
Corrective Action Plan (“CAP”) as required by the Stipulated Consent Agreement.
In that CAP, DUSA has proposed the abandonment of a number of the wells listed
below. The implementation of the CAP, shall supersede any requirements contained
in this QAP and Appendix. Nitrate Program wells shall be purged from the least
contaminated to the most contaminated as based on the most recent quarterly results.

Mill - Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 59 of 61

 TWN-1
 TWN-2
 TWN-3
 TWN-4
 TWN-5*
 TWN-6**
 TWN-7
 TWN-8*
 TWN-9*
 TWN-10*
 TWN-11*
 TWN-12*

 TWN-13*
 TWN-14**
 TWN-15*
 TWN-16**
 TWN-17*
 TWN-18
 TWN-19**
 Piezometer-01
 Piezometer-02
 Piezometer-03

*Recommended for abandonment
**Recommended for depth to water measurements only. DUSA has proposed
that monitoring cease.

7) Nitrate Program Sample Containers and Collection Volume

The Nitrate Program sampling requires a specific number of sampling containers and
the collection of specific volumes of sample. Accordingly, the following sample
volumes are collected by bailer from each sampling location:

 For Nitrate/Nitrite determinations, collect one sample into a 100 ml container.
 For Inorganic Chloride, collect one sample into a 100 ml container.
The Analytical Laboratory will provide the sampling containers and may request that certain
analytes be combined into a single container due to like sampling requirements and/or like
preservation. The container requirements will be determined by the Analytical Laboratory
and specified with the bottles supplied to the Field Personnel. Bottle requirements may
change if the Analytical Laboratory is changed or if advances in analytical techniques allow
for reduced samples volumes. The above list is a general guideline.
8) Laboratory Requirements

Collected samples which are gathered for Nitrate Program purposes are
shipped to an analytical laboratory where the requisite analyses are performed. At
the laboratory the following analytical specifications must be adhered to:

Mill - Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 60 of 61

Analytical
Parameter
Analytical
Method
Reporting
Limit
Maximum
Holding
Times
Sample
Preservation
Requirement
Sample
Temperature
Requirement
Nitrate & Nitrite
(as N)
E353.1 or
E353.2
0.1 mg/L 28 days H2SO4 to
pH<2
≤ 6oC
Inorganic
Chloride
A4500-Cl B
or A4500-Cl
E
or E300.0
1 mg/L 28 days None ≤ 6oC

9) Field Parameters

Field parameters will be measured in Nitrate Program wells as described in
Attachment 2-3 of the groundwater QAP.

10) Nitrate Program Investigation Reports

The Nitrate Program Reports will include the following information:

a) Introduction

b) Sampling and Monitoring Plan

 Description of monitor wells
 Description of sampling methodology, equipment and decontamination
procedures
 Identify all quality assurance samples, e.g. trip blanks, equipment blanks,
duplicate samples

c) Data Interpretation

 Interpretation of groundwater levels, gradients, and flow directions.
Interpretations will include a discussion on: 1) A current site groundwater
contour map, 2) hydrographs to show groundwater elevation in each
monitor well over time, 3) depth to groundwater measured and
groundwater elevation from each monitor well summarized in a data table,
that includes historic groundwater level data for each well, and 4) an
evaluation of the effectiveness of hydraulic capture of all contaminants of
concern.
 Interpretation of all analytical results for each well, analytical results for
each well summarized in a data table, that includes historic analytical
results for each well.
 Calculate nitrate mass removed by pumping wells (as the pumps are
installed and operational). Calculations would include: 1) total nitrate
Mill - Groundwater Discharge Permit Date: 06-06-12 Revision 7.2
Groundwater Monitoring
Quality Assurance Plan (QAP) Page 61 of 61

mass removed, 2) total historic nitrate mass removed for each pumping
well, 3) total nitrate mass removed for the quarter and, 4) total nitrate
mass removed from each pumping well for the quarter.

d) Conclusions and Recommendations

e) Electronic copy of all laboratory results for Nitrate Program monitoring
conducted during the quarter.

f) Copies of DUSA field records, laboratory reports and chain of custody
forms.

Except as otherwise specified above, the Mill will follow the procedure set out in the Mill’s
QAP.

