DRC-2007-001824 - 0901a06880afdb72

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WHITE MESA URANIUM MILL
LICENSB RENEWAL APPLICATION
STATE OF UTAH RADIOACTIVB MATERIALS
LICENSE No. UT1900479
February 28r 2007
Denison Mines (USA) Corp.
1050 17& Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
1. INTRODUCTION..... ............... I1.1 Applicable standards for Review and Approval of this Application...................... I1,.2 Components of this Application ........31.2.1 Application Documenr ...................31.2.2 Environmental Report ....................4I.2.3 Monitoring Reports...... ................61.2.4 Groundwater Monitoring.............. ...................61.2.5 Inspection Reports .......................71.2.6 Listing and Description of Violations, Incident Investigations, Excursions,
Regulatory Exceedances and License Amendments............ .................71.2.7 Chloroform Investigation................ .................71.2.8 THF Study ...................92. PROPOSED ACTMTIES ..................... 102.1 Activity Summary. .......... 103. SITE CHARACTERISTICS ..................124. MrLL PROCESS AND EQUTPMENT .................... 134.1 Conventionally Mined Ores.......... ...................... 134.1.1 Mill Process Summary ................ 134.1.2 Receiving and Stockpiling Delivered Ore ...... 164.1.3 Grinding and Wet Ore Storage ..................... 164.1.4 Leaching... ................ t64.1.5 Counter-Current Decantation (CCD) Washing Circuit....... ................174.1.6 Solvent Extraction.. ..................... lg4.1.7 Precipitation and Dewatering......... ............... lg4.1.8 Drying ..................... t94.1.9 Mill Process Laboratory................ ................. 194.1.10 By-Product Vanadium Recovery ...................204.1.11 Chemical and Reagent Use.......... ..................2O
4.1.12 Process/Chemical Tankage .........22
4.1.13 Fire Protection System ................234.1.14 Instrumentation ........... ................244.2 Alternate Feed Processing......... ......254.2.1 The Mill's Alternate Feed program............... ..................25
4.2.3 Alternate Feed Materials Licensed to Date for Processing at the Mill .................274-3 Direct Disposal of 11e.(2) Byproduct Material From In Situ Recovery Facilities 29
5. WASTE MANAGEMENT SYSTEM ..... 305.1 Gaseous - Mill ................. 30
5.1.1 AirbomeDust and Fume Control - Mill .......305.1.2 Airborne Dust Control - Mill Stockpile... ......345.1.3 Airbome Dust and Fume Control - Process Laboratory ..................-.34
5.2 Liquids and Solids ..........345.2.1 Tailings Retention Area.......... .....345.2.1 Sanitary and Other Mill Solid Wastes ...........405.2.2 Liquid Discharges .....405.2.3 Contaminated Equipment............... ................406. ADMINISTRATION .............416.L Corporate Organization.............. ......416.1.1 Management................. ...............41
6.1.2 Committees ...............446.2 Qualifications............ ......456.3 Administrative Procedures........... ...................... 456.3.1 Management Controls.. ...............456.3.2 ALARA Program.... ....................456.3.3 Training..... ...............466.3.4 Security ....................476.4 Radiation Protection Program... ......4g6.4.1 Mill Extemal Radiation Monitoring ..............4g6.4.1 Mill Airborne Radionuclide Monitoring............ ..............506.4.3 Radioactive Material Intake - CEDE .............53
6.4.4 Total Effective Dose Equivalent. ................... 546.4.5 Bioassay Program ....................... 546.4.6 Contamination Control Program.... ................55
6.4.7 Respiratory Protection Program.... .................556.4.8 Summary of Effectiveness of Mill Controls and Radiation Protection Program.. 556.5 Environmental Monitoring Program ................ 556.5.1 Ambient Air Monitoring............ .................... 556.5.2 External Radiation ......................5g
6.5.3 Soil and Vegetation. ....................5g6.5.3 Meteorological ............ ................ 596.5.4 Point Emission............. ............... 596.5.5 Water......... ................60
6.5.6 Seeps and Springs Monitoring .......................626.5.7 Solid Waste .............63IO
6.5.8 MILDOS AREA Modeting.. .......656.5.9 Summary of Effectiveness of Environmental Controls and Monitoring.............. 657. MILL ACCIDENTS ............. .................... 667.1 Process Accidents ..........6g
7 .l.l Unloading/Storage of Ammonia or propane................. ..................... 6g7.1.2 Leach Tank Failure ................ ...................... 6g7.1.3 Ammonia Explosion in a BuiIding................ ..-..............6g7.1.4 SX Fire...... ................. 697.2 Acts of God........... ......... 697.2.1 Tornado.... ................697.2.2 Flood Water Breaching of Retention System .................707.2.3 Seismic Damage..... ....................707.3 Tailings Accidents.. ........70
7 .3.1 Structural Failure of Tailings Dikes......... ....................... 707.4 Transportation Accidents............. .................... 707.4.1 Concentrate Shipments ...............707.4.2 Ore Shipments............. ..._............717.4.3 Reagent Shipments.. ....................717.5 On Site Spill Countermeasures................ ........ j|
7.6 Emergency Procedures................ .._...................727.6.1 GWDP Contingency plan .........738 RECLAMATION PLAN....... .................749. LISTING AND DESCRIPTION OF YIOLATIONS,INCIDENT
INVESTIGATIONS, EXCURSIONS AND REGULATORY EXCEEDANCES ANDLICENSE AMENDMENTS .......... ........759.1 Regulatory Authorities................. ..................... 759.2 License Violations Identified During NRC or State of Utah Site Inspections SinceMarch 3l,lW7. ...........759.2.I Environmental Control and Radiation Safety Notices of Violation .....................759.2.2 Air Quality Norices of Violation ..................779.2.3 Warer Quality Notices of Violation .......-..-..779.3 Occupational Safety and Health Citations... ......................7g9.4 Excursions,Incident Investigations or Root Cause Analyses, and Resultant
Cleanup Histories or Status since March 31,lgg7. ...........7g9.5 Exceedances of Regulatory Standards or License Conditions Pertaining toRadiation Exposure, Contamination, or Release Limits Since March 31, 1997... g0
9.6 License Amendments Since March 1997.......... .................. g0
10. CONCLUSTONS ..................84
lll
INDEX TO FIGURBS
2.0-l
4.1-l
4.1-2
5.1-l
6.1.1
6.4-l
6.5-l
White Mesa Mill Location Map
Mill Block Flow Diagram
General Layout of the Mill Site
Flow Diagram - Airbome Dust and Fume
Control
Mill Management Organization Chart
Airborne Radiation Sample Locations in Mill
Locations of High Volume Environmental Air
l7
2t
38
59
63
Particulate Monitoring Stations
lv
INDEX TO TABLES
4.2-l
4.2-2
4.2-3
4.2-4
4.2-5
4.2-6
5.1-1
5.t-2
5.2-l
6.4-l
6.4-2
6.5-1
7.0-l
General Features of Alternate Feed Materials
Licensed to Date for Processing at the Mill
Uranium Content of Alternate Feed Materials
Metal and Inorganic Content of Altemate Feed
Materials
Semi-Volatile Organic Compounds in Alternate
Feed Materials
Volatile Organic Compounds in Altemate Feed
Materials
Transportation of Altemate Feed Materials to the
Mill
Gas-Mist-Dust Emissions Equipment Inventory
Stack Heights and Emission Data
Tailings S olution Char acterization Data
Beta-Gamma Survey Locations
Airborne Radiation Sample Locations
Operational Phase Surface Water Monitoring
Program
27
29
30-31
32
33
34
37
39-40
4t-43
55
56-57
66
73trum of Potential Mill Accidents
INDEX TO APPEI\DICES
Appendix Description
A Environmental Protection Manual
B Release and Shipping of Vanadium Blackflake,
Standard Operating Procedure
C Stormwater Best Management Practices Plan
D Emergency Response Plan
E Radiation Protection Manual
F Ore Receiving, Feed and Grind Standard
Operating Procedure
G Uranium Precipitation, Drying and Packaging
Standard Operating Procedure
H SERP Standard Operating Procedure
I ALARA Program
J Training Program
K Security Program
L Respiratory Protection Program
M GWDP Quality Assurance Plan
N Transportation Accidents Plan
O lnspection Reports and Notices of Violation
P Reclamation Plan, Revision 4.0
a Ceil 4A BAT Monitoring Operations and
Maintenance Plan
vi
This page was revised or March 3,2010
INDEX TO APPENDICES
Environmental Protection Manual
Release and Shipping of Vanadium Blackflake,
Standard Operating Procedure
Stormwater Best Management practices plan
Emergency Response Plan
Radiation Protection Manual
Ore Receiving, Feed and Grind Standard
Operating Procedure
Uranium Precipitation, Drying and packaging
Standard Operating Procedure
SERP Standard Operating Procedure
ALARA Program
Training Program
Security Program
Respiratory Protection Program
GWDP Quality Assurance PIan
Transportation Accidents Plan
O Inspection Reports and Notices of Violation
, i,"
A
B
C
D
E
F
H
I
J
K
L
M
N
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1. INTRODUCTION
Denison Mines (USA) Corp. ("Denison")l operates the White Mesa Uranium Mill (the "Mill"),
located approximately six miles south of Blanding, Utah, under State of Utah Radioactive
Materials License No. UT 1900479 (the "License"). The License was last renewed by the
United States Nuclear Regulatory Commission ("NRC") on March 31,1997, for 10 years, and is
up for timely renewal on March 31, 2007 in accordance with Utah Administrative Code("uAC") R313-2246.2
ln accordance with R3l3-22-36, this is an application to the Executive Secretary of the Utah
Radiation Control Board ("the Executive Secretary") for renewal of the License under R3l3-22-
37. This License Renewal Application (the "Application") is appended to and incorporated by
reference in Form DRC-01, 02/94, which is the form prescribed by the Executive Secretary
under R313'22-37 for the renewal of a State of Utah Radioactive Materials License for a
uranium mill.
