DRC-2011-008598 - 0901a06880a3d916

DENISOJ)I/
MINES
Drnbon Hino (US ) Cotp.
t050 1iln Shrrl.$ulbe$
Donor. CO 80265
USA
Tel : !03 62E.7798
Frr: tOt 3tt4t26
sr*.doltLonmh.|.com
October 17,2411
VIA EflAlL AilD OVERNIGHT DELIVERY
Mr, Rus$ Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 841144850
Re: Denison Mines (USA) Corporation (.DUSA') White Mesa MillFacility DRC lnspection Results: Storm
Water Best Management Practices Plan ("SWBMPP'), Ground Water Module 65, Oc'tober 9, 2010,
Utah Ground Water Discharge Permit No. UGW370004: DRC Request for lnformation and
Confirmatory Action Letter
Dear Mr
This letter transmits Denison Mines (USA) Corp's (.DUSA's") respons€s to the DRC Request for lnformation
and Confirmatory Action Letter, dated September 1, 2011,
We have re4uoted each RFI and Confirmatory Action item and provided below, specific responses to each
request as required by the DRC September 1, 2011 letter.
DRC Requeet for lnformltion:
l. DRC requosts information regarding updates to the plans/lnspeclions b provida inspections arcording to
frequencies requtrcd by the Storm Water Best Managament Pnclicr,s Plan (SWBIIPP). For example, the
SWBMPP requlrcs a weekly inspedion of the diversion clitches; however, they are mnducted monthly. Failure
to provide thesa lnqpeclions in cpnfarmarrce with the SWBMPP or mdity the SWBMPP is a violation of the Part
1.D.10 of the Groundwater Permil.
OUSA Reeponre:
Per the telephone conversation between DRC and DUSA on September 21,2O11, the diversion ditch
inspections will continue to be conducted monthly. This inspection hequency continues to be appropriate br
identifying th€ types of Elowdeveloping changes that may occur in the diversion dibhes. The Storm Wabr
Best Management Practices Plan (SWBMPP) has been revised to reflecl monthly inspections of the diversion
ditches. A revised SWBMPP has been enclosed in Attachment A.
2. DRC rcguesfs information regarding the inspwtion procedures for reagent stonage E,nks (including
intermediate proc?ss tanks, e.g. Pregnant Lhuors) which are installed ongrade (orynde refers to tank
instal/atbns where the tank bottom is in nntact wilh the gmund) to insure that thd strudunl integrity of tha tank
bottom is aceptabldappropriate. Cathode prc/radkn for on gnde fantrs rs pre*ribed in Part l.D.l0(a) of the
Groundwaler furmit.
N:Vnspedions and NOVs\Stonnwater lnspeciionsEW lnspedion 20!0 and 2011 RA410.15.11 Responses b 09.01 11
Stonmuater lnspectbn letteA'!0.1 7.1 1 Response b OEQ 0S.01 .1 I ilr.doc
Letter to Mr. Rusty Lundberg
Storm Water lnspection RFI/Confirmatory Action Response
Octohr 17,2011
Page 2
DUSA Regponse:
Cathodic protection per se is not prescribed in part 1.D.10(a) of the GWDP. Part .D.10(a) refers to non-specificgeneral requirements. However, DUSA has agreed to modify tanks for consistency with the general
requirements where appropriate as discussed below.
Per email correspondence from DRC on September 26,2011, DUSA understands that DRC requires cathodic
protection on tanks whose bases are in contiact with the ground surface. That is, DRC does not require tanks
which are on concrete pedesEls, whether diked or not, to have cathodic protection. Based on the
correspondence and the inspection report, DUSA has completed an inspection of all onarade tanks to
deternine the necessity of cathodic protection. The following results of the tank inspection were noted:
There are three kerosene tianks. The east tank is on a concrete pedestial. The two west tanks are
placed onArade, on the ground surface.
The ammonia tanks are on concrete pedestals.
The sulfuric acid tank is on a concrete pedestal.
The exterior VPL and water tank by the Old Decontamina$on Pad ('ODP') are on concrete pedestials.
Dirt had fllled in the area around the pedestials and, at the time of the 2010 lnspec{ion, gave tre
mistaken impression that the tanks were on-grade.
DUSA had discussed with DRC the inetallation of cathodic potection on reagent or fuel tanks that were not on
pedestals, saddles, or dikes, specifically the kerosene tanks. DUSA has since decided that it would be more
prudent to construct comparable concrete bases (pedestals) for the remaining kerosene tanks, as are ln place
on the other flat bottomed tanks. The west h^,o kerosene tanks will be modified by being raised for pouring of
tank pedestals, and replaced afier concrete for the pedestals ls set and suitable for tank setting. Construction
of these modifications will be comphte by the end of December 2011. Based on DRC's email of September
26,2011, tanks wih concrele foundations, with or without dikes, will not be required to have cathodic protection
and will be considered to be compliant with EPA requlrements for tanks where lnspection procedures arc not
practicable.
The pedestals of the exterior VPL and water tank by the ODP were cleared of soil buildup during October,
2011. Photographs documenting the removal of the loose soil are provided in Attachment B,
3 DRC reguests an outline of a plant proaess for intemal notification and documentatkn of the claan up of
small quantity sp/ls (less than reputable quanffihs). Fer the 2fiA inspection, if was oDseryed that a tuel sSill
had o*uned at the fuel tank arca and had not been deaned up and there dkl not appear to be a process to
identify, document, or dean up such spills. Failurc to provide/maintain such a p/oosss is in non-conformance
with the White Mesa Mill, June, 2008 SWBMPP, Paft 4.2.1
DUSA Rerpon*:
DUSA has implanted an intemal notification process for small quantity spills (less than reportrable quantities),
with the fiollowing steps:
1) Mill environmental personnel will fill out on the daily inspec{ion brm observations of spills of reagent
chemicals of any size. The form will be amended to add spaces for this item.2) ln addition, all Mill employees will be hained to advise Mill envircnmential personnel of any spills that
they observe during the day, ard these willalso be noted in the daily inspection form.
a
a
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7
Letter to Mr. Rusty Lundberg
Storm Water lnspection RF|/Confirmatory Action Response
October 17,2011
Page 3
3) lf the spill is of a reportable quantity, environmental personnel will follow the procedures in the Mitl's
SWBMPP plan.4) For spills smaller than reportable quantities, the envirbnmental inspector will record information
regarding the spill, and the nature and type of cleanup, on the form.5) This information on the inspection form will be added to a database maintained at the Mill, The
datiabase wrll be updated and maintiained on site indefinitely. Cards are maintained for no longer than
one year.
4. DRC reguasts thal DUSA review tha White Mesa Mill SPCC Plan (dated June, 2008) to insure that att tanks
included under the cunent facility Spill Pnvention Countermeasur€, and Control (SPCC/ plan maet current
requirements of cunent EPA rules {40 CFR 112). Speclfically, any addilional tank, including non-PCB
containing tanks, should be evaluated and includ$ under the oilstorage inventory and inspection pmtocols,
where requircd. This RFI is raguired in order to insure that procedures and policies at llre mill are ln accordance
with cu rre nt req u ire ments.
DUSA Responle:
The Mill has historically not been considered to fall within the rules set out in 40 CFR 112, lor the reasons
discussed below; therefore DUSA does not believe that the specifrc requirements of those regulations apply to
the site. However, as a matter of prudency and good operating practice, DUSA will review those regulations to
determine whelher or not any modifications to the SPCC would be appropriate for the Mill. Denison will submit
the results of its review under separate cover within 30 days from the date of this letter.
SPCC requirements apply to "[alny owner or operator of a non-transportation-related onshore ... facility, using,
or consuming oil and oil products, which due to its location, could reasonably be expected to discharge oil in
quantities that may be harmful...into or upon the navigable waters of the United Strates... or that may affect
natural resources belonging to, appertaining to. or under the exclusive management authority of the UnitedStates..' 40 CFR 112.1(b).
SPCC rules allow the owner to consider whether due to the geographical and location aspects of the facility(such as proximity to navigable waters or adjoining shorelines, land contour, drainage, etc.), lt could not
reasonably be expected to discharge oil in harmful quantities to a navigable water. The Mill was constructed
with an overall grade and diversion ditch system designed to channel any non-recovered portion of any material
spill to the tailings management system. The land contour and drainage characteristics of the site are
permanent geographical aspects of the site which do not involve man<nade features or devices which couldfail. These hatures, along with the Mill's relative distance from any navigable water, or means to reach
navigable water, prevent any potential discharge of oil at the Mill site from reaching navigable waters.
Upon review of our files DUSA has detennined that the Mill's SPCC plan was originally developed during theperiod when the Mill was operated by Umetco Minerals Corp., a subsidiary of Union Carbide Corporation. Aswith all Union Carbide operating fracilities, as a matter of Union Carbide corporate policy, Union Carbide
reguired Umetco to prepare and maintain an SPCC phn for the Mill. That is, we understand that the Mitl's
SPCC plan was implemented voluntrarily by the Mill operator as manner of prudent operating practices, and not
as a result of a regulatory requirement. DUSA also believes that it is prudent to maintain and comply with the
SPCC plan. As stated in the lntroduction to the Mill's SWBPP, "(allthough 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."
Therefore, based on the Mill site's permanent characteristrcs as described above, DUSA does not believe that
the specific requirements of the Clean Water Act are applicable to ttle Mill site. However. as mentioned above,
orN'soJlllfiilNrs
\
Letter to Mr. Rusty Lundberg
Storm Water lnspectkrn RFI/Conftrmatory Action Response
October 17,2011
Page 4
DUSA will mview the regulatbns at 40 CFR 112 to determine whether or not any modifications to the SPCC
plan woutd be appropnaE br the Mill
5. DRC rcquesb thaf DU&A seal tfe interior dnin(s) in the whlcle maintenanw araas to prevent interior spills
frun draining to outdoor, uncovered area{cahhmenfs. Ihis is speci/?ed in the tacility SWBMPP and is
considend a 'besl nanagenrent prccthe'to minimize the quantity of conlaminated mateial. The open druin(s)
nol in conformance with the SWBMPP part 4.3.1, seond bullet'clean up spills promptly, don't let minor
qpi/ls qpread.'
DUSA Rasponae:
Per Denison's communicatbns with DRC on September 21 and 22,2011, DRC will not require sealing of the
interior drain(s) in the vehicle maintenancs areas if DUSA provides a description of the spill management
practices in this area demonstrating that the practices do not increase the volume of contaminated water sent to
the oilAryater separator. The maintenance area sflll management prac'tices and operation of the oilArater
separator are describecl below.
Spills in lhe Maintenance Shop are initially managed by on-the-spot cleanup of the majority of the spilled
volume with clay or sorbents. The sorbent media used for spill pickup is transferred to a disposal area in
tailings Cell 3. Following initial spill pickup, the floor is washed to the inside oilAltrater sump.
The sumps operate as follows. The outside wash bay sump oilwater separator on the north side of he Shop
collects wash water from washdown of mobile equipment, along with building roof runoff. The separator has two
sections separated by an overf,ow wgir. The smaller section (sump1, beyond the weir, allows mud to settle.
Mud collected in this sump is removed approximately annually or as operations and maintenance allows, and
transferred to Cell3.
The overllow from the overflow sump is piped through an underground line to a second stage oiUwater
separator inside the building. This separator also has an overflow weir and sump br collection of entrained
solids. The overflow sump has not required removal of solids to date, but is monitored, as is the oubide
overflow sump, and can be emptied as required, Overflow solutions from the separator are tansfened to the
CCD tailings sump from which they are pumped to one of the tailings cell as directed by operaUons
management.
The above pftrctice does not increase the volume of contaminated water to the oi[\rater separator or the
tailings, and does not combine contaminated water with clean water. Regardless of the conltguration, all
overflow water and all removed solids from both the inside and outside separators are transferred to the tailings
system. Sealing the floor drain valves and management of water from inside the Shop would not reduce the
volume of water trc the tailings system, since all the water, inside or outside, would still be transbned to tailings
system.
6. DRC requesfs that DUSA insure that the clean water tank vaMe is xalad properly. fur the 2010 storm water
inspection, if was noted that this valw was leaking and was cnating ponded water areas in unlined ditclthoil
amas. Ihis is not in conformane mth Sec&bn 1.1.4 of the SWBMPP which sfates, 14mas raquiring
maintenance or opair, such as axcessr'ra ryetatiw gmwth, channel erosion or pooling of surft,cc water runofr,
will be raportted] to srte management and maintenan@ departments for necessary action to repair damage or
peiorm reconstructbn in order for the control feature to per{orm as intended.'
OEHEOJ)IIJ{tNls
Letter to Mr. Rusty Lundberg
Storm Water lnspection RF|/Confirmatory Action Response
October 17,2011
Page 5
DUSA Response:
The clean water tank valve hat was noted as leaking during the inspection is an overflow valve. The overflow
noted was not due to ina<lequate maintenance of any valve. The flow which DRC observed was, in fact,
operating properly to drain an overflow of clean water makeup hom the top of the tank to the drainage system.
ln a tiank overfill situation, the overflow sysEm, by design, allows llow of exoess water until the overflow rate
reduces to a near trickle prior to lhe cessation of flow when the tank level is stabilized. \A/hat the DRC inspector
observed during the 2010 inspection was proper normal operation of the overflow loop near the end of the
overflow, not a matfunctioning valve. Morbover, the area below the clean water tank is graded such that when
the overflow valve releases clean waler, the water will drain to Cell 1 so that no significant ponding will result
from this design.
DRC Conlirmatory Actlon:
1. DUSA has violated Part 1.D,11 of the Groundwater Permit by fatling to manage drums containing alternate
feed material (located autside of the teedstack management area) in compliana with the required peilormance
standards.
a. Feedstock materialwas not stored in water tight containers,
b. Faedstock material was not stored on a hardened engineercd surface or asphalt or concrete,
c. Feedstock material was not sforad in a designed and apprcved slorage area (by the Co-Executiva
Secretary), or other approved area.
d. DRC obsorued open and degraded containers containing feedstock material on soil and located
outside of the feedstock management area.
DUSA Rccponse:
Based on communications with DRC on September 21 and September 22,2011, Denison has completed the
following modifications to the Altemate Feed area:
a) Denrson disagrees with DRC's statement that feedstock maErial was not stored in watertight
containers. All alternate feed materials have been and will continue to be stored in water{ight drums or
in overpack drums. Denison considers intact shipping drums, with no apparent leakage, as well as
overpack drums, both to be water tight containers. Denison disagrees that containers that may be
'degraded' are not watertight, when no leakage is present. However, one drum with perbrations was
staged in the altemate fued area prior to processing As a result, regardless of the type of drum, all
drums in the Altemate Feed area are now placed on the new concrete pad described in item b), below,
when not in the drum rack.b) A concrete pad has been installed in the altemate hed area The design of the concrete pad was
approved by DRC prior to the installation (see the leter dated September 30, 2011 in Attachment G).
Photographic documenl,ation and as-built drawings of the concrete storage pad, whose construction
was completed on October 14,201l, are included in Attachment Oc) See response to item b), above.d) See respoose to atem b), above.
2. DUSA has violated Part l.D.lO ot the Groundwater Permit by tailing to replae/repair concrete in the
secondary containment of the Caustic Soda Tank.
oEffioJ)llfilllrlES
Letter to Mr. Rus$ Lundberg
Storm Water lnspeclion RF|/Confirmatory Action Response
October 17,2011
Page 6
DUSA Reponae:
The secondary containment area for the Caustic Soda tanks has been repaired during Oclober 2011, as shown
in the photographs indudad in Attachment E. As discussed during communications between DRC and DUSA
on September 21 and 22, 2011, DUSA plans further upgrades to the caustic soda area during a future
maintenance outage in 2012, at which time the caustic tanks and secondary containment will be reconfigured.
However, per communications between DRC and DUSA on September2l and 22,2011, DRC agreed to
consider the caustic soda area in compliance with Part 1.D.11 based on the repairs completed on October 14,
2011.
3. DUSA has violated Part 1.D.10 ol the Groundtratar Permit by failing to repair craclrs in tfie *condary
antainment area for the soda asft tanks.
DUSA Reponrc:
The secondary containment area for the soda ash tanks has been repaired during the first week of Oc{ober
2011, as shown in the photographs included in Attachment F. Per communications between DRC and DUSA
on September 21 and 22, 2011 DRC agreed to c.onsider the caustic soda area in compliance with Part 1,D.11
once the repairs are completed.
Please contact me if you have any questions or require any further information.
Yours very truly,
lrExrsox trres (USA] Gonp.
OrA^r,- d'jrA*
/
Jo Ann Tischler
Director, Compliance and Permitting
cr: David C. Frydenlund
Harold R. Roberts
Davkl E. Turk
K. Weinel
Centralftles
oENrsot)ll
Tf,INES
Attachment A
Stormwater Best Management Practices Plan
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TABLEOFCOMENTS
1.0 INTRoDTTTDN/PURPOSE. ..........,.,,...1
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3.0 RESPONSIBLTTY
.f .0 BEST MANACEMENT PRACnC-ES ....................
4.1 Oolrral Mrnagcnrnt Pnctices Applicablc ao All 4rc8s.,......,......-- .-..,,...,--.,.,.......44.1.1 Kocp Po@otid Polluuou &om Cmtr.t widt Soil. rnd Surfacc Wller:....,....,...--......,.-...-..,.,*..-.a4.12 Kccp hcnrial PollutsaE hoil Co{llel with PrGcipitraion ,-.* -..,.......-.-..*-*,ta4,1,1 lccp Paved Arc's from Becoming lblhaant Sourcce .-..,*.-.4
4.1.,1 lnspcrrion rnd Malntenaocc of Divcrrion Ditchcc fid Drdnrge C:hrnncb wirhh thc hoccss and
Rcagrnr Sorrgc Arcr...........-,,.........,-. -..-..-.....,,.....-44.1.5 Rccpb Fhids Whancvr Posciblc: ......-...,.,......-,... .....,..,.........4
1,2 Muagemeuhrticcsforhommdlabo(
4.2.1 Clcan Up Spilb Propcrly....-,......-.....-.,...
Laboruoy 4ftas...,,.....,.......**....... g
R
4,2,2 ProegMarrialeSurdoutdmts
1.2,4 Malcriall Muugerarnt...---.--------,-
Managamnt Pracriccs lor Meintilanco Activities ... ..........-..,......,..6
43,1 Kccp r Cheo Dry S[roe......,,........,.. ..-.,".,.,....6
..'*...'.'......'..,.......'.. 64.33 Urc Controls Dudng Print Rcmovrl-...--.-....-,.. .,.-.-.-.-*...,.643,4 Uso Coorolr Duri[t Print Appllcrlim rad Clcaup. ,..-............6
1.1 Managcrmnt Practicsr for Orc hd, Tailiop Arcr ad lkavy Equipnatl...*,..-,...-.....,......-'-............7
4.4.1 Wash Dowo Vchiclcr rnd F,quipmcot in Propcr Arqs ..............7
4.1.2 Mrnagc Stockpilcs lo PrcveotWindborncCmtsohaim. .....................................7
4.1.3 Kccp Errthmoving Activitlcr ftom Bccoming Polluaat Sourccs ,....,...............,...7
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Wbitc Mcas Mill $ic tryout
Wbitc Mss Mill Slo Drain!5G 8arin8..,....--*-.-.,., ...,........,,.......&9
Deniron Mincs (USA) Corp.- White Mera Mill Menagcocot Orguizrrion ()rut.,...,.,,........,,--.*-..4r8
Dcnison Miner (USA) Crp. Corporelc Manrgamcnt &gmizadonrl Chn.-,...'...'...............-*.--*.3$J
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Appcrdiccr
Appcrtdir I
Appcadir 2
tilhitc Mcsr Mill Manrgenrnt Fanouel
REAGENT YAn"D LIST ..............-----
R*poo*iblc for lmphmcnting Thie BMPP--.,..,........-.......-.. 9
TABORATORYCHEMICALIIWENTIRY LUiT I ................ ..........,...........-...9$
REAOENTYARDAMALLQUAT{TITYCHET{ICAI,SLlsTI-......-...... --...$3EAOENT YARD/BI LK CTIEMTA|.S LlsT I -.-......-............I4t3
FETROL^EI.,M FnODTTCIS AND SOLVENTS UST 1................. -.-.-*-.15L
Whitc Mera Mill Spill hevcntioo, Cootml. md Crlrntcrmcuuc Phn
l{hitcMcsl MIll Emrgcncy Reqor Plnr
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Deolso Min* (USA) C6p. fIXJIIA') qodcathGwhitoMGoi UrrnlumMill ('ths MilUir
Blatrdiry; Uolr. Ik MiU is a mt yillr coonmlr, rnd ir r zorodixharys fipility wi0r rtlpcct tr
watsr cftluatr. ltrt rq m wdcr larvla &eMitl rita banuc hc MlIl hrr:r noqr&lleopbEcrtamwaarfiysEms,o nosltf.conmoffbpublicdmurryer$etoo&o rc drdlrrtg o publirty owned bcatmmtvorb (rFuffir'), mdr no dirdrrlpr to arrfrcc wscr bodi6.
ThcSl8tsof Utah irsuodGmudwatcrDischsrrpIemitNo.UGMlilTttr04to DUSAooMrmt &
2fi)5, Ar a part of conplirncc with the ltrsdU DUSA ir rqufuod to robmit I Stsmwacl Bcn
Mmagurmt PrrdiccsPhn ('BMPP) b thcErccufw Sccntrry of lbcDlvldmof Rdetlon
Cmu,ol, Uutr Dcprrmf of Eavlrumtal Qd[y. 1]ir BM?Fpreratr qcrrtmd rd
rllalg!trrcil pmlctt o mblmizo c Fwcrt lpilb of dcdcalr cbmdo$ mdrdat* $lct
awld rt ull iu eodrtdnrtad rurfhcc *rtcr cftln@tr paantidly impee{ag nrfrpe n*crs rr
$snd wlt ts lhtuugb ruoo,ff or drdn4s cmucctiom lo stamsstcr or mrfrca urc dnlorge
routcll AlthilUh tto Mill, by dosign, camot dllctly impa lruwrtrc sur&oc rElcr, or
grauadwdst, &o Mill inplcrmte drcsc procdcr! ln a good fei& offrrt m nfufurir rll rqrce of
poluioc et&critr,
Papl
Bcst Munterrcot Practicq Plur
Rcvirim I "lil: J*m-t&4008&&hiilI0ll
2.0 SCOPG
This BMPP idcatifies practirxs lo prcvenl rpillo of ch€mhals and hazardos materials us€d in
plocBss operations, taboratory opcrations, s'!d maintenaoce activities, and minimize sprcad of
perticulatcs frun stoctpilee and tdliugs mallagsmsnt areas al thc Mill, Storage of ores and
Elternrte bcds on the trc prd, and containnrent of uilings in thc Mill tailingp impormdnrnt
systcrn 6tr not considcrpd 'spills" for lhe purpoes of this BMPP.
ThG Mill eitc was constructal wilh an overall grade and divcrsion ditch systcm derigrrd tn
shannel aU eurface ruooff, including pmcipitation equivalent to a Probable Maximum
Prccipitatiooflhobable Marimum Flood ('PMP/PMF ) stonn evont, to thc tailings rnanagem€nt
rystcrn. tn additioo, Mill uilings, all otlrcr procccs eflluents, all rolid waste and debris (exccpt
uscd oil and rccyclable matcrials), and apilled mataiah that cannot bc rccovcrcd for nuse are
tnnsferred to onc or more of the tailings cdls in accordance with thc Mill's NRC licenrc
conditions. All of trc proccss and labor*ory buitding sinke, rumpq rad 0oor dnins are ticd to
thc mnrfer lines to thc tailings impoun&ncnts. A sitc map of the Mill is pnovided in Figure L A
skrtch of the sitc drainage basins is provided in Figurc 2.
As a rcoult, unlike othcr indusrial facilitlcs, whosc spill managcrncnt pro8rams foc{s on
minimiziry thc introduction of chcmicrl and solid waste and wastcwater into thc pncccss sewerr
and storm drains, $c Mill is pomincd by NRC liccnsc to mamgc Bome spills via drainiog or
wast-down m the prosc$s sewer$. and ultirnately thc tsilings systsrn Howev€r, as good
cnvirunmsntal nranagerncnl practice, lh€ Mill attcmpB to minimir,e:
l. the numbcr arxl sire of matcrial spills, und2. the amount of unrtcovered spilled material and wash-$ate. thal crters the procrss sewcrs
after a spill clcanup.
Section 4.0 itcmizcs the practices in plucc at the Mill to rrrcl ttese objectives.
Requirements rnd rnethods for managpmcnt rccordtecping, and doqrmcntation olhazardous
rnarrial spillr rrc sddrtEs€d ln the DUSA lVhite Mesa Mil! Spill hcvention, Contml and
Countcrmcasurer ('SPCC') Plati**visd+ohfrrttls€f, theErncgancy Rosponse Plan
("ERP"), @ and the housckerping procodurc.s incorporatcd in thc
Whitc Mesa Mill Sudard Opcrating hocedures ("SOPs"). The lrlest revisions of thc SPOC plan
aod thc ERP arc providcd in thcir ciltirdy in Appcndices I and 2, tcrpecrively.
Page2
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All Ul[ fcnod er n{6&[se hOhoffim datb tuffi{ k& E[@. DIBA
WUi! lh fffi ryn.uh$iler tufril& llnffCfficr a r4!ffihi W,lohploartuprtuhll&m@.
Itc lfl rbqcm Oqlrob$o b pGGrlGd h FI8F3. thaDttsi Crp*rtmlmod
Orynizrttun bprdhEgu!{.
turyeEi{l[ glrdm md m$ Mr El hrpn{&{ hTOb t.
Ptt
Be*t Managpmunt Pmcticcr Plm
I n vision 1.3{:}rnr##l0L{&!0bd0ll
4.0 BBSTMANAGEMENTPRACTICES
A summary lisr and inrc.ntory of all liquid aod solid materials manegcd rt thc Mill is pnrvided in
Tablcs 2 through 5.
4.1 Gerrcral Merngement Prrctiotc Apdicrbh to All ArcE
4.1.1 Kcep Potcotld Pollutailt holu Contxt wltlt Soil' and Sur{rce Water:
r Store hazardous rnateridr and other potcntisl pollutEnts in appopriatc conasin€rs.o label the conlainert.. Kecp thc cootaincrs errvcrcd when nd in use.
4.12 Kccp Potcntid Pollutrrfie frqn Coutect with Prcclpltation
r Storc butk mrtcrirls in mrrcrrd tankc or drums.r Store jars, bcttte s simllrr smalt contdngrs in buildinge or undcr covcrcd arcas.. Rcplsct or rcpair brokert dumpstcrs and bins.r Kcep dutnpstcr lids and large contaimr coverc closed when not io usc (to kecp
prccipitrtion ol).
4.13 Kecp Feved Arces flom Becoming Pollutant Snurcc
. S$eep paved rrcas regularly, ard dispoec of dcbris in the solid waslc domp$ers or
tailingr aree as appmpiate.