OENISOJ)~~
MINES
February 29,2012
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisonmines.com
Transmittal of Revised Discharge Minimization Technology Monitoring ("DMT") Revision 11.5,
dated February 2012
Dear Mr. Lundberg:
Reference is made to the Division of Radiation Control ("DRC") letters dated September 13, 2011,
December 14, 2011, December 22, 2011, and February 15, 2012 regarding the White Mesa Mill
Tailings Management System and Discharge Minimization Technology ("DMT") Monitoring Plans dated
June 2011 (Revision 11.2), July 2011 (Revision 11.3), and January 2012 (Re~ision 11.4).
This letter transmits Denison Mines (USA) Corp's ("Denison's") proposed revisions to the White Mesa
Mill DMT Plan. These revisions include changes made to
1. Respond to the DRC Letter dated February 15, 2011, which incorporated specific comments
from the DRC letters dated September 13, 2011, December 14, 2011, December 22, 2011 .
2. Correct additional errors and inconsistencies in the January 2012 Revision of the DMT Plan.
For ease of review we have provided both redline and clean versions of each document.
The attached DMT Plan Revision 11.5 has accepted all the redline changes proposed in Denison's
January 2012 submittal as the base version in black type. Changes resulting from the above-referenced
DRC comment letter are provided in redline/strikeout format.
We have also provided, below, specific responses to each request in DRC's February 15, 2011 letter.
The sections and numbering of the remainder of this letter follow the DRC February 15, 2011 letter.
Each DRC request is shown in italics, below, followed by Denison's response.
Responses to Comments Provided to DUSA in the September 13, 2011 DRC RFl/Confirmatory
Action Letter (as re-transmitted in a DRC letter dated February 15, 2011)
DRCComment
The comment, shown immediately below, corresponds to comment number three (3) in the subject
September 13, 2011 DRC CAL:
3. DUSA states that, "Denison has developed other means to accurately measure cell solution level
elevations prior to construction of any walkways." However, the CAL states that, "The procedures
Letter to M r. Rusty Lu ndberg
February 29,2012
Page 2
for this method to measure the water level elevation will be submitted by DUSA for approval, in a
revised DMT Plan."
Please propose the "other means" to measure the water level, as discussed above. It is not
apparent in the DMT plan what the "other means" to measure the solution elevation are.
Denison Response:
As previously stated in Denison's January 30, 2012 response letter, tailings cell wastewater pool
elevations wi" be monitored within 30 days of authorization for use in accordance with the existing survey
procedures specified in the DMT Plan and in accordance with Mi" health and safety requirements.
The text referring to "other methods" was removed from the DMT Plan, Revision 11.4, submitted in
January 2012. The tailings cell wastewater pool elevations wi" be measured using the standard survey
procedures as described in the DMT Plan. No further descriptions of additional procedures are needed
because the procedures are already described in Section 3.1 d) of the DMT Plan. Additional text has
been added clarifying that for newly constructed cells the same procedure wi" be used.
DRCComment
The comment numbers below correspond to the comment numbers in the subject December 22, 2011
DRC Letter:
~. Part I.D.3(b)(3) of the Permit states that "Annual Slimes Drain Compliance -shall be achieved
when the average annual wastewater recovery elevation in the slimes drain access pipe, as
determined pursuant to the currently approved DMT Monitoring Plan, meets the conditions in
Equation 1 below ... "
Thus, the DMT Plan needs to state how the slimes drain recovery elevations are to be calculated. A
DUSA letter dated January 27, 20121 shows DUSA's current method of calculating the slimes drain
recovery elevation, as well as the annual average slimes drain recovery elevation. This method is
clarified in the second full paragraph on page 2 of that letter. One may call the current DUSA method of
calculating recovery elevations a relative elevation method.
Although this method is valid for comparison purposes, it appears correct elevations, with respect to the
true elevation above mean sea, level (fmsl), are not being used. As mentioned in the January 27, 2012
letter, 1/ ••• the standpipe elevation was re-surveyed, in 2011, which indicated that the elevation of the
measurement point of 5614.83 fmsl reported to date ... was 3.07 feet higher than the 2011 survey result
of 5611.76 fmsl ... 1/
To avoid the complex adjustments to calculate relative elevations, and to avoid future errors, DUSA must
convert to using actual fmsl elevations, not relative elevations, in all of its slimes drain recovery elevation
determinations and calculations. DUSA's method to do this must be stated in the DMT Plan.
Notwithstanding the above, the DMT Plan needs to state how the slimes drain recovery elevations are to
be calculated.
Denison Response:
The current, correct elevation of the measuring point as surveyed by a Utah-Licensed surveyor, has been
added to the DMT Plan. The calculation of the Cell 2 slimes drain elevation (SORE) has been added to
Section 3.1 b)(v) showing how the elevation of the fluid is calculated relative to the surveyed measuring
point on the Cell 2 slimes drain access pipe.
1 January 27,2012 DUSA response letter on Failure to Meet Affirmative Defense Requirements on Cell 2 Slimes
Drain Recovery Elevation.
OENISOJ)JJ
MINES
Letter to Mr. Rusty Lundberg
February 29, 2012
Page 3
As we discussed with DRC on February 14, 2012, the elevation of the Cell 2 slimes drain access pipe of
5611.76 fmsl is a correct value representing the elevation prior to the addition in 2011 of the 6.97 foot
extension. All entries and calculations (for every period from 1/25/2008 through 12/19/2011) in the table
in Attachment 3 of Denison's January 17, 2012 letter using this value are correct.
The surveyed elevation of the slimes drain access pipe of 5618.73 fmsl used in Attachment 3 of
Denison's January 27, 2012 letter is a correct value, surveyed by a Utah-Licensed surveyor, after the
installation of the 6.97 foot extension to the slimes drain access pipe. The entry and calculations for
12/19/2011 in the table in Attachment 3 based on this value are also correct. The plots of slimes drain
elevation based on these values and measured depths to slimes drain solution, as provided in the DMT
reports to date, are also correct. As we agreed on February 14, 2012, since the elevations in fmsl are
correct, there is no need to further revise any of the table entries or the plots and, as the calculations
indicate, the Cell 2 slimes drain recovery is in compliance with Part I.D.3(b)(3) of the Groundwater
Discharge Permit.
As we discussed on February 14, 2012, the value of 5614.83 fmsl, which was identified in Denison's
January 27, 2012, letter is not a correct value. This entries and calculations in the table in Attachment 3
of the letter, and the data used to prepare the slimes drain elevation plots· in the DMT reports, were based
on the correct values discussed above, not on the incorrect value. Therefore, as we agreed on February
14, 2012, since the elevations used are correct, there is no need to further revise any of the table entries
or the plots.
As we discussed on February 14, 2012, all calculation are based on the subtraction of an actual surveyed
value in fmsl for the slimes drain access pipe elevation, and an actual measured depth to fluid for the
slimes drain solution, and are not based on relative elevations. The text in Section 3.1 b)(v) has been
revised to include a description of the process.
DRCComment
5. In Appendix F of the DMT Plan, additionally, the first bullet line should refer to Cell 48 instead of Cell
4A. Please make this correction.
Denison Response:
The text has been changed as requested.
DRCComment
6. The previous comment was, "Paragraph 6.2 needs to be revised due to the construction of Cell 48. It
needs to be corrected to refer to the current exterior dikes required to have movement monitoring."
However, DUSA's response that, "The text corrections have been made as requested," is incorrect, as no
changes were made.
It appears dikes 4A-E, 4A-S, and 48-S are the current dikes exposed exterior dikes subject to movement
monitoring. Please indicate such in this paragraph of the plan.
Denison Response:
The text has been changed as requested.
DRCComment
7. See Appendix A, page 28, Table III. Since the freeboard in Cell 1 is always exposed, and the water
level is often changing, all the dikes in Cell 1 become visible from time to time. Columns need to be
made available so inspection entries can be made for all the dikes of Cell 1.
Similarly, all the dikes of Cells 4A and 48 need to be included in the table.
Denison Response:
Per Denison's discussion with DRC on February 14, 2012, Denison understands the need to include in
the Daily Inspection Form a place to record observations from inspections of the interior walls of all four
OENISOJ)JJ
MINES
Letter to Mr. Rusty Lundberg
February 29,2012
Page 4
dikes of Cells 1, 4A, and 4B. Consistent with our discussion with DRC, Denison has revised Table II of
the Daily Inspection Form to include space for these observations. The title of Table II has been modified
to clarify that it addresses inspection of the interior conditions and issues at Cells 1, 4A, and 4B.
As we discussed, the contents of Table III, which addressed inspection of geotechnical components of
the exterior of visible dikes, have not been changed. The notes inside Table III have been edited to
clarify that the table addresses exterior dikes.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
~~dtAJ
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Ron F. Hochstein
Harold R. Roberts
David E. Turk
Kathy A. Weinel
Attachments
OENISOJ)J~
MINES
CLEAN
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND
DISCHARGE MINIMUMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
Revision 11.5
February 2012
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonl1.5
Page 2 of 55
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
Contents
1. IN"TRODUCTION ................................................................................................................... 4
2. DATI..-Y TATI..-IN"GS IN"SPECTIONS ....................................................................................... 4
2. i. Daily Comprehensive Tailings Inspection ....................................................................... 4
2.2. Daily Operations Inspection ............................................................................................. 7
2.3. Daily Operations Patrol .................................................................................................... 7
2.4. Training ............................................................................................................................ 7
2.5. Tailings Emergencies ....................................................................................................... 7
3. WEEKLY TATI..-IN"GS AND DMT IN"SPECTION ................................................................. 8
3.1. Weekly Tailings Inspections ............................................................................................ 8
Northing ................................................................................................................................ 13
Easting ................................................................................................................................... 13
3.2. Weekly Inspection of Solution Levels in Roberts Pond ................................................. 16
3.3. Weekly Feedstock Storage Area Inspections ................................................................. 16
4. MONTHLY T ATI..-IN"GS IN"SPECTION ............................................................................... 16
5. QUARTERLY TAILIN"GS IN"SPECTION ........................................................................... 17
6. ANNUAL EV ALUATIONS ................................................................................................. 18
6.1. Annual Technical Evaluation ......................................................................................... 18
6.2. Movement Monitors ....................................................................................................... 19
6.3. Freeboard Limits ............................................................................................................ 19
6.3.1. CellI ....................................................................................................................... 20
6.3.2. Cell 2 ....................................................................................................................... 20
6.3.3. Cell 3 ........................................................................................................................ 20
6.3.4. Cell 4A .................................................................................................................... 20
6.3.5. Cel14B .................................................................................................................... 21
6.3.6. Roberts Pond ........................................................................................................... 23
6.4. Annual Leak Detection Fluid Samples ........................................................................... 24
6.5. Annual Inspection of the Decontamination Pads ........................................................... 24
7. OTHER IN"SPECTIONS ....................................................................................................... 24
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonl1.5
Page 3 of 55
8. REPORTIN"G REQUIREMENTS ........................................................................................ 24
8.1. Monthly Tailings Reports ............................................................................................... 25
8.2. DMT Reports .................................................................................................................. 25
8.3. TAaIN"GS IN"SPECTOR TRAIN"IN"G ........................................................................... 42
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. INTRODUCTION
2112 Revision: Denisonll.5
Page 4 of 55
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAIL Y TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cell (Cell 1) and
thefour tailings cells (Cells 2, 3, 4A, and 4B) will be inspected. Observations will be made of the
current condition of each cell, noting any corrective action that needs to be taken.
The Radiation Safety Officer (RSO) or his designee is responsible for performing the daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, 4A and 4B, Dikes 4A-S, 4A-E, and 4B-
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 5 of 55
S ,wind movement of tailings, effectiveness of dust minimization methods, spray evaporation, Cell 2
spillway, Cell 3 spillway, Cell4A spillway, Cell 3, Cell4A and 4B liquid pools and associated liquid
return equipment, and cell leak detection systems.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell
4A or CeIl4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) Celll.
c) Cell 2.
d) Cell 3.
e) CeIl4A.
f) CeIl4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell 2 spillway, Cell 3 spillway, Cell4A spillway, Cell 3, Cell4A and Cell
4B liquid pools and associated liquid return equipment.
i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
j) Spray evaporation pumps and lines.
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
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Page 6 of 55
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
1) Observation of flow and operational status of the dust control/spray evaporation
system(s).
m) Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
4A, and4B.
n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
0) An estimate of flow for active tailings slurry and SX line(s).
p) An estimate of flow in the solution return line(s).
q) Daily measurements in the leak detection system sumps of the tailings cells will
be made when warranted by changes in the solution level of the respective leak
detection system.
The trigger for further action when evaluating the measurements in the CellI and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Ce1l4A or 4B leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Ce1l4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet ams!. For Ce1l4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
of the License Conditions.
2112 Revision: Denisonl1.5
Page 7 of 55
Items (a), (m), (n), and (0) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the RSO and/or Mill
management in the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to his/her duties as an inspector.
2.5. Tailings Emergencies
Inspectors will notify the RSO and/or Mill management immediately if, during their inspection, they
discover that an abnormal condition exists or an event has occurred that could cause a tailings
emergency. Until relieved by the Environmental or Technician or RSO, inspectors will have the
authority to direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO, one of whom will notify Corporate Management. If
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White Mesa Mill -Standard Operating Procedures
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Page 8 of 55
dam failure occurs, notify your supervisor and the Mill Manager immediately. The Mill Manager
will then notify Corporate Management, MSHA (303-231-5465), and the State of Utah, Division of
Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
~ach tailings cell's leak detection system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1 and Cell 3 the leak detection system is
measured by use of a dual-probe system that senses the presence of solutions in
the LDS system (comparable to the systems in Cells 4A and 4B) and indicates the
presence of solution with a warning light. The Ce1l4A and 4B leak detection
systems are monitored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector. The pressure
transducer is calibrated for fluid with a specific gravity of 1.0. The water levels
are measured every hour and the information is stored for later retrieval. The
water levels are measured to the nearest 0.10 inch. The data collector is currently
programmed to store 7 days of water level information. The number of days of
stored data can be increased beyond 7 days if needed. For Cells 1 and 3, the
water level data is recorded on the Daily Tailings Inspection Form. For Cells 4A
and 4B, the water level data is downloaded to a laptop computer periodically and
incorporated into the Mill's environmental monitoring data storage, and into the
files for weekly inspection reports of the tailings cell leak detection systems
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
For Cells 1 and 3, if fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed time
since fluid was last pumped or increases in the LDS fluid levels were recorded,
whichever is the more recent. This calculation shall be documented as part of the
weekly inspection.
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For Cells 1 and 3, upon the initial pumping of fluid from an LDS, a fluid sample
shall be collected and analyzed in accordance with paragraph 11.3 C. of the
Radioactive Materials License.
For Cell4A and 4B, under no circumstance shall fluid head in the leak
detection system sump exceed a I-foot level above the lowest point in the
lower flexible membrane liner. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and 4B leak detection systems, the total
volume of all fluids pumped from the LDS on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day. Under no circumstances shall
the daily LDS flow volume exceed 24,160 gallons/day for Cell4A or 26,145
gallons/day for CeIl4B. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table lA and
IB (for Cells 4A and 4B, respectively) in Appendix E, to determine the
maximum daily allowable LDS flow volume for varying head conditions in
Cell 4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) Denison re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of stormwater on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring .point which is a notch on the side of the
Cell 2 slimes drain access pipe .. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float
mechanism and water level probe system. When the water level reaches the level of
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the float mechanism the pump is activated. Pumping then occurs until the water level
reaches the lower probe which turns the pump off. The lower probe is located one
foot above the bottom of the slimes drain standpipe, and the float valve is located at
three feet above the bottom of the slimes drain standpipe. The average wastewater
head in the Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic
surface of tailings Cell 2, about 27 feet below the water level measuring point on the
slimes drain access pipe. As a result, there is a continuous flow of wastewater from
Cell 2 into the slimes drain collection system. Mill management considers that the
average allowable wastewater head in the Cell 2 slimes drain resulting from pumping
in this manner is satisfactory and is as low as reasonably achievable.
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. The extension of the Cell 2 slimes drain access pipe did
not require any changes to the measurement procedure. The surveyed measuring
point on the extended pipe is used as required. The elevation of the measuring point
is 5618.73 fmsl. The head measurements are calculated in the same manner, using
the same procedures as those used prior to the extension of the Cell 2 slimes drain
access pipe; however, the total depth to the bottom of the pipe is now 37.97 feet as
noted on the corrected form in Attachment A.
All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot.
The results will be recorded as depth-in-pipe measurements on the Weekly Tailings
Inspection Form. The equation specified in the GWDP will be used to calculate the
slimes drain recovery elevation (SDRE). To calculate the SDRE contemplated by the
GWDP, the depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will
be subtracted from the surveyed elevation of the measuring point. The calculation is
as follows:
5618.73 -Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
It is important to note that the extension of the Cell 2 slimes access pipe has not
changed the method of calculation of the pre-and post-pump head calculations, only
the constant (Cell 2 slimes drain access pipe height) used in the calculation has
changed. The head is calculated by subtracting the depth to liquid from 37.97 feet
rather than from the previous measurement of 38 feet. The weekly Tailings
Inspection form included in Attachment A has been changed to reflect the extension
height;
(vi)Effective July 11, 2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
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least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Cell4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell4B slimes drain will be
authorized once it is put into service and while it is active. Prior to initiation of
tailings dewatering operations for Cell 3, CeIl4A, or CeIl4B, a similar procedure
will be developed for ensuring that average head elevations in the Cell 3 and Cell4A
slimes drains are kept as low as reasonably achievable, and that the Cell 3, CeIl4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B and Roberts Pond are to be taken by
survey on a weekly basis. The beach area in Cell 4B with the maximum elevation is to be
taken by survey on a monthly basis when beaches are first observed, as follows:
(i) The 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 (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The Reference Points for Cells 1, Cell 4A, and 4B, and Roberts Pond are known
points established by professional survey. For Cell 1 and Roberts Pond, the
Reference Point is a wooden stake with a metal disk on it located on the southeast
corner of Cell 1. The elevation of the metal disk (the "Reference Point Elevation")
for CellI and Roberts Pond is at 5,623.14 feet above mean sea level ("FMSL"). For
Ce1l4A and 4B, the Reference Point is a piece of stamped metal monument located
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next to the transformer on the south side of Cell4A and 4B. The elevation at the top
of this piece of rebar (the Reference Point Elevation for Cell4A and 4B) is 5600.49
fmsl. The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell 1 and Roberts
Pond, this is typically on the road on the Cell 1 south dike between Cell 1 and
Roberts Pond, approximately 100 feet east of the Cell 11R0berts Pond Reference
Point. For Cell4A and CeIl4B, this is typically on the south side ofCell4A and 4B;
(iv)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;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell 11R0berts Pond Reference Point on the top of the rebar on the
Cell4A and 4B Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established a
level reading;
(vi) The Surveyor will focus the cross hairs of the Survey 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;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the CellI, Cell4A , CeIl4B, or
Roberts Pond, or the area of the beach in Cell4B with the highest elevation, as the
case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted as described above in items d) (i) through d)
(vii) of this Section consistent with current Mill health and safety procedures. The measurements
will be completed using survey equipment and the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Cell4A
The Assistant will walk down the slope in the northeast corner of Cell4A and
place the Survey Rod at the liquid level.
II. Cell4B
The Assistant will walk down the slope in the southeast corner of Cell 4 Band
place the Survey Rod at the liquid level.
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B.
ill. CellI
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
IV. Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northing Easting
Roberts Pond 323,041 2,579,697
CellI 322,196 2,579,277
Cell4A 320,300 2,579,360
Cell4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Cell 4 B Beach Elevation
Beach elevations in Cell4B will commence when beaches are first observed.The
Assistant will place the Survey Rod at the point on the beach area of Cell4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
. (viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface. 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;
(ix)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
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represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
c. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any of the three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
shall indicate a leak in the primary containment.
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E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediatel y prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. IT there are any cracks greater than
118 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontamination Pad will be inspected on a weekly
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the current
condition of the . Existing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. IT there are any cracks greater than 118 inch
separation (width), the RSO must be contacted. The RSO will have
the responsibility to cease activities and have the cracks repaired.
f) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3.2. Weekly Inspection of Solution Levels in Roberts Pond
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On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be visually inspected at key
locations to determine pipe wear. The critical points of the pipe include bends, slope
changes, valves, and junctions, which are critical to dike stability. These locations to
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be monitored will be determined by the Radiation Safety Officer or his designee from
the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) Overspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overs pray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
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White Mesa Mill-Standard Operating Procedures
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Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
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The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) OperationslM aintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
d) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
e) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
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All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Executive Secretary.
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 4A-
E, 4A-S, and 4B-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the CellI pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
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0.90 feet.
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The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.
The flood volume from the PMP event over the Cell4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell 4A is 40 acres, and in Cell4B is 40
acres. The top of the flexible membrane liner ("FML") for CellI is 5,618.2 FMSL, for Cell4A
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. CellI
The freeboard limit for CellI will be set at 5,615.4 FMSL. This will allow CellI to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 feet equals 2.85 feet. The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell4A (and/or any future tailings cells).
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell4A will be attributed to CeIl4B. A spillway has been added to Cell4A to allow overflow into
Ce1l4B.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
6.3.5. Ce1l4B
2112 Revision: Denisonl1.5
Page 21 of 55
The freeboard limit for Ce1l4B will be set assuming that the total PMP volume for Cells 2,3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Ce1l4B is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell 4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Ce1l4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Ce1l4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
Depth to store PMP an overflow volume
= 197.5 acre-feet/40 acres
Wave run up factor
Total required freeboard
38.1 acre-feet
159.4 acre-feet
197.5 acre-feet
4.9 feet
0.77 feet
5.7 feet
( all values in the above calculation have been rounded to the nearest one-tenth of afoot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation of the beach area in Ce1l4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in /Gell-4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder of the ensuing year (period t=O) (until the next November 1) will be
calculated when that elevation is first exceeded (the "Initial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the 'Initial Calculation Date ("To") will be determined;
ii) The expected number of dry tons to be deposited into Cell 4 B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("~o*"), will be determined;
iii) ~o* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denison11.5
Page 22 of 55
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4B will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell4B
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1 -(~o* x 1.5) / (2,094,000 -To)) x 40 acres = RPAo
vii) The required freeboard for Cell 4B for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the
quotient of 197.5 acre feet divided by the RPAo. The freeboard limit for Cell4B for
the remainder of period t=O would then be the elevation of the FML for Cell4B of
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARPAt-1)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-l).
The RPAt-1 used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt-1 is merely the RPA that would have
been used for period t -1 had the actual tonnages for year t -1 been known at the outset
of period t -1 and had the RP A been calculated based on the actual tonnages for period
t -1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARP At-1 can be calculated using the following formula:
(1 -~t-l / (2,094,000 - Tt-1)) X ARPAt-2 = ARPAt-1
Where:
• ~t-l is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t-l;
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 23 of 55
• Tt-1 is the actual number of dry tons of tailings solids historically deposited in
Cell 4 B prior to the beginning of period t -1; and
• ARPAt-2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARPAt-2 is 40 acres;
ii) Once the ARPAt-1 for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1-(~t* x 1.5) / (2,094,000 - Tt)) x ARPAt-1 = RPAt
Where:
• ~t* is the expected number of dry tons of tailings to be deposited into Cell4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Tt is the actual number of dry tons of tailings solids historically deposited in
Cell 4 B prior to the beginning of period t; and
• ARPAt-1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t -1) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave run up
factor for Cell4B of 0.77 feet plus the quotient of 197.5 acre feet divided by the RP At.
The freeboard limit for Cell 4 B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist until the next Annual Calculation
Date for period t + 1.
An example of this calculation is set out in Appendix F.
(e) When a Spillway is Added to Cell4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Cell4B and a new tailings cell then, if an approved freeboard
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2,3, 4A, 4B
and the new tailings cell, the freeboard limit for Cell4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
6.3.6. Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0 feet above mean sea
level, as specified in the GWDP.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
6.4. Annual Leak Detection Fluid Samples
2112 Revision: Denison 11.5
Page 24 of 55
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C.· The results of the analysis will be reviewed to determine the origin of the
solution.
6.5. Annual Inspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 118 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad Inspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility. All inspection findings and any repairs required shall be documented on the Annual
Decontamination Pad Inspection form. A record of the repairs will be maintained as a part of the
Annual Inspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3,4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/12 Revision: Denisonl1.5
Page 25 of 55
In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2, 3,4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports of DMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required information required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring), 3.2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3.3
(Weekly Feedstock Storage Area Inspections);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 6.5(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September 1 of
each calendar year;
d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection findings, any repairs required, and
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denison 11.5
Page 26 of 55
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; and
e) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
FORMS
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2/12 Revision: Denisonll.5
Page 27 of 55
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/12 Revision: Denisonl1.5
Page 28 of 55
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
Inspection Items Conditions of Potential Concern CellI
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point( s) of Discharge Improper Location or Orientation
II. OPERATIONAL SYSTEMS and INTERIOR of CELLS
Inspection Items Conditions of Potential Concern CellI
N S E W
Interior Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
Beach Cracks, Severe Erosion, Subsidence
Liner and Cover Erosion of cover, Exposure of Liner
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Cell 2
Cell 2
Inspector: _______ _
Date; ________ _
Accompanied by: ___ _
Time: ________ _
Cell 3 Cell4A Cell4B
Cell 3 Cell4A Cell4B
N S E W N S E W
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
III. DIKES AND EMBANKMENTS
Ins12ection Items Conditions of Potential
Concern
Slopes Sloughs or Sliding Cracks,
Bulges, Subsidence, Severe
Erosion, Moist Areas, Areas
of Seepage Outbreak
Crest Cracks, Subsidence, Severe
" Erosion
-_._------------_ .. - ---------------------
IV. FLOW RATES
Dike 1-1
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
I
2112 Revision: Denisonl1.5
Page 29 of 55
Dike 1-Dike 2 Dike 3
lA
No No No
visible visible visible
exterior exterior exterior
slope or slope or slope or
dike to dike to dike to
inspect inspect inspect
No No No
visible visible visible
exterior exterior exterior
slope or slope or slope or
dike to dike to dike to
inspect inspect inspect
Dike
4A-S
Slurry Line( s) Pond Return S-X Tails
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VI. DUST CONTROL
Dusting
Wind Movement of Tailings
Precipitation: inches liquid
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Yes ------
Yes ------
Cell 2 Cell 3
Dike Dike
4A-E 4B-S
Sorav SYstem
______ No
______ No
Ce1l4A Ce1l4B
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
I General Meteorological conditions: __ _
VII. DAILY LEAK DETECTION CHECK I I
CellI Cell 2
Leak Checked Checked
Detection
System Wet Dry Wet Dry
Checked
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
2/12 Revision: Denisonll.5
Page 30 of 55
Cell 3 Cell4A
Checked Checked
Wet Dry Wet Dry
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
Cell4B
Checked
Wet Dry
Initial level
Final
level
Gal. pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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· White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
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2112 Revision: Denisonll.5
Page 31 of 55
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
~o .2J ::..i
-h A.'. Ii-~ 0-~ 0 III I "-
2/12 Revision: Denison11.5
Page 32 of 55
:z '.
o I!Ii ..a:.. "-I OJ
D f1J r-
,~
I .0 ·
i c."
.( ~~ e
,.:f,/;; .. ", .. , ~ '.~,~f'" ~'~~~''"-
-.' ...... ,:..:~ ~ "
~ ,....'"'(!
·""--";~,~".,o; .. :2: ,..
N:\DMT Plan\DMT Plan 02.29.12 Rev 11.5\DMT Plan February 2012 Rev 11.5 clean.doc
.~ -;-
, ...... .....
o m r-r-
~
I'.:J
J._
I J ;.." i ~~x ,:J ,., ~ i~'i
I ~, ~ ~
f ~
0 , rn F z
:P '
' ........ ,
!)l'K:e 1"~I~-t' -_ .. ,,"'-'--"--... ,,"
,..
i
.~
.",
"'-..... .,~ """''''
"-' .... "'--""
j
:~~ ~ ~ ...... -. -,-=~ =-....... rJQ OQ 'if,: 00
~O .,.-Q.) =. :::.: ~ .~
'--. t--f it::' := ...... ' ... U~ V.: __
&~ QJ 11'""1" -. -. UQ 9 ("tI i-'
.~~ o 0 (')'"0
~~ o .. ~
~
-!'"~~'---''' ---~'--~----...
I
:3: .-:F
ICJ)
,iiiiiiiiiiiiiii -t 'm I ~ • t
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denison 1 1.5
Page 33 of 55
Date: _______ _
1. Pond and Beach
elevations (msl, ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKL Y TAILINGS INSPECTION
Inspectors: ____________ _
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation 5597 __ _
(c) Depth of Water above FML ((a)-(b» _____ _
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5555.14_
(c)Depth of Water above FML ((a)-(b» _____ _
Cell 4B: (a)Pond Solution Elevation
Roberts
(b)FML Bottom Elevation 5557.50
(c )Depth of Water above FML ((a)-(b» _____ _
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b )FML Bottom Elevation __ 5612.3
(c )Depth of Water above FML (( a)-(b» _____ _
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly ___ _
_______ Depth to Liquid pre-pump
_______ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97' -Depth to Liquid Pre-
pump= __ _
Post-pump head is 37.97'-Depth to Liquid Post-
pump= __ _
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
2112 Revision: Denison 11.5
Page 34 of 55
(Same data as Daily Inspection Form. Record data on daily form).
Observation:
New Decon Pad2 New Decon Pad2 New Decon Pad
Portal 1 Portal 2 Portal 3
Is LDS (Portal) __ wet __ dry __ wet __ dry __ wet __ dry
wet or dry?
If wet, Record Ftto Ft to Ft to
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented: ______________________ _
6. Remarks: __________________________________ _
7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevatio~ of 5556.14 amsl for Ce1l4A and 5558.50 for Ce1l4B)? no __ yes
If Ce1l4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denison11.5
Page 35 of 55
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector: __________________________ _
Date: __________________ ~----------
1. Slurry Pipeline:
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Diversion Ditch 1
__ yes __ no
__ yes __ no
__ yes __ no
Obstruction of Flow __ yes __ no
Diversion Benn:
Stability Issues
Signs of Distress
Diversion Ditch 2 Diversion Ditch 3
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
Diversion Benn 2
__ yes __ no
__ yes __ no
Comments: ________________________________________ ~ ____________________________ _
3. Summary of Activities Around Sedimentation Pond: _______________________________ _
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: ___ yes ___ no
2112 Revision: Denisonl1.5
Page 36 of 55
Overspray carried more than 50 feet from the cell: __ yes no
If "yes", was system immediately shut off? __ yes __ no
Comments: ________________________________ _
5. Remarks: _______________________________ _
6. Settlement Monitors
Cell 2 WI: CeIl2W3-S: CeIl3-IN: ____ _
Cell 2 W2: CeIl2EI-N: ____ _ CeIl3-IC: ____ _
Cell 2 W3: CeIl2EI-lS: ____ _ CeIl3-IS: ____ _
Cell 2 W4: CeIl2EI-2S: ____ _ Cell 3-2N: ____ _
CeIl2W7-C: ____ _ Cell 2 East: Cell 2W5-N: ____ _
Cell 2 W7N: ____ _ Cell 2 W7S: Cell 2 W6N: ___ _
Cell 2 W6C: Cell 2 W6S: ____ _ Cell 2 W4N: ___ _
CeIl4A-Toe: ____ _ CeIl2W4S: ____ _ Cell 2 W5C: ___ _
Cell 3-2C: _____ _ CeIl3-2S: Cell 2 W5S: ____ _
CeIl3-3S: _____ _ Cell 3-3C; _____ _ CeIl3-3N: ____ _
CeIl3-4N: _____ _ CeIl3-6N: ____ _ CeIl3-7S: ____ _
CeIl3-7C: _____ _ CeIl3-7N: _____ _ Cell 3-8S: ____ _
CeIl3-8C: _____ _ CeIl3-8N: _--'--___ _
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections: ______________ _
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 38 of 55
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERL Y INSPECTION DATA
Inspector: ________________________ __
Date: ____________________________ ___
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities: ------------------------------------------
4. Estimated Areas:
Cell 3 Ce1l4A Ce1l4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
2112 Revision: Denisonll.5
Page 39 of 55
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ Date of Inspection: _______ _
Inspector: ___________ _
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: no: ___ _
comments: ___________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: no: __ _
comments (e.g., conditions of containers): _________________ _
Are all sumps and low lying areas free of standing solutions?
Yes: No: __ _
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free standing water or water running off of the feedstock stockpiles?
Yes: No: __ _
Comments: __________________________________ _
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Other comments:
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2112 Revision: Denisonll.5
Page 40 of 55
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
2112 Revision: Denison 11.5
Page 41 of 55
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection: _______ _
Inspector: __________ _
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 118 inch of separation? _ Yes _No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? __ Yes __ No
Findings:
Repair Work Required:
Note For the annual inspection of the both the ExistIng and New Decontamination Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2nd Quarter report, due September 1 of each
calendar year
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXB
8.3. TAILINGS INSPECTOR TRAINING
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Page 42 of 55
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
. inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
inspected for damage and loss of support. Valves are also to be inspected particularly for
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denison 11.5
Page 43 of 55
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3. Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 4A-S, 4A-E, and 4B-S, , should be inspected closely
for mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Flow Rates:
2112 Revision: Denison 11.5
Page 44 of 55
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by Environmental, Health and Safety personnel as close to 8 :00
a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
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Page 45 of 55
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Cell4A and 4B dike) is 15 mph. These limits should not
be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. W aterfow I seen near the tailings cells should be discouraged from landing
. by the use of noisemakers.
11. Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 46 of 55
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXC
CERTIFICATION FORM
Date: ______________________ __
Name: ------------------------
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Page 47 of 55
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXD
FEEDSTOCK STORAGE AREA
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
N
I
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXE
TABLES
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell4A White mesa Mill
Blanding, Utah
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Page 51 of 55
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day)
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4B White mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
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2112 Revision: Denisonl1.5
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Assumptions and Factors:
APPENDIXF
Example of Freeboard Calculations
For Ce1l4B
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Page 53 of 55
o Total PMP volume to be stored in Cell4B -159.4 acre feet
o Wave runup factor for Cell4B -0.77 feet
o Total capacity of Cell4B -2,094,000 dry tons
o Elevation of FML of Cell 4B -5,600.35 FMSL
o Maximum pool surface area of Cell 4 B -40 acres
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL -1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL -March 1,2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Actual Tailings
Tailings Solids Tailings Solids
Disposition into Solids Disposition into
Cell 4B Dispositio Cell 4B
Determined at n into Cell determined at
the beginning of 4B at the end of the
the period (dry beginning period (dry
tons)* of the tons)*
period,
multiplied
by 150%
Safety
Factor
(dry tons)
March 1, 2012 150,000 225,000 225,000
to November 1,
2012
November 1, 300,000 450,000 275,000
2012 to
November 1,
2013
November 1, 200,000 300,000 250,000
2013 to
November 1,
2014
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2112 Revision: Denisonll.5
Page 54 of 55
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors, the freeboard limits for Cell4B would be calculated
as follows:
1. Prior to March 1,2012
Prior to March 1, 2012, the maximum elevation of the beach area in Cell 4 B is less than or
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1,2012 to November 1,2012
The pool surface area would be reduced to the following amount
(1 -225,0001 (2,094,000 -1,000,000)) x 40 acres = 31.77 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave run up factor for Cell4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1,2012 to November 1,2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of 225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1-450,0001 (2,094,000-1,000,000 -225,000)) x 31.77 acres = 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factor for Cell4B of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1,2012, and this freeboard limit would persist until.November 1, 2013.
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. November 1, 2013 to November 1, 2014
The pool surface area would be reduced to the following amount:
2112 Revision: Denison 11.5
Page 55 of 55
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1-275,0001 (2,094,000 -1,000,000 -225,000) x 31.77 acres = 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1,2013.
Then, calculate the modeled pool surface area to be used for the period:
(1-300,0001 (2,094,000 -1,000,000 -225,000 -275,000)) x 21.72 acres =
10.75 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave run up factor for Cell4B of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1,2014.
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REDLINE
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND
DISCHARGE MINIMUMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
Revision 11.5
February 2012
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
H I12 Revision: Denison 11.4~
Page 2 of 55
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
TABLE OF CONTENTS
Contents
1. rnTRODUCTION ................................................................................................................. ~
2. DAILY T AILrnGS rnSPECTIONS ..................................................................................... ~
2.1. Daily Comprehensive Tailings Inspection ..................................................................... ~
2.2. Daily Operations Inspection ........................................................................................... 16
2.3. Daily Operations Patrol .................................................................................................. 16
2.4. Training .......................................................................................................................... 16
2.5. Tailings Emergencies ..................................................................................................... 16
3. WEEKLY T AILrnGS AND DMT rnSPECTION ............................................................... ~+
3.1. Weekly Tailings Inspections ................................................................ ; ......................... ~+
Northing ............................................................................................................................ 13~
Easting ............................................................................................................................... 13~
3.2. Weekly Inspection of Solution Levels in Roberts Pond ............................................. 1~
3.3. Weekly Feedstock Storage Area Inspections ............................................................. 1~
4. MONTHLY TAILrnGS rnSPECTION ........................................................................... 1~
5. QUARTERLY TAILrnGS rnSPECTION ....................................................................... 17-+6
6. ANNUAL EVALUATIONS ............................................................................................. 18H
6.1. Annual Technical Evaluation ..................................................................................... 18H
6.2. Movement Monitors ................................................................................................... 19+8
6.3. Freeboard Limits ........................................................................................................ 19+8
6.3.1. CellI ................................................................................................................... 20l9
6.3.2. Cell 2 ................................................................................................................... 2019
6.3.3. Cell 3 ................................................................................................................... 2019
6.3.4. CeIl4A ................................................................................................................ 2019
6.3.5. Cell 4B ................................................................................................................ 21W
6.3.6. Roberts Pond ....................................................................................................... 23~
6.4. Annual Leak Detection Fluid Samples ....................................................................... 2~
6.5. Annual Inspection of the Decontamination Pads ....................................................... 2~
7. OTHER rnSPECTIONS ................................................................................................... 2~
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Book 11: Environmental Protection Manual, Section 3.1
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Page 3 of 55
8. REPORTING REQUIREMENTS .................................................................................... 25B
8.1. Monthly Tailings Reports ........................................................................................... 25~
8.2. DMT Reports .............................................................................................................. 25~
8.3. TAILINGS INSPECTOR TRAINING ....................................................................... 424l-
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. INTRODUCTION
4-2112 Revision: Denison11.4J.
Page 4 of 55