The Mill is also subject to State of Utah Groundwater Discharge Permit No. UGW370004 (the
"G'WDP"), which was issued on March 8, 2005 and is not up for renewal until March 8, 2010,
and State of Utah Air Quality Approval Order DAQE-AN1205005-06 (rhe "Air Approval
Order") which was re-issued on July 20, 2006 and is not up for renewal at this time. While the
GWDP and Air Approval Order are referred to in this Application from time to time in order to
allow the Executive Secretary to better understand Mill operations and compliance with
applicable regulatory requirements, this is not an application for renewal of either of those
permits.
1.1 Applicable Standards for Review and Approval of this Application
R3l3-22-39 (Executive Secretary Action on Applications to Renew or Amend) provides that in
considering an application by a licensee to renew or amend a
will use the criteria set forth in Sections R3I3-22-33 (General
Specific Licenses) and R3l3-24 (Uranium Mills and Source
Facility Requirements) as applicable.3
license, the Executive Secretary
Requirements for the Issuance of
Material Mill Tailings Disposal
In addition, Form DRC-01, 02194 requires that the application include responses to the
"respective item and/or sub item of the licensing guide," which Denison understands to be the
I Prior to December 16,2006, Denison was named "Intemational Uranium (USA) Corporation."2 Th. Li".rs. was originally issued by the NRC as a source material license under l0 CFR Part 40 on March 3t, 1980. It was
renewed by NRC in 1987 and again in 1997 . After the State of Utah became an Agreement State for uranium mills in August
2OO4,the License was re-issued by the Executive Secretary as a State of Utah Radioactive Materials License on February 16,
2005, but the remaining term of the License did not change.3 p3t3-22-39 also requires the Executive Secretary to use the applicable criteria in R3l3-22-50 (Special Requirements for
Specific Licenses of Broad Scope), and R3l3-22-75 (Special Requirements for a Specific License to Manufacture, Assemble,
Repair, or Distribute Commodities, Products, or Devices Which Contain Radioactive Material) and in Rules, R3l3-25 (License
Requirements for Land Disposal of Radioactive Waste-Ceneral Provisions), R313-32 (Medical Use of Radioactive Material),
R3l3-34 (Requirements for Inadiators), R3l3-36 (Special Requirements for Industrial Radiographic Operations), or R3l3-38
(Licenses and Radiation Safety Requirements for Well Logging). However, none of these criteria are applicable to uranium
mills.
applicable NRC Standard Review Plan for the type of activity being licensed. For the renewal ofuranium mill licenses, Denison has been advised by NRC that the applicable Standard ReviewPlan is the Standard Review Plan for In Situ Leach IJranium Extraciion License Applications,NUREG- I 569, June 2003 ("NUREG- I 569,,).4
Accordingly, this Application must demonstrate that the following criteria enumerated in R313-22-33 are satisfied:
The applicant and all personnel who will be handling the radioactive material arequalified by reason of training and experience to use the material in question forthe purpose requested in accordance with the applicable rules in a minner as to
minimize danger to public health and safety or the environment;
The applicant's proposed equipment, facilities, and procedures are adequate tominimize danger to public health and safety or the environment;
The applicant's facilities are perrnanently located in Utah;
The issuance of the license will not be inimical to the health and safety of thepublic;
The applicant satisfies applicable special requirements in sections R3l3-22-50
and R313-22-75, and Rules R3l3-24, R3r3-25, R3l3-32, R313-34, R313-36, orR3l3-38; and
0 To the extent the original siting of the mill has resulted in any environmental
costs, the Executive Secretary will be able to conclude, after weighing theenvironmental, economic, technical and other benefits against such environmentalcosts and considering available alternatives that the action called for is the
issuance of the proposed license renewal.
R3l3-22-33 provides that a license application shall be approved by the Executive Secretary ifthe Executive Secretary determines that the forgoing criteria are satisfied.
Similarly, this Application must also demonstrate that the Mill continues to comply with theapplicable provisions of 10 CFR Part 40 Appendix A, as required by R3l3-24-3 and mustcontain an environmental report describing the proposed action, a statement of its purposes, andthe environment affected as required byR3r3-24-3 and NUREG-1569.
It is important to note that since this is an application for renewal of an existing licensed facility,this Application will focus on any changes to currently licensed activities andln demonstratin!how existing licensed facilities continue to meet applicable regulatory criteria. As stated in theintroduction to NUREG-1569:
4 NRC staff advised that they did not prepare a similar Standard Review Plan for uranium mills at that time because they did notanticipate any new uranium mills being constructed, and they concluded that, because both uranium mills and ISL uraniumrecovery facilities are subject to I0 CFR Part 40, NUREG- I 569 could be applied universally to both types oiracitities.
a)
b)
c)
d)
e)
For renewals, the licensee need only submit information containing changes fromthe currently accepted license. . . . The licensee need not resubmit a c-ompleteapplication covering all aspects of facility operation. Reviewers should urilyr"the inspection history and operation of the siie to see if any major problems havebeen identified over the course of the license term and should ieview changes tooperations from those currently found acceptable (see Appendix A). If thechanges are found to be acceptable, then the license is acceptable for renewal.
For license amendments and renewals, the operating history of the facility is often
a valuable source of information concerning the adequacy of rit" characterization,
the acceptability of radiation protection and monitorirg i.ogrums, the success ofand adherence to operating procedures and training programs, and other data thatmay influence the staff's determination of compianie. Appendix A to thestandard review plan provides guidance for review of these historical aspects offacility performance. )
As indicated in the excerpts quoted above and elsewhere in NUREG-1569, Appendix A toNUREG-1569 lists the documentation required and the criteria to be applied in connection withlicense renewal applications for uranium mills. Appendix A provides that for license renewals,the historical record of site operations, including air and groundwater quality monitoring,provides valuable information for evaluating the licensing actions. The Appendix then lists anumber of specific areas where a compliance history or iecord of site op.iutiorm and changesshould be provided in the application for review. The Appendix then piovides that if, after areview of these historical aspects of site operations, tfre staff concludes that the site has beenoperated so as to protect health and safety and the environment and that no un-reviewed safety-related concerns have been identified, then only those changes proposed by the license renewalapplication should b-e reviewed using the appropriate sectiois of NuRpc-isoq. The Appendixconcludes by specifically stating that aspects of the facility and its operations that have notchanged since the last license renewar should not be re-examined.
1.2 Components of this Application
In order to satisfy the requirements of R3l3-22-3g, and applicable criteria set out inR3l3-22-33,R3l3-24-3 in accordance with the provisions of NURgc^-isog, this Application is comprised ofthe following:
1.2.1 ApplicationDocument
This Application document describes the Mill's process and equipment; waste systems;administration, including qualifications of personnel, management controls, inspection and auditprograms, training program, radiation protection program, and envirorrn"rtul surveillanceprogram; a review and analysis of potential accidents and the Mill's emergency responseprograms; the Mill's reclamation plan; and a listing and description of violltions, incident
5 NURnc-t569, page xvii.
investigations, excursions and regulatory exceedances. Attached to or incorporated by reference
in this Application are the Mill procedures and programs that are relevant to those matters.
While NUREG-I569 provides that aspects of the facility and its operations that have not changed
since the last license renewal should not be re-examined, it is intended that this Application and
the documents appended hereto and incorporated by reference herein, together with the
accompanying Environmental Report, will
demonstrate that Denison and all Mill personnel are qualified by reason of
training and experience to perform their respective functions in accordance with
applicable rules in a manner as to minimize danger to public health and safety or
the environment;
describe the Mill's existing equipment, facilities, and procedures and demonstrate
that they continue to be adequate to minimize danger to public health, safety or
the environment; and
confirm that the Mill facilities are located in Utah,
as required under R3l3-22-33, and that the Mill continues to satisfy the applicable special
requirements of R3 13-24.
No changes to the Mill's existing equipment, facilities, and procedures are requested as part of
this License renewal process. Some changes to the Mill's equipment, facilities and procedures
have been made with the approval of the NRC or in accordance with existing License conditions
since the last License renewal in March 1997. These changes are reflected in the descriptions set
out in this Application and in the documents incorporated by reference herein. However, since
the changes are comprised in the existing License, Executive Secretary approval of these changes
is neither sought nor requested.
1.2.2 Environmental Report
An Environmental Report accompanies and is incorporated by reference into this Application.
The Environmental Report incorporates by reference, updates or supplements the information
previously submitted in previous environmental analyses performed at the Mill to reflect any
significant environmental changes, including any significant environmental change resulting
from operational experience or a change in operations or proposed decommissioning activities
since the last License renewal on March 31, 1997.o
6 Page xvi of NUREG-1569 provides that an applicant for a new operating license, or for the renewal or amendment of an
existing license, is required to provide detailed information on the facilities, equipment, and procedures to be used and to submitan environmental report that discusses the effect of proposed operations on public health and safety and the impact on the
environment as required by l0 CFR 51.45, 51.60, and 51.66. l0 CFR 51.60 provides that in the case ofan application to renew a
license issued under l0 CFR Part 40 for which the applicant has previously submitted an environmental report, the applicant may
submit a supplement to the applicant's previous environmental report, which may be limited to incorporating by reference,
updating or supplementing the information previously submined to reflect any significant environmental change, including any
significant environmental change resulting from operational experience or a change in operations or proposed decommissioning
activities. Although the regulations in l0 CFR 51.45,51.60 and 51.66, which implement Section lO2(2) of the National
Environmental Policy Act, do not apply to State licensing activities, the State of Utah has its own requirements to prepare an
a)
b)
c)
4
The Environmental Report includes the following matters as contemplated by Appendix A to
NUREG-1569:
a) Updates and changes to any site characterization information important to the
evaluation of exposure pathways and doses including site location and layout;
uses of adjacent lands and waters; population distributions; meteorology; the
geologic or hydrologic setting; ecology; background radiological or non-
radiological characteristics ; and other environmental features;
Environmental effects of site operations including data on radiological and non-
radiological effects, accidents, and the economic and social effects of operations;
Updates and changes to factors that may cause reconsideration of alternatives to
the proposed action;
Updates and changes to the economic costs and benefits for the facility since the
last application; and
The results and effectiveness of any mitigation proposed and implemented in the
original license.