+1.4 Impcctioo end Maintcnrncc otltirrtrfon Ditcher rad Drriaege Chrnncb virtrin lhc
Procreas rnd Rcagrut Stongc Arca
r Divcrsion ditclres, drainagc cbarmcls and surfscc war€r control structurcs in and around
I rhc Mill arca will bc inspected tt least crri&f0@lblttin mrdance with lhe rcgularly
rc.hcdulcd inspcclions rcquircd by Gmundwatcr Discharge Permit No. UGW37ffiO4, sDd
I gUy product Materials Liccnse fUT1900479, Arcas requiring maintenoncc or rcpair, such
ss cxcsssivc vcgctltivc growth, chanoel erodon or pooling of surface water runoff, will
I tc rcportgl o rltc nfilagenront aod maintenancc departlnent$ for nrxc*sary action to
repair damrge or pcrform rcconsuucrior in ordcr for thc control fcaturc to pcrform ar
ioteodcd. Sarus of mtinteo&nce or rePairs will be documented during follow up
iorpcctionr md ddidonal aaion takcn if necewury.
{.15 Recyde SluidsllYherevcrPmiblc;
. Whcn 6ssible, sclect sutoru,rtive lluidr, solvents. and clerncrs thet can bc rtcycled or
reclsitrl€dr \fflrn poeriblc, sclrct conrumable matcrials frum supplicrs who will reclaim empty
coiltaiocrs.r Kq rpcnt fluids ia pnrpcrly labeled, coverud containers until they are picked up for
rceyclc or transfcncd to the tailings rrea for disposal.
Page 4
Bd Muugemant Pracficcr Plm
Revisioo I 3{: }il+r}{fl}lQqXqb113!trU
12 Managcmat Prredet lor Oroccs md l^eborUory Are
4.Ll ClernUpSpilkPropcrly
. Clean up spills wift dry cleanup methods (absorbents, sweeping collcclion dnrms) inrtoad crf
water whcncvcr possiblc.. CJcan spills of stred rcagcnts or othcr drcmicrls immedirtcly aftr discovcry.r (Gmundwator Discharge Permit No, UCW3?0004, Scaion l&l"BJI0r.). Rccover and rc-uro rpilled metcrial whercvcr pqssible.. Kccp eupplie* of ragr, sothant matsialr (such as cd litlcr), rpill colloctiur drums, and p€ruonocl
proteaive cquiprnent ('PPE') norr fic arees wlrsc thcy may bc oeadcd for spill ncspon$e,r lf spills must be wacM down, urc ths minirnum :rmornt d wiler necdexl for effectivc cleanup.
4,2,2 Pnotecr Mshrirb Slorcd Outdoorr
r lf drumocd feeds or Frd{su musl bc rtorEd ertdqx6. sttre thcrn in covered tr diked areas whon
possiblc.r If drummod chemicals must be slo.Ed outdoors. stss thcm in covcred or diked are&e when
prxsiblc.r Ma*e cure drums and containers storcd mrtdoq3 are in good qrnditioo ard sccured against wind
or lealagc. Placc any damaged contrincrs into an ovcrpack &um q secmd container.
4.23 Mrnrgoent
r When possible. recycle urd rcose wxEr hom flushiog and prcssure tcstint cquipmcsLWhon
possiblg wipe down thc ouhides of csltainers insread of rinsing drm ol'f in dre-rink.r Wlrcn purriblc. wipc dnwn ctnrntc$ aod wok gurfaces instcad of hosing or rinriug thcn1o,ff to
siuks and drain
42.4 Mrteris&Meugcm.nl
r Purchue and invcntoy the sirnallast rrrcunr of labor[ttry reagent ncccs$ry.. Do not strct more of a rcagcnt thrn will be uscd up beforc its erpiration date.. -All new construdion of reagent $orlge frcilitics wiU include secfidry coltainmont_which *trall
control srd prcvoat s&y contaci dsill€d rsatsnts, or othcru/isc rclcued. reatent o product, wift the groond surftoe. (Grormdwarcr Disctrargc Permit No.. UcW3?0004, Seetim t.D.3.q.)
Page 5
Best Manageurcnt Prscticcs Plan
Rcvirion l.l4r fi*c{arr€S$itglsrl0ll
aJ Mrnsgurmt Practtces for Mrintlnancc Acfivitier
4J.f Xocp a Ocor Ihy Shog
r Swgcp orvacuum slnp floom rcgularly..
}A:ide rpcific re*r indoos fr parts cleaning, ud uee clcanem aod solvonlr rmty in those
r Clean up rpills prorrytly. Donl lct mitc spills spreod.r Kocp rupplicc of ragr, collcctitrn unbincrs, &nd sorbcnt msterid ncar elch work area where thoy
are needed.r Stsr bulk fluids, w{se fluids, and baucries in an arca wift secondary contaiilnent (double drum,
drip prn) to capnrrc leaftrgc and oortain spills.
43J MormscVchldcFloidc
r Dmin fluids frorn leaking or wecked/damagcd vehiclcs and oquipment as soor an po*sible. Use
drip pam or plastic tarpe to prcwnt spiltagc and spread of fluids.. ttornptly conlain and transfcr draincd fluids to appropriatc *toragc arca [or rcusc. nryclc, a
disposal.. R€cycle rnrtomotivc flui&, if poseible, when thclr urcful life is linishod.
4J.3 the Conrrob During PrIm f,cmovd
r Use drop cloths and shectiog to prevcnt windbrne contamination from paint chipr and
sardblasing dust.r Collec{" contein. and tnrusfer. as soon !s po*sibl* accumulalcd ducts und paint chipr to r dirposal
localisl io dre tailings arca au&cized to aoccpt wasle mataiuls fiom maintonanca or
collttruelion rctivirier.
431 Urr Cootrob Dorlng Prit Applicrtion nd Clcaaup
r Mir and usc the riglrt enornt of paint for tlte job. Use up onc ontaincr bcfore opcnint a secrud
onG.r Rocyclc q reuse leftover print whcnever pocible.r Never clean bruahes q rinse r drain paid mnnincrs on the groutd (pavcd o unpevcd).. Clean brushs and conluncrs only u sinks 8nd statlms th* drain totho proc€si rcnrcr lo the
tailingE system.r Paint out brmhm to the cxtcnt possiblc before watcr wastring (warcr-band paint) 6 solveot
rinsi ng (oil'barcd paint).. Piltcr rrd reosc thinnors ard rolvcnt *henewr posrible). Contgin solidg ud ununblc cxccss
liquids fr traorfer o tlte uilings uea
PaCe 6
Bc* Meugamt Brcthcr PlrrI novUcrtr+h..&re.U
*{ Mlngerd Prrcdslor Ora h4 &e? Ar., md ncryy Eqrftrr.n
Dctrilcd irmuqism for me mlordiry" &r ntppetriou rnd trlbt4r umgomont ta pmvHad
in tltc Mill S0fir.
rfuLl f,13[Do6f.tldrljEqd!:trfi*hft'olrAra;
Weoh dorn tnrctr. rrilcn, rnd otlu havy cquipocat only io rrre dcrigmod fr tbis prporaI trotr rr wrltdfirn p.d ruiand tllornrir wi*li *arhn), -
r At tha urrk wai& $illott. mate ruru thc **lr cdloc{or md rcqdhg rynonr lr uolting befsr
tumiruott wlsrryrill'.
4A.2 MrlulsgoOqut3 to hmot Whdtomccodmhdm
. u/rrcr rpry ttcacprd atl urpold ar*.t tpgnopl{o frr{uory ir rooodmoc wilh Mills&r X,btcr sptrl rtefttitcr * ruryircd by opocity gu*r& c wcdlcr coadhinc.o Dqololltr-wrtcr. Kcry wfw mde burmtnhuizcnrmffwrtcr.
+aJ XaeBnhnoUnf Adlfi.rthm fcooatof Fo&mlSeirwr
r Sdicduhqsveiion,frdiasado0nrwthmviagulvltlccuhcoortrGlE&IB3atrd Ndt
rxin& yin rd be I fgr (p Frcreot fic ncod fa crcsdrr &rn qerorslonlo Rarucoritiry rqerliol oaly tytrlll rbrolutdy nccwy.o SadaflrncogorrywEs*imfrrruioouurdmdopcr.
Prlc7
Page 8
A complete copy of Tabh 1 will be included in the Stormwater Best Management Pnctices Plan
maintained at the MillSite.
TABLE 2
BEAGETTYABD UST
REAGENT 9UAMr,nY(I..BS)EUIIEELgESTORAGETANKIS
CAPAOTTY
lGALLOlilSl
eD€ltrNixttEl
ADA/tN+AeE-re+n
AilrtERSl+E
AlllNS-€€4
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE(BAGS)
ANHYDROUS AMMONIA
GI.IEMFA&I€0
€LdRJflEe€+F{€{P
TBIDECYI.-ALCOHOL
DIESEL FUEL
FtE€€UIESIerfi€jl{+I
FL€CeU}slrT{n€me
GRINDING BALLS
lsegEeANet
KEFOSENE
$/q€l€i'll$f€
ITITJ#ERsElru3e+{58
$AL€488r5
PEREC,I A51
PERGE! 1OO
PEReet7l5
POLOX
PEIYHATI YEF
PROPANE
SALT (BAGS)
SALT (zuLK)
SODAASH (BAGS)
SODA ASH (BULK)
SODIUM CHLOHATE
SOD]UM HYDROXIDE
SULFURIC ACID
UNLFJDED GASOLINE
USED OIL
q+3ow
c
{8#4s
54,(X)0
4,e€a2g&@
107,920
+epee
eB00
45,430
3e€60
3#5e
48#992e.@g
45r€e
1,344
3d€0#{€e
s
r.r6eoe
+eB6e
e
10.360
e
39,2E0
0
39,280
84,100
101,128
0
4,80'1,440
1
2
-
31
=
:
I
-1
-1-
1
1
1
1
1
1
1
2t
2W
6,000
24.366
31,409
4€r€el9g1g
10.095
3ep0ee5€99
13.763
r8.864
16,921
8,530
{r#eo&.921
1€'5e0egsg1
29.e4q
rs,9og4
{"€00,s001393.$D
3€9r*€0
3,000
5 00()
Page 10
Amrnonium billuoride
Amrpnlum chloride
Arnrmnium oxahte
Ammonium thiocyanate
Antimony pcnasoium tatrate
n-Buty4 acotate
€e*e*{claehledele
Cyclohexane 43t
Ferrlc chlorlde
Ferrous ammonium sullate
Polassium c+rromatE
Sodium nitrite
Sodium phosphate tdbasic
45.4 kg
*7ok9
227Akg
2270 kg
45.4 kguTow
1^E4{€
kg24
454 kg
454 kg
4.5,{ kg
45.4 kg
?2'7okg
1.8 kg
2.21kg
?.27 kg
6.8 kg
7.8 kg
0.454
4L{+
L
6.81 kg
0.57
0.114 kg
2.5 kg
1.4
TABLE 3.0
IIBORATORY CHETICAL II{YENTORY LlsT I
This llsl klentifres chemlcale whicfi are reguhted as hazardorc subttanoes under the
Federal Wat* Pollution Confrd Act '00 CFB Part 117. The lab also storee srmll
quantlie d other matsrlals lhat are not hazardous eub$ancee per he abore
regulatim.
RaportaHe Otnntitbs are those k €ntitied in tl0 CFR Part 1 1 7 Table 1 17.3:
'Reportable Quarf,nies ol Hazardous Substancos Deslgruted Pursuaril to Sac'tion
3l1of teGbanWabrAol.'
Page 12
CHETIICAL ES gutgI
cor
Iu
E
t{D
Acdic Acid. Glacial 1.00O lbs 4oe
Ammonium Hrdroxide 1.flP lbs 5L
Ge$en$eufliCe {m}.lb6 e.lbe
Calcium l'lvoochlorile 1O lbs 2 ko (4.4 lbs)
Chlorine 10lbs 0lbs
Fenous Sullata Heotahvdrato l.m0 lbs 5 ko (1 llbs)
Hrdroc-tlbric 5.000 lbs 60 oal ol 4O7o golution
Nitric AcH 1-fi)O lbs 101
Potassium Perrnanoanate 0.1 N 32 oal 5 ko ('l llbsl
Sodium Hypochlodte 5.5%100lbs 2 kg (11 lbs) of 5.5olc
cn&rlian
Silver Nitrate 1rb 0lbs
Trichloroethvlene tm tb 2L
)tden*{f,ffttott-lesmers}{€e{be e{b6
1.
TABLE /f,O
BEAGEI{T YARD'SIIALL OUANTITY CHEUICALS LIST I
This list idEntilies chemicals whict ars regulated as hazardous
substances under the F€deral Water Pollulion Control Act 40 CFR
Pail 117, Materials h this list arc stored in a locked elorage
compund nearlhe bulk stoage tiank arca. The Mill also etores small
quantities of oth6r materials thd aro not hazardous subelances per
ihs above regulation.
RepoilaHe Quantities are lhoss k entilied in/m CFR Part 117 TaUe
117.3: "Reportable Quantilies ol Hazardans Substancee Designated
Pursuant lo Seciion 311 ol the Cban Water Ac-t.'
Pagc 13
REAGENT Eg OUANTITY Iil REAGENT
YAED
Fl€e43e+
Hypsrlloc 102
Ammonia - East Tank
Ammonia - West Tank
Kerooene
Soda ABh Dense (Bag)
PAeepneee+oiA
Polyox
t*il€p€rse
ltal€o.T)(760
l,lele+?2Oe
Trbutyl phosphate
Dietilla*ee
Diasel
Gasolina
Alsmlne 336 drums
Flec{€9
Flee€O8
Sles{O4
HBeflee-SS4
Sdt(Bulk Solids)
Salt(Bulk SolutlonE)
Caustlc Soda
Ammonlum Sufate
Sodium Chlorate
Alamine€3e9u[e
Alamine 310 Bulk
lsodecanol
Vanadium Psntoxide3
Yellorvcake3
Ammonia [ieta Vanadate
Floc 655
1,000 bs
Nefio
None
100lbg
100lbs
100 gal
None
lteno
Norp
6P00+6
None
llene
!{eee
Nef,6
None
Neae
100 gal
1@ gal
None
Ilenell€m
llem
I'lef,e
None
None
t.0q) lbs
None
None
ll€no
Norts
None
1Ofi) lbs
None
1Ofi) lbs
9,000,000lbs
*309-tbs
1,500 lbs
0lbs
105,0fi) hs
5@gal
epee+czo.aoqlus
+tbs!pl@!bs
e€0e{b6
490lbs
1;110 he
9{a#€lg
{#0Se6
9,450 bs
{€O€el
Appror 3300 gal
Appro:c 6000 gal
erb€gesogs!
e{be
g.lbe
Olbs
S.lbs
0s65aJ09lDs
+lbe90g9-sl
slb610l00o hg
S.lbe
0lbs
e+ea429sa!
30.00O lbe
<100,000lb6
0lbs
21.000 lbs
TABLE5.O
REAGET{T YARD'BULK CHEIIICALS Llsf
l. Thb llst ldenililEo all cfiemicab h tho ,€agent yad wh6hor or mt lhoy are rsgulaled as
mzaldous attsla.lcas ud€r fte Federal Wder Pdlulbn Contml Acf t|o CFB Patt t 17.
2. RepoltaUe Quant'ties a'l ttrose itendtied ln 40 CFR Pdl I 1 7 Tablo 1 17.3: 'Reportable
Qr.rantfries d Hazardors SJbltarrc€s Oesignal€d Pursuant lo Sodon 0t t o{ ihe Claan
WaterAnt'
3. vanaffrn Pentoxido and Ydlorcke. the Mt's ptodds. ar€ not stoted ln ths Rae0tBnt
Yard itsell, hl are pr6e.f h cbs€d cantalmrs h the M1U Buildog andbr Mall Yard
Page 14
t.
2.
TAELEC.O
PETROLEIfl FROffJgTE llt|D SOLVEIITB U8I4
Thb lht lndudm alllohr€rls and p*deum{rad pm*dg ln fie Mlllrmrclruse pdrclqrm and cfiemlcal sbrage ddee.
RWilabte Quan0lhs aro thoseb.ntlflod ln 40 CFR Parl ll7Td6
117,8: *Bsport&lc Orantldec of Hrzarbuc &bdancea Oeetgnabd
Purcuart b Socdon 911 ol the Clem Wder H.'
PROIIT,CT E9 E'AUIEI.U/AnEHOlrS€
Lnbrtdrg O[8ln 55 gslon drums
Tranen{oalon O[c
Wdar$oldileOila
Xylcne (r*od bornn)
Toluane
Vend Sohr€nt
12% trimdry benzono h pdroleum
dstlfratee)
rurga
tOognl
t00 Sal
100gal
1000$l
1000d
1,61O gdons
TllQ.gqlons
a$U$galorta0gdml
0 galons
Ogaions
Paa" f5
FIGURE.S
Page 16
Figure I
White Mesa Mlll
Mill Site Layout
PaBelT
Figtttnc 2WhtbMcsrlfil
Mill SttelMmgeBrdoi
Page 18
llgure 3
VYhite Mcsa Mill
Mill Manegerneot Organlzatlon Cbarl
Page 19
El\I
s
{
$
eJ ?
I
T
ilF
f igure 4
WhitcMessMill
Dcnison Mines (USA) Corpomtion
Organieatioual Structure
Page2L
.\.lt|
$
l$l
APPBNI}ICHi
Page 23
Aooend!*fr
Whltc Mclr Mill Soill l'rcvcnrlon. Conlrol rnd Countrrnrrssrx Ptrrl
Page 24
The$pilt Pretnntlon, Control ard Countermeasurrs Plan ("Srcfl h currantly undcr rwlew.
wtttou-.mtf#i*n'*^*ntt ' @
Page 25
The White Mesa Mill Emergency Response Plan is not being resubmitted because there are no changes
at this time.
Stormwater Best Management Pnctlces Plan
STORMWATER
BEST II,IANGEMENT PRACTICTS PLAhI
Whito Mcsa UrtdumMill
6425 Sortth Highway l9l
P.O. Box E@
Blarding Utah
Oetober 201I
heprcd by:
Denison Mircs (USA) Corp.
1050 t?th Strcet, Suite 950
Denrrer. C0 80265
for
t.0
2.0
3.0
4.O
TABLE OF CONTET.ITS
BEST MANAGEMENT PRACTICES ............,...........,..4
4.1 General Management Practiccs Applicable to All Areas.. ...............,...........44.1.1 Keep Potential Pollutants from Contact with Soil, und Surface \Vater:........... ....,......44.1.2 Keep Potential Pollutants from Contact with Prccipitation ........,...............'..-.44.1.3 Keep Paved Areas from Becoming Pollutant Sourccs........ ...."....,........4
4.1 .4 lnspection and Maintenancc of Diversion Ditchss and Drainage Channels within thc Process and
4.1.5 Recycle Fluids Vilhenever Possible:. .........4
4.2 Management Practices for Proccss and l,aboratory Areas....-... ...................54.2,1 Clean Up Spills Properly................... .............................5
4.2,2 Protect Matgriels Storcd Outdoors.................... ........,.....54.2.3 Managcment .........................5
4.2.4 Materials Managemcnt .............................5
4.3 Managern€nt Practices for Maintenance Activities. .....,..,......6
4.3.1 Keep a Clean Dry Shop ,.........., ................64.3.2 Manage Vehicle F1uids........... ......-............64.3.3 Use Controls During Paint Remova1.................... .........,.6
4.3.4 Usc Controls During Paint Application and Cleaoup....... .............-.......6
4.4 Management Prrctices for Ore Pad, Tailings Aroa. and Heavy Equipment......................,......................7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas............ .............74.4.2 Manage Stockpiles to Prevent Wiodborne Conumination............,...... ......................7
4.4.3 Kecp Earthmoving Activities from Becoming Pollutant S1ourccs......... .....................7
Figures
Figure2r White Mcsa Mill Site Drainqge 8asins."........ ...."...17
Figurc 3: Denison Mines (USA) Corp.- Whitc Mesa Mill Managcmcnt Ory.anization Charl....................................19
Figure 4: Dcnison Mincs (USA) Corp. - Corporate Managemcnt Organizational Chart............ .....-.,.20
'tabtes
TABLE I.O:
TABLE 2.0:
TABLE3.O:
TABLIi4.O:
TABLE 5.0:
TABLE 6.0:
Appendice,s
Appendix I
Appendir. 2
White Mcsa Mill Management Personnel Responsible for Implementing This 8MPP...........................9
REACENT YARD LIST............. ...................10
LABORATORY CHEMICAL INVENT0RY LIST t.......,......,-..,. ..........11
REACENT YARD/SMALL QUANTITY CHEMICATJ LIST t.................... ..............12
EACENT YARD/BULK CI{EMICALS LIST 1......,......-..-... ...-.-...-.......-_13
PETROLEUM PRODUCTS ANDSOLVENTS LIST I ...............-... ..-...-14
White Mssa Mill Spill Prevention, Conlrol, and Counternrcasures Plan
lVhite Mcsa Mill Enrcrgcncy Rcsponse Plan
Best Managemcnt Practices Plan
Revision 1.4: October 201 I
1.0 INTRODUCTION/PURPOSE
Denissn 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 zerodischarge 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 stormwater systems,. no discharges to publicly owned treatment works 1"POTWs"), and. no discharges to surface water bodies.
The State of Utah issued Croundwater Discharge Permit No. UGW370004 to DUSA on March 8,
2005. As a pan of compliance with the Permit, DUSA is required to submit a Stormwater Best
Managcment Practiccs PIan ("I|MPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
managenrcnt practices to minimize or prevent spills of chemicals or hazardous materials, which
could rcsult in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainagc
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements thcse practices in a good faith effort to minimiz.e all sources of
pollution at the site.
Page 1
Best Management Practiccs Plan
Revision 1.4: October 201 I
2.fi SCOPE
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 thc 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 aL Probable Maximum
Precipitation/hobable Maximum Flood ("PMP/PMF") storm evont, 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 canttot be rccovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC licen.se
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 l. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill managerment programs focus on
minimizing the introduction of chemical and solid waste and warstewater into the process sewers
and storm drains, the Mill is permitted by NRC license to managp some spills via draining or
wash down to the process sewers, and ultimately the tailings sysr[em. However, as good
environmental management practice, the Mill attempts to minimize:
L the number and size of material spills, and
2. the amount of unrecovered spilled material and wash wa:ter that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet the,se 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
procedurcs incorporated in the White Mesa Mill Standard Operating Procedures ("SOPs"). The
latest revisions of the SPCC plan and the ERP are provided in their entirety in Appendices I and
2, respectively.
Page 2
resrrvtanageryllffii;ii
3.0 NE$FONSIBILTTY
All Mill personnelarc rcsponsible for implenrentation of the pratices in this BMPP. DUSA
l{thile Mcra Mill managenpnt is responsible for providing the faeilitis* orquipnrcnt neoessary
to implern*nt thc pactices in this BMPP.
The Mill Managenrnt Organization is presnted in Figurc 3. Thc DUSA Corporate Managenrcnt
Organization is prescnted in Figure 4.
An updated spill prevention and coiltrol notification list is provided in Table t.
Fage 3
Best. Management Practices Plan
Revision 1.4: Octobcr 201I
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 AII Aneas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
r Store harardous materials and other potential pollutants in appropriate containers.o Label thecontainers.. Keep the containers covered when not in use.
4,1.2 Keep Potential Pollutants from Contact with Precipitation
o Store bulk materials in covered tanks or drums.o 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.fJ Keep Paved Areas from Becoming Pollutant Sources
o Sweep paved areas regularly, and dispose of debris in ttre 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
o Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accor,lance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT1900479. Areas requirring 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 tht: 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.f .5 Recycle Fluids Whenever Possible:
r When possible, select automotive fluids, solvents, and c.leaners that can be recycled or
reclaimedo When possible, select consumable materials from suppliers who will reclaim empty
containers.. Keep spcnt fluids in properly labeled, covered containem until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 4
Bcst Managemcnt Practiccs Plan
Rcvision 1.4: October 201I
42 Management Practices for Process and Laboratory Areas
4.2,1 Clern Up Spills Properly
a
a
a
a
4.22
4.2.3
a
a
a
4.2.4
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. UCW370004, Section I.D.lO.c.)
Recover and re-use spilled material whenever possible.
Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response.
If spills must be washed down, use the minimum amount of water needed for effective cletrnup.
Protect Materials Stored Outdoors
lf drummed feeds or products must be stored outdoors, storc them in covered or diked areas when
possiblc.
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.
Management
When possihle, rccycle and reuse water from flushing and pressure testing equipnrcnt. When
possible, wipe down the outsides of containers instead of rinsing them off in the sink.
When possible, wipe down counters and work surfaces instead of hosing or rinsing them off to
sinks and drain
Materials Management
Purchase and inventory the smallest amount of laboratory 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 prevcnt any contact of spilled reagents, or dherwise released
reagent or product, wilh the ground surface. (Groundwater Discharge Pcrmit No.
UGW370004, Section I.D.3.g.)
a
a
Page 5
Best Management Practices Plan
Revision 1.4: Octobcr 2011
4.1 Management Practices for Maintenrnce Activities
43.1 Keep a Clean Dry Shop
r Sweep or vacuum shop floors regularly.r Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.r Clean up spills promptly. Don't let minor spills spread.
r Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.o Store bulk fluids, waste fluids, and batteries in an area with secondary containmenl (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
o Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon es possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
o Promptly contain and transfer drained fluids to appropriate $torage area for reuse, recycle, or
disposal.o Recycle automotive fluids, if possible, when their useful life is finished.
4.33 Use Controls During Paint Removal
r Use drop cloths and shecting to prevent windborne contamination from paint chips and
sandblasting dust.o 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 maintcnance or
construction activities.
4.3.4 Use Controls During Paint Applicstion and Cleanup
o Mix and usc the right amount of paint for the job. Use up one container before opening a second
one-o Recycle or reuse leftover paint whenever possible.
o Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
o Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.e Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
o Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excqss
Iiquids for transfer to the tailings area
Page 6
e cst uan agor111 ffiff:;Ji?
4A Manrgemmt Practices for Ore Pad, Tallings Area, and Heavy Equipment
Detailed irstructions for ore unloading dust suppression, and tailings management are provided
ir the Mill SOk.
4.4.1 l{ish llorn Vehicles and Equipment in ProperArcas
r Wash down trucks, traiters, and other heavy equiprnent only in arcas designatcd for this purpose
(such as wash down pad area.s and tile truck wash .station).o At the truck wash station, make sure the water colleaion and recycling system is working before
turning on walcr sprays.
4.42 Manage Stockpile to Frovcnt l,Vtndborne Contaminetion
r Water spray the ore pad and unpaved areas al appropriate frequency in accordance with Mill
SOPS.r Water spray stockpiles as rcquired by opacity standards or weather conditions.o Don't over-water. Keep surfacqs moist but minimize nrnoff water.
4.4,3 lftep Earthmoving Acfivities frum Becoming Pollntant Sources
r Schedula excavation, grading, and other earrhrnoving aeiivities when extrrenrc dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).r Remove existing vegetetion only when absolutely neses$ary.r Seed or plant temporary vegetation for erosion control on slopes.
Page 7
TABI,ES
Page 8
A complete copy of Table l will be included in the Stormwater Best Management Practkes Plan
maintained at the MillSite.