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioacti ve Materials License"), as well as procedures for operating and maintenance of monitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAIL Y TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1. Daily Comprehensive Tailings Inspection
On a daily basis, including weekends, all areas connected with the evaporation cell (Cell 1) and
thefour tailings cells (Cells 2, 3, 4A, and 4B) will be inspected. Observations will be made of the
current condition of each cell, noting any corrective action that needs to be taken.
The Radiation Safety Officer (RSO) or his designee is responsible for performing the daily tailings
inspections. The RSO may designate other individuals with training, as described in Section 2.4
below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A). The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1, 2, 3, 4A and 4B, Dikes 4A-S, 4A-E, and 4B-
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Book 11: Environmental Protection Manual, Section 3.1
+.2/12 Revision: Denisonl1.4,5.
Page 5 of 55
S, wind movement of tailings, effectiveness of dust minimization methods, spray evaporation, Cell 2
spillway, Cell 3 spillway, Cell4A spillway, Cell 3, Cell4A and 4B liquid pools and associated liquid
return equipment, and cell leak detection systems.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell
4A or CeIl4B; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
b) CellI.
c) Cell 2.
d) Cell 3.
e) CeIl4A.
f) Ce1l4B.
g) Dike structures including dikes 4A-S, 4A-E, and 4B-S.
h) The Cell 2 spillway, Cell 3 spillway, Cell4A spillway, Cell 3, Cell4A and Cell
4B liquid pools and associated liquid return equipment.
i) Presence of wildlife and/or domesticated animals in the tailings area, including
waterfowl and burrowing animal habitations.
j) Spray evaporation pumps and lines.
k) Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: 1) areas of tailings subject to blowing and/or wind movement, 2)
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+2112 Revision: Denisonl1.4.J.
Page 6 of 55
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization activities.
1) Observation of flow and operational status of the dust control/spray evaporation
system(s).
m) Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
4A, and4B.
n) Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
0) An estimate of flow for active tailings slurry and SX line(s).
p) An estimate of flow in the solution return line(s).
q) Daily measurements in the leak detection system sumps ofthe tailings cells will
be made when warranted by changes in the solution level of the respective leak
detection system.
The trigger for further action when evaluating the measurements in the CellI and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell 4A or 4B leak detection system is not allowed to be more
than 1.0 foot above the lowest point on the bottom flexible membrane liner
(FML) (Cell4A FML elevation is 5555.14 amsl and with the addition of the 1.0
foot of solution the solution elevation is 5556.14 feet ams!. For Cell4B the FML
elevation is 5557.50 amsl and with the addition of the 1.0 foot of solution the
solution elevation is 5558.50 feet amsl). If any of these observations are made,
the Mill Manager should be notified immediately and the leak detection system
pump started. In addition, the requirement to notify the Executive Secretary in
accordance with Parts I.D.6 and I.G.3 of the Groundwater Discharge Permit must
be adhered to when the solution level trigger for Cell 4A or 4B has been
exceeded.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Data form. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
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of the License Conditions.
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Page 7 of 55
Items (a), (m), (n), and (0) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the RSO and/or Mill
management in the event that during their inspection they discover that an abnormal condition or
tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
indi vidual, after reviewing the training pack, will sign a certification form, indicating that training
has been received relative to hislher duties as an inspector.
2.5. Tailings Emergencies
Inspectors will notify the RSO and/or Mill management immediately if, during their inspection, they
discover that an abnormal condition exists or an event has occurred that could cause a tailings
emergency. Until relieved by the Environmental or Technician or RSO, inspectors will have the
authority to direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the RSO, one of whom will notify Corporate Management. If
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Book 11: Environmental Protection Manual, Section 3.1
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dam failure occurs, notify your supervisor and the Mill Manager immediately. The Mill Manager
will then notify Corporate Management, MSHA (303-231-5465), and the State of Utah, Division of
Dam Safety (801-538-7200).
3. WEEKL Y TAILINGS AND DMT INSPECTION
3.1. Weekly Tailings Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly (as well as
daily) to determine whether it is wet or dry. If marked wet, the liquid levels need
to be measured and reported. In Cell 1 and Cell 3 the leak detection system is
measured by use of a dual-probe system that senses the presence of solutions in
the LDS system (comparable to the systems in Cells 4A and 4 B) and indicates the
presence of solution with a warning light. The Cell 4A and 4B leak detection
systems are monitored on a continuous basis by use of a pressure transducer that
feeds water level information to an electronic data collector. The pressure
transducer is calibrated for fluid with a specific gravity of 1.0. The water levels
are measured every hour and the information is stored for later retrieval. The
water levels are measured to the nearest 0.10 inch. The data collector is currently
programmed to store 7 days of water level information. The number of days of
stored data can be increased beyond 7 days if needed. For Cells 1 and 3, the
water level data is recorded on the Daily Tailings Inspection Form. For Cells 4A
and 4B, the water level data is downloaded to a laptop computer periodically and
incorporated into the Mill's environmental monitoring data storage, and into the
files for weekly inspection reports of the tailings cell leak detection systems
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDS shall be returned to a
disposal cell.
For Cells 1 and 3, if fluid is pumped from an LDS, the flow rate shall be
calculated by dividing the recorded volume of fluid recovered by the elapsed time
since fluid was last pumped or increases in the LDS fluid levels were recorded,
whichever is the more recent. This calculation shall be documented as part of the
weekly inspection.
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+Z112 Revision: Denison 11.42
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For Cells 1 and 3, upon the initial pumping of fluid from an LDS, a fluid sample
shall be collected and analyzed in accordance with paragraph 11.3 C. of the
Radioactive Materials License.
For Cell4A and 4B, under no circumstance shall fluid head in the leak
detection system sump exceed a I-foot level above the lowest point in the
lower flexible membrane liner. To determine the Maximum Allowable Daily
LDS Row Rates in the Cell 4A and 4B leak detection systems, the total
volume of all fluids pumped from the LDS on a weekly basis shall be
recovered from the data collector, and that information will be used to
calculate an average volume pumped per day. Under no circumstances shall
the daily LDS flow volume exceed 24,160 gallons/day for Cell4A or 26,145
gallons/day for CeIl4B. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table lA and
IB (for Cells 4A and 4B, respectively) in Appendix E, to determine the
maximum daily allowable LDS flow volume for varying head conditions in
Cell4A and 4B.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is nearly full and will commence closure when filled. Cell 2 is partially
reclaimed with the surface covered by platform fill. Each cell has a slimes drain
system which aids in dewatering the slimes and sands placed in the cell;
(ii) Denison re-graded the interim fill on Cell 2 in order to reduce the potential for the
accumulation of stormwater on the surface of Cell 2. As a result of the re-grading of
the interim cover and the placement of an additional 62,000 cubic yards of fill
material on Cell 2, the slimes drain access pipe was extended 6.97 feet. The
extension pipe is 6.97 feet in length, and therefore the new measuring point is 37.97
feet from the bottom of the slimes drain. The measuring point on the extension pipe
was surveyed by a Utah-Certified Land Surveyor. The measuring point elevation is
5618.73 fmsl. For the quarterly recovery test described in section vi below, this
extension has no effect on the data measurement procedures.
Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
37.97 feet below a water level measuring point which is a notch on the side of the
Cell 2 slimes drain access pipe.. This means that the bottom of the slimes drain pool
and the location of the pump are one foot above the lowest point of the FML in Cell
2, which, based on construction reports, is at a depth of 38.97 feet below the water
level measuring point on the slimes drain access pipe for Cell 2;
(iii) The slimes drain pump in Cell 2 is activated and deactivated by a float
mechanism and water level probe system. When the water level reaches the level of
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the float mechanism the pump is activated. Pumping then occurs until the water level
reaches the lower probe which turns the pump off. The lower probe is located one
foot above the bottom ofthe slimes drain standpipe, and the float valve is located at
three feet above the bottom of the slimes drain standpipe. The average wastewater
head in the Cell 2 slimes drain is therefore less than 3 feet and is below the phreatic
surface of tailings Cell 2, about 27 feet below the water level measuring point on the
slimes drain access pipe. As a result, there is a continuous flow of wastewater from
Cell 2 into the slimes drain collection system. Mill management considers that the
average allowable wastewater head in the Cell 2 slimes drain resulting from pumping
in this manner is satisfactory and is as low as reasonably achievable.
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the water level probe and float mechanism are working properly, which is noted
on the Weekly Tailings Inspection Form. If at any time the pump is observed to be
not working properly, it will be fixed or replaced within 15 days;
(v) Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. The extension of the Cell 2 slimes drain access pipe did
not require any changes to the measurement procedure. The surveyed measuring
point on the extended pipe is used as required. The elevation of the measuring point
is 5618.73 fmsL The head measurements are calculated in the same manner, using
the same procedures as those used prior to the extension of the Cell 2 slimes drain
access pipe; however, the total depth to the bottom of the pipe is now 37.97 feet as
noted on the corrected form in Attachment A.
All head measurements must be made from the same measuring point (the notch at
the north side of the access pipe 5618.73 fmsl), and made to the nearest 0.01 foot.
The results will be recorded as depth-in-pipe measurements on the Weekly Tailings
Inspection Form. The equation specified in the GWDP will be used to calculate the
slimes drain recovery elevation (SDRE). To calculate the SDRE contemplated by the
GWDP, the depth to wastewater in the Cell 2 slimes drain access pipe (in feet) will
be subtracted from the surveyed elevation of the measuring point. The calculation is
as follows:
5618.73 -Depth to wastewater in the Cell 2 slimes drain access pipe = SDRE
It is important to note that +lhe extension of the Cell 2 slimes access pipe has not
changed the method of calculation ofthe pre-and post-pump head calculations, only
the constant (Cell 2 slimes drain access pipe height) used in the calculation has
changed. The head is calculated by subtracting the depth to liquid from 37.97 feet
rather than from the previous measurement of 38 feet. The weekly Tailings
Inspection form included in Attachment A has been changed to reflect the extension
height;
(vi) Effective July 11,2011, on a quarterly basis, the slimes drain pump will be turned off
and the wastewater in the slimes drain access pipe will be allowed to stabilize for at
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least 90 hours. Once the water level has stabilized (based on no change in water level
for three (3) successive readings taken no less than one (1) hour apart) the water level
of the wastewater will be measured and recorded as a depth-in-pipe measurement on
Quarterly Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii) No process liquids shall be allowed to be discharged into Cell 2;
(viii) If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year, the
Licensee will comply with the requirements ofPartl.G.3 oftheGWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix) Because Cell 3 and Cell4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. No pumping from the Cell4B slimes drain will be
authorized once it is put into service and while it is active. Prior to initiation of
tailings dewatering operations for Cell 3, Cell 4A, or Cell 4B, a similar procedure
will be developed for ensuring that average head elevations in the Cell 3 and Cell4A
slimes drains are kept as low as reasonably achievable, and that the Cell 3, CeIl4A,
and Cell 4 slimes drains are inspected and the results reported in accordance with the
requirements of the permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells 1, 4A, and 4B and Roberts Pond are to be taken by·-- --{ Formatted: Justified ~------------------------~ survey on a weekly basis. The beach area in Cell 4B with the maximum elevation is to be
taken by survey on a monthly basis when beaches are first observed, as follows:
(i) The 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 (the "Survey fustrument")
accurate to 0.01 feet, such as a Sokkai No. B21, or equivalent, together with a survey
rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The Reference Points for Cells 1, Cell 4A, and 4B, and Roberts Pond are known
points established by professional survey. For Cell 1 and Roberts Pond, the
Reference Point is a wooden stake with a metal disk on it located on the southeast
comer of Cell 1. The elevation of the metal disk (the "Reference Point Elevation")
for CellI and Roberts Pond is at 5,623.14 feet above mean sea level ("FMSL"). For
Cell4A and 4B, the Reference Point is a piece of stamped metal monument located
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next to the transformer on the south side of Ce1l4A and 4B. The elevation at the top
of this piece of rebar (the Reference Point Elevation for Ce1l4A and 4B) is 5600.49
fmsl. The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell I south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell IIRoberts Pond Reference
Point. For Ce1l4A and Ce1l4B, this is typically on the south side ofCe1l4A and 4B;
(iv)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;
(v) The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell IIRoberts Pond Reference Point on the top of the rebar on the
Ce1l4A and 4B Reference Point. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established a
level reading;
(vi) The Surveyor will focus the cross hairs of the Survey 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;
(vii) The Assistant will then move to a designated location where the Survey Rod can be
placed on the surface of the main solution pond in the CellI, Ce1l4A , Ce1l4B, or
Roberts Pond, or the area of the beach in Ce1l4B with the highest elevation, as the
case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
For a newly-constructed cell, when the cell is first placed into operation, the solution level is
typically zero feet above the FML or a minimal elevation above the FML due to natural precipitation.
-For newly-constructed cells, measurement of solution level will commence within 30 days of
authorization for use. Measurements will be conducted eonsistent ","ith the flfoeeEffires as described
above in items d) (0 through d) (vii) of this Section in this DMT Plan anEl consistent with current
Mill health and safety procedures. The measurements will be completed using survey equipment and
the appropriate length survey rod (either 25' or 45').
A. Pond Surface Measurements
I. Ce1l4A
The Assistant will walk down the slope in the northeast comer of Cell 4A and
place the Survey Rod at the liquid level.
II. Ce1l4B
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B.
The Assistant will walk down the slope in the southeast comer of Cell4B and
place the Survey Rod at the liquid level.
III. CellI
A mark has been painted on the north side of the ramp going to the pump
platform in CellI. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
IV. Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
Northing Eastin~
Roberts Pond 323,041 2,579,697
CellI 322,196 2,579,277
Cell4A 320,300 2,579,360
Cell4B 320,690 2,576,200
These coordinate locations may vary somewhat depending on solution elevations
in the Pond and Cells;
Cell4B Beach Elevation
Beach elevations in Cell4B will commence when beaches are first observed.The
Assistant will place the Survey Rod at the point on the beach area of Cell4B that
has the highest elevation. If it is not clear which area of the beach has the highest
elevation, then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell4B beach area with the highest
elevation has been surveyed. If it is clear that all points on the Cell 4B beach area
are below 5,593 FMSL, then the Surveyor may rely on one survey point;
(viii) The Assistant will hold the Survey Rod vertically with one end of the Survey
Rod just touching the pond surface. 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;
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(ix)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Decontamination Pads
(i) New Decontamination Pad
The New Decontamination Pad is located in the southeast comer of the ore
pad, near the Mill's scale house.
A. In order to ensure that the primary containment of the New
Decontamination Pad water collection system has not been
compromised, and to provide an inspection capability to detect
leakage from the primary containment, vertical inspection portals
have been installed between the primary and secondary containments;
B. These portals will be visually observed on a weekly basis as a means
of detecting any leakage from the primary containment into the void
between the primary and secondary containment. The depth to water
in each portal will be measured weekly, by physically measuring the
depth to water with an electrical sounding tape/device. All
measurements must be made from the same measuring point and be
made to the nearest 0.01 foot;
C. These inspections will be recorded on the Weekly Tailings Inspection
form;
D. The water level shall not exceed 0.10 foot above the concrete floor in
any standpipe, at any time. This will be determined by subtracting the
weekly depth to water measurement from the distance from the
measuring point in the standpipe to the dry concrete floor The depth
to water from the top (elevation 5589.8 feet amsl) of any ofthe three
(3) observation ports to the standing water shall be no less than 6.2
feet. Depths less than 6.2 feet shall indicate more that 0.1 foot of
standing water above the concrete floor (elev. 5583.5 feet amsl), and
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shall indicate a leak in the primary containment.
E. Any observation of fluid between the primary and secondary
containments will be reported to the Radiation Safety Officer (RSO).
F. In addition to inspection of the water levels in the standpipes, the
New Decontamination Pad, including the concrete integrity of the
exposed surfaces of the pad, will be inspected on a weekly basis. Any
soil and debris will be removed from the New Decontamination Pad
immediately prior to inspection of the concrete wash pad for cracking.
Observations will be made of the current condition of the New
Decontamination Pad. Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection form. If there are any cracks greater than
118 inch separation (width), the RSO must be contacted. The RSO
will have the responsibility to cease activities and have the cracks
repaired.
(ii) Existing Decontamination Pad
The Existing Decontamination Pad is located between the northwest comer of the
Mill's maintenance shop and the ore feeding grizzly.
A. The Existing Decontamination Pad will be inspected on a weekly
basis. Any soil and debris will be removed from the Existing
Decontamination Pad immediately prior to inspection of the concrete
wash pad for cracking Observations will be made of the current
condition of the Existing Decontamination Pad, including the
concrete integrity of the exposed surfaces of the pad. Any
abnormalities relating to the pad and any damage or cracks on the
concrete wash surface of the pad will be noted on the Weekly
Tailings Inspection form. If there are any cracks greater than 118 inch
separation (width), the RSO must be contacted. The RSO will have
the responsibility to cease activities and have the cracks repaired.
f) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection
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form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below theFML
for that area, the pond will be recorded as being dry. .
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D;
b) a 4 ft. buffer is maintained at the periphery of the storage area which is absent bulk material
in order to assure that the materials do not encroach upon the boundary of the storage area;
and
c) all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHL Y TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be visually inspected at key
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locations to determine pipe wear. The critical points ofthe pipe include bends, slope
changes, valves, and junctions, which are critical to dike stability. These locations to
be monitored will be determined by the Radiation Safety Officer or his designee from
the Radiation Safety Department during the Mill run.
b) Diversion Ditches
Diversion ditches 1, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 should be checked
for stability and signs of distress.
c) Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
d) Overspray Dust Minimization
The inspection shall include an evaluation of overs pray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overs pray is carried more than 50 feet from the cell, the overs pray system should
be immediately shut-off.
e) Remarks
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f) Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
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Book 11: Environmental Protection Manual, Section 3.1
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Page 18 of 55
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
b) Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
d) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3, 4A and 4B.
e) Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year. The Technical
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Book 11: Environmental Protection Manual, Section 3.1
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Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsidence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year. During the
annual inspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by November 15th of every year to the
Executive Secretary.
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes ~
4A 'ill, aad 4A S 4A-E, 4A-S, and 4B-S to detect any possible settlement or movement of the dikes.
The data generated from this survey is reviewed and incorporated into the Annual Technical
Evaluation Report of the tailings management system.
6.3. Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP) event, which was determined in the January 10, 1990 Drainage
Report (the "Drainage Report") for the White Mesa site to be 10 inches.
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White Mesa Mill-Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
+2112 Revision: Denisonl1.4,2
Page 20 of 55
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water, with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas, plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres, plus the adjacent drainage area of 3.25 acres), times
the PMP of 10 inches), with a wave run up factor of 0.77 feet.
The flood volume from the PMP event over the Cell4B area has been calculated to be 38.1 acre-
feet of water (40 acres, plus the adjacent drainage area of 5.72 acres), times the PMP of 10
inches, with a wave run up factor of 0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres, in Cell4A is 40 acres, and in Cell4B is 40
acres. The top of the flexible membrane liner ("FML") for CellI is 5,618.2 FMSL, for Cell4A
is 5,598.5 FMSL and for Cell 4B is 5600.4 FMSL.
Based on the foregoing, the freeboard limits for the Mill's tailings cells will be set as follows:
6.3.1. CellI
The freeboard limit for CellI will be set at 5,615.4 FMSL. This will allow CellI to capture all of
the PMP volume associated with Cell 1. The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet, plus the wave run up factor of 0.90 feet equals 2.85 feet. The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL. Under Radioactive
Materials License condition 10.3, this freeboard limit is set and is not recalculated annually.
6.3.2. Cell 2
The freeboard limit for Cell 2 is inapplicable, since Cell 2 is filled with solids. All of the PMP
volume associated with Cell 2 will be attributed to Cell4A (and/or any future tailings cells).
6.3.3. Cell 3
The freeboard limit for Cell 3 is inapplicable, since Cell 3 is close to being filled with solids, and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4B (and/or any future
tailings cells).
6.3.4. Cell 4A
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Book 11: Environmental Protection Manual, Section 3.1
+2/12 Revision: Denisonl1.4~
Page 21 of 55
The freeboard limit for Cell 4A is inapplicable since all of the PMP flood volume associated with
Cell4A will be attributed to Ce1l4B. A spillway has been added to Cell4A to allow overflow into
Ce1l4B.
6.3.5.
The freeboard limit for Cell4B will be set assuming that the total PMP volume for Cells 2, 3, 4A,
and 4B of 159.4 acre feet will be accommodated in Cell 4B. The procedure for calculating the
freeboard limit for Cell4B is as follows:
(a) When the Pool Surface Area is 40 Acres
When the pool surface area in Cell4B is 40 acres (i.e., when there are no beaches), the freeboard
limit for Cell4B will be 5,594.6FMSL, which is 5.7 feet below the FML. This freeboard value was
developed as follows:
PMP Flood Volume
Overflow from Cell 4A assuming no storage in Cell 3 or 4A
Sum of PMP volume and overflow volume
Depth to store PMP an overflow volume
= 197.5 acre-feetl40 acres
Wave run up factor
Total required freeboard
38.1 acre-feet
159.4 acre-feet
197.5 acre-feet
4.9 feet
0.77 feet
5.7 feet
(all values in the above calculation have been rounded to the nearest one-tenth of afoot);
(b) When the Maximum Elevation of the Beach Area is 5,594 FMSL or Less
When the maximum elevation of the beach area in Ce1l4B is 5594 FMSL or less, then the freeboard
limit will be 5,594.6 FMSL, which is the same as in (a) above. This allows for the situation where
there may be beaches, but these beaches are at a lower elevation than the freeboard limit established
in (a) above, and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume. The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c) When the Maximum Elevation of the Beach Area First Exceeds 5,594 FMSL
When the maximum elevation of the beach area in Cell 4B first exceeds 5,594 FMSL, then the
freeboard limit for the remainder ofthe ensuing year (period t=O) (until the next November 1) will be
calculated when that elevation is first exceeded (the "Initial Calculation Date"), as follows:
i) The total number of dry tons of tailings that have historically been deposited into Cell
4B prior to the ~itial Calculation Date ("To") will be determined;
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Book 11: Environmental Protection Manual, Section 3.1
+2112 Revision: Denisonl1.4~
Page 22 of 55
ii) The expected number of dry tons to be deposited into Cell4B for the remainder of the
ensuing year (up to the next November 1), based on production estimates for that
period ("L10*"), will be determined;
iii) L10* will be grossed up by a safety factor of 150% to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year. This grossed up number can be referred to as the
"modeled tonnage" for the period;
iv) The total design tailings solid storage capacity of Cell 4B will be accepted as
2,094,000 dry tons of tailings;
v) The available remaining space in Cell4B for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi) The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell4B
for solids. That is, the reduced pool surface area for period t=O ("RP Ao"), after the
reduction, will be calculated to be:
(1-(L10* x 1.5) / (2,094,000 -To)) x 40 acres = RPAo
vii) The required freeboard for Cell 4B for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4B of 0.77 feet plus the
quotient of 197.5 acre feet divided by the RPAo. The freeboard limit for Cell4B for
the remainder of period t=O would then be the elevation of the FML for Cell 4B of
5594.0 FMSL less this required freeboard amount, rounded to the nearest one-tenth of
a foot; and
viii) The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
(d) Annual Freeboard Calculation When the Maximum Elevation of the Beach Area Exceeds
5,594FMSL
On November 1 of each year (the "Annual Calculation Date"), the reduction in pool area for the
ensuing year (referred to as period t) will be calculated by:
i) First, calculating the Adjusted Reduced Pool Area for the previous period (ARP At-I)
to reflect actual tonnages deposited in Cell 4B for the previous period (period t-l).
The RPAt-1 used for the previous period was based on expected tonnages for period t-
1, grossed up by a safety factor. The ARPAt-1 is merely the RPA that would have
been used for period t -1 had the actual tonnages for year t -1 been known at the outset
of period t -1 and had the RP A been calculated based on the actual tonnages for period
t-1. This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation. The
ARP At-l can be calculated using the following formula:
(1-L1t-l / (2,094,000 -Tt-l)) X ARPAt-2 = ARPAt-l
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+2.112 Revision: Denisonl1 .4~
Page 23 of 55
Where:
• ~t-l is the actual number of dry tons of tailings solids deposited in Cell 4B
during period t -1 ;
• Tt-1 is the actual number of dry tons oftailings solids historically deposited in
Ce1l4B prior to the beginning of period t-1; and
• ARPAt_2 is the Adjusted Reduced Pool Area for period t-2. If period t-2
started at the Initial Calculation Date, then ARP At-2 is 40 acres;
ii) Once the ARPAt-1 for the previous period (period t-1) has been calculated, the RPA
for the subject period (period t) can be calculated as follows:
(1-(~t* x 1.5) / (2,094,000 -Tt)) x ARPAt-1 = RPAt
Where:
• ~t* is the expected number of dry tons of tailings to be deposited into Ce1l4B
for the ensuing year (period t), based on production estimates for the year (as
can be seen from the foregoing formula, this expected number is grossed up
by a safety factor of 1.5);
• Tt is the actual number of dry tons of tailings solids historically deposited in
Cell 4B prior to the beginning of period t; and
• ARPAt-1 is the Adjusted Reduced Pool Area for period t-1, which is the pool
surface area for the previous period (period t-1) that should have applied
during that period, had modeled tonnages (i.e., expected tonnages grossed up
by the 150% safety factor) equaled actual tonnages for the period;
iii) The required freeboard for period t can be calculated in feet to be the wave run up
factor for Ce1l4B of 0.77 feet plus the quotient of 197.5 acre feet divided by the RPAt•
The freeboard limit for Ce1l4B for period t would then be the elevation of the FML
for Cell 4B of 5594.0 FMSL less this required freeboard amount, rounded to the
nearest one-tenth of a foot; and
iv) The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist until the next Annual Calculation
Date for period t+ 1.
An example of this calculation is set out in Appendix F.
(e) When a Spillway is Added to Cell4B that Allows Overflow Into a New Tailings Cell
When a spillway is added between Ce1l4B and a new tailings cell then, if an approved freeboard
limit calculation method for the new cell is set to cover the entire PMP event for Cells 2, 3, 4A, 4B
and the new tailings cell, the freeboard limit for Ce1l4B will be inapplicable, except for approved
provisions to prevent storm water runoff from overtopping dikes.
6.3.6. Roberts Pond
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Book 11: Environmental Protection Manual, Section 3.1
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Page 24 of 55
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0 feet above mean sea
level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
ill the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
6.5. Annual illspection of the Decontamination Pads
a) New Decontamination Pad
During the second quarter of each year, the New Decontamination Pad will be taken out of service
and inspected to ensure the integrity of the wash pad's exposed concrete surface. If any
abnormalities are identified, i.e. cracks in the concrete with greater than 1/8 inch separation (width)
or any significant deterioration or damage of the pad surface, repairs will be made prior to resuming
the use of the facility. All inspection findings and any repairs required shall be documented on the
Annual Decontamination Pad illspection form. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due September 1
of each calendar year.
b) Existing Decontamination Pad
During the second quarter of each year, the Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank. Once the water and any sediment
present is removed from the steel tank containment, the walls and bottom of the tank will be
visually inspected for any areas of damage, cracks, or bubbling indicating corrosion that may
have occurred since the last inspection. If any abnormalities are identified, defects or damage
will be reported to Mill management and repairs will be made prior to resuming the use of the
facility. All inspection fmdings and any repairs required shall be documented on the Annual
Decontamination Pad illspection form. A record of the repairs will be maintained as a part of the
Annual illspection records at the Mill site. The inspection findings, any repairs required and
repairs completed shall be summarized in the 2nd Quarter DMT Monitoring Report due
September 1 of each calendar year.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4, 5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
8. REPORTING REQUIREMENTS
+,2/12 Revision: Denisonl1.4~
Page 25 of 55
In addition to the Daily Inspection Data, Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Data fonns included as Appendix A and described in Sections 2, 3, 4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill Inspection fonns
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection fonn will
also be attached. Quarterly inspection fonns will accompany the report when applicable. The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
8.2. DMT Reports
Quarterly reports ofDMT monitoring activities, which will include the following information, will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
a) On a quarterly basis, all required infonnation required by Part 1.F.2 of the GWDP
relating to the inspections described in Section 3.1 (b) (Slimes Drain Water Level
Monitoring), 3.I(d) (Tailings Wastewater Pool and Beach Area Elevation
Monitoring), 3.2 (Weekly Inspection of Solution Levels in Roberts Pond) and 3.3
(Weekly Feedstock Storage Area Inspections);
b) On a quarterly basis, a summary of the weekly water level (depth) inspections for
the quarter for the presence of fluid in all three vertical inspection portals for each
of the three chambers in the concrete settling tank system for the New
Decontamination Pad, which will include a table indicating the water level
measurements in each portal during the quarter;
c) With respect to the annual inspection of the New Decontamination Pad described
in Section 6.5(a), the inspection findings, any repairs required, and repairs
completed shall be summarized in the 2nd Quarter report, due September I of
each calendar year;
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Book 11: Environmental Protection Manual, Section 3.1
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d) With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b), the inspection findings, any repairs required, and
repairs completed shall be summarized in the 2nd Quarter report, due September 1
of each calendar year; and
e) An annual summary and graph for each calendar year of the depth to wastewater
in the Cell 2 slimes drain must be included in the fourth quarter report. After the
first year, and beginning in 2008, quarterly reports shall include both the current
year monthly values and a graphic comparison to the previous year.
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Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A
FORMS
+2112 Revision: Denison 11.4~
Page 27 of 55
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Book 11: Environmental Protection Manual, Section 3.1
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APPENDIX A (CONT.)
DAILY INSPECTION DATA
Any Item not "OK" must be documented. A check mark = OK, X = Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM I
Inspection Items Conditions of Potential Concern CellI
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends
Pipeline Joints Leaks, Loose Connections
Pipeline Supports Damage, Loss of Support
Valves Leaks, Blocked, Closed
Point(s) of Discharge Improper Location or Orientation
II. OPERATIONAL SYSTEMS and INTERIOR of CELLS
Inspection Items Conditions of Potential Concern CellI
N S EW
Interior Cell Walls
Liner Observable Liner Damage
Water Level Greater Than Operating Level, Large
Change Since Previous Inspection
I Beach Cracks, Severe Erosion, Subsidence
I Liner and Cover Erosion of cover, Exposure of Liner
Cell 2
Cell 2
Inspector: ______ _
Date; ________ _
Accompanied by: ___ _
Time: ________ _
Cell 3 Cell4A Cell4B
Cell 3 Ce1l4A Ce1l4B
N S E W ~ S EW
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.. ---i Formatted: Section start: New page --- - -J
.. ---i Formatted Table
.. - - -{ Formatted: Centered
.. - --{ Formatted Table
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Book 11: Environmental Protection Manual, Section 3.1
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Page 29 of 55
II biflet: I Oesef'f'al31e LiHer Damage 6 I I
I
I
III. DIKES AND EMBANKMENTS
InsQection Items Conditions of Potential Dike 1-1 Dike 1-
Concern lA
Slopes Sloughs or Sliding Cracks, No No
Bulges, Subsidence, Severe visible visible
Erosion, Moist Areas, Areas exterior exterior
of Seepage Outbreak slope or slope or
dike to dike to
inspect inspect
Crest Cracks, Subsidence, Severe No No
Erosion visible visible
exterior exterior
slope or slope or
dike to dike to
inspect inspect
IV. FLOW RATES I
Slurry Line( s) Pond Return
GPM
V. PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
VI. DUST CONTROL
I Dusting
Dike 2
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
Cell 2
Dike 3 Dike
4A-S
No
visible
exterior
slope or
dike to
inspect
No
visible
exterior
slope or
dike to
inspect
S-X Tails
_____ yes
_____ yes
Cell 3
1
Dike Dike
4A-E 4B-S
Spray System
______ No
______ No
Ce1l4A Ce1l4B
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Book 11: Environmental Protection Manual, Section 3.1
Wind Movement of Tailings
Precipitation: inches liquid
General Meteorological conditions:
------
VII. DAILY LEAK DETECTION CHECK I I
CellI Cell 2
Leak Checked Checked
Detection
System ---Wet ___ Dry ___ Wet ___ Dry
Checked
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
4-,2/12 Revision: Denison 11.42
Page 30 of 55
Cell 3 Cell4A
Checked Checked
---Wet ___ Dry ---Wet ___ Dry
Initial level Initial level
Final Final
level level
Gal. pumped Gal. pumped
Cell4B
Checked
---Wet ___ Dry
Initial level
Final
level
Gal. pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
-1-2112 Revision: Denisonl1.4~
Page 31 of 55
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
-1-2/12 Revision: Denison 11.42
Page 32 of 55
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
H I12 Revision: Denison 1 1.4,2
Page 33 of 55
Date: _______ _
1. Pond and Beach
elevations (msl, ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors: ____________ _
CellI: (a) Pond Solution Elevation
(b) FML Bottom Elevation ___ 5597 __ _
(c) Depth of Water above FML ((a)-(b» _____ _
CeIl4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation ___ 5555.14_
(c)Depth of Water above FML ((a)-(b» _____ _
CeIl4B: (a)Pond Solution Elevation
Roberts
(b)FML Bottom Elevation ___ 5557.50
(c)Depth of Water above FML ((a)-(b» _____ _
(d)Elevation of Beach Area with Highest Elevation
(monthly)
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation ___ 5612.3_
(c)Depth of Water aboveFML ((a)-(b» _____ _
2. Slimes Drain Liquid Levels Cell 2 Pump functioning properly ___ _
_______ Depth to Liquid pre-pump
_______ Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 37.97' -Depth to Liquid Pre-
pump= __ _
Post-pump head is 37.97' -Depth to Liquid Post-
pump= __ _
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
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Page 34 of 55
(Same data as Daily Inspection Form. Record data on daily form).
Observation:
New Decon Pad, New Decon Pad, New Decon Pad
Portal 1 Portal 2 Portal 3
Is LDS (Portal) __ wet __ dry __ wet __ dry __ wet __ dry
wet or dry?
If wet, Record ---Ftto ---Ft to ___ Ftto
liquid level: Liquid Liquid Liquid
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented: _____________________ _
6. Remarks: _________________________________ _
7. Designated Disposal Area for Non-Tailings Mill Waste (awaiting DRC approval)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (solution
elevation of 5556.14 amsl for Ce1l4A and 5558.50 for Ce1l4B)? no __ yes
If Ce1l4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notify supervisor or Mill manager immediately.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+.2/12 Revision: Denisonl1.4~
Page 35 of 55
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector: __________________________ _
Date: ____________________________ __
1. Slurry Pipeline:
2. Diversion Ditches and Diversion Berm:
Observation:
Di version Ditch 1
Diversion Ditches:
Sloughing __ yes __ no
Erosion __ yes __ no
Undesirable __ yes __ no
Vegetation
Obstruction of Flow __ yes __ no
Diversion Berm:
Stability Issues
Signs of Distress
Diversion Ditch 2 Diversion Ditch 3
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
__ yes __ no __ yes __ no
Diversion Berm 2
__ yes __ no
__ yes __ no
Comments: ______________________________________________________________________ _
3. Summary of Activities Around Sedimentation Pond: ____________________________ _
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White Mesa Mill-Standard Operating Procedures
Book 11 : Environmental Protection Manual, Section 3.1
4. Overspray Dust Minimization:
Overspray system functioning properly: ___ yes ___ no
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Page 36 of 55
Overspray carried more than 50 feet from the cell: __ yes ___ no
If "yes", was system immediately shut off? __ yes __ no
Comments: ________________________________ _
5. Remarks: _______________________________ _
6. Settlement Monitors
Cell 2 WI: Ce1l2W3-S: Ce1l3-IN: ____ _
Cell 2 W2: Cell2EI-N: ____ _ Cell 3-IC: ____ _
Cell 2 W3: Cell2EI-IS: ____ _ Cell 3-IS: ____ _
Cell 2 W4: Cell 2EI-2S: ____ _ Cell 3-2N: ____ _
Cell 2W7-C: ____ _ Cell 2 East: Ce1l2W5-N: ___ _
Cell 2 W7N: ____ _ Cell 2 W7S: ____ _ Cell 2 W6N: ___ _
Cell 2 W6C: Cell 2 W6S: ____ _ Cell 2 W4N: ___ _
Ce1l4A-Toe: ____ _ Cell 2 W4S: ____ _ Cell 2 W5C: ____ _
Cell 3-2C: ____ _ Cell3-2S: ____ _ Cell 2 W5S: ___ _
Ce1l3-3S: ____ _ Cell3-3C; _____ _ Ce1l3-3N: ____ _
Cell 3-4N: _____ _ Ce1l3-6N: ____ _ Ce1l3-7S: ____ _
Cell 3-7C: _____ _ Ce1l3-7N: ____ _ Ce1l3-8S: ____ _
Cell 3-8C: _____ _ Cell3-8N: ____ _
7. Movement Monitors: (Is there visible damage to any movement monitor or to adjacent
surfaces)?
8. Summary of Daily, Weekly and Quarterly Inspections: ______________ _
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
-1-2112 Revision: Denisonl1.4~
Page 37 of 55
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Book 11: Environmental Protection Manual, Section 3.1
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Page 38 of 55
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector: __________________________ _
Date: __________________________ __
1. Embankment Inspection:
2. Operations/Maintenance Review:
3. Construction Activities: _______________________________________ _
4. Estimated Areas:
Cell 3 Ce1l4A Ce1l4B
Estimated percent of beach surface area
Estimated percent of solution pool area
Estimated percent of cover area
Comments:
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
+2/12 Revision: Denison 11.4~
Page 39 of 55
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of ____ through ____ Date of Inspection: _______ _
Inspector: ___________ _
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes: ___ no: ___ _
comments: ____________________________________ _
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes: ___ no: __ _
comments (e.g., conditions of containers): _________________ _
Are all sumps and low lying areas free of standing solutions?
Yes: No:
If "No", how was the situation corrected, supervisor contacted and correction date?
Is there free stllnding water or water running off of the feedstock stockpiles?
Yes: No: Comments: ___________________________________ _
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Book 11: Environmental Protection Manual, Section 3.1
Other comments:
+2/12 Revision: Denison 11.4,1
Page 40 of 55
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT.)
+2112 Revision: Denisonll.4~
Page 41 of 55
ANNUAL DECONTAMINATION PAD INSPECTION
Date of Inspection: _______ _
Inspector: ___________ _
New Decontamination Pad:
Are there any cracks on the wash pad surface greater than 1/8 inch of separation? _Yes _No
Is there any significant deterioration or damage of the pad surface? __ Yes __ No
Findings:
Repair Work Required:
Existing Decontamination Pad:
Were there any observed problems with the steel tank? __ Yes __ No
Findings:
Repair Work Required:
Note For the annual inspection of the both the Existing and New Decontamination Pads, the
annual inspection findings, any repairs required, and repairs completed, along with a summary of
the weekly inspections, shall be discussed in the 2nd Quarter report, due September 1 of each
calendar year
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXB
8.3. TAILINGS INSPECTOR TRAINING
+2/12 Revision: Denisonll.4J.
Page 42 of 55
,This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
inspected for damage and loss of support. Valves are also to be inspected particularly for
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Book 11: Environmental Protection Manual, Section 3.1
+2/12 Revision: Denisonl1.4,l
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leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3, 4A and 4B solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells 1 and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3. Dikes and Embankments:
Inspection items include the slopes and the crests of each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 4A-S, 4A-E, and 4B-S, , should be inspected closely
for mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection report
should be marked accordingly.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. Flow Rates:
+2112 Revision: Denison 11.4~
Page 44 of 55
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (OPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
5. Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6. Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2, 3, 4A, and 4B. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by Environmental, Health and Safety personnel as close to 8:00
a.m. as possible. All snow or ice should be melted before a reading is taken.
7. Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applica~le.
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White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
1. Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
+2/12 Revision: Denisonl1.4J.
Page 45 of 55
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit on Cell 4A and 4B dike is 5 mph, and the posted speed limit for
the tailings area (other than the Ce1l4A and 4B dike) is 15 mph. These limits should not
be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
10. Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
11. Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the Certification
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Book 11: Environmental Protection Manual, Section 3.1
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Page 46 of 55
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXC
CERTIFICATION FORM
Date: ____________ _
Name: ___________ __
+2.112 Revision: Denisonl1.4~
Page 47 of 55
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel! Tailings System
Supervisor
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Book 11: Environmental Protection Manual, Section 3.1
+.2/12 Revision: Denison 11.4~
Page 48 of 55
APPENDIXD
FEEDSTOCK STORAGE AREA
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Book 11: Environmental Protection Manual, Section 3.1
t
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Page 49 of 55
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White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIXE
TABLES
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Page 51 of 55
Table lA
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding, Utah
Head above Liner System (feet) Calculated Action leakage Rate
5
10
15
20
25
30
35
37
( gallons / acre / day)
Table IB
Calculated Action leakage Rates
for Various head Conditions
Cell 4 B White mesa Mill
Blanding, Utah
222.04
314.01
384.58
444.08
496.50
543.88
587.46
604.01
Head above Liner System (feet) Calculated Action leakage Rate
( gallons / acre / day)
5 211.40
10 317.00
15 369.90
20 422.70
25 475.60
30 528.40
35 570.00
37 581.20
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1l.4'Tailiags Mgat S)stem ae£l DMT Mea Plae Jaellfli) ;!(ll;! Fe 11.4 eleae.£lee
White Mesa Mill -Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
Assumptions and Factors:
APPENDIXF
Example of Freeboard Calculations
For Ce1l4B
+2112 Revision: Denison 11.4~
Page 53 of 55
o Total PMP volume to be stored in CeIl4I!A -159.4 acre feet
o Wave runup factor for Cell4B -0.77 feet
o Total capacity of Cell 4B -2,094,000 dry tons
o Elevation of FML of Cell4B -5,600.35 FMSL
o Maximum pool surface area of Cell 4 B -40 acres
o Total tailings solids deposited into Cell 4B at time beach area first exceeds 5,594
FMSL -1,000,000 dry tons*
o Date beach area first exceeds 5,594, FMSL -March 1,2012*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Actual Tailings
Tailings Solids Tailings Solids
Disposition into Solids Disposition into
Cell 4B Dispositio Cell 4B
Determined at n into Cell determined at
the beginning of 4B at the end of the
the period (dry beginning period (dry
tons)* of the tons) *
period,
multiplied
by 150%
Safety
Factor
(dry tons)
March 1, 2012 150,000 225,000 225,000
to November 1,
2012
November 1, 300,000 450,000 275,000
2012 to
November 1,
2013
November 1, 200,000 300,000 250,000
2013 to
November 1,
2014
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ll.4lTailiags Mgat S)stem ami DHT Hea Plan Jaflllaf) 2912 fe 1l.1 eleaH.elee
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
+2112 Revision: Denisonl1.4.J.
Page 54 of 55
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors, the freeboard limits for Ce1l4B would be calculated
as follows:
1. Prior to March 1. 2012
Prior to March 1,2012, the maximum elevation of the beach area in Cell4B is less than or
equal to 5,594 FMSL, therefore the freeboard limit is set at 5,594.6 FMSL.
2. March 1,2012 to November 1, 2012
The pool surface area would be reduced to the following amount
(1-225,0001 (2,094,000 -1,000,000)) x 40 acres = 31.77 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by 31.77
acres equals 6.22 feet. When the wave run up factorforCell4B of 0.77 feet is added to this, the total
freeboard required is 6.99 feet. This means that the freeboard limit for Cell4B would be reduced
from 5594.6 FMSL to 5592.2 FMSL (5594.6 FMSL minus 6.22 feet, rounded to the nearest one-
tenth of a foot). This calculation would be performed at March 1, 2012, and this freeboard limit
would persist until November 1, 2012.
3. November 1, 2012 to November 1, 2013
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since the actual tonnage of 225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons, the recalculated pool surface area is the same as
the modeled pool surface area for the previous period, which is 31.77 acres.
Then, calculate the modeled pool surface area to be used for the period:
(1-450,0001 (2,094,000 -1,000,000 -225,000)) x 31.77 acres = 15.32 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
15.32 acres equals 12.89 feet. When the wave run up factor for Cell4B of 0.77 feet is added
