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June 13,2008
Sent VIA Federal Express and Electronic MNil $,.fi; ^ I
Mr. Dane L. Finerfrock
Executive Secretary
n t'ltiontoouo
X'stsN\|'",.n110\
Utah Radiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
Dear Mr. Finerfrock,
Re: White Mesa Mill Stormwater Best Management Practices Plan
Pursuant to Part I.H.16 of the Ground Water Discharge Permit (No.UGW370004), and ltern 5 of Mr.
Loren Morten's email of June 9,2008 pertaining to action items for DRC approval to use tailings Cell
44, please find enclosed a revised Stormwater Best Management Practices Plan (*SBMPP'). The
Plan was modified to incorporate a recent revision to the Mill Site Drainage Basins Figure (Figure 2 of
the SBMPP and Figure 2 of Appendix I to the SBMPP).
If you should have any questions regarding this modification to the Stormwater Best Management
Practices Plan, please contact me.
Yours very truly,
zbolL
Dnxrsox Mnrs (USA) Conp.
Steven D.Landau
Manager Environmental Affairs
Cc. Ron F. Hochstein
Harold R. Roberts
David C. Frydenlund
David E. Turk
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.C,
otI
i DEC-14-eO@7 t3z?4 From:DENISON I"IINES USR
DENrsoNDffi-t
,vllNES
Facsimile Transmittal
Mr. David RuppTo:
ta, No"
UDEQ
Gomoanv:Date:+.
Steve Landau page I of:
Re:9!qr[lWa!el Best Mar.ragement practices plan
To:918815334@97
(801) 5334097
Pagez Lt4
Dcnlran Mtner (USAI Corp.
,050 tTdr Stroe[ Sutro gAb
Denvcr, C0 t0?56
USA
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December 14,ZOO7
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'DEC-14-?A@7 t3:?4 From:DENISON MINES USR To:91801
DEN'SOJ)#d
Donison Mlnsa {U$A) Corp.
{050 lTth Stroot, Bulte DJO
Dsnvor, C0 80265
USA
Tel : 303 62&7798
Fax : 303 300{i26
www.denbonminos,eom
,r,llNEs
Sent Vh Frcimile and Regular Mail
Dccemher 14,2007
Mr. David Rupp
Utah Dep*trnent of Envirorunental Quulity
168 North 1950 West
l'.O.!-lox 144850
Salt Lakc City, Utah 84114-4850
Dear Mr. Rupp;
Rc: DRC Request for lrtbnnation
Storrn Water Best Mrnugcment Praotices Plal
Tltis is in response to UDEQ's corrcspondence and r-oquesl fi:r inl'ormatiol dated Nqvomber 21,2007,aru1 as alollow-up to our conversatir)n lotlay. The refetenced corcspondeuce roquests that Denison respond in writing
relative to stxnding water which lud beeu observed by the UDEQ during rucent inspcctions at ihc facility and tocorrect tttinor differenccs between "stan(l alone" copies of the Emergeniy Response plan and the Sto,n WirttrBest Matragcment Practices Plau,
Rcgarding the standing water observatiotx, with the exceptiotr of lhs "bone yard,, area location, tlrcc ar6aswhere stantling water had been ohservctl during your inspectirms of August iB, 2007, October I t, 2007 anrlOctober 31,2007 have beert providcd with appropriate lill and re-grade-cl to provide better drai'age. As to thehone yard looatiou, this area will be re-gmded similarly. llowevei, equiptrrint in that ared must bs rcmoved
before thar. work can bc co,r,Fleted- Accordingly. Denison pla.ns to renrove such equipment ancl completedrai[age rcsttlration in that locatiott tro later than Jauuary 31, 2008. With respecr rri 1h" ,"".ssary change in theEmergcncy ltesponsc Plan (ERP) ftat document had been modified in lebruary ot2007 to appropriatcly
refereurce Section I .5 of the Spill Prcvention, Controls and Clountenueasures P[au (See attacf,ot p"ge E-i of ttrcERP),
If you should have ftirther qucstions regarding these matter.s, please oontact nre.
Yours very truly. /-ffiru-"DExrson MrNEs (uSA) Coru'.
SrevEN T}. LAND^U
M Aru noER, EN V RoNMENTA T, fu,TAIRs
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'DEC-1.4-?AB7 L3t?5 From:DENIS0N MINES USRo
CC. RoNHocr{srErN
DavIn FRyTDENLIJNI)
HiTNOIO ROBNRTS
DAvIDTTIRK
Paset3t45334497oTo:91BEl1
DEMsot)dd
,WNES
DEC-14-?OZ7 13:25 r.or'PrsoN I"trNES usn To:9188153348q1 P6ss z 4/4
EXTItrBIT 2
INTERNAT NOSr[xCaTIoNg
Intemal lcportirg requiremen[s for Incidents, Spills and Significant Events ars as follows:
Renortlm4diately:
Event Criteria;
Release of toxic or haz.ardous substances.
Fire, explosions or other accidents,
Govemment investigariorrs information, I cqucst$ or enforcemerrt act ionu.hivate actiorx or clairns (corporations or ertrployees).
Deviotion's from Corporate pdlicies or gooenior.int rdquirenrants by Managoment.
Other signifioafl[ cvcnts, which havc resulted ol could result in:
peath, serious injrxy or"adverse_hefllrh effect (employees or public).Aopcrty damage exceeding $1,000,000.
Govcrurnent invostigation or entbrccrnent flction - limiting opetation or penaltiesof $100,000 or more.
Significanr crimi nal actioru.
SubsAntial media coverage.
Unscheduled downlirne of nore ftran 24 hours.
Report at thq,Fegitrning,,otthe Next Rusinees Dav:
hrcidenr Criteria:
Was reported te a gover.nm$nt agcncy as required bv law.Wotker (IUSA or Contractor)_rccorddble injury or iliness associated with a releace.Community impact - r.eporte<lor awartness.
Publicity resulted or is anticipatcd.
Release of . prccess ffqtsnql, wastre or product in exccss of the Reportable
Quantities li.qted in Section 1.5 oi' 0re Spill Preveption, Conrfoi, anaCountermcaeures PIan.
l'he local rnanagcr in chargc is to call Ron Hochatnin or Dave Frydenlund.
Naue Title OfticePhor_E Hoqlplhgng
R<rn l.Iochsrein (hesident End eOO)... ..3.03-6?g-77g9 (office)
604"931-6334 (home)
6M-177-1167 (ccil)
David Frydcnlund (v.P. and General couruel) ......... 303 -3 gg-4 130 (off,rce)
303-221-0098 (home)
303-80&6648 (ccil)
Mlstcr soFg\Book t 6-Ernargency Rquponcs Plan\Emergcncy Rerlxrnrc Plan Rcv 0 (02. 1a.07),b2
DENISONM
o
IN ES
February 19,2OO7
VIA OVERNIGHT DELIVERY
Mr. Dane L. Finerfrock
Director
Division of Radiation Control
Department of Environmental Quality
168 North 1950 West
P.O Box 144850
Salt Lake City, UT 84114-4850
Re: Ground Water Discharge Permit No. UGW370004, White Mesa Mill
Dear Mr. Finerfrock:
Pursuant to Section 1.H.17. of Ground Water Discharge Permit No. UGW370004, attached is a revised
copy of the Stormwater Best Management Practices Plan for the White Mesa Mill, incorporating the
changes and modifications requested in the January 5,2007 letter from Dave Rupp.
ll you have any questions, please feel free to contact me.
Yours very truly,
Deusorl Mnes (USA) Gonp.
fl-'?,'\ff^'a- -$)
S necarrzeri i'fr -"urr/€fi BEN
Q**:iir, da"zl-g
ffi%
Executive Vice President - U.S. Operations
Ron F. Hochstein
Dave C. Frydenlund
Steven D. Landau
Rich E. Bartlett
David Turk
Denison Mines (USA) Corp.
www.denlsonmlnes.com
1 050 1 7th Street, Suate 950
Denver, CO, USA 80265
Tel : [phone]
Fax : 303 389"4125
NI UC
Tel:[phone]
Fax: [phone]
.(ro
fu*,sq"
INTER'\'ATIONAL URANIUM (UsA) CORPORATION
February 3,2006
ffu"'/{f,'"
Re: Ground Water Discharge Permit No. UGW370004, White Mesa Mill
Dear Mr. Finefiock:
Pursuant to Section l.H.17. of Ground Water Discharge Permit No. UGW370004,
attached is a copy of the Stormwater Best Management Practices Plan for the White Mesa
Mill.
If you have any questions please feel free to contact me.
Very tnrly yours,
/ , / ,") ./ /n "^ffi'Zm
Harold R. Roberts
Vice President - Corporate Development
cc: Ron F. Hochstein, IUSA, w/ attachment
David C. Frydenlund, IUSA, d attachment
Rich E. Bartlett, ruSA, w/ attachment
David E. Turk, IUSA, w/ attachment
VIA OVERNIGIIT DELTVERY
Mr. Dane L. Finerfrock
Director
Division of Radiation Control
Deparfrnent of Environmental Quality
168 North 1950 West
P.O Box 144850
Salt Lake City, UT 84114-4850
1050 Seventeenth St., Suite 950
Denver, Colorado, USA 80255
[e-mail]
www.intluranium.com
l
roN M. rrIsMAN, rR
Governor
GARY HERBERT
Lieutenant Governor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OFRADIATION
CONTROL
Dane L. Finerfrock
DirecTor
July 1,2008
Mr. Steven D. Landau
Manager Environmental Affairs
Denison Mines (USA) Corporation
1050 Seventeenth Street
Denver, CO 80265
Dear Mr. Landau:
Subject:June 13, 2008 DUSA Letter; June 2008 White Mesa Mill Revised StormWater Best
Management Practices Plan (SWBMPP); March 17,2008 Utah Ground Water Discharge
Permit No. UGW370004; February 2007 DUSA StormWater Best Management Practices
Plan: Approval of Revised Plan
We received your subject letter dated June 13, 2008 conveying a revised Storm Water Best Management
Practices Plan dated June 2008. This updated plan was submitted in fulfillment of requirements contained
in Part I.H.16 of the Ground Water Discharge Permit to address the effects of construction of Tailings Cell
4A. We have reviewed the plan, and it is hereby approved.
The original deadline for submittal of the subject revised plan was May 15, 2008. As mentioned in Mr.
Morton's email of June 9, 2008, the DRC elected to use enforcement discretion in this matter. In lieu of an
enforcement issue, approval of this plan was made a condition to be satisfied prior to DUSA operating the
relined Cell 4A at the White Mesa Uranium Mill. Final approval to use Cell 4.A' will be issued at a later
date, after resolution of other outstanding items communicated to you previously.
If you have any questions on the above, please contact Dave Rupp.
UTAH WATER QUALITY BOARD
Dane L. Finerffdck, Co-Executive Secretary
DLF/DAR: dr
F:\Rad ConEolUUC\G.w.D.P. Related Docs\SW Mgt.\Updrted Plan Approval0T-01-08 File: Ground Water File lzt0
168 North 1950 West . PO Box 144850 . Salt Lake City, UT 841 l4-4850 . phone [phone]' fax [phone]
T.D.D. (801 ) 536-441 4 . wwu,.deq.utah. gov
,o*tr*oMAN,rR
Goyernu.
CARY HERBERT
Lieutenant Govenutr
O6
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, ph.D.
Executive Director
DIVISION OFRADIATION
CONTROL
Dane L. Finerfrock
Director
November 2l,Z0O7
Certified Mail
(Return Receipt Requested)
Mr. Steven Landau
Environmental Manager
Denison Mines (USA) Corporation
1050 lTth Street, Suite 950
Denver, CO 80265
Dear Mr. Landau:
Subject:Denison Mines (usA) corporation (DUSA) white Mesa Miil FacirityDT.c Inspection Results: Storm water Besi Management-practices plan(Engineering Module 77) August 2g, october ll,-and october 3l,z0o7DRC Review Findings and Request for Information
An inspection was held on the subject dates at the DUSA mill facilities near Blanding, utah withMessrs' David Rupp of the DRC and David rurk of DusA. Details of the inspection module arediscussed below.
The Storm Water.Best Management Practices Plan, Modu le 7i ,was reviewed. This was the,first DRC inspection regarding this module. via weekly inspections, the DUsA staff is to :identify areas requiring maintenance or repair, such as excessive vegerative #iiir,'.i"rl.lierosion or pooling of surface water runoff. ' * -l
Two large areas with pooling storm water were identified during this inspection. Elimination ofsuch areas is one of the targets of the Storm water Best Manag*"rt practices plan. rvrr vr
The Mill was constructed with overall grades and diversion ditch systems designed to dhannelall surface runoff, up to the Probable Maximum Flood event, to the tailings #;;;;;#;H,.,(Storm Water Best Management practices plan 2.0).
i
i168 Norrh lg50 Wcsr . pO Box t44950. Salr Lake Cit_y. trT 84t t4_4g50. phone (g0t) 536-4?.t50. fax (801) 5j:j_4097 ..,.
T. D. D. (80 I ) 53(t-44I 4 . wrttr.tl et1. u ta h. gr n.
t Mr. Steven Landau
Engineenng Module 77
Page 2
Storm water problem areas discovered by DUSA staff during required weekly inspections are to
be reported to DUSA site management and maintenance departments for necessary action. The
status of such construction, maintenance and repairs are to be documented during follow up
inspections (Storm Water Best Management Practices Plan, paragraph 4.L.4).
It was noted during the inspection that all tanks containment vessels are in process of being
replaced by DUSA in-house workers. These vessels will have reinforced concrete or steel
walled vessels for spill containment. Interior walls will be sprayed with "Rhino liner" type
material. This new spill containment project is slated for completion about March 2008.
The Ground Water Discharge Permit requires any new construction of reagent storage facilities
(after March 8, 2005) to have secondary containment and control to prevent any contact of the
spilled or otherwise released reagent or product with the ground surface (Ground Water
Discharge Permit I.D.3.e).
DRC review of DUSA records showed that there were no spills or reportable spills recorded
since the beginning of the Storm Water Best Management Practices Plan was implemented
(May 9, 2007). The Ground Water Discharge Permit requirement for the Storm Water Best
Management Practices Plan is to include the "cleanup spills of stored reagents or other
chemicals at the mill site immediately upon discovery" (I.D.8.c), and that the company must
report reagent spills or other releases at the mill site to the Executive Secretary in accordance
with Utah Code, Title l9-5-114 (LD.S.d).