With respect to the assessment of any impact on groundwater resulting from the activities
conducted pursuant to the License, the Environmental Report will incorporate by reference
certain reports, or portions thereof, filed with the Co-Executive Secretary of the Utah Water
Quality Board pursuant to the Mill's GWDP.
Included with this Application are the following previous environmental analyses:
. 1978 Environmental Report, prepared by Dames & Moore. 1978 Final Environmental Statement, prepared by NRC. 1997 Environmental Assessment, prepared by NRC
The result of the foregoing is that, as required by R313-24-3, the Environmental Report, together
with the previous environmental analyses and reports incorporated by reference therein,
describes the proposed action, a statement of its purposes, and the environment affected, and
presents a discussion of the following:
. An assessment of the radiological and non-radiological impacts to the public health from
the continuation of the activities to be conducted pursuant to the License;
Environmental Report in R3l3-24-3. It should also be noted that R313-22-32 states that this Application may incorporate by
reference information contained in previous applications. By including changes since the last appiication and incorporating by
reference those aspects ofprevious applications that have not changed, the Executive Secretary will be able to focus his review
on those aspects of licensed operations that have changed since the license issuance or subsequent renewals.o
' An assessment of any impact on waterways and groundwater resulting from the
continuation of the activities conducted pursuant to the License;
' Consideration of altematives, including alternative sites and engineering methods, to the
continuation of the activities to be conducted pursuant to the Liclnse; and
' Consideration of the long-term impacts including decommissioning, decontamination,and reclamation impacts, associated with the continuation of the activities to be
conducted pursuant to the License.
1.2.3 Monitoring Reports
Copies of the following monitoring reports are included with this Application:
Effluent Monitoring Reports ;
Annual National Emission Standards for Hazardous Air Pollutants (NESHAP)
Reports;
Particulate matter compliance test results for the North yellowcake ScrubberDryer Baghouse and Superior Boiler conducted under the Air Approval Order;
and
Radionuclide Emission Tests for the Yellowcake Scrubber since the last License
renewal in March 1997. It should be noted that due to abeyant operations formost of the time since 1997, particulate matter compliance tests were only
performed in June 2006, and Radionuclide Emission Gsts for the yellowcakl
Scrubber were only performed in the second, third, and fourth quarters of 2006.
Also included are the semi-annual meteorological reports for the last three years.
1.2.4 Groundwater Monitorins
While the Mill currently has a State of Utah GWDP that is not up for renewal until March 2OlO,
certain reports filed with the Co-Executive Secretary of the UtatrWater euality Board under theGWDP are relevant to an evaluation of any potential impacts the Mill could have on theenvironment. Accordingly, the following documents are included with this Application:
GWDP No. uGW370004, as amended, and accompanying statement of Basis;
Quarterly Groundwater and DMT Performance Standard Monitoring Reports
since the issuance of the groundwater discharge permit in March zo05;
Notice of violations under the GWDp dated July 17, 2006 and August 24, 2006
(See Appendix O);
a)
b)
a)
b)
d) Letter dated October 20, 2006 from the Executive Secretary relating to the
resolution of the July 17, 2006 Notice of Violation (See Appendix O);
e) Final Consent Agreement dated October 23,2006 relating to the resolution of the
August 24,2006 Notice of Violation (See Appendix O); and
0 Background Groundwater Quality Report: Existing Wells for Denison Mines
(USA) Corp.'s White Mesa Mill Site, San Juan County Utah, dated December
2006, prepared by Intera, [nc. (See Appendix B to the Environmental Report)
The groundwater status at the site is addressed in detail in the Environmental Report.
1.2.5 Inspection Reports
Included with this Application (See Appendix O) are copies of all NRC and State of Utah
Division of Radiation Control ("DRC") inspection reports and license performance reports, as
contemplated by Appendix A to NUREG-1569, since the last License renewal on March 31,
1997.
t.2.6 Listing and Description of Violations. Incident Investisations. Excursions. Regulatory
Exceedances and License Amendments.
As contemplated by Appendix A to NUREG-1569, included in Secrion 9 of this Application is a
listing and description of:
a) License violations identified during NRC or State of Utah site inspections;
b) Excursions, incident investigations or root cause analyses, and resultant cleanup
histories or status;
Exceedances of any regulatory standard or License condition pertaining to
radiation exposure, contamination, or release limits; and
License amendments.
since the last license renewal on March 31,1997.
1.2.7 Chloroform Investigation
ln May 1999, excess chloroform concentrations were discovered in monitoring well MW-4,
found in the shallow perched aquifer along the eastern margin of the Mill site. Because these
concentrations were above the State Ground Water Quality Standard ("GWQS") for chloroform,
the Executive Secretary of the Utah Water Quality Board initiated enforcement action against the
Mill on August 23, 1999 through the issuance of a Groundwater Corrective Action Order, which
required completion of: 1) a contaminant investigation report to define and bound the
contaminant plume, and 2) a groundwater corrective action plan to clean it up. Repeated
c)
d)
groundwater sampling by both the Mill and DRC have confirmed the presence of chloroform in
concentrations that exceed the State GWQS along the eastem margin of the site in wells that are
upgradient or cross gradient from the tailings cells. Other VOC contaminants have also beendetected in these samples. After installation of 23 new monitoring wells at the site, groundwater
studies appear to have defined the eastem and southern boundaries of the chloroiorm plume.
The Mill is currently in the process of installing additional wells in order to define the westem
and northern bounds of the plume.
Based on the location of the plume and characterization studies completed to date, thecontamination resulted from the operation of laboratory facilities that weri located at the siteprior to and during construction of the Mill facility, and septic drainfields that were used for
laboratory and sanitary wastes prior to construction of the Mill's tailings cells. lnterim measureshave been instituted in order to contain the contamination *d to pump contaminatedgroundwater into the Mill's tailings cells. A final corrective action plan has not yet beendeveloped.
In the Statement of Basis for the GWDP, the DRC noted that7, while the contaminantinvestigation and groundwater remediation plan are not yet complete, the DRC believes thatadditional time is available to resolve these requirements based on the following factors: l) thehydraulic isolation found between the shallow perched aquifer in which the contamination has
been detected and the deep confined aquifers which are a source of drinking water in the area, 2)the large horizontal distance and the long groundwater travel times between the existinggroundwater contamination on site and the seeps and springs where the shallow aquifeidischarges at the edge of White Mesa, and 3) the lack of human exposure to these shallow
aquifer contaminants along this travel path.
Denison and DRC have agreed on a schedule for drilling of the additional
define the boundaries of this plume and for completion of the contaminant
and preparation of a groundwater corrective action plan.
Enclosed with this application are the following:
wells necessary to
investigation report
a) Groundwater Corrective Action Order dated August 23, 1999 (See Appendix O);
and
Quarterly Chloroform
2005.
Reports commencing with the 2nd quarter of
These documents are included as representative of the charactefization and interim corrective
actions taken to date. The Executive Secretary should also refer to the DRC files, which containcopies of all correspondence and reports to date relating to this matter.
' See page 3 of the Statement of Basis, dated Decemb er l,2C/|,4.
1.2.8 THF Study
Detectable concentrations of tetrahydrofuran ("THF') have been found in four wells at the Mill,
including upgradient well MW-l, and far downgradient well MW-3, as well as wells MW-2 and
MW-12 which are close to the Mill's tailings cells. Two of these wells, upgradient well MW-l
and far downgradient well MW-3, have THF concentrations that exceed the State GWeS. The
two other wells, MW-2 and MW-12 that are closest to the tailings cells exhibited detectable THF
concentrations that did not exceed the GWQS. Denison believes that the THF was most likely
derived from PVC glues and solvents used during construction of the PVC well casings found in
several monitoring wells at the facility, including each of the four wells described above. This
position is consistent with the occurrence of THF in both up and far downgradient wells at thesite. However, the Executive Secretary has determined that further evaluation is required to
determine why three other wells installed at the same time do not exhibit detectable THF
concentrations. As a result, Part I.H.19 of the GWDP requires that Denison submit a work plan
to examine this matter further. Such work plan was submitted to the Executive Secretary and
further evaluations are ongoing at this time.
1.2.9 Summary
Denison has attempted to make this Application as complete as possible so that, together with the
information within DRC files, the Executive Secretary will have all information necessary to
determine whether or not:
a) Denison and all personnel at the Mill are qualified by reason of training or
experience to perform their functions in a manner as to minimize danger to public
health and safety or the environment;
the existing equipment, facilities, and procedures at the Mill are adequate to
minimize danger to public health and safety or the environment;
the renewal of the Mill's license will not be inimical to the health and safety of
the public;
the applicable requirements of R3l3-24 and all other applicable regulations have
been satisfied; and
after weighing the environmental, economic, technical and other benefits against
any environmental costs and considering available alternatives, the action called
for is the issuance of the proposed license renewal.
However, if the Executive Secretary requires any further information or has any questions in
order to fully evaluate this Application, Denison would be pleased to supplement this
Application as necessary. All such supplements should be considered to be incorporated by
reference into this Application.
2. PROPOSED ACTIVITIES
Denison proposes to continue to operate the Mill, producing a calendar year limit of 4,380 tons
UlOs. The Mill is owned by Denison White Mesa LLC, a Colorado limited liability company
and an affiliate of Denison. See Figure 2.0-1, Location Map, for regional information and site
location.
2.1 Activity Summary
Feed for the Mill will be provided through: 1) mining operations of Denison and its affiliates,
including joint ventures to which Denison or its affiliates are party, and 2) other
uranium/vanadium mining operations; and 3) alternate feed materials (alone or in combination
with 1) and/or 2) above) containing uranium alone or together with vanadium and/or other
recoverable metals. Nominal uranium content from uranium ores referred to in 1) and 2) above
is expected to range from approximately 0.O4Vo or lower to approximately 4Vo, with an expected
annual average concentration of approximately O.64Vo UrOs or less. Alternate feed materials
may contain uranium in lower concentrations than this, as well as uranium in disequilibrium in
excess of these concentrations, as well as natural thorium and its decay products and other
radionuclides and metals. Mill feed rate will be a function of ore hardness, uranium/vanadium
content, acid consumption and leach retention time and will vary between 1,500 and 2,500 tons
per day (TPD), with annual average throughout of approximately 2,000 TPD.