to this, the total freeboard required is 13.66 feet. This means that the freeboard limit for Cell
4B would be reduced from 5592.2 FMSL to 5586.7 FMSL (5600.35 FMSL minus 13.66
feet, rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2012, and this freeboard limit would persist until November 1,2013.
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1 U'Tailiags Mgat S)stem ood DMT Mea Plaa Jaall~ 2Q12 Fe 11.4 eleaa.dee
White Mesa Mill-Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
4. November 1. 2013 to November 1. 2014
+2/12 Revision: Denisonl1.4~
Page 55 of 55
The pool surface area would be reduced to the following amount:
First, recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e., expected tonnages grossed up by the 150% safety factor) equaled
actual tonnages for the period. Since modeled tonnages exceeded actual tonnages, the pool
area was reduced too much during the previous period, and must be adjusted. The
recalculated pool area for the previous period is:
(1 -275,0001 (2,094,000 -1,000,000 -225,000) x 31.77 acres = 21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1,2013.
Then, calculate the modeled pool surface area to be used for the period:
(1-300,0001 (2,094,000 -1,000,000 -225,000 -275,000)) x 21.72 acres =
10.75 acres
Based on this reduced pool area, the amount of freeboard would be 197.5 acre feet divided by
10.75 acres equals 18.37 feet. When the wave run up factor for Cell4B of 0.77 feet is added
to this, the total freeboard required is 19.14 feet. This means that the freeboard limit for Cell
4B would be reduced from 5586.7 FMSL to 5581.2 FMSL (5600.4 FMSL minus 18.4 feet,
rounded to the nearest one-tenth of a foot). This calculation would be performed at
November 1, 2013, and this freeboard limit would persist until November 1, 2014.
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:
STORMWATER
BEST MANG.EMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
October 2011
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
1.0 INTRODUCTION/PURPOSE ............................................................................................................................... 1
2.0 SCOPE ................................................................................................................................................................... 2
3.0 RESPONSIBILITY ................................................................................................................................................ 3
4.0 BEST MANAGEMENT PRACTICES .................................................................................................................. 4
4.1 General Management Practices Applicable to All Areas ......................................................................... 4
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: ............................................ 4
4.1.2 Keep Potential Pollutants from Contact with Precipitation ............................................................. .4
4.1.3 Keep Paved Areas from Becoming Pollutant Sources ...................................................................... 4
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and
Reagent Storage Area ...................................................................................................................................... 4
4.1.5 Recycle Fluids Whenever Possible: .................................................................................................. 4
4.2 Management Practices for Process and Laboratory Areas ....................................................................... 5
4.2.1 Clean Up Spills Properly .................................................................................................................. 5
4.2.2 Protect Materials Stored Outdoors .................................................................................................... 5
4.2.3 Management ..................................................................................................................................... 5
4.2.4 Materials Management ..................................................................................................................... 5
4.3 Management Practices for Maintenance Activities .................................................................................. 6
4.3.1 Keep a Clean Dry Shop .................................................................................................................... 6
4.3.2 Manage Vehicle Fluids ..................................................................................................................... 6
4.3.3 Use Controls During Paint Removal ................................................................................................. 6
4.3.4 Use Controls During Paint Application and Cleanup ....................................................................... 6
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment.. ........................................... 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas ..................................................................... 7
4.4.2 Manage Stockpiles to Prevent Windborne Contamination ............................................................... 7
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources .................................................... 7
Figures
Figure 1: White Mesa Mill Site Layout. ..................................................................................................................... 16
Figure2: White Mesa Mill Site Drainage Basins ........................................................................................................ 17
Figure 3: Denison Mines (USA) Corp.-White Mesa Mill Management Organization Chart .................................... 19
Figure 4: Denison Mines (USA) Corp. -Corporate Management Organizational Chart.. ......................................... 20
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP ........................... 9
TABLE 2.0: REAGENT YARD LIST ....................................................................................................................... 10
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1 .......................................................................... 11
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1 ........................................................ 12
TABLE 5.0: BAGENT YARD/BULK CHEMICALS LIST 1 ................................................................................... 13
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1 ...................................................................... 14
Appendices
Appendix 1
Appendix 2
White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
White Mesa Mill Emergency Response Plan
1.0 INTRODUCTION/PURPOSE
Best Management Practices Plan
Revision 1.4: October 2011
Denison Mines (USA) Corp. ("DUSA") operates the White Mesa Uranium Mill ("the Mill) in
Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect to
water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public storm water systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to DUSA on March 8,
2005. As a part of compliance with the Permit, DUSA i required to ubmit a Storm water Best
Management Practices Plan (''BMPP") to the Executive Secretary of the Divi ion of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spiil of chemical or hazardous materiaL which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices in a good faith effort to minimize all sources of
pollution at the site.
Page 1
2.0 SCOPE
Best Management Practices Plan
Revision 1.4: October 2011
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure 1. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
Requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are addressed in the DUSA White: Mesa Mill Spill Prevention, Control and
Countermeasures ("SPCC") Plan, the Emergency Response Plan ("ERP"),, and the housekeeping
procedure incorporated in the White Mesa Mill Standard Operating Procedures ("SOPs"). The
latest revi ion of the SPCC plan and the ERP are provided in their entirety in Appendices 1 and
2, respectively.
Page 2
3.0 RESPONSIBILITY
Best Management Practices Plan
Revision 1.4: October 20 I J
All Mill personnel are responsible for implementation of the practices in this BMPP. DUSA
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3. The DUSA Corporate Management
Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table I.
Page 3
Best Management Practices Plan
Revision 1.4: October 2011
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT1900479. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended. Status of maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 4
Best Management Practices Plan
Revision 1.4: October 2011
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.lO.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such a cat litter), pill collection drums, and personnel
protective equipment ("PPE") near the area where they may be needed for piU respon e.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers in, tead of rinsing them off in the sink.
• When possible, wipe down counter and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount oflaboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 5
Best Management Practices Plan
Revision 1.4: October 2011
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windbome contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or .unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings area
Page 6
Best Management Practices Plan
Revision 1.4: October 2011
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailer , and other heavy equipment only in areas designated for this purpose
(such as wa h down pad areas and tile truck wash tation).
• At the truck wa h station, make sure the water collection and recycling sy tern is working before
turning on water pray .
4.4.2 Manage Stockpiles to Prevent Wiodborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water pray tockpile as required by opacity standard or weather conditions.
• Don't over-water. Keep urfaces moi t but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme drynes and high
winds will not be a factor (to prevent the need for excessive du t uppression).
• Remove existing vegetation only when ab olutely necessary.
• Seed or plant temporary vegetation for erosion control on l.ope .
Page 7
TABLES
Page 8
:
Personnel
Dan Hillsten
Wade Hancock
Scot Christensen
David E. Turk
Personnel
Ron F. Hoch tein
David C. Frydenlund
TABLE1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Manager
Maintenance
Superintendent
Mill Superintendent
Mill Staff
Work Phone
435-67 8-2221
Ext. 105
435-678-2221
Ext.l66
435-678-2221
Radiation Safety Officer 435-678-2221
Ext. 113
Corporate Management Staff
Title Work Phone
Pre ident/ Chief 604-689-7842
Operating Officer
Vice President and 303-389-4130
General Coun eJ
Home Phone/
Other Contact Number
Cell: 435-979-3041
435-678-2753
Cell: 435-979-0410
435-678-2015
435-678-7802
Cen: 435-459-9786
Home Phone/
Other Contact
Number
Cell: 604-377-1167
303-221-0098
Cell: 303-808-6648
Page 9
REAGENT ,. •)'
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE{BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POLO X
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
TABLE 2
REAGENT YARD LIST
QUANTITY N U f\:IIBE~ OF
(L.BS) BTO~A@lE,
'TANKS
54,000 2
26,000 ---
107,920 2
45,430 ---
2
1
72,000 ---
1,344 1
2
10,360 ---
1
39,280 ---
0 1
1
39,280 ---
84,1 00 1
1
1011128 1
1
1
0 1
4,801 ,440 1
1
1
CAPACITY
(GALLO~S}
24,366
31 ,409
250
6,000
10,315
10,095
25,589
13,763
18,864
16,921
8,530
16,921
22,561
29,940
19,905
1,394,439
3,000
5,000
Page 10
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST 1
Chemical In Lab RQ<! Quantitv in Stock
Aluminum nitrate 2270 kg 1.8 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2270 kg 2.27 kg
Ammonium oxalate 2270 kg 6.8 kg
Ammonium thiocyanate 2270 kg 7.8 kg
Antimony potassium tatrate 45.4 kg 0.454
n-8utyl acetate 2270 kg 4L
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.81 kg
Ferrous ammonium sulfate 454 kg 0.57
Potassium chromate 4.54 kg 0.114 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2270kg 1.4
Zinc acetate 454 kg 0.91 kg
Chemical. in Volatiles and RQ2 Quantit)£ in Stock
Flammables Lockers
(A B Cl
Chloroform 4.54 kg_ 8L
Formaldehyde 45.4 kg < 1 L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ<! Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochloric acid 2,270 kg 58 _gal
Nitrate acid 454 kg 5L
Phosphoric Acid 2,270 kg 10 L
Sulfuric acid 454 k_g_ 25 L
Hydrofluoric acid 45.4 kg 1 L
Ammonium h_ydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 11
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
CHEMICAL RQZ QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,000 lbs 4gal
Ammonium Hydroxide 1,000 lbs 5L
Calcium Hypochlorite 101bs 2 kg_(4.4 lbs)
Chlorine 10ibs Olbs
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (111bs)
Hydrochloric 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32gal 5 kg (11 1bs)
Sodium Hypochlorite 5.5% 1001bs 2 kg (11 lbs) of 5.5%
solution
Silver Nitrate 1 lb Olbs
Trichloroethylene 1001b 2L
1. This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area. The Mill also stores small
quantities of other materials that are not hazardous substances per
the above regulation.
2. Reportable Quantities are those identified in40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 12
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
REAGENT RQ' QUANTITY IN REAGENT
YARD
Sulfuric Acid 1,000 lbs 9,000,000 lbs
Hyperfloc 1 02 None 1,500 lbs
Ammonia -East Tank 1001bs Olbs
Ammonia-West Tank 100ibs 105,000 lbs
Kerosene 100 gal 500 gal
Salt (Bags) None 20,000 lbs
Soda Ash Dense (Bag) None 50,000 lbs
Polyox None 490ibs
Tributyl phosphate None 9,450 lbs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx. 6000 gal
Alamine 336 drums None 8,250 gal
Salt(Bulk Solids) None 50,000 lbs
Salt(Bulk Solutions) None 9,000 gal
Caustic Soda 1,000 lbs 16,000 lbs
Ammonium Sulfate None 150,000 lbs
Sodium Chlorate None 350,000 lbs
Alamine 31 0 Bulk None Olbs
lsodecanol None 2,420 gal
Vanadium Pentoxide3 1000ibs 30,000 lbs
Yellowcake3 None <1 00,000 lbs
Ammonia Meta Vanadate 10001bs Olbs
Floc 655 21,000 lbs
Floc 712 1,250 lbs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or Mill Yard
Page 13
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1 ,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal 0 gallons
Toluene 1000 gal 0 gallons
Varsol Solvent 100 gal 0 gallons
(2% trim ethyl benzene in petroleum
distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 14
FIGURES
Page 15
Figure 1
White Mesa Mill
Mill Site Layout
Page 16
sx
BUILDING
SAMPLE PLANT
! 10
D
100 50 100 200
SCALE IN FEET
Figure2
White Mesa Mill
Mill Site Drainage Basins
Page 17
Figure 3
White Mesa Mill
Mill Management Organization Chart
Page 18
Mill Superintendent
Operations
Foreman
Shift Foreman
(4)
Operating
Crews
Maintenance
Foreman
Maintenance
Personnel
I
White Mesa
Inc. Foreman
Figure3
Denison Mines (USA) Corporation
White Mesa Mill Management
Organizational Structure
President & CEO t-
l
Mill Manager
j_
I I
Radiation Safety
Officer
Senior Metallurgist
1--
;-----1
Safety
Radiation
Tech
L--1 Environmental
Tech
.______. Chief Chemist
I
Purchasing Manager
I
Payroll/
Administrator
Page 19
Figure 4
White Mesa Mill
Denison Mines (USA) Corporation
Organizational Structure
Page 20
'
1 J
VP & General VP Corporate
Counsel Development
\
Figure4
Denison Mines (USA) Corporation
Organizational Structure
President & CEO
VP & Chief Financial
Officer
Controller
Director Project
Development
Technical Manager
'----------· ----
'·.
I ....,
Administration Manager
Page 21
;
APPENDICES
Page 22
:
Appendix 1
White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
Page 23
:
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
1.1 OBJECTIVE:
The objective of the Split Prevention, Control, and Countermeasures (SPCC}
Plan is to serve as a site-specific guideline for the prevention of and
response to chemical and petroleum spills. The plan outlines spill potentials,
containment areas, and drainage characteristics of the White Mesa Mill site.
The plan addresses chemical spill prevention, spill potentials, spill discovery,
and spill notification procedures. Spills are reportable if the spill leaves the
site. Ammonia Is the only chemical (as vapor) that has the potential to leave
the site. In addition, chemical and petroleum spills will be reported In
accordance with applicable laws and regulations.
Figure 1 , Site Layout Map shows a map of the mill site including the locations
of the chemical tanks on-site. Figure 2 shows the basins and drainage ditch
areas for the mill site. Table 1.0 is an organization chart for Mill operations.
Table 2.0 lists the reagent tanks and their respective capacities. Table 3.0
lists the laboratory chemicals, their amounts, and their reportable quantities.
Table 4.0 lists the operations chemicals. Table 5.0 lists the chemicals In the
reagent yard, their amounts, and their reportable quantities. Table 6.0 lists
the petroleum products and solvents on site.
1.2 RESPONSIBILITIES:
Person in charge of facility responsible for spill prevention:
Mr. Dan Hillsten, Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Mr. David Turk, Department Head, Health, Safety, and Environmental
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
{435) 678-7802 (home)
Refer to Section 1.9 Spill Incident Notification for a list of personnel to be
notified in case of a spill. In addition, an organizational chart is provided in
Table 1.0.
1.3 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS:
The main drainage pathways are illustrated In Plate 1 .• 0. The map shows
drainage basin boundaries, flow paths, constructed diversion ditches, tailing
cells, the spillway between Cell 2 and 3, dikes, berms, and other relevant
features. The White Mesa Mill is a "2:ero" discharge facility for process liquid
wastes. The mill area has been designed to ensure that all spills or leaks
from tanks will drain toward the lined tailing cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 100% of the PMP (Probable Maximum Precipitation).
This allows for a maximum of 10 Inches of rain at any given time.
1.4 DESCRIPTION OF BASINS:
Precipitation and unexpected spills from the mill site are contained within
their prospective drainage basins. Overflow ultimately drains into one of the
four lined tailings cells.
1.4.1 Basin A1
Basin A 1 is north of Cell 1·1 and Diversion Ditch No. 1. The basin
contains 23 tributary acres, all of which drain into Westwater Creek.
1.4.2 Basin A2
Basin A2 contains all of Cell 1 ~1 Including an area south of the Diversion
Ditch No. 1. The basin covers 84 acres. Any overflow from this basin
would be contained within Cell1-l.
1.4.3 Basin B1
Basin 81 is north of the mill area. The basin contains 45.4 tributary
acres.
Overflow from this basin drains Into a flood retention area by flowing
through Diversion Ditch No. 2. Diversion Ditch No. 2 drains Into
Westwater Creek.
1.4.4 Basin B2
Basin 82 is northeast of the mill area and contains only 2.6 tributary
acres. Overflow from this basin would drain into Diversion Ditch No. 3.
Diversion Ditch No.3 ultimately drains into Diversion Ditch No. 2.
2
1.4.5 Basin B3
Basin 83 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normal direction of flow in this basin Is from the
northwest to the southwest. Any overflow from this basin would drain into
Cell1-l. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 1 00% of the PMP (Probable Maximum
Precipitation). This allows 1 0 Inches of rain for any given storm event.
1.4.6 Basin C
Basin C contains all of Cell2. The basin consists of 80.7 acres. Areas In
this basin include earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All overflows In this
basin is channeled along the southern edge of the basin. Overflow then
flows into Cell 3 via the spillway from Cell2 to Cell 3.
1.4.7 Basin D
Basin D contains all of Cell3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains all flows, including those caused by the PMF.
1.4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows
Including those caused by the PMF will be contained within the basih and
will flow directly Into Ceii4A.
1.4.9 Basin F
Basin F will contain Ceii4B, if and when constructed. The area consists
of 44 acres at a relatively low elevation. Direction of flow in this basin is
towards the southwest.
1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTAINMENT
1.5.1 Reagent Tanks (Tank list Included in Table 2.0)
1.5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of
31,409 gallons each. The tanks are located southeast of the Mill building.
Dally monitoring of the tanks for leaks and routine integrity inspections will be
conducted to minimize the hazard associated with ammonia. The reportable
quantity for an ammonia spill Is 7 gallons.
----------·· -
3
:
Ammonia spills should be treated as. gaseous. Ammonia vapors will be
monitored closely to minimize the hazard associated with Inhalation. If
vapors are detected, effort.s will be made to stop or repair the leak
expeditiously. Ammonia Is the only chemical (as vapor) that has the potential
to leave the site.
1.5.3 Ammonia Meta-Vanadate
Ammonia meta-vanadate is present in the SX building as the process
solutions move through the circuit to produce the vanadium end product.
But, the primary focus will be on the transportation of this chemical. The
reportable spill quantity for ammonia meta-vanadate is 1 ,000 pounds.
1.5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank Is located on a splash pad on the northwest corner
of the SX building. The tank has a capacity of 19,904 gallons. The tank
supports are mounted on a concrete curbed catchment pad which directs
spills Into the sand filter sump In the northwest corner of the SX building.
The reportable spill quantity for sodium hydroxide Is 85 gallons.
1.5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located in
the northeast comer of the SX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and Is located In the SX building. Spills will be
diverted Into the boiler area, and would ultimately drain Into Cell 1-1. There is
no reportable spill quantity associated with sodium carbonate.
1.5.6 Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity of 17,700 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and Integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable spill quantity
for sodium chlorate is 400 gallons.
1.5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin B3 and Is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
spill. All flows resulting would be channeled to Cell 1-1. The tank is equipped
4
:
with a high level audible alarm which sounds prior to tank overflows. A
concrete spill catchment with a sump In the back provides added
containment around the base of the tank. However, the catchment basin
would not be able to handle a major tank failure such as a tank rupture. The
resulting overflow would flow towards Cell 1-1.
The two smaller storage tanks are located within an equal volume spill
containment dike east of the mill building. The tanks are not presently in
use, but are equipped with high level audible alarms.
The reportable spill quantity for sulfuric acid is 65 gallons.
1.5.8 Vanadium Pentoxide
Vanadium pentoxide Is produced when vanadium Is processed through the
drying and fusing circuits and is not present in the vanadium circuit until after
the deammoniator. Efforts will be made to minimize leaks or line breaks that
may occur In processes in the circuit that contain vanadium pentoxlde.
Special care will be taken in the transportation of this chemical. The
reportable spill quantity for vanadium pentoxide is 1000 pounds.
1.5.9 Kerosene (Organic)
The kerosene storage area is located In the central mill yard and has a
combined capacity of 10,152 gallons in three tanks. Any overflow from these
three tanks would flow around the south side of the SX building and then Into
Cell 1-1. These tanks have drain valves which remain locked unless
personnel are supervising draining operations. The reportable spill quantity
for kerosene is 1 00 gallons.
1.6.0 Used/ Waste Oil
Used/ Waste oil for parts washing is located north of the maintenance shop
in a tank and has a capacity of 5,000 gallons. The tank is contained within a
concrete containment system. Ultimate disposal of the used oil is to an EPA
permitted oil recycler. Any oil escaping the concrete containment system will
be cleaned up. Soil contaminated with used oil will be excavated and
disposed of in Cell2.
1.&.1 Propane
The propane tank is located in the northwest corner of the mill yard and has
a capacity of 30,000 gallons. Daily monitoring of the tank for leaks and
integrity inspections will be conducted to minimize potential hazards
associated with propane leaks. Propane leaks will be reported immediately.
There is no reportable quantity associated with propane.
5
:
1.7 POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
1.1.1 Petroleum Tanks
1.1.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The
tanks have capacities of 250 gallons each. One of the diesel tanks is for the
emergency generator. The other tank is located In the pumphouse on an
elevated stand. Spillage from either tank would uHimately flow Into Cell1-l.
The reportable spill quantity for diesel is 1 00 gallons. The spill Is also
reportable If the spill has the potential for reaching any nearby surface waters
or ground waters.
1.7.2 Aboveground Fuel Pump Tanks
1. 7 .2.1 Diesel
The diesel tank is located on the east boundary of Basin 83 and has a
capacity of 6,000 gallons. The tank is contained within a concrete catchment
pad. The reportable spill quantity for diesel is 100 gallons. A diesel spill is
also reportable If the spill has the potential for reaching any surface waters or
ground waters.
1. 7 .2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded
gasoline tank has a capacity of 3,000 gallons and Is contained within the
same containment system as the diesel tank. Spills having the potential for
reaching any surface waters or ground waters will need to be reported. The
reportable spill quantity for unleaded gasoline is 1 00 gallons.
1.7.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
company vehicles used around the mill site. The pump station is equipped
with an emergency shut-off device in case of overflow during fueling. In
addition, the station is also equipped with a piston leak detector and
emergency vent. Check valves are present along with a tank monitor
console with a leak detection system. The catchment Is able to handle a
complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a
temporary berm would need to be constructed. Absorbent diapers or floor
sweep would be used in an effort to limit and contain the spill. The soil would
have to be cleaned up and placed in the authorized dump in Cell 2.
6
1.7. 2.4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or diesel fuel is spilled. Proper clean-up
procedures will be followed to minimize or limit the spill. The spill may be
temporarily bermed or localized with absorbent compounds. Any soils
contaminated with diesel fuel or oil will be cleaned up and placed In Cell 2.
1.8 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is Important to take
measures to limit additional spillage and contain the spill that has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, If
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personal danger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Department Head of EA/HS
and/or the Environmental Coordinator.
The Mill Manager will assess the spill and related damage and direct
remedial actions. The corrective actions may Include repairs, clean·
upt disposal, and company notifications. Government notifications
may be necessary in some cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
1.9 SPILL INCIDENT NOTIFICATION
1.9.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies
should be notified:
7
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
:
1-800-424-8802
301/816-5100
801/538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301/816-5100
2. Sta1e of Utah, Natural Resources 801/538-7200
1.9.2 Internal Notification
Internal reporting requirements for incidents, spills, and significant spills are
as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement
actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by
management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits
operations or assesses penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-
product
8
HmD!
:
In the event of a spill requiring reporting, the Mill Manager Is required to call
the Corporate Environmental Manager or the President and Chief Executive
Officer. The spill will first be reported to the Shift Foreman. The Shift
Foreman will then report the spill to the Production Superintendent,
Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will report to the Mill
Manager. The Department Head of EA/HS and the Environmental
Coordinator will be contacted by the Mill Manager.
Home Phone
Mill Personnel:
Dan Hlllsten
David Turk
Scot Christensen
Wade Hancock
Jeremy Gagon
Thayne Holt
Denver Personnel:
Mill Manager
RSO
Production Superintendent
Maintenance Superintendent
Mill Foreman
Mill Foreman
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
Ronald F. Hochstein
David C. Frydenlund
Jo Ann Tischler
President and Chief Executive Officer (303) 986·3634
Vice President and General Counsel (303) 221·0098
Environmental Manager [phone]
In the event the next person In the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Table 1.0 shows the
organizational chart for the mill site.
1.10 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the
Environmental Coordinator for inspection and review for a minimum of three
years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
2. Tank to soil potential measurements
9
3. Annual bulk oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation Inspections
7. Spill Incident reports
8. Latest revision of SPCC plan
1.11 SPILL REPORTING REQUIREMENTS
~. Report to applicable government agency as required by laws and
regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of
spill impacts
4. Report release of 5,000 pounds or more of any process material or
waste product
1.12 PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and
control. They are informed that leaks in piping, valves, and sudden
discharges from tanks should be reported immediately. Abnormal flows from
ditches or impoundments are of Immediate concern. In addition, a safety
meeting Is presented annually by the Environmental Coordinator to review
the SPCC plan.
1.12.1 TrainIng Records
Employee training records on chemical and petroleum spill prevention are
maintained in the general safety training files.
1.12.2 Monitoring Reports
Shift Jogs shall provide a checklist for inspection items.
1.13 REVISION
This procedure is to be reviewed by the mill staff and a registered
professional engineer at least once every three years, and updated when
circumstances warrant a revision.
10
; ;
1.14 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison Mines (USA) Corp.
White Mesa Mill facilities, and attest that this SPCC plan has been prepared
in accordance with the Standard Operating Procedures currently In effect.
1.15 CERTIFICATION BY
~--·----~-
Dan Hlllsten
Mill Manager
REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison Mines (USA) Corp.
White Mesa Mill facilities, and attest that this SPCC plan has been prepared
in accordance with good engineering practices.
~
? Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
1.16 Summary
11
Chemical and petroleum spills will be reported in accordance with applicable
laws and regulations. Spills that leave the property need to be reported
immediately. Below is a table listing the specific reportable quantities
associated with the major chemical and petroleum products on-site.
CHEMICAL REPORTABLE
QUANTITY (RQ)
AMMONIA 100 POUNDS
AMV 1,000 POUNDS
SODIUM 1,000 POUNDS
HYDROXIDE
SODA ASH No Reportable
Quantity
SODIUM 400GALLONS
CHLORATE
SULFURIC ACID 1,000 POUNDS
VANADIUM 1000 POUNDS
PENTOXIDE
KEROSENE 100GALLONS
OIL No Reportable
Quantity
PROPANE No Reportable
Quantity
DIESEL & 100 GALLONS
UNLEADED
FUEL
12
Appendix2
White Mesa Mill Emergency Response Plan
Page 24
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 1 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
INTRODUCTION
The purpose of this Emergency Response Plan (this "Plan") is to reduce the risk to our
employees and to the community from potential health, safety and environmental emergencies
that could arise at the Denison Mines (USA) Corp. ("DUSA") White Mesa Uranium Mill (the
"Mill").
This plan includes the following:
• evaluation of the potential risks for accidents, including fire, explosions, gas releases,
chemical spills and floods (including tailings dam failure), that could occur at the Mill;
• specific emergency programs for each potential event;
• administrative response actions; and,
• emergency response contacts -both internal and externaL
The Mill operates under the jurisdiction of the following regulatory agencies:
• Utah State Department of Environmental Quality, Division of Radiation Control;
• Mine Safety and Health Administration;
• Environmental Protection Agency;
• Utah State Department of Environmental Quality, Division of Air Quality; and,
• Utah State Division of Natural Resources Bureau of Dam Safety.
This Plan follows the standard format and content for emergency plans for fuel cycle and
materials facilities set out in U.S. Nuclear Regulatory Commission ("NRC") Regulatory Guide
3.67 (January 1992) ("Reg. Guide 3.67"), to the extent applicable to the Mill. Section 3 of Reg.
Guide 3.67 states that "in its emergency response plan and in coordination meetings with offsite
authorities, the licensee should convey the concept that fuel cycle and materials facilities do not
present the same degree of hazard (by orders of magnitude) as are presented by nuclear power
plants. Thus the cla sification scheme for these facilities is different." Reg. Guide 3.67 also
refers to NRC's NURBG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel
Cycle and Other Radioactive Material Licensees", S.A. McGuire, January 1988, for a description
of past incidents involving radioactive materials.
NUREG-1140 analyzed potential accidents for 15 types of fuel cycle and other radioactive
material licensees, including uranium mills, for their potential for offsite releases of radioactive
materials. NUREG-1140 concludes that for most of these licensees, for example uranium mills,
the degree of hazard is small and that "the low potential offsite doses ... the small area, where
actions would be warranted, the small number of people involved, and lhe fact that the local
police and fire departments would be doing essentially the same things they noxmally do, are all
factors that tend to make a simple plan adequate." NUREG-1140 concludes that "an appropriate
plan would (1) identify accidents for which protective actions should be taken by people offsite.
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 2 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
(2) list the licensee's responsibilities for each type of accident, including notification of local
authorities (fire and police generally), and (3) give sample messages for local authorities
including protective action recommendations. This approach more closely follows the approach
used for research reactors than for power reactors."
As a result, this Plan incorporates the most appropriate responses for the Mill, in accordance with
the requirements of Reg. Guide 3.67 and the conclusions set out in NUREG-1140.
MILL OVERVIEW
Master files containing Material Safety Data Sheets ("MSDSs") for all materials in use at the
Mill are maintained at the Safety Office, Mill Maintenance Office, Mill Laboratory and Mill
Central Control Room. Copies are also on file at the Blanding Clinic, Doctor's Offices, Blanding
Fire House and Office of the San Juan County Emergency Medical Coordinator.
PLAN OBJECTIVES
The primary objectives of this plan are:
• To save lives, prevent injuries, prevent panic, and minimize property/environmental
damage to the lowest possible level;
• To evacuate and account for all people in the area including visitors, truck drivers,
contractors, etc.;
• To provide assembly areas that are as safe as possible and which can be reached without
traveling through a hazardous area. Assembly areas will be properly manned to deal with
sick or injured persons, and provisions will be made to evacuate those persons to proper
shelter; and
• To make adequately trained personnel available to cope with rescue and recovery
operations as directed by the Incident Commander.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 3 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
1. FACILITY DESCRIPTION
1.1 Description of Licensed Activity
The Mill is located approximately 6 miles south of Blanding, Utah. The Mill processes
conventional uranium or uraniurnfvanadium ores to recover uranium and vanadium. In addition
to tbe processing of conventional ores, the Mill also processes alternate feed materials using
similar process steps and chemicals. The conventional ore is stored on the Ore Pad (shown on
the Site Layout Map included as Exhibit 3). Alternate feed materials are also stored on the Ore
Pad and may be stored in bulle form, tined burrito bags, liners or drums. In certain
circum tances, containerized altemale feed materials may be stored in locations off of the ore
pad.
All of the ores and feeds processed at the Mill contain natural uranium and its daughter products.
Uranium is in equilibrium with its daughters for conventional ores and is generally in various
degrees of disequjJib:dum with its daughters for alternate feed materials, depending on the
specific feed material. The descriptions of each alternate feed material are maintained by the
Mill's Radiation Safety Officer. However, the Mill does not receive, process or produce
enriched uranium of any sort, therefore there is no risk of a criticality accident at the Mill. The
products produced at the Mill include ammonium metavanadate (AMV), vanadium pregnant
liquor (VPL), vanadium pentoxide (V20 5), and yellowcake, or uranium concentrate (U30 8). The
VzOs and U30s producls are packaged in steel drums for shipment. The AMV is packaged in
either steel drwns or super-saks while the VPL i~ sold in liquid form in bulk.
Drums containing U308 and vanadium product are stored from time to time in a fenced, locked,
paved area in the Mill's restricted area, pending shipment offsite.
The Mill utilizes a semi-autogenous grind circuit (SAG mill) followed by a hot sulfuric acid
leach and a solvent extraction process to extract uranium and vanadium from ores, using large
amounts of sulfuric acid, sodium chlorate, kerosene, amines, ammonia and cau tic soda in the
process. The reagent storage tank locations m·e described in further detail in Section 1.2.9 below.
At any one time, there may by 1.4 million gallons of sulfuric acid, 63,000 gallons of anhydrous
ammonia, 220,000 gallons of kerosene, 20,000 gallons of cau tic soda and 30,000 gallon of
propane and various quantities of other reagents stored or located on site. See Sections 1.26,
1.27 and 1.29 for a more detailed discussion of the chemicals and reagents used and stored at the
site.
Tailings and wastes generated fTOm processing conventional ores and alternate feed materials are
disposed of permanently in fue Mill's lined tailings impoundments. The Mill's tailings cells are
comprised of four below grade engineered cells, Celll, 2, 3 and 4A. Liquids are stored in Cell
1, Cell3 and Cell 4A the active tailings cell. The liquid in the tailings cells is very acidic. In
addition to the tailings cells, there is also an emergency lined catchment basin ("Roberts Pond")
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 4 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
west of the Mill building. Solutions in this basin or the tailings cells should not be used to fight
fires in the Mill facility.
1.2 Description of Facility and Site
1.2.1 Site Drawing
The Mill facilities are shown on the Site Layout Map included as Exhibit 3 and on the General
Area Map included as Exhibit 4. See also Exhibit 7 for a listing and the locations of the main
shut-off valves.
1.2.2 Communication and Assessment Centers
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation area will serve as the initial assessment
center. Other_cororo_un_ic_ations and assessment centers will he set up_ in the_Mill's Office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
1.2.3 Assembly and Relocation Areas
When the evacuation alarm sounds or when persmmel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• North side of Tailings Celll; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The Radiation Safety Officer ("RSO")/Fire Chief or Shift Foreman will specify the
appropriate assembly site.
1.2.4 Fire Water Supply and Alarm Systems
a) Fire Water Supply
The fire water supply facilities include:
• 400,000 gallon Storage Tank of which 250,000 gallons are reserved for fire
emergencies; and
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• Centrifugal diesel driven pump rated at 2,000 gpm at 100 psi. This pump statts
automatically when the pressure in the fire main drops below 100 psi (See Figure 1,
Fire System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm.
b) Alarm System
The alarm systems include the following:
• public address system;
• hand held radios; and
• siren.
1.2.5 Office Building and Laboratory
a) Office Building
The office building (approximately 10,000 square feet) contains the administration offices,
radiation health and safety offices and the Mill laboratory. The central file vault and the main
computer system are also in this building. The ambulance is kept on the west side of the office
building near the safety office entrance.
b) Laboratory
The laboratory facilities contain the following:
• three flammable cabinets (keys required);
• chemical storage room south of main lab;
• seven fume hoods-hoods 1,2, 3 and 4 are in the chemical laboratory and hoods 5, 6
and 7 are in the metallurgical laboratory. Only hoods 1 and 2 may be used for
perchloric acid;
• outside laboratory chemical storage north of office building (key required); and
• perchloric acid storage vault located underground west of office building (key
required).
A wide variety of chemicals in small quantities are located in the Mill laboratory. These
chemicals range from acids to bases along with flammable metal compounds and peroxide
forming compounds. Oxidizers and organic chemicals are stored in a storage room in the
laboratory, which have a strong potential of producing harmful vapors if the containers are
damaged to the point that the chemicals are exposed. There are no acids stored in this storage
room. The acids (including but not limited to sulfuric, nitric, acetic perchloric, phosphoric and
hydrochloric acids) are stored in the main laboratory area in 2.5 liter or 500-ml bottles. MSDS
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books for all chemicals in the laboratory are located in the Laboratory, Safety Department, Mill
Maintenance office and Mill Central Control room.
c) Electrical
Electrical transformers and electrical switches are located in the laboratory at the east end of the
chemical storage room.
d) Fire Protection System
The fire protection systems in the office building and laboratory include:
• a fire hose station located on the east end o£ the office building. The station includes
two sets of tumout gear, two SCBA units and Incident Commander materials;
• automatic "wet" sprinkler system which is actuated at 212° F; and
• portable dry chemical extinguishers strategically located throughout the building.
1.2.6 Solvent Extraction Building
The solvent extraction (SX) building (approximately 21,000 square feet) houses the uranium and
vanadium solvent extraction circuits and the ELUEX circuit. The SX circuits may contain up to
200,000 gallons of kerosene (757 ,000 liters ) which has a flash point of 185° F.
Associated equipment in the SX building includes a temporary boiler located at the southwest
end of the SX building which maintains the temperature for the fire system.
Chemicals which may be encountered in the SX building include:
• Kerosene;
• Caustic Soda;
• Anhydrous Ammonia;
• Sulfuric Acid;
• Salt (Brine);
• Soda Ash;
• Ammonium Sulfate;
• Amines;
• Alcohol;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane .
The VPL product is stored in the SX building.
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a) Electrical
All electrical switches are located outside in the Mill Central Control room north of the SX
building. The main control panel for all of the equipment is located in the Central Control Room
in the main Mill building.
b) Fire Protection System
The SX building fire protection systems include:
• a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212°F; and
• portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure 1 in this Plan.
1.2.7 Mill Building
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, and drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
• Caustic Soda;
• Anhydrous Ammonia;
• Sulfuric Acid;
• SodaAsh;
• Ammonium Sulfate;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane.
The finished products which are contained in the mill building include AMY, V20 5 and U30 8 (or
yellowcake).
a) Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west comer of the mill building. Circuit control panels are located in the SAG mill control room,
the central control room, the vanadium roaster control room and the AMY area.
b) Fire Protection System
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The main mill building fire protection systems include:
• portable dry chemical extinguishers strategically located throughout the building; and
• water hoses throughout the building.
For fire hydrant and hose cabinet locations in the mill building refer to the Fire System
Schematic included as Figure 1 of this Plan.
1.2.8 Maintenance Shop/Warehouse/Change Room Building
This building (approximately 20,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located on the south end of the
building) and the personnel change rooms and lunch/training room (located on the extreme south
end of the building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
• the main maintenance shop area contains welding and cutting equipment, lathes,
presses, and drill presses;
• a carpenter shop which contains various saws and planes. Fiberglass work is also
done within this shop area and it is located at the northwest end of the maintenance
shop area;
• an electrical shop which is located south of the carpenter shop;
• a heavy equipment maintenance shop area is located at the north end of the
maintenance shop in the center of the building;
• a rubber room for rubber lining of equipment is located east of the equipment shop
area; and
• the maintenance shop office, instrument shop and tool room are located at the south
end of the maintenance shop area.
The warehouse area contains primarily dry good storage for repair parts and consumables for the
operation of the Mill. There is an electrical water heater for the change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in the
following locations:
• small quantities of flammable material such as starting fluid and spray paint are kept
in the warehouse;
• drums of new oil and anti-freeze are stored along the east wall of the equipment
maintenance area and on the east side of the warehouse on oil storage racks;
• used oil is stored in a tank located northeast of the equipment shop. The tank has a
capacity of approximately 5,800 gallons;
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• in the main maintenance shop area and the rubber room there are flammable storage
cabinets and east of the warehouse there is a trailer which is used to store flammable
items such as rubber cements, paints and fiberglass resins; and
• compressed gas cylinder storage, both empty and full is located outside, east of the
maintenance shop.
a) Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is located
on the east wall inside the Maintenance shop. Auxiliary electrical panels for the change room
and warehouse are located in the southwest comer of the warehouse area.
b) Fire Protection System
The fire protection system within the maintenance shop/warehouse/change room building
includes:
• "wet" automatic sprinkler system that releases at 212° F; and
• portable dry chemical extinguishers strategically located throughout the maintenance
area, warehouse area and the change room and lunch room.
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure 1).
1.2.9 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
• a sulfuric acid tank located northwest of the mill building which has a capacity of
approximately 1.4 million gallons;
• a storage tank for propane is located on the north edge of the Mill site, northwest of
the mill building. It has a storage capacity of 30,000 gallons;
• four sodium chlorate tanks located east of the SX building, north of the office
building and east of the pulp storage tanks. The two tanks east of the SX building are
for sodium chlorate storage and the other two tanks are for dilution of the sodium
chlorate;
• two anhydrous ammonia tanks located east of the SX building, with capacity of
31,409 gallons each;
• three kerosene tanks located east of the SX building, with a capacity of 10,152
gallons each;
• one caustic soda tank north of the SX building, with a capacity of 19,904 gallons; and
• three soda ash tanks which are located east of the SX building. One tank is the dry
soda ash tank with a capacity of 70,256 gallons. Two of the tanks are soda ash
dilution tanks with capacities of 16,921 gallons each.
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• diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore
pad. The gasoline storage capacity is 3,200 gallons, while diesel storage capacity is
8,000 gallons.
Other reagents are stored in steel barrels or super saks in a reagent yard located east of the office
building. Typical reagents which are stored in this yard include:
• polymers and flocculants;
• boiler feed water chemicals;
• methanol;
• tributyl phosphate;
• "dirty" soda ash and ammonium sulfate;
• SX amines and emulsion breakers;
• decyl alcohol;
• minimal amounts of acid in barrels; and
• used oil in drums and overpacks.
1.2.10 Boiler Fa__cilities
The main building (approximately 12,400 square feet) is located on the west side of the Mill site
and contains air compressors and water treatment facilities. To the north of the main building is
a building which houses a propane-fired boiler. The vanadium oxidation tank, oxidation
thickener, and pH adjustment tank are located south of the boiler house facilities.
a)
b)
Electrical
The main electrical panel for the boiler facilities is located outside of the building, on the
south wall.
Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically
located portable dry chemical extinguishers.
1.2.11 Sample Plant
The sample plant building (approximately 8,000 square feet) is located on the ore pad, east of the
maintenance shop/warehouse building. The sampling plant equipment has been removed from
the building and it is currently used as a storage area for maintenance.
a) Electrical
The electrical panel for the sample plant building is located on the east wall upstairs.
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b) Fire Protection System
There are no extinguishers or sprinkler systems in the sample plant.
1.2.12 Tailings Cells and Roberts Pond
TaiHngs and wastes generated from processing conventional ores and alternate feed materials are
disposed of permanent! y in the Mill's lined tailings impoundments. The Mill's tailings cells are
comprised of four below grade engineered cells, Cell 1, 2, 3 and 4A. Liquids are stored in Cell
1 Cell 3 and Cell4A the active tailings cell. The liquid in the tailings cells is very acidic. It also
contains virtually all of the radionuclides contained in the ores and alternate feed materials that
are processed at the Mill, other than uranium, which is included in the tailings at approximately
5% of its concentration in the ores and alternate feed materials.
In addition to the tailings cells, there is also an emergency lined catchment basin (Roberts Pond)
west of the mill building. Solutions in this basin or the tailings cells should not be used to fight
fires in the Mill facility.
1.2.13 Stack Heights, Diameters and Typical Flow Rates
Emissions from the Mill process are in the form of air emissions from exhaust stacks and
solid/liquid tailings which are stored in the Mill's tailings cells located west/southwest of the
main Mill building. The major exhaust stack parameters are shown in the following table.
Height (ft from Diameter Estimated Flow Rate
Description surface) (inches) (cfm)
Leach Exhaust -100 36 13,700
Yell ow Cake Drying -85 18 4,000 per stack
(3 stacks)
Vanadium Roasting & -85 38 4100
Fusion
There are also smaller exhaust stacks associated with the Laboratory in the Mill Office building
and the boiler exhaust stack.
1.2.14 Main Shut-Off Valves
The main shut-off valves and their locations are indicated on Exhibit 7.
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1.3 Description of At;ea Near the Site
The site and sun·ounding area are indicated on the general area map included as Exhibit 4 and on
the Drainage Map indicated on Exhibit 5.
The Mill lies within a region designated as the Canyon Lands section of the Colorado Plateau
physiographic province. Elevations in the region range from approximately 3,000 feet in the
bottom of canyons to over 11,000 feet among the peaks of the Henry, Abajo and La Sal
Mountains. The average elevation for the area, excluding deeper canyons and isolated mountain
peaks is about 5,000 feet. The average elevation at the Mill site is approximately 5,600 feet
above mean sea level.
Although varying somewhat with elevation and terrain, the climate in the vicinity of the Mill can