Pertaining to Storm Water Pooling:
1. The first two site visits took place on the day following rainstorms, so it was easy to locate
areas of pooling water. There were random locations of large puddles of storm water , both
in and out of the tailing cells proper. These varied about 10-25 feet in diameter, and from a
few to several inches in depth. Initially, there were about 15 such pools. Mr. Turk reported
that he and Mr. Bartlett of DUSA discussed possible methods to eliminate these pooling
areas. Puddles within the tailings ponds are not considered an issue. During later site visits
on October 11 and 3I,2007 , it appeared grading had been implemented and had eliminated
most of the "puddle areas" on the roads and just east of the tailings cells.
2. The two largest pools of storm water were separately identified. One is located in the
boneyard area just north of the fence and propane tank. On August 28,2001 it appeared to
have surface dimensions of about 30 by 3O-feet and about 6-inches deep. This pool
overflows south across the road and through the chain link fence to a marshy area south of
the sulfuric acid tank. This pond has probably existed for several years. Tall tamarisk and
other plants were observed to be growing nearby, attesting to the age of the pool. By
October 31,2007, the bulk of the pool had been filled in, however it appeared additional
effort is still needed to eliminate this stagnation.
3. The other pooling area was much larger. It is Iocated southwest of the mill building in the
former fly ash storage area. Its rough dimensions were 150 by 4O-feet and about 5-inches
deep. It receives runoff from the most southern mill buildings, office and ore storage areas.
Some of the drainage into this area is the result of new westbound ditches discharging to the
Mr. Steven Landau
Engineering Module 77
Page 3
pool. Progress was noted in later site visits, and by October 31,2007 , the bulk of the pool
had been filled in.
4. Monitoring of these two large pool areas, needs to be continued to assure the pools are
eliminated and free-draining conditions to Cell 1 maintained. Therefore, we request a copy
of DUSA's written plans and schedule for the elimination of these pools.
5. All stand alone copies of the Emergency Response Plan (ERP), as well as all copies of the
ERP incorporated into the Storm Water Best Management Practices Plan, need to include a
provision. The last indented line in the ERP (e.g. in the Storm Water Best Management
Practices Plan, Exhibit 2) under "Report at the Beginning of the Next Business Day,"
should be revised to not conflict with listed reportable quantities found in Section 1.5 of the
Spill Prevention, Control and Counterrneasures Plan. This item was originally requested in
the DRC January 5,2007 comment letter on the storm water plan for plan approval. Mr.
Turk indicated that DUSA will make the change.
Mr. Turk also mentioned DUSA would like such internal inspection report records to be relaxed
from weekly to quarterly. DRC plans to see how well DUSA can eliminate problems associated
with storm water, prior to making any adjustment on the approved inspection frequency.
In our telephone conversation on November 21,2007, you committed to fully respond in writing on
or before December 14,2OO7 regarding paragraphs 4 and 5 above. If you have any questions or
comments on this matter, please contact me at [phone].
Geotechnical Services Section
DAR: dr
Cc: John Hultquist, DRC
F:\Rad\lnspections\2007 draft XmtlModule 77 SWBMPPI I -07
File: DMC 03.04
State of ljtah
Department of
Environmental Quality
Richard W. Sprott
Exet:utive Director
DTVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
TO:
FROM:
DATE:
,o* ,. ,OMAN, rR
Gtnernor
GARY HERBERT
Lieut(nant Goverrutr
MEMORANDUM
DUSA Ground Water File 140
Storm Water Best Management Practices Plan Inspection
Engineering Module 77ox"wffi
November 19,2007
SUBJECT: Some Brief Thoughts, Inspection Module and Pictures
The attached module form and pictures give a general overview of the storm water management
situation at DUSA. The mill has pursued the grading of the large pools quite vigorously.
New spill containment vessels are being constructed around reagent and other tanks. The
adequacy of the volume of these containments needs to be evaluated in a separate inspection and
review in 2008.
Also in the future, the marshy depression acting as a sump, south of the sulfuric acid tank needs to
be removed and drainage corrected. There is probably room for drainage improvement to be
elsewhere via the Storm Water Best Management Practices Plan and Module 77. Ireviewed with
Mr. Turk my thoughts that storm water management is an ongoing cooperative issue.
168 Norrh 1950 Wesr. PO Box 144850. Salt Lake City. tlT 841 l4-4850. phone (801y 536-4250. fax [phone]O9-l
T.D.D. (80I ) 536-441 4 . x t u'.deq.utah. Sol
Inspection Module 77 for the DUSA
Storm Water Best Management Practices Plan
Site visits were August 28, 2007and October 11, 2007
General Sites Observations:
This is the first inspection performed by DRC on this module. The DUSA Storm
Water Best Management Practices Plan was approved on April 3,2007 by the DRC.
It includes weekly inspection of drainage coincidental to DMT and other inspections.
The DUSA staff is to identify and eliminate problems areas of pooling water, caused
by improper grading and plugged ditches, drainage and process sewer piping systems.
Areas of concern identified during this inspection include pooling storm water areas
and storm water traveling over road surfaces. Elimination of pooling water and storm
drainage crossing roads are targets of the Storm Water Best Management Practices
Plan. Ditches should be maintained to rapidly channel runoff under roadways using
culverts, rather than over road surfaces, to prevent ground water infiltration and road
damage.
Problem areas are to be reported to site management and maintenance departments
for necessary action to perform reconstruction in order for the control feature to
perform as intended. The status of such construction, maintenance and repairs are to
be documented during follow up inspections, and additional action taken if necessary.
Documentation of construction, repairs and maintenance for storm water management
should be checked in future Module 77 inspections.
Reasent Tank Facilities:
Are there any new reagent tank facilities?
Yes. All tanks containment vessels are in process of being replaced by DUSA in-
house workers. These vessels will have reinforced concrete walled vessels for spill
containment. Interior walls will be sprayed with "Rhino liner" type material. This
new spill containment project is slated for completion about March 2008.
The Ground Water Discharge Permit requires any new construction of reagent storage
facilities (after March 8, 2005), secondary containment and control to prevent any
contact of the spilled or otherwise released reagent or product with the ground surface
(Ground Water Discharge Permit I.D.3.e).
Spills:
Any spill records?
No. The permit requirement for the Storm Water Best Management Practices Plan is
to include the "cleanup spills of stored reagents or other chemicals at the mill site
immediately upon discovery" (I.D.8.c).
Reportable spills?
No. The permit requirement that a Storm Water Best Management Practices Plan
include that the company must report reagent spills or other releases at the mill site to
the Executive Secretary in accordance with Utah Code, Title l9-5-114 (I.D.8.d).
Pertainins to Storm Water Pooling:
It is the objective of both the grading on site and the Storm Water Best Management
Practices Plan that runoff from the mill system (which includes areas around the
tailings ponds) be channeled into the tailings cells or the Roberts Pond, but not into
other pools. It is an objective of the approved plan to eliminate pooling of drainage.
Site visits took place on days following rainstorms, so it was easy to locate areas of
pooling water. There were random locations of large puddles of rainwater, both in
and out of the cells proper. These varied about 10-25 feet in diameter, and from a
few to several inches in depth. There were about 15 such pools. Mr. Turk reported
that he and Mr. Bartlett of DUSA discussed possible methods to eliminate these
pooling areas. Puddles within the tailings ponds are not considered an issue.
There were also two large pools of storm water identified. One is located in the
boneyard area north of the propane tank. Its depth on August 28,2007 appeared to be
about 6-inches. It overflows south across the road and through the chain link fence to
a marshy area south of the sulfuric acid tank. This pond has probably existed for
several years. Tall tamarisk and other plants are growing nearby, attesting to the age
of the pool.
The other pooling area was much larger. It is located southwest of the mill building
in the former fly ash storage area. It receives runoff from the most southern mill
buildings, office and ore stacking areas. Some of the drainage into this area is the
result of new westbound ditches discharging to the pool.
On the second site visit on October 11,200J, it appeared grading had been
implemented to eliminate most of the "puddles" in the tailings area. And, some
efforts had been made to grade the two large pools to drain. However, these large
pools were still significant in size. Mr. Turk explained that DUSA would be
installing facilities to drain and eliminate these pools. Procedures would be
implemented to maintain the facilities as well.
These ponds must be eliminated, and methods of maintaining their drainage
implemented.
Drainage Crossing Roads:
Drainage from the large pools was crossing adjacent roads on both days of inspection.
Specifically drainage crossing the road east of Cell I and north of the propane tank
were evident on both August 8,2007 and October 11,2007. This problem is linked
to the method chosen to convey drainage across these roads.
Is the Storm Water Best Management Practices PIan kept on file? Yes
Is the SPCCP kept separately on file? No. It has been consolidated with the SWBMPP.
Is the ERP kept separately on file? Yes. It is kept separately in the central vault files.
Is the DMT Monitoring Plankept separately on file? Yes. It is kept separately in the
central vault files.
In Exhibit 2 of the ERP, the last indented line under "Reporl at the Beginning of the Next
Business Day," should be revised to not conflict with listed reportable quantities found in
Section 1.5 of the SPCCP. Mr. Turk indicated that DUSA will do such.
Records of storm water related necessary maintenance being kept (Section 4.1.4)?
Status of maintenance and repairs are to be documented during weekly follow-up
inspections, and additional actions taken if necessary. No check of documentation was
performed.
Weekly inspection records kept? Only applicable in cases where maintenance and repairs
are necessary, per the above. Mr. Turk mentioned DUSA would like such internal report
records to be changed to quarterly from weekly.
Reference from the Storm Water Best Management Practices Plan:
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within
the Process and Reagent Storage Area.
Diversion ditches, drainage channels and surface water control structures in and
around the Mill area will be inspected at least weekly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370 004,
and Byproduct Materials License #UT1900479. Areas requiring maintenance or
repair, such as excessive vegetative growth, channel erosion or pooling of surface
water runoff, will be report to site management and maintenance departments for
necessary action to repair damage or perform reconstruction in order for the control
feature to perform as intended. Status of maintenance or repairs will be documented
during follow up inspections and additional action taken if necessary.
F:\DUSA\ inspections\ Eng lnspections \2007 draft Module 77:8-28 & l0- I I .doc
Page 7 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
Looking East. Photo depicts some drainage to or from the boneyard drainage pond, which is
out of the picture, on the left. The drainage is flowing north or south.
View SE cor C-l. Likely well pumpage from pipe from difficult to see black pipe rn
foreground.
Page 8 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
View l: Drainage pooling from office area, ore pad, etc. Location E of C-1.
Same pool as above, view further north.
Page 9 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
Same pool as above, further north, the outlet is flowing northwest across frontage road.
Same pool as above, view further north.
Page 10 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
High mound of inert cover between cells C-2 & C-3.
Page I White Mesa Uranium Mill
Photographs taken 8-28-07 regarding the Storm Water Best Management Practices
Plan inspection. Photos taken the day following two days of successive rain storms.
N dike C-l
Small diameter discharge line to Cell 1.
Page2 of photos.
Storm Water Best Management Practices Plan
New tank spill containment system, in construction mill-wide.
Pipe crossing beneath dike at Cell I east-side.
Page 3 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
Tlpical distinct after-storm puddles on a dike top road.
Drainage pipe from'\retland area" near H2SO4 tank. Note new backfill.
Page 4 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
-t*,
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Page 5 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
Another view of previous. Drainage way in wetland areajpg
New inlet box at SW comer of the ore pad.
Page 6 of photos regarding the
Storm Water Best Management Practices Plan
08-28-07.
Boneyard drainage pond and flow on right ofphoto.
The boneyard drainage pond
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DUSA Photo
Storm Water Best Management Practices Plan
Taken October 31,2007 - - D.A.R.
Covered ore trucks from Tony M mine unloading in north west ore pad area.
aJON M. HI.J}TTSMAN, JR.
Govemor
GARYHERBERT
Lieutenant Governor
State of Utah
Department of
Environmental Quality
Danne R Nielson, Ph.D.
Executive Director
DTVISION OF RADI,ATION
CONTROL
Dane L. Finerfr,ock
Direclor
TO:
FROM:
DATE:
MEMORANDUM
FILE IUC0I.l4a
Dave Rupp, Envir. nnglneer fu
April23,2007
SUBJECT: FILE IUC01.l4a and the File Location of the
Storm Water Best Management Practices Plan Information
Denison Mines (USA) Corporation (DUSA)
Subsequent to the above date, the Storm Water Best Management Practices Plan
documents and related approval/comment correspondence will generally be placed in the
Ground Water File 140. This is due to the fact that such plans at Denison Mines (USA)
Corp.'s White Mesa mill are a requirement of DUSA's Ground Water Discharge Permit.
168 North 1950 we.st . Po Box 1,14E50. Salt Lake City, UT E4l144E50 . phone [phone]. fax (801) s334097
T.D.D. (801 ) 5364414 . www.deq.utah.gov
a
HUNTSMAN,
Govemor
JON M
GARY HERBERT
Lieutenant Governor
State of Utah
Department of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OF RADI,ATION
CONTROL
Dane L. Finerfrock
Direclor
April23,2007
Mr. Harold R. Roberts
Executive Vice President - U.S. Operations
Denison Mines (USA) Corporation
1050 Seventeenth Street
Denver, CO 80265
Dear Mr. Roberts:
Subject:March 8, 2005 Utah Ground Water Discharge Permit No. UGW370004; DUSA
Storm Water Best Management Practices Plan, oiginal plan dated February 3,
2006 and revised plan dated February 19,20O7: Approval of Revised Plan
On April 18,2OO7 we received your email transmitting a revised page four, for insertion into the
subject plan. With this change included, the Storm Water Best Management Practices Plan dated
February 2OO7 is hereby approved. This plan is to support in fulfillment of the Ground Water
Discharge Permit requirements contained in part I.H.17 of the permit.
Therefore, as required in permit part I.H.17, DUSA should now immediately implement all
provisions of the plan. If you have any questions on the above, please contact Dave Rupp.