TABLE 2
REAGENT YARD LIST
HEAGENT OUANTIW
(LBSl
NUMEER OF
STOHAGE
TANKS
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE(BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GHINDING BALLS
KEHOSENE
POLOX
PROPANE
SALT (BAGS)
sALr (BULK)
soDA ASH (BAGS)
soDA ASH (BULI0
SODIUM CHLOBATE
SODIUM HYDROXIDE
SULFUHIC ACID
UNLEADED GASOLINE
USED OIL
54,000
26,000
107,920
45,490
72,000
1,344
10,360
39,280
0
39,280
94,100
101,128
0
4,901,446
2
2
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
24,966
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
1,394,4119
3,000
5.000
Page 1O
ehemical-ln-Leb RQ'Quantitv in Stock
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassium tatrate
n-Eutylacetate
Cyclohexane 454
Ferric chlorida
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Znc acetate
2270k9
45.4 kg
2270k9
227Okg
2270k9
45.4 kg
227Akg
kg24
454 kg
454 kg
4.54 kg
45.4 kg
227okg
454 ko
1.8 kg
2.27 kg
2.27 kg
6.8 kg
7.8 kg
0.4s4
4L
L
6.81 kg
0.57
0.114 kg
2.5 kg
'l.4
0.91 ko
TABLE 3.0
LABORATORV CHEIIICAL INVENTOHY LtsT I
Chemical ln Acid Shed RO'Quantitv in Stock
Chloroform 4.54 ko 55 qal
Hvdrochloric acid 2,27Ako 58 oal
Nltrate acid 454 kq 5L
Phosohoric Acid 2.270ko 10L
Sulfuric acid 454 ko 25L
Hvdrofluoric acid 45.4 ko 'l L
Ammonium hvdroxide 454 ko 18L
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
regulatlon.
2. Beportable Quantitie are those identified in 40 CFR Part 117 Table 117.3:
'Beportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act.'
thprT{cal. ln Volatileg and
Flammables Lockers(AB.C)
Egt Ouantftv ln Stock
Chloroform 4.54 kq 8L
Formaldehvde 45.4 ko <1L of 37% solution
Nitrobenzene 454 ko 12L
Toluene 454 ko 12L
Page 11
CHEiIICAL Eg OUANTITY.IN
srqRAFE
coilFout{D
Acetic Acld. Glacial 1.000 lbs 4 oal
Ammonium Hvdroxide 1.000 lbs 5L
Calcium Hvoochlorite l0lbs 2lto (4.4lbs)
Chlorine l0lbs 0lbs
Ferrous Sulfate Heptahvdrate 1.0001bs 5 ko (11lbs)
Hvdrociloric 5.000|bs 60 oal d 4Oo/" solution
Nitric Acid 1.000 lbs 10L
Potassium Permanoanate 0.1 N 32 qal 5 ko (11lbs)
Sodium Hypochlorite 5.5ol"100lbs 2 kg (11 lbs) ol 5.5%
solution
Sllver Nitrate 1tb 0lbs
Trichloroethvlene 100|b 2L
TABLE 4.0
BEAGENT YARD/SMALL OUANNTY CHEMICALS LlsT t
1. This list identifies chemicals which are regulated as hazardous
substances under the FederalWater Pollution ControlAct 40 CFB
Part 117, Materials in this list are stored in a lockad storage
compound nearthe bulk storage tank area. The Millalso stores small
quantities of other materials that are not hazardous substiances per
the above regulation.
2. Beportable Quantities are those identified in40 CFH Part 117 Table
117.3: "Reportable Quantities ol Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act.'
Page 12
TABLE 5.0
BEAGENT YARDIBULK CHEMICALS UST,
1. This list idantilies all chernicals in the reagent yard whether or rrct they are reguhted as
hazardous subatance under the Federal Water Pollutlon Confol Act 40 CFR Part 117.
2. Reportable Quantitiec are those identllied in 40 CFR Part 1 17 Table 1 1 7.3: 'Reportable
Quantitbs ol Hazardous Substances Designated Pursuant to Sec{ion 311 of the Clean
WaterAct.'
3, Vanadium Pentoxide and Yellowcake, lhe Mill's products, are not stored in the Reagent
Yard ilsslf, but are present in ched containerc in the Mill Building and/or$illYxd
REAGENT RQ'OUANNW N REAGENT
YARD
Sulfuric Acid
Hyperlloc 102
Ammonia - Ea$ Tanlt
Ammonia *West Tank
Kerosene
Sall (Bags)
Soda Ash Dense (Bag)
Polyox
Tributyl phosphate
Diesel
Gasoline
Alamine &36 drums
Salt(Bulk Solids)
Salt(Bulk Solutions)
Gaustic Soda
Ammonium Sutfate
Sodium Chlorate
Alamine 310 Bullr
lsodecanol
Vanadium PentoxideS
Yellotrvcake3
Ammonia Meta Vanadate
Floc 655
F\oc,712
1,000|bs
None
100lbs
100lbs
100 gal
None
None
None
None
100 gal
100 gal
None
None
None1,ffi lbs
None
None
None
None
1000lbs
None
1ffiOlbs
9,000,000|bs
1,500 lbs
0lbs
105,0001bs
500 gal
20,000|bs
50,000|bs
490lbs
9,4501bs
Approx. 3300 gal
Approx. 6000 gal
8,250 gal
50,000|bs
9,000 gal
16,0001bs
1fl),000lbs
350,0001bs
0lbs
2,420 gal
30,000|bs
<100,000|bs
0lbs
21,000 lbs
1.250lbs
Page 13
TABLE 6.0
PETROLEU1I PRODUCTS AND SOLVE}ITS LISTI
1. This list includee allsolvents and patroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.2. Reportable Quantities are thoee identifled in 40 CFR Part 117 Table
117.3: 'Repodable Quantities d Hazardoue Substances Designated
Pursuant to Seclion 311 of the Clean Water Act.'
PRODUCT re OUA}.ITITY IN
WAHEHOUSE
Lubrlcating Oils ln 55 gallon drums
Transmiseion Oils
Water Soluble Oils
Xylene (mixed isomers)
Toluene
VarsolSolvent(2"/" trimethyl benzEne in petroleum
distillates)
100 gal
100 gal
100 gal
100 gal
1000 gal
100 gal
1,540 gallons
110 gallons
110 gallons
0 gallons
0 gallons
0 gallons
Page 14
FIGURES
Page 15
Figure I
White Mesa Mill
Mill Site Layout
Page 16
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White Meoa Mill
Mill Site Drainage Brdns
Page 17
figure 3
Whltet[csrMill
Mlll Mrnrgcmcut Otgrnicrtion Chert
Page 18
otrlo!0aua
Bgs
,Bgg
FISure4
WhiteMcorMill
Ihnlsor llilfur {USA) Corporrfon
Orgmlratioml Stmcturt
Page 20
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APPENDICES
Page22
Appendlx I
White Mesa Mill Spill Prevention, Control, and Coun0ermeasures Plan
Page 23
The Splll Prqnntlon, Oontrol End Countcrmeasunes Phn ('SfCff) b cunantly urder revlew.
Appendix 2
Whitc Mesa Mill Emergency Response PIan
Page 24
The White Mesa Mlll Emergency Besponsa Plan ls mt being resubmltted because there are no changes
atthktime.
Attachment B
Attachment C
Stat€ of Utah
,O.I M. HI.'NNMAH,JR"
Ctqmw
CAN,Y HEN,BERTUauwlhvemor
Departnent of
Environmental Quality
Anrrde Snidr
tdrag&.v;rd,/cDfuctor
DTVEION OF RADIATK}I{ CONTROL
DrooL Finorfioelr
Dbacbr
Scptcrnbcr 30,201I
CERTTFTED MAIL
(Rcum ReciptRequcstd)
Jo AmTischlcr
Dircstor, Compliaucc and Pernrining
Deoisorl Mincs (USA) Corp. @USA)
1050 Ssveoteedh Sboct, Suitc 950
Dcnvcr, CO 80265
DearMs. Tischler:
SUBJECT: Proposod Conqcte Pads for Dnnn Managcmcnt, Slhitc Mcsa Uranium Mill Grouod lllatcr
Disctrargc Permit No. UGW3700O{; Coudltionrl Approvrl
On Septonbcr 26,2011tha Divisiou of Radiation Conftol (DRC) receivod tbrough crnail a single-choct
plan for ncw conmdo pads for drum managcmcnt et thc Altcrnstc Fcd Arca at the DUSA White Mcsa
Urmium Mill" mr Blanding, UEtr. Tho rubjcct lino in thc oov€r mcssagc acconryanying thc plan
rcliroccd the Septcmber l, 201I Requct for hformatiou ffid ConnrmaoryAction l"etter, Storm watcr
Inopcction,
DRC understaills tbc projcct to inclrdc placccrcot of coactde 0atwork as a managemcnt surface for drums
of feedstock The pads will inclrdc low-pro8lc r,ollod cu$ at the periphery to p,rovide mdcrid cortsinmcot
for spills thu may occur. thc pads will clope to cxisting drain sumps, thus prwcoting spilted fbodstock
matcrid from washing onto eiurormding aoil*
DRC han rwiqrod thc submittod plan for coofomtansc with thc intcnt of Part I.D.l I of thc Whitc Mesa
Uranium Mill Ground Watcr Discbargp P6mit No. UGW370004 (P6rni0 ard fird the plao to comply with
thie Psmit roquircurent; tberefore thc plm ir ryprovd srfijoc to the bllowing conditions:
l. DUSA rhall submit As.Built dr$vings srithin 14 caleodar days upon completion of thc project
for Bxoctttivp Sowfary rwicm and rppoval. ThG As-Built drawings will iaclrdc a scction or
detail of thc crrrbing constructod on thc pcripbcry of &e pads 8s 8 rnatccial coutainmcnt fcature
Thc plan will includ€ sufficicot qot elwationr to detsil how thc padr will draia The record
drawing will rcflect aoy dcviations &rom thc 4provod pl^m.
2. The padr rhall not bc placod in rcrvipc until ap,pmval of tbe As-Built drawings by thc
Exerrtivs Secraary.
l5t No(6 l9J0 Wcr . $lt bb Ciry, UTl{ri[ryAd&cr: ?,O, Eil llltilO.Sdtl&Cry, m &{ll4-{tr}
Tclqtono (t0l) t3642t0 . Fer (t0l ) 513{01}7 . T.D.D. (t0 I ) $6.t41{
rrr.figrtl.5wlt*dc l00ttrg.rGldrt.t
Jo AmTirshlcr
Scptcmb€r 28, 201I
Pep2
DRC lirtibd its rwicw of tbo subjccr plm to ctaluditg aonfomeca with ths idsrt of tho Pcroit. No
struatuml crnltratioo orvrluc cuginooriagwas pcrfonncd as prrt of thc rwiew.
If pu hsvr any qtudms ou tho abovq plca:o cmt*t &rsr TWham. of my *rfr, ar (tOt) 53fi256.
UTAII WATBR QUALTTY BOARD
Pv<./t-"y Lr^dbe^
Rusryrundbcre 0 %
Co-Exootive Secogtary
RLRT:rt
P:hpluar\DlllA\UllA Alm Fod fruo tihgmtloc
Aftachment D
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Attachment E
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Attachment F
DI? C
o
4(0 x 1-0 07 323
State of Utah
GARY R. HERBERT
Goverrutr
GREG BELL
Lieutenant Governor
DePartment of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
September l,20lL
VIA HAND DELIVERY
David C. Frydenlund, Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) CorP'
1050 17th Street, Suite 950
Denver, CO 80265
Subject: Denison Mines (usA) corporation @ujiA) White Mesa Mill Facility
OnCmrp"ction'Results: dtorm Water Best Management Practices Plan
(SWBMPP), Ground Water Module 65, october !9,Z}lo,Utah Ground Water
Olsct *!" permit No. UCWS70004: DRC Request for Information and
ConfirmatorY Action Letter
Dear Mr. FrYdenlund:
I
on october 19, 2010 Tom Rushing, utah Division of Radiation control (DRc) met with Mr'
David Turk, Radiation safety officer, for Denison Mines (usA) corp' (DUSA) to conduct a
storm water inspection at the DUSA white Mesa uranium Mil near Branding, utah. A copy of
the inspection findings (2010 DRC Groundwater Module 65) including a cop,y of the DRc photos
is attached for your iiformation. Please refer to the attached Groundwater Module for more
specific information regarding the Request for Information andror conftrmatory Actions listed
below.
Re qu e st for I nformatio n :
As discussed during a conference call amongst Phil Goble (DRC)' Tom Rushing (DRC)' Jo Ann
Tischler (DUSA) aia oavia Turk (DUSA) Jn a37zollat 3:30 P'M' as well as a follow up
confirmation call between Jo Ann fisctrtei (DUSA) and Tom Rushing (DRC) on 8/3112011 at
5:00 p.M., DUSA will submit a letter of response listing each of the request for information items
below and an explanation of all follow up actions taken or planned to address the items' post- '
marked, or otherwise delivered to the pRC office on or before 30 calendar days after DUSA
receipt of this letter.
195 North 1950 West' Salt Lake City' UT
Mailing Address: P.O. Box 144850 'Salt hke City' UT 84114-4850
r;;il;;"" iili t
-ito. qzso.
TJJiL] ),1ii_".,:e7
. r. D D ( B0 r ) 5 36-44 r 4
E;nrPrl ^n lOOqZ, recvcled DaDer
White Mesa Uranium Mill
2010 DRC Storm Water InsPection
Page2
1. DRC requests information regarding updates t-o th.e plans/inspections to provide
inspections according to frequenciei requireA bI !!: Storm Water Best Management
practices plan (SWBI\4pp). no, L*u*pie, the swBMPP requires a weekly inspection of
the diversion ditches; however, they are conducted monthly' Failure to provide these
inspections in conformance with th; swBMPP or modify the swBMPP is a violation of
thsPart I.D.10 of the GroundwaterPermit'
2.DRCrequestsinformationregardingtheinspectionproceduresforreagentstoragetanks
(including intermediate process tanfs, e.g. Pregnant Liquors) which are installed on-grade
(on-grade refers to tank installations whJe the tank boitom is in contact with the ground)
to insure that the structural integrity of the tank bottom is acceptable/appropriate' Cathode
protection for on grade tanks is-prescribed in Part I.D.10(a) of the Groundwater Permit'
3. DRC requests an outline of a plant process for internal notification and documentation of
the clean up of small quantity spills (less than reportable quantities)' Per the 2010
inspection, it was observed ,t uf u fuel spill had occurred at the fuel tank area and had not
been cleanJ up and there did not appear to be a process to identify, document, or clean up
such spills. Failure to provide/maintain such a process is in non-conformance with the
White Mesa Mill, June, 2008 SWBMPP' Part4'2'L'
4. DRC requests that DUSA review the white Mesa Mill SPCC Plan (dated June' 2008) to
insure that all tanks included under the current facility Spill Pre'rention countsrmeasure
and Control (SpCC) plan meet current requirements of Current EPA rules (40 CFR 112)'
Specificallf,'any additional tanks, including non-PCB containing tanks' should be
evaluated and included under the oil storage inventory and inspectior protocols, where
required. This RFI is required in order to insure that procedures and policies at the mill are
in accordance with current requirements'
5. DRC requests that DUSA seal the interior drain(s) in the vehicle maintenance areas to
prevent interior spills from draining to outdoor, uncovered areas/catchments. This is
specified in the facility SWBMPP ind is considered a "best management practice" to
minimizethequantityofcontaminatedmaterial.Theopendrain(s)notinconformance
with the SwBivlpp purt +.z.t,second bullet "clean up spills promptly, don't let minor
sPills sPread-"
6. DRC requests that DUSA insure that the clean water tank valve is sealed properly' Per the
2010 storm water inspection, it was noted that this valve was leaking and was creating
ponded water areas in unlined ditch/soil areas. This is not in conformance with Section
4.1.4 ofthe SWBMpp which states, "Areas requiring maintenance or repair, such as
excessive vegetative growth, channel erosion i' pooling of surface water runoff' will be
report[ed] 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'"
White Mesa Uranium Mill
2010 DRC Storm Water InsPection
Page 3
Confirmatory Action:
The confirmatory action items listed below are per agreements made between DUSA and DRC
during a conference call amongst phil Goble (DRC), Tom Rushing (DRC), Jo Ann
Tischler (DUSA) and David Turk (DUSA) on 8l3lt2ol1 at 3:30 P.M, as well as a follow up
confirmation call between Jo Ann Tischler (DUSA) and Tom Rushing (DRC) on 8l3ll20ll at
5:00 P.M.. Per those calls, it was agreed that the three listed items will be addressed within 45
calendar days of your receipt of this letter. Additionally, DUSA will submit a letter of response
listing each of the items beiow and an explanation of all follow up actions/activities taken to
address the items. The response will be iost-marked, or otherwise delivered to the DRc office,
on or before expiration of the 45 calendar day period'
1. DUSA has violated part I.D.11 of the Groundwater Permit by failing to manage drums
containing alternate feed material (located outside of the feedstock management area) in
complian-e with the required performance standards.
c.
Feedstock material was not stored in water tight containers,
Feedstock material was not stored on a hardened engineered surface or asphalt
or concrete,
Feedstock material was not stored in a designed and approved storage area (by
the Co-Executive Secretary), or other approved area'
DRC observed open and dlgraded containers containing feedstock material on
soil and located outside of the feedstock management area'
DUSA has violated Part I.D.10 of the Groundwater Permit by failing to replace/repair
concrete in the secondary containment of the caustic Soda Tank.
DUSA has violated part I.D.10 of the Groundwater Permit by failing to repair cracks in the
secondary containment areafor the soda ash tanks'
have questions or concerns regarding this letter please contact Tom Rushing at (801) 536-
Sincerely,
UTAH WATER QUALITY BOARD
a-
b.
d.
2.
aJ.
If you
0080.
7,4% t^^d'b1f
Rusty Lundberg
Co-Executi ve SecretarY
Attachment: DRC Module 65 (Including photo pages)
RL:TR:tr
F:\DUSA\Storm Water Managementg0l0 SW Inspection\DRc 2010 SWBMPP CAL'doc
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page I of 22
Utah Division of Radiation Control (DRC)
Ground Water Module 65
Denison Mines, White Mesa Uranium Mill
DRC Annual Storm Water InsPection
Ground Water Permit UGW370004
Inspection Year: 2010
Inspection Date: October 19, 2010
Module Reviewers NamesAnitials:
Phil Goble, Compliance Section Manager fDb
Loren Morton, Environmental Program Manger
Module PrePared bY:
s/'>/zo t t
Tom Rushing, P.G., Compliance Section X{t
g l;s/ tt
DRC Staff Present: TomRushing, P.G., Compliance Section
DenisonMinesStaffPresent:DavidTurk'WhiteMesaUraniumMillRSO
currenfly Approved storm water Best Management Practices Plan (swBMPP) for the white
Mesa Uranium Mill:
Date: June,2008
Revision No.: 1.3
ViolationsldentiliedinLast(2009)Inspection:oist)None
Two requests for information were issued to DUSA per the 2009 storm water inspection which
resulted in a DRC tett"iautea December !2,2009, summarized below for ease of reference:
1. DRC noted that the sPcc Plan requires tank to soil potential measurements' It was unclear
whether this item was being oro"rtut"n. Please pro,id" information to clarify the intent of
these measurements and whether or not the measurements are currently conducted'
Denison ResPonse:
LJponreviewoftheSPCCPlanDenisonnolesthattanktosoilpotentialmeasur€Inefltsare
referred to at section 1.10 0f the plan within the context of a record that would be maintained
should such measurements actually uoo* necessary. Soil to tank potential measuternents are
. utilized to test cathodic protection ,y*"** for underground tanks antl Piplog' DEnison does not
currenrly ernptoy cathodic prot""tioi-,"r;;;;;; and, th-erefore, such testing is not required at this
time. However, if in the future such systems \ryere to ue utitizea these records would be retained
in accordance with Section l' l0 of the SPCC Plan-
Form Updated December l4' 2010
White Mesa Mill O
Ground Water Module 65
Storm Water Management
Page 2 of 22
2. Please clarify the protocols to determine whether used oil generated at the White Mesa
facility is determined contaminated (i.e. 11e.(2) byproduct material) and disposed of in the
tailings cell, or determined uncontaminated (or not l1e.(2) byproduct material) and sent
offsite for recycling.
I)enison Rgsponse:
Used oit at the White Mesa Mill that has the potential for having been contatninated by
radioacdve material (such as that which may be generated by cleaning of machinery in the shop
and received by the floor drain and conveyed to the used oil tank) is disposed onsite in the Milt
tailings impoundrneut. Oils that are intcrnal to plant machinery (such as vehicle engines) are not
subject ro contamination poteutial and can be drained for offsite recycling. Currently, the oil that
is retained in the used oil tank has received floor drain materials from the shop and is to be
disposed in thc tailings impounclment a.'i I Ie.(2) byproduct material.
An additional RFI will be included per DRC review of the response concerning cathodic protection
(item l) as detailed per the 2010 inspection findings and per the RFI issues outlined in the conclusion
at the end of this memo. Specifically, DRC is concemed that although no underground tanks are
emplaced at the White Mesa Mill, there are on-grade tank installation where the bottom of the tank is
in intimate contact with soil.
Summary of Recommendations Made to DUSA Resardins Previous (2009) lnspection Findinss
(December L2.2009 DRC Letter):
October 2009 Recommendations:
Recommended Actions:
Recommendations related to StormWater Documentation at the Mill
o Part 4.1.4 of the Storm Water Best Management Practices Plan requires a weekly inspection
ofdiversion ditches, drainage channels and surface water control structures in and around the
mill area, Per DRC findings the White Mesa Standard Operating Procedures, Book 11,
Envirogmental Protection Manual, Section 3.1 includes forms for Daily lnspections, Weekly
tailings Inspections, and Monthly Inspections. DRC noted that the diversion Ditches and
Berms are included on the Monthly inspection form (not weekly as included as Part 4.L.4. of
.. the SWBMPP). DRC recommends that Denison insure that all documented inspections
match the frequencies specified in the SWBMPP (including appendices).
. Similar to the recommendation above, DRC noted that the SPCC Plan Part 1.10 refers to a
Quarterly Tailings Inspection. DRC noted that the Tailings Inspections are likely done on a
shorter time schedule (daily inspections) and that a Quarterly Inspection Data form did not
appear to exist. DRC again recommends that all documented inspections match the
frequencies specified in the SWBMPP.. SPCC Plan Part 1.9.2 - It was reported onsite that no "reportable quantity" spills had
occurred at the facility over the period of records reviewed (RQ's from 40CFR117). DRC
noted that there was not a process to document smaller spills, less than reportable quantities.
DRC recommends that a process be developed for employee reporting and documentation of
smaller quantity spills and clean up actions to be included in the SWBMPP/SPCC and that a
log or other documentation is generated to clarify clean-up actions. Section 4.2.I of the
SWBMPP refers generally to this requirement; the Ground Water Permit (Part I.D.10) also
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page3 of 22
requires the control of contaminant spills and immediate clean-up upon discovery (regardless
of iuantity). DRC is only recommending this measure at this time.
. spcc plan 1.10 - It was noted that the daily, weekly and monthly inspection data reports do
not include a field for follow up actions. DRC recommends that follow up actions, and dates
of completion, relating to any iroblems noted during the inspection be logged on the same
insPection data form'
SiteWalkthroughRecommendations(Previous200gInspection)
. During the.site walkthrough of the shop area, DRC noted that a floor drain is located inside of
the vehicle maintenance irea which drains to an outdoor storage tank (See photo log, photo
4). It was report"a by Denison that any oil contaminated water in these tanks is pumped to
the used oil tank and that uncontaminated water is pumped to Roberts pond. DRC noted that
the current process creates a larger quantity of contaminated water (commingling of process
water and storm water) and recommends tirat the indoor drain be blocked and that any indoor
spills be cleaned up at the spill location'
. DRC noted that the sX building roof is currently routed into the concrete containment vault
inside of the building. DRC reiommends that the roof drains be inspected, and the results
documented, during a storm event to insure that the runoff is effectively drained to that point
and is not contribuiing to any ponding of stormwater in the area of processing
. DRC noted that the secondary containment for the caustic soda tank was highly deteriorated'-DRa;;;;;"nds that the secondary containment floor for the caustic soda tank be repaired
or replaced. (See photo log, photos 27,28 and 30)
. DRC noted that the secondary containment for the soda ash tanks showed cracking on the
floor (see photo log, photos
-::
and 34). DRC recommends that the cracks be
1. trfl#:H:fstaging is currently conducred 1, th" south side of the processing-area.on the
soil without berms or containmerfi. (note that Denison made no comfinent regarding this issue-
and. provided no action to resolve t'ir, ,rro**ended actions by DRC) DRC noted that one of
the drums.which had been removed from its overpack was badly corroded and that alternate
feed material.(black flake) was visible through a hole in the top of the barrel (see photos)'
DRC also noted that a trace amount of the black flake was visible on the ground at the base
of the drum. Although the st/orage during staging-is- not currently a violation of the ground
warer p".Ji, pr"use ie adriJea ltrat part t.o. i t or the revised permit will include BAT
requirements ior feedstoclimaterial storage. It is recommended that the barrels be kept in the
overpack ontit ,"uAy to'be loaded onto the 1t1ern1te feed rack within the containment area or
other alternative method at the discretion of Denison. (**note that these staging practices
became a ground water peftnit violation per a 1/102,010 p-ermit modification of Part I'D'11' This is
discussed in more detail in comments/observations related to the alternate feed circuit below)
. DRC noted that when water from the decontamination pad tanks is transferred to the concrete
vault (flushed from the recycle tanks) it is allowed to dlscharge across open ground' DRC
recommends that piping from the decontamination tanks be extended to the concrete vault to
avoid potential erosionlmpacts and/or infiltration concerns (see photos)'
october, 2010 lnspection (current), DRC Staff Findings:
Section I - Document Review
Form Updated December 14, 2010
Part 4.1.4.-- Diversion ditches, drainage channels and surface wat91 control strrretures in and
around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair,
such as excessive ""t"t ur" groitn channel erosion Lr pooling of surface-water runoff' will be
reported to appropriate departments and all follow up actions are to be documented'
Findings:
Diversion Ditch 1 showed excessivs vegetation growtJr as well as evidence of rilling and erosion on
the side banks (See Attached Photos 4, $,44). DRC communicated these issle-s during the
inspection ana onsitapei.onn"t reported that they would provide remediation of the banks
immediatelY.