Mill tailings will be deposited within the existing authorized tailings cells at the Mill. Additional
cells may be constructed and operated in accordance with applicable regulations. Refer to the
Mill's Environmental Protection Manual, included as Appendix A to this Application, for
additional information regarding the tailings retention system.
Liquid wastes are retained in lined cells as described in the tailings management plan, or as
approved through the License Amendment process.
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3. SITECHARACTERISTICS
A full description of the Mill site characteristics is contained in the accompanying
Environmental Report dated February 28,2007.
12
4. MILL PROCESS AND EQUIPMENT
4.1 Conventionally Mined Ores
4.1.1 Mill Process Summary
Operations at the Mill begin with the weighing, receiving, sampling and stockpiling of
conventional ore and other feed materials from various sources. Mine run ore as well as
stockpiled crushed ore is fed at the rate of 1,500 to 2,500 (TPD) to the semi-autogenous grinding
(SAG) Mill, depending on the ore type. The ground feed material, stored as a wet slurry in one
of two agitated tanks, is then fed to the first stage of leach. The two-stage acid leach is followed
by the recovery of uranium-bearing pregnant solution in a counter-current decantation (CCD)
system. Once the pregnant solution is clarified, it is pumped to the solvent extraction (SX)
circuit. Vanadium, when recovered, is stripped from the barren uranium raffinate, also using a
solvent extraction circuit. Both uranium and vanadium are precipitated in their respective
circuits, followed by drying and packaging.
The following sections describe the Mill flowsheet including unit operations and major
equipment groups. A block flow diagram of the Mill's uranium recovery circuit is shown on
Figure 4.1-1. Figure 4.1-2 shows the general layout of the Mill site.
13
Figure 4.1-1
Generalized Flow Diagram of the Uranium Mitling Process for the White Mesa Mill
Ore Stookpihs Atrnsphere
H20 Trommel, Crushing
orGrindhg Clrcuit
Dust Colledion or
Supptession
Solvent
BdracilonlEuex
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StrippirE
Add teadrng Rsagents
Leaoh
r (Rafrnate)
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TatrngsWahr
Rcc!/clo
Opllond Flowhl
Vamdun Reovery
Cirorlt
Atmosphere
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OYARD
100 0 100 200 300:fe€r
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Denison Mines (USA) Corp.
Figure 4.1 - 2
General Layout of the Miil Site
4.I.2 Receiving and Stockpiling Delivered Ore
Conventional ores are delivered by truck to the Mill. Each truck is weighed on a 60-ton truck
scale and unloaded in a specified area on the Mill ore storage pad. The empty truck is reweighed
to determine the net wet tons of ore delivered.
After the empty truck has been weighed, it is washed at the decontamination pad and then
proceeds to the Mill gate. The vehicle is radiologically scanned by qualified personnel to ensure
the vehicle meets the release criteria prior to leaving the Milr site.
The ore is placed in stockpiles based on source of ore prior to processing.
4.1.3 Grinding and Wet Ore Storage
Ore is trammed to the ore grizzly from the storage stockpiles by loaders and trucks. The orefrom the gtizzly is fed at a controlled rate to the semi-autogenous ("SAG") mill circuit.
The SAG mill circuit consists of an 18 foot x 6 foot grinding mill. The Overflow from the sizing
returns to the SAG mill in a closed circuit. The underflow from the screens (opening size varies
in response to ore type) is pumped to the three 35 foot diameter mechanically agitated wet slurry
storage tanks.
Minor spills from the slurry tanks are contained within concrete barriers. This area isperiodically cleaned, with the cleanup retumed to the circuit or taken to a tailings cell. The
slurry from a catastrophic tank failure would flow to the lined catchment basin (Roberts pond)
west of the Mill.
In order to minimize the risk of a tank overflow, operators visually check tank levels
approximately once per hour when grinding.
4.1.4 Leaching
Leaching at the Mill is designed for vanadium, as well as uranium extraction. A two-stage acid
leach having a nominal retention time of 24 hours is employed to maximize recoveries.
The two-stage leach process starts with separating the strong acid leach liquor from the leached
residue in the No. 1 counter-current decantation thickener and mixing it with fresh ore in the first
stage leach tankage. The slurry from the first stage leach is pumped to a cyclone (or altematelyto the pre-leach thickener). The cyclone overflow reports to the pre-leach thickener, while thl
underflow continues through the leach circuit. Acid and oxidants are added through the second
stage leach. The function of the first stage leach is to utilize the residual acidity from the second
stage leach by reacting it with the alkaline constituents of the freshly ground ore, thereby
reducing the amount of chemicals added in the second stage and loweringthi acid content of the
tailings effluent.
The overflow from the pre-leach thickener reports to a conventional thickener called the clarifier.
t6
The underflow from the clarifier is pumped periodically and the slury is returned to the pre-
leach thickener. The overflow from the clarifier is pumped to the claricone, a device that
removes suspended solids through centrifugal action. The overflow from the claricone (pregnant
liquor) is pumped to the solvent extraction circuit.
Concrete curbs are constructed around the leach area to contain spillage from the leach circuit.
This catchment area holds sufficient volume to contain the entire contents of any one of the leach
tanks. The concrete floors are sloped toward floor sumps where spills can easily be washed and
recycled back into the circuit.
In the event of an overflow, each leach tank is constructed with an overflow pipeline down the
side of the tank and directed toward the floor.
The thickened underflow from the pre-leaching thickener is combined with the cyclone
underflow as feed to the second stage leach circuit. Two rubber-lined, steel tanks are used in the
first leach stage and seven rubber-lined, steel tanks all equipped with rubber-covered turbine type
agitators are used in the second stage. Sulfuric acid (HzSOa) and an oxidant are added to the
leach tanks in the second stage to dissolve the uranium and vanadium.
Approximately 250 to 1,000 pounds of H2SOa per ton of ore is typically used, resulting in a free
acid concentration typically of 75 to 180 grams/liter. Oxidant requirements also vary with ore
type, and can run from approximately 3 pounds to 20 pounds of sodium chlorate per ton of ore.
The temperature of the secondary leach circuit is elevated to approximately 60 to 90' C by the
injection of steam.
4.1.5 Counter-Current Decantation (CCD) Washing Circuit
Separation of the strong acid liquor and washing of the leached residue is accomplished in a
multi-stage counter-current thickener arrangement using 40 foot diameter high-capacity type
thickeners. The barren raffinate or tailings solution recycle is added to the final thickener for
washing, drastically reducing fresh water requirements. This intemal recycle is equivalent to
approximately 2.5 tons of solution for each ton of ore processed, or conservation of 833 gallons
per minute of fresh water.
During each CCD thickening stage, solid particles settle to the bottom leaving a clarified
uranium bearing solution at the top of the thickener tank. The underflow slurry is pumped to the
next thickener mix tank ("down" the circuit), while the overflow solution is pumped to the next
mix tank ("up" the circuit). Polymeric flocculants are utilized to increase the settling rates of the
solid in each stage of thickening. The under flow slurry, from the last thickener, is sampled and
pumped to the tailings retention area.
As mentioned above, the solution from the No. 1 CCD thickener is utilized in the first stage
leach circuit before reporting to the pre-leach thickener. Overflow from the pre-leach thickener
is transferred to clarification prior to solvent extraction.
The CCD thickener tanks are situated on a concrete slab with a curb around the perimeter. Any
t7
overflow or spillage from this area is contained within the perimeter unless several thickenertanks would fail or collapse at once. In this event, the contents would flow into the linedcatchment basin west of the Mill area (Roberts pond), as shown in Figure 4.1-2.
The thickeners and claricone have overflow pipelines, flowing to overflow sumps. The overflowfloor sump pump starts automatically when the sump becomes full and diverts tire material to theappropriate circuit.
-
In the event the pre-leach thickener, clarifier, or claricone would collapse,
the contents would flow into the lined catchment basin where it would be contained and pumped
back (Roberts Pond) into the Mill circuit.
4.1.6 Solvent Extraction
Solvent extraction is used to concentrate and purify the uranium contained in the overflowsolution. The solvent extraction process is carried out in a series of mixing and settling vesselsusing an amine-type compound carried in kerosene modified by addition of an alcohol(collectively called organic). The organic selectively adsorbs the dissolved uranyl ions from the
aqueous leach solution. The organic and aqueous solutions are agitated by mechanical meansand then allowed to separate into organic and aqueous phases in thi settling tanks. Each settler
has an area ofabout 1,400 square feet.
This procedure is performed in four stages using a counterflow principle, where the organic flowis advanced to the preceding stage and the aqueous flow (drawn from-the bottom) is advanced tothe following stage. After four stages, the organic phase will typically contain about 5-g gramsof U3Os per liter and the depleted aqueous phase (raffinate) less than 5 milligrams per liter. Theraffinate is discharged to the tailings area (or alternately recycled to th" counter-current
decantation step previously described), or further processed for the i""or"ry of vanadium.
The strip circuit begins when the organic phase is washed with acidified water and then strippedof uranium by contact with an acidified sodium chloride solution in mixer-settler veiiels(strippers). The barren organic solution is cleaned as necessary in the regeneration circuit andretumed to the solvent extraction circuit. The enriched strip solution, typically containing about40-60 grams of U3Os per liter, is stored in the Pregnant Solution tank before being pumped toprecipitation.
All solvent extraction settling tanks (inside the solvent extraction building) are constructed with
an overflow at the discharge end. In the event of a tank overflow or collapse, the content flowsinto the concrete sump on the west edge of the solvent extraction builiing. The sump willcontain the contents of two mixer-settlers. A sump pump is installed in the r*pr to transfer thecollected material to the appropriate tank.
4.1.7 Precipitation and Dewatering
The pregnant solution pumped from solvent extraction is neutralized with ammonia to precipitateammonium diuranate ("yellowcake"). The yellowcake is settled in two 2g-fooi diameter
thickeners in series, and the overflow solution from the first is used as brine makeup solution or
combined with the overflow No.l CCD.
18
A pump withdraws the yellowcake from the thickener and transfers the yellowcake to acentrifuge- The centrifuge further thickens the yellowcake in addition to pioviding another
washing stage.