UTAH WATER QUALITY BOARD
bck, Co-Executive Secretary
DLF/DAR: dr
F:\Rad ControlVUC\G.W.D.P. Relilted Docs\SW Mgt.\Plan Approval 04'07
File: Ground Water File ItlO
168North tg50West.POBox 144850.Saltl-akeCiry.UT84t 14-4850.phone[phone] 'fax[phone]
T.D.D. (80 I ) 536-441 4 . \'A'A'.deq. utoh. got,
"gt
Page I of 2
From: "Harold R. Roberts"
To: "'Dave Rrpp"'
Date: 411812007 10:39 AM
Subject: RE: Storm Water Best Management Practices Plan
Attachments:
Dave:
Attached is a pdf of page 4 of the revised BMP Plan with the latest revisions. Please insert and replace this page in the latest Plan
submittal. Let me know if you need any additional input.
I r : 'a o ,.'ail
From: Dave Rupp Imailto:[e-mail]]
Sent: Thursday, April12,2007 3:50 PM
To: Harold R. Robeds
Subject: Re: Storm Water Best Management Practices Plan
Hi Harold,
I have reviewed the changes you conveyed via your email of 415107, and I feel it is sufficient for approval. Please transmit
appropriate inserts or a new copy of the plan, including the changes, for our formal approval. Thank you.
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake City, UT 84114-4850
Telephone [phone]
Fax (801) s33-4097
Email: [e-mail]
>>> "Harold R. Roberts" <[e-mail]> 41512007 9:47 AM >>>
Dave:
Please see attached modifications to section 4.1.4 of the BMP plan. I
understand you are out of the office until next week. i will call you next
file://C:\Documents and Settings\Drupp\Local Settings\Temp\XPgrpwise\4625F56FEQDOMAINEQRADl... 4ll812007
Page 2 of 2
week to see if this is sufficient.
Regards,
Harold R. Roberts
Executive Vice President - U.S. Operations
Denison Mines (USA) Corp.
[phone]
file://C:\Documents and Settings\Drupp\Local Settings\TempU(Pgrpwise\4625F56FEQDOMAINEQRADl... 411812007
a
Best Management Practices Plan
Revision 1.1: February 2007
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1, General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil. and Surface Water:
o Store hazardous materials and other potential pollutants in appropriate containers.. Label the containers.o Keep the containers covered when not in use.
4.L.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.
o Replace or repair broken dumpsters and bins.o Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.L.3 Keep Paved Areas from Becoming Pollutant Sources
o Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1,.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
o 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 #UT1900479. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be report to site management and maintenance departments for necessary action to repair
damage or perform reconstruction in order for the control feature to perform as intended.
Status of maintenance or repairs will be documented during follow up inspections and
additional action taken if necessary.
4.1,.5 Recycle Fluids Whenever Possible:
o When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed.
. When possible, select consumable materials from suppliers who will reclaim empty
containers.o Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 4
Page 1 of 1
Dave Rupp - Storm Water Best Management Practices Plan: Paragraph
4.L.4
From: Dave Rupp
To: Harold R. Robefts
Date: 31812007 4:37 PM
Subject: Storm Water Best Management Practices PIan: Paragraph 4.L.4
CC: Loren Morton
Hi Harold,
I am finished reviewing the subject SWBMPP plan. I appreciate your responses. Only
coflrment number five in our letter of January 5, 2007 seems unresolved. If you resubmit
the subject section4.I.4to be very specific on what, how and when the recurring
inspection and maintenance will be done, I believe the plan would be complete. Please
contact me if you have questions on this.
David A. Rupp, P.E.
Utah Division of Radiation Control
P. O. Box 144850
Salt Lake city, uT 84114-4850
Telephone (80 I ) 536-4023
Fax [phone]
Email: [e-mail]
file://C:\Documents and Settings\Drupp\Local Settings\Temp\XPgrpwise\45F03BC6EQDOMAINEQRADI... 312612007
o
HI.'NTSMAN,
Govemor
State of Utah
Department of
Environmental Quality
Dianne R. Nielso, Ph.D.
Executive Direcnr
DTVISIONOFRADI,ATION
CONTROL
Dane L Finerfrock
Dircctor
JON M.
GARY HERBERT
Ueutenant Govemor
January 5,2W7
Mr. Harold R. Roberts
Denison Mnes (USA) Corporation
1050 Seventeenth Street
Denver, CO 80265
DearMr.Roberts:
March 8, 2005 Utah Ground Water Discharge Permit No. UGW37ON4; February
3,2006 ruSA StormWater Best Management Practices Plan: Unresolved Issues
and Request for Information
On December 5, 2006, you, Loren Morton and David Rupp visited the White Mesa Mill facilities,
and reviewed storm drainage configurations concurrent with our review of the subject storm water
plan. We have the following comments on the plan:
l.The permit requirement that for any new construction of reagent storage facilities (after March
8, 2005), secondary containment and control shall prevent any contact of the spilled or
otherwise released reagent or product with the ground surface (Ground Water Discharge
Permit I.D.3.e), needs to be incorporated appropriately into the plan.
The permit requirement for the Storm Water Best Management Practices Plan to include the
"cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery" (I.D.8.c), needs to be incorporated appropriately into the plan.
The permit requirement that a Storm Water Best Management Practices Plan include that the
company must report reagent spills or other releases at the mill site to the Executive Secretary
in accordance with UAC [sic] [Utah Code, Title] L9-5-Ll4 (I.D.8.d), needs to be incorporated
appropriately into the Plan.
The statements that no water effluents leave the site (plan section 1.0), should indicate
contaminated surface water effluents. A statement needs to be added, indicating ground water
is the water most likely to be impacted by the mill.
The diversion ditches, drainage and process sewer piping systems for the mill site are
referenced as an important part of ground water pollution prevention. Therefore,
168 North 1950 Wcst. PO Box 1,14850. Salt lake City, UT 841 14-4850. phone (E0l) 5364250. fax (801) 533-'1097
T.D.D. (801 ) 5364414. www.deq.utah. gov
2.
3.
5.
Mr. Harold Roberts
January 5,2007
Page2
appropriate recurring inspection and maintenance of these facilities needs to be in the plan.
The plan needs to specify what, how and when inspection and maintenance will be done.
Ditches should be maintained to rapidly channel runoff under roadways using existing
culverts, rather than over road surfaces.
6. Indicate the location of the disposal area for paint dust and chips (sect. 4.3.3).
Appendix I: Since the Spill Prevention, Control, and Countenneasures Plan (SPCCP), dated
September 2005 in appendix I is referenced for use with the StormWater Best Management
Practices Plan (section 2.0), we provide the following comments on the SPCCP:
7. In the SPCCP the last sentence of Section L.5.7 ., the reportable quantity for a sulfuric acid
spill should be adjusted to agree with the reportable quantity in the Table 5 of the Storm Water
Best Management Practices Plan.
8. In Section 1.1, the pollution prevention goals related to the Ground Water Discharge Permit
should be mentioned, to clarify the applicability of the SPCCP to ground water protection.
g. Flow paths and diversion ditches are mentioned many times in the plan. The ditches are
emphasized as important in rapid conveyance to containment. Therefore, all drainage ditches
on company property need to be shown on a drawing. Please also, specifically include the
following:
A. Ditches that are specifically mentioned within Section 1.4 regarding drainage basins Al,
A2,Bl andBZ.
B. Indicate how the runoff is to be channeled along the southern edge of basin C into Cell 2
(Section 1.4.6).
C. Indicate how basin D contains all flows (Section 1.4.7)-
10. In Section 1.5 the "reportable quantities" listed may be a good starting place for internal
evaluation. However, if the "reportable quantities" are undersized, the company is still
responsible for any spill which causes or may cause pollution.
11. In the first sentence of section 1.9.1 the phase, "and therefore not be reportable," should be
deleted.
12. Section l.9.2,ltem 5 under "Report at the Beginning of the Next Day," should be revised to
not conflict with listed reportable quantities found in Section 1.5.
13. Section 1.13 the reportable quantity of sulfuric acid listed should be revised, if needed, to not
conflict with other sections.
Appendix tr: Since the Emergency Response Plan (ERP), dated September 29,2005,is
referenced for use with the Ground Water Discharge Permit (I.D.3.e) and the Storm Water Best
Management Practices Plan (2.0), we are providing the following comment on the ERP:
14. In Exhibit 2 of the ERP, the last indented line under "Report at the Beginning of the Next
Business Day," should be revised to not conflict with listed reportable quantities found in
Section 1.5 0f the SPCCP.
. Ivk. Harold Roberts
January 5,2007
Page 3
Please review the above comments, and incorporate appropriate changes into final revised
documents, and resubmit for approval on or before February 19,20A7. If you have any questions
on the above, please contact me.
Sincerely,
(
^r"'-t*@
David A. Rupp, P.E. \
Geotechnical Services Section
DAR:dr
F:\Rad Conrol\IUC\G.W.D.P. Relatcd Docs\SW M6.E.EI. I Jan 2007
ffiF
OLENES. WALKER
Governor
GAYLE F. MCIGACHNIE
Lieutenant Governor
*$,v, i f ,l-.. . , ".;
State of Utah
Deparfinent of
Environmental Quality
Dianne R. Nielson, Ph.D.
Executive Director
DTVISION OF RADIATION
CONTROL
Dane L. Finerfrock
Director
December 6,2004
David C. Frydenland
International Uranium (ruSA) Corporation
1050 Seventeenth Street
Denver, CO 80265
Subject: Stormwater Best Management Practices Plan July 17, 2001 - Draft - for Review and
Comment
Dear Mr. Frydenland,
We have reviewed the Draft Stormwater Best Management Practices Plan dated July 17, 2001.
As you will recall, the draft groundwater discharge permit, that is curently in process, requires
IUC to submit this plan for Executive Secretary approval (Part I.H.17). In order to expedite this
process have completed this review and we have several changes that we would like to see prior to
issuing our approval. Please revise the plan to address and resolve the following issues:
l. Add the Utah Division of Radiation Control to the contacts list in case of a spill,
tailings embankment failure, or emergency.
2. Many of the reportable quantities in the report are taken from 40 CFR I17.
However, some are defined as, "a 'reportable quantity' will be defined as quantities
... which could be expected to reach navigable waters of the United States." (i.e.
Section 1.5 of the Spill Prevention, Control and Counteflneasures Plan) Statements
as to where the all of the Reportable Spill Quantities listed in the report are taken
from or how they were derived need to be included in the final report.
3. Any additional updates that have been made to the Stormwater Best Management
practices Plan; Spill Prevention, Control, and Counterneasures Plan for Chemicals
168 North 1950 West. PO Box lrl4850 . Sah Lake City, UT 841 14-4850. phone [phone] 'fax [phone]
T.D.D. (801) 53$-1.!,1Q, ' vrytv.4,q.utah.gov
lltah!
Where ideas connecl*
Page2
and petroleum Products; and the Emergency Response Plan that have been made in
the past three Years.
If you have any questions or cofilments, please contact me at [phone].
JPC: jc
F:\FACILITIESWC - WHITE MESA\Ore Pad Seepage\2004-12-06 lrtter - Spill Management Plan - final.doc
File: IUC.0I.09.A
Dane Finerfrd[, Director
Division of RXdiation Control
for
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STORMWATER
BEST MANGEMENT PRACTICES PLAN
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
June 2008
Nr
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
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TABLE OF'CONTENTS
1.0 Purpose2.0 Scope3.0 Responsibility4.0 Best Management Practices4.1 General Management Practices Applicable to All Areas4.2 Management Practices for Process and I_aboratory Areas4.3 Management Practices for Maintenance Activities4.4 Management Practices for Ore Pad, Tailings Area, and heavy Equipment
Operations
Figures
Figure I White Mesa Mill Site Map
Figure 2 Mill Site Drainage Basins
Figure 3 ruSA Mill Management Organization Chart
Figure 4 ruSA Corporate Management Organization Chart
Tables
Table I White Mesa Mill Management Personnel Responsible for Implementing
This BMPP
Appendices
Appendix I White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
Appendix 2 White Mesa Mill Emergency Response plan
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Best Management Practices Plan
Revision 1.3: June 12,2008
1.0 INTRODUCTION/PURPOSE
Denison Mines (USA) Corp. ("DUSA") operates the White Mesa Uranium Mill ("the Mill) in
Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect to
water effluents. That is, no water leaves the Mill site because the Mill has:
o flo outfalls to public stormwater systems,
o no surface runoff to public stormwater systems,
. no discharges to publicly owned treatment works ("POTWs"), and
o ilo discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to DUSA on March 8,
2005. As a part of compliance with the Perinit, DUSA is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spills of chemicals or hazardous materials, which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices in a good faith effort to minimize all sources of
pollution at the site.
Page I
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I 2.0 scoPE
Best Management Practices Plan
Revision 1.3: June 12,2008
I This BMPP identifies practices to prevent spills of chemicals andhazardous materials used inr process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
I atErfrete reediffilffi*" p;a;;na-con"i -ffieTdill tailingslmpoundmentr system are not considered "spills" for the purposes of this BMPP.
I ( The Mill site was constructed with an overall grade and diversion ditch systan designed to
] channel all surface runoff, including precipitation equivalent to a Probable Maximum
I I Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
t Lsystem. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
I transferred to one or more of the tailings cells in accordance with the Mill's NRC license
t conditions. Al1 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
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sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
I minimizing the introduction of chemical and solid waste and wastewater into the process sewersr and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
washdown to the process sewers, and ultimately the tailings system. However, as good
I environmental management practice, the Mill attempts to minimize:
r 1) the number and size of material spills, and
I 2) the amount of unrecovered spilled material and washwater that enters the process sewers
after a spill cleanup.
t Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
I Requirements and methods for management, recordkeeping, and documentation of hazardous
I material spills are addressed in the DUSA White Mesa Mill Spill Prevention, Control and
Countermeasures ("SPCC") Plan Revised February 2007, the Emergency Response Plan
I ("ERP"), also revised in February,2007, and the housekeeping procedures incorporated in the
t White Mesa Mill Standard Operating Procedures ("SOPs"). The SPCC plan and the ERP are
provided in their entirety in Appendices 1 and 2, respectively.
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I Best ManageT:r,i#:,ff:,,xi;
I 3.0 RESP,NSIBILITY
I All Mill personnel are responsible for implementation of the practices in this BMPP. DUSAr White Mesa Mill managernent is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP.
I The Mill Managemen tOrganization is presented in Figure 3. The DUSA Corporate
I
ManagementOrganization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table 1.