be considered as semi-arid with normal annual precipitation of about 13.4 inches. Primary land
uses in the region include livestock grazing, wildlife range, recreation, and exploration of
minerals, oil and gas. The area within 5 miles of the Mill site is predominantly range land owned
by residents of Blanding or of the White Mesa Ute community of the Ute Mountain Ute Tribe.
There are no pereriilial surface waters on or iii the vicinity of the Mill site. Cornil Creek, located
east of the site is an intermittent tributary to Recapture Creek. Westwater Creek is an
intermittent tributary of Cottonwood Wash, with its confluence with Cottonwood Wash located
1.5 miles west of the Mill site. Both Recapture Creek and Cottonwood wash are similarly
intermittent. They both drain to the south and are tributaries to the San Juan River
approximately 18 miles south of the Mill Site.
The Mill site is near Utah State Highway 191 and can be accessed by a paved access road from
the highway to the Mill facilities. This would be the primary route for access of emergency
equipment and evacuation. A municipal airport is also located approximately 3 miles north of
the Mill site. There are no significant potential impediments to traffic flow in the area, such as
rivers, drawbridges, railroad grade crossings, etc.
The nearest residence to the Mill is approximately 1.2 miles to the north of the Mill, the next is a
residence approximately two miles north of the Mill, followed by the community of White Mesa,
about 3.5 miles to the south. The City of Blanding is located approximately 6 miles to the
northeast. Exhibit 6 shows these population centers.
The local fire station and police station are located in Blanding, Utah. Blanding also has a
medical clinic. The closest hospital is located in Monticello, Utah, approximately 30 miles north
of the Mill. St. Mary's hospital in Grand Junction, Colorado, approximately 3 hours drive by
highway, is the nearest trauma center. Specialized medical attention for radioactive
contamination or chemical exposure would be located either in Salt Lake City at the University
of Utah Medical Center (approximately 5 hours drive by highway), or in Denver, Colorado
(approximately 7 hours drive by highway).
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There are 110 faci lities close to the Mill sile that could presenL potential protective acti(>n
problems. All schools, arenas, stadiums, prisons, nul'Sing homes and hospitals are located in
Blanding, approximately 6 miles north of the Mill site.
There nre no sites of potential eme(gency significance such as liquefied petroleum gas (LPG)
terminals, chemical plants, pipelines, electrical lt~msformers and underground cables in the
vicinity of the Mill, oU1er than Mill site facilities described in detail in Section 1.2 above.
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2. TYPES OF ACCIDENTS
2.1 Description of Postulated Accidents
The following is a description of each type of radioactive materials and other accident that could
potentially occur at the Mill site that could require a1i emergency response.
2.1.1 Unloading, Storage of Ammonia
A release of anhydrous ammonia could occur through tank failure, overfilling, and failures of
piping, loading hoses, hose couplings, and emergency relief valves.
No radiological impacts are foreseen from a release of anhydrous ammonia. However, in the
event of an ammonia tank spill, the material would be expected to evaporate quickly. Release of
the entire contents of one or both of the onsite ammonia tanks during a short period of time could
result in a significant release to the environment (the atmosphere) of a hazardous material that
could require a response by an offsite organization to protect persons offsite. Such a release is
addressed hi the Mill's Risk Management Pfan, required under Section 1i2r of the Clean Air
Act, a copy of which plan is attached hereto as Appendix K. The Risk Management Plan
contemplates a worst case scenario of the release of the entire 140,000 pound contents of one of
the anhydrous ammonia tanks over a 10 minute period, which could result in a dangerous cloud
of anhydrous ammonia that could extend 12 miles from the point of origin at the Mill. An
alternate scenario of a release of 500 pounds of ammonia over a one minute period could result
in a dangerous cloud of anhydrous ammonia that extends 0.8 miles from the point of origin.
Therefore, an uncontrolled release of ammonia that could result in the release of 100 or more
pounds of ammonia is classified as a Site Area Emergency. Any other uncontrolled release of
ammonia, other than a minor release, is classified as an Alert. A minor release of ammonia is
classified as an On-Site Emergency. See Section 3 below for a discussion of the significance of
these classifications.
A minor release of ammonia would be any release that is expected to be of a small amount (less
than 7 gallons (36 pounds)) that is not expected to be uncontrolled. Minor releases of ammonia
are not subject to the notification requirements of this Plan; however they are subject to the
procedures for response to an ammonia release outlined in Appendix A.
The procedures for response to an ammonia release are outlined in Appendix A. An
uncontrolled release of 100 lbs or more of anhydrous ammonia would also require that notice be
given to the Community Emergency Coordinator for the local Emergency Planning Committee
under the Emergency Response and Community Right to Know Act (see Section 10 below). The
procedures for giving such notifications are also set out in Appendix A to this Plan.
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2.1.2 Ammonia Explosion in a Building
An ammonia-air explosive mixture could be formed inside the Mill and SX buildings if a line
ruptured. Existing controls include emergency powered vent fans, operator presence at all times
for surveillance, and one-half inch piping that minimizes potential release amounts.
Radiological impacts from the explosion would be minimal and mo t likely contained within the
restricted area, unless the explosion resulted in a fire (see Sections 2.1.6 and 2.1.7 below for the
emergency response procedmes to follow in the event of a fire). An ammonia explo ion would
be classified as a Site Area Emergency if it involved the uncontrolled release of greater than
IOOlbs of anhydrous ammonia, and as an Alert if it involved an uncontrolled release of 36 lbs (7
gallons) to 100 lbs of anhydrous ammonia. Releases of less than 7 gallons are classified as On-
Site Emergencies (see Section 3 for significance of this classification). Any contamination
would be recycled or disposed of, as appropriate.
The procedure for response to an ammonia explosion are set out in Appendix B.
2.1.3 Unloading/Storage of Propane/Propane Fire or Explosion
A release of propane could occur through tank failure, overfilling, and failures of piping, loading
hoses, hose couplings, and emergency relief valves.
Daily inspections of the propane tank for leaks and integrity are conducted to minimize potential
hazards associated with propane leaks.
No radiological impacts are predicted for a release of propane, unless the release is a ·sociated
with a fire. Inhalation of propane is also Jess a hazard than inhalation of ammonia, and would
not be expected to be a significant threat to the public, although it could pose hazards to workers
in the immediate vicinity of the release. Vapors can cau e dizziness or asphyxiation without
warning.
However, there is a significant risk of fire or explosion in the event that the release was
uncontrolled and the propane was ignited. Such a release is addressed in the Mill's Risk
Management Plan, required under Section 112r of the Clean Air Act, a copy of which plan is
attached hereto a Appendix K. The Risk Management Plan contemplates a worst case scenario
of the release of 110,000 pounds of propane, resulting in a vapor cloud explosion extending 0.40
miles from the point of origin. An alternate scenario of a release of 500 pounds of propane could
result in a vapor cloud explosion extending 0.01 miles from the point of origin. The propane
tank is located approximately 0.5 miles from Highway 191 and the nearest Mill property
boundary, o a propane explosion is unlikely to have direct offsite impacts. However, as a
maHer of caution, notice i provided to offsite authorities.
An uncontrolled release of propane that could result in the possibility of an explosion is
classified as an Alert. A minor release of propane (see below) is classified as an On-Site
Emergency. See Section 3 below for a discussion of the significance of these classifications.
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A minor release of propane would be any release that is expected to be of a small amount and
that is not expected to be uncontrolled or pose a risk of explosion. Minor releases of propane are
not subject to the notification requirements of this plan; however, they are subject to the
procedures set out in Appendix C.
The procedures for response to a propane release are outlined as Appendix C.
2.1.4 Leach Tank Failure
The rubber lined leach tanks contain the nearly boiling ore/sulfuric acid slurry. Tank failure due
to corrosion and break-out is a possibility. Procedures and practices are in place and functioning
to minimize this possibility. Failure due to loss of structural integrity is also possible. The tanks
are evaluated periodically to determine structural stability and the potential need for replacement.
Radiological impacts are minimal from an occurrence of this type. Any release of material
would be contained in the leach area or would flow to the lined catchment basin (Roberts Pond)
west of the Mill for containment, as designed.
Accidents of this type are classified as On-Site Emergencies. See Section 3 for the significance
of this classification.
The procedures for response to a leach tank failure are outlined in Appendix C and in the Mill's
Spill Prevention, Control, and Countermeasures Plan For Chemicals and Petroleum Products (the
Spill Response Plan"), a copy of which is attached as Appendix L to this Plan.
2.1.5 Sulfuric Acid Storage Tank Failure
The Mill's sulfuric acid storage tanks consist of one large above ground tank that can hold up to
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons each. Tank failure
due to corrosion and break out is possible. Failure due to loss of structural integrity, as well as
failures of piping, loading hoses, hose couplings, and emergency relief valves.
A sulfuric acid tank spill would flow via an above ground path to tailings Cell 1 or to Roberts
Pond.
There would be no radiological impacts associated with an accident of this type. Nor would
there be any significant hazards to the environment from off gases from any such release.
However, there would be potential hazards to workers in the close vicinity from contact with
sulfuric acid or inhalation of sulfuric acid vapors, and a release to the surface soils.
The large tank is equipped with a high level audible alarm which sounds prior to tank overflows.
The two smaller tanks are also equipped with high level audible alarms.
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Accidents of this type are classified as On-Site Emergencies, because they will not lead to a
significant release to the environment of radioactive or other hazardous material. See Section 3
below for the significance of this classification.
The procedures for response to a sulfuric acid tank failure are outlined in Appendix D and in the
Mill's Spill Response Plan.
2.1.6 SX Fire
The possibility of a major fire in the solvent extraction building is remote, as very strict safety
precautions are adhered to. This part of the process is kept isolated and in separate buildings due
to the large quantities of kerosene present. These facilities are equipped with an independent fire
detection and protection system. In the event of a fire in the solvent extraction building, the fire
suppression system delivers foam to the affected area. The foam is designed to spray for 25
minutes, followed by water at 100 psig and up to 2,000 gpm.
In spite of the safety precautions, a major fire in the solvent extraction building could occur.
NRC staff concluded in NUREG-1140 that a fire in the solvent extraction circuit is the accident
of greatest significance for emergency preparedness for a uranium mill, from the point of view of
potential radiological impacts offsite. However, NRC staff concluded that the calculated dose
from this type of accident is small (0.1 rem or less) because of the very low specific activity of
the uranium and the low volatility of the uranium compounds, which causes a low release
fraction. NRC staff noted that these low release fractions are the reason why no offsite ground
contamination was ever detected due to the historic fires that have occurred at other uranium
mills. In the 1980s, two solvent extraction fires occurred at other uranium Mills. Neither fire
resulted in appreciable release of uranium to the unrestricted environment, and essentially
complete recovery of the uranium was obtained.
As a result, NRC staff concluded in NUREG-1140 that no credible accident would justify
emergency protective actions because radiation doses to the public offsite from an accident
would be below the EPA's protective action guides. Also, the quantity of uranium inhaled is
below the quantity where chemical toxicity effects are observed. Thus, neither radiation doses
nor chemical toxicity from licensed materials is a concern with respect to the need for prompt
protective actions.
If a major fire were to occur, the radiological environmental effects would be confined within a
few hundred feet of the buildings. Recovery of uranium that would be scattered by the burning
solvent would be accomplished. Uranium-contaminated soil would be processed in the Mill
circuit or disposed of in the Mill's tailings cells, as appropriate. The Mill would be required by
existing regulations to take certain actions. Among these, the Mill would be required by 10 CPR
20.201(b) to conduct surveys (offsite if appropriate) to determine whether the NRC's limits on
radioactivity in effluents to unrestricted areas in 10 CFR 20.106 were exceeded. A major fire
would also require immediate notification of the Executive Secretary by telephone (10 CFR
20.403)
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Consequently, the impact from such an event at the Mill would be limited to (1) cleanup of
contaminated material, (2) replacement of destroyed Mill components, and (3) a short duration
release of combustion products to the atmosphere.
A major SX fire is classified as an Alert. See Section 3 for the significance of this classification.
The procedures for response to an SX fire are outlined in Appendix E.
2.1. 7 Other Fire
A fire could start anywhere in or around Mill facilities as a result of a number of causes, such as
lightning strikes, electrical malfunction, human error etc. However, at the Mill there is an
increased risk of fire and of severe onsite or offsite consequences in the following areas, due to
the nature of the chemicals stored or used at those areas:
• SX Building (see Section 2.1.6 above);
• Propane Tanks (see Section 2.1.3 above); and
• Lab or Lab Storage Area.
Fires could start in these areas due to equipment malfunction or human error and the intensity
and consequences of the fire could be severe, although direct radiological hazard from any such
fires would be expected to be relatively low (see Section 2.1.6 for a discussion of the radiological
impacts of an SX fire, which is the type of accident con idered to have the highest risk of
radiological impacts at a uranium mill). To the extent that facilities arc damaged as a result of
any such fire, there could be secondary radiological hazards, such as fire damage in the
yellowcake product drying, packaging and storage areas that would have to be evaluated.
As discussed in Section 2.1.6 above, an uncontrolled fire in the SX building is classified as an
Alert. All other uncontrolled fires in Mill buildings are classified as On-Site Emergencies. See
Section 3 for a discussion of the significance of these classifications.
Should a fire (other than an SX fire) occur, the procedure outlined in Appendix F for reporting
and responding to fires will be followed (the procedure to be followed for an SX fire is outlined
in Appendix E).
2.1.8 Tornado
Although this is highly unlikely, a tornado could occur at the Mill. A severe tornado could cause
buildings and other structures to collapse, chemical or gas releases, major fires as well as general
panic. The environmental impacts from a tornado could be the transport of tailings solids and
liquids, ores or product from the Mill area into the environment. This dispersed material would
contain some uranium, radium, and thorium. An increase in background radiation could result,
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and, if sufficient quantities are detected and isolated, they would be cleaned up. However, NRC
staff have concluded in NUREG-1140 that while tornadoes could release a large amount of
radioactive material, they spread the material so greatly that resulting doses are very small. As a
result, tornadoes are not discussed further in NUREG-1140 and are not considered to be a
significant radiological risk at uranium mills.
However, to the extent that a tornado has caused or is likely to result in an ammonia leak or
propane release, an SX building fire or a breach of the Mill's tailings cells, it would be classified
as a Site Area Emergency or Alert depending on which one of these other accidents resulted
from the tornado. All other tornadoes would be classified as On-Site Emergencies. See Section
3 below for the significance of these classifications.
In the event of a major tornado, the procedures outlined in Appendix G will be followed.
2.1.9 Major Earthquake
Although this is highly unlikely, an earthquake could occur at the Mill. A severe earthquake
could cause buildings and other structures to collapse, chemical and/or gas releases, major fires
as well as general panic. NRC staff concluded in NUREG-1140 that earthquakes were not
identified as leading to significant releases of radionuclides unless they were followed by a fire.
To the extent that an earthquake has caused or is likely to result in an ammonia leak or propane
release, an SX building fire or a breach of the Mill's tailings cells, it would be classified as a Site
Area Emergency or Alert, depending on which one of these accidents resulted from the
earthquake. All other major earthquakes would be classified as On-Site Emergencies. See
Section 3 for the significance of these classifications.
In the event of a major earthquake the procedures outlined in Appendix G will be followed.
2.1.10 Tailings Accidents
2.1.10.1 Flood Water Breaching ofRetention System
In general, flood water breaching of tailings embankments presents one of the greatest dangers
for the sudden release of tailings solids and impounded water. The tailings cells are designed
with sufficient freeboard (at least three feet) to withstand back-to-hack 100-year storm events or
40% of the probable maximum flood (PMF) followed by the 100-year storm event. The flood
design is equivalent to 15 inches of rainfall. In addition, the tailings dikes were designed in
accordance with NRC regulations and allow a sufficient margin of safety even in the event of an
earthquake.
The possibility of floods in Westwater Creek, Corral Creek, or Cottonwood Wash causing
damage to the tailings retention facility is extremely remote. This is due to the approximately
200 foot elevation difference between the streambeds of the creeks and the toe of the tailings
dikes.
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Flood water breaching a tailings embankment is classified as an On-Site Emergency, because it
is unlikely that any re1eases to the environment will leave the Mill properly, and in the event that
any contamination were to leave the property, it is Llnlikely that the release is expected to require
a response by an offsite response organi~alion to protect persons offsite. See Section 3 below for
the significance of this classification.
In the event of a Flood Water Breach of the tailings retention system, to procedures in Appendix
H will be followed.
2.1.10.2 Structural Failure of Tailings Dikes
All tailings dikes have been designed with an ample margin of safety as per NRC regulations.
This has included design calculations showing dike stability even when the dike is saturated with
moisture during a seismic event, the most severe failure mode. In addition, the tailings discharge
system is checked at least once per shift during operation, or once per day during Mill standby.
NRC staff concluded in NUREG-1140 that tailings pond failures also release a large quantity of
material. However, NRC taff concluded that rapid emergency response is not needed to avoid
doses exceeding protection action guides because dose rates at a spill site are very low. NRC
staff concluded that an appropriate response is to monitor drinking water, especially for radium-
226, to be sure that drinking water standards are met Gamma ray monitoring of the ground i
also appropriate to determine where the tailings have been deposited. However, NRC staff
concluded that ground contamination present Little immediate hazard to the public becau e the
gamma dose rates are low. Gamma dose rates in contact with tailings should be les than 0.1
mR/hr. A clean-up of the spilled tailings would be expected, but this could be done effectively
without pre-existing emergency preparedness.
Although U1e di charge from a dike failure would soon cross the restricted area boundary, the
flow path is over three miles in length before leaving the Mill property. In the event of a dam
failme, large operating equipment will be mobilized to construct temporary earthen dikes or
berms downgradient to the failed dike. In addition, the State of Utah, Division of Radiation
Control Executive Secretary (the "Executive Secretary), MSHA, and State of Utah, Department
of Natural Resources, Division of Dam Safety will be notified. The contamination from such an
event would be cleaned up and returned to the tailings area.
A tailings dam failure is classified as an On-Site Emergency, because it is unlikely that any
releases to the environment will leave the Mill propetty. and in the event that any contamination
were to leave the property, it is unlikely that the relea e is expected to require a response by an
offsite response organization to protect persons offsite. See Section 3 for the significance of this
classification.
In the event of a tailings dam failure the procedures outlined in Appendix H will be followed.
2.1.10.3 Seismic Damage to Transport System
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In the event of a seismic rupture of a tailings slurry pipeline, the released slurry will be contained
in the tailings cells regardless of the quantity released. The tailings retention system pipe is in
the same drainage basin as the retention system. Any tailings slurry released by a pipe rupture,
no matter what the cause, would flow downhill where it would be impounded inside a tailings
cell.
If a break occurred, the pumping system would be shut off, personnel removed from the
immediate area, and the Executive Secretary notified. The break would be repaired and the
affected area cleaned up in the safest and most expeditious manner. The advice and direction of
the Executive Secretary would be sought and heeded throughout the episode.
A seismic rupture in the tailings slurry pipeline would be classified as an On-Site Emergency.
See Section 3 for the significance of this classification.
In the event of a rupture in the tailings slurry pipeline the procedures outlined in Appendix H
will be followed.
2.1.11 Terrorist/Bomb Threat
In the event that any person should receive a threat of a bomb, the procedure set out in Appendix
I should be followed.
Because of the unknown nature of the risk, a terrorist/bomb threat is classified as an Alert. See
Section 3 for the significance of this classification.
In the event of a terrorist/bomb threat, the procedures in Appendix I will be followed.
2.1.12 Chemical or Reagent Spills
Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow and dikes and/or curbs are constructed around process and
storage tanks (excluding the water tank) to confine the material in the event of a tank spill,
However, as an operating facility, it is possible for spills of chemicals or reagents to occur from
time to time. Unless such a spill qualifies as an ammonia release (see Section 2.1.1 above), a
propane release (see Section 2.1.3 above) or a sulfuric acid release (see Section 2.1.5 above), the
spill will be considered a minor spill and will be addressed and cleaned up in accordance with
the Mill's Spill Response Plan.
It is unlikely that any such minor spills will impact the environment if cleaned up in accordance
with the Mill's Spill Response Plan. The entire Mill facility is graded such that run-off will drain
into the Mill's tailings cells.
A copy of the Mill's Spill Response Plan is included as Appendix L to this Plan.
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Any such minor spills are classified as Non-Subject fucidents. See Section 3 for the significance
of this classification.
2.1.13 Transportation Accident on the Mill Property Involving a Spill of Yellowcake
In the event of a transportation-related accident on the Mill property involving a spill of
yellowcake, immediate containment of the product will be achieved by covering the spilJ area
with a plastic sheeting or equivalent material to prevent wind and water erosion. If sheeting is
not available, and depending on where the spill occurs, soil from the surrounding area may be
used. Perimeter ditching will be used to contain the pill if it should occur in an area where
runoff could result from precipitation.
All human and vehicular traffic through the spill area will be restricted. The area would be
cordoned off if possible. All persons not patticipating in the accident response will be restricted
to 50 feet from the accident site. Local law enforcement officers will be notified and may be
asked to assist in controlling traffic and keeping unauthorized persons out of the spill area.
Covered containers and removal equipment, i.e., large plastic sheeting; radioactive signs, t•opes,
hoses, shovels, vacuums, axes, stakes, heavy equipment (front-end loaders, graders, etc.), will be
available to clean up the yellowcake. A Radioactive Material Spill Kit L available and tmder the
control of the Radiation Department. If conditions warrant, water will be applied to the spilled
yellowcake in a fine spray to assist in dust abatement.
Gloves, protective clothing and any personal clothing contaminated during cleanup operations
will be encased in plastic bags and kept in the plant area for decontamination or disposal.
Any fire at the site will be controlled by local experienced fire fighting personnel wearing
appropriate respiratory protective equipment.
Response team members will have a thorough knowledge in basic first aid and of the physical
hazards in inhalation, ingestion, or absorption of radionuclides. Team members will adequately
protect themselves.
As per R313-15 requirements, the Executive Secretary will be notified promptly of any accident
of this type.
Any minor spills are classified as Non-Subject Incidents. See Section 3 for the significance of
this classification.
2.1.14 Offsite Transportation Accidents
2.1.14.1 Concentrate Shipments
Concentrates will be shipped in sealed 55-gallon dmms built to withstand normal handling and
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minor accidents. Each mum will contain approximately 900 pounds of yellowcake. A
maximum of 43 drums will be shipped in each closed van. The drums will be sealed and marked
"Radioactive LSA" (low specific activity), and the trucks will be properly marked. Because
most of the radioactive daughter products of uranium are removed in the extraction process and
radioactive buildup of daughter products is slow, yellowcake has a very low level of
radioactivity and is therefore classified by the Department of Transportation as a low specific
activity material.
The environmental impact of a transportation accident involving release of the product would be
minimal. Yellowcake, having a high density, even in a severe accident in which multiple drums
are breached, would not easily disperse. More than likely, the drums and any released material
would remain within the damaged vehicle or in an area of close proximity of the accident site.
Driver or carrier instructions are given to each driver of each transport leaving the plant site with
a load of yellowcake. These instructions will consist of an explanation of the product,
preliminary precautions at lhe accident site, whom to notify and what to do in case of fire. A
copy of these instructions is included in the Mill's Transportation Accidents Plan, a copy of
which is attached as Appendjx M to this Plan.
Mill persom1el would respond if reque ted fo1· the initial spill response to handle any yellowcake
transport accident. A procedure for this likelihood is included in the Mill's Transportation
Accidents Plan. DUSA may contract with a carrier or firm properly trained to handle any
yellowcake transport accident.
Offsite accidents involving the transportation of product concentrates are classified as Non-
Subject Incidents. See Section 3 for the significance of this classification.
In the event of an offsite accident involving a spill of yellowcake, the procedures outlined in the
Mill's Transportation Accidents Plan, attached as Appendix M hereto, will be followed.
2.1.14.2 Ore or Alternate Feed Material Shipments
Ore is shipped in 20 to 25 ton shipments in highway trailers that are covered by tarpaulins. The
truck trailers are labeled "Radioactive LSA". Because the ore is typically in the form of large
particles and is typically wet (2% to 5% moisture), the potential for a significant release from an
accident involving an ore shipment truck is quite small.
Alternate feed materials can be transpmted to the Mill in a number of conveyances. Most
typically, alternate feed materials are either shipped in bulk in intermodal containers (either with
or without a secondary containment such as a supersac), or in teel drums (possibly in plastic
overpacs) in the back of a van trailer. Bulk shipments in intermodal container are labeled
"Radioactive LSA". For bulk materials, the potential release from an accident is similar to
potential releases from an accident involving conventional ores, but this may vary depending on
the feed material and the manner of conveyance. The potential release from alternate feed
materials that are transported in drums will vary, depending on the particular alternate feed
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material, and in some cases could be equal to or exceed the risks associated with transportation
of yellowcake.
In the event of an accident, the transportation company will respond to clean up any spilled
material and ensure that the area is clean. Mill personnel will support the transportation
contractor in cleaning up the affected area and radiological scanning of the impacted area.
Offsite accidents involving the transportation of ores and alternate feed materials are classified as
Non-Subject Incidents. See Section 3 below for the significance of this classification.
2.1.14.3 Reagent Shipments
Reagents are shipped in properly marked trailers and the driver are trained in hazardou materials
transportation and accident procedures. In the event of an accident, all of the reagent supplier '
transportation contractors are required to have emergency response contractors to respond to an
accident and a potential spill. Many of the reagents that are used at the Mill are shipped on a
daily basis to other industrial facilities throughout the United States. The potential for an
accident is minimized due to quick respo11se of the transportation contractor's emergency
response team and the training of many of the country's emergency-response services.
Offsite accidents involving the transportation of reagents are classified 1:1· Non-Subject Incidents.
See Section 3 below for the significance of this classification. However, the State of Utah
Division of Radiation Control (80 1-536-4250) should be notified within 24 hours of the incident.
2.1 Detection of Accidents
Mill personnel perform a number of daily and weekly inspections of the Mill facilities. These
are:
• The Mill's Shift Foremen conduct inspections of all facility areas each operating shift;
• The Mill's RSO or designee performs a daily inspection of all facility areas;
• Mill personnel perform daily, weekly, monthly and quarterly inspection of the Mill's
tailings cells; and
• The Mill's RSO or designee performs weekly inspections of all areas of the Mill.
These inspections, particularly the shift and daily inspections provide a means for Mill personnel
to detect and alert the Mill's operating staff of any abnormal ope:rating condition or of any other
danger to safe operations. Thes1e in pections, along with the observations of operating personnel
in any impacted area, are the primary means of detecting the accident and alerting the operating
staff for chemical or gas leaks, any fires in areas that do not have fire detection equipment, or
any impairment to the tailings cells.
For areas of the Mill with fire detection equipment, such as the SX Building, the office building
and the Maintenance/Warehouse Building, in addition to the foregoing inspections, the fire
detection equipment would be expected to also provide an early warning of a fire.
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Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow.
For terrorist or bomb threats, the threat itself would provide the means of detection of the
incident. Where no threats are given, suspicious activity would be observed during the shift and
daily inspections. In addition, the Mill employs surveillance cameras in a limited number of
areas, which are intended to aUow Mill personnel to monitor product storage areas and certain
access poinls to the facility.
The required responses to any detected accidents are set out in Section 2.1 above and in
Appendices A through I for the various types of accidents.
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3. CLASSIFICATION AND NOTIFICATION OF ACCIDENTS
In this Emergency Response Plan, accidents have been classified into four categories as
described below. It should be noted that Reg. Guide 3.67 concludes that fuel cycle and material
facilities, such as the Mill, do not present the same degree of hazard (by orders of magnitude) as
are presented by nuclear power plants. Thus the classification scheme for the Mill, which has
four classes of accidents (Alerts, Site Area Emergencies, On-Site Emergencies and Non-Subject
Incidents), is different from the classification scheme for other nuclear facilities, which have two
classes of accidents (Site Area Emergencies and Alerts).
Reg. Guide 3.67 provides that "[t]he NRC intends that licensees be allowed to have a single
emergency plan that can apply to all licensee needs and regulatory requirements. To this end it
should be understood that a licensee may wish to include in the emergency plan some incidents
that do not fall within the jurisdiction of the NRC. For example, the licen ee may wish to
include industrial accidents or fires unrelated to the licensee's work with nuclear material . The
licensee may include such incidents in the emergency plan."
As a result, this Plan includes O.n-Site Einergericies, most of which do not involve risks of offsite
releases of radiation and are therefore not specifically required by Reg. Guide 3.67 to be
included in an emergency response plan for the Mill, and Non-Subject Incidents, which are
incidents that are addressed by other plans (such as the Mill's Spill Response Plan and
Transportation Accidents Plan) and that either involve incidents that could occur on site but that
would not involve risks of offsite releases of radi.onuclides or that involve offsite accidents, and
for these reasons are not required by Reg. Guide 3.67 to be included in this Plan. These On-Site
Emergencies and Non-Subject Incidents are included in this Plan in order to compile all potential
emergencies into one Plan. Although in some cases this merely involves referencing the type of
accident or incident and then referring the reader to another plan, the pwpose is to allow Mill
personnel to have a reference source that will allow them to be able to respond quickly to each
type of incident.
3.1 Classification System
At the Mill, there are four classes of accidents, Alerts, Site Area Emergencies, On-Site
Emergencies and Non-Subject Incidents, described as follows:
a) Alert
An Alert is defined as an incident that has led or could lead to a release to the environment of
radioactive or other hazardous material, but the release is not expected to require a response by
an offsite response organization to protect persons offsite. An Alert reflects mobilization of the
Mill's emergency response organization, either in a standby mode that will activate some
portions of the Mill's organization or full mobilization, but does not indicate an expectation of
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offsite consequences. However, an Alert may require offsite response organizations to respond
to onsite condition such as a fire.
The following potential accidents are classified as Alerts:
• An uncontrolled release of 36 pounds (7 gallons) or more but less than 100 pounds of
anhydrous ammonia (see Section 2.1.1);
• An ammonia explosion that involves a release of 36 pounds (7 gallons) or more but less
than 100 pounds of anhydrous ammonia (see Section 2.1.2);
• An uncontrolled release of propane that could result in an explosion (see Section 2.1.3);
• A major fire in the SX building (see Section 2.1.6); and
• A terrorist/bomb threat (see Section 2.1.11)
b) Site Area Emergency
A Site Area Emergency is defined as an incident that has led or could lead to a significant release
to the environment of radioactive or other hazardou material and that could require a response
by an offsite organization to protect persons offsite. A Site Area Emergency reflects full
mobilization of the Mill's emergency response organization and may result in requests for offsite
organizations to respond to the site.
Although it is unlikely that a Site Area Emergency requiring offsite actions will occur at a fuel
cycle or materials facility such as the Mill, the Mill must nevertheless be able to recognize
potential offsile hazards and make the required notifications in such a manner that offsite
response organizations can take appropriate actions, such as sheltering or evacuating persons in
the affected area.
Accordingly, the following potential accidents have been classified as Site Area Emergencies,
because they could require a response by an offsite organization to protect persons offsite:
• An uncontrolled release of 100 lbs or more of anhydrous ammonia (see Section 2.1.1);
and
• An ammonia explosion that involves a release of 100 lbs or more of anhydrous ammonia
(see Section 2.1.2).
c) On-Site Emergency
An On-Site Emergency is defined as an incident that is of a nature that has not led or could not
lead to a significant release to the environment of radioactive or other hazardous material, and
hence does not qualify as an Alert or a Site Area Emergency, but that nevertheles could pose
significant and unusual safety hazards to workers at the site, and is therefore subject to the
procedures under this Plan.
The following potential accidents are or could be classified as On-Site Emergencies:
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• A minor release (less than 36 lbs (7 gallons)) of anhydrous ammonia that is not
uncontrolled (see Section 2.1.1);
• An ammonia explosion in a building, unless this results in a fire in the SX building, an
uncontrolled release of 36 pounds (7 gallons) or more of anhydrous ammonia or an
uncontrolled release of propane that could result in an explosion, in which case the
classifications applicable to those other incidents would apply (see Section 2.1.2);
• A minor release of propane that is not uncontrolled and could not lead to an explosion
(see Section 2.1.3);
• A leach tank failure (see Section 2.1.4);
• A sulfuric acid storage tank failure (see Section 2.1.5);
• A fire (other than a major fire in the SX building) (see Section 2.1.7);
• A tornado, unless thl results in a fire in the SX building, an uncontrolled release of
anhydrous ammonia or propane, in which case the classifications applicable to those
other incidents would apply (see Section 2.1.8);
• A major earthquake, unless this results in a fire in the SX building, an uncontrolled
release of anhydrous ammonia or propane, in which case the classifications applicable to
those other incidents would apply (see Section 2.1.9); and
• Tailings Accidents
o A flood water breaching of the tailings retention system (see Section 2.1.10.1)
o Structural failure of a tailings dike (see Section 2.1.10.2); and
o Seismic damage to the tailings transportation system (see Section 2.1.10.3).
d) Non-Subject Incidents
A Non-Subject Incident is defined as an incident that involves an accident of a specific nature
that is covered under a different plan and is not subject to this Plan but is listed in this Plan for
informational purposes only.
The following potential incidents are or could be classified as Non-Subject Incidents:
• A chemical or reagent spill (other than a release of anhydrous ammonia or propane, or a
sulfuric acid leak or spill). These types of spills are covered by the Mill's Spill Response
Plan (see Section 2.1.12);
• A transportation accident on the Mill property involving a spill of yellowcake. These
accidents are covered by the Mill's Spill Response Plan (see Section2.1.13); and
• An offsite transportation accident
o Concentrate shipments. These types of accidents are covered by the Mill's
Transportation Accidents Plan (see Section 2.1.14.1);
o Ore or alternate feed material shipments (see Section 2.1.14.2); and
o Reagent Shipments (see Section 2.1.14.3).
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3.2 Notification and Coordination
3.2.1 Alert
The purpose of declaring an Alert is to ensure that emergency personnel are alerted and at their
emergency duty stations to mitigate the consequences of the accident, that the emergency is
properly assessed, that offsite officials are notified, and that steps can be taken to escalate the
response quickly if necessary.
An Alert, like a Site Area Emergency, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Radiation Control. This is because there is a potential for offsite consequences.
The actions to be taken in the event of an Alert vary somewhat depending on the incident. The
actions to be taken for each incident described in Section 2.1 above that is classified as an Alert
are set out in the various subsections in Section 2.1 and corresponding Appendices A through I
to this Plan that relate to the specific incidents. The actions set out in the Appendices describe,
to the extent appropriate for each incident, how and by whom the following actions will be taken
with respect to each specific incident:
• Decision to declare an Alert (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that an Alert has been declared
(normally within 15 minutes of declaring an Alert);
• Notification to the State of Utah Division of Radiation Control immediately after
notification of offsite authorities, and in any event within one hour of the declaration of
an Alert;
• Decision to initiate any onsite protective actions;
• Decision to escalate to a Site Area Emergency, if appropriate;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
3.2.2 Site Area Emergency
The purpose of declaring a Site Area Emergency is to ensure that offsite officials are informed of
potential or actual off ite consequences, that offsite officials are provided with recommended
actions to protect persons offsite, and that the Mill's re pon e organization is augmented by
additional personnel and equipment.
A Site Area Emergency, like an Alert, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Radiation Control. This is because there is a potential for offsite consequences. Unlike an Alert,
a Site Area Emergency assumes that offsite emergency response assistance will be required.
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The Mill has identified only two incidents that should be classified as Site Area Emergencies -
an uncontrolled release of greater than 100 pounds of anhydrous ammonia; and an ammonia
explosion that involves the release of greater than 100 pounds of anhydrou ammonia. The
actions to be taken in the event of such Site Area Emergencies are et out in subsection 2.1.1
above and in Appendices A and B to this Plan, and describe, to the extent appropriate, how and
by whom the following actions will be taken:
• Decision to declare a Site Area Emergency (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that a Site Area Emergency has been
declared, including recommendation for offsite protective actions (normally within 15
minutes of declaring a Site Area Emergency);
• Notification to the State of Utah Division of Radiation Control immediately after
notification of offsite authorities, not later than one hour after the Mill has declared a Site
Area Emergency;
• Decision on what onsite protective actions to initiate;
• Decision on what offsite protective actions to recommend;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
3.3 Information to be Communicated
Mill personnel will do their best lo provide clear, concise information to offsite response
organizations. The communication should avoid technical terms and jargon and should be
stated to prevent an under-or over-evaluation of the seriousness of the incident.
The procedures set out in the Section 2.1 and Appendices A through I de-scribe the key types
of information that will be communicated with respect to facility status, releases of
radioactive or other hazardous materials and recommendations for protective action to be
implemented by offsite response organizations, where applicable. Such Appendices also
contain the preplanned protective action recommendations the Mill will make to each
appropriate offsite organizaUon for each incident that is classified as an Alert or Site Area
Emergency, including the ize of the area where the actions are to be taken. The Appendices
also contain a standard reporting checklist to facilitate timely notifications.
Mill personnel meet annually with the various offsite emergency response providers to
ensure that:
• This Plan contains the most practical and efficient protective actions for each
postulated accident and that such providers understand and agree with the
recommended courses of action; and
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• The notifications sel oul in lhis Plan are appropriale and the cantacl information is
current.
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4. RESPONSIBILITIES
4.1 Normal Facility Organization
The Mill Manager is ultimately respon ible for the Mill site. The Mill Manager reports to the
Executive Vice President, US Operations of DUSA. The Executive Vice President, US
Operations of DUSA reports to the President and Chief Executive Officer of DUSA.
The Mill Superintendent, Maintenance Superintendent and Radiation Safety Officer report
directly to the Mill Manager. The Utility Crew, Administrative Staff and Chief Metallurgist also
report directly to the Mill Manager.
One or more Mill Foremen report to the Mill Superintendent. The number of Mill Foremen will
depend on Mill activities. In full operations, there are two Mill Foremen. The Shift Foremen
report to the Mill Foremen.
The Radiation Technicians, the Safety Coordinator and his staff and the Environmental
Coordinator and his staff report to the Radiation Safety Officer.
The Maintenance Foreman and Electrical Foreman report to the Maintenance Superintendent.
These relationships are indicated on the following diagram:
Book#l6 DENTSON l'vfiNES (USA) CORP.
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Date: August 18, 2009 Title: White Mesa MiU Emergency Re ponse Plan
Maintenance
Superintendent
I
Maintenance
Foreman
I
Maintenance
Personnel
MILL ORGANIZATION CHART
NORMAL OPERATIONS
I
Administrative
Staff
I
Electrical
Foreman
I
Electricians
President and
Chief EF;ecutive
Officer
I
Executive Vice
President, US
Operations
1
Mill Manager
I
Mill
Superintendent
Mill Foremen
Shift Foremen
Operations
Personnel
I
Crew Radiation
Technician(s)
Utility Crew
Lead Radiation
Technician
Radiation
Technician(s)
I
Chief
Metallurgist
I
Mill Chemist
I
Lab Persmmel
I
Environmental
Coordinator
I
Environmental
Technician(s)
Page 33 of
111
Radiation Safety
Officer
I
Safety
Coord ina tor
I
Safety
Technician(s)
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The procedures to be followed for the types of possible emergencies that have been identified for
the Mill are set out in Section 2.1 above and more specifically in Appendices A through I. The
individuals who have the authority and responsibility to declare the various types of emergencies
are detailed in Section 2.1 and those Appendices.
4.2 Onsite Emergency Response Organization
The response crew for each operating shift will normally consist of the following operators under
the direction of the shift foreman. This organization may be changed for individual shifts subject
to the approval of the RSO/Fire Chief.
4.2.1 Direction and Coordination
The Incident Commander will be the Mill Manager, or in his absence, the Mill Superintendent,
or in the absence of both the Mill Manager and the Mill Superintendent, the RSO.
The Incident Commander has the overall responsibility for implementing and directing the
emergency response. The Incident Commander has the following duties and authorities:
• Control of the situation;
• directing activities during the emergency;
• coordination of staff and offsite personnel who may augment the staff;
• communication with parties requesting information about the event;
• reporting to local, State and Federal authorities;
• authority to request support from offsite agencies;
• termination of the emergency; and
• authority to delegate any of the foregoing responsibilities to:
o the Mill Superintendent;
o theRSO; or
o such other individual or individuals that the Incident Commander deems
appropriate in the circumstances.
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact or direct others to contact
all outside services.
The Incident Commander has the ultimate responsibility to account for all employees at the Mill,
using the assistance of supervisors and/or any DUSA personnel. The Incident Commander has
the responsibility for the news media and reports directly to the Executive Vice President or
President of DUSA.
:
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Shift Foremen are in charge until the Incident Commander arrives and are responsible for all
functions listed above. Shift Foremen have the respon'sibility to account for all of their people in
addition to any visitors, contractors, etc., in their areas and report to the Incident Commander; or,
in the absence of the Incident Commander, to administer all of the above duties.
4.2.2 Onsite Staff Emergency Assignments
The following individuals, organizational group or groups are assigned to the functional areas of
emergency activity listed below.
During normal working hours while the Mill is in full operation, all of the individuals or their
alternates should be available on site to fulfill their emergency assignments. During evening or
night shifts, or during other times when the Mill is not in full operation, not all of the individuals
listed below will be on site. However, there will always be a Shift Foreman on site.
Blanding is a small town, and most of the individuals listed below live within a short distance of
the Mill. In the event of an emergency during a non-working period, afternoon or night shift,
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, wiU initiate procedures to effect any
necessary evacuations of the site and will contact the required personnel from the list of
assignments below to assemble the team required in order to fill all of the necessary assignments.
Two of the first persons contacted will be the Mill Manager and the RSO, who will ensure that
the remainder of the team is assembled in order to carry out the emergency procedures set out in
this Plan for the emergency.
a) Facility System Operations
The Mill Superintendent, or in his absence a Mill Foreman or the Mill Manager, is responsible
for all operational activities on the property. In this capacity, the Mill Superintendent, Mill
Foreman or Mill Manager can shut down any affected areas within the process and render aid to
the other departments.
The Maintenance Superintendent, or in his absence the Maintenance Foreman or the Mill
Manager, is responsible for all mechanical and instrumentation on the site and has the ability to
gather resources during any declared emergency.
Shift Foremen are in charge until the foregoing personnel arrive and are responsible for all of the
foregoing functions until relieved by one or more of the foregoing individuals.
b) Fire Control
As Fire Chief, the RSO has the responsibility to maintain trained fire crews and operable
equipment, mobilize and direct the fire crews and equipment in a fire emergency or one
containing the threat of fire, and to assist in evacuation and rescue or recovery operations. The
RSO/ Fire Chief makes sure that the team or crew has been established, equipped and properly
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trained every six months. The RSO/Fire Chief works with the Safety Department and the Safety
Coordinator under 30 CFR 56.4330 Firefighting, evacuation, and rescue procedures.