In response to this issue DRC received an e-mail from DUSA (from Dave Turk) on I0ll9l20lo (same
day of the inspectioni *[i"r', notifies DRC that the diversion ditches were cleaned of vegetation (via
graAing) and provides 3 photos (below):
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 4 of 22
ffiAe-mailtoDRCdated lO t Lg l2O lO showing Diversion Ditch
Maintenance
Diversion Ditch 2 was in reasonable conditions (Attactred Photo 45). DRC noted minor
amounts of vegetation in the ditch'
Form Updated December 14' 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 5 of 22
per DRc review of the DUSA Inspection Forms, it was noted that the Diversion Ditches and
Berms are inspected monthly (note that Part 4-1.4 of the swBMPP requires that these
inspections be done at least weekly)' Per review of the.forms' DRC did not find any
ou..*utions by DUSA regarding ihe excessive vegetation in Diversion Ditch 1 (contrary to
DRC observations Arrirgit. Oc"tober lg,2OlO inspection). The DRC staff recommend that
these issus be included ii a Confirmatory Action letter to DUSA, citing violations of the
Permit Part I.D-10(a) and the SWBMPP Part 4'l'4f'or:
1. Failing to provide inspections of the diversion ditches weekly, and'
z. F*i;; to clean the diversion ditches of excess vegataion which is a failure to
provide active operation measures'
As per above discussion above, DRC comments during the 2009 inspection (December 12'
200g Reco**"noutionrl it *u. noted in a letter as a recommended action that thej-nspection
of diversion Ait"t", J" conauctea and documented weekly as required by the SWBMPP'
However, this iternwas not responded to or addressed and it appears thallhe monthly reports
were made without a physical examination of the ditches (inspection findings were
documented but no inspection was completed)'
Requirements):
1.6.1. - Daily monitoring of propane tanks required'
Findings: :
per DRC review of the forms it was noted that the inspection of the propanetanks is included
on the daly foreman,s inspection forms, however this is onry a checklist and does not require
specific items to be cheqked or specificatly include-tlr: Petroleum tanks, or their individual
condition. The same cornment was made per ttre 2009 rnspection' See the; "December 10'
2009, GroundWater Module 65 Inspectioi, S'o'*Water Best Mana'gement Practices Plan
(swBMPP) Inspection, DRC Review Memo, page 3" as well ast.helDecember 12' 2009
DRC Findings Letter, Page 2'"
..DRC noted that the fuel area is included on the"operating Foreman's-Daily Inspection-.
form, however the form does not specifically refei ti the petroleum tanks within the confines
of the facility, or indicate how thoiough of an inspection is conducted'"
During the october, 2010 inspection, DRC.staff also noted that there was a small volume
diesel spill on the refueling p;d during the inspection (Attached Photo 5)' No evidence was
found during the inspection that DUSA cleaned this spill up-
1.9.1. - External Notification of "reportable quantity" spills'
Findings: During the october, 20r0 inspection, the facility representative stated that there
have been no r"poiuu;;;;;;i,y *p1r.1as per the Community Rigtrt to Know Act' EPCRA)
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 6 of 22
at the facility. DRC confirmed that over the period since the last inspection no reportable
qruntitv spiits 1> 100 kg) were documented. Further, DRC review of DUSA records found
no spitis of uny size were recorded on any of the self-inspection documents'
1.g.2. Internal Notification of incidents, spills, and significant spills'
Performance Standards (list) :
Findings: Per the 2009 observation concerning the reporting of smaller qu1[i!v spills, the
followlng observation was made (December tl,ZOOS DRC letter,page 2): "DRC noted that
there is not a process to report small quantity spills at the site' DRC recommended that a
process be instituted to insure that employ"es lino* who to contact regarding small quantity
spill and follow through with a process of clean-up'"
DRC notes that the Groundwater Discharge Perrnit Part I.D.lO(c) requires DUSA to
,,Cleanup spilts of stored reagents or other chemicals at the mill site immediately upon
discovery" and that the Permi"t part I.D.10(d) requires DUSA to'"report reagent spills or
other rei.eases at the mill site to the Executive Secretary in Accordance with Utah
Administrative code (uAC) 19.5-114-" UAC Lg-s-lli- states that"Any personwho spills or
discharges any oil or other substance which may cause the pollution of the waters of the state
shall iimediately notify the Executive Secretary of the spill or discharge, any containment
procedures undertakin, and a propos?d proceiluie for -cleanup and disposal, in accordance
'with rures of the board'.,, while nRc ugrr"s thatsm{l g}rantity spill would likely not pose a
threat to waters of the State if cleaned ul appropriately, the Administrative Code and Permit
requirements do not state a minimum qruttitv of substance spilled requiring notification
from the company. Per the 2009 recommondation, DRC is allowing the reporting for small
quantity spills (Less than the quantity required to be refglled under the Emergency Planning
Community Right to Know Aci Reportin[ Requirements(CleanWater Act Section 3I] and
Code of Federal Regulations Tftl; 40 pirt liZ)to be an inhouse process of documentation
which can be reviefied by the Executive Secretary during the annual storm water inspection'
per these findings, the 2009 module included a "recommendation" to institute a process'for-
employee reporting and documentation of small quantity and clean up actions @ecenfoer 12'
2009 DRC letter, Page2)-
per the 2010 inspection it was noted that the 2009 recommendation was not addressed by
DUSA, and per interview with the onsite representatives it appeared that creating such a
process *u, not being considered. Failure io institute the spill reporting process is in
violation of the groundwater permit parts I.D 10(c) and (d) as well as UAC 19-5- 1 14' It is
therefore recommended that thi, it"* be included for follow up as a request for information
item to insure that infor-mation regarding process needs and a schedule of implementation for
reporting and documentation of clean up or oit a1{reae91t spills' Failure to provide such a
process i, not in conformance with the swBMpp Part 4.2.1.
Form Updated December 14' 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page7 of 22
L.10 Records and Reports.
Period of Records Examined During Inspection:
Begin/Ending: 4t Lt}}t}l 413012010 and daily 9 123 / 20t0
No. of on-site Records Required: Daily, weekly and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: L07o (Percent of Total)
How Selected: DRC Inspected a full month of daily, weekly and monthly forms as
well as the daily (9123110) form which included a visual inspection
of the SX building roof runoff.
Daily Tailings InsPection Data:
Findings: Daily inspection of tailings slurry transport system, operational systems (wateir
level, b1ach, liner and cover), dikes and embankments, physical inspection of the slurry lines,
dust control and leak detection was implemented and documented on an inspection form.
See attachment 1 (Daily Inspection Form). DRC reviewed all of the forms for the month of
April (April I,20LO rhrough April 30,2010). This month was picked at random. DRC also
rwiewed the daily inspection form for 9t23t2}l}, this report was chosen since includes an
addendum with observations, post rain event, of the SX building roof drainage. DRC noted
that each quafter of reports was organized in a separate hard copy file. All of the reports
(daily, *"ikly, monthly) were on file for the reviewed month (April, 2010). DRC did note
that ihere *ri ,o quarterly report and it was reported by DUSA tt{f thlt_,_ltpections
required quarterly were included on reports at a higher frequency. The DUSA onsite
representative (David Turk) indicated that the higher frequency would be more protective of
thi environment and should be allowed as an improvement to the inspection process. DRC
advised DUSA that a more frequent inspection was likely more protective, but that the storm
water best management practices plan needed to be updated to reflect the current inspection
process and frequencies in order to avoid confusion.
per the 2009 storm water inspection, DRC noted that follow up actions (resolution of noted
problems) were not documented on the actual daily form (December 12,2009 DRC letter).
bRC .""o*mended that the follow up be documented on the daily form. The issue of
follow-up actions and date of completion of follow up being documented on-the same
inspection form (as the one where the problem was identified) was discussed with David
tuik during the October,20IO inspection. He agreed that this process could be improved
and agreedlo modify the inspection form to include a section for follow up actions needed
and dates of comPletion.
per fOllow up of this item during the 2010 inspection it was found that the inspection forms
have not been modified to include date/time of follow up actions on the same form, therefore,
it is still necessary to look at additional forms (following forms) to determine if follow up
actions were taken.
DRC will include the issue of follow up actions for daily inspections as well as updating the
SWBMPP to accurately reflect the inspection frequencies as a "Request for Information"
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 8 of 22
item since these issues are not specific violations of Rule, Permit or Plan. DRC recognizes
that the company has different options in terms of how to better track deficiencies noted
during an inspection. The issue may be addressed on the current inspection forms, or DUSA
may opt to initiate a separated tracking system (e.g. a monthly non-compliance report) to
document inspection deficiencies and follow-up actions.
Weekly Tailings Inspections and Survey:
Findings: The weekly tailings inspection was done and documented on a weekly tailings
inspection form. The form includes sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for cell l, 3, 4A and
Roberts Pond, as well as slimes drain liquid levels in cell 2. The form also includes
information regarding the leak detection systems for cells 1,2, and 3 and 4A as well as
potential blowing of tailings. The form, as part of the Standard Operating Procedures, also
includes sections for reporting parameters about the kak Detection Systems (part of the
DMT plan requirements, not stonn water related). Per the 2009 inspection, DRC had no
comments regarding the weekly tailings inspection (see December 12,2009 DRC letter). Per
this 2010 inspection, the weekly form still meets the required frequency, and appears to
include required information. However, per in-house discussions amongst DRC staff, it was
noted that in order to avoid confusion it may be preferable to organize inspection protocols
for storm water requirements separate form engineering related tcipics. This topic will be
reviewed again during the 2011 storm water inspection, and options regarding the forms will
be discussed with onsite DUSA representatives.
Monthly Tailings Inspection, Pipeline Thickness z :
Findings: The monthly inspection report includes a summary of the slurry pipeline condition
and measurement of pipe thickness during 2010. Per the 2009 inspection (December 10,
2009, GroundWater Module 65 Inspection, StormWater Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo, page 4), it was noted that the March 21,2009
monthly report did not include a measurement of pipe thickness due to the mill being in non-
operational status.
The monthly report additionally contains inspection protocols and observations related to the
diversion ditches and berms, sedimentation pond, dust control, settlement monitors and
slimes drain static head measurements for cell 2. Per above (weekly form comments) DRC
will require that follow up actions regarding any findings or maintenance needs be included
on the same inspection form or per an alternative method such as the use of an internal non-
compliance report which could by developed by DUSA. Per above, this issue will be
included as a "Request for Information" item.
Quarterly Tailings Inspection:
Findings: During the October, 2010 inspection, DRC staff noted that there is not a Quarterly
inspection form. It appears that all inspections required on a quarterly inspection frequency
are conducted at other (shorter) frequencies and are recorded on alternate forms. Per
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 9 of 22
discussion above in the daily inspection RFI section, these are not specific violations of Rule
or the Groundwater permit, however, the DUSA facility SWBMPP does need to be kept
current, thus, this item will be included in an RFI letter to the facility'
Tank to soil potential measurements:
Findings: This item was included as a request for information to the facility on the 2009
Findings and RFI T.etter, the response from DUSA is below:
Donisp[r Eeeoonse:
Upon review of the SPCC Plan Denison noree that tank ts soil potential tnEa$urementr Bre
re,ierrc* to at Section L l0 of the Flffi within the cofltext of a rpcord rhat tYould be maiatained
shouldsuehrneasuremenuaauallybecomenecessary.$niltotankpotentialmeasurementsare
utilired to test cathodic protection $ysteru for underground tanks and piping' Dcnison does.ntrt
curreutly employ cathod'ic protertion $ystcms sild, therefnre, such testing is not rcquired *t thit
time. Hcwever, if inthe n tur" sach systems wett ts be utilized these records would beretainod
in acsordance with Sedior l.l0 of the SPCC Plan'
DRC notes that although DUSA states that no underground storage tanks are currently
emplaced at the white Mesa Mill, there are several tanks which are sitting on the ground and
can not be visually inspected (On Grade Tanks). DRC will therefore request additional
information frombuSA regarding their current inspection protocols for on-grade tanks.
Cathodic protection is needed for bUSl to comply with Part I.D.10(a) of the groundwater
permit ito insure integrity of the bottoms of tanks which are installed on-grade).
,Annual bulk oil and fuel tank visual inspections:
Findings: Per the DRC 2009 inspection review cofilments (December 10,2009, Ground
Water Module 6i5 Inspection, StormWater Best Management Practices Plan (SWBMPP)
Inspection, DRC Reiiew Memo): tank condition is not specifically checked by the mill. DRC
did note that a general inspection ofthe tank area is conducted (listed as fuel area) and
documented on the operating foreman's daily inspection log, however, this does not
comprehensively address the conditions of each tank at the facility. DRC also noted that
daily volume measurements are recorded for the fuel tanks, but, again, the tank condition is
not taken into account. These omissions on DUSA inspection reports were noted to be the
same per the 2010 inspection. Per DRC review of the facility Groundwater Permit and
SWBMp it was noted that there is not requirement for DUSA to inspect and document the
condition of these tanks. It is recommended that inspections to visually inspect the integrity
of each of these tanks be included in the permit at atleast an annual frequency (Item to be
included in a Ground Water Permit Modification).
DRC noted that the diesel storage tanks located on the north side of the mill building (2
tanks, 250 gallons each) do not have secondary containment systems. The unleaded gasoline
tank does include a 3,000 gallon secondary containment structure which is the same volume
as the tank. Diesel tanks ut tt " pump station include secondary containment for the volume
of I tank (2 tanks located inside of the containmen|. DRC will insure that potential issues
Form Updated December 14,2O1O
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page lO of 22
regarding these tanks are addressed with the SPCC review "Request for Information" as
described below.
Tank and PiPeline thickness tests:
Findings: Per DRC review the only thickness test noted was the slurry pipeline thickness and
this is only taken during times when the Mill is operating. No issues were noted during the
inspection regarding this requirement'
Quarterly and annual PcB transformer inspections (currently PcB only):
Findings: Per the 2009 inspection, the facility reported that there are currently no PCB
transformers at the site. DRC discussed that ihe SpCC rule, 40CFR112 has.been updated to
i;;ffi;;;;-pCg oil types. Denison agteed to review the new language and update the
SpCC plan as uppropriirr. Per the ZOtO follow up, it does not appear that-the SPCC plan has
been re-evaluated p"i th" 2009 recommendation (December L2,2OO9 DRC 6tter)' DRC
will include this issue as a request for information item, to ensure that all inspections are
consistent with the ""*"r, SpCC regulations. Also, DRC will request information regarding
the current inventory of petroleum stored at the rnill to insure that all oil types and tank
luantities, secondary containment (tank descriptions) included on the mill inventory list are
ionsistent with current SPCC requirements'
Tank supports and foundation inspections:
Findings: The operating foreman.r-dlly inspection provides a general inspection of the Fuel
Area, but does not provlde a specific irspe"ilot of tank supports and foundation' This item is
also covered in theiank condiiion inspection section above. DRC noted that the inspection
frequency is not noted, it was interpreted that this inspection relates to a visual inspection of
th.int"grity of tank supports only and is likely conducted with the tanks condition report'
DRC will follow up *iri, this item during tt " ZOt 1 storm water inspection. Specifically,
ilia ;iiiin* trrat tank supporrs and f6undations are inspected and documented with the
tank coirdition rePorts.
. Spill Incident RePorts:
Findings: No spitl reports/incident reports were filled out on any of the DUSA inspection
forms examined auring the october, j010 inspection. Denison representative reported that
there have been no ,plttr. Per comments above, DRC will include a "Request for
Information,, to insu're that small volume (smaller than reportable quantity spills) and follow
;;i;i;;;;pl unJ ao"umentation prorocots associated with the spills is implemented.
Latest revision of sPcc plan (onsite and available?):
Findings: The current SPCC plan (dated June, 2008) was onsite and available during the
inspection.
Form UPdated December 14' 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 1 I of22
1.11" Personnel training and spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
DRC reviewed the log of people who have been trained to conduct the daily inspections at
the White Mesa facilitY as below
Period of Records Examined:
Begin: October 23.2009
Ending: October 19,2010
No. of Records Found: 13
No of Records Examined: 13 (100 Percent of Total)
HowSelected:ComprehensiveReviewofthisTraining
Findings: DRC found that specific to 2010, 4 people had been trained including those
conducting current daily inspections at the site The Radiation Safety Personnel also signed
the forms Certifying the'trainee as qualified to conduct the daily inspections
Regulatory Requirements (Groand water PerrnitllGwi7\\h4, utah Administrative code
(UAC) and Utah Code Annotureil (UCA)
This section quotes the White Mesa GroundWat:er Quality Permit and' SWBMPP to clarify
issues of non-compliance and./or nonconformance with the requirements'
In the Ground Water Permit:
The ground water permit Part I.D.10 requires provisionsin the facility SWMPP to: 1' Protect
groundwater quality or other waters Uy iesign, construction, and/or active operational
measures that meeithe requirements of Groundwater Quality Protection Regulations (uAC
iltir:a-e.tiG) and R3t7-6-6.4(C),2. Prevent, control and contain spills of reagents and
chemicals, 3. Clean up spills of reagents or chemicals immediately upon discovery'
UAC R31 7-6-6.3(G)stui., "lnformationwhich shows that the d.ischarge can be controlled
and will not migrati in* ,, od.rrrr"ly affict the quatity -of any other waters of the state'
including the ipplicable surface water iuatity standards, that the diicharge is compatible
with the receivrng giouod iater, and tiat thi discharge will comply with the applicable class
TDS limits, grouni *oter quality standards, class protection levels or an alternate
. concentration limit proposed by the facility-"
R317-6-6.4(C) states "The Executive secretary may issue a groundwater discharge permit
for an existing facilitY Provided:
" l. the applicint deminstrates that the applicable class TDS limits, groundwater quality
standards and protection levels will be met;
2. the monitoring plan, sampling and reporting requirements are adequate to determine
compliance witi ipplicabli reqiirement s ;
Form Updated December 14,2010
White Mesa Mill
Ground Water Mbdule 65
Storm Water Management
Page L2 of 22
3. the applicant utilizes treatment and discharge minimization technology commensurate
with plait process design capability and similar or equivalent to that utilized by facilities
that produce similar products or services with similar production process technology; and,
4. there is no current or anticipated impairment of present and future beneficial uses of the
ground water."
UAC R3l7-6-6.3(G)and R317-6-6.4 refer to requirements for ground water permit
applications and require that any discharges will be consistent with ground water class limits,
appropriate discharge minimization technology is in place etc'
(UCA) 19-5-114 requires that a person who spills any substance which may cause pollution
of waters of the State (includes groundwaters) is required to "immediately notify the
executive secretary of the spill or discharge, any containment procedures undertaken, and a
proposed procedure for cleanup and disposal, in accordance with rules of the" water quality
board.
The following quotations are from the White Mesa Stormwater Best Management Practices
plan (pp. 4 -b'. These quotation refer specifically to best management practices that have
been approved by the Co-Executive Secretary to be followed by DUSA.
Best Management Practices Plan (June 2008), List of General Best Management Practices
(performaice Standards) applicable to all areas and specific areas of the site (Section 4-0 of
the SWBMPP) as listedbelow
All Areas:
1,Keep potential pollutants from contact with soil and surface water,
. - Stor" hazardous materials and other potential pollutants in appropriate
containers. Label the containers
. Keep the containers covered when not in use.
Keep potential pollutants from 6ontact with precipitation
. Store bulk materials iir covered tanks or drums
o Store jars, bottle, br 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)
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
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 weekly in accordance with
the regularly scheduled inspections required by Groundwater Discharge
Permit No. UGW370004 and Byproduct Materials License #r/f19$479-
Areas requiring maintenance or repair, such as excessive vegetative growth,
J.
4.
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 13 of 22
channel erosion or pooling of surface waterrunoff, will be reported to the site
rnanagement and mainte**"" departments for necessary action to repair
au.nuE" or perform reconstruction in order for the control feature to perform
as intind"d. Stutu. of maintenance or repairs will be documented during
follow up inspections and additional action taken ifnecessary
s' Recvcle fluids
[1!il,:::3,t#llr",o-otr. fluids, solvenrs and cleaners that can be
recycled or reclaimed, when possible, select consumable materials from suppliers who will reclaim
empty containers
Process and. Lnboratory Areas:
I Clean UP SPills ProPerlY
bto* up spills with dry cleanup methods (absorbents, sweeping, collection
drums) instead of water whenever possible
; fff iffi;.;,ffi,''"'ffi ;:':*""**
drur;, una p"rroor-"I protective equipment (PPE) near the areas where they
may be needed for sPill resPonse'
;:x*tll;"*u
down, use rhe minimum amount of water needed for
2 n"1'l
*iffi','*iffiH*- ::: #:; ;"::";""'
diked areas when Possibleo 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' t3 Water Management. when possible, recycle and reuse *ur", irorn flushing and pressure testing
equipment. Wt * possible, wipe down the outsides of containers instead of rinsing them
off in the sink
o when possible, wipe down counters and work surfaces'instead of hosing or
rinsing them off to sinks and drains
4 Materials Managemento Purchase and inventory the smallest amount of laboratory reagent necessary
Do not stock more of a reagent than will be used up before its expiration date
o All new construction of reagent storage facilities will include secondary
containment which shall control and prevent any contact of spilled reagents'
orotherwisereleasedreagentorproduct,withthegroundsurface'
M aint ena,nc e A ctiv iti e s :
I KeeP a Clean DrY ShoP
Sweep or vacuum shop floors regularly
Form Updated December 14' 2010
White Mesa MilI
Ground Water Module 65
Storm Water Management
Page14of22.
. Designate specific areas indoors for parts cleaning, and use cleaners and solvents
onlY in those areas
. Clean up spills promptly
. Keep supplies of rags, collection containers and sorbent material near each work
area where theY are needed
o Store bulk fluids, waste fluids and batteries in an area with secondary
containment to capture leakage and contain spills
2 Manage Vehicle Fluids
o Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon
as possible
o Promptly contain and transfer drained fluids to appropriate storage area for reuse,
recycle or disPosal
o Recycle automotive fluids, if possible when their useful life is finished
3 Use Controls During Paint Removal
o Use drop cloths and sheeting to prevent windborne contamination from paint
chips and sandblasting dust
o 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 Use Controls During Paint Application and Cleanup
o Mix and use the right amount of paint for the job. Use up one container before
opening a second one
. Ricycle or reuse leftover paint whenever possible
o 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 sewei to the tailings system
o Paint out brushes to the extent possible before water washing (water-based paint)
or solvent iinsing (oil-based paint)
o Filter and reuse thinners and solvent whenever possible. Contain solids and
unusable excess liquids for transfer to the tailings area
Ore Pad, Tailings area, and Heavy Equipment
1 Wash down vehicles and equipment in proper areas
. Wash down trucks, trailers, and other heavy equipment only in areas designated
for this purpose (such as washdown pad areas and the truck wash station
o At the truck wash station, make sure the water collection and recycling system is
working before turning on water sprays
2 Manage stockpiles to prevent windborne contamination
. Water spray the ore pad and unpaved areas at appropriate frequency in
accordance with Mill SOP's
o Water spray stockpiles as required by opacity standards or weather conditions
o Don't over-water, Keep surfaces moist but minimize runoff water
3 Keep earthmoving activities from becoming pollutant sources
o Schedule excavation, grading and other earthmoving activities when extreme
dryness and high winds will not be a factor
o Remove existing vegetation only when absolutely necessary
. Seed or plan temporary vegetation for erosion control on slopes
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 15 of 22
Section II -- Sire Walk Through Inspection
Areas and Observations:
Ore Storage:
Observations (attach extra sheets if needed): Ore is currently being stockpiled at the facility
until a large enough quantity is stored for an ore run. DRC noted that a runoff drain (piped to
the tailings cells) was constructed at the southwest corner of the ore storage area per past
DRC comments and that the drain appeared to be clean and that the overflow pipe was
visible above accumulations of sediment. Although accumulations of silt/clay were within
the drain it did not appear that the integrity of the drain was impacted and that it was likely
free draining. Also, the berm on the eastern side of the tailings storage area had been re-
graded and heightened and appeared improved over what was observed during 2009. (Photos
I and}) DRC had no additional recommendations concerning this area.
Reagent Yard:
Observations: (attach extra sheets if needed): A new, enclosed, reagent building is has been
constructed for dry chemical storage (Photo 39).
Per DRC inspection of the reagent yard it appeared that drum storage was appropriate. No
degraded or tapped drums were noted in those areas. (Note that alternate feed/intermediate
product drum storage are logged in other sections below)
Shop/Vehicle Maintenance Area :
Observations: Per the 2009 walkthrough comments it was noted that (December 10, 2009,
Ground Water Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo):
"DRC noted that a floor drain was located inside of the building which drains to an outdoor
storage tank (below ground concrete vaults). It was reported that any oil contaminated water
in these tanks was primped to the used oil tank. DRC noted that this creates a large quantity
of contaminated stonn water and recommended that the indoor drain be blocked and that
indoor oil spills be cleaned prior to contamination of storm water. If the water in the vault is
determined to be uncontaminated then it is transferred to Roberts Pond."
Per the October, 2010 inspection, DRC noted that the interior floor drain was still open and-
operating (Photo 7) and that no reconfiguration or process changes had occurred in response
to the DRC findings. Since these issues are in conflict with the best management practices
quoted above, specifically since the interior drain and containment area produce a larger
volume of contaminated fluid (mixes with storm water), this item will be included as a
request for information for follow-up.
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 16 of 22
Mill Processing Areas:
Two specific areas of observation comments were noted during the 2010 site walk through as
below.
Observations l: SX Building Roof Drainage Runoff - The 2009 DRC inspection
recommendations included this as an item and recommended that the SX roof drainage be
evaluated (per an onsite personnel inspection) to evaluate whether the current system was
adequate to avoid roof drainage downgradient into the alternate feed circuit . It was noted
that this onsite inspection was conducted on 9/2312010 by David Turk and that the comments
were included as an addendum to the daily log. Per the 9/23110 DUSA inspection onsite
personel observed that the current drainage system is "not adequate." In follow up the
9123110 inspection states that "the drainage system needs to be addressed by the engineer and
have the situation corrected." DRC will include a request for information to determine what
findings have been made and if any corrective actions were conducted.
Observation 2: Vanadium intermediate product stored in open drums (Photo 17). DRC
noted that approx 20 open drums, containing product, were located onsite directly
downgradient from the existing decontamination pad: It was noted that these drums are
located within the "Feedstock Storage Area" as defined by coordinates listed in the
Groundwater Permit Part I.D.3.F. Therefore no additional follow up will be done regarding
the observation.
Alternate Feed Circuit South of SX Building:
:
Observations: During the October,20L0 inspection, DRC observed the new altemate feed
processing aiea. It was noted that drainage within the containment area was pumped into
overhead tanks. During the inspection it was reported by David Turk that a Denison
employee was posted at the alternate feed location 24 hours aday,7 days a week, see Photos
33 through 35. DRC noted that drums of black flake were still being staged on soil areas
adjacent to the alternate feed circuit. Per the 2009 recommendations, DRC stated (December
12,2009 DRC Findings Letter, p. 3):
o Alternate Feed staging is currently conducted on the south side of the processing area on the
soil without berms or containment. DRC noted that one of the drums which had been
removed from its overpack was badly corroded and that alternate feed material (black flake)
was visible through a hole in the top of the barrel (see photos). DRC also noted that a trace
amount of the black flake was visible on the ground at the base of the drum. Although the
storage during staging is not currently a violation of the ground water permit, please be
advised that Part I.D.11 of the revised permit will include BAT requirements for feedstock
material storage. It is recommended that the banels be kept in the overpack until ready to be
loaded onto the alternate feed rack within the containment area or other alternative method at
the discretion of Denison.
Per the 20lO inspection findings it was noted that the same issue was present onsite. Several
barrels of alternate feed material (black flake) were found stored (staged) on soil on the south
sidg of the processing area, west of the SX building, without overpacks in badly deteriorated
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 17 of 22
drums which had been perforated on the side and without cover (see photos 36,37 ,38).
Therefore, Denison Mines ignored the recommendations of the 2009 inspection
correspondence.