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'""#ll,ffiTl iJff'ff,'o,6;4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil. and Surface Water:
o Store hazardous materials and other potential pollutants in appropriate containers.o Label the containers.
. 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.o Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
o Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
o 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 scheduledf
inspections required by Groundwater Discharge Permit No. UGW3 70004, and t
Byproduct Materials License #UTl900479. Areas requiring maintenance or repair, such )
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will I
be report to site management and maintenance departments for necessary action to repair[
damage or perform reconstruction in order for the control feature to perform as intendedJ
Status of maintenance or repairs will be documented during follow up inspections and
additional action taken if necessary.
4.1,5 Recycle Fluids Whenever Possible:
o When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed.
o When possible, select consumable materials from suppliers who will reclaim empty
containers.
o Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 4
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4.2
4.2.1
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Best ManageT:f i#Iff: ;Jsl
Management Practices for Process and Laboratory Areas
Clean Up Spills Properly
Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums)
instead of water whenever possible.
Clean spills of stored reagents or other chemicals immediately after discovery.
(Groundwater Discharge Permit No. UGW370004, Section I.D.S.o.)
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
cleanup.
4.2.2 Protect Materials Stored Outdoors
If drummed feeds or products must be stored outdoors, store them in covered or diked
areas when possible.
If drummed chemicals must be stored outdoors, store them in covered or diked areas
when possible.
Make sure drums and containers stored outdoors are in good condition and secured
against wind or leakage. Place any damaged containers into an overpack drum or second
container.
4.2.3 Water Management
o When possible, recycle and reuse water from flushing and pressure testing equipment.
o When 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.
4.2.4 Materials Management
o Purchase and inventory the smallest amount of laboratory reagent necessary.
o 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, or otherwise released
reagent or product, with the ground surface. (Groundwater Discharge Permit No.
UGW370004, Section I.D.3.e.)
Page 5
liI Best Management Practices Plan
Revision 1.3: June 12,2008
I 43 Management Practices for Maintenance Activities
I 43.1 Keep a Clean Dry Shop
o Sweep or vacuum shop floors regularly.
I il:rrr.T:5specific
areas indoors for parts cleaning, and use cleaners and solvents only in
I . Clean up spills promptly. Don't let minor spills spread.
I o Keep supplies of rags, collection containers, and sorbent material near each work area
r lff:"rtl,7ffiifl*; fluids, and batteries in an area with secondary containment
I (double drum, drip pan) to capture leakage and contain spills.
I 4.3.2 Manage Vehicle Fluids
o Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as
I possible. Use drip pans or plastic tarps to prevent spillage and spread of fluids.r o Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle,
or disposal.
I o Recycle automotive fluids, if possible, when their useful life is finished.
r 4.3.3 Use Controls During Paint Removalto Use drop cloths and sheeting to prevent windborne contamination from paint chips and
I sandblasting dust.
I o Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a
disposal location in the tailings area authorizedto accept waste materials from
I
maintenance or construction activities.
I 4.3.4 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
I [:;;1#:.",r.","oor", paint whenever possible.
r o Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
I :rf?;lil.rrr.;and.containers
only at sinks and stations that drain to the process sewer to
I o Paint out brushes to the extent possible before water washing (water-based paint) or
I solvent rinsing (oil-based paint).o Filter and reuse thinners and solvent whenever possible). Contain solids and unusable
t
excess liquids for transfer to the tailings area.
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I Best Manage?:r'ifi:'iT:;,iiil
I 4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
I 3T:,iX,,,llH:1"*
for ore unloading, dust suppression, and tailings manasement are provided
I 4.4.1 Wash Down Vehicles and Equipment in Proper Areas
r o Wash down trucks, trailers, and other heavy equipment only in areas designated for this
I purpose (such as washdown pad areas and the truck wash station).
I fJr:T lffil,:1'l;?[::#*: sure the water couection and recvcring svstem is working
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
I
ilfiffiffJll
the ore pad and unpaved areas at appropriate frequency in accordance with
I o Water spray stockpiles as required by opacity standards or weather conditions.r o Don't over-water. Keep surfaces moist but minimize runoff water.
I 4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
r . Schedule excavation, grading, and other earthmoving activities when extreme dryness and
t high winds will not be a factor (to prevent the need for excessive dust suppression).
a : fffi"J.",:;lT[il::#T:;,:1ilHt;:":::':'J#Ti::T;,.,
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TABLES
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Personnel
Rich E. Bartlett
Wade Hancock
Scot Christensen
David E. Turk
Personnel
Ron F. Hochstein
David C. Frydenlund
Table I
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Staff
TitIe Work Phone
lnterim Mill Manager 435-678-2221
'Ext. 105
Maintenance Foreman 435-678-2221
Ext.166
Mill Foreman 435-678-2221
RadiationSafetyOfficer 435-678-2221
Ext. 113
Corporate Management Staff
Title Work Phone
President/ Chief Operating 604 806-3589
Officer
Vice President and
General Counsel
Home Phone/
Other Contact Number
435 678-249s
435 678-27s3
435 678-2015
43s 678-7802
Home Phone/
Other Contact
Number
Cell: 604 377-1167
303 221-0098
Cell: 303 808-6648
303 389-4130
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TABLE 2
REAGENT YARD LIST
REAGENI OUANTTTY.(LBS)NUIVIBER gF. ' ,
STORAGE.TANKS
,gAPAprrY,
](GAUONS)
ADOGEN 2382
ADVANTAGE lO1M
AMERSITE 2
AMINE 2384
AMMONIUM SULFATE (BULK)
AMMONIUM SULFATE (BAGS)
ANHYDROUS AMMONIA
CHEMFAC 1OO
CI.ARIFLOC N-10lP
DECYI.ALCOHOL
DIESEL FUEL
FLOCCULENT M1O11N
FLOCCULENT M13O2C
GRINDING BALLS
ISODECANOL
KEROSENE
MACKANATE
MILLSPERSE 802
NALCO 2458
NALCO 8815
PERCOL 351
PERCOL 406
PERCOL 745
POLOX
POLYHALL YCF
PROPANE
SALT (BAGS)
SALT (BULK)
soDA ASH (BAGS)
soDA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
6,L20
2,475
0
19,440
54,000
4,300
707,920
12,900
3,000
45,430
30,550
3,550
48,290
45,430
7,344
3,150
t,4t0
0
0
1,500
13,950
0
10,360
0
39,280
0
39,280
84,100
101,128
0
4,80L,440
2
2
1
3
1
1
1
1
1
1
1
2
1
1
3L,409
10,152
30,000
t6,921
9,530
17,700
10,500
19,904
1,600,000
269,L60
3,000
5,000
250
6,000
1.
2.
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TABLE 3.0
LABORATORY CHEMICAL INVENTORY LISTI
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassium tartrate
n-Butyl acetate
Carbon tetrachloride
Cyclohexane
Ferric chloride
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Zinc acetate
2,270 kg
45.4 kg
2,270 kg
2,270 kg
2,270 ks
45.4 kg
2,270 kg
4.54 kg
454 kg
454 kg
454 kg
4.54 kg
45.4 kg
2,270 kg
454kq
1.8 kg
2.27 kg
2.27 kg
6.8 kg
7.8 kg
0.454 kg
4L
1.0 L
24L
6.810 kg
0.57 kg
0.114 kg
2.5 kg
1.4 kg
0.91 kq
Chemical in Acid Shed Bg!:Quantitv ln Stock
Chloroform 4.54 kq 55 oal
Hydrochloric acid 2,270 kq 58 oal
Nitric acid 454 ko 5L
Phosohoric acid 2.270 ko 101
Sulfuric acid 454ko 251
Hvdrofluoric Acid 45.4ko 1L
Ammonium hvdroxide 454ko 181
This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 3't1 of the Clean
Water Act."
Chemical in Volatiles and
Flammables Lockers (A,B,C)
E Quantitv ln Stock
Chloroform 4.54 kq 8L
Formaldehvde 45.4 ko <1L of 37% solution
Nitrobenzene 454 kq 12L
Toluene 454ko 12L
cHEMlCfil- "'- ,.*',
Acetic Acid, Glacial 1,000 lbs 4 sal
Ammonium Hydroxide 1,000 lbs 5L
Carbon Disulfide 100 lbs 0lbs
Calcium Hypochlorite 10lbs 2 ko (4.4 lbs)
Chlorine 10lbs 0lbs
Ferrous Sulfate Heptahvdrate 1,000 lbs 5 ks (11lbs)
Hydrochloric Acid 5,000 lbs 60 gal of 40%
solution
Nitric Acid 1,000 lbs 101
Potassium Permanganate 0.1 N 32 sal 5 ks (11 lbs)
Sodium Hypochlorite 5.5%100 lbs 2 kg (1 1 lbs) of
5.5% solution
Silver Nitrate 1tb 0lbs
Trichloroethylene 100 rb 2L
Xylene (Mixed lsomers)100 lbs 0 lbs
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
1. This list identifies chemicals which are regulated as hazardous substances
under the Federal Water Pollution ControlAct 40 CFR Part 117. Materials
in this list are stored in a locked storage compound near the bulk storage
tank area. The Mill also stores small quantities of other materials that are
not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 cFR part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
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TABLE 5.0
REAGENT YARD/BULK CHEMICALS LtSTl
REAGENT BAr QUANTITY IN
REAGENT YARD
Sulfuric Acid
Floc #301
Hyperfloc 102
Ammonia - East Tank
Ammonia - West Tank
Kerosene
Salt (Bags)
Ammonium Hyd rogend ifluoride
Soda Ash Dense (Bag)
Phosphoric Acid
Polyox
Millsperse
Nalco TX760
Nalco 7200
Tributyl phosphate
Distillates
Diesel
Gasoline
Alamine 336 drums
Floc 109
Floc 208
Floc 904
Hyperfloc 624
Salt (Bulk solids)
Salt (Bulk solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
Alamine 335 Bulk
Alamine 310 Bulk
!sodecanol
Vanadium Pentoxide3
Yellowcake3
Ammonia Meta Vanadate
1,000 lbs
None
None
100 lbs
100 lbs
1 00 gal
None
None
None
5,000 lbs
None
None
None
None
None
None
1 00 gal
1 00 gal
None
None
None
None
None
None
None
1,000 lbs
None
None
None
None
None
1000 lbs
None
1000 lbs
9,000,000 lbs
1,200 lbs
1,500 lbs
0 lbs
105,000 lbs
500 gal
2,000 lbs
20,450 lbs
0lbs
6,300 lbs
490 lbs
1 ,410 lbs
9 barrels
1,590 lbs
9,450 lbs
1 00 gal
Approx. 3300 gal
Approx. 6000 gal
0 lbs
0lbs
0 lbs
0 lbs
0 lbs
0 lbs
0 lbs
0 lbs
0 lbs
20,000 tbs
0lbs
0lbs
0lbs
30,000 lbs
< 100,000 lbs
0lbs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Parl117 Table 117.3: "Reportable Quantities
of Hazardous Substances Designated Pursuant to Section 31 1 of the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent Yard itself,
but are present in closed containers in the Mill Building and/or Mill Yard.
1.
2.
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TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
Lubricating Oils in 55 gallon drums
Transmission Oils
Water Soluble Oils
Xylene (mixed isomers)
Toluene
Varsol Solvent
(2% himethyl benzene in petroleum distillates)
1 00 gal
100 gal
100 gal
100 lbs
1000 lbs
100 gal
1,540 gallons
0 gallons
30 gallons
0 gallons
0 gallons
0 gallons
This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
Reportable Quantities are those identified in 40 CFR Part 1 17 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
QUANTITY IN
WAREHOUSE
FIGURES
Figure L
White Mesa Mill
Mill Site Layout
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Denison Mines (USA) Corp. [*11p-"..1D/lProject WHITE MESA MILL
REVISIONS County: g6n .1ron I slele: Utoh (\t
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scale: t.-2OOOft I uare: 2OOS lfiguru 2-O9t205.dr
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Figure 3
White Mesa MiIl
MilI Management Organization Chart
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Corporate Management Organization Chart
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APPENDICES
APPENDIX 1
WIIITE MESA IVILL
SPILL PREVENTION, CONTROL, AND COTINTERMEASTTRES
PLAN
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I sprLL eREVENTToN, coNTRoL, AND couNTERMEASURES
PLAN
I FoR .HEMT.ALS AND
'ETR.LEUM
pRoDucrs
White Mesa Uranium Mill
6425 South Highway 191
P. O. Box 809
Blanding, Utah 84511
February 2007
for
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, Colorado 80265
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SECTION
1.1 Objective
1.2 Responsibilities
1.3 Drainage Basins, Pathways, and Diversions
1.4 Description of Basins
1.4.1 Basin A1
1.4.2 Basin M
1.4.3 Basin B1
1.4.4 Basin 82
1.4.5 Basin 83
1.4.6 Basin C
1.4.7 Basin D
1.4.8 Basin E
1.5 Potential Ghemical Spill Sources And Spill Gontainment
1.5.1 Reagent Tanks
1.5.2 Ammonia
1.5.3 Ammonium Meta Vanadate
1.5.4 Caustic Storage (Sodium Hydroxide )
1.5.5 Sodium Carbonate
1.5.6 Sodium Chlorate
1.5.7 Sulfuric Acid
1 .5.8 Vanadium Pentoxide
1 .5.9 Kerosene (Organic)
1.6.0 UsedMaste Oil
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SECTION
1.6.1 Propane
1.7 Potential Petroleum Sources And Containment
1.7.1. Petroleum Storage Tanks
1.7.1.1. Diesel
1.7.2 Aboveground Fuel Pump Tanks
1.7 .2.2 Unleaded Gasoline
1.7.2.3 Pump Station
1 .7 .2.4 Truck Unloading
1.8 Spill Discovery And Remedial Action
1.9 Spill lncident Notifications
1.9.1 External Notification
1 .9.2 lnternal Notification
1.10 Records And Reports
1.11 Personnel Training And Spill Prevention Procedures
1 .11 .1 Training Records
1.11.2 Monitoring Reports
1.12 Revision
1.13 Summary
1.14 Mill Manager Approval
1.15 Certification by Registered Professiona! Engineer
PAGE
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Table 1.0 Mill Organization Chart
I rable 2.0 Reagent rank List
LIST OF TABLES
LIST OF FIGURES
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Table 3.0 Laboratory Chemical lnventory List
Table 4.0 Reagent Yard/Small Quantity Chemicals List
I Table 5.0 Reagent Yard/Bulk Chemicals List
- Table 6.0 Petroleum Products and Solvents ListI
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I Figure 1 Mill Site Layout
Figure 2 MillSite Drainage Basins
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WHITE MESA MILL
SPILL PREVENTION, CONIRO L, AND COUNTERMEASURES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
1.1 OBJEGTIVE:
The objective of the Spill Prevention, Control, and Countermeasures (SPCC)
Plan is to serve as a site-specific guideline for the prevention of and response to
chemical and petroleum spills, and as a guidance document for compliance with
Groundwater Discharge Permit No. UGW370004. The plan outlines spill
potentials, containment areas, and drainage characteristics of the White Mesa
Mill site. The plan addresses chemical spill prevention, spill potentials, spill
discovery, and spill notification procedures. The Oil Pollution Prevention Sections
of the Clean Water Act (40 CFR 1 12 to 117), also referred to as the Spill
Prevention, Control, and Countermeasures (.SPCC') rules, establish
requirements that apply to facilities which could reasonably be expected to
discharge oil in quantities that may be harmful, as described in that Act, into or
upon the navigable waters of the United States or that may affect natural
resources of the United States. Section 1 12 states that the Act is not applicable
to facilities that are not subject to the authority of the U. S. Environmental
Protection Agency (.EPA') for one of the following reasons:
1. Due to its location, the facility could not reasonably be expected to
discharge oil into navigable waters of, or impact natural resources of, the
U.S. or
2. The facility is subject to authority of the Department of Transportation as
defined in a Memorandum of Understanding ('MOU') between the
Secretary of Transportation and the EPA Administrator, or
3. The facility does not exceed either the underground or the above ground
storage capacity (42,000 gallons and 1,320 gallons, respectively)
prescribed in the rules.