In the absence of the RSO, the Mill Safety Coordinator will assume these duties. If the Safety
Coordinator is not present, those responsibilities fall to the next senior member of the Safety
Department. Scheduled time off at the Mill is worked around the RSO and Safety Coordinators
time off. Both individuals will not be given time off work at the same time, thereby ensuring
supervised coverage in the event of an emergency.
During an emergency situation, the Safety Coordinator will also be present and receive direction
from the RSO/Fire Chief as to how to proceed. If the RSO is present during the emergency, the
Safety Coordinator will act as the Assistant Fire Chief to free up the RSO' s time to deal with
radiation decontamination or other issues that may arise. If the RSO is not present the Safety
Coordinator will be the acting Fire Chief and the radiation designee will act as the Assistant Fire
Chief, but will only deal with radiation related issues.
c) Personnel Evacuation and Accountability
The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with
the emergency, including isolation of utilities and providing technical advice as needed. The
Maintenance Supervisor will be assisted by the Mill Safety Coordinator.
The Laboratory Supervisor has the responsibility to direct and account for all office persmmel
(including DUSA personnel and office visitors) in evacuation and in activities to cope with the
emergency. In case of a mill tour, the Supervisor accompanying the tour will be responsible for
evacuation of visitors.
The Scale house person on shift will be responsible to account for ore truck drivers and reagent
truck drivers.
The Mill's Emergency Evacuation and Shut-Down Procedure are outlined in Appendix J to this
Plan.
d) Search and Rescue Operations
The RSO will direct rescue operations and provide the necessary emergency medical personnel
and facilities to cope with the emergency.
e) First Aid
First aid will initially be the responsibility of the Safety Coordinator or a Safety Technician. If
the need for first aid is minimal, there may not be a need to require offsite assistance. However,
if there are any significant injuries, or there is a risk of any significant injuries, the Safety
Coordinator or a Safety Technician will have the responsibility of contacting offsite medical and
ambulance services for assistance.
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f) Communications
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact all outside services.
g) Radiological Survey and Assessment (Onsite and Offsite)
On-site and offsite radiological surveys and assessments will be performed by one or more
Radiation Technician(s) under the direction of the RSO. The RSO may assist in performing any
such surveys.
The surveys and assessments that will be required will depend on the incident. In most cases,
radiological contamination resulting from the Mill would be expected to be limited and restricted
to the Mill site. In some cases, however, radiological contamination could be dispersed offsite.
The RSO will detennine what surveys and assessments are required in order to: a) determine to
what extent if any, radiological contamination has or could be dispersed offsite as a result of the
incident; and b) determine what surveys are necessary in the circumstances to assess any onsite
or offsite radiological contamination that may have resulted from the incident. In the absence of
the RSO, the Lead Radiation Technician will make these determinations.
The Mill has established an emergency call sheet that will be used in the event of an emergency
to alert all members of the department, whether on-site and on-duty or not. When an emergency
occurs, the RSO is notified first. If the RSO is not available, the Lead Radiation Technician is
notified. The on-shift Radiation Technicians notify the off-shift Radiation Technicians. All
Radiation Technicians are required to report to the site to assist in the emergency, unless advised
otherwise by the RSO. This ensures that there will be adequate Radiation Safety Staff available
for any emergency that may arise.
h) Personnel Decontamination
Personnel decontamination will be performed by Mill Radiation Technicians under the direction
of the RSO, or in the absence of the RSO, under the direction of the Lead Radiation Technician,
as needed.
i) Facility Decontamination
Facility decontamination will be performed by Mill operations personnel, maintenance personnel
and/or utility crew personnel under the direction of the Mill Manager, Mill Superintendent or
Maintenance Superintendent, to decontamination standards set by the RSO and monitored by
Radiation Safety Staff.
j) Facility Security and Access Control
:
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The Mill Superintendent, or in his absence a Mill Foreman, has the responsibility
of directing outside emergency personnel and has the responsibility for plant
security and will report directly to the Incident Commander.
k) Request Support from Offsite Agencies
During an emergency, the Incident Commander and/or the RSO/Fire Chief will coordinate that
the crew or team has the available members needed to respond to the emergency. After the team
or crew has responded and is in the process of handling the situation, the Incident Commander
and/or RSO/Fire Chief will then coordinate with the Radiation/Safety Departments to maintain
scene safety. Scene safety includes, but is not limited to, crowd control, outside emergency
assistance requests and any decontamination.
l) Post-Event Assessment
A post-event assessment of facility condition for future operations will be performed by the Mill
Manager, Mill Superintendent and/or Maintenance Superintendent. A post-event asses ment of
facilities for occupational safety will be performed by. the Safety Coordinator. A post-event
assessment of any on-site or offsite radiological contamination resulting from the incident will be
performed by lhe Radiation Safety Staff w1der the direction of the RSO.
m) Recordkeeping
The RSO will coordinate all record keeping relating to the incident and will be responsible for
the preparation of an incident report.
n) Media Contact
The Incident Commander, President and Chief Operating Officer or Executive Vice President,
US Operations of DUSA shall be the sole media contact in the event of an emergency at the Mill.
4.3 Local Offsite Assistance to Facility
Under a Letter of Agreement with the San Juan County Emergency Management Office, DUSA
will be assisted in the event of an emergency with all needed equipment and services at the
disposal of San Juan County. Local agencies have also volunteered services in the event of an
emergency. These local agencies are (see Section 4.4 below and Exhibit 1 for contact
information):
a) First Aid and Initial Medical Services
• Blanding Family Practice Medical Clinic -This facility is located approximately 8
miles north of the Mill in Blanding, Utah; and
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• Blanding Clinic-This facility is located approximately 11 miles north of the Mill in
Blanding, Utah.
b) Ambulance and Paramedic Services
• San Juan County Ambulance Service-This facility is located approximately 11 miles
north of the Mill in Blanding, Utah.
c) Fire Department
• Blanding City Fire Department-This agency is located approximately 9 miles north
of the Mill in Blanding, Utah. This agency is a volunteer fire department.
d) Law Enforcement
• Blanding City Police Department -This agency is located approximately 11 miles
nmth of the Mill in Blanding, Utah; and
• San Juan County Sheriff-This agency is located approximately 30 miles north of the
Mill in Monticello, Utah.
e) Highway Patrol
• Utah Highway Patrol-This agency is located approximately 30 miles north of the in
Monticello, Utah.
f) Hospitals
• San Juan County Hospital -This facility is located in Monticello, Utah,
approximately 33 miles north of the facility; and
• Blue Mountain Hospital -This facility is located approximately 8 miles north of the
facility in Blanding, Utah.
The Mill has provided a11 of the for~going facilities and agencies with Material Safety Data
Sheets (MSDS's) for any potential incident at the Mill. These are updated periodically by the
Mill. Also, each facility has an understanding with DUSA, that DUSA will perform all
radiological assessments and decontaminate any area or equipment that has been contaminated
during emergency activities.
Annual visits with each agency or facility are conducted to update and refresh the various
departments about potential emergencies that may be encountered. These visits are documented
and housed in the Safety Office at the Mill.
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Given that Mill personnel will be il'l attendance at any emergency situation, there is no need to
make any provisions to suspend security or safeguard measures for site access during an
emergency in order to accommodate any of the agencies referred to above.
4.4 Coordination with Participating Government Agencies
Below are listed the principal State agency and other government (local, county, State, and
Federal) agencies or organizations having responsibilities for radiological or other hazardous
material emergencies at the Mill:
• State of Utah, Division of Radiation Control.. ................. 801-536-4250
• NRC .............................................................. 301-951-0550
• MSHA Field Office--801-524-3450 District Office ........ 303-231-5465
• MSHA, Arlington ............................................................ 800-746-1553
• State Emergency Response Comm .................................. 801-538-3400
• State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
• National Response Center ................................................ 800-424-8802
• Utah Poison Control Center.-.-.•... -... .-........... -.-.,, .. -... -.-.............. -....... 800-456-7707
• Blanding City Fire Department .............................. Dial 911 or 678-2313
• Blanding City Police Department ........................ Dial911 or 678-2916 or 678-2334
• San Juan County Sheriff, Monticello, Utah ................. Dial 911 or 587-2237
• Utah Highway Patrol, Monticello, Utah .................... Dial911 or 587-2000
Mill persotmel meet annually with San Juan County Office of Emergency Management and Fire
Control and City of Blanding Fire Department to review items of mutual interest, including
relevant changes in this Plan. During those meetings Mill personnel discuss the Plan,
notification procedures, and overall response coordination, as necessary.
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5. EMERGENCY RESPONSE MEASURES
Reg. Guide 3.67 suggests that specific response measures should be identified for each class of
emergency and related to action levels or criteria that specify when the measures are to be
effected. However, rather than describe specific responses applicable to classes of emergencies,
this Plan describes the specific n.,sponse measures for each type of accident. Since the number of
different types of accidents that have been postulated for the Mill is relatively small, it was
concluded that this more direct approach is most appropriate for a facility such as the Mill.
There is no need to describe the specific actions and responses for each class of emergency when
the actual specific response measures can be described more directly for each accident.
Section 2.1 and Appendices A through I set out the specific response measures for each
postulated accident.
5.1 Activation of Emergency Response Organization
Activation of the Emergency Response Organization for each type of accident is set out in
Section 2.1 and the applicable Appendix A through I.
A contact list is maintained through the Mill Safety Department. All supervisors and key
personnel onsite have a copy of this contact list. The individuals listed are available at all times.
Blanding is a small town, and most of the individuals listed live within a short distance of the
Mill. In the event of an emergency during a non-working period, afternoon or night shift, or
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, will initiate procedures. In addition, the
Radiation Safety Department has established an emergency call sheet that will require
notification throughout the department. When an emergency occurs, the RSO/Fire Chief is
notified and then the Shift Radiation Technicians notify the off shift Radiation Technicians. The
shift Radiation Technicians will maintain scene security until directed by the RSO to do
otherwise. When the off duty Radiation Technicians arrive, they will report immediately to the
RSO and receive their instructions.
5.2 Assessment Actions
For each type of emergency, the actions to be taken to determine the extent of the problem and to
decide what cotTective actions may be required are set out in Section 2.1 and the applicable
Appendix A through I. Where appropriate, Section 2.1 and the applicable Appendix describe the
types and methods of onsite and offsite sampling and monitoring that will be done in case of
release of radioactive or other hazardous material. To the extent not specifically addressed in
Section 2.1 or in Appendices A through I, Mill personnel will use procedures contained in
existing Mill Standard Operating Procedures.
5.3 Mitigating Actions
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The means and equipment provided for mitigating the consequences of each type of accident are
specified in Section 2.1 and Appendices A through I. To the extent applicable, these include the
mitigation of consequences to workers onsite as well as to the public offsite, as well as the
criteria that will be used to decide whether a single process or the entire facility will be shut
down.
The Mill's Emergency Evacuation and Shut Down Procedure is set out in Appendix J.
5.4 Protective Actions
The nature of onsite and offsite protective actions, the criteria for implementing those actions,
the areas involved, and the procedures for notification to affected persons are described in
Section 2.1 and Appendices A through I for each type of accident. In order to prevent or
minimize exposure to radiation, radioactive materials, and other hazardous materials, the
procedures specified in Section 2.1 and those Appendices provide for timely relocation of onsite
persons, timely recommendation of offsite actions, effective use of protective equipment and
supplies, and use of appropriate contamination control measures, a:Rpropriate for each specified
---·--c---•--- --•
type of accident. To the extent that any actions and equipment are described generally in Section
2.1 and those Appendices, Mill personnel will take actions and use equipment in accordance with
Mill Standard Operating Procedures.
5.4.1 Onsite Protective Actions
5.4.1.1 Personnel Evacuation and Accountability
For each type of accident, Section 2.1 and Appendices A through I include:
• Criteria for ordering an evacuation;
• The means and time required to notify persons involved;
• Evacuation routes, transpmtation of personnel;
• Locations of onsite and offsite assembly areas;
• Search and rescue;
• Monitoring of evacuees for contamination and control measures if contamination is
found;
• Criteria for command center and assembly area evacuation and reestablishment at
alternate location;
• Procedures for evacuating and treating injured personnel, including contaminated
personnel; and
• Provisions for determining and maintaining the accountability of assembled and
evacuated personnel.
5.4.1.2 Use ofProtective Equipment and Supplies
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Section 2.1 and Appendices A through I specify the required protective equipment and supplies,
to the extent not already covered by Mill Standard Operating Procedures. To the extent that
Section 2.1 and Appendices A through I do not specify protective equipment and supplies, then
protective equipment and supplies normally required or available under existing Mill Standard
Operating Procedures for the required procedure or activity will apply.
In addition to normal supplies of equipment at the Mill, such as respirators, protective clothing
etc., the Mill maintains supplies of specialized equipment in certain locations for use in
emergency situations as follows:
a) Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-1/2" hose,
two spanner wrenches, spray nozzles and one hydrant wrench:
• South of SX;
• WestofCCD;
• North of mill building;
• East of pulp storage tanks;
• Northwest of Maintenance Shop;
• West of Warehouse; and
• East of office building.
b) Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus (SCBA) units are located at each of the following
locations:
• Hose station east of office building;
• Hose Station South of SX;
• North End SX Outside Wall; and
• North end of mill building, outside wall.
c) Spill Clean-up Equipment
Barrels of soda ash are located throughout the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near the
laboratory. The laboratory also contains acid spill kits and absorbent materials to be used in case
of a spill.
d) Fire Fighting PPE
.. ;
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Two complete sets of turnout gear for firefighting and/or emergency extrication are located in the
Fire Hose Station located on the east side of the office building.
e) Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. (Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.)
5.4.1.3 Contamination Control Measures
Because of the nature of potential accidents that can occur at uranium mills, it is unlikely that an
accident would result in a significant risk of overexposure to any workers or members of the
public (see the conclusions of NRC staff in NUREG-1140 discussed in section 2.1.6 above).
Therefore the Mill's existing Standard Operating Procedures are considered adequate for
preventing further spread of radioactive materials and for minimizing radiation exposures from
radioactive materials that could be unshielded or released by abnormal conditions. Section 2.1
and Appendices A through I describe isolation, area access control, and application of criteria for
permitting return to normal use to the extent necessary and not otherwise covered by existing
Standard Operating Procedures for the types of accidents that could occur at the Mill.
5.4.2 Offsite Protective Actions
Section 2.1 and Appendices A through I describe the conditions that would require protective
actions offsite for the various types of accidents, and describe the protective action
recommendations that would be made to offsite authorities, when each recommendation would
be made, and what area offsite would be affected.
5.5 Exposure Control in Radiological Emergencies
Given the radioactive materials found at the Mill and the types of postulated accidents, it is not
likely that Mill personnel or offsite workers would be exposed to levels of radiation that cannot
be adequately addressed under existing Mill Standard Operating Procedures.
5.5.1 Emergency Radiation Exposure Control Program
5.5.1.1 Radiation Protection Program
During the emergency situation, the Radiation Protection Manual, SOP Book 9, will be the guide
for all decontamination and exposure monitoring.
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The Mill's RSO will be responsible for the determination of exposures to be allowed during the
event of an emergency situation. This includes the unlikely event of authorizing workers to
receive emergency doses and for permitting onsite volunteers to receive radiation doses in the
course of carrying out lifesaving and other emergency activities.
5.5.1.2 Exposure Guidelines
The onsite exposure guidelines to be used for all postulated accidents, including actions to
control fires, stop releases or protect facilities will be those set out in UAC R313-15 and the
Mill's Radiation Protection Manual. These exposure guidelines will also apply to
• Removing injured persons;
• Undertaking mitigating actions;
• Providing onsite first aid;
• Performing personnel decontamination;
• Providing ambulance service; and
• Providing offsite medical treatment.
5.5.1.3 Monitoring
DUSA will provide all needed instrumentation for determining doses received by individuals
during all emergency situations. DUSA will also provide OSL badge monitoring to those
emergency response individuals during situations that may require extended periods of exposure
to high radiation areas.
In the event of an accident, such as an accident that involved the dispersion of yellowcake, or a
fire in the SX building or elsewhere on the facility that could involve the dispersion of
radioactive materials, breathing zone samples will be taken if practicable in the circumstances.
Emergency personal who must wear respiratory devices, must have their own devices. DUSA
will not furnish these devices.
Radiation safety personnel will also monitor various areas of the facility occupied by emergency
personnel, to the extent practicable.
Records of dose and dose commitments will be maintained for Mill personnel and offsite support
organization's emergency workers involved in the accident.
5. 5 .1.4 Decontamination of Personnel
Any emergency response equipment that enters the Mill's Restricted Area in response to an
incident will be scanned and decontaminated prior to leaving the site according to the
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requirements found in Table 1 of the NRC's Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted
Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May
1987.
Any personnel leaving the Mill's restricted area, or otherwise exposed to radiation from the
incident, will be scanned and decontaminated in accordance with the procedures set out in the
Mill's Radiation Protection Manual for personnel leaving the Mill's restricted area.
Injured personnel will be evaluated for radiation contamination at the earliest convenience, if
there is a potential for contamination. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
carmot be decontaminated, the clinic/hospital personnel will be notified in advance. Mill
radiation safety personnel will be available to provide health physics support clinic/hospital
personnel.
5.6 Medical Transportation
One fur1y-equipped First Responder Unit (Ambulance) is located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
All transportation vehicles will be surveyed and decontaminated by the Radiation Department at
the Mill. Any emergency response equipment or personnel that enters the Re tricted Area in
response to an incident will be scanned and decontaminated prior to leaving the site according to
the requirements found in Table 1 of the NRC's Policy and Guidance Directive FC-85-23,
Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unre tricted
Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material" issued May
1987. If any injured personnel who may also be radiologically contaminated, will be transported
to medical treatment facilities, the inside of the transport vehicle will also be scanned and
decontaminated in accordance with the foregoing Guidance.
Injured personnel will be evaluated for radiation contamination, jf there was a potential for
contamination, at the earliest convenience. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, clinic/hospital personnel will be notified in advance.
5. 7 Medical Treatment
All medical facilities will be made aware of potential radiological and chemical hazards
associated with the postulated accidents described in Section 2.1. St. Mary's hospital in Grand
Junction, Colorado, approximately 3 hours drive by highway, is the nearest trauma center.
Specialized medical attention for radioactive contamination or chemical exposure would be
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located eil'her in Salt Lake City at the University 0f Utah Medical Center (appreximateJy 5 hours
drive by highway), or in Denver, Colorado (approximately 7 hours drive by highway).
All facilitie!S are awar~ that DlJ.SA will take responsibility for tire mouit<i>ring and potential
·tteconttu:tiltiati6i'L&f all !atilli~es :ctm~ammat¢d during these emergencies. The Mill will provide
a.mbula;n:oe: and 'h~$p;l:~1 p~'®rnJ.el with· . .kealth physics support if needed.
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 48 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
6. EMERGENCY RESPONSE EQUIPMENT AND FACILITIES
6.1 Command Center
When the evacuation alarm sounds or when personnel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• North side of Tailings Cell 1; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The Incident Commander, RSO/Fire Chief or Shift Foreman will specify the appropriate
assembly site.
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation an~a will , erve as the initial assessment
center. Other communications and assessment centers will be set up in the Mill's office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
6.2 Communications Equipment
6.2.1 Onsite Communications
Employees will be notified to evacuate the area by dialing 184 on any area telephone and
announcing that the Mill should be evacuated. This announcement will be repeated three times.
When the paging system cycles through, the evacuation siren (continuous frequency) will
automatically sound for approximately forty-five seconds, and then automatically shut off,
allowing cominw1ications by radio from that point. If the 184 number is dialed accidentally the
evacuation alarm may be canceled by disconnecting the phone until the page cycle ends, then re-
dial184. (See Exhibits 1 and 2.).
The primary onsite communications will be by radio throughout the course of the emergency and
the subsequent recovery. Onsite communication by radio is the typical day-to-day manner of
communication within the Mill facility, and is pmformed by individual hand held VHF
transceivers. There is no central relay or similar system that could be disabled in the event of an
emergency. As a result, there is no need to provide for an alternative onsite communication
system or perform operational tests of that communications system.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 49 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
6.2.2 Offsite Communications
During an emergency situation, DUSA's onsite ambulance is equipped with a radio to
communicate with the San Juan County Dispatch. This service provides a backup means of
offsite communication, other than commercial telephone, and will allow the Mill to be in
communication with all emergency response services.
Operational tests are conducted on this system periodically during the normal weekly operational
checks of the onsite ambulance.
6.3 Onsite Medical Facilities
The Mill maintains medical supplies at the site for typical occupational injuries as required by
MSHA.
One fully-equipped First Responder Unit (Ambulance) is located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
Given the types of accidents identified, it is unlikely that any personnel would require
contamination control over and above the controls set out in the Mill's Radiation Protection
Manual, which would be applied to injured personnel. If it is not possible or there is not
sufficient time to decontaminate individuals, then advance notice will be applied to offsite
medical personnel and facilities. In addition, Mill pers01mel will be available to provide health
physics assistance to such medical personnel if necessary.
6.4 Emergency Monitoring Equipment
The monitoring equipment used on a day-to-day ba is by the Radiation Safety Department will
be available to monitor personnel and petform area monitoring, as well as to assess the release of
radioactive materials to the environment. As discussed in Section 2.1.6 above, none of the
po ·tulated accidents described in Section 2.1 above is expected to release significant quantities
of radionuclides into the environment. The greatest risk of that would be a fire in the solvent
extraction building, but, as NRC concluded in NUREG-1140 the potential for overexposures
offsite would not be significant. Mill personnel will monitor to assess the magnitude and
dispersion of any releases after the fact by use of hand held gamma meters in the areas offsite
that could have been impacted. The existing high volume particulate stations will also provide
some information on the magnitude and dispersion of any such releases.
Onsite area monitoring and personnel scanning will be performed by use of existing monitoring
equipment, which is located in the Radiation Safety Department. This is considered to be as
Book 4116 DBNfSON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 50 of
Date: August 18, 2009 Titlo: White Mesil Mill Emergency Response Plnn Ill
"non-hazardous" a location as possible atlhe ~;ite, because it is not located particularly close to
any locations that could involve one of the postulated accidents.
Mill Radiation Safety Staff will usc dragger lubes primarily to detect dangerous levels of
anhyd rous nmmonia and propane and other chemically toxic materials. If necessary, monitoring
personnel wi ll be equipped with SCBA respimtory protection while performing such monilori.ng.
; :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 51 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7. MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY
7.1 Written Emergency Plan Procedures
This Plan will be reviewed annually by the RSO and, if required, updated by the ALARA
Committee. The SERP Committee will then validate all changes that are being requested before
such changes will be implemented into a new revision of this Plan.
After final SERP approval, changes will be updated to the Document Control System. The
Document Control supervisor will update this Plan and then amend all current copies of the Plan
to the recipients listed on the Distribution List at the beginning of this document.
7.2 Training
Semi-annual training for the emergency response teams will be conducted. This training will
include, but not be limited to, fire suppression, emergency medical services, evacuation under
hazardous atmosphere conditions, search and rescue, proper PPE usage during each potential
emergency situation and radiological contamination surveying onsite and offsite.
Each member of the emergency response team will be assigned his or her tasks and trained in
detail about those tasks. The Radiation Staff will be trained in the proper decontamination of
personnel, PPE and potentially offsite medical facilities.
All employees onsite will be trained in the use of respiratory protection and on radiological
hazards during their normal monthly safety meetings and as needed during special radiation
training sessions as processes change at the facility.
Because appropriately trained Mill personnel will be in attendance at the Mill to accompany any
offsite emergency response personnel, there is no need to provide periodic orientation tours of
the facility to such personnel.
7.3 Drills and Exercises
Quarterly drills, as required by MSHA, are conducted by the Safety and Radiation Departments
to monitor performance of personnel responding to emergency situations. Each drill is enacted
upon one or more of the potential emergencies contemplated by this Plan. The drill and
evacuation activities are documented by the Mill's Safety Coordinator and maintained within
plant files. Management reviews all drills at quarterly ALARA Committee Meetings.
Because the impacts associated with most types of emergencies that could occur at the Mill are
limited to the Mill site itself, and the risks to the public are very low, offsite agencies are not
typically invited to participate in any drills or exercises at the Mill.
Book#16 ·DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 52 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7.3.1 Biennial Exercises
Training exercises will be held every two years with the potential offsite emergency responders.
These exercises consist of training and information pertaining to the operational activities at the
time.
7.3.2 Qual"terly Communications Checks
Quru.1erly communication checks with all potential offsite emergency responders will be
performed. The communication checks will be documented and housed in the Safety
Department records. These checks will update any changes to contact information for needed
parties.
Emergency response groups that are required to be contacted are:
• Blanding Police Department;
• Blanding City Fire Department;
• San Jua:o County Sheriff;
• San Juan County EMS;
• All local medical clinics and or hospitals; and
• Utah Highway Patrol
7.4 Critiques
This Plan is subject to audit by the ALARA audit team (see Section 7.5 below), and the periodic
drills and exercises referred to in Section 7.3 above are subject to review periodically by the
Mill's ALARA Committee. Given the nature of the potential incidents that could occur at the
Mill and the low risk to the public relative to incidents that could occur at other types of
facilities, such as nuclear power reactors, the Mill does not require that a critique be prepared for
each drill and exercise by one or more of the nonparticipating observers, other than the audits
and reviews conducted by the ALARA Audit Committee and the ALARA Committee.
7.5 Independent Audit
This Plan, including all procedures, training activities, emergency facilities, equipment, and
supplies, and records associated with offsitc snpport agency interface, described therein, is
subject to annual review by the Mill's ALARA audit team. The Mill's ALARA audit team is
comprised of DUSA corporate environmental and safety personnel who do not have direct
responsibilities for implementing the emergency response program, as well as an independent
outside consultant with expertise in environmental and radiation safety matters.
Any recommendations or deficiencies observed by the ALARA audit team will be presented to
the ALARA Committee for consideration typically within approximately 60 days after the audit
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 53 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
has been completed. Decisions by the Mill's ALARA Committee to make any changes to this
Plan will be submitted to the Mill's SERP for implementation. Any changes in plant layout,
process or facilities are included in the types of changes that will be reviewed and could warrant
revision to this Plan.
7.6 Maintenance and Inventory of Emergency Equipment, Instrumentation and
Supplies
Fire extinguishers, as well as the fire pump system, are inspected on an annual basis. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.
7.7 Letters of Agreement
Any changes to this Plan that would impact the actions of any offsite response organizations will
be communicated to such organizations. The Mill will review all letters of agreement with
offsite agencies periodically to ensure that they are kept up to date and in force.
;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 54 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
8. RECORDS AND REPORTS
8.1 Records of Incidents
A written report will be prepared for all incidents of abnormal operation, equipment failure and
accidents that led to a plant emergency that is classified as an Alert or Site Area Emergency.
The report will include the cause of the incident, persom1el and equipment involved, extent of
injury and damage (onsite and offsite) resulting from the incident, all locations of contamination
with the final decontamination survey results, corrective actions taken to terminate the
emergency, and the action taken or planned to prevent a recurrence of the incident. The report
will also include the onsite and offsite support assistance requested and received, as well as any
program changes resulting from the lessons learned from any critique of emergency response
activities.
All such reports unique to a radiological emergency, not covered by existing regulations or
License conditions will be retained until the License is terminated.
The foregoing reports will be prepared under the direction of the RSO, and will be maintained in
the Mill's files for inspection.
8.2 Records of Preparedness Assurance
Records will be maintained in accordance with all MSHA, State of Utah and ALARA criteria.
These documents will be available on site and housed in the Safety Department for review.
: :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 55 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
9. RECOVERY AND PLANT RESTORATION
The Incident Commander will make the determination as to when the facility has been restored
to safe status. In making this determination, the Incident Commander will:
i) Assess the damage to and the status of the facility's capabilities to control radioactive
materials and hazardous materials. Specifically, the Incident Commander must be
satisfied that all safety-related equipment required for safe occupation and use of the
facility, in those areas to be occupied and used (e.g., radiation monitoring
instruments, respiratory protection equipment, fire-suppression and fire-fighting
equipment, containments, and air filters) have been checked and restored to normal
operations. The Incident Commander will be assisted by the RSO, the Safety
Coordinator and the Maintenance Supervisor or Maintenance Forman in making these
determinations; and
ii) Determine the actions necessary to reduce any ongoing releases of radioactive or
other hazardous material and to prevent further incidents. The Incident Commander
will be assisted by the RSO, the Safety Coordinator and the Maintenance Supervisor
or Maintenance Forman in making these determinations.
The Incident Commander will direct the resources and personnel required in order to accomplish
the tasks to meet any required restoration action. During any planned restoration operations,
personnel exposures to radiation will be maintained within UAC R313-15limits and as low as is
reasonably achievable.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 56 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
10. COMPLIANCE WITH COMMUNITY RIGHT-TO-KNOW ACT AND CLEAN
AIR ACT
10.1 Community Right to Know Act
Section 11002 and 11004 of the Emergency Response and Community Right to Know Act
("EPCRA") of 1986; 42 U.S.C. 11001 et seq., requires that notice be given to the community
emergency response coordinator for the local emergency planning committee in the event of a
release of an extremely hazardous substance offsite. This requirement does not apply to any
release which results in exposure to persons solely within the sites or sites within which the
facility is located.
The Mill maintains inventories of two extremely hazardous substances: anhydrous ammonia and
propane. Mill personnel are required to provide notice to the community response coordinator
for the local emergency planning committee in the event of an offsite release of either of those
two substances. See Sections 2.1.1, 2.1.2 and 2.1.3 above and Appendices A, Band C.
10.2 Clean Air Act
When Congress passed the Clean Air Act Amendments of 1990, Section 112r required EPA to
publish regulations and guidance for chemical accident prevention at facilities using substances
that posed the greatest risk of harm from accidental releases. These regulations require facilities
such as the Mill that use, store or otherwise handle a threshold quantity of certain listed regulated
flammable and toxic substances to develop a Risk Management Program.
The Mill uses, stores and handles threshold quantities of two substances listed under the
regulations promulgated under Section 112r of the Clean Air Act: anhydrous ammonia and
propane, and has submitted to EPA a Risk Management Program for those two substances. A
copy of that Risk Management Program is attached as Appendix K to this Plan.
Book#16
Rev. No.: R-2.1
Date: August 18, 2009
:
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mili Emergency Response Plan
EXHIBIT 1
ElVIERGENCY NOTIFICATION LIST
ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR:
Give artificial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
Scan the injured person for excessive alpha prior to transporting if time allows.
Page 57 of
111
(If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office).
Pe1form other first aid as more specifically described in Section 2.1 or Appendices A
through I for the specific types of accidents and resulting injuries
THE INCIDENT COMMANDER OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING
AS NEEDED:
Blanding Clinic ............................ 678-2254 or 678-3434 (930 N. 400 W.)
Blue Mountain Hospital, Blanding ... 678-3993 (802 S. 200 W.)
San Juan Hospital, Monticello ..... 678-2830 or 587-2116 (364 W. 1st N.)
EMT TRAINED -The following personnel should be contacted, if they are on-site, in the event
of an emergency to aid in the event of any injuries to personnel.
David Turk
AMBULANCE SERVICE
Blanding ....................................... Dial 911
If the Company Ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
OTHER EMERGENCY NUMBERS
Fire Department ........................... Dial911 or 678-2313
County Sheriff .............................. Dial911 or 587-2237
Highway Patrol ............................ Dial 911 or 587-2000
Blanding Police ............................ Dial 911, 678-2916 or 678-2334
MANAGERS
The Supervisor will notify one of the following of all incidents:
R.E. Bartlett ................................. 435-678-2495 or 435-979-3893
D. Turk ......................................... 435-678-7802 or 435-459-9786
R. Wallace ........................... .435-459-1093
Book#t6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 58 of
Date: August 18, 2009 Title: While Mesa Mill Emergency Response Plan 111
A MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING
AGENCIES AS REQUIRED F"()R EACH INCIDENT (SEE SECTION 2.1 AND
APPENDICES A THROUGH I):
State of Utah, Division of Radiation Cont1'0l. .................. 801-536-4250
MSrlAField Office--801-524-3450 District Office ........ 303-231-5465
MSHA, Arlington ............................................................ 800-746-1553
State Emergency Response Comm .................................. 801-538-3400
State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
National Response Center ................................................ S00-424-8802
Utah Poison Control Center ............................................. 800-456-7707
Notification of surrounding communities and or residences will be handled by the appropriate
agencies as required by EPCRA (Emergency Planning and Community Right to Know Act). See
Section 2.1 and Appendices A through I.
Book #16
Rev. No.: R-2.1
Date: August 18, 2009
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
EXHIBIT2
INTERNAL NOTIFICATIONS
;
Page 59 of
111
Internal reporting requirements for Incidents, Spills and Significant Events are as follows: (see
Section 2.1 of the Plan and Appendices A through I for more specific internal notification
requirements that may apply to each type of emergency situation):
Report Immediately:
Event Criteria:
Release of toxic or hazardous substances.
Fire, explosions or other accidents.
Government investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or government requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $1,000,000.
Government investigation or enforcement action -limiting operation or penalties
of $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled down time of more than 24 hours.
Report at the Beginning of the Next Business Day:
Incident Criteria:
Was reported to a government agency as required by law.
Worker (DUSA or contractor) recordable injury or illness associated with a
release.
Community impact-reported or awareness.
Publicity resulted or is anticipated.
Release of 5,000 pounds or more of process material, waste or product.
The local manager in charge is to call Harold Roberts, Ron Hochstein or David Frydenlund.
Harold Roberts (Executive Vice President) ........... .303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
Ron Hochstein (President/CEO) ................................ 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
Book 4~16 DENISON MINES (US!\) CORP.
Rev. N0.: R-2.1 S'f.ANDARD .OPERATING PROCEDURES
Date: Augusl 18, 2.009 Title: White MesH Mil.l Emergency Response Plan
l)a.vi4:FryitW.W1d (Vice President) ............................. 303-628-7798 (offic_e)
303-221-009.8 (home)
303-808-6.648 (cell)
Page ClO of
111
Booldt16 ))ENISON M.CNES (tTSA) CORP.
Rev . N0.: R-2.1 STANDARD OPERATING PROCEDURES Page 61 of
Dale: August l8, 2009 Title: White Mesa Mill Emergency Response Plan lll
EXlDBIT3
SITE LAYOUT MAP
-_,.. -• • _...,. •• --... vv ... VVCI .... .,U
a
!
J
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPilR/\TfNG PROCEDURES Page62 of
DaLe: Augusll8, 2009 Title: While Mesa Mill Emergency Response Plan Jll
EXHIBIT4
GENERAL AREA MAP
.·
(
(
International Uranium (USA) Corporation
ProJect WHITE MESA MILL
e: UT
Figure 3.2 - 1
White Mesa Mill
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page63 of
'• Date: August 18,2009 Title: White Mesa Mill Emergency Response Plan llJ
EXHIDITS
DRAINAGE MAP
·.
fi 1 USGS GAUGE NO. 09376900
e 2 USGS GAUGE NO. 09378630
~ 3 USGS GAUGE NO. 09378700
lntemational Uranium (USA) Corporation
ProJoat WHITE MESA MILL
Date
o: liT
Figure 3. 7 -1
Drainage Map of the Vicinity
of the White Mesa Mill
Book4/!.l6
Rev. N0.: R~2.1
Date: August 18, 2009
DENISON MINES (USA) CURP.
STANDARD OPERATING PROCEDURES
Title: White Mesa MiU Emergency Response Plnn
EXHIBITk)
POPutATION CENTERS MAP
Page 64 of
111
(
(
:. . \ t'} \1 I ,. ..
\ I L-" .. · .. \:j
i.. I it
/ ..
)
\
I
I ._,
l
I I
I
l.l BLAND N.}
l 3162 (CITY) K\
l /\ r ·) \t 250 ('SUlm! ~\P.)D 'G) l {_\....1.,1 .) t ):'!./• ( ~ u i
: -~ :~.-• 1
1.1' f i r;
t ~ : ' • 1 ~----~----+---r4~~-----r----i-~·~,(~·~-t"----r----, ( i ~ \( ./ \~. ) \1\ ~:j
(
·.(
1
) I j)J ) I !)' ·~ \ '·.· ~f.: t-·.1 I .L.l"_: _;,.' I i . \·~f\1.,?
': 1.,._, ( ( \~ ffJ '{ ~ M SX) ':
t ( ··f _f:~ / ,, ~"·: ~> ••. ..... \ l L ·'
/ ' I ! '
\":>0.'\ f ( ..
'
0
SCALE
l 2
PROPERTY BOUNDARY
RESERVAnONBOUNDARY ·· .... · .... · ··· CANYON RIM
International Uranium (USA) Corpora1Jon
PrOfed WHITE MESA MILL
UT
Figure 3.8 • 1
Population In The
Project VIcinity • 2000 Census
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 65 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response P lan 111
EXHIBIT 7
MAIN SHUT-OFF VALVES
During an emergency this list should be used along with Site Layout Map (Exhibit 3) to locate
tanks and valves associated with these tanks.
REAGENT SHUT-OFF VALVE LOCATIONS
Sulfuric Acid
4" Main located south side of acid tank
East acid pump discharge valve
West acid pump discharge valve
3" Main (leach area) located 25 feet west of Derrick screens next to walkway
1-1/2" Main (SX area) located south of Central Control room
Ammonia
4" Main (east tank) located on end at bottom
4" Main (west tank) located on end at bottom
2" Valve located on top of tank (east tank)
2" Valve located on top of tank (west tank)
Kerosene
2" Main valve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
2" Main valve located at bottom of tank (south tank)
Pump discharge 2" valve
Soda Ash
Main valve located at bottom of tank (dry storage)
4" Main valve located at bottom of tank on 30% dilution tank
4" Main valve locate at bottom of tank on dilution tank
Book4tl6 DENISON MINES (tJSA) CQRP.
Rev. No.: R-2.1 STANDARD OPERATlNG PROCEDURES Page 66 of
Dale: Aug~rsl J 8, 2009 Title: While Mesa Mill Emergency Response. Plnn lll
')~' Mrdu Y.~~ located~. bottom::ol:~
Caustic Soda
l'' Mi!fl::\t'ti;l~' l~~~·At boltom·::aftank.: east and w.~ between supporLs
Book #16 DENISON M1NBS (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 67 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
Sodium Chlorate
3" Main valve located at bottom of tank (cast tank)
3" Main valve located at bottom of tank (norlh tank)
3" Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3" Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
PLANT UTILITY SHUT-OFF VALVE LOCATIONS
Process Water
Main valve located on west side of water storage tank
Discharge valve off service water pump east
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Mrun valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2'' Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERA TIN'G PROCEDURES Page 68 of
Date: August l8, 2009 Title: White Mesa Mill Emergency Response Plan ill
Steam
Main discharge valve for Superior boiler located at top of boiler
Main steam valve located south side of boiler house
Plant Air
Main valve located atieceiver tank in compressor room at boiler house
Main valve to mill building located south of Centnl Control room
PROCESS SHUT-OFF VALVE LOCATIONS
Pulp Storage
No. 1 valve located on west side of tank
No.3 valve located on west side of tank
Pre-leach (old No.2 pulp storage) valve located on west side of tank
Pre-leach Thickener
Main valve located undemeath at center cone
Clarifier
Main valve located underneath at center cone
Main valve located underneath at center cone
CCD Thickeners
Main valve located underneath at center cone of each thickener
; ;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 69 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIX A
EMrnRGENCYRESPONSEPROCEDUREFOR A RELEASE OF ANHYDROUS
AMMONIA
(See also Section 2.1.1 of the Emergency Response Plan)
The following steps will be followed for an uncontrolled release of anhydrous ammonia. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The fucident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AM:MONIA CAN CAUSE INCAPACITATION,
SERIOUS INJURY AND DEATH.
1. A release of anhydrous ammonia would most likely occur suddenly. The person who would first
witness the release should immediately contact his or her supervisor who would activate the
evacuation alarm by using the "dial 184" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the spill, and account for all
personnel, including all contractors and visitors at the Mill and all ore, product and reagent truck
drivers, in accordance with the Emergency Evacuation and Shutdown Procedure described in
Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, Anhydrous ammonia has an ID No. of 1005 and is covered by
Guide No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
Book#l6 DENISON MINES (USA) CORP.
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Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water
• In case of contact with substance, immediately flush skin or eyes with running water for at
least 20 minutes;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any.fraGtures and stabilize for-transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet.
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
8. Initiate necessary steps to contain and/or neutralize the release, such as spraying with water fog,
turning off valves, etc.
• See Material Safety Data Sheet attached to this Appendix; and
• See Exhibit 7 for a list and locations of main shut-off valves.
9. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas.
:
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 71 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
10. If the incident involves an uncontrolled release of greater than 100 lbs (19 gallons) of anhydrous
ammonia, the incident is classified as a Site Area -Emergency and could pose a hazard to the
public. If the incident involves an uncontrolled release of between 36 lbs (7 gallons) and 100 lbs
of anhydrous ammonia, it is classified as an Alert. In either case, notify the community
emergency response coordinator for the local emergency planning committee as soon as possible
(within 15 minutes after declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
In its notificalions to the foregoing offsite official , the MiU pers01mel making the notification
should ad vise of the expected quantity of anhydrous ammonia released and provide the Mill's
initial recommendation for offsite protective actions, which are that the offsite response
authorities should follow the recommendations for releases of anhydrous ammonia contained in
the DOT Guidebook. ln the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005 and is
covered by Guide No. 125. Initial isolation and protective action distances are set out in Table 1
to the DOT Guidebook. Copies of the relevant portions of the Guidebook are attached to this
Appendix. An uncontrolled release of the contents of one of the anhydrou ammonia tanks at the
Mill would be similar to an uncontrolled release from a rail car or tanker truck and would be
considered to be a "large pill" tmder Table 1 of the DOT Guidebook. The foregoing offsite
officials hould also be advised of the conclu ions of the Mill s Risk Management Plan, attached
hereto as Appendix K, as itielates to anhydrous ammonia.
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 72 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
11.1£ the incident involves an Qncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Radiation Control (801-536-4250)
immediately after notification of offsite authorities, and in any event within one hour after
declaration of the emergency, if possible. This immediate notification is required because an
uncontrolled release of anhydrous ammonia of greater than 36 lbs (7 gallons) and 100 pounds is
classified as an Alert and a release of greater thanlOO pounds is classified as a Site Area
Emergency.
12. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
13. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediate! y.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
· 604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
14. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention to
low points. The RSO or Safety Coordinator will make a determination if it is safe for personnel
to re-enter the facility or any portion of the facility or whether or not any portion of the facility
must remain shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode.
16. Notification of Regulatory Agencies:
Book#l6 DENISON MINDS (USA) CORP.
Rev. No.: R-2. L STANDARD OPERATING PROCBDUHI!S Page 73 of
Dale: August 18, 2009 'Tttle; Whftc Mesa.·Mtu Bmet·gency Response Plan Ill