The Denison Mines Groundwater Permit, Part I.D.11 (BAT Requirements for Feedstock
Mateial Stored Outside the Feedstock Storage Areawas modified on January 20,2010 and
states:
*BAT' Requirements for Feedstock Material Stored Outside the Feedstock Storage Area -
the Permittee shall store and manage feedstock materials outside the ore storage pad
in accordance with the following minimum performance requirements:
a) Feedstock mateials wilt be stored at all times in water-tight containers, and
b) Aisle ways will be provided at all times to allow visual inspection of each and
every feedstock container, or
c) Each and every feedstock container will be placed inside a water-tight overpack
priar to storage, or
d) Feedstock containers shalt be stored on a hardened surface to prevent spilla,ge
onto subsurface soils, and that conforms with the following minimum physical
requirements:
I ) A storage area cornposed of a hardened engineered surface of a.sphalt or
concrete, and
2) A storage area designed, constructed, and operated in accordance with
engineering plans and specifications approved in advance by the Executive
Secretary. All such engineering plans or speciftcations submitted shall
demonstrate compliance with Part 1.D.4, and
3) A storage area that provides containment berms to control stormwater run-on
and run-off, and
4) Stormwater drainage works approved in advance by the Executive Secretary,
or
Other storage facilities and means approved in advance by the Executive Secretary "
Therefore, the storage practices observed in October, Z0l0 are a violation of the
Groundwater Permit Part I.D.1 l, for the following reasons:
1. Feedstock Staging and Manag"*"ni - staging of feedstock in preparation of
its entry into the alternate feed circuit is part of feedstock management, and
subject to the requirements of Part I.D.l I of the Permit.
2. ObservedFeedstock - during the October,2010 inspection DRC observed:
a. Feedstock material was not stored in water tight containers,
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page L8 of 22
b. Feedstock material was not stored on a hardened engineered surface
or asphalt or concrete,
c. Feedstock material was not stored in a designed and approved
storage area (by the Co-Executive Secretary), or other approved area,
d. Feedstock material was stored in open and degraded containers
containing placed on soil and located outside of the feedstock
gement area.
As a result, DRC staff recommend that the feedstock management violation be included on
the confirmatorY action letter-.
Old Decontamination Pad:
Observations: Wash water is recycled until too dirty to be used effectively for vehicle
washing, the water is then discharged to a below glade tank thence to the process water pond'
DRC noted that the concrete collection vault for overflow from the pad (thence discharging
to Roberts pond) was repaired per the inspection findings listed in the 2009 DRC review
memo and Findings LeGr. Splcifically it was noted that the discharge from the
decontamination pad holding iank was piped completely to the wash-out tank. It was noted
that the wash-out tank was fuU of sediment and required clean-out. Note that this
decontamination pad is seldom used since commencement of operation of the new facility'
DRC has observed the pad during visits to the facility subsequent to the inspection and
verified that the old pad is defunJt. No further action will be conducted related to the
findings at the old decontamination pad.
New Scale House Decontamination Pad:
Observations: The new decontamination pad (facitity) was not in operation at the time of the
t.
st-orm water rnspection. The baffle water iontainment/treatment tanks had been drained of all
- *ut". and a Utact< sealer was applied on all interior seams.(See Photo 3 and 4)- Onsite DUSA
representatives stated that the containment system was being prepared for a hydrostatic test
to prove tank integrity. Note that the tank improvements were being conducted during no-
opiration period of tfr" new decontamination pad. No further action will be conducted per
otservations at the scale house decontamination pad'
Reagent Tanks:
Sodium Chloride Tanks - DRC noted that the containment area was earthen. It was
reported that this was allowable due to the age of the tanks. Per discussion between TR and
LM it was noted that LM had a past discussion with Harold Roberts regarding the secondary
containment. An agreement wai forged that all reagent tanks that pre-existed the Ground
Water permit (3/05j would be acceptable as is - and that'as upgrades or replacements were
installed, DUSA would work to meet BAT requirements. More detail regarding this
"g*"*"", is in the December 2004 Statement of Basis, and in Part I'D'3(g)' See Photo 15'
Form Updated December 14' 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 19 of 22
Kerosene Tanks -- DRC noted that the containment area was earthen. It was reported that
this was allowable due to the age of the tanks as discussed in the Sodium Chloride Tank
Section above. Photo 14
Ammonia Tanks -- DRC noted that the containment area was earthen. It was reported that
this was allowable due to the age of the tanks as discussed in the Sodium Chloride Tank and
Kerosene Tank sections above- Photo l3
Used Oil Tank - Appeared to have appropriate secondary containment. No records
concerning visual inspections of tank integrity. Photo 6
Kerosene Tank - Located in the same secondary containment area as the used oil tank.
Facility reported that this was acceptable (by rule) as long as the containment was
constructed for the largest tank. This criterion is consistent with past inspections by DRC at
the site with similar findings. Photo 6
Fuel Tanks - Above ground tanks appeared maintained and had secondary containment.
Photo 5
Uranium I.iquor Tanks - Containment areas appeared to be in good condition. Photo 18
Vanadium Pregnant Liquor (VPL) Tanks - Per comments related to an Engineering
(Discharge Minimization) inspection conducted by DRC personel during 2010 it was noted
that steam condensate from the VPL tanks was being allowed to accumulate in the area of the
tanks and around the tanks. In response to these comments DUSA has agreed to provide a
concrete secondary containment and pumpout system for the steam condensate (this item is
being tracked under separate cover). For additional information, see DUSA letter dated July
15, 2010 and DRC ,"rporr" dated September 2'7,2070. DRC noted per this inspection that,
pending the construction of the containment pad, DUSA has provided drain extensions and is
discharging ttt. *gi"r into storm drains awayfrom the VPL tanks (Photos 11, 12). DRC will
follow ,p *ith tt li item as necessary to insure that condensate water or upgradient runoff
does not accumulate in the VPL tank area-
Clean Water Tank -- DRC noted that the clean water tank valve was not sealed, the valve
was leaking water (exact volume/time was not measured) at approx 60 gallons/minute. Photo
19. The repair of this valve will be included as a request for information item to insure that
water is noi surface ponding in the confines of the facility without adequate engineering
controls (eg liner).
Sulfuric Acid Tank - The tank appeared in good condition. DRC noted that a new berm
was recently constructed around the sulfuric acid tank. Onsite DUSA representatives
reported that this was done in response to historical DRC comments regarding potential large
scale breaches of the tanks. DUSA representative also reported that if such a breach occurred
it could impact a transformer station (electric power) located approx 200 meters east of the
tank. Photos 21, 22 &23
Form Updated December l4,2OlO :
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page}O of 22
Propane Tank - No issues observed. DRC noted that the valves and air quality system was
recently replaced. Area was clean. Photo 25
Caustic Soda Tank - Secondary Containment was not in good condition. Concrete was
highly degraded and appeared to have holes extending to underlying earthen material. The
DRC 2009 recommendation was to repair or replace the secondary containment floor. This
recommendation item was not addressed and therefore will be included with the 2010
Confirmatory Action items. Failure to maintain the integrity of the secondary containment is
a violation of the Groundwater Permit Part I.D.10.b. (See photos 29,30)
Soda Ash Tanks - Secondary containment floor showed cracks. DRC 2009
recommendation was to repair or replace the secondary containment floor. The
recommendation was not addressed and will therefore be included on the 2010 Confinnatory
Action Items. Failure to maintain the integrity of the secondary containment is a violation of
the Groundwater Permit Part I.D.10.b.
Tailings Cells Areas (Note that upland drainage was included in comments above) --
DRC toured the tailings cell areas (Cell s I,2,3,4A and 48 (under construction at time of
inspection) and observed the condition of the outer toe areas of the dikes to insure that
excessive erosion or damage (e.g: burrowing animal intrusion or rooting damage) was not
present. Per the DRC review the dikes appeared in good condition.
Summary of Onsite Closeout Meeting: An onsite close-out meeting took place between
Torn Rushing (DRC) and David Turk (DUSA). During this meeting DRC infonned the
DUSA representative of the issues stated in the inspection above. It was especially noted that
the DRC 2009 recommended actions were for the most part not addressed and that these
items would likely be included as confirmatory action items for the 2010 correspondence.
DatelTime: 10- 19-2010/1300
:DUSA Representatives Present --'David Turk, RSO
DRC Representatives Present - Tom Rushing, P.G.
Conclusions
DRC will arrange a conference call with DUSA representatives to discuss the confirrnatory
action items and request for information items detailed above and summarized below. It is
anticipated that compliance schedules (deadlines) will be negotiated and finalized during the
conference call:
Form Updated December l4,20l0
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page}l of 22
The CAL items are:
l. DUSA has violated the Groundwater Permit Part I.D.1l by failing to manage drums
containing alternate feed material (located outside of the feedstock management area)
in compliince with the required performance standards.
a. Feedstock material was not stored in water tight containers,
b. Feedstock material was not stored on a hardened engineered surface or
asPhalt or concrete,
c. Feedstock material was not stored in a designed and approved storage area
(by the Co-Executive SecretarY), or other approved area'
d. DRC observed open and dbgraded containers containing feedstock
material on soil and located outside of the feedstock management area.
DUSA has violated the Groundwater Permit Part I.D.10 by failing to replace/repair
concrete in the secondary containment of the Caustic Soda Tank.
DUSA has violated the Groundwater Permit Part I.D.10 by failing to repair cracks in
the secondary containment area for the soda ash tanks'
The RFI items are:
1. DRC will requiest information regarding updates to the plans/inspections to provide
inspections according to frequencies required by the Storm Water Best Management
pracrices plan (SWBI{PP). For example, the SWBMPP requires a weekly inspection
of the diversion ditches, however, they are conducted monthly. Failure to provide
these inspections in conformance with the SWBMPP or modify the SWBMPP is a
violation of the Groundwater Permit Part I.D.:10., "The Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices
Plan."
Z. DRC will request information regarding the,insiection procedures for reagent storage
tanks (including intermediate p*"rr tanks, eg Pregnant Liquors) which are installed
on-grade (on-giade refers to tank installations where the tank bottom is in contact
witfi the groun-a; to insure that the structural integrity of the tank bottom is
acceptable/appropriate. Cathodic protection for on grade tanks is prescribed for the
on-giade tanks, in order for DUSA to comply with Part I.D.10(a) of the groundwater
permit.
3. bRC *itt request an outline of a plant process for internal notification and
documentation of the clean up of small quantity spills (less than reportable
quanrities). per the 2010 inspection it was noted that a fuel spill had occurred at the
fuel tank area, however, had not been cleaned up and there did not appear to be a
process to identify, document, or clean up such spills. Failure to provide such a
pro""ur is not in conformance with the SWB'MPP Patt4.2.l.
4. bRc *i1 request that DUS,{ review the facility SPCC plan to insure that all tanks
included und". the current facility Spill Prevention Countsrmeasure and Control
Form Updated December 14' 2010
2.
J.
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 22 of 22
(SPCC) plan meet current requirements of current EPA rules (4OCFRI12).
Specifically, any non-PCB containing tanks should be included under oil inventory
ara U* included with inspection protocols. This RFI is required in order to insure that
cuffent procedures and policies at the mill are up to date.
5. Seal interior drains in the vehicle maintenance areas that drain to outdoor uncovered
areas. This is specified in the facility SWBMPP and is considered a best management
practice to minimize the quantity of contaminated material. The open drain is not in
conformance with the SWBMPP part 4.3.1, second bullet "clean up spills promptly,
don't let minor spills sPread."
6. Insure that the clean water tank valve is sealing properly. Per the 2010 storm water
inspection it was noted that this valve was leaking and was creating pond areas in
unlined ditch/soil areas. This is not in conformance with Section 4.1.4 of the
SWBMPP which states, "Areas requiring maintenance or repair, such as excessive
vegetative growth, channel erosion or pooling of surface water runoff, will be
report[ed] 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."
F:\DUSA\Storm Water ManagernenM0l0 SW krspectionV0lO SW Inspection Memo - White Mesa Mill - Fnl.doc
U:Vad\COMMON\Uraniummills\l le(2)UT1900479 Denison Mines - White Mesa UMill\Storm Water
Management\Modu le65 MemoFormat.doc
Forh Updated December 14,2010
White Mesa Mill, 2010 DRC Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 1 - Copies of Daily, weekly and Monthly Inspection Data Logs for April,
2010
White Mesa Mll - Standard Operating Procedures
Book 1l: Envirorunental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 17 of25
APPENDIX A (CCINr")
DATLY UYSPECTION DAT^A
Daf€; q-q-lO
Accompaniedby:-atA--
rime: l3o0
Ahy Item not'!OK;'must be doouniented.A oheckmark= 0& X: Action Required
gEpgrIlplrttelrrs Cell l Cell2
Stuiif,Fin-e"liae Ircaks-Damase, Brlookage, Sharp Bends ; : " ':{i'{...1'i,-',1:
S'.iiietiiiElldfiiliC'ffiirons
Dii.liilffi6Bs66brs ;ti.' iy". r i'i .: 1(/'':i',il
Velves'Lesks-Blocked'dloSed ..,.l
Poin(s).of.Disgharee. . ....4.,
. 1.r. a]. .rili{..i. , ::j
o
IMhite Mesa &{ill * Standard Operating Frocedures
Eook I l: Environmental Protection hianual, Section 3.1
2/OTRevision: DUSA-2
Page lB of25
. o. FnYsrcALTffiSEioFroB.sLrrRRY
Walked to Discharge Point
Observed Entire Discharge Line
-I;"dl. cs - cl A
Yes-----V-Y.,
Ll f6 Gptvl
"/ No
No
VI. DUST
s,+tl\ Cr-q,\ co0eneA eypose,A
.*r,U9.4. Bllo AR. sLli"n..
Dcekln bJ.llt r,ccre y'
fina ar cclt L
Si^J.a. A.n+hf Rc.ou..p 04 sr;fts #J.
CIA[[-t dsPEer!8rf REP0&rTAlultrGS StUREY 0.ISEHAnGE E 0GATXOru
oATE: Ll^S- *o_!Q
tHSPgCtOB: fr.lu-f
*! Ll-g
's* 4R\
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
APPENDIX A (CONT)
DENISON MINES ruSA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
@) FML Bottom Elevation
Ce[l 4A': (a)Pond Solution Elevation
(b)FML Bottom Elevation
3/10 Revision: Denison-9
PageZ8 of 46
5613 58
5597
al,G7
sCH 5l
nut"' Ll-2- l0 lnspectors:
1. PondandBeach
elevations (msl,ft)
(c) Depth of Water above FML (a)-(b)) 16-Lg
5F 85.6-I
5564-.
(c)Depth of Waterabove FML (a)-(b))
(d)Elevation of Beach Area
with Highest elevation (monthlY)
Roberts
Pond: (a)Pond Solution Elevation
Lctl 3
2. Slimes Drain Liquid Levels Cell}
(b)FML Bottom Elevation --n-5i,Y.34-(c)Depth of Water above FML (a)-(b)) A't'
Depth to Liquid pre-pump
Depth to Liquid Post-PumP
5s6\.qq
5s10jl'qq.
Pump tunctioning properly Y"*
Pump Timer set at tsmin-on +imin off .aro l-L*al'c Flo{ tgdtr
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
_laaq
Post-pump head is 38' -Depth to Liquid Post-
pump = lf\.qS
White Mesa Mill - Standard Operating procedures
Book I 1: Environmental protection Vtanua, Section 3.1
3/10 Revision: Denison-9
Page29 of46
3. Irak Detection Systems
Observation:
UEII I Cell2 anl3 CqIL4A
V wet d
Is LDS wet or dry?wet V rl*t/ wet drv wet-yldrylf wet, Record
liquid level:
- .t{t to
Liquid
Ft to
Liquid - Ftto
Liquid
67 Ft to
Liquid *If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Flow Rate -Volume
Flow Rate_
'rrl
Flow Rate -
Volume ,5ASO
Flow Rate_
Was fluid sample
collected?
yes_lr no ),es- -11 no Yes / ns
-yes-6;-
fai$ry Area lnspection (Nore dispersal of blowing tailings):
7. Contaminated Waste Oo*r,
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/10 Revision: Denison-9
Page 30 of46
8.0 DecontaminationPadlnspections
Remarks (including a description of any abnormalities relating to the New Decon Pad or Existing Decon
Pad)
* Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (elevation
5556.14 amsl)? ,,/ no
-
Yes
tf Cell44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexible
membrane liner (elevation 5556.14 amsl), notrfy supervisor or Mill manager immediately.
Are there any cracks on the
wash pad surface greater
than l/8 inch of
seoaration? Yes i/No
Contact the RSO if a
problem has been
observed.
Are there any cracks on the
wash pad surface greater
than tr/8 inch of
senaration? Yes r/No
Contact the RSO if a
problem has been
observed.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
7O7 Revision: D-USA-2
Page2? of25
APPEI{DIX A (COII{T.)
MONTIILY INSPECTION DATA
lnspector:
.r:1,. l
,:l
:,.1
.*?rL " J
r.rl'rili,.
(:
L , Slqrry
White Mesa Mill - Standard Opelating Procedures
Book 1l: Environrnental Protection Manual, Section 3.1
, .*-\
4. Overspray Dust Minimization: Vr,*i t Tru \
!'
Overspray system functioning properly:,f , . ,r. -yo o ,
Overspray carried more than 50.feet Ap*Sffif:
-/es--no
If "yes", was system immediatbly shut off? yes .no
2/07 Revision:Df]SA-2
PageZ3 of ?5
': *'+rirr. :l!.;.:.S,i,
'..:tti"
,:,i{jr:.,r
.l:l
.1,,6;. fumbihtMorritors See 4n *"1,f
8. Monfliiv Slintes1 1..-:.i:i il :i.:r.:.1.-
tl&iteMesaMill - Stmdard Opaatiqg Froeedrme
Eook I l: Enviloameiotat Protection Mamul, Seotioa 3.t
2/07 Revisiou DUSA-3
Pageli of25
APPENDIX A (AON?.)
oRE sroaaGE/saMPE E PI,ANT wEEKLy EvspECTroN REpoRT
Weeilrof tf lirltp thro@ tlt+)rc Dareoflnspotioo,Xfgil_Lt lell
N.\
krspgctor: (p,1^.e- ll \ .cv c J
Weathq cquditioo$ for tftb weelc
Blowiag &itut eonUitiruu plfiro wo*:
r'ltearcaiiidi m&e
Othercmefrft:
{
B
!i
$
I
t
B
E3
Eg
Location Trans. Shot Base Applied Elevation
Cell 44 5.5 5574.5 5577 Name: Tanner Holliday, Garrin Palmer
lntitial B 5582.5
Date: 413012010
C2W1 3.1 5613.04 5619.0€
czw2 1-22 5613.04 5620.94
c2w3 4.46 5613.04 5617.t
czw4 4.92 5613.04 5617.24
lnitial 9.26 5622.16
L,tt:r+.o 5623.14 5623.8€
281-1N r.1()5623.14 5627.4
2E1"1S 5.78 5623.14 5622.88
2Ei-2S 5.22 s623,14 5623.44
2W7"C Cr.4b 5623.14 5622.2
2W7.N i.18 5623.14 5621.48
2W7 S 8.78 5623.14 5619.88
2W6'l.i 8"2 5623.14 5620.46
2W6.C 10.58 5623.14 5618.08
2W6.S 12.22 5623.14 5616.44
!rritial 5.52 5628.66
2W5-C 4.A2 5613.04 5618.14
2W4.N 3.08 5613.04 5619.08
2W4-S 6.2 5613.04 5615.96
2W5-N 3.46 5613.04 5618.7
2W3-S 5.66 5613.04 5616.5
2W5-S 8.1 5613.04 5614.06
2.84 5615.88
lnitial 4.9 5617.94
3-1N 1 5613.04 5616.94
3-1C 5.16 5613;04 5612.78
3-1S 2.78 5613,04 5615.16
3-2N 4.78 5613.04 5613.1€
3-2C 2.28 5613.04 5613.€
3-2S 3.74 5613.04 5612.14
tocation Trans. Shot Base APPlied Elevation
Cell 44 5-S 5574.5 5574.5 Name: Tanner Holliday, Garrin Palmer
lntitial 86 5574.5
Date: {'3O'1010
c2w1 3. t 5612.77 56't2.77
e.g ,u'll'tt to" Jf,
c2w2 t.l:5612.77 5612.77
c2w3 L4 qA 5612.77 s6'12.77
czw4 Ll-qa 5612.77 5612.77
lnitial 5612.77
CzE Llg 5623.14 5623.14
2E1-1N 26 5623.14 5623.14
281-1S s.1R 5623.14 5623.14
2E1-2S 1. tl 5623.'t4 5623.'14
2W7-C ,4t 5623.14 5623.14
2W7-N 1- l*s623.14 5623.14
2W7-$91q 5623.14 5623.14
2W6.N 9-L 5623.14 5623.14
2W6.C lo.9s,5623.14 5623.14
2W6.S t9,_42 5623.14 5623.14
lnitial 5.st 5623.14
2W5-C Ll.ol 5612.77 5612.77
2W4.N 90R 5612.77 5612.77
2W4.S ,.5612.77 5612.77
2W5-N 3 ,lA 5612.77 5612.77
2W3-S E, LE 5612.77 5612.77
2t*rS-9 ?.t
lnitial {.q 5613.04
3-1N l.o 5613.04 5613.04
3-1C cta 5613.04 5613.04
3-1S tr-11 5613.04 5613.04
3-2N rl.#5613.04 5613.04
3-2C q.t8 5613.04 5613.04
3-2S ?.24 5613.04 5613.04
?r',)fiavL,5 i^ ll'<- 4r^f-bre@'" sh'ts
White Mesa Mill * Standard Operating Procedures
Book l1: Environnrental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Pagel7 of25
APPENDD( A (CONT.)
DAILY INSPECTION DATA
Accompani ed by:TZta oc tbf t l /.4^/
rtme: l33O
Any Item not "OK" must be documented.
Data; Q. 23- lO
A check mark: OK X = Action Required
ilTiATT TI\T'1S GT TTIIIII/'FD AN.sPrlRT SYSTEM
krspectioqltems Conditions of Potential Concem Cell 1 Cell2 Cell3 c!!
4A
SlurrvPipeline T -^t-. rl*o-o Etlnnlrqae Sham BendS ^tlA La
nlaPioeline Joinb r aoLe f nnae (lonnections
ffiport ,l:,,la ,rl
Valves Leaks- Blocked. Closed N,A
Point(s) of Discharge T*-s -6? T nnqfinn nr Orientation ,tlA
II. OPERATIONAL SYSTEMS
Oeater fnan Operating Level, Large Change
S ince Ptevious InsPecti
Eros6n--6f6ov% ExPqsure bf Liner
rII DII(tr"S AND EMRANKMENTS
Inspection Items Conditions of Pbtential Conoern D&
1-I
Dikq l;
1A
Dike 2 Dike 3.Dike 4.{-
S
DtKE
ilopes Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosioru Moist
Areas. Areas of Seepaqe Outbreak
't/4
White Mesa Mill - Standard Operating procedures
Book I l: Environmental protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page l8 of25
V. PHYSICAL INSPECTION OF SLT'RR'Y
LrNES(S)
Walked to Discharge point
Observed Entire Discharge Line ,/ *o.No
Yes
v/ yes
VI. DUST COIYTROL
General Meteorological conditions:
__Wet_gf;y'
'iriitiat lwet r-- *-
'Finallevel €
i
12f,*--_1ory
aULInitial level :-/ -
Final level '/'
-
-w"t-6ry-Initiallevel
-Finallevel -
Gal. oumoed
tzlwa__.lo"t
rnifial tevet-}, I
Final lerrel
FlowMeter2 lo (90
vrtr oBSERVATIONS OF pQTENflAL CONCERN
d"al,{ ,-tco-*iy',te czoj,; l-taa,s -gl;-a;l
p-r^t f vJorV l.o bu do* o'- t;
5+.r+;:> qr**e- a.ou,Ju Ct t r,,1.6 n
CIAll-l r{SPEerI0H BEPOftrtAr r" Ie'65 STUPB? 0'tSEHABGE L06eIlOru
ITATET q]?'lO -"IHsPEeaoRr&
I
N
I
o:".fu,r,i
ndj
r,
c,
I
,l-ccll 5
September 23,2O7O
After the rain event on the 22nd of September, an event in which over !.2" of rain fell, it was observed
that the drainage from the SX building roof is not adequate. The rainfall caused pooling solutions. The
drainage system needs to be addressed by the engineer and have the situation corrected.
!:,("ff
Radiation Safety Officer
White Mesa Mill, 2010 DRC Storm Water Inspection
Ground Water Module 65
Storm Water Managernent
Attachments
Attachment 2 - Copies of Cortifiiation for Tailings Management Systems Daily
InsPections
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual' Section 3' l
3/l 0 Revision: Denison'9
Page 4A of 46
APPENDIX C
CERTIFICATION FORM
o^t",5-l-f,- lO
I have read the document titled "Tailings Management System, white Mesa Mill Tailings
trnspector Training,, *d h"r" received on-site iistruction at the tailings system, This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
fuilurrr, unusual flows), notification procedures and safety'
I certify that the above-named person is quarified to perform the daily inspection of the tailings
system at the White Mesa Mill' :
zu/0
(
Signature
White Mesa Mill - Standard Operating Procedurcs
Book I l: Environmental Protection Manual. Section 3.1
3/l 0 Revision: Denison-9
Page 40 of46
APPENDIX C
CERTIFICATION FORM
o^r", 3 :l*1 '*.rt10
Name:
I have
w pa^r,-
document titled "Tailings Managemenr system, white Mesa Mill Tailings
Inspector Training't and have received on-site instruction at the tailings system. This instruction
included documentation of d{ly tailings inspections, analysis of potentiai problerns (dike
failures, unusual flows), notification procedures and safety.
I certify that the.above-named person is qualified to perform the gaily inspoction of the tailings
system at the White Mesa Mill. rt
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Plotection Manual, Section 3'l
3/10 Revision: Denison-9
Page 40 of 46
APPENDIX C
CERTTFICATION FORM
Date: 3/zq I ,o
Name:n^j,lT,tl+-
I have read thedocument titled'ltailings Management System, White Mesa Mill Tailings
lnspector Training" and have rereived on'site instnrction at the taitings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Signature
White Mesa Mill * Standard Operating Procedures
Book I I : Environrnental Protection Manual, Section 3.1
3/10 Revision: Denison-9
Page 4A of 46
APPENDIX C
CERTIFICATION FORM
I haveread the document titled'"Tailings Management System, White MesaMillTailings
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, unusueil flows), notification procedures and safety.
I certiS that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
put", 3-21-2olo
Safety Personnel/ Tailings System
Whirc Mesa Mill - Standard Opcrating Procedures
ilk f l: Environment'al hotection Manual' Scction 3'2
APPENDIX D
CERTTFICATION TORM
Date: l3-!a^tc1
Name:
I have read the document titled "Tailingrs Management systeg, white Mesa Mill Tailings
rnspector Training, *i r,rr" received oryrit" iirtru"tior, ut the tailings system- This instnrction
included documentation of daily tailings inspections, alalysis of potential problems (dike
i;iG, unusual flows), notification procedures and safety'
I certify that the above-named person is qualified to perform the daily inspection of the '"ni'g',i-t"*",thewhiteMesaMir.
{/ W( -
n"aiuti* Safety PersormeU Tailings System
Supervisor
2107 Revision: DUSA-2
Page 6 of6
(.
White Mesa Mill - Staldard Operating Procedures
Book t l; Environrnental Protection Manual, Section 3.2
2CI7 Revision: DUSA'2
Page6 of6
APPENDIX D
CERUFICATION FORM
Date://-70.-0X
Name: &ot< Skrt; gL.