A concrete curb is constructed around the yellowcake holding and thickening tanks. Spillagefrom any of these tanks is contained by this curb. Sumps are situated inside the curbs and floors
slope to these sumps so yellowcake spills can easily be cleaned up.
4.1.8 Drying
The thickened, dewatered yellowcake sluny is then conveyed to a totally enclosed 6 footdiameter propane fired multiple-hearth dryer (calciner) operating at approximately 650' C (1200'F). The dried uranium concentrate (about 94Vo tJtOil is passed ttrrough a lump breaker toproduce a product of less than ll4 inch size. The dried concentrate, whichls the final production
of the plant, is then packaged in the packaging enclosure into 55-gallon drums for shipment.
The uranium concentrate drying, crushing and packaging operations are conducted in an isolated,
enclosed building with a negative ventilation pressure to contain and collect (by wet scrubbing)
all airbome particles. A description of the scrubber is given in Section 5.1.1.
Radiation, monitoring equipment is all portable, and the monitoring locations are described
under items 6.4.1 and 6.4.2.
4.1.9 Mill Process Laboratory
The Mill office building contains a laboratory. The laboratory performs analytical functions in
the following areas:
a)
b)
c)
include uranium determinations of feed, process, and tailings itreams
uranium release to the tailings area, and analysis of concentrates prior
to the converters.
Examples
to minimize
to shipment
Health. Safety and Environmental samples. Examples are bioassays for urinary
uranium and airborne uranium content from air filters. The Mill also has the
capability to analyze for uranium content of surface and groundwaters, althoughfor compliance samples required under the License or the GwDp, such analysis
are performed by an independent analytical laboratory.
Metallursical samples. Examples include amenability testing of proposed feed tothe Mill, determination of the causes of circuit nonperformance, and exploring
potential circuit improvements.
19
4.1.10 By-Product Vanadium Recoverv
Vanadium is present in some of the ores and is solubilized along with the uranium during
leaching. The solubilized vanadium reports with the uranium raffinate from the SX circuit, with
vanadium recovery commencing in the Vanadium solvent extraction circuit.
The vanadium recovery process consists of a separate solvent extraction circuit to treat the
uranium raffinate and precipitate the vanadium from the strip solution. The uranium raffinate is
pumped to the oxidation and clarification circuit. In this circuit both pH and emf are adjusted
with ammonia and sodium chlorate (altemately hydrogen peroxide), respectively. The vanadium
solvent extraction section is essentially of the same design as utilized for the uranium. An amine
type compound carried in kerosene (the same as used for uranium) adsorbs the vanadium ions
from the uranium raffinate solution. The organic is then stripped of vanadium, with a soda ash
solution. The barren organic solution is returned to the solvent extraction circuit, and vanadium
is precipitated from the enriched strip solution in the vanadium precipitation circuit.
The vanadium oxidation circuit is exterior to the solvent extraction building, and is constructed
on a concrete-curbed slab. Spillage flows to a sump where the solutions can be pumped back to
the circuit. A major tank rupture/failure would flow to tailings for containment.
The precipitated ammonium metavanadate (AMV) is filtered, dried, and can be packaged as a
final product. The AMV can also have the ammonia driven off prior to a fusion step (which
occurs at approximately 800" C) to produce V2O5 @lack flake). Packaging is in 55-gallon steeldrums. Drying and packaging dusts are collected by wet scrubbing to control employee
exposure. The vanadium product must meet release standards for any trace concentrations of
contained radionuclides (see the Mill's Release and Shipping of Vanadium Blackflake standard
operating procedure, included as Appendix B to this Application).
4.l.ll Chemical and Reagent Use
The Mill uses a number of chemicals and reagents in the milling process. The main chemicals
and reagents are described below.
Uranium Circuit
The following are the main chemicals and reagents used in the uranium circuit:
. SAG Mill- Water. Pre-Leach- Water or solutions from the CCD circuit. Pre-leach Thickener- Flocculant
2A
u
. Leach
- Acid (typically sulfuric acid)- Oxidant (Sodium Chlorate, air, hydrogen peroxide or some other type of oxidant)- Steam
CCD
- Water or barren solutions- Flocculant
Solvent Extraction
- Kerosene
- Amine
- Isodecanol
SX Stripping
- Acidified brine (sulfuric acid and salt)
Precipitation and drying- Ammonia- Air
- Propane- Steam
Vanadium Circuit
The following are the main chemicals and reagents used in the vanadium circuit:
. EMF adjustment tanks- Ammonia
- Sodium chlorate. Solvent extraction- Kerosene- Amine- Isodecanol. SX stripping- Soda ash solution
ut Laboratory
The following are the chemicals currently used in the Mill's laboratory in some of the major
procedures performed by the laboratory:
Extraction procedure for Organic samples- Sodium carbonate
Acidmetric Determination of Amines- Perchloric acid- 1,4 dioxane
- THAM (thris hydoxymethy - amino methane)- Methanol- Thymol Blue
2t
- Ethanol
- Sodium carbonate. Determination of Uranium in Ore Samples (Colormetric)
- Perchloric acid
- Nitric acid- Hydrochloric acid- Hydrofluoric acid- Sodium sulfate- Ammonium hydroxide- Acetic acid- Aluminum nitrate- Meta cresol puryle
- Tributyl phosphate
- Iso-octane
- 1,3 diphenyl- 1,3 propanedione
- ethanol
Part I.H.10 of the GWDP required that Denison complete a historical review, and conduct an
inventory of all chemical compounds or reagents stored, used, or currently in use at the Mill
including:
. The identification of all chemicals used in the milling and milling related processes at the
Mill; and
. A determination of the total volumes currently in use and historically used, as data is
available.
Such inventory was prepared by Denison and submitted to and approved by the Co-Executive
Secretary. Part I.D.7 of the GWDP requires that at the time of GWDP renewal, Denison must
submit a report to update this chemical inventory.
Part 1.8.7 of the GWDP requires that Denison monitor and maintain a current inventory of all
chemicals used at the Mill at rates equal to or greater than 100 kg/yr. Such inventory must be
maintained on-site, and shall include, but is not limited to:
. Identification of chemicals used in the milling process and the on-site laboratory; and
. Determination of volume and mass of each raw chemical currently held in storage at the
Mill.
4.1.12 Process/ChemicalTankaee
Tanks are used to store slurries, process solutions, and chemicals throughout the Mill. Different
systems are used to control spillage, either routine or catastrophic, from each tank, depending on
Iocation and construction details. A rupture of any chemical holding tank would: l) be contained
22
by dikes or curbs, 2) flow to the lined catchment basin west of the pre-leach thickener, or 3) flow
to Cell 1.
The sulfuric acid tank is equipped with an overflow near the top of the tank in addition to an
automatic audible signal which will sound before the tank overflows.
In case of a large spill in the Mill, CCD or pre-leach thickener area, such as several tanks
collapsing, a lined catchment basin (Roberts Pond) is utilized ro contain the spills. This
catchment basin holds approximately 1.5 million gallons, which will hold all of the contents
from the pre-leach thickener or the contents of several of the CCD thickener tanks.
Part I.D.8 of the GWDP requires that Denison manage all contact and non-contact stormwater
and control contaminant spills at the Mill in accordance with an approved Stormwater Best
Management Practices Plan. The Mill's Stormwater Best Management Practices Plan is
included as Appendix C to this Application. That Plan includes provisions to adequately:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Groundwater QualityProtection Regulations found in UAC R317-6-6.3(G) and R3l7-6-6.4(c);
b) Prevent, control and contain spills of stored reagents or other chemicals at the Mill site;
c) Cleanup spills of stored reagents or other chemicals at the Mill site immediately upon
discovery; and
d) Report reagent spills or other releases at the Mill site to the Executive Secretary in
accordance with UAC 19-5-114.
Part I.D.3.e) of the GWDP provides that for all chemical reagents stored at existing storage
facilities and held for use in the milling process, the Mill must provide secondary containment to
capture and contain all volumes of reagent(s) that might be released at any individual storage
area. Response to spills, cleanup thereof, and required reporting must also comply with the
provisions of the Mill's Emergency Response Plan, a copy of which is enclosed as Appendix D
to this Application. For any new construction of reagent storage facilities, the secondary
containment and control is intended to prevent any contact of the spilled or otherwise released
reagent or product with the ground surface.
4.1.I3 Fire Protection System
The solvent extraction, warehouse, and office buildings are equipped with sensor operated fire
control systems. In addition, there are hose stations located in the Mill yard. The solvent
extraction building has a foam dispersion sprinkler system. The main water supply tank has a
250,000 gallon reserve, for fire protection use, which feeds an automatic starting diesel-fired
pump rated at 2,000 gallons per minute at one hundred pounds pressure per square inch. The fire
protection system receives documented monthly inspections. Refer to the Mill's Emergency
Response Plan, included as Appendix D to this Application.
23
4.1.14 Instrumentation
Automatic or semi-automatic instruments are utilized where applicable in the Mill circuit for
safety, quality control, and process efficiency. The following describes the current
instrumentation controls. The Mill is currently undergoing a review of its instrumentation and
controls.
i. Grinding Circuit and Wet Ore Storage
The rate the ore is fed to the grinding circuit will be determined by belt scales. The ore feed rate
is controlled by the operator. Feed to the grinding circuit is shut down by electric circuit
interlocks in the event of equipment failure.
ii. Leach Circuit
Sulfuric acid and an oxidant, such as sodium chlorate, are added to the leach slurry to dissolve
the uranium. The acid content is measured manually by titration and/or pH. Control is by
manual adjustment of acid addition as indicated by an in-line flowmeter. Oxidation potential is
determined in the leach slurry from individual samples. Oxidant is added as a slurry or solution
and controlled manually through an in-line flowmeter.
Steam is injected into the leach slurry to elevate the temperature to approximately 80-90'C. The
slurry temperature is monitored by tank thermometers and controlled by manual adjustment of
steam addition.
iii. Counter-Current Washing of Leach Solids
The leached solids are washed in the CCD thickener circuit.
Determination of the density of the individual thickener underflow slurries is measured manually
as well as flocculant additions and pumping rates are by manual operation.
iv. Solvent Extraction
The flow rate of the pregnant liquor feed to the solvent extraction circuit is determined by a mass
flow (magnetic) meter and the flow is controlled automatically. Flow rates are recorded
continuously.