A membe1· of Mill management or Corporate management will notify the foJlowing regulating
agencies as indicated below:
• Report to MSHA
Any release of anhydrous ammonia at the Mill fitcility must be reported within 15' minutes to the
MSHA -1-800-746-1553.
17. Written Reports
The RSO will prepare a written report of the incident for Mill files, containing the in[orm:ation set
out in Section 8.1 of the Plan.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 74 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXB
E:MERGENCY RESPONSE PROCEDURE FOR AN AMMONIA EXPLOSION IN A
BUILDING
(See also Section 2.1.2 of the Emergency Response Plan)
The following steps will be followed in the event of an ammonia explosion in a building. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AMMONIA CAN CAUSE INCAPACITATION,
SERIOUS INJURY AND DEATH.
1. An ammonia explosion would most likely occur suddenly. The person who would first witness
the explosion should immediately contact his or her supervisor who would activate the evacuation
alarm by us-ing the "dial 1-84" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the impacted area, and account
for all personnel, including all contractors and visitors at the Mill and all ore, product and reagent
truck drivers, in accordance with the Emergency Evacuation and Shutdown Procedure described
in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, anhydrous ammonia has an ID No. of 1005 and is covered by Guide
No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped as a result of the explosion; do this
only with properly trained and equipped personnel.
7. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas.
: :
Book#l6 DENISON MlNES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 75 of
Date: August 18, 2009 Title: White Mesa M ill Emergency Response Plan 111
8. In the event of fire, follow procedures set out on Guide No. 125. If the fire is in the SX Building,
follow the procedures in Appendix E in addition to the procedures in this Appendix.
9. Isolate utility lines affected by the fire.
10. Extinguish the fire and post a fire watch for flare-ups.
11. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of contact with substance, immediately flush skin or eyes with running water for at
least 20 minutes;
• In case of bums, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• Keep victim warm and quiet;
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 76 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. Initiate necessary steps to contain and/or neutralize the release of ammonia that caused the
explosion, such as spraying with water fog, turning off valves, etc.
• See Material Safety Data Sheet attached to this Appendix; and
• See Exhibit 7 for a list and locations of the main shut-off valves.
15. If the incident involves an unconb:olled release of greater than 00 lbs (19 gallons) of anhydrous
ammonia, the jncident is classified as a Site Area Emergency and could pose a hazard to the
public. If the incident involves an uncontrolled release of between 36 lbs (7 gallons) and 100 lbs
of anhydrous ammonia, it is classified as an Alert. In either case, notify the community
emergency response coordinator for the local emergency planning committee as soon as possible
(within 15 minutes of declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of anhydrous ammonia released and provide the Mill's
initial recommendation for offsite protective actions, which are that the offsite response
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 77 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
authorities should follow the recommendations for releases of anhydrous ammonia contained in
the DOT Guidebook. In the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005 and is
covered by Guide No. 125. Initial isolation and protective action distances are et out in Table 1
to the DOT Guidebook. Copies of the relevant pmtions of the Guidebook are attached to this
Appendix. An uncontrolled release of the contents of one of the anhydrous ammonia tanks at the
Mill would be similar to an uncontrolled release from a rail car or tanker truck and would be
considered to be a "large spill" under Table 1 of the DOT Guidebook. The foregoing offsite
officials should also be advised of the conclusions of the Mill's Risk Management Plan, attached
hereto as Appendix K, as it relates to anhydrous ammonia.
16. If the incident involves an uncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Radiation Control (801-536-4250)
immediately after notification of offsite authorities, and in any event within one hour after
declaration of the emergency, if possible. This immediate notification is required because an
uncontrolled release of anhydrous ammonia of greater than 36 lbs (7 gallons) and 100 pounds is
classified as an Alert and a release of greater thanlOO pounds is classified as a Site Area
Emergency.
17. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
18. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ........ .303-389-4160 (office)
303-7 56-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 78 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
19. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention to
low points. The RSO or Safety Coordinator will make a determination if it is safe for personnel
to re-enter the facility or any portion of the facility or whether or not any pottion of the facility
must remain shut down;
20. Inspect facility for damage that may have resulted from a fire or explosion and identify any of the
following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations; and
• Damage to any licensed material or any device, container or equipment containing
licensed material.
21 . The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down;
22. The Incident Commander will make the decision to terminate the emergency or enter into recover
mode.
23. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 79 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposmes to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CFR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60. ; or
o any of the events listed in 10 CFR 20.2202(b),
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553.
24. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CFR
20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 80 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXC
EMERGENCY RESPONSE PROCEDURE FOR A RELEASE OF PROPANE
(See also Section 2.1.3 of the Emergency Response Plan)
The following steps will be followed for an uncontrolled release of propane. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
CAUTION: PROPANE IS EXTREMELY FLAMMABLE. RISK OF FIRE OR EXPLOSION
1. A release of propane would most likely occur suddenly. The person who would first witness the
release should immediately contact his or her supervisor who would activate the evacuation alarm
by using the "dial184" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the spill, and account for all
persom1el, including all contractors and visitors at the Mill and all ore, product and reagent truck
drivers, in accordance with the Emergency Evacuation and Shutdown Procedure desc1ibed in
Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transpmtation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, propane has an ID No. of 1075 and is covered by Guide No. 115. A
copy of Guide 115 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
7. In the event of a spill or leak, follow the procedures set out under the heading "Spill or Leak" in
Guide No. 115.
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 81 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
8. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas. See Exhibit 7 for a list and locations of main shut-off
valves.
9. In the event of fire, follow procedures set out under the heading "Fire" in Guide No. 115.
10. Isolate utility lines affected by the fire.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• Clothing frozen to the skin should be thawed before being removed;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of bums, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• Keep victim warm and quiet;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Montice11o 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves;
;
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 82 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• If the Mill ambulance is used, an attendant must ride with the i1Dured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. If the incident involves an uncontrolled release of propane that could result in an explosion it is
classified as an Alert. As a result, notify the community emergency response coordinator for the
local emergency planning committee as soon as possible (within 15 minutes after declaration of
the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of propane released and provide the Mill's initial
recommendation for offsite protective actions, which are that the offsite response authorities
should follow the recommendations for releases of propane contained in the DOT Guidebook. In
the DOT Guidebook, propane has an ID No. of 1075 and is covered by Guide No. 115. Initial
isolation and evacuation recommendations are set out in Guide No. 115. Copies of the relevant
portions of the DOT Guidebook are attached to this Appendix. An uncontrolled release of the
contents of the Mill's propane tank would be similar to an uncontrolled release from a rail car or
tanker truck. The foregoing offsite officials should also be advised of the conclusions of the
Mill's Risk Management Plan, attached hereto as Appendix K, as it relates to propane.
15. If the incident involves an uncontrolled release of propane that could result in an explosion report
the release to the State of Utah Division of Radiation Control (801-536-4250) immediately after
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 83 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible. This immediate notification is required because an uncontrolled release
of propane that could result in an explosion is classified as an Alert.
16. Perform scans on personnel that may have been exposed to areas of high radiation. Pelform
bioassays if appropriate.
17. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
18. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
19. Inspect facility for residual concentrations of propane, paying particular attention to low points.
20. Inspect facility for damage that may have resulted from a fire or explosion and identify any of the
following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 84 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
dete1mination if it is safe for personnel to re-enter the facility or any pmtion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
21. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down;
22. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode, or to escalate the emergency to a different category if necessary.
23. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 85 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (sec 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary
The Stale of Utah, Division of Radiation Control (801-536-4250) must be notified within 24 hours
after the discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b).
• Report to MSHA
Aily fire or explosion at the Mill facility must be reported within 15 minutes to the MSHA -1-
800-7 46-1553.
24. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CFR
20.2203(b) and 10 CPR 40.60 (c)(2), as applicable.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 86 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXD
EMERGENCY RESPONSE PROCEDURE FOR A LEACH TANK FAILURE OR
SULFURIC ACID TANK FAILURE
(See also Sections 2.1.4 and 2.1.5 of the Emergency Response Plan)
The following steps will be followed for a leach tank failure or a sulfuric acid tank failure. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
1. The person who would first witness the tank failure should immediately contact his or her
supervisor who would, as an immediate precautionary measure, isolate the spill or leak area in all
directions for at least 150 feet. All unauthorized personnel will be required to stay out of this
area.
2. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
3. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
4. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See the Material Data Safety Sheet for sulfuric acid, a copy of which is attached to this Appendix.
5. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
6. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas. See Exhibit 7 for a list and locations of the main shut-off
valves.
7. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any ~uries to personnel:
o David Turk
• Move victim to fresh air;
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 87 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with substance, immediately flush skin or eyes with mnning water for at
least 20 minutes;
• For minor skin contact, avoid spreading material on unaffected skin;
• Removal of solidified molten material from skin requires medical assistance;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transpmtation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet;
• Effects of exposure (inhalation, ingestion or skin contact) to substance may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
8. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
9. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 88 of
111
10. Initiate necessary steps to contain and/or neutralize the release, in accordance with precautions set
out in the Material Safety Data Sheet attached to this Appendix .
11. In the case of a release from the sulfuric acid tank, remove any contaminated soil to the Mill's
tailings cells for disposal, in accordance with the precautions set out in the Material Safety Data
Sheet attached to this Appendix. Make any notifications required under the Mill's Spill Response
Plan, a copy of which is attached to this Plan as Appendix L.
12. Inspect facility for damage that may have resulted from a leach tank failure and identify any of
the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 89 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
13. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down.
14. The Incident Commander will make the decision to terminate the emergency or enter into recover
mode.
15. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary:
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified;
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the ammal permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary:
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60; or
o any of the events listed in 10 CFR 20.2202(b).
• Report to MSHA
Not reportable to MSHA.
16. Written Reports
Book 4t l 6. DENISON I\11NES (USA) CORP.
Rev. No.: R~2.J STANDARD OPERATING PROCEDURES Page 90 of
D<lte: Augusl 18, 4,009 'rHle: While Mesn Mill Emergency Response Plan 1.11
The RS'O will prepare a written report of ~ incident ~ MiiUiles. :tn. a<ldition,lf notification ofs:
required to be submitted to the State under paragraph 15 nbove, the RSO wilJ prepare a written
report and submit il to l'he State of Utah Division of" Radiation Control witbi.11 30 days of the
incident. The wxitten reporl will ~~i~ .tlil~ information rcq~lixed ~ Ul C.~20.2203(b) and JO
CFR 40.60 (c)(2), as applicable.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 91 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXE
EMERGENCY RESPONSE PROCEDURE FOR A FIRE IN THE SOL VENT EXTRACTION
BUILDING
(See also Section 2.1.6 of the Emergency Response Plan)
(See ApJ>endix F for aU other fires)
The following steps will be followed for a fire in the SX building. All other fires will be addressed in
Appendix F. The steps should be followed in the order set out below, unless more than one crew is
mobilized, in which case some of the steps can be taken simultaneously by different crews. The
Incident Commander has the authority to vary from the steps set out below if he deems it necessary in
the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by dialing 185 on any telephone in the area and announcing the location of the fire over
the paging system. This announcement will be repeated twice, for a total of three
announcements. When the paging system cycles through, the fire siren (alternating frequency)
will automatically sound for approximately forty-five seconds then automatically shut off,
allowing radio communications to resume.
2. Evacuate all personnel and account for all personnel, including all contractors and visitors at the
Mill and all ore, product and reagent truck drivers, in accordance with the Emergency Evacuation
and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Mobilize the fire crew.
5. Notify the community emergency response coordinator for the local emergency planning
committee as soon as possible (within 15 minutes after declaration of the emergency, if possible)
as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Police
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 92 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
6. Report the fire to and request the assistance of the following Emergency offsite centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
7. Report the fire to the State of Utah Division of Radiation Control (801-536-4250) immediately
after notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible. This immediate notification is required because a fire in the SX building
is classified as an Alert.
8. Determine other crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
9. Rescue any victims of the fire; do this only with properly trained and equipped persotlllel.
10. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 7 for a
list and locations of the main shut-off valves.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to persollllel:
o David Turk
• Give artificial respiration if necessary;
• Control any bleeding;
; : ;
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 93 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to skin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
15. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
43 5-459-1093
16. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
;
; :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 94 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
303-221-0098 (home)
303-808-6648 (cell)
111
17. Perform radiation surveys to determine if the fire has caused a dispersion of radioactive materials
and record the results of the surveys. These surveys will be performed in various areas of the
Mill's restricted area as well as outside of the restricted area, particularly in areas downwind of
the fire. In addition, surveys will be taken in the vicinity of the nearest residence downwind of
the fire.
18. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
19. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not a portion of the facility must remain
shut down.
20. The Incident Commander will make the decision to terminate the emergency or enter recovery
mode or to escalate the emergency to a different category if necessary.
21. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
..
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 95 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CPR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CPR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CPR 40.60.; or
o any of the events listed in 10 CPR 20.2202(b ).
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553.
22. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in the
Mill's tailings cells.
23. Written Reports
The RSO will prepare a written report of the incident for Mill files. fu addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CPR
20.2203(b) and 10 CPR 40.60 (c)(2), as applicable.
.
;
Book#16 DENISON ¥INES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 96 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan Ill
APPENDIXF
E.M.ERGENCY RESPONSE PROCEDURE FOR A FIRE
(See also Section 2.1. 7 of the Emergency Response Plan)
(See Appendix E for a fire in the Solvent Extraction Building)
The following steps will be followed for all fires, other than a fire in the SX building, which is
addressed in Appendix E. The steps should be followed in the order set out below, unless more than
one crew is mobilized, in which case some of the steps can be taken simultaneously by different
crews. The Incident Commander has the authority to vary from the steps set out below if he deems it
necessary in the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by dialing 185 on any telephone in the area and atmouncing the location of the fire over
the paging system. This announcement will be repeated twice, for a total of three
announcements. When the paging system cycles through, the fire siren (alternating frequency)
will automatically sound for approximately forty-five seconds then automatically shut off,
allowing radio communications to resume.
2. Evacuate all personnel and account for all personnel, including all contractors and visitors at the
Mill and all ore, product and reagent truck drivers, in accordance with the Emergency Evacuation
and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Mobilize the fire crew.
5. Determine other crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
6. Rescue any victims of the fire; do this only with properly trained and equipped personnel.
7. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 7 for a
list and locations of the main shut-off valves.
8. Extinguish the fire and post a fire watch for flare-ups.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 97 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
9. If the Incident Commander determines that the fire is not capable of being controlled by the
Mill's Emergency Response crews, then Report the fire to the following Emergency offsite
centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or ( 435) 587-2237
10. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
11. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Give artificial respiration if necessary;
• Control any bleeding;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to slrin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
12. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 98 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
13. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-67 8-7802 or 435-459-9786
435-459-1093
14. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
15. Perform radiation surveys if necessary to determine if the fire has caused a dispersion of
radioactive materials and record the results of the surveys.
16. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
;
.Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 99 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
17. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
he facility or any portion of the facility or whether or not a portion of the facility must remain
shutdown
18. The Incident Commander will make the decision to terminate the emergency or enter recover
mode or to escalate the emergency to a different category if necessary.
19. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CPR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
B~0k m·6 DENISON MJNES (USA) CORP.
Rev. No.: R-2.1 STANDARD Ol'ERATlNG .PR,OCEDURES Fagc roo of
Dale: August 18, 2009 r['itlc: While Mesn Mill Emergency Response Plan 111
o any of (he event listed iJ1 10 CFR 40.60.; ()r
o any of lhe ·events listed in 10 CPR 20.2202(b).
• Report to MS IA
Any fire al the Mill facility must be repo.rted within 15 minutes to the MS.HA -1-800-74G-
I $53 if there is an ir~ury that has a reasonable potential to cause death.
20. Written Reports
The RSO will prepare a written report of the incident for Mill files.
In addition, if a report is required to be given to the State of Utah., Division. of Racli~tion Control
as indicated in paragraph 19 above, the RSO will prepare a written report and subri1it it to the
State of Utah Division of Radiation Control within 30 days of uch initial report The written
report will contain. the information required by 10 CFR 20.2203(b) and 0 CFR 40.60 (c)(2), a.
applicab1e.
; ; :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 101 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXG
EMERGENCY RESPONSE PROCEDURE FOR A TORNADO OR MAJOR EARTHQUAKE
(See also Sections 2.1.8 and 2.1.9 of the Emergency Response Plan)
The following steps will be followed for a tornado or major earthquake. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. In the case of a tornado, seek cover in areas where there is no potential for falling objects. Such
as in a doorway. After the incident has concluded, the emergency evacuation alarm will be
sounded and a head count will then take place. After all employees have been accounted for, the
emergency response activities will begin, such as shutting down valves, flows, etc ...
2. In case of a major earthquake, seek cover in areas where there is no potential for falling objects.
Such as in a doorway. After the incident has concluded, the emergency evacuation alarm will be
sounded and a head count will then take place. After all employees have been accounted for, the
emergency response activities will begin, such as shutting down valves, flows, etc ...
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. If the earthquake or tornado has caused one of the other incidents referred to in the Plan, refer to
the specific procedures to be followed for that incident set out in Section 2.1 of the Plan and the
applicable Appendix A through I.
5. Determine the crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
6. Rescue any victims of the tornado or earthquake; do this only with properly trained and equipped
personnel.
7. Isolate utility lines and turn off any valves etc necessary in order to prevent fires or explosions.
See Exhibit 7 for a list and locations of the main shut-off valves.
8. Attend to any injured persons:
Book#16 DENISON MINES (USA) GORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 102 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Give artificial respiration, if necessary;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transpmted in a car or
pickup.
9. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
10. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
11. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediate! y.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
Book#l6_ DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 103 of
111
12. Perform radiation surveys to determine if the tornado or earthquake has caused a dispersion of
radioactive materials and record the results of the surveys. In the case of a tornado, those surveys
will be performed in various areas of the Mill's restricted area as well as outside of the restricted
area, particularly in areas along the path of the tornado.
13. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to petform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
14. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
he facility or any portion of the facility or whether or not a portion of the facility must remain
shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter recover
mode or to escalate the emergency to a different category if necessary.
16. Notification of Regulatory Agencies:
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 104 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CPR 20.2202(b).
• Report to MSHA
Any tornado or major earthquake that resulted in structural damage or potentially life
threatening injuries at the Mill facility must be reported within 15 minutes to the MSHA -1-
800-746-1553.
17. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in the
Mill's tailings cells.
18. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, if a report has been
given to the State under paragraph 61 above, the RSO will prepare a written report and submit it to
the State of Utah Division of Radiation Control within 30 days of the incident. The written report
will contain the information required by 10 CPR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
;
Book#l6 DENISON MINES (USA) CORP. _
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 105 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXH
EMERGENCY RESPONSE PROCEDURE FOR TAILINGS ACCIDENTS
(See also Sections 2.1.10.1. 2.1.10.2 and 2.1.10.3 of tlte Emcl'gency Res!lonse Plan
The following steps will be followed in the event of a tailings accident (flood water breaching,
structural failure of tailings dike or damage to tailings transport system). The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. The person who first witnesses the tailings accident should immediately contact his or her
supervisor, who will initiate the procedures set out below.
2. Evacuate personnel from areas around the impacted area as necessary to prevent possible injury
to those personnel. Access to those areas will be limited to authorized personnel.
3. Turn off all feed of tailings or solutions to the tailings cells and to the tailings transport system.
4. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Co{Ilmander arrives.
5. Notification of Mill Management
The Supervisor will notify one of the following if not already alerted and part of the Emergency
Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
6. To the extent possible, solutions from an impacted tailings cell will be pumped to an un-impacted
tailings cell.
7. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 106 of
111
8. In the event of damage to the transport system, the system will be shut down and repaired. Any
spills will be cleaned up and deposited in the tailings cells.
9. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
mobilize large operating equipment to construct temporary earthen dikes or berms downgradient
to the impacted dike, if appropriate in the circumstances.
10. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
report the incident to the State of Utah Division of Radiation Control (801-536-4250) within 24
hours of the discovery of the incident.
11. Take other measures and perform remediation work as necessary and in accordance with advice
and instructions of the State of Utah Division of Radiation Control.
12. Other reporting
• Report to MSHA
Does not have to be reported.
• Report to State of Utah Department of Natural Resources, Division of Dam Safety
• A written report will be made to the State of Utah Division of Radiation Control within 5
days after the incident.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 107 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIX I
EMERGENCY RESPONSE PROCEDURE FOR A TERRORIST/BOMB THREAT
(See also Section 2.1.11 of the Emergency Response Plan)
The following steps will be followed in the event of a terrorist/bomb threat. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. The person who would first witness the threat should immediately contact his or her supervisor
who would activate the evacuation alarm by using the "dial184" notification system.
2. Evacuate all personnel from the Mill site, and account for all personnel, including all contractors
and visitors at the Mill and all ore, product and reagent truck drivers, in accordance with the
Emergency Evacuation and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Since the consequences of the threat are unknown, the incident is considered an Alert. Notify the
community emergency response coordinator for the local emergency planning committee
immediately (within 15 minutes after declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications immediately:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
:
Book #16 DENISON MINES (USA) CORP. .
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 108 of
Date: August 18, 2009 Title: White Mesa Mil1 Emergency Response Plan 111
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
5. Notify the State of Utah Division of Radiation Control (801-536-4250) immediately after
notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible.
6. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
7. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
8. Follow instructions given by offsite emergency response officials.
9. To the extent that the threat or bomb results in any of the incidents, such as fire, release of
anhydrous ammonia etc. described elsewhere in the Plan, follow the specific procedures
applicable to such incidents set out in Section 2.1 of the Plan and in Appendices a through I, to
the extent applicable.
:
Book 4116 DENfSON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERA TTNG PROCEDURBS Page 109 of
Dale: August 18, 2009 Title: White Mesa Mill Emergeney Response Plan Ill
10. The Site Incident Commander will make the decision lo terminate the emergency or enter into
recover mode or to escalale the emergency to a different category If necessary.
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 110 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXJ
EMERGENCY EVACUATION AND SHUT DOWN PROCEDURE
1. Activate evacuation alarm by using the "dial 184" notification system. Evacuate and account for
all personnel.
2. Personnel are to assemble in one of the following areas:
• The parking lot south of the office building;
• The scalehouse;
• The north side of Tailings Cell 1, or
• North of the Mill.
The area will be designated by the Incident Commander or Shift Foreman.
3. Specific Procedure for Operations Personnel
• See specific emergency shutdown procedure for Operations by area under the relevant
Operating Procedure for your area.
o A list of the main shut-off valves and their locations is set out in Exhibit 7 to the
Plan.
• All employees not mentioned under Operating Procedures are to immediately report to the
assembly area and congregate by crew so that all persons can be accounted for. As
employees leave their work areas, they must pass the word to evacuate to any persons who
may not be aware of the emergency.
• After the Mill has been determined to be safe for re-entry, employees will be verbally
notified to return to their work stations.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page Ill of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan Ill
FIGURE!
FlRE SYSTEM SCHEMATIC DRAWING
:
I
I
I
I
I
I
I
I --·*
I
I
I
I
I
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.... ~!.,;.~
I ·. ,
u~·~ \
f'i( ~t
~! ......
t.
~ ::. If
t .. (I
)'
' F
(\ ~ :t. If J1l
I lf\ r ..( 1 -II\
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IT
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' l t
o,
~...(& .... o
11tl :'-0
0 -0 1 Q . ~~~ :s ... , .. tO <~o
!J 11~ " -~ t
" 0 ' i:O . ,. 0
~ :,8 r ~.X: DO~ I
I -. <.; ~ " D...._ ~~~ ~~~ ~ -.. ~ ..... ~ (., f r. ,~r • • I)
t "o 0 z. ~[~
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0 0 X
' ......
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,. '· s ! •Q
-~ -tit• .. -~ U!aO <( ~'
~~~ 0 • !i XQ . t :' • .J .. J -~ ..
~··~ ~iff d; fF a "~:z:.· _6il 00 i 0 2 <JPPe&""
!!~' ,. .. &lt.lll.liC .... -
,.. ~
~t~-,-r-C' "t . ··--ft t •
t. r li Cl . ·rj (I" • , ,.. ~ . . 1 .. ~ . ·-~ ,..f. ... -~ J: n .. ;~ .......
. . . . . . . . . .
Appendix
A
. . (
112 Ammonium nitrate-fuel oil 1013 120 Carbon dioxide, compressed
mixtures 1014 122 Carbon dioxide and Oxygen mixture
158 Biological agents 1014 122 Carbon dioxide and Oxygen ::
112 Blasting agent, n.o.s. mixture, compressed ~· .,
112 Explosive A 1014 122 Oxygen and Carbon dioxide ~:.:
I
112 Explosive B mixture ·l , . . )
1014 122 Oxygen and Carbon dioxide I
114 Explosive C ,,
II
mixture, compressed lj
112 Explosives, division 1.1, 1.2, .-.: ,I
1.3,1.5or1.6 1015 126 Carbon dioxide and Nitrous 'i
oxide mixture ·' 114 Explosives, division 1.4 I ·l 1015 126 Nitrous oxide and Carbon :~~
153 Toxins ...
dioxide mixture .~f "·t ,1.
1001 116 Acetylene ;,1 .,J ·:·
1001 116 Acetylene, dissolved ~~ ;
1002 122 Air, compressed ·~ ·,
•,)
1003 122 Air, refrigerated liquid 1018 126 C hlorod ifluoromethane (
(cryogenic I iq uid) :1
1018 126 Refrigerant gas R-22 '{
;! 1003 122 Air, refrigerated liquid )
(cryogenic liquid), non-1020 126 ChI oro pen tafl uoroethane J
pressurized 1020 126 Refrigerant gas R-115
j
1021 126 1-Chloro-1 ,2,2,2-'i 'l tetrafluo roetha n e _,t ..
I
1021 126 Chlorotetrafl uoroethane I
1021 126 Refrigerant gas R-124
1022 126 C hlorotrifluoromethane 'i
1022 126 Refrigerant gas R-13 ;!
1009 126 B romotrifl uoro methane l
.'\
1009 126 Refrigerant gas R-1381 ~i
1010 116P Butadienes, stabilized )I
··I 1010 116P Butadienes and hydrocarbon ·I .,
mixture, stabilized 1027 115 Cyclopropane .I, .,
--~ 1 011 115 Butane 1028 126 Diehl orad ifluoromethane . ' '! ,'I
1011 115 Butane mixture 1028 126 Refrigerant gas R-12 l ~:~:
1012 115 Butylene 1029 126 Diehl orofluoromethane ~
; ~ .
1013 120 Carbon dioxide 1029 126 Refrigerant gas R-21 : ... ,
'· . ·,l~
~. ""~' ~~ . ·:· ·~!, ... . ... • '":, .•. ._,._ ... : :-~· ·,") .. ~-· :· ·.·· .,. \· .. , . ~ :· • ... ..• . . ~· ... ~:: ;.~~:.\-, ~~, ' ....... ,. ., . ~ ·'!;.(;·!'· :; ~ , •• · .~::: ·::...-'R._···· .~ ... ~2 ~~;,~.t ~J ·~~ • v ·' ~·~! ,~, ...... ". ···~·.r\,~ ~ . .-· .. :~:-·: ....... ,..,.., ~J '·it"~•·' .. :·,··= .. -: ... '· ;· .:·!·'·.j.~·,': :~~·'"\.~'!• !~ t~~·~·£:·~'-r '··:· .l.·: ..;":'l;'t" .... , .-v~~~.~·~.~~~ ·,·aae.~· ... ; .. \'~
• TOXIC; may be fatal if inhaled, ingested or absorbed through skin.
• Vapors are extremely irritating and corrosive.
• Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite.
• Fire will produce irritating, corrosive and/or toxic gases .
• Runoff from fire control may cause pollution.
• Some may burn but none ignite readily.
• Vapors from liquefied gas are initially heavier than air and spread along ground.
• Some of these materials may react violently with water.
• Cylinders exposed to fire may vent and release toxic and/or corrosive gas through
pressure relief devices.
• Containers may explode when heated.
• Ruptured cylinders may rocket.
• CALL Emergency Response Telephone Number on Shipping Paper first. If
Shipping Paper not available or no answer, refer to appropriate telephone
number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area for at least 100 meters
(330 feet) in all directions.
• Keep unauthorized personnel away .
• Stay upwind.
• Many gases are heavier than air and will spread along ground and collect in low or
confined areas (sewers, basements, tanks).
• Keep out of low areas .
• Ventilate closed spaces before entering.
TIVE CLOTHING
• Wear positive pressure self-contained breathing apparatus (SCBA).
• Wear chemical protective clothing that is specifically recommended by the manufacturer.
It may provide little or no thermal protection.
• Structural firefighters' protective clothing provides limited protection in fire situations
ONLY; it is not effective in spill situations where direct contact with the substance is
possible.
Spill
• See Table 1 -Initial Isolation and Protective Action Distances for highlighted materials .
For non-highlighted materials, increase, in the downwind direction, as necessary, the
isolation distance shown under "PUBLIC SAFETY".
Fire
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all
directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions.
..
• Dry chemical or C0 2•
Large Fire
I Water spray, fog or regular foam.
I Move containers from fire area if you can do it without risk.
• Do not get water inside containers.
I Damaged cylinders should be handled only by specialists.
Fire involving Tanks
I Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
• Cool containers with flooding quantities of water until well after fire is out.
I Do not direct water at source of leak or safety devices; icing may occur.
• Withdraw immediately in case of rising sound from venting safety devices or
discoloration of tank. • ALWAYS stay away from tanks engulfed in fire.
• Fully encapsulating, vapor protective clothing should be worn for spills and
leaks with no fire.
• Do not touch or walk through spilled material.
• Stop leak if you can do it without risk.
• If possible, turn leaking containers so that gas escapes rather than liquid.
• Prevent entry into waterways, sewers, basements or confined areas.
• Do not direct water at spill or source of leak.
• Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to
contact spilled material. • Isolate area until gas has dispersed.
FIRST-A
• Move victim to fresh air. • Call911 or emergency medical service.
• Give artificial respiration if victim is not breathing.
• Do not use mouth-to-mouth method if victim ingested or Inhaled the substance;
give artificial respiration with the aid of a pocket mask equipped with a one-way
valve or other proper respiratory medical device.
• Administer oxygen if breathing is difficult.
• Remove and isolate contaminated clothing and shoes.
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
• In case of contact with substance, immediately flush skin or eyes with running water for
at least 20 minutes.
In case of contact with Hydrogen fluoride, anhydrous (UN1052), flush skin and
eyes with water for 5 minutes; then, for skin exposures rub on a calcium/jelly
combination ; for eyes flush with a water/calcium solution for 15 minutes.
I Keep victim warm and quiet. • Keep victim under observation .
• Effects of contact or inhalation may be delayed.
Ensure that medical personnel are aware of the material(s} involved and take
precautions to protect themselves .
(
-. . . . . . . . .
Appendix
B
-·
HOW TO USE TABLE 1 · INITIAL ISOLATION AND
PROTECTIVE ACTION DISTANCES
The responder should already have:
• Identified the material by its ID Number and Name; (if an ID Number cannot be
found, use the Name of Material index in the blue-bordered pages to locate that
number.)
• Found the three-digit guide for that material in order to consult the emergency
actions recommended jointly with this table;
• Noted the wind direction.
Look in Table 1 (the green-bordered pages) for the ID Number and Name of the Material
involved in the incident. Some ID Numbers have more than one shipping name listed-
look for the specific name of the material. (If the shipping name is not known and
Table 1 lists more than one name for the same 10 Number, use the entry with the
largest protective action distances.)
Determine if the incident involves a SMALL or LARGE spill and if DAY or NIGHT.
Generally, a SMALL SPILL is one which involves a single, small package (e.g., a drum
containing up to approximately 200 liters), a small cylinder, or a small leak from a large
package. A LARGE SPILL is one which involves a spill from a large package, or
multiple spills from many small packages. DAY is any time after sunrise and before
sunset. NIGHT is any time between sunset and sunrise.
Look up the INITIAL ISOLATION DISTANCE.
Direct all persons to move, in a crosswind
direction, away from the spill to the
distance specified-in meters and feet.
Spill
Initial Isolation
Distance
Look up the initial PROTECTIVE ACTION DISTANCE shown in Table 1. For a given
material, spill size, and whether day or night, Table 1 gives the downwind distance-in
kilometers and miles-for which protective actions should be considered. For practical
purposes, the Protective Action Zone (i.e., the area in which people are at risk of
harmful exposure) is a square, whose length and width are the same as the downwind
distance shown in Table 1.
Initiate Protective Actions to the extent possible, beginning with those closest to the
spill site and working away from the site in the downwind direction. When a water-
reactive TIH producing material is spilled into a river or stream, the source of the toxic
gas may move with the current or stretch from the spill point downstream for a substantial
distance.
The shape of the area in which protective actions should be taken (the Protective
Action Zone) is shown in this figure. The spill is located at the center of the small
circle. The larger circle represents the I~ITIAL ISOLATION zone around the spill.
Protective
Action Zone
Spill
Wind Direction
>
....
>
Downwind Distance
.... ........ ....
1/2 Downwind
Distance
1/2 Downwind
Distance
NOTE 1: See "Introduction To Table 1 -Initial Isolation And Protective Action
Distances" for factors which may increase or decrease Protective Action
Distances.
NOTE 2: See Table 2 -Water-Reactive Materials which Produce Toxic Gases for the
list of gases produced when these materials are spilled in water.
Call the emergency response telephone number listed on the shipping paper, or the
appropriate response agency as soon as possible for additional information on the materiaL
safety precautions, and mitigation procedures.
'·.
First Then First
ISOLATE PROTECT ISOLATE
in all Directions oersons Downwind durina-in all Directions
NAME OF MATERIAL Meters (Feet) DAY I NIGHT
Kilometers (Miles) Kilometers (Miles) Meters (Feet)
Ammonia, anhydrous 30m (100ft) 0.1 km (0.1 mi) 0.2km (0.1 mi) 150m (500ft) I o.Bkm
Anhydrous ammonia
Boron 1rifluoride I 30m (100ft) I 0.1 km (0.1 mi) 0.6km (0.4 mQ I 300 m (1000 ft) 1 1.9 km (12mi) 4.8km (3.0 mi)
Boron trifluoride, compressed
Carbon monoxide I 30m (100ft) I 0.1 km (0.1 mi) 0.1 km (0.1 mQ I 150m (500ft) I 0.7km (0.5mi) 2.7 km
Carbon monoxide, compressed
Chlorine 60m (200ft) 0.4km (0.3mi) 1.6km (1.0 mi) I 600 m (2000 ft) I 3.5 km (2.2 mi) B.Okm (5.0mi)
Coal gas 30m (100ft) 0.1 km (0.1 mi) 0.1 km (0.1 mi) I 60m (200ft) I 0.3 km (0.2 mi) 0.4km (0.3mi)
Coal gas, compressed
1 30m (100ft) I 0.2 km (0.1 mi) 0.9km (0.5mi) 150m (500ft) 1.0 km (0.7mi) 3.5km
Ethylene oxide I 30m (100ft) I 0.1 krn (0.1 mi) 0.2km (0.1 mi) 150m (500ft) 0.8km (0.5 mi) 2.5km
Ethy~ne oxide with Nitrogen
Fluorine I 30m (100ft) I 0.1 km (0.1 mi) 0.3 krn (0.2 mi) I 150m (500ft) I 0.8km (0.5mi) 3.1 km (1:9 mi)
Fluorine, compressed
Hydrogen bromide, anhydrous 30m (100ft) 0.1 krn (0.1 mi) 0.4km (0.3 mD 300m (1000 ft) 1.5km (1.0 mi) 4.5km
Hydrogen chloride, anhydrous 30m (100ft) 0.1 km (0.1 mi) 0.4 krn (0.2mi) 60m (200ft) 0.3km (0.2mi) 1.4km
AC (when used as a weapon) 100m (300ft) 0.3km {02mQ 1.1krn (0.7 mi] 1000 m (3000 ft) 3.8km (2.4mi) 7.2km
Hydrocyanic acid, aqueous 60m (200ft) 0.2km (0.1 mi) 0.6 krn (0.4 mi) 400m (1250 ft) 1.6km (1.0 mi) 4.1 km
solutions, with more than 20%
Hydrogen cyanide
Hydrogen cyanide, anhydrous, stabilized
Hydrogen cyanide, stabilized
Hydrogen fluoride, anhydrous I 30m (100ft) I 0.1 km (0.1 mi) 0.5km (0.3 mi) I 300 m (1000 ft) l 1.7 km (1.1 mi) 3.6km
:
PROTECTIVE CLOTHING
Street Clothing and Work Uniforms. These garments, such as uniforms worn by police
and emergency medical services personnel, provide almost no protection from the harmful
effects of dangerous goods.
Structural Fire Fighters' Protective Clothing (SFPC). This category of clothing, often
called turnout or bunker gear, means the protective clothing normally worn by fire fighters
during structural fire fighting operations. It includes a helmet, coat, pants, boots, gloves and
a hood to cover parts of the head not protected by the helmet and facepiece. This clothing
must be used with full-facepiece positive pressure self-contained breathing apparatus (SCBA).
This protective clothing should, at a minimum, meet the OSHA Fire Brigades Standard
(29 CFR 191 0.156). Structural fire fighters' protective clothing provides limited protection
from heat and cold, but may not provide adequate protection from the harmful vapors or
liquids that are encountered during dangerous goods incidents. Each guide includes a
statement about the use of SFPC in incidents involving those materials referenced by that
guide. Some guides state that SFPC provides limited protection. In those cases, the responder
wearing SFPC and SCBA may be able to perform an expedient, that is quick "in-and-out",
operation. However, this type of operation can place the responder at risk of exposure,
injury or death. The incident commander makes the decision to perform this operation only
if an overriding benefit can be gained (i.e., perform an immediate rescue, turn off a valve to
control a leak, etc.). The coverall-type protective clothing customarily worn to fight fires in
forests or wildlands is not SFPC and is not recommended nor referred to elsewhere in this
guidebook.
Positive Pressure Self~Contained Breathing Apparatus (SCBA). This apparatus provides
a constant, positive pressure flow of air within the facepiece, even if one inhales deeply while
doing heavy work. Use apparatus certified by NIOSH and the Department of Labor/Mine
Safety and Health Administration in accordance with 42 CFR Part 84. Use it in accordance
with the requirements for respiratory protection specified in OSHA 29 CFR 1910.134
(Respiratory Protection) and/or 29 CFR 1910.156 (f) (Fire Brigades Standard). Chemical-
cartridge respirators or other filtering masks are not acceptable substitutes for positive pressure
self-contained breathing apparatus. Demand~type SCBA does not meet the OSHA 29 CFR
1910.156 (f)(1 )(i) of the Fire Brigades Standard. If it is suspected that a Chemical Warfare
Agent (CW) is involved, the use of NIOSH-certified respirators with CBRN protection are
highly recommended.
Chemical Protective Clothing and Equipment. Safe use of this type of protective clothing
and equipment requires specific skills developed through training and experience. It is
generally not available to, or used by, first responders. This type of special clothing may
protect against one chemical, yet be readily permeated by chemicals for which it was not
designed. Therefore, protective clothing should not be used unless it is compatible with the
released material. This type of special clothing offers little or no protection against heat and/
or cold. Examples of this type of equipment have been described as (1) Vapor Protective
Page 348
Suits (NFPA 1991), also known as Totally-Encapsulating Chemical Protecttve (TECP) Suits
or Level A* protection (OSHA 29 CFR 1910.120, Appendix A & B), and (2) Liquid-Splash
Protective Suits (NFPA 1992 & 1993), also known as Level B* or C* protection (OSHA 29
CFR 1910.120, Appendix A & B) or suits for chemical/biological terrorism incidents (NFPA
1994 ), class 1, 2 or 3 Ensembles. No single protective clothing material will protect you from
all dangerous goods. Do not assume any protective clothing Is resistant to cold and/or heat
or flame exposure unless it is so certified by the manufacturer. (NFPA 1991 5-3 Flammability
Resistance Test and 5-6 Cold Temperature Performance Test)
* Consult glossary for additional protection lev~ Is under the heading ftProtective Clothing" .
. ·
Page 349
Appendix
c
1063 115 Refrigerant gas R-40
1065 Neon, compressed
1 066 121 Nitrogen
1066 121 Nitrogen, compressed
1072 122
1072 122
1073 122
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
Oxygen
Oxygen, compressed
Oxygen, refrigerated liquid
(cryogenic liquid)
Butane
Butane mixture
Butylene
lsobutane
lsobutane mixture
lsobutylene
Liquefied petroleum gas
LPG
Petroleum gases, liquefied
Propane
Propane mixture
Propylene
. :·! I o o -·~. ·-. .. . . ...... ·•. :
1077 115 Propylene
1078 126 Dispersant gas, n.o.s.
1078 126 Refrigerant gas, n.o.s.
1080 126 Sulfur hexafluoride
.1.080 126 Sulphur hexafluoride
1081 116P Tetrafluoroethylene, stabilized
118 Trimethylamine, anhydrous
1085 116P Vinyl bromide, stabilized
1086 116P Vinyl chloride, stabilized
1087 116P Vinyl methyl ether, stabilized
1088 127 Acetal
1089 129 Acetaldehyde
1090 127 Acetone
1091 127 Acetone oils
1099 131 Allyl bromide
1100 131 Allyl chloride
1104 129 Amyl acetates
1105 129 Amyl alcohols
1105 129 Pentanols
1106 132 Amylamines
1107 129 Amyl chloride
1108 128 n-Amylene
1108 128 1-Pentene
1109 129 Amyl formates
1110 127 n-Amyl methyl ketone
1110 127 Amyl methyl ketone
·i ,I
i
'! .. •·j 'l; ··t \ ., i
1
> .,
..
·~· .,
.1 ..
;
:
:I
..
'l :··l
'4 .,
.•
.........
•' ;\
i ·! ·I
)
i ;o
·= .
.... l ~·.: :
llj
• tt ··;••.: • ,,. •••"' ,~. • • ' I 'P ' 29 t• ~ ~·: .. :.· .. '\, ·. · . ~· _,. Jaae· · ·
• Will be easily ignited by heat, sparks or flames.
• Will form explosive mixtures with air.
• Vapors from liquefied gas are initially heavier than air and spread along ground.
CAUTION:Hydrogen (UN1049), Deuterium (UN1957), Hydrogen, refrigerated liquid
(UN1966) and Methane (UN1971) are lighter than air and will rise. Hydrogen and
Deuterium fires are difficult to detect since they burn with an invisible flame. Use
an alternate method of detection (thermal camera, broom handle, etc.)
• Vapors may travel to source of ignition and flash back.
• Cylinders exposed to fire may vent and release flammable gas through pressure relief
devices.
I Containers may explode when heated.
• Ruptured cylinders may rocket.
• Vapors may cause dizziness or asphyxiation without warning.
• Some may be irritating if inhaled at high concentrations.
• Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite .
• Fire may produce irritating·and/or toxic gases.
• CALL Emergency Response Telephone Number on Shipping Paper first. If
Shipping Paper not available or no answer, refer to appropriate telephone
number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area for at least 100 meters
(330 feet) in all directions.
I Keep unauthorized personnel away.
• Stay upwind .
• Many gases are heavier than air and will spread along ground and collect in low or
confined areas (sewers, basements, tanks).
• Keep out of low areas.
LOTH lNG
Large Spill
• Consider initial downwind evacuation for at least 800 meters (1/2 mile).
Fire
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all
directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions.
• DO NOT EXTINGUISH A LEAKING GAS FIRE UNLESS LEAK CAN BE STOPPED.
CAUTION: Hydrogen (UN1049), Deuterium (UN1957) and Hydrogen, refrigerated liquid
(UN1966) burn with an invisible flame. Hydrogen and Methane mixture, compressed
(UN2034) may burn with an invisible flame.
Small Fire
• Dry chemical or C02.
large Fire
• Water spray or fog.
I Move containers from fire area if you can do it without risk.
Fire involving Tanks
I Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
I Cool containers with flooding quantities of water until well after fire is out.