I have read the document titled'Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-sitc instnrction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
U,{'-t}' i,*
Signahrre
., {
I certify that the above-named person is qualified to perform the daily inspection of thc tailings
system at the white Mesa Mill.
(
White Mesa Mill - Standard Operating hocedures
s;;i i r Environmentdl Protection Manual' Section 3'2
2/07 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTIMCATION FORM
oats, f/-ta'o8
Ihaveread&edocrrmenttitled.,TailingsManagem"Ts]o::PWhiteMesaMillTailings
Inspector Training" *a t.r" received o*rit" ii*t"rction at the tailings system. This instruction
included docu*entatil, oiO"ifV tailings inspectionl, analysis of potential problems (dike
f;i#, unusual flows), notification procedures and safety'
Abry
Signature
Name:
I certify that the above_named person is qualified to p€rforo the da*y inspection of the tailings
systenlat the White Mesa Mill'
Safety
White Mesa Mill - Standard Operating procedures
Book I l: Environmental protection Manual, Section 3.2
207 Revision: DUSA-2
Page 6 of6
I have read the document titled "Tailings Manleement System, White Mesa Mill Taitings
fnsgggr Training" and have received on-site i*n"eion at th; tailings slrstd.
-
mi, instnrctionincldded documentation of daily tailings inspections, analysrs of pot#tiai pro-niems ta1<efailures, unusual flows), notification pro.ua*"r ara,"r"tv. -. rrvurw
APPENDIX D
CERTIFICATION FORM
Date: tolzlzatr
Name: D...-:JT"/t-
I certify that the above,-named person is qualified to perform the daily inspection of the tailingssystem at the White Mesa Mi[.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Scction 3'2
2/07 Revision:DUSA-2
Page 6 of6
APPENDIX D
CERTIF'ICATION TOBT{
Pl3lz^oof
Name: Q* A' .
Ihavereadthedocumenttitled..TailingsManagementSystem,WhiteMesaMillTailings
Inspector Trainingl, and have received on-site instruction at the tailings.system. This instruction
inoiuded documsntation of daity tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I certifu that the above,named person is qualified to perform the daily inspmtion of the tailings
system at the White Mesa Mill.
Radiation Safety PersonneU Tailings System
White Mesa Mill - Standard Operating procedures
Book I l: Environmental protection Manual, Section 3.2
2/07 Revision: DUSA-2
page 6 of6
APPENDD( D
CERTIT'ICATION FORM
Date: tpl ifzaoY
Narne: Annnr, l{,tl i,o'*.
I have read the doorme,nl titled "Tailings Management system, white Mesa Mill Tailings
fnlpagtorJralning" and have receivod on-site inshuctionat the tailings rvJ.* rnis instructionincluded documentation of daily lailings mfnectiong, ";tri. ;rp"iJi}-iiiiiems (dikefailures, unusual flows), notification pioceaures and safety. 's t'rvvrv .
I c€rtiry that the above-named person is qualified to perform the daily inspection of the tailingssystem at the WhiteMesa Mill.
White Mesa Mill - Standard Operating Procedures
S";k r l: Environmental hotection Manual' Scction 3'2
210? Revision: DUSA'2
Page 6 of6
APPENDIX D
CERTII|ICATION FORM
o*, (o f */08
I have read the document titled'Tailings Management System, white Mesa Mill Tailings
Inspector rraining" ffi&;i"d ;":Ja try*"*::: *:gg1:l^i:*' "*t;
jp;ruction
il:f,ffiJffi'#"i#;; "i'a",ry
*riigs inspections, anallnis of potential problems (dike
i;i;, unusual flows), notification procedures and safety'
I certify that the above-named person is qualified to Perforrn the daily inspection of the tailings
system at the white Mesa Mill. -- n
{lt(
[ffi"ti* Safety PersonneU Tailinp System
t
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2r0? Revision: DUSA-2
Page 6 of6 .
APPENDTI( D
CERTTIICATION FORM
oae: /Dr/'zg/o{
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 insUuction
included docurnentation of daily tailings inspections, analpis of potential problcms (dike
failures, unusual flows), notification procedures and safety.
I certify that thc above-named pcrson is qualified to perform the daily inspection of the tuiirrg,
system at the WhiteMesaMilt. /l
ntu{
Radt"ti"r S"f"ty P
Supervisor
t
Whie Mesa Mill - Standard Operating Procedures
S;f f l: Environrnental ProtectionManual' Scction 3'2
2/07 Revision: DUSA-2
Page 6 of6
APPENI}IX D
CERTITICATION TORM
a^t*, l0-*-(4{
Name: {,;, A. Ll
I have read the document titled "Tailings Management Systel, White Mesa Mill Tailings
Inspector Training,, *i nu"" received on-site iisuuaionat rlr" hitings systern. This instruction
incruded documentatioi oi a"iry tailings inspections, analysis of potential problems (dike
i;ilr*t: unusual flows), notification proceduras and safety'
I certify ttrafthe above-na,ed person is qualified to pcrform t]re daily inspection of the Oi**
sysrcm at the Wbite Mesa Mill'4,{/
Radiation Safety PersonneU Tailings System
Supervisor
{
o
White Mesa Mill, 2010 DRC Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 3 - Photo Pages
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 1 of16
Photo 1 --loCrt"d at the south-east corner of the tailings padWir,'''
Photo 2 -- Drainage Berm on the eastern side of.thg-tailh storage pad
Photo3_NewD"coffitethatthecontainmenthasbeendrainedand
:!t*:: *
the concrete seams have been coated with black sealer
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct' 19,2010)
Photo Pages
Page 2 of 76
Photo 5 - Small scale house' sPill
Photo+- albottom
photo o - u."affi at the Equipment Maintenance Area
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 3 of 16
Photo8_AreaAm(Noteo1ddecontaminationpadinbackground)'
photo 7 - Drain inside of Vehicle Maintenance Area, Subject of 2009 comment,
recommended that DUSA remove this drain
photo g - Total Contuin *rt So*ps outside oithe vehicle maintenance area, consists of
3 baffled concrete containments
Area has been regarded to control runoffinto the Vanadium Pregnant Liquor (VPL) Area
Denison Mines White Mesa Uranium MiIl
2010 DRC Storm Water lnspection (Oct. 19,2010)
Photo Pages
Page 4 of 16
Photo 9 - Drainage from area in photo 8 to discharge into the containment area (left of
r2)
Photo 10 - Area between the VPL tanks which previously had standing water from
condensate
Photo l1 - Condensate from VPL tanks piped to storm drain (steam area in background)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 5 of 16
Photo 12 -YPL condensate draining to storm drain, also note pipe entering drain (photo
right), this is from regional drgigage {gyg-qtlgln! tanks
Photo 13 - Ammonia T note soil berm and soil containment floor
Photo 14 - Kerosene Tanks, note soil containment
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19,2010)
Photo Pages
Page 6 of 16
photo 16 -- Collection vaulafrom the old decontamination pad, note that the vault is fulI
photo tS -- Sodium chlorate t'dnki and secondary containment, note wash down area left
oftanks on concrete pad
of sediment and needs to be cleaned out
Photo 17 - Vanadium intermediate product stored in drums south of the old
decontamination pad (visible in background)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19, 2010)
Photo Pages
Page 7 of 16
Photo 20 --
leakage from
Photo 19 - Fresh water tank, DRC noted that the tank yq!ry_yiras leaking
Area below the fresh water tank drains to Roberts Pond, DRC noted that
the fresh water tank was draining across bare ground to the discharge pipe
o
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct' i9, 2010)
Photo Pages
Page 8 of 16
photo 2l - Nm tank, standing water in area is from
ent of a monitoring well (white casi
Plrotr 2r- New berm around sulfuric qqid t!gq!
photo 23 - m" areaeast of the sulfuric acid tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19,2010)
Photo Pages
Page 9 of 16
Photo 24 - Consrete area east side of the sulfuric acid tank
Photo 25 -Di drains to Roberts Pond
Photo 26 - Roberts Pond, note that vegetation has been removed from perimeter
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19,2010)
Photo Pages
Page 10 of 16
Photo27_Disch*@inio-RobertsPond,DRCnotedthatthesourceof
this water was from washdown of the Leach House (see 28)
photo 28 - Washao*n *uto ton tfr" Leach House across bare ground (discharging into
Roberts Pond
Photo Zq - Caustic Soda secondary containment still badly deteriorated
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 11 of16
Photo 30 --"ont"inr"ent for caustic soda badly deteriorated, not functional
photo f t - Roof drainage ar"a from SX building, DRC noted that improvement needed in
this area
Photo 32 - Area south of SX building slated for drainage improvements
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19,2010)
Photo Pages
Page 12 of 76
Photo 33 -AitematsFeed Circuit Area, note that the concrete is lightly deteriorated
Photo 34 --Alternate Feed Circuit area holdi return tank
inside of curbed berm
Photo 35 --Alternate Feed containment drainage sump, pumped back into holding tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19, 2010)
Photo Pages
Page 13 of 16
Photo 36 -- Alterate Feed stagingarea,note that 7 drums are in area, onsite staff
in drums
reported that all drqaqfryoulq !g
Photo 37 -- Another view of alternate feed
Photo 38 -- Close up view of perforated drum
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct' 19,2010)
Photo Pages
Page 14 of 16
Photo 41 -- Area of northeast berm of cell 2, south of the mill processing area, onsite
DUSA staffstated that drainage had been improved in this area
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct' 19,2010)
Photo Pages
Page 15 of 16
Photo 42 -Dirrerr ng excessive vegetation growth in the
Photo43--Dim-e1l1)showingril1ingonbanksandheavy
bottom of the ditch
photo 44 - me cell 1), slumping (photo middle left)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19, 2010)
Photo Pages
Page 16 of 16
Photo 45 - Diversion Ditch 2,
Photo 46 -- U area northeast of mill
Photo 47 -- Upla"d *ea *ithLawry Lake Depression in the mid-ground
oWhite Mesa Mill
Ground Water Module 65
Storm Water Management
Page I of 22
Utah Division of Radiation Control (DRC)
Ground Water Module 65
Denison Mines, White Mesa Uranium Mill
DRC Annual Storm Water Inspection
Ground Water Permit UGW370004
Inspection Year: 2010
Inspection Date: October 19,2010
Module Reviewers Names/Initials:
Phil Goble, Compliance Section Manager ; iZtg
Loren Mofton, Environmental Program Manger
Module Prepared by:
Tom Rushing, P.G., Compliance Section "JtL * lzl/ tr
g/'>/z " t t
DRC Staff Present: Tom Rushing, P.G., Compliance Section
Denison Mines Staff Present: David Turk. White Mesa Uranium Mill RSO
Denison Mines Staff Interviewed: David Turk, White Mesa Uranium Mill RSO
Currently Approved Storm Water Best Management Practices PIan (SWBMPP) for the White
Mesa Uranium Mill:
Date: June, 2008
Revision No.: 1.3
Violations Identified in Last (2009) Inspection: (list) None
Requests for Information Per Previous (2009) Inspection:
Two requests for information were issued to DUSA per the 2009 storm water inspection which
resulted in a DRC letter dated December 12,2009, summarized below for ease of reference;
l. DRC noted that the SPCC Plan requires tank to soil potential measurements. It was unclear
whether this item was being undertaken. Please provide information to clarify the intent of
these measurements and whether or not the measurements are currently conducted.
Denison Resuonse:
Llpon revie w of the SPCC Plan Denisorl lrotes that tank to soil por.ential measurernsrrts are
referred to at Section l.l0 of the Plan within the context of a record that would be maintained
should such nreasurcrnents actually becomc rreccssary. Soil to tank potenlial mea.surenrents are
utilized to tesl cathodic protection systcills for underground tanks and piping. Dcrrisu: docs not
currently employ cathodic protectitxr systems and. therefore, such testing is not required at this
time. However, if in the luture such systems werc to be utilized these records would be retaincd
in accordance with Section i.l0 of tlre SPCC Pliur.
F,rrm []rrdated Dccember 14. 2010
White Mesa Mill O
Ground Water Module 65
Storm Water Management
Page 2 of 22
2. Please clarify the protocols to determine whether used oil generated at the White Mesa
facility is determined contaminated (i.e. 11e.(2) byproduct material) and disposed of in the
tailings cell, or determined uncontaminated (or not 11e.(2) byproduct material) and sent
offsite for recycling.
l)enison Response:
Used oil at the Wtrite Mesa Mill that has the potential for having been eontaminatcd by
radioactive material (such as that which may be generated by cleaning of machinery in the shop
and receivcd hy the floor drain and conveyed to the used oil tank) is disposed onsite in the Mill
tailings inrpoundrrent. Oils that arc internal to plant rnachinery {such as velricle engines) are not
sub.iect to contarnination poteutial and can be drained for off.sitc recycling. Clurrently, the oil that
is retained in the used oil tank has received floor drain materials from the shop and is to be
tlisposetN in thc tailings inrpounclment as I lc"{2) byproduct inaterial.
An additional RFI will be included per DRC review of the response concerning cathodic protection
(item l) as detailed per the 2010 inspection findings and per the RFI issues outlined in the conclusion
at the end of this memo. Specifically, DRC is concerned that although no underground tanks are
emplaced at the White Mesa Mill, there are on-grade tank installation where the bottom of the tank is
in intimate contact with soil.
Summary of Recommendations Made to DUSA Resardins Previous (2009) Inspection Findinss
(December 12.2009 DRC Letter):
October 2009 Recommendations:
Recommended Actions:
Recommendations related to Storm Water Documentation at the Mill
o Part 4. 1.4 of the Storm Water Best Management Practices Plan requires a weekly inspection
of diversion ditches, drainage channels and surface water control structures in and around the
mill area. Per DRC findings the White Mesa Standard Operating Procedures, Book 11,
Environmental Protection Manual, Section 3.1 includes forms for Daily Inspections, Weekly
tailings Inspections, and Monthly Inspections. DRC noted that the diversion Ditches and
Berms are included on the Monthly inspection form (not weekly as included as Part 4.1.4. of
the SWBMPP). DRC recommends that Denison insure that all documented inspections
match the frequencies specified in the SWBMPP (including appendices).. Similar to the recommendation above, DRC noted that the SPCC Plan Part l.l0 refers to a
Quarterly Tailings Inspection. DRC noted that the Tailings Inspections are likely done on a
shorter time schedule (daily inspections) and that a Quarterly Inspection Data form did not
appear to exist. DRC again recommends that all documented inspections match the
frequencies specified in the SWBMPP.. SPCC Plan Part 1.9.2 - It was reported onsite that no "reportable quantity" spills had
occurred at the facility over the period of records reviewed (RQ's from 40CFRl17). DRC
noted that there was not a process to document smaller spills, less than reportable quantities.
DRC recommends that a process be developed for employee reporting and documentation of
smaller quantity spills and clean up actions to be included in the SWBMPP/SPCC and that a
log or other documentation is generated to clarify clean-up actions. Section 4.2.1 of the
SWBMPP refers generally to this requirement; the Ground Water Permit (Part I.D.l0) also
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 3 of 22
requires the control of contaminant spills and immediate clean-up upon discovery (regardless
of quantity). DRC is only recommending this measure at this time.. SPCC Plan 1.10 - It was noted that the daily, weekly and monthly inspection data reports do
not include a field for follow up actions. DRC recommends that follow up actions, and dates
of completion, relating to any problems noted during the inspection be logged on the same
inspection data form.
Site Walkthrough Recommendations (Previous 2009 Inspection)
During the site walkthrough of the shop area, DRC noted that a floor drain is located inside of
the vehicle maintenance area which drains to an outdoor storage tank (See photo log, photo
4). It was reported by Denison that any oil contaminated water in these tanks is pumped to
the used oil tank and that uncontaminated water is pumped to Roberts pond. DRC noted that
the current process creates a larger quantity of contaminated water (commingling of process
water and storm water) and recommends that the indoor drain be blocked and that any indoor
spills be cleaned up at the spill location.
DRC noted that the SX building roof is currently routed into the concrete containment vault
inside of the building. DRC recommends that the roof drains be inspected, and the results
documented, during a storrn event to insure that the runoff is effectively drained to that point
and is not contributing to any ponding of stormwater in the area of processing
DRC noted that the secondary containment for the caustic soda tank was highly deteriorated.
DRC recommends that the secondary containment floor for the caustic soda tank be repaired
or replaced. (See photo log, photos 27,28 and 30)
DRC noted that the secondary containment for the soda ash tanks showed cracking on the
floor (See photo log, photos 33 and 34). DRC recommends that the cracks be
sealed/repaired.
Alternate Feed staging is currently conducted on the south side ofthe processing area on the
soil without berms or containment. (note that Denison made no comment regarcling this issue
and provided no action to resolve the recommended actions by DRC) DRC noted that one of
the drums which had been removed from its overpack was badly corroded and that alternate
feed material (black flake) was visible through a hole in the top of the barrel (see photos).
DRC also noted that a trace amount of the black flake was visible on the ground at the base
of the drum. Although the storage during staging is not curently a violation of the ground
water permit, please be advised that Part I.D.11 of the revised permit will include BAT
requirements for feedstock material storage. It is recommended that the barrels be kept in the
overpack until ready to be loaded onto the alternate feed rack within the containment area or
other alternative method at the discretion of Denison. (**note that these staging practices
became a ground water permit violation per a l/10/2010 permit modification of Part I.D.1l. This is
discussed in more detail in comm.ents/observations related to the alternate feed circuit below)
DRC noted that when water from the decontamination pad tanks is transferred to the concrete
vault (flushed from the recycle tanks) it is allowed to discharge across open ground. DRC
recommends that piping from the decontamination tanks be extended to the concrete vault to
avoid potential erosion impacts and/or infiltration concerns (see photos).
October, 2010 Inspection (Current), DRC Staff Findings:
Section I - Document Review
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 4 of 22
SWBMPP (Documentation Requirements):
Part 4.1.4. -- Diversion ditches, drainage channels and surface water control structures in and
around the Mitl area will be inspected at least weekly. Areas requiring maintenance or repair,
such as excessive vegetative growth channel erosion or pooling of surface water runoff, will be
reported to appropriate departments and all follow up actions are to be documented.
Findings:
Diversion Ditch I showed excessive vegetation growth as well as evidence of rilling and erosion on
the side banks (See Attached Photos 42,43,44). DRC communicated these issues during the
inspection and onsite personnel reported that they would provide remediation of the banks
immediately.
In response to this issue DRC received an e-mail from DUSA (from Dave Turk) on l0ll9l20l0 (same
day of the inspection) which notifies DRC that the diversion ditches were cleaned of vegetation (via
grading) and provides 3 photos (below):
3 Photos - Attached to DUSA e-mail to DRC dated 10/19/2010 showing Diversion Ditch
Maintenance
Diversion Ditch 2 was in reasonable conditions (Attached Photo 45). DRC noted minor
amounts of vegetation in the ditch.
Fornr Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 5 of 22
Per DRC review of the DUSA Inspection Forms, it was noted that the Diversion Ditches and
Berms are inspected monthly (note that Part 4.1.4 of the SWBMPP requires that these
inspections be done at least weekly). Per review of the forms, DRC did not find any
observations by DUSA regarding the excessive vegetation in Diversion Ditch 1 (contrary to
DRC observations during the October 19,2010 inspection). The DRC staff recommend that
these issus be included in a Confirmatory Action letter to DUSA, citing violations of the
Permit Part I.D.10(a) and the SWBMPP Part 4.l.4for:
1. Failing to provide inspections of the diversion ditches weekly, and,
2. Failing to clean the diversion ditches of excess vegataion which is a failure to
provide active operation measures.
As per above discussion above, DRC comments during the 2009 inspection (December 12,
2009 Recommendations) it was noted in a letter as a recommended action that the inspection
of diversion ditches be conducted and documented weekly as required by the SWBMPP.
However, this item was not responded to or addressed and it appears that the monthly reports
were made without a physical examination of the ditches (inspection findings were
documented but no inspection was completed).
Spill Prevention, Control, and Countermeasures Plan (SPCC) (Documentation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings:
Per DRC review of the forms it was noted that the inspection of the propane tanks is included
on the daily foreman's inspection forms, however this is only a checklist and does not require
specific items to be checked or specifically include the petroleum tanks, or their individual
condition. The same comment was made per the 2009 inspection, See the; "December 10,
2009, Ground Water Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo, page 3" as well as the "December 12,2009
DRC Findings Letter, page 2."
"DRC noted that the fuel area is included on the "Operating Foreman's Daily Inspection"
form, however the form does not specifically refer to the petroleum tanks within the confines
of the facility, or indicate how thorough of an inspection is conducted."
During the October,2010 inspection, DRC staff also noted that there was a small volume
diesel spill on the refueling pad duing the inspection (Attached Photo 5). No evidence was
found during the inspection that DUSA cleaned this spill up.
1.9.1. - External Notification of "reportable quantity" spills.
Findings: During the October,20lO inspection, the facility representative stated that there
have been no repoftable quantity spills (as per the Community Right to Know Act, EPCRA)
Form tJpdated December 14.2Ol0
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 6 of 22
at the facility. DRC confirmed that over the period since the last inspection no reportable
quantity spills (> 1 00 kg) were documented. Further, DRC review of DUSA records found
no spills of any size were recorded on any of the self-inspection documents.
1.9.2. Internal Notification of incidents, spills, and significant spills.
Performance Standards (list):
Findings: Per the 2009 observation concerning the reporting of smaller quantity spills, the
following observation was made (December 12,2009 DRC letter, page 2): "DRC noted that
there is not a process to report small quantity spills at the site. DRC recommended that a
process be instituted to insure that employees know who to contact regarding small quantity
spill and follow through with a process of clean-up."
DRC notes that the Groundwater Discharge Permit Part I.D.lO(c) requires DUSA to
"Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery" and that the Permit part LD.10(d) requires DUSA to "report reagent spills or
other releases at the mill site to the Executive Secretary in Accordance with Utah
Administrative Code (UAC) 19-5-114." UAC 19-5-114 states that"Any personwho spills or
discharges any oil or other substance which may cause the pollution of the waters of the state
shall immediately notifu the Executive Secretary of the spill or discharge, any containment
procedures undertaken, and a proposed procedure for cleanup and disposal, in accordance
with rules of the board-" While DRC agrees that small quantity spill would likely not pose a
threat to waters of the State if cleaned up appropriately, the Administrative Code and Permit
requirements do not state a minimum quantity of substance spilled requiring notification
from the company. Per the 2009 recommendation, DRC is allowing the reporting for small
quantity spills (Less than the quantity required to be reported under the Emergency Planning
Community Right to Know Act Reporting Requirements(Clean Water Act Section 311 and
Code of Federal Regulations Title 40 Part 117) to be an inhouse process of documentation
which can be reviewed by the Executive Secretary during the annual storm water inspection.
Per these findings, the 2009 module included a "recommendation" to institute a process for
employee reporting and documentation of small quantity and clean up actions (December 12,
2009 DRC letter, page 2).
Per the 2010 inspection it was noted that the 2009 recommendation was not addressed by
DUSA, and per interview with the onsite representatives it appeared that creating such a
process was not being considered. Failure to institute the spill reporting process is in
violation of the groundwater permit parts LD10(c) and (d) as well as UAC 19-5-114. It is
therefore recommended that this item be included for follow up as a request for information
item to insure that information regarding process needs and a schedule of implementation for
reporting and documentation of clean up of oil and reagent spills. Failure to provide such a
process is not in conformance with the SWBMPP Part 4.2.1.
Form Updated December 14,2OlO
White Mesa Mill
Ground Water Module 65
Storm Water Management
PageT of 22
1.10 Records and Reports.
Period of Records Examined During Inspection:
B e gin/End ing: 4 I I I 20 l0 I 4 I 30 I ZO l0 an d dally 9 I 23 I 20 l0
No. of On-site Records Required: Daily, Weekly and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: lOTo (Percent of Total)
How Selected: DRC Inspected a full month of daily, weekly and monthly forms as
well as the daily (9/23110) form which included a visual inspection
of the SX building roof runoff.
Daily Tailings Inspection Data:
Findings: Daily inspection of tailings slurry transport system, operational systems (water
level, beach, liner and cover), dikes and embankments, physical inspection of the slurry lines,
dust control and leak detection was implemented and documented on an inspection form.
See attachment I (Daily Inspection Form). DRC reviewed all of the forms for the month of
April (April l, 2010 through April 30, 2010). This month was picked at random. DRC also
reviewed the daily inspection form for 912312010, this report was chosen since includes an
addendum with observations, post rain event, of the SX building roof drainage. DRC noted
that each quafter of reports was organized in a separate hard copy file. All of the reports
(daily, weekly, monthly) were on file for the reviewed month (April, 2010). DRC did note
that there was no quarterly report and it was reported by DUSA staff that inspections
required quarterly were included on reports at a higher frequency. The DUSA onsite
representative (David Turk) indicated that the higher frequency would be more protective of
the environment and should be allowed as an improvement to the inspection process. DRC
advised DUSA that a more frequent inspection was likely more protective, but that the storm
water best management practices plan needed to be updated to reflect the current inspection
process and frequencies in order to avoid confusion.
Per the 2009 storm water inspection, DRC noted that follow up actions (resolution of noted
problems) were not documented on the actual daily form (December 12,2009 DRC letter).
DRC recommended that the follow up be documented on the daily form. The issue of
follow-up actions and date of completion of follow up being documented on the same
inspection form (as the one where the problem was identified) was discussed with David
Turk during the October,20lO inspection. He agreed that this process could be improved
and agreed to modify the inspection form to include a section for follow up actions needed
and dates ol completion.
Per follow up of this item during the 2010 inspection it was found that the inspection forms
have not been modified to include date/time of follow up actions on the same form, therefore,
it is still necessary to look at additional forms (following forms) to determine if follow up
actions were taken.
DRC will include the issue of follow up actions for daily inspections as well as updating the
SWBMPP to accurately reflect the inspection frequencies as a "Request for Information"
Folm Updated December 14.2Ol0
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 8 of 22
item since these issues are not specific violations of Rule, Permit or Plan. DRC recognizes
that the company has different options in terms of how to better track deficiencies noted
during an inspection. The issue may be addressed on the current inspection forms, or DUSA
may opt to initiate a separated tracking system (e.g. a monthly non-compliance report) to
document inspection deficiencies and follow-up actions.
Weekly Tailings Inspections and Survey:
Findings: The weekly tailings inspection was done and documented on a weekly tailings
inspection form. The form includes sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for cell l, 3, 4,{ and
Roberts Pond, as well as slimes drain liquid levels in cell 2. The form also includes
information regarding the leak detection systems for cells 1,2, and 3 and 4,{ as well as
potential blowing of tailings. The form, as part of the Standard Operating Procedures, also
includes sections for repoftrng parameters about the Leak Detection Systems (part of the
DMT plan requirements, not storm water related). Per the 2009 inspection, DRC had no
comments regarding the weekly tailings inspection (see December 12,2009 DRC letter). Per
this 2010 inspection, the weekly form still meets the required frequency, and appears to
include required information. However, per in-house discussions amongst DRC staff, it was
noted that in order to avoid confusion it may be preferable to organize inspection protocols
for storm water requirements separate form engineering related topics. This topic will be
reviewed again during the 2011 storm water inspection, and options regarding the forms will
be discussed with onsite DUSA representatives.