The organic flow rate is controlled similar to the pregnant liquor, except a differential pressure
flowmeter is utilized in place of the magnetic flowmeter. Flow rate of the pregnant strip solution
is controlled and recorded in the same manner as the pregnant liquor feed.
24
v. Precipitation
The pregnant liquor
anhydrous ammonia.
measurement.
from solvent extraction strip circuit is neutralized by the addition of
The addition of the ammonia is automatically controlled by pH
vi. Drying and Packaging
The partially dewatered yellowcake slurry is dried and calcined in a multi--hearth dryer at about
650' C. The temperature of the dryer is controlled by automatic thermal controllers. An audible
signal indicates excess temperature in the dryer. In addition, the yellowcake feed pump to the
dryer is interlocked with the scrubber fan and water circulating pump. This feed pump, as well
as the discharge scrubber fan, will shut down if the scrubber water supply fails. A flow meter is
installed on the scrubber water supply line and checked twice per shift.
Manometer readings of the yellowcake dryer off gases are checked twice each shift and
recorded.
R adi at i on S afe ty and M o nit o rin g I n s t rum e nt at i o n
Equipment used in monitoring for the radiation safety program is detailed within the Radiation
Protection Manual included as Appendix E to this Application.
4.2 Alternate Feed Processing
4.2.1 The Mill's Alternate Feed Program
In addition to processing conventionally mined ores for the recovery of uranium and vanadium
for many years, the Mill License gives the Mill the right to process other uranium-bearing
materials known as "alternate feed materials," pursuant to the Alternate Feed Guidar..8.
Alternate feed materials are uranium-bearing materials, other than conventionally mined uranium
ores, such as residues from other processing facilities, which usually are classified as waste
products to the generators of the materials. Each different altemate feed material requires an
amendment to the Mill License. The Mill can process these uranium-bearing materials and
recover uranium, alone or together with other valuable metals such as niobium, tantalum and
zirconium. License condition 9.11 also requires that, prior to the placement of alternate feed
material, Denison must determine using a SERP-approved procedure, that adequate tailings cell
space is available for that additional material.
As of February 28, 2007, the Mill has received fourteen license amendments, authorizing the
Mill to process seventeen different alternate feed materials. As of February 28,2007, the Mill
has processed over 360,000 tons of alternate feed materials, recovering over 1.6 million pounds
of U:Og from these materials.
8 See NRC Regulatory Issues Summary 00-023, Recent Changes to ILranium RecoveryPolicy, (November 30, 2000).
25
4.2.2 Processins Altemate Feeds
General
The Mill circuit that is applicable to processing altemate feed materials generally follows the
description given in Section 4.1 for conventionally mined ores, but usually with some minor
variations, depending on the type of feed.
Alternate feed materials that are received in bulk and require grinding are typically introduced
into the Mill circuit in the same fashion as conventional ores. Alternate feed materials that are
received in bulk but that do not require grinding are typically introduced into the Mill circuit by
way of a trommel. Altemate feed materials that are received in drums can be introduced into theMill circuit by way of a remote barrel dumping station.
Certain altemate feed materials require modifications to the process steps described in Section4.1, including the use of ion exchange alone or in combination with solvent extraction.
Generally, the changes to the process involves utilizing some, but not all of the steps, or
changing the order of the steps, or in some cases modifying the reagents, used for procissing
conventional ores.
Introducing Alternate Feed Materials Into the Mill circuit via Trommel
To feed the Mill from its stockpiles of bulk alternate feed ores, the ore is dumped, by front-end
loader, through a stationary grizzly and into an ore-receiving hopper. The ore is then transferred
to the trommel screen via a conveyor belt. Water is added with the ore into the trommel wherethe washing of the material, break-up of the larger material, and removal of debris is
accomplished. The finer particles, now in slurry form, are pumped to the pulp (wet) storage
tanks. The debris that is removed is hauled to the tailings cells where it is placed in lifts priorio
placement of random fill cover material.
Introducing Alternate Feed Materials Into the Mill Circuit via the Remote Drum
Dumping Station
The Mill also has specific equipment for remotely emptying drums of alternate feed materials.
This equipment is used for drummed material that has a high specific activity and that can not be
introduced into the Mill circuit manually.
Uranium Extraction
For some alternate feed materials, ion exchange or a combination of ion exchange and solvent
extraction is used rather than solvent extraction alone.
The ion exchange circuit is utilized to extract dissolved uranium from clarified pregnant liquor.
The ion exchange process selectively removes uranium from an acid water solution, leaving
unwanted metals in solution. The uranium-acid solution from the clarifiers, or the aqueous feed,
is pumped to the first ion exchange column. Ion exchange resin, in the form of small beads, acts
26
the same as the organic in the solvent extraction circuit in that it picks up uranium in the
extraction phase and releases uranium in an acid stripping solution. After uranium bearing
solution flows through the columns, the resin is "loaded" and the aqueous is barren of uranium.
The barren aqueous solution or "raffinate", now free of uranium, leaves the extraction stage and
is pumped to the CCD thickener circuit as a washing solution or is disposed of in a tailings cell.
From the extraction stage, the uranium bearing resin is pumped to the stripping stage, where
uranium is stripped from the resin by an acid brine. The brine leaves the circuit typically
containing approximately 40 times the concentration of uranium as comp.ued to the acid water
solution or aqueous that was introduced into the ion exchange circuit. The resin leaving the strip
stage of the circuit is free of uranium and ready for re-use in the extraction stage. The loaded
high-grade strip solution is then pumped to a solvent extraction circuit for further purification.
The raffinate from the solvent extraction circuit is pumped to the tailings cells. The loaded high-
grade strip solution from the solvent extraction circuit is then pumped to the precipitation circuit.
4.2.3
Table 4.2-1 sets out the sources of altemate feed materials and their source material content that
have been licensed to date for processing at the Mill.
at the Mill
27
4.3 Direct Disposal of 11e.(2) Byproduct Material From In Situ Recovery Facilities
License condition 10.5 authorizes the Mill to dispose of 11e.(2) byproduct material generated at
licensed in situ recovery facilities, subject to the following:
o Disposal of waste is limited to 5,000 cubic yards from a single source;
All contaminated equipment must be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges must be emptied into the
disposal area and the barrels crushed. Barrels containing soil or sludges must be verified
to be full prior to disposal. Barrels not completely full must be filled with tailings or soil;
All waste must be buried in Tailings Cell No. 3 unless prior written approval is obtained
from the Executive Secretary for alternate burial locations; and
All disposal activities must be documented. The documentation must include descriptions
of the waste and the disposal locations, as well as all actions required by license condition
10.5.
An annual summary of the amounts of waste disposed of from off-site generators is sent to the
Executive Secretary.
29
5. WASTE MANAGEMENT SYSTEM
The methods used for control of gaseous emissions and liquid/solid effluents are discussed
below.
5.1 Gaseous - Mill
Table 5.1-1 summarizes the ventilation, confinement, filtration, and dust collection system
relating to emission sources at the Mill. Tab 1.4, Stack Emissions, in the Environmental
Protection Manual included as Appendix A to this Application, details measurement procedures
for gaseous effluents.
5.1.1 Airborne Dust and Fume Control - Mill
Dust generated in the ore hopper area is collected in a reverse jet bag house dust collecting
system. Bag house negative pressure checks are made and logged every two hours. In addition,
a dust suppression spray system is installed in the SAG mill feeding system and used when
exceedingly dry ores are being fed to the SAG mill. Water added for these purposes remains
with the ore and goes to process. See the Mill's Ore Receiving, Feed and Grind Standard
Operating Procedure included as Appendix F to this Application for specific operational
parameters and procedures.
The Mill operates two yellowcake dryers feeding into a single packaging area. Yellowcake
particles carried in flue gases and fumes from each of the uranium dryers pass through two
different scrubbing trains that are joined in a common discharge stack. Both trains consist of a
Ducon UW-4 wet scrubber, or equivalent, followed by Ducon packed tower mist eliminator, or
equivalent. The wet fan scrubbers are intended to remove particulates, while the packed tower is
intended to remove gases and mists that may contain dissolved solids. Air from the packaging
area enclosure is cleaned through a baghouse with a separate discharge stack. Figure 5.1-1 is a
flow diagram that sets out the airbourne dust and fume control systems for both the uranium and
vanadium circuits at the Mill, as taken from the Mill's Air Approval Order. See the Mill's
Uranium Precipitation, Drying and Packaging Standard Operating Procedure included as
Appendix G to this Application for specific operational parameters and procedures.
Specifications for the fan-type scrubbers show efficiencies to be greater than 99 percent. Figure
5.1-1 is a flow diagram that sets out the airboume dust and fume control systems for both the
uranium and vanadium circuits at the Mill, as taken from the Mill's Air Approval Order. See the
Mill's Uranium Precipitation, Drying and Packaging Standard Operating Procedure included as
Appendix G to this Application for specific operational parameters and procedures.
The solution and particulates collected from the scrubbers are recycled to the No. I yellowcake
thickener.
30
o
troo
o
EFf+rrutPEd
E,glLo
oc
o.rt
E9Ea9
EO
!!;]E
E(u
Lo)
.go
=o
TL
EfE(U
E(d
Ec(U
E.fC(U
f
t
ciLoo
U)f
ao
l-
=Co
.9,
l-oo
f
LC
Eq
Ea60>F
9-E E8.e5 EE -Ee I'iqd 5
E{d
The monitored emission rate from
approximately 4,000 scfm containing
approximately 2 pounds per hour.
the yellowcake dryer emission stack during operation is
0.050 pounds per hour UrOs, with a total emission rate of
The stack is approximately eighteen inches in diameter,
above roof level and consists of discharges from bothextending approximately eighty feet
scrubbers.
Two wet dust collectors also are installed to collect and recycle dust generated from the
vanadium drying operation. An isolated portion of the building is utilized for precipitation,
drying, and packaging of the vanadium. Since uranium is removed prior to vanadium recovery,
virtually no release of radioactivity is expected in the vanadium drying and fusion step.