• Do not direct water at source of leak or safety devices; icing may occur.
I Withdraw immediately in case of rising sound from venting safety devices or
discoloration of tank.
• ALWAYS stay away from tanks engulfed in fire.
• For massive fire, use unmanned hose holders or monitor nozzles; if this is impossible,
withdraw from area and let fire burn.
SP
• ELIMINATE all ignition sources (no smoking, flares, sparks or flames in immediate area).
• All equipment used when handling the product must be grounded.
• Do not touch or walk through spilled material.
• Stop leak if you can do it without risk.
• If possible, turn leaking containers so that gas escapes rather than liquid.
I Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to
contact spilled material.
Do not direct water at spill or source of leak.
• Prevent spreading of vapors through sewers, ventilation systems and confined areas.
I Isolate area until gas has dispersed.
CAUTION: When in contact with refrigerated/cryogenic liquids, many materials become
brittle and are likely to break without warning.
FIRST AID.
I Move victim to fresh air. I Call 911 or emergency medical service.
I Give artificial respiration if victim is not breathing.
• Administer oxygen if breathing is difficult.
I Remove and isolate contaminated clothing and shoes.
• Clothing frozen to the skin should be thawed before being removed.
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
• In case of burns, immediately cool affected skin for as long as possible with cold water. Do
not remove clothing if adhering to skin. • Keep victim warm and quiet.
I Ensure that medical personnel are aware of the material(s) involved and take precautions t
protect themselves.
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Cell 4A and 4B BAT Monitoring, Operations and Maintenance Plan.

TABLE OF CONTENTS

1.0 Introduction .............................................................................................................. 2 
2.0 Cell Design............................................................................................................... 2 
2.1 Cell 4A Design ................................................................................................. 2 
2.2 Cell 4B Design ................................................................................................. 5 
3.0 Cell Operation .......................................................................................................... 8 
3.1 Solution Discharge to Cell 4A .......................................................................... 8 
3.2 Solution Discharge to Cell 4B .......................................................................... 8 
3.3 Initial Solids Discharge into Cell 4A ................................................................ 9 
3.4 Initial Solids Discharge into Cell 4B ................................................................ 9 
3.5 Equipment Access to Cell 4A and Cell 4B ..................................................... 10 
3.6 Reclaim Water System at Cell 4A .................................................................. 10 
3.7 Reclaim Water System at Cell 4B .................................................................. 10 
3.8 Interim Solids Discharge to Cell 4A............................................................... 11 
3.9 Interim Solids Discharge to Cell 4B ............................................................... 11 
3.10 Liner Maintenance and QA/QC for Cell 4A ............................................... 11 
3.11 Liner Maintenance and QA/QC for Cell 4B ............................................... 11 
4.0 BAT Performance Standards for Tailings Cell 4A and 4B .................................... 11 
5.0 Routine Maintenance and Monitoring ................................................................... 13 
5.1 Solution Elevation .......................................................................................... 13 
5.2 Leak Detection System ................................................................................... 13 
5.3 Slimes Drain System ...................................................................................... 15 
6.0 Tailings Emergencies ............................................................................................. 16 
7.0 Solution Freeboard Calculations ............................................................................ 16 
8.0 List of Attachments ................................................................................................ 18 

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1.0 Introduction

Construction of Cell 4A was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control (“DRC) on June 25, 2007. The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the
Groundwater Discharge Permit No. UGW370004 (“GWDP”) and fulfill the
requirements of Parts I.D.6, I.E.8, and I.F.9 of the GWDP.

Construction of Cell 4B was authorized by DRC on June 21, 2010. The construction
authorization provided that Cell 4B shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part I.F.3 of the GWDP and
fulfill the requirements of Parts I.D.12, I.E.12, and I.F.9 of the GWDP

2.0 Cell Design

2.1 Cell 4A Design

Tailings Cell 4A consists of the following major elements:
a) Dikes – consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to 1V. The west dike has an interior slope of 2H to
1V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from 89-feet on the
east dike (with no exterior embankment), to 211-feet at the west dike.
b) Foundation – including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 90%. Floor of
Cell 4A has an average slope of 1% that grades from the northeast to the
southwest corners.
c) Tailings Capacity – the floor and inside slopes of Cell 4A encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems – including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) – consisting of impermeable 60
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mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4A floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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2) Leak Detection System – includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4A, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML – consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4A floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner – consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4A, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28, 2007
e) Slimes Drain Collection System – including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System – is installed in a herringbone pattern
across the floor of Cell 4A that drain to a “backbone” of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System – includes a “backbone”
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. The non-woven geotextile
material is overlain at the surface by a woven geotextile fabric, which is
ballasted laterally by sandbags on each side of the backbone of the berm.
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In turn, the gravel is overlain by a layer of non-woven geotextile to serve
as an additional filter material. This perforated collection pipe serves as
the “backbone” to the slimes drain system and runs from the far northeast
corner downhill to the far southwest corner of Cell 4A where it joins the
slimes drain access pipe.
3) Slimes Drain Access Pipe – consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and nonwoven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted by sandbags.A reducer
connects the horizontal 18-inch pipe with the 4-inch SDC pipe. At some
future time, a pump will be set in this 18-inch pipe and used to remove
tailings wastewaters for purposes of de-watering the tailings cell.
f) Dike Splash Pads – A minimum of eight (8) 20-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads consist of an extra layer of 60 mil
HDPE membrane that is placed down the inside slope of Cell 4A, from the top
of the dike and down the inside slope. The pads extend to a point 5-feet
beyond the toe of the slope to protect the liner bottom during initial startup of
the Cell. The exact location of the splash pads is detailed on the As-Built
Plans and Specifications.
g) Rub Protection Sheets – In addition to the splash pads described in f) above,
rub sheets are installed beneath all piping entering or exiting Cell 4A that is
not located directly on the splash pads.
h) Emergency Spillway – a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. A second
spillway has been constructed in the southwest corner of Cell 4A to allow
emergency runoff from Cell 4A into Cell 4B. All stormwater runoff and
tailings wastewaters not retained in Cells 3 and 4A, will be managed and
contained in Cell 4B, including the Probable Maximum Precipitation and
flood event.

2.2 Cell 4B Design

Tailings Cell 4B consists of the following major elements:
a) Dike – consisting of a newly-constructed dike on the south side of the cell
with a 15-foot wide road at the top (minimum) to support an access road.
The grading plan for the Cell 4B excavation includes interior slopes of 2H
to 1V. The exterior slope of the southern dike will have the typical slopes
of 3H to 1V. Limited portions of the Cell 4B interior sideslopes in the
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northwest corner and southeast corner of the cell (where the slimes drain
and leak detection sump will be located) will also have a slope of 3H to
1V. The base width of the southern dike varies from approximately 100
feet at the western end to approximately 190 feet at the eastern end of the
dike, with no exterior embankment present on any other side of the cell.
b) Foundation – including subgrade soils over bedrock materials. Foundation
preparation included 6-inch over excavation of rock and placement and
compaction of imported soils to a maximum dry density of 90% at a
moisture content between +3% and -3% of optimum moisture content, as
determined by ASTM D-1557. The floor of Cell 4B has an average slope
of 1% that grades from the northwest corner to the southeast corner.
c) Tailings Capacity – the floor and inside slopes of Cell 4B encompass
about 45 acres and the cell will have a water surface area of 40 acres and a
maximum capacity of about 1.9 million cubic yards of tailings material
storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems – including the following layers, in
descending order:
1) Primary Flexible Membrane Liner (FML) – consisting of 60 mil high
density polyethylene (HDPE) membrane that extends across both the
entire cell floor and the inside side-slopes, and is anchored in a trench at
the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4B floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
2) Leak Detection System – includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4B, and
drains to a leak detection sump in the southeast corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
3) Secondary FML – consisting of a 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends
across the entire Cell 4B floor, up the inside side-slopes and is also
anchored in a trench at the top of all four dikes.
4) Geosynthetic Clay Liner – consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4B, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50% by weight.
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e) Slimes Drain Collection System – including a two-part system of strip
drains and perforated collection pipes both installed immediately above
the primary FML, as follows:
1) Horizontal Strip Drain System – is installed in a herringbone pattern
across the floor of Cell 4B that drain to a “backbone” of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 50-foot centers,
where they conduct fluids downgradient in a southeasterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System – includes a “backbone”
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact with the primary FML. In turn, the gravel is overlain
by a layer of non-woven geotextile to serve as an additional filter material.
The non-woven geotextile material is overlain at the surface by a woven
geotextile fabric, which is ballasted by sandbags. This perforated
collection pipe serves as the “backbone” to the slimes drain system and
runs from the far northwest corner downhill to the far southeast corner of
Cell 4B where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe – consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4B at the southeast corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and non-woven geotextile that serves as a cushion to protect the primary
FML. The non-woven geotextile material is overlain at the surface by a
woven geotextile fabric, which is ballasted laterally by sandbags on each
side of the backbone of the berm. A reducer connects the horizontal 18-
inch pipe with the 4-inch SDC pipe. At some future time, a pump will be
set in this 18-inch pipe and used to remove tailings wastewaters for
purposes of de-watering the tailings cell.
f) Cell 4B North and East Dike Splash Pads - Nine 20-foot-wide splash pads
will be constructed on the north and east dikes to protect the primary FML
from abrasion and scouring by tailings slurry. These pads will consist of
an extra layer of textured, 60 mil HDPE membrane that will be installed in
the anchor trench and placed down the inside slope of Cell 4B, from the
top of the dike, under the inlet pipe, and down the inside slope to a point at
least 5 feet onto the Cell 4B floor beyond the toe of the slope.
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g) Rub Protection Sheets – In addition to the splash pads described in f)
above, rub sheets are installed beneath all piping entering or exiting Cell
4B that is not located directly on the splash pads.
h) Emergency Spillway – a concrete lined spillway constructed near the
southern corner of the east dike to allow emergency runoff from Cell 4A
into Cell 4B. This spillway will be limited to a 6-inch reinforced concrete
slab, with a welded-wire fabric installed within its midsection, set atop a
cushion geotextile placed directly over the primary FML in a 4-foot deep
trapezoidal channel. A 100 foot wide, 60 mil HDPE geomembrane splash
pad will be installed beneath the emergency spillway. No other spillway
or overflow structure will be constructed at Cell 4B. All stormwater
runoff and tailings wastewaters not retained in Cells 2, 3 and 4A, will be
managed and contained in Cell 4B, including the Probable Maximum
Precipitation and flood event.

3.0 Cell Operation

3.1 Solution Discharge to Cell 4A
Cell 4A will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3, or transferred from Cell 2
tailings dewatering operations. The solution will be pumped to Cell 4A through
appropriately sized pipelines. The initial solution discharge will be in the
southwest corner of the Cell. The solution will be discharged in the bottom of
the Cell, away from any sand bags or other installation on the top of the FML.
Building the solution pool from the low end of the Cell will allow the solution
pool to gradually rise around the slimes drain strips, eliminating any damage to
the strip drains or the sand bag cover due to solution flowing past the drainage
strips. The solution will eventually be discharged along the dike between Cell 3
and Cell 4A, utilizing the Splash Pads described above. The subsequent discharge
of process solutions will be near the floor of the pond, through a discharge header
designed to discharge through multiple points, thereby reducing the potential to
damage the Splash Pads or the Slimes Drain system. At no time, subsequent to
initial filling, will the solution be discharged into less than 2 feet of solution. As
the cell begins to fill with solution the discharge point will be pulled back up the
Splash Pad and allowed to continue discharging at or near the solution level.

3.2 Solution Discharge to Cell 4B
Cell 4B will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3 or Cell 4A, or transferred
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from Cell 2 dewatering operations. The solution will be pumped to Cell 4B
through appropriate sized pipelines pipelines. The initial solution discharge will
be in the southeast corner of the Cell. The discharge pipe will be routed down the
Splash Pad provided in the southeast corner of the Cell at the spillway to protect
the primary FML. The solution will be discharged in the bottom of the Cell, away
from any sand bags or other installation on the top of the FML. Building the
solution pool from the low end of the Cell will allow the solution pool to
gradually rise around the slimes drain strips, eliminating any damage to the strip
drains or the sand bag cover due to solution flowing past the drainage strips. The
solution will eventually be discharged along the dike between Cell 3 and Cell 4B,
utilizing the Splash Pads described above. The subsequent discharge of process
solutions will be near the floor of the pond, through a discharge header designed
to discharge through multiple points, thereby reducing the potential to damage the
Splash Pads or the Slimes Drain system. At no time, subsequent to initial filling,
will the solution be discharged into less than 2 feet of solution. As the cell begins
to fill with solution the discharge point will be pulled back up the Splash Pad and
allowed to continue discharging at or near the solution level.

3.3 Initial Solids Discharge into Cell 4A
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4A, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1A. Figure
2A illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6” or 8” stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2A. Because of the
depth of Cell 4A, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.

3.4 Initial Solids Discharge into Cell 4B
Once Cell 4B is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through appropriately sized
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pipelines. The pipelines will be routed along the dike between Cell 3 and Cell
4B, with discharge valves and drop pipes extending down the Splash Pads to the
solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1B. Figure
2B illustrates the general location of the solution and slurry discharge pipelines
and control valve locations. The valves are 6” or 8” stainless steel knife-gate
valves. The initial discharge of slurry will be at or near the toe of the Cell slope
and then gradually moved up the slope, continuing to discharge at or near the
water surface. This is illustrated in Section A-A on Figure 2B. Because of the
depth of Cell 4B, each of the discharge points will be utilized for an extended
period of time before the cone of material is above the maximum level of the
solution. The discharge location will then be moved further to the interior of the
cell allowing for additional volume of solids to be placed under the solution level.
The solution level in the cell will vary depending on the operating schedule of the
Mill and the seasonal evaporation rates. The tailings slurry will not be allowed to
discharge directly on to the Splash Pads, in order to further protect the FML. The
tailings slurry will discharge directly in to the solution contained in the Cell, onto
an additional protective sheet, or on to previously deposited tailings sand.

3.5 Equipment Access to Cell 4A and Cell 4B
Access will be restricted to the interior portion of the cells due to the potential to
damage the flexible membrane liners. Only low pressure rubber tired all terrain
vehicles or foot traffic will be allowed on the flexible membrane liners. Personnel
are also cautioned on the potential damage to the flexible membrane liners
through the use and handling of hand tools and maintenance materials.

3.6 Reclaim Water System at Cell 4A
A pump barge and solution recovery system is operating in the southwest corner
of the cell to pump solution from the cell for water balance purposes or for re-use
in the Mill process. Figure 3A illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.

3.7 Reclaim Water System at Cell 4B
A pump barge and solution recovery system will be installed in the southeast
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3B illustrates the routing of the solution return
pipeline and the location of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
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the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.

3.8 Interim Solids Discharge to Cell 4A
Figure 4A illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4A. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.

3.9 Interim Solids Discharge to Cell 4B
Figure 4B illustrates the progression of the slurry discharge points around the
north and east sides of Cell 4B. Once the tailings solids have been deposited
along the north and east sides of the Cell, the discharges points will subsequently
be moved to the sand beaches, which will eliminate any potential for damage to
the liner system.

3.10 Liner Maintenance and QA/QC for Cell 4A
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised Construction Quality
Assurance Plan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.

3.11 Liner Maintenance and QA/QC for Cell 4B
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Construction Quality Assurance Plan
for the Construction of the Cell 4B Lining System, October 2009, by
Geosyntec Consultants.

4.0 BAT Performance Standards for Tailings Cell 4A and 4B
DUSA will operate and maintain Tailings Cell 4A and 4B so as to prevent release of
wastewater to groundwater and the environment in accordance with this BAT Monitoring
Operations and Maintenance Plan, pursuant to Part I.H.8 of the GWDP. These
performance standards shall include:

1) Leak Detection System Pumping and Monitoring Equipment – the
leak detection system pumping and monitoring equipment in each cell
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includes a submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system in each
cell at no more than 1 foot above the lowest level of the secondary flexible
membrane, not including the sump. A second leak detection pump with
pressure transducer, flow meter, and manufacturer recommended spare
parts for the pump controller and water level data collector is maintained
in the Mill warehouse to ensure that the pump and controller can be
replaced and operational within 24 hours of detection of a failure of the
pumping system. The root cause of the equipment failure will be
documented in a report to Mill management with recommendations for
prevention of a re-occurrence.

2) Maximum Allowable Head – the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane in each cell
by the use of procedures and equipment specified in the White Mesa
Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan, 10/10 Revision: Denison-10.2,
or the currently approved DMT Plan. Under no circumstance shall fluid
head in the leak detection system sump exceed a 1-foot level above the
lowest point in the lower flexible membrane liner, not including the
sump.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from each LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day for Cell 4A or 26,145 gallons/day for Cell
4B. The maximum daily LDS flow volume will be compared against the
measured cell solution levels detailed on the attached Table 1A or 1B for
Cells 4A or 4B, respectively, to determine the maximum daily allowable
LDS flow volume for varying head conditions in the cell.
4) 3-foot Minimum Vertical Freeboard Criteria – the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell 4A and Cell 4B. Said measurements
shall be made to the nearest 0.1 foot.
5) Slimes Drain Recovery Head Monitoring – immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4A or Cell
4B slimes drain system, quarterly recovery head tests and fluid level
measurements will be made in accordance with a plan approved by the
DRC Executive Secretary. The slimes drain system pumping and
monitoring equipment, includes a submersible pump, pump controller,
water level indicator (head monitoring), and flow meter with volume
totalizer.

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5.0 Routine Maintenance and Monitoring

Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection reports are
summarized on a monthly basis and reviewed and signed by the Mill Manager and RSO.

5.1 Solution Elevation

Measurements of solution elevation in Cell 4A and Cell 4B are to be taken by
survey on a weekly basis, and measurements of the beach area in Cell 4A and Cell
4B with the highest elevation are to be taken by survey on a monthly basis, by the
use of the procedures and equipment specified in the latest approved edition of the
DMT Plan.

5.2 Leak Detection System

The Leak Detection System in Cell 4A and Cell 4B is monitored on a
continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The water levels are measured
every hour and the information is stored for later retrieval. The water
levels are measured to the nearest 0.10 inch. The data collector is
currently programmed to store 7 days of water level information. The
number of days of stored data can be increased beyond 7 days if needed.
The water level data is downloaded to a laptop computer on a weekly
basis and incorporated into the Mill’s environmental monitoring data base,
and into the files for weekly inspection reports of the tailings cell leak
detection systems. Within 24 hours after collection of the weekly water
level data, the information will be evaluated to ensure that: 1) the water
level in the Cell 4A and Cell 4B leak detection sumps did not exceed the
allowable level (5556.14 feet amsl in the Cell 4A LDS sump and 5558.5
feet amsl in the Cell 4B sump), and 2) the average daily flow rate from the
LDS did not exceed the maximum daily allowable flow rate at any time
during the reporting period. For Cell 4A and Cell 4B, under no
circumstance shall fluid head in the leak detection system sump exceed a
1-foot level above the lowest point in the lower flexible membrane liner,
not including the sump. To determine the Maximum Allowable Daily
LDS Flow Rates in the Cell 4A and Cell 4B leak detection system, the
total volume of all fluids pumped from the LDS of each cell on a weekly
basis shall be recovered from the data collector, and that information will
be used to calculate an average volume pumped per day for each cell.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day from Cell 4A or 26,145 gallons/day from Cell 4B. The
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maximum daily LDS flow volume will be compared against the measured
cell solution levels detailed on the attached Tables 1A and 1B, to
determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A and Cell 4B. Any abnormal or out of
compliance water levels must be immediately reported to Mill
management. The data collector on each cell is also equipped with an
visual strobe light that flashes on the control panel if the water level in the
leak detection sump exceeds the allowable level (5556.14 feet amsl in the
Cell 4A LDS sump and 5558.5 feet amsl in the Cell 4B sump). The
current water level is displayed at all times on each data collector and
available for recording on the daily inspection form. Each leak detection
system is also equipped with a leak detection pump, EPS Model # 25S05-
3 stainless steel, or equal. Each pump is capable of pumping in excess of
25 gallons per minute at a total dynamic head of 50 feet. Each pump has a
1.5 inch diameter discharge, and operates on 460 volt 3 phase power.
Each pump is equipped with a pressure sensing transducer to start the
pump once the level of solution in the leak detection sump is
approximately 2.25 feet (elevation 5555.89 in the Cell 4A LDS sump and
5557.69 feet amsl in the Cell 4B sump) above the lowest level of the leak
detection sump (9 inches [0.75 feet] above the lowest point on the lower
flexible membrane liner for Cell 4A and 2 1/4 inches [0.19 feet] for Cell
4B), to ensure the allowable 1.0 foot (5556.14 feet amsl in the Cell 4A
LDS sump and 5558.5 feet amsl in the Cell 4B sump) above the lowest
point on the lower flexible membrane liner is not exceeded). The attached
Figures 6A and 6B (Cell 4A and 4B, respectively), Leak Detection Sump
Operating Elevations, illustrates the relationship between the sump
elevation, the lowest point on the lower flexible membrane liner and the
pump-on solution elevation for the leak detection pump. The pump also
has manual start and stop controls. The pump will operate until the
solution is drawn down to the lowest level possible, expected to be
approximately 4 inches above the lowest level of the sump (approximate
elevation 5554.0 and 5555.77 ft amsl for Cells 4A and 4B, respectively).
The pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
are recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
perforated section of the PVC collection pipe. The distance from the top
flange face, at the collection pipe invert, to the centerline of the 22.5
degree elbow is 133.4 feet in Cell 4A and 135.6 feet in Cell 4B, and the
vertical height is approximately 45 feet in Cell 4A and approximately 42.5
feet in Cell 4B. The pump is installed at least 2 feet beyond the centerline
of the elbow. The bottom of the pump will be installed in the leak
detection sump at least 135.4 feet in Cell 4A and 137.6 feet in Cell 4B or
more from the top of the flange invert. A pressure transducer installed
within the pump continuously measures the solution head and is
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programmed to start and stop the pump within the ranges specified above.
The attached Figure 5, illustrates the general configuration of the pump
installation.
A spare leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller on either cell can be replaced and operational
within 24 hours of detection of a failure of the pumping system. The root
cause of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.

5.3 Slimes Drain System

(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe of each cell and a near
as possible to the bottom of the slimes drain sump. The bottom of the
slimes drain sump in Cell 4A and Cell 4B are 38 and 35.9 feet below a
water level measuring point, respectively, at the centerline of the slimes
drain access pipe, near the ground surface level. Each pump discharge
will be equipped with a 2 inch flow meter, E/H Model #33, or equal, that
reads the pump discharge in gallons per minute, and records total gallons
pumped. The flow rate and total gallons will be recorded by the Inspector
on the weekly inspection form.
(ii) The slimes drain pumps will be on adjustable probes that allow the pumps
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 4A and Cell 4B slimes drain pumps will be checked weekly to
observe that they are operating and that the level probes are set properly,
which is noted on the Weekly Tailings Inspection Form. If at any time
either pump is observed to be not working properly, it will be repaired or
replaced within 15 days;
(iv) Depth to wastewater in the Cell 4A and Cell 4B slimes drain access riser
pipes shall be monitored and recorded weekly to determine maximum and
minimum fluid head before and after a pumping cycle, respectively. All
head measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) After initiation of pumping conditions in Tailings Cell 4A or 4B, n a
quarterly basis, each slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on a Quarterly Data form, by
measuring the depth to water below the water level measuring point on the
slimes drain access pipe;
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The slimes drain pumps for each cell will not be operated until Mill management
has determined that no additional process solutions will be discharged to that cell,
and the cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell 2.
6.0 Tailings Emergencies

Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occurred that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.

Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).

7.0 Solution Freeboard Calculations

The maximum tailings cell pond wastewater levels in Cell 1, Cell 2, Cell 3, Cell 4A, and
Cell 4B are regulated by condition 10.3 of the White Mesa Mill 11e.(2) Materials
License. However, freeboard limits are no longer applicable to Cell 2, Cell 3, and Cell
4A, as discussed below.

Condition 10.3 states that “Freeboard limits, stormwater and wastewater management for
the tailings cells shall be determined as follows:

A. The freeboard limit for Cell 1 shall be set annually in accordance
with the procedures set out in Section 3.0 to Appendix E of the
previously approved NRC license application, including the
January 10, 1990 Drainage Report. Discharge of any surface water
or wastewater from Cell 1 is expressly prohibited.
B. The freeboard limit for Cell 4B shall be recalculated annually in
accordance with the procedures established by the Executive
Secretary. Said calculations for freeboard limits shall be submitted
as part of the Annual Technical Evaluation Report (ATER), as
described in Condition 12.3 below [of the license and not included
herein]. Based on approved revisions to the DMT Plan dated
January 2011, the freeboard limit is no longer applicable to Cells 2,
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3 and 4A.
C. The discharge of any surface water, stormwater, or wastewater
from Cells 3, 4A, and 4B shall only be through an Executive
Secretary authorized spillway structure. [Applicable NRC
Amendment:16] [Applicable UDRC Amendment: 3] [Applicable
UDRC Amendment:4]”

The freeboard limits set out in Section 6.3 of the DMT Plan are intended to capture the
Local 6-hour Probable Maximum Precipitation (PMP) event, which was determined in
the January 10, 1990 Drainage Report for the White Mesa site to be 10 inches.

Based on the PMP storm event, the freeboard requirement for Cell 1 is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell 1 freeboard
limit is not affected by operations or conditions in Cells 2, 3, 4A, or 4B.

Cells 2 and 3 have no freeboard limit because those Cells are full or near full of tailings
solids. Cell 4A has no freeboard limit because it is assumed that all precipitation falling
on Cell 4A will overflow to Cell 4B. All precipitation falling on Cell 2, 3, and 4A and
the adjacent drainage areas must be contained in Cell 4B. The flood volume from the
PMP event over the Cell 2, 3, and Cell 4A pond areas, plus the adjacent drainage areas,
which must be contained in Cell 4B, is 159.4 acre-feet of water.

The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of 10 inches). For the
purposes of establishing the freeboard in Cell 4B, it is assumed Cell 4A has no freeboard
limit and all of the flood volume from the PMP event will be contained in Cell 4B. The
flood volume from the PMP event over the Cell 4B area is 38.1 acre-feet of water (40
acres, plus the adjacent drainage area of 5.7 acres, times the PMP of 10 inches). This
would result in a total flood volume of 197.5 acre-feet, including the 123.4 acre-feet of
solution from Cells 2 and 3 and 36 acre-feet of solution from Cells 2, 3, and 4A that must
be contained in Cell 4B. The procedure for calculating the freeboard limit for Cell 4B is
set out in the DMT Plan.

The Groundwater Quality Discharge Permit, No. UGW370004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for Cells 1, 4A, and 4B but
based on License condition 10.3 and the procedure set out in the DMT Plan, the
freeboard limits for Cells 1, 4A, and 4B will be at least three feet.

Figure 7, Hydraulic Profile Schematic, shows the relationship between the Cells, and the
relative elevations of the solution pools and the spillway elevations.

The required freeboard for Cell 4B will be recalculated annually.

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8.0 List of Attachments

1) Figures 1A and 1B, Initial Filling Plan, Geosyntec Consultants

2) Figure 2A and 2B, Initial Filling Plan, Details and Sections, Geosyntec
Consultants

3) Figure 3A and 3B, Initial Filling Plan, Solution and Slurry Pipeline Routes,
Geosyntec Consultants

4) Figure 4A and 4B, Interim Filling Plan, Geosyntec Consultants

5) Figure 5, Leak Detection System Sumps for Cell 4A and 4B, Geosyntec
Consultants

6) Figure 6A and 6B, Leak Detection Sump Operating Elevations, Geosyntec
Consultants

7) Figure 7, Hydraulic Profile Schematic

8) Cell 4A and Cell 4B Freeboard Calculations

9) Table 1A, Calculated Action leakage Rates for Various Head Conditions,
Cell 4A, White Mesa Mill, Blanding, Utah, Geosyntec Consultants

10) Table 1B, Calculated Action leakage Rates for Various Head Conditions,
Cell 4B, White Mesa Mill, Blanding, Utah, Geosyntec Consultants

11) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan.

Area of Maps and Aerial Photos:
 Topography
 Relief
 Spring Locations
 Drainages

Utah Division of Water Rights
Explanation
Reference

Page 1 of 1
6/20/2012http://maps.waterrights.utah.gov/cgi-bin/mapserv.exe
Utah Division of Water Rights
Explanation
Reference

Page 1 of 1
6/20/2012http://maps.waterrights.utah.gov/cgi-bin/mapserv.exe
Utah Division of Water Rights
Explanation
Reference

Page 1 of 1
6/20/2012http://maps.waterrights.utah.gov/cgi-bin/mapserv.exe
Utah Division of Water Rights
Explanation
Reference

Page 1 of 1
6/20/2012http://maps.waterrights.utah.gov/cgi-bin/mapserv.exe
Utah Division of Water Rights
Explanation
Reference

Page 1 of 1
6/20/2012http://maps.waterrights.utah.gov/cgi-bin/mapserv.exe
Table 2.4-1
Permit Monitoring Wells (Depth and Purpose)
Well Location Total Depth Purpose
MW-1 115.00 Semi-Annual Groundwater Compliance
MW-2 125.00 Semi-Annual Groundwater Compliance
MW-3 96.00 Semi-Annual Groundwater Compliance
MW-3A 95.00 Semi-Annual Groundwater Compliance
MW-4 122.00 No Longer Included In Groundwater
Program
MW-5 138.50 Semi-Annual Groundwater Compliance
MW-11 135.00 Quarterly Groundwater Compliance
MW-12 129.00 Semi-Annual Groundwater Compliance
MW-14 127.00 Quarterly Groundwater Compliance
MW-15 134.00 Semi-Annual Groundwater Compliance
MW-17 110.00 Semi-Annual Groundwater Compliance
MW-18 148.50 Semi-Annual Groundwater Compliance
MW-19 149.00 Semi-Annual Groundwater Compliance
MW-20 114.50 Semi-Annual Groundwater Monitoring
MW-22 140.00 Semi-Annual Groundwater Monitoring
MW-23 129.00 Semi-Annual Groundwater Compliance
MW-24 119.90 Semi-Annual Groundwater Compliance
MW-25 115.10 Quarterly Groundwater Compliance
MW-26 121.33 Quarterly Groundwater Compliance
MW-27 91.00 Semi-Annual Groundwater Compliance
MW-28 106.00 Semi-Annual Groundwater Compliance
MW-29 125.00 Semi-Annual Groundwater Compliance
MW-30 107.00 Quarterly Groundwater Compliance
MW-31 129.00 Quarterly Groundwater Compliance
MW-32 133.70 Semi-Annual Groundwater Compliance
MW-33 103.50 Dry, Not sampled
MW-34 109.00 Water Level Monitoring only
MW-35 123.60 Quarterly Groundwater for Background
MW-36 119.90 Quarterly Groundwater for Background
MW-37 120.20 Quarterly Groundwater for Background

Table 2.5.2.1-1
Water Quality of Groundwater in the Mill Vicinity

Parameter
FES, Test Well
(G2R)
(1/27/77 - 3/23/781)
Well #2
6/01/991
Well #5
6/08/991
Field Specific Conductivity
(umhos/cm) 310 to 400
Field pH 6.9 to 7.6
Temperature (ºC) 11 to 22
Estimated Flow m/hr (gpm) 109(20)
pH 7.9 to 8.16
Determination, mg/liter
TDS (@180ºC) 216 to 1110
Redox Potential 211 to 220
Alkalinity (as CaCOS3) 180 to 224
Hardness, total (as CaCO3) 177 to 208
Bicarbonate 226 214
Carbonate (as CO3) 0.0 <1.0 <1.0
Aluminum 0.003 0.058
Aluminum, dissolved <0.1
Ammonia (as N) 0.0 to 0.16 <0.05 <0.05
Antimony <0.001 <0.001
Arsenic, total .007 to 0.014 0.018 <0.001
Barium, total 0.0 to 0.15 0.119 0.005
Beryllium <0.001 <0.001
Boron, total <0.1 to 0.11
Cadmium, total <0.005 to 0.0 <0.001 0.018
Calcium 50.6 39.8
Calcium, dissolved 51 to 112
Chloride 0.0 to 50 <1.0 2.3
Sodium 7.3 9.8
Sodium, dissolved 5.3 to 23
Silver <0.001 <0.001
Silver, dissolved <0.002 to 0.0
Sulfate 28.8 23.6
Sulfate, dissolved (as SO4) 17 to 83
Vanadium 0.003 0.003
Vanadium, dissolved <.002 to 0.16
Manganese 0.011 0.032
Manganese, dissolved 0.03 to 0.020
Chromium, total 0.02 to 0.0 0.005 0.005
Copper, total 0.005 to 0.0 0.002 0.086
Fluoride 0.18 0.18
Fluoride, dissolved 0.1 to 0.22
Iron, total 0.35 to 2.1 0.43 0.20
Iron, dissolved 0.30 to 2.3
Lead, total 0.02 - 0.0 <0.001 0.018
Magnesium 20.4 21.3
Magnesium, dissolved 15 to 21
Mercury, total <.00002 to 0.0 <0.001 <0.001
Molybdenum 0.001 <0.001

1 Zero values (0.0) are below detection limits. 

Parameter
FES, Test Well
(G2R)
(1/27/77 - 3/23/781)
Well #2
6/01/991
Well #5
6/08/991
Molybdenum, dissolved 0.004 to 0.010
Nickel <0.001 0.004
Nitrate + Nitrate as N <0.10 <0.10
Nitrate (as N) <.05 to 0.12
Phosphorus, total (as P) <0.01 to 0.03
Potassium 3.1 3.3
Potassium, dissolved 2.4 to 3.2
Selenium <0.001 <0.001
Selenium, dissolved <.005 to 0.0
Silica, dissolved (as SiO2) 5.8 to 12
Strontium, total 0.5 to 0.67
Thallium <0.001 <0.001
Uranium, total (as U) <.002 to 0.16 0.0007 0.0042
Uranium, dissolved (as U) <.002 to 0.031
Zinc 0.010 0.126
Zinc, dissolved 0.007 to 0.39
Total Organic Carbon 1.1 to 16
Chemical Oxygen Demand <1 to 66
Oil and Grease 1
Total Suspended Solids 6 to 1940 <1.0 10.4
Turbidity 5.56 19.1
Determination (pCi/liter)
Gross Alpha <1.0
Gross Alpha + precision 1.6+1.3 to 10.2+2.6
Gross Beta <2.0
Gross Beta + precision 8+8 to 73+19
Radium 226 + precision 0.3+0.2
Radium 228 <1.0
Ra–226 + precision 0.1+.3 to 0.6+0.4
Th–230 + precision 0.1+0.4 to 0.7+2.7
Pb–210 + precision 0.0+4.0 to 1.0+2.0
Po–210 + precision 0.0+0.3 to 0.0+0.8
Source: Adapted from FES Table 2.25 with additional Mill sampling data

Table 2.5.3-1
Results of Quarterly Sampling
Ruin Spring (2003-2004)

Parameter Ruin Spring
Q1-03 Q2-03 Q3-03 Q4-3 Q1-04 Q2-04 Q3-04 Q4-04
Major Ions (mg/L)
Alkalinity - - 196 198 193 191 195 183
Carbon Dioxide - - ND ND ND ND 12 ND
Carbonate - - ND ND ND ND ND ND
Bicarbonate - - 239 241 235 232 238 223
Hydroxide - ND ND ND ND ND ND
Calcium 153 156 149 158 158 162 176 186
Chloride 28.1 21.5 27.4 28.0 29.3 28.5 26 25
Fluoride - - ND 0.5 0.5 0.6 0.6 0.6
Magnesium 34.8 34.2 31.7 34.2 35.8 35.1 37.1 38.6
Nitrogen, Ammonia As N ND ND ND ND ND 0.06 ND 0.06
Nitrogen, Nitrate+Nitrite as N 1.6 1.5 1.4 1.4 1.73 1.85 1.34 1.7
Phosphorous 0.10 ND - ND ND ND ND ND
Potassium 2.6 3.3 3.3 3.9 3.4 3.6 4.0 3.7
Sodium 110 105 103 113 104 110 113 116
Sulfate 503 501 495 506 539 468 544 613
Physical Properties
Conductivity (umhos/cm) - - 1440 1410 1390 1440 1320 1570
pH - - 7.91 7.98 - - -
TDS (mg/L) - - 1040 1000 1050 1110 1050 1070
TSS (mg/L) - - 13.5 ND ND ND ND ND
Turbidity (NTU) - - 0.16 0.13 ND 0.12 - -
Metals-Dissolved (mg/L)
Aluminum ND ND 0.40 ND ND ND ND ND
Antimony ND ND ND ND ND ND ND ND
Arsenic 0.001 ND ND 0.001 ND ND ND ND
Barium ND ND ND ND ND ND ND ND
Beryllium ND ND ND ND ND ND ND ND
Cadmium ND ND ND ND ND ND ND ND
Chromium ND ND ND ND ND ND ND ND
Copper ND ND 0.082 ND ND ND ND ND
Iron ND ND ND ND ND ND ND ND
Lead ND ND ND ND ND ND ND ND
Manganese ND ND ND ND ND ND ND ND
Mercury ND ND ND ND ND ND ND ND
Molybdenum ND ND ND ND ND ND ND ND
Nickel ND ND ND ND ND ND ND ND
Selenium 0.013 0.012 0.012 0.012 0.012 0.012 0.012 0.012
Silver ND ND ND ND ND ND ND ND
Thallium ND ND ND ND ND ND ND ND
Uranium 0.009 0.011 0.010 0.010 0.011 0.011 0.009 0.010
Vanadium ND ND ND ND ND ND ND ND
Zinc 0.014 ND ND ND ND ND ND ND
Radionuclides (pCi/L)
Gross Alpha Minus Rn & U - - - - ND ND 1.4 ND
Lead 210 42 ND ND ND ND ND ND ND
Radium 226 0.3 ND 0.3 ND ND ND 1.3 ND
Thorium 230 0.3 0.2 0.5 ND ND ND 0.4 ND
Thorium 232 - - ND ND ND ND ND -
Thorium 228 - - ND ND ND ND - -

Table 2.5.3-2
Results of Annual Sampling
Ruin Spring (2009-2011)
Ruin Spring
Constituent 2009 2010
Range of Average
Historic Values for
Monitoring Wells 1
*
Ave 2003-
20042 2011 - May 2011 - July
Major Ions (mg/l)
Carbonate <1 <1 <1 1 -- --
Bicarbonate 233 254 241 239 -- --
Calcium 151 136 145 148 -- --
Chloride 28 23 25 44 ND - 213 27
Fluoride 0.5 0.53 0.45 0.5 ND - 1.3 0.6
Magnesium 32.3 29.7 30.6 31.1 -- --
Nitrogen-
Ammonia 0.09 <0.05 ND <0.05 -- --
Nitrogen-Nitrate 1.4 1.7 1.7 1.6 -- --
Potassium 3.3 3.07 3.2 3.3 -- --
Sodium 104 93.4 110 111 -- --
Sulfate 528 447 486 484 ND - 3455 521
pH (s.u.) 7.85 7.51 7.66 8.14 6.7 - 8.9 7.9
TDS 1010 903 942 905 1019 - 5548 1053
Metals (ug/l)
Arsenic <5 <5 <5 <5 -- --
Beryllium < 0.5 < 0.5 < 0.5 < 0.5 -- --
Cadmium <0.5 <0.5 <0.5 <0.5 ND - 4.78 0.01
Chromium <25 <25 <25 <25 -- --
Cobalt <10 <10 <10 <10 -- --
Copper <10 <10 <10 <10 -- --
Iron <30 <30 <30 <30 ND - 7942 25
Lead <1.0 <1.0 <1.0 <1.0 -- --
Manganese <10 <10 <10 <10 ND - 34,550 5
Mercury <0.5 <0.5 <0.5 <0.5 -- --
Molybdenum 17 17 16 17 -- --
Nickel <20 <20 <20 <20 ND - 61 0.05
Selenium 12.2 10 11.8 10.2 ND - 106.5 12.1
Silver <10 <10 <10 <10 -- --
Thallium <0.5 <0.5 <0.5 <0.5 -- --
Tin <100 <100 <100 <100 -- --
Uranium 9.11 8.47 9.35 8.63 ND - 59.8 10
Vanadium <15 <15 <15 <15 -- --
Zinc <10 <10 <10 <10 -- --
Radiologics (pCi/l)
Gross Alpha <0.2 <0.2 <-0.3 <-0.05 ND - 36 0.28
VOCS (ug/L)
Acetone <20 <20 ND ND -- --
Benzene <1.0 <1.0 ND ND -- --
Carbon
tetrachloride <1.0 <1.0 ND ND -- --
Chloroform <1.0 <1.0 ND ND -- --
Chloromethane <1.0 <1.0 ND ND -- --
MEK <20 <20 ND ND -- --
Methylene
Chloride <1.0 <1.0 ND ND -- --
Naphthalene <1.0 <1.0 ND ND -- --
Tetrahydrofuran <1.0 <1.0 ND ND -- --
Toluene <1.0 <1.0 ND ND -- --
Xylenes <1.0 <1.0 ND ND -- --
1 From Figure 3, Table 10 and Appendix B of the Revised Addendum, Background Groundwater Quality Report: New Wells
for Denison Mines (USA) Corp’s White Mesa Mill Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc.
and Table 16 and Appendix D of the Revised Background Groundwater Quality Report: Existing Wells for Denison Mines
(USA) Corp.’s White Mesa Uranium Mill Site, San Juan County, Utah, October 2007, prepared by INTERA, Inc.
2 From Figure 9 of the Revised Addendum, Evaluation of Available Pre-Operational and Regional Background Data,
Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.’s White Mesa Mill Site, San Juan
Couinty, Utah, November 16, 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-1, MW-2, MW-3, MW-
3A, MW-4, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-23, MW-24,
MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)2

Table 2.5.3-3
Results of Annual Sampling
Cottonwood Seep (2009-2011)

Cottonwood Seep
Constituent 2009 2010
Range of
Average Historic
Values for
Monitoring
Wells1*
Ave 1977 - 1982 1 2011 - May 2011 - July
Major Ions (mg/l)
Carbonate <1 <1 <1 6 -- --
Bicarbonate 316 340 330 316 -- --
Calcium 90.3 92.2 95.4 94.2 -- --
Chloride 124 112 113 134 ND - 213 31
Fluoride 0.4 0.38 0.34 0.38 ND - 1.3 0.8
Magnesium 25 24.8 25.2 25.2 -- --
Nitrogen-
Ammonia <0.05 <0.05 <0.05 <0.05 -- --
Nitrogen-Nitrate 0.1 <0.1 0.1 <0.1 -- --
Potassium 5.7 5.77 6 5.9 -- --
Sodium 205 214 229 227 -- --
Sulfate 383 389 394 389 ND - 3455 230
pH (s.u.) 7.73 7.47 7.55 8.04 6.7 - 8.9 7.6
TDS 1010 900 1030 978 1019 - 5548 811
Metals (ug/l)
Arsenic <5 <5 <5 <5 -- --
Beryllium <0.5 <0.5 <0.5 <0.5 -- --
Cadmium <0.5 <0.5 <0.5 <0.5 ND - 4.78 --
Chromium <25 <25 <25 <25 -- --
Cobalt <10 <10 <10 <10 -- --
Copper <10 <10 <10 <10 -- --
Iron <30 <30 53 <30 ND - 7942 150
Lead <1.0 <1.0 <1.0 <1.0 -- --
Manganese <10 <10 <10 <10 ND - 34,550 580
Mercury <0.5 <0.5 <0.5 <0.5 -- --
Molybdenum <10 <10 <10 <10 -- --
Nickel <20 <20 <20 <20 ND - 61 --
Selenium <5.0 <5.0 <5.0 <5.0 ND - 106.5 --
Silver <10 <10 <10 <10 -- --
Thallium <0.5 <0.5 <0.5 <0.5 -- --
Tin <100 <100 <100 <100 -- --
Uranium 8.42 8.24 7.87 8.68 ND - 59.8 --
Vanadium <15 <15 <15 <15 -- --
Zinc <10 <10 <10 <10 -- --
Radiologics (pCi/l)
Gross Alpha <0.2 <0.2 <0.1 <-0.1 ND - 36 7.2
VOCS (ug/L)
Acetone <20 <20 ND ND -- --
Benzene <1.0 <1.0 ND ND -- --
Carbon
tetrachloride <1.0 <1.0 ND ND -- --
Chloroform <1.0 <1.0 ND ND -- --
Chloromethane <1.0 <1.0 ND ND -- --
MEK <20 <20 ND ND -- --
Methylene
Chloride <1.0 <1.0 ND ND -- --
Naphthalene <1.0 <1.0 ND ND -- --
Tetrahydrofuran <1.0 <1.0 ND ND -- --
Toluene <1.0 <1.0 ND ND -- --
Xylenes <1.0 <1.0 ND ND -- --
1 From Figure 3, Table 10 and Appendix B of the Revised Addendum, Background Groundwater Quality Report: New Wells for
Denison Mines (USA) Corp’s White Mesa Mill Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. and Table 16
and Appendix D of the Revised Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.’s White
Mesa Uranium Mill Site, San Juan County, Utah, October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-1, MW-2, MW-3, MW-3A, MW-
4, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-23, MW-24, MW-25, MW-26, MW-
27, MW-28, MW-29, MW-30, MW-31 and MW-32)

Table 2.5.3-4
Results of Annual Sampling
Westwater Seep (2009-2011)

Westwater Seep
Constituent 2009 2010
Range of Average
Historic Values for
Monitoring Wells1 * 2011 - May 2011 - July
Major Ions (mg/l)
Carbonate <1 <1 <1
Not Sampled -
Dry
--
Bicarbonate 465 450 371 --
Calcium 191 179 247 --
Chloride 41 40 21 ND - 213
Fluoride 0.7 0.6 0.54 ND - 1.3
Magnesium 45.9 44.7 34.7 --
Nitrogen-Ammonia <0.05 0.5 0.06 --
Nitrogen-Nitrate 0.8 <0.1 <0.1 --
Potassium 1.19 6.57 3.9 --
Sodium 196 160 112 --
Sulfate 646 607 354 ND - 3455
pH (s.u.) 8.01 7.38 7.2 6.7 - 8.9
TDS 1370 1270 853 1019 - 5548
Metals (ug/l)
Arsenic <5 <5 12.3
Not Sampled -
Dry
--
Beryllium <0.5 <0.5 0.91 --
Cadmium <0.5 <0.5 0.9 ND - 4.78
Chromium <25 <25 <25 --
Cobalt <10 <10 <10 --
Copper <10 <10 16 --
Iron 89 56 4540 ND - 7942
Lead <1.0 <1.0 41.4 --
Manganese 37 87 268 ND - 34,550
Mercury <0.5 <0.5 <0.5 --
Molybdenum 29 29 <10 --
Nickel <20 <20 29 ND - 61
Selenium <5.0 <5.0 <5.0 ND - 106.5
Silver <10 <10 <10 --
Thallium <0.5 <0.5 <0.5 --
Tin <100 <100 <100 --
Uranium 15.1 46.6 6.64 ND - 59.8
Vanadium <15 <15 34 --
Zinc <10 <10 28 --
Radiologics (pCi/l)
Gross Alpha < -0.1 <0.3 0.5 Not Sampled -
Dry ND - 36
VOCS (ug/L)
Acetone <20 <20 ND
Not Sampled -
Dry
--
Benzene <1.0 <1.0 ND --
Carbon tetrachloride <1.0 <1.0 ND --
Chloroform <1.0 <1.0 ND --
Chloromethane <1.0 <1.0 ND --
MEK <20 <20 ND --
Methylene Chloride <1.0 <1.0 ND --
Naphthalene <1.0 <1.0 ND --
Tetrahydrofuran <1.0 <1.0 ND --
Toluene <1.0 <1.0 ND --
Xylenes <1.0 <1.0 ND --
1 From Figure 3, Table 10 and Appendix B of the Revised Addendum, Background Groundwater Quality Report: New Wells for Denison Mines (USA)
Corp’s White Mesa Mill Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc. and Table 16 and Appendix D of the Revised
Background Groundwater Quality Report: Existing Wells for Denison Mines (USA) Corp.’s White Mesa Uranium Mill Site, San Juan County, Utah,
October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-1, MW-2, MW-3, MW-3A, MW-4, MW-5, MW-11,
MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-23, MW-24, MW-25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-
31 and MW-32)

Table 2.5.3-5
Results of Annual Sampling
Entrance Spring (2009-2011)

Entrance Spring
Constituent 2009 2010
Range of Average
Historic Values
for Monitoring
Wells1 * 2011 - May 2011 - July
Major Ions (mg/l)
Carbonate <1 <1 <1 7 --
Bicarbonate 292 332 270 299 --
Calcium 90.8 96.5 88.8 96.6 --
Chloride 60 63 49 64 ND - 213
Fluoride 0.7 0.73 0.58 0.58 ND - 1.3
Magnesium 26.6 28.9 26.4 28.4 --
Nitrogen-Ammonia 0.28 <0.05 <0.05 0.32 --
Nitrogen-Nitrate 1.4 1 1.4 0.5 --
Potassium 2.4 2.74 2.6 2.9 --
Sodium 61.4 62.7 62.5 68.6 --
Sulfate 178 179 166 171 ND - 3455
pH (s.u.) 7.85 7.56 7.96 8.17 6.7 - 8.9
TDS 605 661 571 582 1019 - 5548
Metals (ug/l)
Arsenic <5 <5 <5 <5 --
Beryllium <0.5 <0.5 <0.5 <0.5 --
Cadmium <0.5 <0.5 <0.5 <0.5 ND - 4.78
Chromium <25 <25 <25 <25 --
Cobalt <10 <10 <10 <10 --
Copper <10 <10 <10 <10 --
Iron <30 <30 37 55 ND - 7942
Lead <1.0 <1.0 <1.0 <1.0 --
Manganese 54 11 47 84 ND - 34,550
Mercury <0.5 <0.5 <0.5 <0.5 --
Molybdenum <10 <10 <10 <10 --
Nickel <20 <20 <20 <20 ND - 61
Selenium 12.1 9.2 13.1 5.5 ND - 106.5
Silver <10 <10 <10 <10 --
Thallium <0.5 <0.5 <0.5 <0.5 --
Tin <100 <100 <100 <100 --
Uranium 15.2 17.8 18.8 15.3 ND - 59.8
Vanadium <15 <15 <15 <15 --
Zinc <10 <10 <10 <10 --
Radiologics (pCi/l)
Gross Alpha 0.9 <0.5 1.5 1.6 ND - 36
VOCS (ug/L)
Acetone <20 <20 ND ND --
Benzene <1.0 <1.0 ND ND --
Carbon tetrachloride <1.0 <1.0 ND ND --
Chloroform <1.0 <1.0 ND ND --
Chloromethane <1.0 <1.0 ND ND --
MEK <20 <20 ND ND --
Methylene Chloride <1.0 <1.0 ND ND --
Naphthalene <1.0 <1.0 ND ND --
Tetrahydrofuran <1.0 <1.0 ND ND --
Toluene <1.0 <1.0 ND ND --
Xylenes <1.0 <1.0 ND ND --
1 From Figure 3, Table 10 and Appendix B of the Revised Addendum, Background Groundwater Quality Report: New Wells
for Denison Mines (USA) Corp’s White Mesa Mill Site, San Juan County, Utah, April 30, 2008, prepared by INTERA, Inc.
and Table 16 and Appendix D of the Revised Background Groundwater Quality Report: Existing Wells for Denison Mines
(USA) Corp.’s White Mesa Uranium Mill Site, San Juan County, Utah, October 2007, prepared by INTERA, Inc.
*Range of average historic values for On-Site Monitoring Wells as reported on April 30, 2008 (MW-1, MW-2, MW-3, MW-
3A, MW-4, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-20, MW-22, MW-23, MW-24, MW-
25, MW-26, MW-27, MW-28, MW-29, MW-30, MW-31 and MW-32)

Table 2.9.1.3-1
Groundwater Monitoring Constituents Listed in Table 2 of the Permit

Nutrients:
Ammonia (as N)
Nitrate & Nitrite (as N)

Heavy Metals:
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Uranium
Vanadium
Zinc

Radiologics:
Gross Alpha

Volatile Organic Compounds:
Acetone
Benzene
2-Butanone (MEK)
Carbon Tetrachloride
Chloroform
Chloromethane
Dichloromethane
Naphthalene
Tetrahydrofuran
Toluene
Xylenes (total)

Others:
Field pH (S.U.)
Fluoride
Chloride
Sulfate
TDS
Table 2.13.1-1
Drainage Areas of Mill Vicinity and Region

Basin Description Drainage Area
sq. miles km2
Corral Creek at confluence with Recapture Creek 5.8 15.0
Westwater Creek at confluence with Cottonwood Wash 26.6 68.8
Cottonwood Wash at USGS Gauge west of project site ≈ 205 <531
Cottonwood Wash at confluence with San Juan River ≈ 332 <860
Recapture Creek at USGS gauge 3.8 9.8
Recapture Creek at confluence with San Juan River
≈ 200

<518
San Juan River at USGS gauge downstream at Bluff, Utah ≈ 23,000 <60,000
Source: Adapted from 1978 ER, Table 2.6-3