Monthly Tailings Inspection, Pipeline Thickness:
Findings: The monthly inspection report includes a summary of the slurry pipeline condition
and measurement of pipe thickness during 2010. Per the 2009 inspection (December 10,
2009, Ground Water Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo, page 4), it was noted that the March 21,2009
monthly report did not include a measurement of pipe thickness due to the mill being in non-
operational status.
The monthly report additionally contains inspection protocols and observations related to the
diversion ditches and berms, sedimentation pond, dust control, settlement monitors and
slimes drain static head measurements for cell 2. Per above (weekly form comments) DRC
will require that follow up actions regarding any findings or maintenance needs be included
on the same inspection form or per an alternative method such as the use of an internal non-
compliance report which could by developed by DUSA. Per above, this issue will be
included as a "Request for Information" item.
Quarterly Tailings Inspection:
Findings: During the October,2010 inspection, DRC staff noted that there is not a Quafierly
inspection form. It appears that all inspections required on a quarterly inspection frequency
are conducted at other (shorter) frequencies and are recorded on alternate forms. Per
Form Updated December 14,20lO
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 9 of 22
discussion above in the daily inspection RFI section, these are not specific violations of Rule
or the Groundwater permit, however, the DUSA facility SWBMPP does need to be kept
current, thus, this item will be included in an RFI letter to the facility.
Tank to soil potential measurements:
Findings: This item was included as a request for information to the facility on the 2009
Findings and RFI T etter, the response from DUSA is below:
Denison Kesro-fse:
Upon revieu of the SPC(I Plan Dcnison note$ that tank [o soit potential mcflsurcrrrents ore
referred trr *t Section l. l0 crf the Plan within the context * a rer:tlrd thar wuuld be maintained
should sueh nre{sutrnreflls *ctually Lrecome necessary. Soil to tank potentia} fireilsurements iltc
utilized to test cathodic protecti*rr $ysterns krr underground lardt.c and piping. Denison does nnt
currenlly employ cathodic protec(ion liyste ms arrcl. therel'or*. su*h tcstirg is nut rcquircd at this
time. llowevcr" if in the future such systerrs lryrrf; to be utilizcd these rec*rds ra'ould be retaincd
in accurdance with liection l.lt) of the SPCC Plan.
DRC notes that although DUSA states that no underground storage tanks are currently
emplaced at the White Mesa Mill, there are several tanks which are sitting on the ground and
can not be visually inspected (On Grade Tanks). DRC will therefore request additional
information from DUSA regarding their current inspection protocols for on-grade tanks.
Cathodic protection is needed for DUSA to comply with Part I.D.10(a) of the groundwater
permit (to insure integrity of the bottoms of tanks which are installed on-grade).
Annual bulk oil and fuel tank visual inspections:
Findings: Per the DRC 2009 inspection review comments (December 10, 2009, Ground
Water Module 65 Inspection, Storm Water Best Management Practices Plan (SWBMPP)
Inspection, DRC Review Memo)'. tank condition is not specifically checked by the mill. DRC
did note that a general inspection ofthe tank area is conducted (listed as fuel area) and
documented on the operating foreman's daily inspection log, however, this does not
comprehensively address the conditions of each tank at the facility. DRC also noted that
daily volume measurements are recorded for the fuel tanks, but, again, the tank condition is
not taken into account. These omissions on DUSA inspection repofis were noted to be the
same per the 2010 inspection. Per DRC review of the facility Groundwater Permit and
SWBMP it was noted that there is not requirement for DUSA to inspect and document the
condition of these tanks. It is recommended that inspections to visually inspect the integrity
of each of these tanks be included in the permit at atleast an annual frequency (Item to be
included in a Ground Water Permit Modification).
DRC noted that the diesel storage tanks located on the north side of the mill building (2
tanks, 250 gallons each) do not have secondary containment systems. The unleaded gasoline
tank does include a 3,000 gallon secondary containment structure which is the same volume
as the tank. Diesel tanks at the pump station include secondary containment for the volume
of 1 tank (2 tanks located inside of the containment). DRC will insure that potential issues
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
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Page l0 of 22
regarding these tanks are addressed with the SPCC review "Request for Information" as
described below.
Tank and pipeline thickness tests:
Findings: Per DRC review the only thickness test noted was the slurry pipeline thickness and
this is only taken during times when the Mill is operating. No issues were noted during the
inspection regarding thi s requirement.
Quarterly and annual PCB transformer inspections (currently PCB only):
Findings: Per the 2009 inspection, the facility reported that there are currently no PCB
transformers at the site. DRC discussed that the SPCC rule, 40CFRl12 has been updated to
include non-PCB oil types. Denison agreed to review the new language and update the
SPCC plan as appropriate. Per the 2010 follow up, it does not appear that the SPCC plan has
been re-evaluated per the 2009 recommendation (December L2,2009 DRC Letter). DRC
will include this issue as a request for information item, to ensure that all inspections are
consistent with the current SPCC regulations. Also, DRC will request information regarding
the current inventory of petroleum stored at the mill to insure that all oil types and tank
quantities, secondary containment (tank descriptions) included on the mill inventory Iist are
consistent with current SPCC requirements.
Tank supports and foundation inspections:
Findings: The operating foremans daily inspection provides a general inspection of the Fuel
Area, but does not provide a specific inspection of tank supports and foundation. This item is
also covered in the tank condition inspection section above. DRC noted that the inspection
frequency is not noted, it was interpreted that this inspection relates to a visual inspection of
the integrity of tank supports only and is likely conducted with the tanks condition report.
DRC will follow up with this item during the 20ll storm water inspection. Specifically,
DRC will insure that tank supports and foundations are inspected and documented with the
tank condition reports.
Spill Incident Reports:
Findings: No spill reports/incident reports were filled out on any of the DUSA inspection
forms examined during the October,2010 inspection. Denison representative reported that
there have been no spills. Per comments above, DRC will include a "Request for
Information" to insure that small volume (smaller than reportable quantity spills) and follow
up (clean up) and documentation protocols associated with the spills is implemented.
Latest revision of SPCC plan (onsite and available?):
Findings: The current SPCC plan (dated June, 2008) was onsite and avarlable during the
inspection.
Form Llpdated f)ecember 14,2010
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Page 1l of22
L.LL Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
DRC reviewed the log of people who have been trained to conduct the daily inspections at
the White Mesa facility as below
Period of Records Examined:
Begin: October 23,20O9
Ending: October 19,2010
No. of Records Found: 13
No of Records Examined: 13 (100 Percent of Total)
How Selected: Comprehensive Review of this Training
Findings: DRC found that specific to 2010,4 people had been trained including those
conducting current daily inspections at the site. The Radiation Safety Personnel also signed
the forms certifying the trainee as qualified to conduct the daily inspections.
Regulatory Requirements (Ground Water PermitUGW370004, Utah Administrative Code
(UAC) and Utah Code Annotated (UCA)
This section quotes the White Mesa Ground Water Quality Permit and SWBMPP to clarify
issues of non-compliance and/or nonconformance with the requirements.
In the Ground Water Permit:
The ground water permit Part I.D.l0 requires provisions in the facility SWMPP to: 1. Protect
groundwater quality or other waters by design, construction, and/or active operational
measures that meet the requirements of Ground Water Quality Protection Regulations (UAC
R317-6-6.3(G) and R317 -6-6-4(C),2.Prevent, control and contain spills of reagents and
chemicals, 3. Clean up spills of reagents or chemicals immediately upon discovery.
UAC R3l7-6-6.3(G) states "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,
including the applicable surface water quality standards, that the discharge is compatible
with the receiving ground water, and that the discharge will comply with the applicable class
TDS limits, ground water quality standards, class protection levels or an alternate
concentration limit proposed by the facility."
R3l7-6-6.4(C) states "The Executive Secretary may issue a groundwater discharge permit
for an existing facility provided:
l. the applicant demonstrates that the applicable class TDS limits, ground water quality
standards and protection levels wiLl be met;
2. the monitoring plan, sampling and reporting requirements are adequate to determine
c ompliance with applicable requirement s ;
Form Updated December 14,20lO
White Mesa Mill
Ground Water Mbdule 65
Storm Water Managemenl
Page 12 of 22
3. 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 similctr production process technology; and,
4. there is no current or anticipated impairment o.f present and future beneficial uses of the
ground water."
UAC R317-6-6.3(G)and R317-6-6.4 refer to requirements for ground water permit
applications and require that any discharges will be consistent with ground water class limits,
appropriate discharge minimization technology is in place etc.
(UCA) 19-5-114 requires that a person who spills any substance which may cause pollution
of waters of the State (includes groundwaters) is required to "immediately notify the
executive secretary of the spill or discharge, any containment procedures undertaken, and a
proposed procedure for cleanup and disposal, in accordance with rules of the" water quality
board.
The following quotations are from the White Mesa Stormwater Best Management Practices
Plan (pp. 4 - 7). These quotation refer specifically to best management practices that have
been approved by the Co-Executive Secretary to be followed by DUSA.
Best Management Practices Plan (June 2008), List of General Best Management Practices
(Performance Standards) applicable to all areas and specffic areas of the site (Section 4.0 of
the SWBMPP) as listed below
All Areas:
r
"" ":' "!:::rlrll::il'J:?L :iJ;x'j Jl'l ;:l#l"ilTiff Jffi l upp.op.i u,"
containers. Label the containers. Keep the containers covered when not in use.2*":'"i"f
i'i]':x,jilffiJ:T,'il:lJ#[*'i":,ffi luroing.orundercovered
areas. Replace or repair broken dumpsters and bins. Keep dumpster lids and large container covers closed when not in use (to
keep precipitation out r3 "*: n"l;lffi :i::T,:::1U:i"il1'HT:,',"r:'S:, debris in the so,id waste
dumpsters or tailings area as appropriate
4. Inspection and maintenance of diversion ditches and drainage channels within the
process
f,iJffflT;:?T':iffi"ge channers and surrace water contror srructures in
and around the Mill area will be inspected at least weekly in accordance with
the regularly scheduled inspections required by Groundwater Discharge
Permit No. UGW370004 rnd Byproduct Materials License #UT1900479.
Areas requiring maintenance or repair, such as excessive vegetative growth,
Form Updated December 14,2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 13 of 22
channel erosion or pooling of surface waterrunoff, will be reported to the 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 ifnecessarys' Recvcle fluids;Ttr;::5,""'iJllio.no,,""
fluids, sorvents and cleaners that can be
recycled or reclaimed
When possible, select consumable materials from suppliers who will reclaim
empty containers
Process and Laboratory Areas:
Clean Up Spills Properly. Clean up spills with dry cleanup methods (absorbents, sweeping, collection
drums) instead of water whenever possibleo Clean spills of stored reagents or other chemicals immediately after
discoveryo Recover and re-use spilled material whenever possible. Keep supplies of rags, sorbent materials (such as cat litter), spill collection
drums, and personnel protective equipment (PPE) near the areas where they
may be needed for spill response.o If spills must be washed down, use the minimum amount of water needed for
effective cleanup
Protect Materials Stored Outdoorso If drummed feeds or products must be stored outdoors, store them in covered
or diked areas when possible
o If drummed chemicals must be stored outdoors, store them in covered or
diked areas when possible
o 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.
Water Managemento When possible, recycle and reuse water from flushing and pressure testing
equipmento When possible, wipe down the outsides of containers instead of rinsing them
off in the sinko When possible, wipe down counters and work surfaces instead of hosing or
rinsing them off to sinks and drains
Materials Managemento Purchase and inventory the smallest affiount of laboratory reagent necessaryo Do not stock more of a reagent than will be used up before its expiration dateo 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.
M ai n teno nc e Activitie s :
I Keep a Clean Dry Shopr Sweep or vacuum shop floors regularly
Ftrrnr Lrpciated December 14, 20lO
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 14 of 22
. Designate specific areas indoors for parts cleaning, and use cleaners and solvents
only in those areas. Clean up spills promptly
. Keep supplies of rags, collection containers and sorbent material near each work
area where they are neededo Store bulk fluids, waste fluids and batteries in an area with secondary
containment to capture leakage and contain spills2 Manage Vehicle Fluidso Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon
as possibleo Promptly contain and transfer drained fluids to appropriate storage area for reuse,
recycle or disposalo Recycle automotive fluids, if possible when their useful life is finished
3 Use Controls During Paint Removal
o Use drop cloths and sheeting to prevent windborne contamination from paint
chips and sandblasting dusto 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 activities4 Use Controls During Paint Application and Cleanupo Mix and use the right amount of paint for the job. Use up one container before
opening a second oner Recycle or reuse leftover paint whenever possibleo 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 systemo Paint out brushes to the extent possible before water washing (water-based paint)
or solvent iinsing (oil-based paint)o Filter and reuse thinners and solvent whenever possible. Contain solids and
unusable excess liquids for transfer to the tailings area
Ore Pad, Tailings area, and Heavy Equipment
I Wash down vehicles and equipment in proper arease Wash down trucks, trailers, and other heavy equipment only in areas designared
for this purpose (such as washdown pad areas and the truck wash stationo At the truck wash station, make sure the water collection and recycling system is
working before turning on water sprays
2 Manage stockpiles to prevent windborne contaminationr Water spray the ore pad and unpaved areas at appropriate frequency in
accordance with Mill SOP's. Water spray stockpiles as required by opacity standards or weather conditionso Don't over-water. Keep surfaces moist but minimize runoff water
3 Keep earthmoving activities from becorning pollutant sourceso Schedule excavation, grading and other earthmoving activities when extreme
dryness and high winds will not be a factoro Remove existing vegetation only when absolutely necessarye Seed or plan temporary vegetation for erosion control on slopes
Fornr Upilated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 15 of 22
Section II -- Site Walk Through Inspection
Areas and Observations:
Ore Storage:
Observations (attach extra sheets if needed): Ore is currently being stockpiled at the facility
until a large enough quantity is stored for an ore run. DRC noted that a runoff drain (piped to
the tailings cells) was constructed at the southwest corner of the ore storage area per past
DRC comments and that the drain appeared to be clean and that the overflow pipe was
visible above accumulations of sediment. Although accumulations of silt/clay were within
the drain it did not appear that the integrity of the drain was impacted and that it was likely
free draining. Also, the berm on the eastern side of the tailings storage area had been re-
graded and heightened and appeared improved over what was observed during 2009. (Photos
1 and 2) DRC had no additional recommendations concerning this area.
Reagent Yard:
Observations: (attach extra sheets if needed): A new, enclosed, reagent building is has been
constructed for dry chemical storage (Photo 39).
Per DRC inspection of the reagent yard it appeared that drurn storage was appropriate. No
degraded or tapped drums were noted in those areas. (Note that alternate feed/intermediate
product drum storage are logged in other sections below)
Shop/Vehicle Maintenance Area:
Observations: Per the 2009 walkthrough comments it was noted that (December 10, 2009,
Ground Water Module 65 Inspection, Storm Water Best Managernent Practices Plan
(SWBMPP) Inspection, DRC Review Memo):
"DRC noted that a floor drain was located inside of the building which drains to an outdoor
storage tank (below ground concrete vaults). It was reported that any oil contaminated water
in these tanks was pumped to the used oil tank. DRC noted that this creates a large quantity
of contaminated stom water and recommended that the indoor drain be blocked and that
indoor oil spills be cleaned prior to contamination of storm water. If the water in the vault is
determined to be uncontaminated then it is transferred to Roberts Pond."
Per the October, 2010 inspection, DRC noted that the interior floor drain was still open and
operating (Photo 7) and that no reconfiguration or process changes had occurred in response
to the DRC findings. Since these issues are in conflict with the best management practices
quoted above, specifically since the interior drain and containment area produce a Iarger
volume of contaminated fluid (mixes with storm rvater), this item will be included as a
request for information for follow-up.
Form Updated December 14.2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 16 of 22
Mill Processing Areas:
Two specific areas of observation comments were noted during the 2010 site walk through as
below.
Observations l: SX Building Roof Drainage Runoff - The 2009 DRC inspection
recommendations included this as an item and recommended that the SX roof drainage be
evaluated (per an onsite personnel inspection) to evaluate whether the current system was
adequate to avoid roof drainage downgradient into the alternate feed circuit . It was noted
that this onsite inspection was conducted on 912312010 by David Turk and that the comments
were included as an addendum to the daily log. Per the 9l23llO DUSA inspection onsite
personel observed that the current drainage system is "not adequate." In follow up the
9l23ll0 inspection states that "the drainage system needs to be addressed by the engineer and
have the situation corrected." DRC will include a request for information to determine what
findings have been made and if any corrective actions were conducted.
Observation 2: Vanadium intermediate product stored in open drums (Photo 17). DRC
noted that approx 20 open drums, containing product, were located onsite directly
downgradient from the existing decontamination pad. It was noted that these drums are
located within the "Feedstock Storage Area" as defined by coordinates listed in the
Groundwater Permit Part I.D.3.F. Therefore no additional follow up will be done regarding
the observation.
Alternate Feed Circuit South of SX Building:
Observations: During the October,20l0 inspection, DRC observed the new alternate feed
processing area. It was noted that drainage within the containment area was pumped into
overhead tanks. During the inspection it was reported by David Turk that a Denison
employee was posted at the alternate feed location 24 hours a day,7 days a week, see Photos
33 through 35. DRC noted that drums of black flake were still being staged on soil areas
adjacent to the alternate feed circuit. Per the 2009 recommendations, DRC stated (December
12,2009 DRC Findings Letter, p. 3):
o Alternate Feed staging is currently conducted on the south side ofthe processing area on the
soil without berms or containment. DRC noted that one of the drums which had been
removed from its overpack was badly corroded and that alternate feed material (black flake)
was visible through a hole in the top of the barrel (see photos). DRC also noted that a trace
amount of the black flake was visible on the ground at the base of the drum. Although the
storage during staging is not currently a violation of the ground water permit, please be
advised that Part I.D. t 1 of the revised permit will include BAT requirements for feedstock
material storage. It is recommended that the barrels be kept in the overpack until ready to be
loaded onto the alternate feed rack within the containment area or other alternative method at
the discretion of Denison.
Per the 2010 inspection findings it was noted that the same issue was present onsite. Several
barrels of alternate feed material (black flake) were found stored (staged) on soil on the south
side of the processing area, west of the SX building, without overpacks in badly deteriorated
Form Updated Deccmber 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page l7 of 22
drums which had been perforated on the side and without cover (see photos 36,37 ,38).
Therefore, Denison Mines ignored the recommendations of the 2009 inspection
correspondence.
The Denison Mines Groundwater Permit, Part I.D.ll (BAT Requirements for Feedstock
Material Stored Outside the Feedstock Strtrage Area was modified on January 20,2010 and
states:
"BAT' Requirements for Feedstock Material Stored Outside the Feedstock Storage Area -
the Permittee shall store and manage feedstock materials outside the ore storoge pttd
in accordance with the following minimum perfornrunce requirements:
o) Feedstock materials will be stored at all times in water-tight containers, and
b) Aisle ways will be provided at all times to allow visual inspection of ectch and
eve ry .feedstock container, or
c) Ettch and every feedstock container will be placed inside a water-tight overpack
prior to storage, or
d) I'eedstock containers' shall be stored on a hardened surface to prevent spillage
onto subsurface soils, and that confornts with the following ninimum physical
requirements:
I ) A storctge areo composed oJ' a hardened engineered surfnce of ctsphalt or
concrete, and
2) A storage area designed, c'onstructed, and operated in accordance with
engineering plans cmd specificcttions approved in advance by the Executive
Secretary. All such engineering plans or specifications submitted shall
demonstrate complictnce with Part I.D.4, and
j) A storage area that provides cctntuinment bernts to control stonnwater run-on
and run-off, and
4) Stormwcfier drainage works approved in advance by the Executive Secretary,
0r
Other storage Jacilities and means approved in adt,ance by the Executive Secretary "
Therefore, the storage practices observed in October,2010 are a violation <-rf the
Groundwater Permit Part I.D.l 1, for the following reasons:
l. Feedstock Staging and Management - staging of feedstock in preparation of
its entry into the alternate t'eed circuit is part of feedstock management, and
subject to the requirements of Part I.D.1 1 of the Permit.
2. Observed Feedstock - during the October,2010 inspection DRC observed:
a. Feedstcck rnaterial was not stored in water tight contarners,
Form l-lpdated D.ccntber 14, 20t0
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 18 of 22
b. Feedstock material was not stored on a hardened engineered surface
or asphalt or concrete,
Feedstock material was not stored in a designed and approved
storage area (by the Co-Executive Secretary), or other approved area,
Feedstock material was stored in open and degraded containers
containing placed on soil and located outside of the feedstock
management area.
As a result, DRC staff recommend that the feedstock management violation be included on
the confirmatory action letter..
Old Decontamination Pad:
Observations: Wash water is recycled until too dirty to be used effectively for vehicle
washing, the water is then discharged to a below grade tank thence to the process water pond.
DRC noted that the concrete collection vault for overflow from the pad (thence discharging
to Roberts Pond) was repaired per the inspection findings listed in the 2009 DRC review
memo and Findings Letter. Specifically it was noted that the discharge from the
decontamination pad holding tank was piped completely to the wash-out tank. It was noted
that the wash-out tank was full of sediment and required clean-out. Note that this
decontamination pad is seldom used since commencement of operation of the new facility.
DRC has observed the pad during visits to the facility subsequent to the inspection and
verified that the old pad is defunct. No further action will be conducted related to the
findings at the old decontamination pad.
New Scale House Decontamination Pad:
Observations: The new decontamination pad (facility) was not in operation at the time of the
storm water inspection. The baffle water containment/treatment tanks had been drained of all
water and a black sealer was applied on all interior seams (See Photo 3 and 4). Onsite DUSA
representatives stated that the containment system was being prepared for a hydrostatic test
to prove tank integrity. Note that the tank improvements were being conducted during no-
operation period of the new decontamination pad. No further action will be conducted per
observations at the scale house decontamination pad.
Reagent Tanks:
Sodium Chloride Tanks - DRC noted that the containment area was earthen. It was
reported that this was allowable due to the age of the tanks. Per discussion between TR and
LM it was noted that LM had a past discussion with Harold Roberts regarding the secondary
containment. An agreement was forged that all reagent tanks that pre-existed the Ground
Water Permit (3/05) would be acceptable as is - and that as upgrades or replacements were
installed, DUSA would work to meet BAT requirernents. More detail regarding this
agreement is in the December 2004 Statement of Basis, and in Part I.D.3(g). See Photo 15.
Form Updated December 14,2010
c.
d.
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 19 of 22
Kerosene Tanks -- DRC noted that the containment area was earthen. It was reporled that
this was allowable due to the age of the tanks as discussed in the Sodium Chloride Tank
Section above. Photo 14
Ammonia Tanks -- DRC noted that the containment area was earthen. It was reported that
this was allowable due to the age of the tanks as discussed in the Sodium Chloride Tank and
Kerosene Tank sections above. Photo 13
Used Oil Tank - Appeared to have appropriate secondary containment. No records
concerning visual inspections of tank integrity. Photo 6
Kerosene Tank - Located in the same secondary containment area as the used oil tank.
Facility reported that this was acceptable (by rule) as long as the containment was
constructed for the largest tank. This criterion is consistent with past inspections by DRC at
the site with similar findings. Photo 6
Fuel Tanks - Above ground tanks appeared maintained and had secondary containment.
Photo 5
Uranium Liquor Tanks - Containment areas appeared to be in good condition. Photo 18
Vanadium Pregnant Liquor (VPL) Tanks * Per comments related to an Engineering
(Discharge Minimization) inspection conducted by DRC personel during 2010 it was noted
that steam condensate from the VPL tanks was being allowed to accumulate in the area of the
tanks and around the tanks. In response to these comments DUSA has agreed to provide a
concrete secondary containment and pumpout system for the steam condensate (this item is
being tracked under separate cover). For additional information, see DUSA letter dated July
15, 2010 and DRC response dated September 27,2010. DRC noted per this inspection that,
pending the construction of the containment pad, DUSA has provided drain extensions and is
discharging the water into storm drains away from the VPL tanks (Photos I l, l2). DRC will
follow up with this item as necessary to insure that condensate water or upgradient runoff
does not accumulate in the VPL tank area.
Clean Water Tank -- DRC noted that the clean water tank valve was not sealed, the valve
was leaking water (exact volume/time was not measured) at approx 60 gallons/minute. Photo
19. The repair of this valve will be included as a request for information item to insure that
water is not surface ponding in the confines of the facility without adequate engineering
controls (eg liner).
Sulfuric Acid Tank - The tank appeared in good condition. DRC noted that a new berm
was recently constructed around the sulfuric acid tank. Onsite DUSA representatives
reported that this was done in response to historical DRC comments regarding potential large
scale breaches of the tanks. DUSA representative also reported that if such a breach occurred
it could impact a transformer station (electric power) located approx 200 meters east of the
tank. Photos 21, 22 &23
Form Updated December 14. 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 20 of 22
Propane Tank - No issues observed. DRC noted that the valves and air quality system was
recently replaced. Area was clean. Photo 25
Caustic Soda Tank - Secondary Containment was not in good condition. Concrete was
highly degraded and appeared to have holes extending to underlying earthen material. The
DRC 2009 recommendation was to repair or replace the secondary containment floor. This
recommendation item was not addressed and therefore will be included with the 2010
Confirmatory Action items. Failure to maintain the integrity of the secondary containment is
a violation of the Groundwater Permit Part I.D.lO.b. (See photos 29,30)
Soda Ash Tanks - Secondary containment floor showed cracks. DRC 2009
recommendation was to repair or replace the secondary containment floor. The
recommendation was not addressed and will therefore be included on the 2010 Confirmatory
Action Items. Failure to maintain the integrity of the secondary containment is a violation of
the Groundwater Permit Part I.D.l0.b.
Tailings Cells Areas (Note that upland drainage was included in comments above) -'
DRC toured the tailings cell areas (Cells 1,2,3,4A and 48 (under construction at time of
inspection) and observed the condition of the outer toe areas of the dikes to insure that
excessive erosion or damage (e.g. burrowing animal intrusion or rooting damage) was not
present. Per the DRC review the dikes appeared in good condition.
Summary of Onsite Closeout Meeting: An onsite close-out meeting took place between
Tom Rushing (DRC) and David Turk (DUSA). During this meeting DRC informed the
DUSA representative of the issues stated in the inspection above. It was especially noted that
the DRC 2009 recommended actions were for the most part not addressed and that these
items would likely be included as confirmatory action items for the 2010 correspondence.
Date/Time : 10-19-2010/1300
DTISA Representatives Present -- David Turk, RSO
DRC Representatives Present - Tom Rushing, P.G.
Conclusions
DRC will arrange a conference call with DUSA representatives to discuss the confirmatory
action items and request for information items detailed above and summarized below. It is
anticipated that compliance schedules (deadlines) will be negotiated and finalized during the
conference call:
Forr:'r Updated l)ecember l4,2OlO
White Mesa Mill
'Ground Water Module 65
Storm Water Management
Page 2l of 22
The CAL items are:
l. DUSA has violated the Groundwater Permit Part I.D.11 by failing to manage drums
containing alternate feed material (located outside of the feedstock management area)
in cornpliance with the required performance standards.
a. Feedstock material was not stored in water tight containers,
b. Feedstock material was not stored on a hardened engineered surface or
asphalt or concrete,
c. Feedstock material was not stored in a designed and approved storage area
(by the Co-Executive Secretary), or other approved area.
d. DRC observed open and degraded containers containing feedstock
material on soil and located outside of the feedstock management area.