The Mill could not reasonably be expected, as described in the SPCC regulation,
to discharge oil into the navigable waters, or impact natural resources, of the
U.S. The Mill site was constructed with an overall grade and diversion ditch
system designed to channel the non-recovered portion of any material spill to the
tailings management system. Hence, it is not reasonable to expect that surface
spills will ever reach navigable waters or natural resources of the U.S. or Utah.
Therefore, the SPCC reporting requirements in the Clean Water Act are not
applicable to the Mill. However, as good environmental management practice,
the Mill has implemented the spill management program, described in this
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document, which is consistent with the intent of the Clean Water Act to the
extent practicable. Although the Mill, by design, cannot directly impact navigable
waters of the U.S., and as a result, spills that may occur but are retained within
the site would not be "reportable", the Mill implements these practices in a good
faith effort to minimize all potential sources of pollution at the site.
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 SPCC.
Ammonia is the only chemical that has the potential to leave the site, and would
do so as a vapor.
Figure 1, Site Layout Map shows a map of the mill site including the locations of
the chemical tanks on-site. Figure 2 shows the basins and drainage ditch areas
for the mill site. Table 1.0 is an organization chart for Mill operations. Table 2.0
lists the reagent tanks and their respective capacities. Table 3.0 lists the
laboratory chemicals, their amounts, and their reportable quantities. Table 4.0
lists the operations chemicals. Table 5.0 lists the chemicals in the reagent yard,
their amounts, and their reportable quantities. Table 6.0 lists the petroleum
products and solvents on site.
1.2 RESPONSIBILITIES:
Person in charge of facility responsible for spill prevention:
Mr. Richard E. Bartlett, lnterim Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill record keeping and/or reporting:
Mr. David E. Turk, Department Head, Health , Safety, and Environmental
6425 South Highway 191
Blanding, UT 84511
(43s) 678-2221 (work)
[phone] (home)
Refer to Secfion 1.9 Spill lncident Notification for a list of company personnel
to be notified in case of a spill. ln addition, an organizational chart is provided
in Table 1.0.
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The main drainage pathways are illustrated in Figure 2. The map shows
drainage basin boundaries, flow paths, constructed diversion ditches, tailings
cells, the spillway between Cell2 and 3, dikes, berms, and other relevant
features. The White Mesa Mill is a"zero" discharge facility for process liquid
wastes. The mill area has been designed to ensure that all spills or leaks
from tanks will drain toward the lined tailings cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 100% of the PMP (Probable Maximum Precipitation).
This allows for a maximum of 10 inches of rain at any given time.
DESCRIPTION OF BASINS:
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',.4.1
1.4.2
1.4.3
1.4.4
Precipitation and unexpected spills on the mill property are contained within
their respective drainage basins. Runoff would ultimately drain into one of
the three (3) lined tailings cells.
Basin A1
Basin 41 is north of Cell 1-l and Diversion Ditch No. 1. The basin
contains 23 acres, all of which drain into Westwater Creek. This area is
not affected by mill operations.
Basin A2
Basin A2 contains all of Cell 1-l including an area south of the Diversion
Ditch No. 1. The basin covers 84 acres. Any runoff from this basin
would be contained within Cell 1-1.
Basin Bl
Basin Bl is north of the mill property and is not affected by mill
operations. The basin contains 45.4 tributary acres. Runoff from this
basin drains into a flood retention area by flowing through Diversion Ditch
No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
Basin 82
Basin 82 is northeast of the mill and contains only 2.6 acres. Runoff from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3
ultimately drains into Diversion Ditch No. 2. This basin is not affected by
mill operations.
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1.4.5
1.4.6
1.4.7
1.4.8
Basin 83
Basin 83 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normal direction of flow in this basin is from the
northwest to the southwest. Any runoff from this basin would drain into
Cell 1-1. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 100% of the PMP (Probable Maximum
Precipitation). This allows '10 inches of rain for any given storm event.
Basin C
Basin C contains all of Cell 2. The basin consists of 80.7 acres. This
basin contains earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All runoff in this basin
would be channeled along the southern edge of the basin. Runoff would
then flow into Cell 3 via the spillway from Cell 2 to Cell 3.
Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains all flows, including those caused by the PMF.
Basin E
Basin E contains Cell 4A and consists of 43.3 acres. All anticipated flows
including those caused by the PMF will be contained within the basin and
will flow directly into Cell 4A.
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1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTAINMENT
This section details potential sources of chemical spills and "reportable quantities". For
purposes of this SPCC, a "reportable quantity" will be defined as quantities listed below
which could be expected to reach navigable waters of the United States. Reportable
Quantities are those identified in 40 CFR Part 1 17 Table 117.3: "Reportable Quantities
of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act."
It is not expected that any spill would reach navigable waters of the United States.
However, if a spill of a volume listed below occurs, and remains on the mill site, which is
the more likely scenario, then management is to be notified so that proper internal
evaluations of the spill are made.
1.5.1
1.5.2
1.5.3
1.5.4
Reagent Tanks ( Tank list included in Table 2.01
Ammonia
The ammonia storage tanks consist of two tanks with a capacity of
31,409 gallons each. The tanks are located southeast of the Mill building.
Daily monitoring of the tanks for leaks and routine integrity inspections will be
conducted to minimize the hazard associated with ammonia. The reportable
quantity for an ammonia spill is 7 gallons.
Ammonia spills should be treated as gaseous. Ammonia vapors will be
monitored closely to minimize the hazard associated with inhalation. lf
vapors are detected, efforts will be made to stop or repair the leak
expeditiously. Ammonia is the only chemical ( as vapor) that has the
potentialto leave the site.
Ammonia Meta Vanadate
Ammonia meta vanadate is present in the SX building as the process
solutions move through the circuit to produce the vanadium end product.
But, the primary focus will be on the transportation of this chemical. The
reportable quantity for an ammonia meta vanadate spill is 1,000 pounds.
Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest corner
of the SX building. The tank has a capacity of 19,904 gallons. The tank
supports are mounted on a concrete curbed catchment pad that directs spills
into the sand filter sump in the northwest corner of the SX building. The
reportable quantity for a sodium hydroxide spill is 85 gallons.
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1.5.5
1.5.6
1.5.7
1.5.8
Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921gallons and is located in
the northeast corner of the SX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and is located in the SX building. Spills will be
diverted into the boiler area, and would ultimately drain into Cell 1-1. There is
no reportable quantity associated with a sodium carbonate spill.
Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity of 17,7Q0 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable quantity for a
sodium chlorate spill is 400 gallons.
Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1 ,6000,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin 83 and is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
spill. All flows resulting would be channeled to Cell 1-1. The tank is equipped
with a high level audible alarm which sounds prior to tank overflows. A
concrete spill catchment with a sump in the back provides added
containment around the base of the tank. However, the catchment basin
would not be able to handle a major tank failure such as a tank rupture. The
resulting overflow would flow towards Cell 1-1.
The two smaller storage tanks are located within an equal volume spill
containment dike east of the mill building. The tanks are not presently in
use, but are equipped with high level audible alarms.
The reportable quantity for a sulfuric acid spill is 65 gallons (1,000 pounds).
Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the
drying and fusing circuits and is not present in the vanadium circuit until after
the deammoniator. Efforts will be made to minimize leaks or line breaks that
may occur in processes in the circuit that contain vanadium pentoxide.
Special care will be taken in the transportation of this chemical. The
reportable quantity for a vanadium pentoxide spill is 1,000 pounds.
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1.5.9
1.6.0
1.6.1
Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a
combined capacity of 10,1 52 gallons in three tanks. Any overflow from these
three tanks would flow around the south side of the SX building and then into
Cell 1-1. These tanks have drain valves which remain locked unless
personnel are supervising draining operations. The reportable quantity for a
kerosene spill is 100 gallons.
Used/ Waste Oil
Used/ Waste oil for parts washing is located north of the maintenance shop
in a tank and has a capacity of 5,000 gallons. The tank is contained within a
concrete containment system. Ultimate disposal of the used oil is to an EPA
permitted oil recycler. Any oil escaping the concrete containment system will
be cleaned up. Soil contaminated with used oil will be excavated and
disposed of in Cell 2.
Propane
The propane tank is located in the northwest corner of the mill yard and has
a capacity of 30,000 gallons. Daily monitoring of the tank for leaks and
integrity inspections will be conducted to minimize potential hazards
associated with propane leaks. Propane leaks will be reported immediately.
There is no reportable quantity associated with a propane spill.
POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
1.7
This section details potential sources of petroleum spills and "reportable quantities". For
purposes of this SPCC, a "reportable quantity" will be defined as quantities listed below
which could be expected to reach navigable waters of the United States. lt is not
expected that any spill would reach navigable waters of the United States. However, if a
spill of a volume listed below occurs, and remains on the mill site, which is the more
likely scenario, then management is to be notified so that proper internal evaluations of
the spill are made.
1.7.1 Petroleum Tanks
1.7.1.1 Diesel
Two diesel storage tanks are located north of the mill building. The tanks
have capacities of 250 gallons each. One of the diesel tanks is for the
emergency generator. The other tank is located in the pumphouse on an
elevated stand. Spillage from either tank would ultimately flow into Cell 1-1.
The reportable quantity for a diesel spill is 100 gallons.
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I 1.7.2 Aboveground Fuel Pump Tanks
I 1.1.2.1 Dieset
The diesel tank is located on the east boundary of Basin 83 and has a
I capacity of 6,000 gallons. The tank is contained within a concrete catchment
I pad. The reportable quantity for a diesel spill is 100 gallons.
I 1.7.2.2 Unleaded GasolineI The unleaded gasoline tank is located next to the diesel tank. The unleadedI iiliiTglif*Tf;ftrifUl;lit:fl:"ir TfJ?i,",r-:iE',ul',1J13,,n
I 1.7 .2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
I company vehicles used around the mill site. The pump station is equipped
I with an emergency shut-off device in case of overflow during fueling. ln
addition, the station is also equipped with a piston leak detector and
f emergency vent. Check valves are present along with a tank monitor
t console with a leak detection system. The catchment is able to handle a
complete failure of one tank. However, if both tanks failed the concreteI i#l#:[.i3,iT:li.l;:$,Tf""':"TJl3lilJ!l i"i.;,"i"H}!?!i,i,1"",
sweep would be used in an effort to limit and contain the spill. The soil would
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be cleaned up and placed in the authorized disposal area in Cell2.
1.7. 2.4 Truck Unloading
ln the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or diesel fuel is spilled. Proper clean-up
procedures will be followed to minimize or limit the spill. The spill may be
temporarily bermed or localized with absorbent compounds. Any soils
contaminated with diesel fuel or oil will be cleaned up and placed in the
authorized disposal area in Cell2.
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I 1.8 sprLL DrscovERy AND REMEDTAL Ac,oN
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Once a chemical or petroleum spill has been detected, it is important to take
measures to limit additional spillage and contain the spill that has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, if
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personal danger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Environmental Health and Safety
Manager.
The Mill Manager will assess the spill and related damage and direct
remedial actions. The corrective actions may include repairs, clean-
up, disposal, and company notifications. Government notifications
may be necessary in some cases.
lf a major spill continues uncontrolled, these alternatives will be considered.:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
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t 1.e sPrLL TNcTDENT NonFrcATIoN
I 1.9.1 Externat NotificationI
As stated in Section 1.1, spills are not expected to reach navigable waters of
I the United States. lf a spill of a "reportable quantity" occurs, then mill and
t corporate management must be notified and they will evaluate whether or not
the following agencies must be notified:
1. EPA National Response Center 1-800-424-8802
2. State of Utah, Department of Environmental
Quality, Division of Radiation Control 801/536-4250
3. State of Utah 801/538-7200
Water Quality Division 801/538-6146
ln case of a tailings dam failure, contact the following agencies:
1. State of Utah, Department of Environmental
Quality, Division of Radiation Control 801/536-4250
2. State of Utah, Natural Resources 801/538-7200
I 1.9.2 lnternal Notification
I lnternal reporting requirements for incidents, spills, and significant spills are
as follows:
I Report tmmediatelv
Event Criteria:
I 1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
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"r""liJlyent
investigations, information requests, or enforcement
4. Private actions or claims (corporate or employee)
I 5. Deviations from corporate policies or government requirements byI management
Which have or could result in the following:
I 1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
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3. Government investigation or enforcement action which limits
operations or assesses penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report At The Beqinninq Of The Next Dav
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding the reportable quantities listed in Section 1.5, for
each specific process material, waste, or by-product
ln the event of a spill of a reportable quantity, the Mill Manager is required to
call the Corporate Environmental Manager or the President and Chief
Executive Officer. The individual first discovering the spillwill report it to the
Shift Foreman, Production Superintendent or Maintenance Superintendent,
who will in turn ensure that the Mill Manager is notified. The Environmental
Health and Safety Manager will also be contacted by the Mill Manager.