Processing buildings and equipment are provided with ventilation fans, hoods and ducting to
control the concentration of gaseous effluents. Table 5.1-1 describes the Gas-Mist-Dust
Emission Equipment inventory at the Mill.
Table 5.1-1
Gas-Mist-Dust Emissions Equipment Inventory
Source Emission Type Control Method Control Design Efficiency
Ore from Stockpile
to SAG Mill
Pre-Leach
Agitators and Final
Leach Agitators
Boiler, Gas Fired
Boiler, Oil Fired
Uranium and
Vanadium
Extraction
Yellowcake
Drying and
Packaging
Vanadium Drying-
Fusion
Vanadium
Fugitive Dust
Mist
Flue Gas
Flue Gas
Vapor
Vapor-Dust
Dust
Dust Baghouse Dust
Collectors (3,060
Sq. Feet)
Covered Tanks,
and Demister
Exhaust Fans to
Atmosphere
NA
NA
Forced Air
Building
Ventilation
Wet Fan Scrubbers
Wet Venturi
Scrubber
Wet Venturi
Scrubber
Torit Model T-d 99.9
3,060 Ft2- Air to
Cloth Ratio L6:l
Heil Model 716
14,000 cFM
NA
NA
Vent Fans, up to 6-
Changes per Hour
Ducon Packed
Towers and Mist
Eliminator
Sly Wet Venturi
Scrubber 12,000
CFM
Sly Venturi
Scrubber 6,980
CFM
99.s
99.5
Dust
32
99.s
A forced air ventilation system designed for the entire solvent extraction and stripping buildings
removes kerosene vapors. The ventilation fans are checked visually for proper operation on a
daily basis. In addition, the fans are equipped with a "running light" so that a malfunction is
readily apparent.
Table 5.1-2 summarizes information regarding the Mill discharge stacks and effluents.
Table 5.1-2
Stack Heights and Emission Data
Mill Facility Release
Height Feet
Exit Exit Radionuclide
Diameter TemperatureInches Degree F
Observed
Emissions
uCi/ml
Ore Hopper 4,300
CFM
Leach Exhaust
r3,700 cFM
Yellowcake Dryingand Packaging
4,000 cFM
Yellowcake Dryer
(Shaft Cooling)
Vanadium Dryer
Vanadium Dryer
(Shaft Cooling)
Boiler, Propane
Boiler, Propane
Laboratory Fume
Hood
Boiler, Propane
(sx)
35 18 Ambient Unat
Ra-226
Th-230
Pb-210
Unat
F.a-226
Th-230
Pb-210
Unat
Ra-226
Th-230
Pb-210
NA
NA
3E-t I
2E-fi
6E-12
lE-l I
3E-l I
5E-13
7E-13
3E-13
lE-9
5E-14
5E-13
2E-12
NA
NA
13036t0l
200l883
l2
38
l2
26
26
l0
70
83
70
20
20
35
200
r88
r88
NA
NA
NA
NA
NA
NA
NA
60
43 l0
33
NA NA
5.1.2 Airbome Dust Control - Mill Stockpile
A daily inspection of the ore stockpile area for dusty conditions will dictate if dust suppression
measures are necessary. The inspection is documented by the radiation staff and filed with the
radiation department. If dusty conditions are present, the roadways and/or stockpiles will be
sprayed with water or stabilized to minimize dusting. A log sheet of water applications is
maintained by the radiation staff. See Section 3 of Tab 3-3, Tailings Dust Minimization, in
Appendix A for the products used to control airbome dust on the ore pad.
5.1.3 Airborne Dust and Fume Control - Process Laboratorli
The Mill facility is complemented with an analyical laboratory which routinely assays ore,
process streams and final products to ensure adequate quality control and plant operating
efficiency. The laboratory fume hoods collect air and mixed chemical fumes for venting to the
atmosphere. These gases contain non-radioactive chemicals, including acids and organics. The
volume of gaseous fumes emitted from the laboratory operations is small and free of dust as
samples processed in the analytical laboratory are wet.
Dust is controlled in the sample preparation room (bucking room) utilizing dust collector
systems over the pulverizer and crusher. Two ISSCO .003 dust collectors with 100 square foot
filter bags, or the equivalent, are used to control dust. (Model PB-12 with 825 cfm, or the
equivalent).
Liquids and Solids
The design of the Mill is such that any leaks or spills are collected and recycled to the
appropriate part of the process, thus eliminating any product loss, hazard to personnel, or
contamination of the surrounding area. These collection systems are described in detail in
Section 4.1 under the specific equipment headings.
Most process liquids are recycled in the Mill; however, about one ton of liquid (water) for every
one ton of tailings solids is discharged to the impoundment area. The water is required to
transport the solid tailings. In addition, the elimination of some process water in this manner
avoids a buildup in chemical ions that could affect the Milling process.
5.2.1 Tailings Retention Area
The tailings (both slurry and solution) from the Milling operation are discharged by pipelines to
an impoundment system southwest of the Mill.
i. Available Characterization Data For Tailings Solutions
Some limited historic wastewater quality sampling and analysis has been done at the Mill's
tailings cells. Some of this work included pre-construction laboratory bench top testing by the
previous Mill operator to estimate the possible contaminants that might be discharged to the
tailings wastewater. Several historical samples of the tailings effluent have been collected and
5.2
34
analyzed by both the NRC and the Mill to determine the chemical properties of the tailings
wastewater for a limited number of parameters.
Part I.E.S of the GWDP requires that, on an annual basis, the Mill collect wastewater quality
samples from each wastewater source at each tailings cell at the Mill, including, but not limited
to: surface impounded wastewaters, and slimes drain wastewaters. Part LE.S of the GWDP also
requires that all such sampling shall be conducted in August of each calendar year in compliance
with an approved Tailings Cell Wastewater Quality Sampling Plan required by Part I.H.5 of the
GWDP. Denison submitted a draft Tailings Cell Wastewater Quality Sampling Plan to the
Executive Secretary for approval on August 4,2005. The draft Plan is currently under review by
the Executive Secretary. Once the Plan is approved by the Executive Secretary, Denison will
commence annual sampling in accordance with that Plan.
Table 5.2-1 sets out the available data as of February 28, 2007 characterizing the tailings
solutions, as taken from the GWDP Statement of Basis.
From this information it is evident that the pre-construction laboratory testing, which analyzed,
effluents to be discharged to the tailings system, under-estimated the actual concentration of
several contaminants that would accumulate over time in the tailings wastewater. Other pre-
construction estimates over-predicted the average measured concentrations, including: silica,
barium, calcium, manganese, and gross alpha. These concentration differences are indicative of
either variability of the feedstocks input to the Mill, the variability of the milling process itself,
and/or increasing concentrations in the solutions in the tailings cells over time due to
evaporation.
35
Table 5.2-1
Tailings Solution Characteri zation Data
Contaminant
1979
Benchtop
Estimate(l)
(melL)
September, 1980 - March, 2003
Mill / NRC Tailings Wastewater Samples(2)
Reported Concentrations
Min.
(me/L)
Max.
(me/L)
Average
(ms/L)
Std. Dev.
(me/L)
Sampl
e
Count
PH (std units)1.8 - 2.0 0.i 2.33 1.83 o.52
Nutrients (mgA)
Ammonia (N)65 3.C r 3,90(3, 130.65 3,3 r 8.4C t7
Nitrire (N)< 100 r00 < t00
Nitrate (N)24 24 24
Nitrite+Nitate (N)l7.a 49.2 30.91 12.53 t2
Phosphorus-total 88. I 62C,273.03 111.23 t7
rKN (N)4,9U 5,30C 5,10i 282.84 2
lnorganics (mg/l)
Bicarbonate (HCO3)<5 5 <5
Bromide < 500 500 < 500 I
3arbonate (CO3)<l <5 < 1.3 l3
Chloride 3,05C 2,lta 8.00c 4,608.44 2,372.39
Cyanide - total 0.o2,0.022 o.o2 I
Fluoride t.4 0.02 4,440 1,694.'t t.M9.2t l3
Phosphate < 500 < 500 < 500
Silica 30(I lc 40t 210.c,164.62
Sulfate 82,2U 29.80C 190,00c 64,913.9 48,36t.C I
Sulfide <5 <5 <5
TDS nla 43,100 r 89,00c 85,960 40,645.55 I
TOC 76.A 8l 78.50 3.54 2
TSS 3l .0 l15 73.0C 59.4(2
Metals (me/l)
Aluminum 4,26t 330.C 2530 1,826.9 591.63 t6
Antimony <20 <20 <20 J
Arsenic 52 0.3 44C t49.1 1 48.1 8 22
Barium 0.3 0.021 0.lc 0.04t 0.02 l3
Beryllium o.341 o.78 0.502 0.r3 t5
Boron 3.:I 1.3 6.9 2.83 l6
Cadmium t.7l 1.il 6.(3.4 r.58 t'1
3alcium 48ol 90.c 6301 361.1 124.7C I
Sfuomium 6t l.c l3 6.2 3.38 I
lobalt N/a t4.c t20l 60.'1 54.12 J
Sopper 1.6201 72.2 7401 234.4 206.O2l t1
lron nla 1080.0 34001 2,2t1 887.561 l6
Gallium 30 <30 30 3
Lead 0.21 6.0 3.01 t.261 t4
o
o
Contaminant
1979
Benchtop
Estimate(l)
(ms,lL)
September, 1980 - March, 2003
Mill / NRC Tailings Wastewater Samples(2)
Reporl .ed Concentrations
Min.
(me/L)
Max.
(mg/L)
Average
(me/L)
Std. Dev.