2. DUSA has violated the Groundwater Permit Part I.D.10 by failing to replace/rcpair
concrete in the secondary containment of the Caustic Soda Tank.
3. DUSA has violated the Groundwater Permit Part I.D.10 by failing to repair cracks in
the secondary containment area for the soda ash tanks.
The RFI items are:
L DRC will requiest information regarding updates to the plans/inspections to provide
inspections according to frequencies required by the Storm Water Best Management
Practices Plan (SWBMPP). For example, the SWBMPP requires a weekly inspection
of the diversion ditches, however, they are conducted monthly. Failure to provide
these inspections in conformance with the SWBMPP or modify the SWBMPP is a
violation of the Groundwater Permit Part I.D.10., "The Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices
Plan."
2. DRC will request information regarding the inspection procedures for reagent storage
tanks (including intermediate process tanks, eg Pregnant Liquors) which are installed
on-grade (on-grade refers to tank installations where the tank bottom is in contact
with the ground) to insure that the structural integrity of the tank bottom is
acceptable/appropriate. Cathodic protection for on grade tanks is prescribed for the
on-grade tanks, in order for DUSA to comply with Part I.D.10(a) of the groundwater
pcrmit.
3. DRC will request an outline of a plant process for internal notification and
documentation of the clean up of small quantity spills (less than reportable
quantities). Per the 2010 inspection it was noted that a fuel spill had occurred at the
fuel tank area, however, had not been cleaned up and there did not appear to be a
process to identify, document, or clean up such spills. Failure to provide such a
process is not in conformance with the SWBMPP Part 4.2.1.
4. DRC wili request that DUSA review the facility SPCC plan to insure that all tanks
included under the current facility Spill Prevention Countermeasure and Control
Form Updatcd Dcccrnircr 14. 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 22 of 22
(SPCC) plan meet current requirements of current EPA rules (40CFR1 l2).
Specifically, any non-PCB containing tanks should be included under oil inventory
and be included with inspection protocols. This RFI is required in order to insure that
current procedures and policies at the mill are up to date.
Seal interior drains in the vehicle maintenance areas that drain to outdoor uncovered
areas. This is specified in the facility SWBMPP and is considered a best management
practice to minimize the quantity of contaminated material. The open drain is not in
conformance with the SWBMPP part 4.3.1, second bullet "clean up spills promptly,
don't let minor spills spread."
Insure that the clean water tank valve is sealing properly. Per the 2010 storm water
inspection it was noted that this valve was leaking and was creating pond areas in
unlined ditch/soil areas. This is not in conformance with Section 4.1.4 of the
SWBMPP which states, "Areas requiring maintenance or repair, such as excessive
vegetative growth, channel erosion or pooling of surface water runoff, will be
report[ed] 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."
F:\DUSA\Storm Water Management\20I0 SW Inspection\20l0 SW Inspection Memo - White Mesa Mill - Fnl.doc
U:\rad\COMMON\Uranium mills\1 1e(2)UTl90M79 Denison Mines - White Mesa UMill\Storm Water
Management\Modu le65 MemoFormat.doc
5.
6.
Form Updated December 14,2010
White Mesa Mill, 201SR.C Storm Water Inspection
Ground Water Module 65
Storm Water Managemont
Attachments
Attachment 1 - Copies of Daily, Weekly and Monthly Inspection Data Logs for April,
2010
II
Write Mesa Mill - Standad Operating Frocedures
Eook I I : Envronmemtal Frotection lV1anual, Seetion 3.1
2/07 Revision: D[JSA-2
Faga17 ot25
AFPEFIDXX,{ (CoNT.)
D.A{tr,Y MqSPECT'I@N D.ATA
rnspector:'f^*, llll.If
Date; tl-LlO
Accompaniedby: rup,
rime: l3OO
.,;,i
Any Item not'!OK" must be documented. A check mark = OK X : Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Inspeotion Items Conditions of Potential Concern Cell l Cell2 Cell3 Cell
'4A
A'A
Slurrv Pioeline Leaks, Damage, Blockaee, Sharp Bends
Pineline Jointj Leaks, Loose Conhections
Pioetin6 Suonbrts Damase. Loss df Suooort v
Valves Leaks, Blocked, Closed
Point(s) of Discharse Impropu Looation- or Orientatio:r".,
U. OPERATIONAL SYSTEMS
Insoection Items Coriil-itionb of Pgteqtial Concern Cell,l Cell2 Cell3 Cell....,:,'.?
4A
N lv
Water Level Greater Than Operating Level, Large Change
Since Previous Inspection
Beach Cracks, Sevele,Erosion, Subsidence
Liner and Cover Erosion of cover. Exoosure ofliner
Inspection Items
III. DIKES AI\D
Areas of SeeDaqe Outbreak
Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
-,}
\
White Mesa iUill - Standard Operating Frocedares
Eook 1tr: Emvironmental Froteetion [r1anual, Section 3.1
2/07 Revision: DUSA-2
Fa-ge lE of25
V. PETYffCAL INSPECTXOFI OS' SLURR,V
- LINES(S)
Walked to Discharge Point
Observed Entire Diseharge Line
-I;di. ss - t! tl Ll 16 GPrq
Yes----7-v",
-wa-/*orvInitial level -
/ w*-)ory
Initial levei 7.5
Final level a
:: , il Checked
_Wet__jaDry
tnitial lwel=__!__
--/ wo--pry
Initial level 73
Final level
VITI OBSERVATIONS OF POTENTIAL CONCERN
s Lc.tl 3 t N \^\nA. Btr;"n T.rlru u.As ,*t*"t:
K*g Ro.trr t$...,I b;t\ iJrk lra6c^ ], ,t"+ d*1,
Action Requiied
M",Xc,r.rd rrias noifia,l (A.ll ltt,r)
lp,ryl.
)
W+tl;t* Ccot cs0ereA exposeA t-ln<. cn c*y L
3.('h.,1-:3*iHlons' S]o'{'J. A'n+h! R<'ov"y ct Sria'<s #J'
-".q4sqb dsPE€rxCIJr REP{}Rtr[Ar u tff6$ sLUsBy misemfrede' iloeanrors
oAT6s Ll^5- ,:olD
IHSPECT0R: {r-ne{
fl
N
I
Qu* 4;
Q/l ?-g
so\.Non
tE[L I-t
5P\ sgt).,"r
Tt1"^'*};"I,@q fu. 1
cEfL 3 -tol*ion
crlr e-a
S ")'-$iu,^,,:
i'
ll.
White Mesa Mill - Standard Operating procedures
Book 1l: Environmental Protection Manual, Section 3.1
APPENDTX A (CONT)
DENTSON MrNES ruSA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation
Cell 44: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(d)Elevation of Beach Area
with Highest elevation (monthly)
Roberts
Pond: (a)Pond Solution Elevation
3/10 Revision: Denison-9
Page}8 of 46
5613 58
_5597
nrt", Li-2- l0 lnspectors:
1. Pond and Beach
elevations (msl,ft)
Lctl 3
2. Slimes Drain Liquid Levels Cell2
(c) Depth of Water above FML ((a)-(bD 16.LK
55 85.{o7
5564
(c)Depth of Water above FML ((a)-(b) eI"67
J6H 5I
(b)FML Bottom Elevation _5612.34_
(c)Depth of Water above FML ((a)-(bD -6.qt -
sto\.qq
5510
. jl.qq,
properly YtPump functioning
Pump Timer set at 15min on 45 min off .ruo A.{nltakc Floc* sgd.rt
Depth to Liquid pre-pump
Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
-laaqPost-pump head is 38' -Depth ro Liquid Post-
pump = i{\.3S
\
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual. Section 3.1
3. Leak Detection Systems
3/10 Revision: Denison-9
Page29 of 46
Observation:
Cell I Cell2 Cell3 Cell4A
Is LDS wet or drv?wet v dry { wet drv
-wet-
f4 drv i/ wet_drv
If wet, Record
liquid level:
- Ftto
Liquid
Ft to
Liquid - Ftto
Liquid
6.7 Pt to
Liquid';lf sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Flow Rate -
Volume
Flow Rate_
'Ttl
Flow Rate - _
Volume r5Dso
Flow Rate_
Was fluid sample
collected?-!es
/ no
-)es
-/ no
-)es
/ no yes t/ no
Observation:
New Decon Pad.
Portal 1
New Decon Pad.
Portal2
New Decon Pad
Portal3
Is LDS (Portal)
wet or drv?
-wet__{_dry
wet ../ drv wet /dw
If wet, Record
liouid level:- Ftto
Liquid
- Ftto
Liquid
- Ftto
Liquid
If wet, Report to
RSO
Tailings Area Inspection (Note dispersal of blowing tailings):
Control Methods lmplemented:
7. Contaminated Waste Dump: L.roK oul
White Mesa Mill - Standard Operating procedures
Book I 1: Environmental Protection Manual, Section 3.I
3/10 Revision: Denison-9
Page 30 of46
8.0 DecontaminationPadlnspections
Concrete Intesritv Concrete In
New Decon Pad Existine Decon Pad
Checked
Are there any cracks on the
wash pad surface greater
than 1/8 inch of
separation?
-Yes
y'Uo
Contact the RSO if a
problem has been
observed.
-.-Checked
Are there any cracks on the
wash pad surtace greater
than 1/8 inch of
separation?
-Yes --,fNo
Contact the RSO if a
problem has been
observed.
Remarks (including a description of any abnormalities relating to the New Decon pad or Existing Decon
Pad)
x Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner (elevation
5556.14 amsl)? ',./ no _ yes
If Cell 44 leak detection system level exceeds 12 inches above the lowest point on the bottom flexiblemembrane liner (elevation 5556.14 amsl), notify supervisor or Mill **ug", immediately.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page22 of25
MPENDTX A (CONT.)
MONTHLY INSPECTION I}ATA
Inspector:
Dare: I <tl Zott)
Pipe Thickness: fu/p ({o be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Sloughing
l1rosron
Undesirable
V,_eggt4tion
Otistruction of FIow
DivgrFion Berm:
Stability Issues
Signs of Distress
Diversion Ditch I
yes__lz'no
VeS L. nO
VeS ,-/' nO
. yes .t/ no
Diversion Ditch 2
yes e no
ves ,- flo
Yes-----,2-no
, , y9s---Y/ no
Diversion Ditch 3
Yes--:tl/noves ,/ no
ves___.rtno
,'/,YeS DO
Diversion Berm 2
yes-Zno
ves ,-/ no
r':'"(i
'9' '
(,
White Mesa Mill - Standard Operating Procedures
Book lI: Enviromnental Prolection Manual, Section 3.1
2/07 Revision: DUSA-2
PageZ3 of25
4. oversprayDustMinimization: Y'"llO \r* \
Overspraysystemfunctioningproperly: L/yes-no
\--f**'*
Overspray canied more than 50 feet from the cell: yes no
If 'oyes", was system immediately shut offl yes no
6, Settlement Monitors Sf. 4 n n ,lJt
Cell2Wl:
Cell,2W2:
Cell 21V3:
Cell2W4:
ceil zwz-c:
Cell.4A-Toe:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell2 East:
Cell3-lN:
Cell3.tC:
Cell l:!S11
Cell3-2N:
Cell,2W5.N:
s. ff#;fti-* D"%ent ror ceu 2 (Depthl:'Tf*tei'r'eva
lVhi'ue hfesa X,4itl - Sfardard Operating Frocedurcs
Eook ltr: F:nvfuonmwrtilprobefion Manual, Seetion S.I
2/07 R.evision: D[,ISA-3
Fagc 25 of25
APFENfl)gX A (a@NT")
@RE s3@RAGE/B.aMpg,E ptArvr \nreEEff y mspECEroN REpo,R?,
Weelcof ltlr,lo thtoagh .t l, il,e Dateoflnspeetionl
lrop*m* (rn,r.- tl"\."rer
Weather conditions for the week:
Blowing dust cotrditions for the week:
Corrertive acjions needed of taken for the week.
glau lttt'Hlltoc*1dlatlslp *ored in rheareaindicared on theapachea diagpm:_____-_G,_
Aoill altEnat"&Pdstqgkmat€rials looatod outsidethe areaindicatod on theattrached diagrammaintainedwithin watg-tight containefie: -'.*w'w vr ue 'rtrilu[Ln (uagrar
yGs:_Y_no:_
commdts (e.g., conditions of containers):t
Conditioni ofsiorage argA8 fofl Sateriale:
Ottreroormemfs:
Ot
{
fi
Bil
$
Banlssn Minee ( U$Atr C"ilrp.
Fesdstoc* Stor*ge Araa Mep
Location Trans. Shot Base Applied Elevation
Cell 4A 5.5 5574.5 5577 Name: Tanner Hollidav. Garrin Palmer
lntitial €5582.5
Date: 413012010
C2W1 3.1 5613.04 5619.06
czw2 1_22 5613.04 5620.94
c2w3 4.46 5613.04 5617.7
czw4 4.S2 5613.04 5617.24
lnitial 9.26 5622.16
5623.14 5623.86
5623.14 5627.4
5623.14 5622.88
5623.14 5623.44
5623.14 5622.2
5623.'t4 5621.48
5623.14 5619.88
5623.14 5620.46
5623.14 5618.08
5623.14 5616.44
5628.66
2W5-C 4.42 5613.04 5618.14
2W4-N 3.08 5613.04 5619.08
2W4-S 6.2 5613.04 5615.96
2W5-N 3.46 5613.04 56't8.7
2W3-S 5.66 5613.04 5616.5
2W5.S 8.1 5613.04 5614.06
2.84 5615.88
lnitial 4.9 5617.94
3-1N 1 5613.04 5616.94
3-1C 5.16 s613.04 5612.78
3-1S 2.78 5613.04 5615.16
3-2N 4.78 5613.04 5613.16
J.ZV 2.28 5613.04 5613.6
3-2S 3.74 5613.04 5612.14
Location Trans. Shot Base Applied Elevation
Cell 4A 5.S 5574.5 5574.5 Name: Tanner Hollidav. Garrin Palmer
lntitial 8.o 5574.5
Date: q.3O-1010
c2wl 3.5612.77 5612.77
c.g ,*rll*t .o". Jf,
czw2 1,11 5612.77 5612.77
c2w3 Ll^..1A 5612.77 5612.77
C2W4 Ll.qa 5612.77 5612.77
Initial 5612.77
t4g 5623.14 5623.14
-26 5623.14 5623.14
5.>r 5623.14 5623.14
4. zr 5623.14 5623.14
.Ll(5623.14 5623.14
1. t8 5623.14 5623.14
9.79 5623.14 5623.14g-2-s623.14 5623.',t4
lo.9E 5623.14 5623.14
t2 12 5623.14 5623.14
\i,:l 5.St 5623.14
2W5-C l.o1 56',12.77 5612.77
2W4-N I -on 5612.77 5612.77
2W4-S ;.)56'12.77 5612.77
2W5-N 3.t1[,5612.77 5612.77
2W3.S ,. ta 5612.77 5612.77
2tvS-9 7.J
lnitial {.q 5613.04
3-1N l.o 5613.04 5613.04
3-1C s_ta 5613.04 5613.04
3-1S l.1t 5613.04 5613.04
3-2N rl.'M 5613.04 5613.04
3-2C 7.el 5613.04 5613.04
3-2S 9.?"1 5613.04 5613.04?,v itovl* 't lltc' r'oa^f
orf" sh'tS
White Mesa Mill - Standard Operating procedures
Book I I : Environmental Protection Manual, Section 3. I
2/07 Revision: DUSA-2
PagelT of25
APPENTITX A (COI[T.)
DAII,Y INSPECTION DATA
Date; Q. ?3- lO
Accompanied by:fa,tncr ib il;to^{
rime: l33O
Any Item not "OK" must be documented. A check mark : OK, X : Action Required
I. TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concem Cell l Cell2 Cell3 Cell
4A
Slurry Pipeline Leaks. Damase. Blockage. Sharp Bends iltA
Pipeline Joints Leaks, Loose Connections nll
Pipeline Suoports Damage, Loss of Support illa
Valves Leaks. Blocked- Closed NIA
Point(s) of Discharse Imurooer Location or Orientation ,tlA
II. OPERATIONAL SYSTEMS
Inspection Items Conditions of Potenti4l Concem Cell I CelL2 Cell3 Cell
4A
Water Level Greater Than Operating Level, Large Change
S ince Previous Insoection NIA x t-/
Beach Cracks. Severe Erosion, Subsidence NIA
Liner and Cover Erosion of cover. Exposure ofliner ttlA
III. DIKES AND EMBANKMENTS
lnspection Items Conditions of Potential Concem Dike
1-I
Dike 1-
1A
Dike 2 Dike 3 Dike 4,A.-
S
Dike
4A-W
Iopes Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
Areas. Areas of Seepaee Outbreak
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page l8 of25
V. PHYSICAL INSPECTION OF SLT'RRY
LrNES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
Yes
,./ No
VI. DUST CONTROL
Wind Movement
General Meteorological conditions:
Wet u.rfry
Final level r
bhl. oumped '-/-
-:2fi"----:o,v
-rULInitial level -./
Final level /
wo_vr5ry
Initiallevol
--
-Final level
-./w*__oo
mitia tevet-2.-ot-
Final level
VIII OBSERVATIONS OF POTENTIAL CONCERN
ir1u,li"N tn?d*-rr Cz*rL; |jaa'S s\o ^oYPi} +. wJoe F |' bt' lo"ut- o'- li*<"-
J+.^/-;5 ura;le- a,.o','Ju Ct t t'\O
'
Action Required
l*csr.r?
!i*x t"'r"
o r,, ( _'
o
re r u, m8*
u$Xru#fl uFFIdgfl -38-fl#[*r, o*
oATEr q-7?'IO"
IHSPE€TOR , Go;-^ (, l. -.,,,
I
N
I
cqt Ll-g
r
tD:(o,,
Solulioa
GELI X-[
E;ll;rl..
6ELL 2
I R,'.A
CELL d-A
September 23,2OLO
After the rain event on the 22nd of September, an event in which over 1.2" of rain fell, it was observed
that the drainage from the SX building roof is not adequate. The rainfall caused pooling solutions. The
drainage system needs to be addressed by the engineer and have the situation corrected.
0(t
Radiation Safety Officer
White Mesa Mill, 2010t Storm Water Inspection O
Ground Water Module 65
Storm Water Management
Attachments
Attachment 2 - Copies of Certifiiation for Tailings Management Systems Daily
Inspections
Wlrite Mesa Mill - Standard Operating Procedures
Book I l: Environmental Ptotection Manual, Section 3.1
3/10 Revision: Denison 9
Page 44 of 46
APPENDIX C
CERTIFTCATION FORM
o^t*,5-2-Y- lC
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
lnspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problerns (dike
failures, unusual flows), notification procedures and safety.
6 * fr,(ru--
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
z//0
-------i1""."*+
Safety Personnel/ Tailings System -
White Mesa Mill - Standard Operating Procedures
Book I l; Environmental Protection Manual, Section 3.1
APPENDIX C
CERTIFICATION FORM
D^8. S:AL-RfiI#-
{il, pa^"o*
3/l 0 Revision: Denison-9
Page 40 of 46
Name:
I have 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 problerns (dike
failures, unusual flows), notification procedures and safety.
I certify that the above-named person
sy$tem at the White Mesa Mill.
is qualified to perform the daily inspection of the tailings
Radiition Safety Personnel/ Tailings System
White Mesa Mill- Standard Operating Procedures
Book I l: Environmental Plotection Manual, Section 3.I
3/l 0 Revision: Denison-9
Page 40 of45
APPENDIX C
CERTIHCATION FORM
Date:3/z< l,u
Name:l,,.,', J*T-,,L
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.
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
White Mesa Mill Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3/l 0 Revision: Denison-9
Page 40 of46
APPENDIX C
CERTIFICATION FORM
put", ..3-21-2QlO
Name:
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
inclu,rled documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I certify that the above-narned person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Secdon 3.2
2107 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTTFICATTON FORM
Pate: tSJnr.tc{
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
inciuded documentation of daily tailings inspections, analysis of potential problerns (dike
failures, unusual flows), notification procedures and safety'
I certify that the above-named person is qualified to perforrn the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety PersonneV Tailings System
Supervisor
White Mesa Mill - Stadard Operating Procedures
Book I l: Environmenlal Protection Manual, Section 3'2
2/07 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTIFICATION FORM
Date: /L:XO'OX
Name: &or< Skrlig[
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspecror Training" and have received on-site instruction at the tailings system. This instruction
inciuded 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.
Safety PersonneU Tailings SYstem
White Mesa Mill - Standard Operating hoccdures
Book I l: Environmenlal Protection Manual, Section 3'2
2/07 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTTFICATION FORM
oate, //'19'Ot
I have read the document titled "Tailings Management Systern, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system' This instruction
inciuded documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
4Lry
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Safety
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Rcvision: DUSA-2
Page 6 of6
APPENDIX D
CERTIFICATION FORM
Date: tolzlzm7
Name: Do-,JT-/rL
I have read the document titled'"Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site insfuction at the tailings system. This instnrction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Safety Personnel/ Tailings System
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision; DUSA-2
Page 6 of6
APPENDIX D
CERTIT'ICATION T'ORM
Date: Pl I lzo, y
Name:
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 insfuction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I cetify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTIFICATION FORM
Date: ial: lzoo*
Name: innn, r )l,ll' &*:i.
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site inskuction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I cetify that the above-named person is qualified to perform the daily inspection of the tailings
systern at the White Mesa Mill.
White Mesa Mill - Standard Operating Procedures '
Book I l: Environmental Protection Manual, Section 3.2
707 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTIIICATION FORM
our", lo f z3/08
I certify that rhe above-named person
system at the WhiteMesa Mill.
Name:0r
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
inciuded documentation of daily tailings inspections, analysis of potential problems (dike
failures. unusual flows), notification procedures and safety'
1-;Gl
is quatified to perform the daily inspection of the tailings
Radiaiion Safety PersonneU Tailings System
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2,/0? Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTTFICATION FORM
oao,: /D/'zs/o/
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
inciuded documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety-
I certify that the above-narned person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
4"t/t/l
Radiation Safety PersomeU Tailings System
Supervisor
White Mesa Mill - Standard Operating hocedures
Book I l; Environrnenlal Protection Manual, Section 3'2
2107 Revision: DUSA-2
Page 6 of6
APPENDIX D
CERTTFICATION FORM
oxe: /0-2$-M
Name: {a, {l l,l
I have read the document titled "Tailings Muragement System, tfVhite Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings systern' This instruction
inciuded docurnentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety'
I certify that the above-named person is quatified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety PersonneU Tailings System
Supervisor
White Mesa Mill, 2010ilC Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 3 - Photo Pages
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 1 of16
Photo 1 --O.e Te4ltgg tg4-D11in, located at the south-east corner of the tailings pad
Photo 2 -- Drainage Berm
t
on the eastern side of the tailings storage padll i]rM*&
Photo 3 - New Decontamination Pad - Note that the
the concrete seams have been coated
containment has been drained and
with black sealer
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page2 of 16
Photo 5 - Small diesel spill located at the refueling tanks west of the scale house, spill
was not cleaned up when it occurred
Photo 6 - Used Oil Tank and Kerosene Tank at the Equipment Maintenance Area
aDenison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 3 of 16
Photo 7 -Draininside of Vehicle Maintenance Area, Subject of 2009 comment
Photo 8 - Total Containment Sumps outside of the vehicle maintenance area, consists of
Photo 8 - Area Above Treatment Area (Note old decontamination pad in background).
Area has been regarded to control runoff into the Vanadium Pregnant Liquor (VPL) Area
recommended that DUSA remove this drain
3 baffled concrete containments
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 4 of 16
Photo 9 - Drainage from area in photo 8 to discharge into the containment area (left of
t2)
Photo 10 - Area between the VPL tanks which previously had standing water from
red fire box) and out through a drainage pipe (see
condensate
Photo 11 - Condensate from VPL tanks piped to storm drain (steam area in background)
Denison Mines White t " Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 5 of 16
Photo 12 -YPL condensate draining to storm drain, also note pipe entering drain (photo
right), this is from regional drainage above the VPL tanks-T*sh1
note soil berm and soil containment floor
Photo 14 - Kerosene Tanks, note soil containment
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 6 of 16
Photo l5 -- Sodium chlorate tanks and secondary containment, note wash down area left
Photo 16 -- Collection vault from the old decontamination pad, note that the vault is fuIl
Photo 17 - Vanadium intermediate product stored in drums south of the old
decontamination pad (visible in background)
oftanks on concrete pad
of sediment and needs to be cleaned out
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
PageT of16
Photo 18 - U Liquor containment area, water in containment is from washdown of
Photo 20 -- Area below the fresh water tank drains to Roberts Pond, DRC noted that
leakage from the fresh water tank was draining across bare ground to the discharge pipe
I
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water lnspection (Oct. 19, 2010)
Photo Pages
Page 8 of 16
Photo 2l - New berm around sulfuric acid tank, standing water in area is from
Photo 22 - New berm around sulfuric acid tank
Photo 23 - Graded area, former "swamp" area east of the sulfuric acid tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 9 of 16
Photo 24 - Concrete drainage area east side of the sulfuric acid tank
Photo 25 -Di around CCD tanks, drains to Roberts Pond
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Photo 26 - Roberts Pond, note that vegetation has been removed from perimeter
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 10 ofl6
Photo 27 -Discharge around CCD tanks into Roberts Pond, DRC noted that the source of
this water was from washdown of the Leach House (see
Photo 28 - Washdown water from the Leach House across bare ground (discharging into
Roberts P
Photo 29 - Caustic Soda secondary containment still badly deteriorated
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 1l of16
Photo 30 --containment for caustic soda badly deteriorated, not functional
Photo 3l - Roof drainage area from SX building, DRC noted that improvernent needed in
this area
Photo 32 - Area south of SX building slated for drainage improvonents
Denison Mines White;." Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 12 of 16
Photo 33 - Alternate Feed Circuit Area, note that the concrete is lightly deteriorated
Photo 34 --return tank
inside of curbed berm
Altemate Feed Circuit areaholdine tank
Photo 35 -- Altemate Feed containment drainage sump, pumped back into holding tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 13 of 16
Photo 36 -- Alterate Feed (Black Flake) staging area, note that7 drums are in area,
onsite staff that all drums would be during the day
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Photo 37 -- Another view of alternate feed
Photo 38 -- Close up view of perforated drum
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 14 of 16
Photo 40 --
Photo 41 -- Area of northeast berm of cell 2, south of the mill
DUSA staff stated that drainage had been improved
af*4
area
processing area, onsite
in this area
Alternate feed drums east of the d
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page l5 of 16
Photo 42 -- Diversion Ditch I (above cell 1) showing excessive vegetation growth in the
bottom of the ditch
Photo 43 --Diversion Ditch 1 (above cell l) showing rilling on banks and heavy
ion in ditch bottom
Photo 44 -Diversion Ditch 1 (above cell l), slumping (photo middle left)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 16 of16
Photo 45 -- Diversion Ditch 2, good condition
Photo 47 -- Upland area wrthLawzy Lake Depression in the mid-ground