Name
Mill Personnel:
Richard E. Bartlett
Wade Hancock
David E. Turk
N/A
N/A
Scot Christensen
Corporate Personnel:
Ronald F. Hochstein
David C. Frydenlund
Title
lnterim Mill Manager
Maintenance Foreman
Environmental Health and
Safety Manager
Production Superintendent
Maintenance Foreman
Mill Shift Foreman [phone]
President and Chief Operating Officer [phone]
Vice President and General Counsel [phone]
Home Phone
[phone]
(435) 678-27s3
[phone]
ln the event the next person in the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Table 1.0 shows the
organizational chart for the mill site.
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I 110 RE..RDS AND REP'RTS
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The following reports and records are to be maintained in Central Files by the
Environmental Health and Safety Manager for inspection and review for a
minimum of three years:
1. Record of site monitoring inspections
a. Daily Tailings lnspection Data
b. Weekly Tailings lnspection and Survey
c. Monthly Tailings lnspection, Pipeline thickness
d. Quarterly Tailings lnspection
2. Tank to soil potential measurements
3. Annual bulk oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation inspections
7. Spill lncident Reports
8. Latest revision of SPCC plan
1.11 PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and
control. They are informed that leaks in piping, valves, and sudden
discharges from tanks should be reported immediately. Abnormal flows from
ditches or impoundments are of immediate concern. ln addition, a safety
meeting is presented annually by the Environmental Health and Safety
Manager to review the SPCC plan.
I 1.11.1 Training Records
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Employee training records on chemical and petroleum spill prevention are
maintained in the general safety training files.
r 1.11.2 Monitoring Reports
I Shift logs sf,att prouiOe a checklist for inspection items.
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I 1.12 REVrsroN
I This procedure is to be reviewed by the mill staff and a registeredI professional engineer at least once every three years, and updated when
circumstances warrant a revision.
I 1.13 Summary
Below is a table listing the specific reportable quantities associated with the
major chemical and petroleum products on-site.
CHEMICAL REPORTABLE
QUANTTY (RQ)
AMMONIA
AMV
SODIUM
HYDROXIDE
SODA ASH
SODIUM
CHLORATE
SULFURIC ACID
VANADIUM
PENTOXIDE
KEROSENE
orL
PROPANE
DIESEL &
UNLEADED
FUEL
1OO POUNDS
1,OOO POUNDS
1,OOO POUNDS
No Reportable
Quantity
4OO GALLONS
1,OOO POUNDS
1,OOO POUNDS
1OO GALLONS
No Reportable
Quantity
No Reportable
Quantity
1OO GALLONS
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1.14 MILL MANAGER APPROVAL
! hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the lnternational Uranium (USA)
Corporation White Mesa Millfacilities, and attest that this SPCC plan has
been prepared in accordance with the Standard Operating Procedures
currently in effect.
Richard E. Bartlett
lnterim Mill Manager
1.15 CERTIFICATION BY
REGISTERED PROFESSIONAL ENGIN EER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the lnternational Uranium (USA)
Corporation White Mesa Millfacilities, and attest that this SPCC plan has
been prepared in accordance with good engineering practices.
Registered Professional Engineer
State of Utah No. 165838
Harold R. Roberts
14
TABLES
Personnel
Rich E. Bartlett
V/ade Hancock
Scot Christensen
David E. Turk
Personnel
Ron F. Hochstein
David C. Frydenlund
Interim Mill Manager
Maintenance Foreman
Mill Foreman
Radiation Safety Offi cer
435-678-2221
Ext. 105
435-678-2221
Ext.l66
435-678-2221
435-678-222t
Ext. 113
Table 1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Staff
Title Work Phone Home Phone/
Other Contact Number
43s 678-249s
435 678-27s3
43s 678-20t5
435 678-7802
Home Phone/
Other Contact
Number
Cell: 604 377-1167
303 221-0098
Cell:303 808-6648
Corporate Management Staff
Title Work Phone
PresidenU Chief Operating 604 806-3589
Officer
Vice President and
General Counsel
303 389-4130
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TABLE 2.0
REAGENT TANK LIST
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AUANIIIT REAGENT CALAOITY (GAL)
2
3
1
1
1
1
2
1
1
1
1
1
1
2
DIESEL
KEROSENE
USEDMASTE OIL
DIESEL
UNLEADED
PROPANE
AMMONIA
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFT
SODIUM CHLOMTE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
250
10,152
5,000
6,000
3,000
30,000
31,409
19,904
16,921
8,530
17,700
10,500
1,600,000
269,160
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassium tartrate
n-Butylacetate
Carbon tetrachloride
Cyclohexane
Ferric chloride
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Zinc acetate
2,270 kg
45.4 kg
2,270 kg
2,270 kg
2,270 kg
45.4 kg
2,270 kg
4.54 kg
454 kg
454 kg
454 kg
4.54 kg
45.4 kg
2,270 kg
454 kq
1.8 kg
2.27 kg
2.27 kg
6.8 kg
7.8 kg
0.454 kg
4L
1.0 L
24L
6.810 kg
0.57 kg
0.114 kg
2.5 kg
1.4 kg
0.91 kq
g
Chloroform 4.54 ko 55 oal
Hvdrochloric acid 2,270 kq 58 qal
Nitric acid 454 ko 5L
Phosohoric acid 2.270 ko 101
Sulfuric acid 454 ko 25L
Hvdrofluoric Acid 45.4 ko 1L
Ammonium hvdroxide 454 ka 18 L
This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. fhe lab also stores small
quantities of other materials that are not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Part 117 Table 1 17.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
Ghemical : in Volatiles and
:Flammables' Lockers (AB,C)
Chloroform 4.54 ko 8L
Formaldehvde 45.4 ko <1L of 37% solution
Nitrobenzene 454 ko 12L
Toluene 454 kq 12L
1.
2.
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
This list identifies chemicals which are regulated as hazardous substances
under the Federal Water Pollution Control Act 40 CFR Part 1 17. Materials
in this list are stored in a locked storage compound near the bulk storage
tank area. The Mill also stores small quantities of other materials that are
not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
.EE.QUANTITY-IN
reBAgE,
COMPOUND.
Acetic Acid. Glacial 1,000 lbs 4 qal
Ammonium Hydroxide 1,000 lbs 5L
Carbon Disulfide 100 lbs 0lbs
Calcium Hvoochlorite 10 lbs 2 ko (4.4 lbs)
Chlorine 10 lbs 0 lbs
Ferrous Sulfate Heptahvdrate 1,000 lbs 5 ks (1 l lbs)
Hydrochloric Acid 5,000 lbs 60 gal of 40%
solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanqanate 0.1 N 32 oal 5 ko (11 lbs)
Sodium Hypochlorite 5.5%100 lbs 2 kg (1 1 lbs) of
55% solution
Silver Nitrate 1lb 0lbs
Trichloroethvlene 100 rb 2L
Xvlene (Mixed lsomers)100 lbs 0 lbs
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TABLE 5.0
REAGENT YARD/BULK CHEMICALS LISTI
REAGENT g QUANTITY IN
REAGENT YARD
Sulfuric Acid
Floc #301
Hyperfloc 102
Ammonia - East Tank
Ammonia - West Tank
Kerosene
Salt (Bags)
Ammonium Hydrogendifluoride
Soda Ash Dense (Bag)
Phosphoric Acid
Polyox
Millsperse
Nalco TX760
Nalco 7200
Tributy! phosphate
Distillates
Diesel
Gasoline
Alamine 336 drums
Floc 109
Floc 208
Floc 904
Hyperfloc 624
Salt (Bulk solids)
Salt (Bulk solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
Alamine 335 Bulk
Alamine 310 Bulk
!sodecanol
Vanadium Pentoxide3
Yellowcake3
Ammonia Meta Vanadate
1,000 lbs
None
None
100 lbs
100 lbs
'100 gal
None
None
None
5,000 lbs
None
None
None
None
None
None
100 gal
100 gal
None
None
None
None
None
None
None
1,000 lbs
None
None
None
None
None
1000 lbs
None
1000 lbs
9,000,000 lbs
1,200 lbs
1,500 lbs
0lbs
105,000 lbs
500 gal
2,000 lbs
20,450 tbs
0lbs
6,300 lbs
490 lbs
1,410 lbs
9 barrels
1,590 lbs
9,450 lbs
100 gal
Approx. 3300 gal
Approx. 6000 gal
0lbs
0lbs
0lbs
0lbs
0lbs
0lbs
0lbs
0lbs
0lbs
20,000 lbs
0lbs
0lbs
0lbs
30,000 lbs
< 100,000 lbs
0 lbs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous
substances under the Federal Water Pollution ControlAct 40 Cf R part t tZ. -
2. Reportable Quantities are those identified in 40 CFR Paft 117 Table 117.3: "Reportable Quantities
of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent Yard itself,
but are presenl in closed containers in the Mill Building and/or Mill yard.
1.
2.
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TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
Lubricating Oils in 55 gallon drums
Transmission Oils
Water Soluble Oils
Xylene (mixed isomers)
Toluene
Varsol Solvent
(2% trimethyl benzene in petroleum distillates)
100 gal
100 gal
100 gal
100 lbs
1000 lbs
100 gal
1,540 gallons
0 gallons
30 gallons
0 gallons
0 gallons
0 gallons
This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
F'IGURES
Figure 1
White Mesa Mill
Mill Site Layout
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Figure 2
White Mesa Mill
MilI Site Drainage Basins
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Denison Mines (USA) Corp. [,*-J]/
NoLf
.9)LL
Project WHITE MESA MILL
REVISIONS county: Son Juon | 58 "' Utoh
Date Bv Location:
2,15N7 BM
Mill Site Drainage Basins10I21n7BM
05/1 6/08 AM
06/11rc8 BM
scare: 1.=2OOOft I Dare: 2OO5 lfioure 2_091205.dw
Author HRR lDEfredBy: unknown
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APPENDIX 2
WHITE MESA IVILL
EMERGENCY RESPONSE PLAN
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EMERGENCY RESPONSE PLAN
REVISION 1.1
Denison Mines (USA) Corp.
'fvhite l{esa iviili
Blanding, Utah
April 74, 1986
REVISED
February 16,2007
Distribution List:
Ron F. Hochstein
Rich E. Bartlett
David Turk
Michael Spillman
Mill Shift Foremen
Blanding Fire Department
San Juan County EMS Coordinator
State of Utah, Department of Radiation Control
Revision Date: January 16,2006
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1.0
2.0
3.0
4.0
TABLE OF CONTENTS
Page
Number
5.0
.......................... I
.......................... I
6.0.
7.0
8.0
9.0
EXHIBITS:
1. Emergency Notification List2. Internal Notifications3. Site Layout Map4. Main Shut-off Valves
E-l
E-2
E-3
E-4
APPENDICES:
A. Emergency Procedure Response to FireB. Emergency Procedure Response to Chemical or Gas ReleaseC. Emergency Evacuation Procedure
FIGURES:
l. Fire System Schematic
A-l
A-2
A-3
F-l
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 1 of 13
l.INTRODUCTION
This Emergency Response Plan is written not only to comply with Federal, State and local
regulations, but even more importantly to reduce the risk to our employees and that of the
community in regards to Health, Safety and Environmental Emergencies.
This plan includes the following:
o evaluation of the potential risks for fire, explosions, gas releases, chemical spills and
floods (including tailings dam failure);. specific emergency programs for each potential event;. definition of administrative response actions; and,. definition of the emergency response contacts - both internal and external.
The White Mesa Mill (the "Mill") operates under the following regulatory agencies:
. Utah State Department of Environmental Quality, Division of Radiation Control;. Mine Safety and Health Administration;. Environmental Protection Agency;o Utah State Department of Fnvironmental Quality, Division of Air Quality; and,. Utah State Division ofNatural Resources Bureau of Dam Safety.
2. WHITE MESA MILL OVERVIEW
The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and
vanadium. In addition to the processing of conventional ores, the Mill also processes alternate
feed materials using similar process steps and chemicals. The conventional ore is stored on the
Ore Pad (shown in Exhibit 3). Alternate feed materials are also stored on the Ore Pad and may
be stored in bulk form, lined burrito bags, liners or drums. The descriptions of each alternate
feed material are maintained by the Mill's Radiation Safety Officer.
The Mill utilizes a semi-autogenous grind circuit followed by a hot sulfiric acid leach and a
solvent extraction process to extract uranium and vanadium from ores, using large amounts of
sulfuric acid, sodium chlorate, kerosene, amines, ammonia and caustic soda in the process The
reagent storage tank locations are described in further detail in Section 4.6.
Emissions from the Mill process are in the form of air emissions from exhaust stacks and
solid/liquid tailings which are stored in the Mill's tailings cells located west/southwest of the
main Mill building. The major exhaust stack parameters are shown in the following table.
Description
Height
(ft from surface)
Diameter
(inches)
Estimated Flow Rate
(cfm)
Leach Exhaust -100 36 13,700
Yellow Cake Drying
(3 stacks)
-85 l8 4,000 per stack
Vanadium Roasting &
Fusion
-85 38 4100
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 2 of 13
There are also smaller exhaust stacks associated with the Laboratory in the Mill Administration
building and the boiler exhaust stack.
The Mill's tailings cells are comprised of four below grade engineered cells, Cell 1-I, 2,3 and
4,A.. Liquids are stored in Cell 1-I and Cell 3, the active tailings cell. The liquid in the tailings
cells is very acidic. In addition to the tailings cells, there is also an emergency lined catchment
basin west of the Mill building. Solutions in this basin or the tailings cells should not be used to
fight fires in the Mill facility.
The products of the Mill include ammonium metavanadate (AMV), vanadium pregnant liquor
(VPL), vanadium pentoxide (VrOr), and yellowcake, or uranium concentrate (UrOr). The VrO,
and UrO, products are packaged in steel drums for shipment. The AMV is packaged in either
steel drums or super-saks while the VPL is sold in liquid form in bulk.
Master files containing Material Safety Data Sheets for all materials in use at the Mill are
maintained at the Safety Office, Mill Maintenance Office, Mill Laboratory and Mill Central
Control Room. Copies are also on file at the Blanding Clinic, Doctor's Offices, Blanding Fire
House and Office of the San Juan County Emergency Medical Coordinator.
The nearest residence to the Mill is approximately one mile to the north of the Mill, the next is a
residence approximately two miles north of the Mill, followed by the community of White Mesa,
about 3.5 miles to the south. The City of Blanding is located approximately 6 miles to the
northeast.
The Mill site is near Utah State Highway l9l and can be accessed by a paved access road from
the highway to the Mill facilities.
3. PLAN OBJECTIVES
The primary objectives of this plan are:
1. To save lives, prevent injuries, prevent panic, and minimize property/environmental
damage to the lowest possible level.
2. To evacuate and account for all people in the area including visitors, truck drivers,
contractors, etc.
3. To provide assembly areas that are as safe as possible and which can be reached without
traveling through a hazardous area. Assembly areas will be properly manned to deal with
sick or injured persons, and provisions will be made to evacuate those persons to proper
shelter.
4. To make adequately trained personnel available to cope with rescue and recovery
operations as directed by the Incident Commander.
4. DESCRIPTION OF FACILITIES
The Mill facilities are shown on the Site Layout Map included as Exhibit 3.
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TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-1
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 3 of 13
4.1 Fire Water Supply and Alarm Systems
4.1.1 Fire Water Supply
The fire water supply facilities include:
. 400,000 gallon Storage Tank of which 250,000 gallons are reserved for fire emergencieso Centrifugal diesel driven pump rated at 2,000 gpm at 100 psi. This pump starts
automatically when the pressure in the fire main drops below 100 psi (See Figure 1, Fire
System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm.
4.1.2 Alarm System
The alarm systems include the following:
. public address system. hand held radios. siren.
4-2 Office Building and Laboratory
4.2.1 Office Building
The office building (approximately 10,000 square feet) contains the administration offices,
radiation health and safety offices and the Mill laboratory. The central file vault and the main
computer system are also in this building. The ambulance is kept on the west side of the office
building near the safety offrce entrance.
4.2.2 Laboratory
The laboratory facilities contain the following:
o three flammable cabinets (keys required). chemical storage room south of main lab. six fume hoods - hoods 1,2,3 ard 4 are in the center of the laboratory and hoods 5 and 6
are along the west wall- Hoods I and 2 are no longer in service. Hoods 3 and 4 are on
the west side, 1 and 2 are on the east side of the center cluster of hoods with 2 being in
front. Only hoods 5 and 6 may be used for perchloric acid.e outside laboratory chemical storage north of office building (key required). perchloric acid storage vault located underground west of office building (key required)
A wide variety of chemicals in small quantities are located in the laboratory. These chemicals
range from acids to bases along with flammable metal compounds and peroxide forming
compounds. Oxidizers and organic chemicals, which have a strong potential of producing
harmful vapors if the containers are damaged to the point that the chemicals are exposed are
stored in a storage room in the laboratory. There are no acids stored in this storage room. The
acids (including but not limited to sulfuric, nitric, acetic, perchloric, phosphoric and hydrochloric
acids) are stored in the main laboratory area in 2.5 liter or 500-ml bottles. MSDS books for all
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TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WIIITE MESA MILL EMERGENCYRESPONSE PLAN I Pue" 4 of 13
chemicals in the laboratory are located in the Laboratory, Safety Department, Mill Maintenance
offrce and Mill Central Control room.
4.2.3 Electrical
Electrical transformers and electrical switches are located in the laboratory at the east end of thechemical storage room.
4.2.4 Fire Protection System
The fire protection systems in the office building and laboratory include:
. a fire hose station located on the east end of the office building. The station includes two
sets of turnout gear, two SCBA units and Incident Commandeimaterials.o automatic "wet" sprinkler system which is actuated at2l2 Fo portable dry chemical extinguishers strategically located throughout the building.
4.3 Solvent Extraction Building
The solvent extraction (SX) building (approximately 21,000 square feet) houses the uranium andvanadium solvent extraction circuits and the ELUEX circuit. Ttre SX circuits may contain up to200,000 gallons kerosene (7 57 ,00;0 liters ) which has a flash point of 1 g5" F.
Assoc^ialed_equipm,ent in th9 SX building includes a temporary boiler located at the southwestend of the SX building which maintains tle temperature foi- the hre system.
Chemicals which may be encountered in the SX building include:
o Kerosene. Caustic Soda. Anhydrous Ammonia. Sulfuric Acid. Salt (Brine)o Soda Ash. Ammonium Sulfate. Amineso Alcohol. Sodium Chlorate. Sodium Vanadate. Propane
The VPL product is stored in the SX building.
4.3.1 Electrical
All electrical switches are located outside in the MCC room north of the SX building. The maincontrol panel for all of the equipment is located in the Central Control Room in thle main Millbuilding.
4.3.2 Fire Protection System
The SX building fire protection systems include:
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TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 I WHITE MESA MILL EMERGENCY RESPONSE PLAN I Paee 5 of 13
o a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212F.o portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure I in this Plan.
4.4 MiU Buildine
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
o Caustic Soda. Anhydrous Ammonia. Sulfruic Acid. Soda Ashr Ammonium Sulfate. Sodium Chlorate. Sodium Vanadateo Propane
The finished products which are contained in the mill building include AMV, VrO, and UrO, (or
yellowcake).
4.4.1 Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west corner of the mill building. Circuit control panels are located in the SAG mill control room,
the central control room, the vanadium roaster control room and the AMV area.
4.4.2 Fire Protection System
The main mill building fire protection systems include:
r portable dry chemical extinguishers strategically located throughout the building.o water hoses throughout the building.
fo1 fire hydrgn! and hose cabinet locations in the Mill building refer to the Fire System
Schematic included as Figure 1 of this Plan.
4.5 Maintenance Shop/Warehouse/ChanqeRoom Building
This building (approximate_ly 29,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located on the south end-of the
building) and the personnel change rooms and lunch/training room (located on the extreme south
end ofthe building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-1
Date: Sept 29,2005 I WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 6 of 13
the main maintenance shop area contains welding and cutting equipment, lathes, presses,
and drill presses.
a carpenter shop which contains various saws and planes. Fiberglass work is also done
within this shop area and it is located at the northwest end of the maintenance shop area.
an electrical shop which is located south of the carpenter shop.o a heavy equipment maintenance shop area is located at the north end of the maintenance
shop in the center of the building.. a rubber room for rubber lining of equipment is located east of the equipment shop area.. the maintenance shop office, instrument shop and tool room are located at the south end
of the maintenance shop area.
The warehouse area contains primarily dry good storage for repair parts and consumables for the
operation of the Mill. There is an electrical water heater for the change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in the
following locations:
. small quantities of flammable material such as starting fluid and spray paint are kept in
the warehouse.
drums of new oil and anti-freeze are stored along the east wall of the equipment
maintenance area and on the east side of the warehouse on oil storage racks.
used oil is stored in a tank located northeast of the equipment shop. The tank has a
capacity of approximately 5,800 gallons.
in the main maintenance shop area and the rubber room there are flammable storage
cabinets and east of the warehouse there is a trailer which is used to store flammable
items such as rubber cements, paints and fiberglass resins.. compressed gas cylinder storage, both empty and full is located outside, east of the
maintenance shop.
4.5.1 Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is located
on the east wall inside the Maintenance shop. Auxiliary electrical panels for the change room
and warehouse zre located in the southwest comer of the warehouse area.
4.5.2 Fire Protection System
The fire protection system within the maintenance shop/warehouse/change room building
includes:
o "\ryet" automatic sprinkler system that releases at2l2" F.o portable dry chemical extinguishers strategically located throughout the maintenance
area, warehouse area and the change room and lunch room.
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure l).
4.6 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 7 of 13
. a sulfuric acid tank located northwest of the mill building which has a capacity of
approximately 1.4 million gallons.. a storage tank for propane is located on the north edge of the mill site, northwest of the
mill building. It has a storage capacity of 30,000 gallons.. four sodium chlorate tanks located east of SX building, north of the office building and
east of the pulp storage tanks. The two tanks east of the SX building are for sodium
chlorate storage and the other two tanks are for dilution of the sodium chlorate.o two anhydrous ammonia tanks located east of the SX building, with capacity of 31,409
gallons each.o three kerosene tanks located east of the SX building, with a capacity of 10,152 gallons
each-. one caustic soda tank north of the SX building, with a capacity of 19,904 gallons.r three soda ash tanks which are located east of the SX building. One tank is the dry soda
ash tank with a capacity of 70,256 gallons. Two of the tanks are soda ash dilution tanks
with capacities of 16,921gallons each.. diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad.
The gasoline storage capacity is 3,200 gallons, while diesel storage capacity is 8;000
gallons.
Other reagents are stored in steel barrels or super sacs in a reagent yard located east ofthe office
building. Typical reagents which are stored in this yard include:
o polymers and flocculants. boiler feed water chemicalsr methanolo tributyl phosphate. "dirty" soda ash and ammonium sulfate. SX amines and emulsion breakers. decyl alcohol. minimal amounts of acid in barrelso used oil in drums and overpacks
4.7 Boiler Facilities
The main building (approximately 12,400 square feet) is located on the west side of the Mill site
and contains air compressors and water treatment facilities. To the north of the main building isa building which houses a propane-fired boiler. The vanadium oxidation tank, oxidat"ion
thickener, and pH adjustment tank are located south of the boiler house facilities.
4.7.1 Electrical
The main electrical panel for the boiler house is located outside of the building, on the south
wall.
4.7.2 Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically located portable
dry chemical extinguishers.
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-1
Date: Sept 29,2005 | wHrTE ]EESA MILL EMERGENCY RESPONSE PLAN I rage 8 of 13
4.8 Sample Plant
The sample plant building (apprqximately 8,000 square feet) is located on the ore pad, east of the
maintenance shop/warehouse building. The sampling plant equipment has been-removed from
the building and it is currently used as a storage area for maintenance.
4.8.1 Electrical
The electrical panel for this building is located on the east wall upstairs.
4.8.2 Fire Protection System
There are no extinguishers or sprinkler systems in the sample plant.
5. ORGANIZATION AND RESPONSIBILITIES
The organizational chart for an emergency situation is illustrated in Figure 2.
5.1 MillManager/IncidentCommander
The Incident Commander has the responsibility for:
. preparing an Emergency Plan. communicating the Plan,o directing activities during emergencies; and,o reporting to local, State and Federal authorities.
The Incident Commander will stop routilg radio usage upon learning of an emergency and set upthe base station in a safe location for directing activities. Radio usage will be liriited to the
emergency. The Incident Commander has the responsibility to contact all outside services.
The Incident Commander has the- responsibility to account for all employees at the Mill, using
the assistance of supervisols and/or any International Uranium (USA) Corporation (*IUSA')
personnel. - fle lryldent Commander iras the responsibility for the news 'media *it r"fort6
directly to the President of IUSA.
5.2 Mill General Superintendent
The Mill General Superintendent has the responsibility of directing outside emergency personnel
and has the responslbitity for plant security ana witt ieport directlly to the Inciddrt Cbmmander.The Mill General Superintendent will act as Incident Commander in the absence of the MillManager.
5.3 Radiation Safe8 Officer/Tire Chief
The.Radiation Safety Officer will direct re.s9u9 operations and provide the necessary emergency
medical personnel and facilities to cope with the emergency. Adequately trained fiie crews ani
operable emergency equipment will be maintained at all times.
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-1
Date: Sept 29, 2005 | WHITE MESA MrLL EMERGENCY RESPONSE PLAN I rug" 9 of 13
As Fire Chief, the Radiation Safety Officer has the responsibility to maintain trained fire crews
and operable equipment, mobilize and direct the fire crews and equipment in a fire emergency or
one containing the threat offire, and to assist in evacuation and rescue or recovery operations.
In the absence of the Radiation Safety Officer, the Mill Safety Coordinator will assume theseduties.
5.4 Maintenance Supervisor
The Maintenance Supervisor will direct all.personnel in evacuation and in activities to cope withthe emergency, including isolation of utilities and providing technical advice as needed. TheMaintenance supervisor will be assisted by the Mill safety coordinator.
5.5 Laboratory Supervisor
The-Laboratory Supervisol has. th^e_responsibility to direct and account for all office personnel(including IUSA personnel and office visitors) in evacuation and in activities to cope with theemergency. In.case of a mill tour the Supervisor accompanying the tour will be responsible forevacuation of visitors.
5.6 Shift Foremen
Shift Foremen are in charge until the Incident Commander arrives and are responsible for allfunctions listed above. Shlft Foremen have the responsibility to account for ali oitheirpeopi" i"addition to any v^isito_rs, contractors, etc., in their arbas and repon to the Incident Comminder; or,in the absence of the Incident Commander, to administer all of ttre above duties.
5.7 Scale House Personnel
Scale house person on shift will be responsible to account for ore truck drivers and reagent truckdrivers.
5.8 Emergency Response Teams
The response cley f91^eagh operating.shift will normally consist of the following operators underthe direction of the shift foreman. This organization may be changed for individuai shifts subjectto the approval of the Fire Chief.
5.8.1 Operational Mode
Leach Operator
CCD Operator
Solvent Extraction Operator
Mill Trainee
5.8.2 Non-OperationalMode
Shift Foreman
Operations Personnel
Maintenance Personnel
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I pue" t0 of 13
Figure 2
Emergency Response Organizational Structure
Non0perational Mode
Shift Foreman, 0perations Personnel
Mainlenanoe Personnel
6.SPECIFIC EMERGENCIES
The following details procedures to be followed during specific emergencies but are not limited
to the following.
6.1 Fire
Should a fire occur, the procedure outlined in Appendix A for reporting and responding to fireswill be followed. Particular areas of concem include:
o Solvent Extraction Building. Propane Tankso Lab or Lab Storage Area
6.2 Chemical or Gas Release
The procedures for response to a chemical or gas release are outlined as Appendix B.
6.3 Earthquake
Altlough thp i? highly unlikely, an earthquake could occur at the Mill. A severe earthquake
could-cause buildings and other structures to collapse, chemical and/or gas releases, major fires
as well as-geryra]_p-anic. In the event of a major earthquake the evacuation procedures outlined
in Appendix C will be followed.
Emergency Response Teams
0perational Mode
Leach Operator, CCD Operator
SX Operator, Mill Trainee
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INTERNATIONAL URAMUM (USA) CORPORATION
Rev. No.: R-1
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Paee l1 of t3
6.4 Terrorist/Bomb Threat
In the event that any person should receive a threat of a bomb, the following evacuation
procedure should be followed:
. Notify lll person of authority, i.e., Superintendent, Foreman, Radiation Safety Officer,
who will immediately notify law enforcement authorities and evacuate the threatened
area.. Evacuate all persons from the affected area and stop all radio transmissions.
6.5 Tailings Dam Break and Major Floods
Flood water breaching tailings embankments presents one of the greatest dangers for the sudden
release of tailings solids and impounded water. The tailings cells are designed with sufficient
freeboard (!ht.g &gt)_to ryithstand back-to-back 100-year storm events or 40yo of the probable
m,aximum floo{ (PIvIF) followed by the 100-year storm event. The flood design is equivalent to
15 inches of rainfall. In addition, the tailings dikes were designed in accordanle withU.S. NRC
regulations and allow a sufficient margin of safety even in the event of an earthquake.
The possibility cf floods resulting from Westwater Creek, Cottonwood Creek, and Corral,Creek
causing a dam failure is extremely remote.
The tailings cells and dikes are inspected on both a daily and shift basis.
Discharges to* q dike failure would extend tlree miles before leaving IUSA's property. In the
event of a dam failure, Iarge operating equipm-ent will be mobilized to construit temporary
earthen dikes or berms downgradient to the failed dike. In addition, the State of-Utah,
pepartment olRadiation Control Executive Secretary (the "Executive Secretary), MSHA, and
State of Utah, Department ofNatural Resources, Division of Dam Safety shall be notified.
In the event of a seismic rupture of tailings slurry pipelines, the released slurry will be contained
in the tailings cells regardless of the quantity released.
7.
7.1
Employees will be -notified to evacuate the area by dialing 184 on any area telephone and
announcing that the Mill should be evacuated. This announcement will be iepeated twice. When
the paging system cycles-thro^ugh, the evacuation siren (continuous frequency) will automaticallysound for approximately forty-five seconds, and then automatiCally ihut off, allowingcommunications by radio from that point. If the 184 number is dialed accidentally tG
gyqcgltion_alarm may be canceled by disconnecting the phone until the page cycle ends, then re-dial 184. (See Exhibits 1 and 2.)
7.2 Assembly
When the evacuation alarm sounds or when personnel are verbally notified by radio or other
means, all personnel will assemble at:
. The parking lot south of the office,
EVACUATION PROCEDURE (See Appendix C)
Notilication
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INTERNATIONAL URAMUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I Page 12 of 13
. The scalehouse,. North side of Tailings Cell l, or. North of the Mill
Assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions, etc.
The Fire Chief or Shift Foreman will specify the appropriate assembly site.
7.3 Specific Procedure for Operations Personnel
l. See specific emergency shutdown procedure for Operations by area under the relevant
Operating Procedure for your area.
2. All employees not mentioned under Operating Procedures are to immediately report to
the assembly area and congregate by crew so that all persons can be accounted for. As
employees leave their work areas, they must pass the word to evacuate to any persons
who may not be aware of the emergency.
3. After the Mill has been determined to be safe for re-entry, employees will be verbally
notified to return to their work stations.
8. Off-SiteEmergencvEquipment/PersonnelRelease
Any emergency response equipment or personnel that enter the Restricted Area in response to an
incident will be scanned and decontaminated prior to leaving the site according to the procedures
included in PBL-9, End Dump Trailer Acceptance, Handling and Release. Any equipment will
be decontaminated according to the requirements found in Table I of the Nuclear Regulatory
Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Injured personnel should be evaluated for radiation contamination, if there was a potential for
contamination, at the earliest convenience. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, notiff the clinic/hospital personnel in advance.
9. EMERGENCY EQUIPMENT
Emergency equipment for the Mill is provided as follows.
9.1 Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-112" hose,
two spanner wrenches, spray nozzles and one hydrant wrench.
. South ofSX. West of CCD. North of Mill Building. East of pulp storage tanks. Northwest of Maintenance Shop. West of Warehouse
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev I (09.29.05).doc 12
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INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAII I Page 13 of 13
. East of office building
9.2 Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus are located at each of the following locations:
. Hose station east of office building. Hose Station South of SX. North End SX Outside Wall. North end of Mill building, outside wall
9.3 Spill Clean-up Equipment
Barrels of soda ash are located throughout the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near the
laboratory. The laboratory also contains acid spill kits and absorbent materials to be used in case
of a spill.
9.4 Fire Fighting PPE
Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in
the Fire Hose Station located on the east side of the office building.
9.5 Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure
that all of the equipment is in place.
10. EMERGENCY TRANSPORTATION
One fully-equipped First Responder Unit (Ambulance) located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations with
support as needed from the local Emergency Medical Services.
11. EMERGENCY DRILLS AND TRAINING
Quarterly drills, as required by MSHA, are prepared by the Safety and Radiation Departments to
monitor performance of personnel responding to emergency situations. Each drill will be
enacted upon one or more of the potential scenarios by this plan. The drill and evacuation
activities are documented by the Mill's Safety Coordinator and maintained within plant files.
Management will review all drills at quarterly ALARA Committee Meetings.
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EXHIBIT 1
EMERGENCY NOTIFICATION LIST
ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR:
Give artificial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
Scan the injured for excessive alpha prior to transporting if time allows.
(If alpha is excessive or there is no time to scan, notify the clinic/trospital personnel and the
Radiation Safety Offi ce).
THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED:
Blanding Clinic ........678-2254 or 678-3434 (930 N.400 W.)
San Juan Hospital, Monticello ....678-2830 or 587-2116 (364 W. lst N.)
EMT and CPR TRAINED - The following personnel should be contacted, if they are on-site, in the
event of an emergency to aid in the event of any injuries to personnel.
David Turk - EMT and CPR trained
Mike Spillman - CPR trained
AMBULANCE SERVICEBlanding Dial9l I
If the Company Ambulance is used, an attendant must ride with the injured in addition to the driver,
except where the injured could normally be transported in a car or pickup.
OTHER EMERGENCY NUMBERS
or 678-2313
or 587-2237
or 587-2000
1,678-2916 or 678-2334
MANAGERS
The Supervisor will notifr one of the following of all incidents:
R.E. Bartlett 435-678-2495
D. Turk ..435-678-7802 or 435-459-1068
M. Spillman 435-678-2761
A MEMBER OF M4NAGEN4EM WILL NOTIFY THE PROPER REGULATING AGENCIES
AS REQUIRED FOR EAEE INEDENT:
State of Utah, Department of Radiation Control... 801-536-4250
MSHA Field Off.-- 801 -524-3450 Dist. Off. ............ ...... 303 -23 I -5465
MSHA, Arlington... 800-746-1553
State Emergency Response Comm. 801-538-3400
State of Utah, Natural Resources, Dam Safety 801-538-7200
National Response Center .........800-424-8802
Utah Poison Control Center ......800-456-7707
Notification of surrourding communities and or residences will be handled by the appropriate agencies as
required by EPCRA (Emergency Planning and Community Right to Know A6t).
Fire Department............. Dial 9l
County Sheriff........ .. Dial 91
Highway Patro1......... Dial9l
Blanding Police ........ Dial 91
Revision Date: January 16,2006 E-l
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EXHIBIT 2
INTERNAL NOTIFICATIONS
lntemal reporting requirements for Incidents, Spills and Significant Events are as follows:
Report Immediately:
Event Criteria:
Release of toxic or hazardous substances.
Fire, explosions or other accidents.
Government investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or govemment requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $ 1,000,000.
Govemment investigation or enforcement action - limiting operation or penalties
of $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled downtime of more than}4 hours.
Report at the Beqinninq of the Next Business Dav:
Incident Criteria:
Was reported to a government agency as required by law.
Worker (ruSA or contractor) recordable injury or illness associated with a release.
Community impact - reported or awareness.
Publicity resulted or is anticipated.
Release of process material, waste or product in excess of the Reportable
Quantities listed in Section 1.5 of the Spill Prevention, Control, and
Countermeasures Plan.
The local manager in charge is to call Ron Hochstein or Dave Frydenlund.
Name Title Office Phone Home Phone
Ron Hochstein (President and COO) ......303-628-7798 (office)
604-931-6334 (home)
604-377-1167 (cell)
David Frydenlund (V.P. and General Counsel) .........303 -3 8 9-4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
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Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev O (02.14.07)E-2
rr/\trrl,l I 5
SITE LAYOUT MAP
t P:\Adminwaster SoPs\Book 16 Emergency Response Plan\Emergency Response plan Rev 0 (09.29.05).doc E-3
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ExHrBrr 4
MAIN SHUT-OFF VALVES
I During an emergency this list should be used along with Site Layout Map (Exhibit 3) to locate
I tanks and valves associated with these tanks.
f REAGENT
'HUT-'FF
vALvE LocATroNS
I t'""';,lfi*n
located south side of acid tankI fx'.,--::i#
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3" Main (leach area) located 25 feet west of Derrick screens next to walkway
l-112" Main (SX area) located south of Central Control room
I o--otiSnoain
(east tank) located on end at bottom
I
4" Main (west tank) located on end at bottom
2" Yaive iocate<i on top of tank (east iank)
I 2" Valve located on top of tank (west tank)
Kerosene
t
2" Main valve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
I 2" Mainvalve located at bottom of tank (south tank)
Pump discharge 2" valve
I soda Ash
n valve located at bottom of tank (dry storage)
I
4" Main valve located at bottom of tank on3|o/o dilution tank
4" Main valve locate at bottom of tank on dilution tank
I Salt
3" Main valve located at bottom of tank
I
causticafirlin
rulr.located at bottom of tank east and west between supporrs
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EXHIBIT 4
MAIN SHUT-OFF VALVES
Sodium Chlorate
3" Main valve located at bottom of tank (east tank)
3" Main valve located at bottom of tank (north tank)
3" Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3" Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
PLANT UTILITY SHUT.OFF VALVE LOCATIONS
Process Water
Main valve located on west side of water storage tank
Discharge vaive off service waier pump easi
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Main valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2" Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Steam
Main discharge valve for Superior boiler located at top of boiler
Main steam valve located south side of boiler house
P:\AdminWaster SOPs\Book l6-Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E4
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I ExHrBrr 4
MAIN SHUT,OFF VALVES
I Plant AirI H:;l:ffi:ffi#:.##;ff::,',1":T--
I pRocESS
'HUT-.FF
vALvE LocATroNS
- Pulp Storage
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' No.'i valve located on west side of tank
No. 3 valve located on west side of tank
Preleach (old No. 2 pulp storage) valve located on west side of tank
r Preleach Thickener
t Main valve located underneath at center cone
Clarifier
I I":"
*1,"
l*"":*1.-"",lat
center cone
Mam valve located undemeatn at center cone
I ccD ThickenersI Main valve located underneath at center cone of each thickener
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P:\AdminWlaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).do c E-4
9.
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2.
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4.
5.
6.
7.
8.
APPENDIX A
EMERGENCY PROCEDURE RESPONSE TO FIRE
The fire will be reported by dialing 185 on any telephone in the area and announcing the
location of the fire over the paging system. This announcement will be repeated twice,
for a total of three announcements. When the paging system cycles through, the fire siren
(altemating frequency) will automatically sound for approximately forty-five seconds
then automatically shut off, allowing radio communications to resume.
Mobilize the fire crew.
Evacuate all personnel.
Rescue any victims of the fire; do this only with properly trained and equipped personnel.
Isolate utility lines affected by the fire.
Extinguish the fire and post a fire watch for flare-ups.
Report the fire to proper local, State, Corporate and Federal agencies.
In cases where the fire is not extinguished within thirty minutes of discovery, the area
-.--a L^ L-.;^^A^) ^ff ^&^- ^.,a:--..:^L:-- ^-l l^f. ---J:^+,,-L^-l ---.:l -^l^^-^-J l--. I /orr ^rllusr utr uarlu4Ll(/u urr 4ll9l E^trrlBurJurrrB 4rru rtrlr urr(lrJrul rrgu ulLlr Icrs45s.u uJ tvr.,.i-Ln
and IUSA management.
Emergency off-site centers - Blanding Fire House and Sheriff s office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
Sheriff s Office
50 West 100 South, Blanding
Phone number is 911 or [phone]
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APPENDIX B
EMERGENCY PROCEDURE
RESPONSE TO CHEMICAL OR GAS RELEASE
A.chemical or gas release would most likely occur very suddenly. The person who would first
witness a chemical or gas release should immediately contact his supervisor who would initiate
the procedures outlined below:
1. Activate evacuation alarm by using the "dial 184" notification system. Evacuate and
account for all personnel.
2. Mobilize trained personnel and emergency equipment such as SCBA's, first
equipment, etc.
3. Initiate rescue operations for any people who may be trapped by the release.
4. Provide first aid and emergency medical care for any ill or injured persons.
5. Initiate necessary steps to contain and/or neutralize the release, such as spraying
water fog, turning off valves, etc.
6. 9yqd against possible fires by shutting off electrical circuits, isolating gas linesoli-i-a+i-a i--i+i^- cnrrr^od f.^- +L- -ff-^+-,l ^-^^vrrurrusturS r6rxrrvrr JuutvvJ rtvlll ulv qrlwvlvu qv4.
with
and
P:\AdminMaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
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APPENDIX C
EMERGENCY EVACUATION PROCEDURE
I 1.
f":T,ri::rr#Jfon
alarm by using the "dial lS4" notification svstem. Evacuate and account
I 2. Personnel are to assemble in one of the following areas:I : Tffi 33;[TSJ:J
south of the office bulding
t : Iliil"#f:*orra,ings cerr 1' or
3. Mobilize trained personnel and emergency equipment such as SCBA's, first aid equipment,
I etc'
4. Initiate rescue operations for any people who may be trapped.
I 5. Provide first aid and emergency medical care for any ill or injured persons.
6. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
I
eliminating ignition sources from the affected area.
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I P:\AdminWlaster SOPs\Book l6_Emergency Response Plan\Emergency Response PIan Rev 0 (09.29.05).doc A- I
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FIGURE I
FIRE SYSTEM SCIIEMATIC DRAWING
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I p:\Admin\Ir4asrer SOPs\Book l6-Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
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