(ms,IL\
Sampl
e
Count
Lithium <10 <2(< 17.5 < 5.C 4
Magnesium 4,06C I,800 7.90C 4,773.i r,871.03 l9
Manganese 4,58C 74.4 222 145.t 34.16 t8
Mercury 0.001 0.000t 17.6 3.5 7.81
Molybdenum 7 0.44 24f.52.E 71.11 I
Nickel N/a 7.2 37(82.C I 15.4C I
Potassium 219.C 82t 433.1 215;7C l4
Selenium 0.5(0.18 2.4 1.4 0.61 I
Silver 0.0(0.005 0.14 0.1 0.10 2
Sodium 4,90C 1,40c r0,00(5,808.7 3,072.10 l9
Strontium 3.6 t4 7.4 4;t4 4
Ihallium 0.7 45 r 6.0 20.54 8
Iin <5 <5 <5 3
Iitanium 6.5 -t -, --t l9.l I l.7C t2
Uranium 2.5 5.0 154 93.C 41.2C l1
Vanadium 240 l3(5r0 263.1 I I l.9l
Linc 90 5C r 300 640.6 598.48 5
Zirconium 2.3 38.5 12.2 12.oc t4
Radiologics (pCiA)
Gross Alpha 250,00c 14,000 189,00c 120,49a 50,345. t l5
Gross Beta 74 I 16,00c 68,942 3s,918.8 l5
Lead-2 l0 680 20.100 3,385 4,660.1 l7
Ihorium-230 3,65(76.640 21,148 r s,394.8 I
Ihorium-232 49 t2t 8i 27.9 I
Polonium-210 r,4lc l,4l(l,4lc
Radium-226 4C I,69(1,027 497.2 l5
Radium-228 t.9 I 1.9
Total Radium 42 t,10c 942 553.2 t9
Selected VOCs (ugfl)
Acetone 28 514 192 278.4 3
Benzene <5 <5 <5 2
2-butanone (I\GK)lt 15.13 13.38 2.13 J
larbon Disulfide l6l l6 t6 I
3arbon tetrachloride <5 <5 <5 2
Chloroform 6t 16.84 10.28 5.77 3
I , I -Dichloroethane <51 <5 <5 2
1,2-Dichloroethane <5 <i <51 2
Dichloromethane l0l ll l0.sl 0.71
Tetrahydrofuran n-a n-2 n-al n-c n-a
Ioluene <5 6.2s1 < 5.62 2
Vinyl chloride < l0l < l0l < tOl 2o
5t
Contaminant
1979
Benchtop
Estimate(r)
(mell-)
September, 1980 - March, 2003
Mill / NRC Tailings Wastewater Samples(2)
Reported Concentrations
Min.
(me/L)
Max.
(melL\
Average
(mell-)
Std. Dev.
(mgil)
Sample
Count
Selected Semi-VOCs
tusn)
Xylene (total)<5 <5 <5 2
Benzo(a)pyrene <lc <lc <lc
Bis(2-
ethvlhexvl)phthalate
I
Ckysene <lc <lc <lc 2
Diethyl phthalate <lc 18. I l8. t 3
Dimethylphthalate 2.1 2.7 2.1 3
Di-n-butylphthalate 1.08 1.08 1.08 J
Fluoranthene <10 <10 <l(2
2-Methylnaphthalene <10 <10 <l(2
Naphthalene 2.M 2.44 2.44 -)
Phenol <lC 38.4 38.4 -1
Footnotes:
I ) From May, I 979 NRC Final Environmental Statement, p. 3- I I , Table 3. I . Original concentrations reported in units of gmllitet converted here to mg/liter.2) Based on samples collected by Denison and the NRC between September, 1980 and March, 2003. For details see Attachment 6 to the GWDp Statement ofBasis.
38
u.CeIl Design
The tailings impoundment consist of a series of cells that are designed for phased construction
and reclamation. The conceptual and permitted total capacity is for the quantity of Mill tailings
produced from a l5-year operating period at a rate of 2,000 TPD, operating 365 days per year.
The cells are membrane lined to provide containment of solids and liquids.
In addition to the barren ore slurry and barren solvent extraction raffinate discharged to the
impoundment area, uranium source material contaminated solid wastes are disposed of in the
tailings area. To prevent damage to the tailings cell liners, these contaminated solid waste
materials (e.g., discarded or scrap metal, wood, etc.) are only placed on top of the tailings
material deposited in that cell. This provides a barrier between the material and the liner.
Materials containing voids are crushed or modified so as to eliminate air pockets which may
cause future differential settling. Existing License Condition 10.4 delineates procedures for the
disposal of source material contaminated material within the tailings impoundments.
The tailings and evaporation cells are designed and constructed as below grade disposal
facilities. Each cell includes an engineered membrane liner, and a leak detection system. The
leak detection system is designed to provide an early warning of catastrophic liner failure.
Tailings cells l, 2 and 3 were constructed and approved for use in 1979-1980 in accordance with
NRC requirements and by the State of Utah State Health Department. See the Mill's GWDP and
Statement of Basis for additional details on the tailings cell design and construction. As those
cells were constructed in 1979 and 1980, they do not meet every current Best Available
Technology ("BAT") standard applicable to the design and construction of similar cells today.
However, the Statement of Basis for the Mill's GWDP concludes that tailings cells 1, 2 and 3
meet the discharge minimization technology ("DMT")/criteria set out in UAC P.3l7-6-6.4(c) and
are therefore permitted for continuous use, in accordance with the terms of the GWDP, which
imposes additional DMT perfonnance standards and monitoring requirements.
iii. Relining of Tailings Cell4A
Tailings cell 4,{ was designed and constructed and placed into operation in 1990 in accordance
with the requirements of l0 CFR Part 40 Appendix A and 40 CFR I92 and was approved by
NRC. Unlike tailings cells 1, 2 and 3, tailings cell 4,A, was designed with a one-foot clay liner
beneath the synthetic liner and leak detection system. However, the synthetic liner in cell 44
experienced seam degradation and damage, as it was only used for a short period of time in 1990
for the disposal of raffinates and has not been used since. In 2001, the calculated flow rate in the
leak detection system for Cell 4A exceeded one gallon per minute and notice was provided to
NRC procedures were followed pursuant to License condition 11.3D.
The raffinates, resulting crystals, and radioactive solids have been removed from cell 44, and
Denison is currently in the processing of re-lining the cell. Part I.D.4 of the GWDP provides that
any construction, modification, or operation of new waste or wastewater disposal, treatment, or
storage facilities shall require submittal of engineering design plans and specifications and prior
Executive Secretary review and approval. Part I.D. 4 also provides that all engineering plans or
39
specifications submitted shall demonstrate compliance with all BAT requirements stipulated by
the Utah Groundwater Quality Protection Regulations (UAC R317-6). Denison has submitted to
the Executive Secretary for approval, under Part I.H.l5 of the GWDP, engineering design plans
and specifications for the re-lining of cell 4 that demonstrate compliance with BAT criteria.
5.2.1 Sanitary and Other Mill Solid Wastes
Trash, rags, wood chips, and other solid debris, including solid waste (trash) from office
buildings, plant buildings, e.g., florescent light bulbs containing mercury, NiCd, batteries, etc.
are collected and buried in the designated tailings dump area. Coveralls used in the yellowcake
area are laundered at the Mill. Mill personnel are provided with a change room and laundering
facility to allow them to leave their work clothes at the Mill. All liquid effluents from the
laundry are routed to the tailings retention system.
Liquid laboratory wastes are discharged to the tailings retention system.
Sanitary wastes are disposed of in state approved leach fields.
5.2.2 Liquid Discharees
No effluents are released into waters of the United States. Therefore, no request has been made
to obtain a UPDES permit under R317-8-3.
5.2.3 Contaminated Equipment
All equipment contaminated by source material in the Mill process is buried in a designated zoneper 10 CFR Part 40 within the tailings impoundments or, if released, is decontaminated for
unrestricted use as specified in NRC Guidelines for Decontamination of Facilities and
Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct,
Source, or Special Nuclear Material, NRC, May, 1987. All solid contaminated waste from
Milling operations will be buried in the Mill's tailings retention system.
40
6. ADMINISTRATION
6.1 Corporate Organization
Denison is a wholly owned subsidiary of Denison Mines Holdings Corp., a Delaware
corporation, which is in turn wholly owned by Denison Mines Corp., an Ontario, Canada
corporation. Uranium operations are managed by Denison, primarily from offices located in
Denver, Colorado.
6.1.1 Management
The management organization of Denison, relevant to Mill operations, is illustrated in Figure
6.1-1.
4t
Figure 6.1-1
Denison Mines (USA) Corp.
Mill Management Organization Chart
42
The authority and responsibilities of each level of management as shown in Figure 6.1-1 is as
follows:
The President and Chief Operating Officer of Denison is responsible for all of the practices and
decisions made by those personnel reporting to him. He delegates the authority for the decisions
in the uranium mining and milling operations to the Executive Vice President, Operations. The
President and Chief Operating Officer of Denison reports to the Chief Executive Officer of
Denison Mines Corp. The Chief Executive Officer of Denison Mines Corp. is also the Chief
Executive Officer of Denison.
The Executive Vice President. Operations reports to the President and Chief Operating Officer of
Denison and is responsible for conducting Denison's uranium mining and milling operations in a
safe and efficient manner. These responsibilities include safety programs, and environmental
and security practices. He also has responsibilities for reclamation operations as well as new
facility development.
The Vice President and General Counsel reports to the President and Chief Operating Officer of
Denison and is responsible for coordinating and reviewing environmental and safety practices to
ensure regulatory and corporate standard compliance. This position performs or oversees
periodic audits of the facilities to identify potential liabilities and recommend remedial actions.
The Manager. Environmental Affairs reports to the Vice President and General Counsel and is
responsible for providing services and coordinating functions to the Mill's Radiation Safety
Officer, Safety Coordinator and operations personnel relative to environmental, occupational
health and permitting activities.
The Mill Manager reports directly to the Executive Vice President, Operations and is responsible
for all of the day-to-day operations, maintenance and functions at the Mill, as well as compliance
with the Mill's health, safety, and environmental practices and standards. His duties also include
reviewing appropriate Mill operations with the Radiation Safety Officer, and Safety Coordinator
to ensure operational compliance with corporate and regulatory standards.
The Radiation Safety Officer is directly responsible for developing, implementing, monitoring,
and reporting activities that ensure that the Mill radiation safety program meets applicable
standards. This responsibility involves monitoring, maintenance, and evaluation of personnel
exposure and plant area surveys; determination of occupational work modifications relative to
radiation protection; personnel radiation protection training; maintenance of plant radiation
monitoring equipment; and report preparation for regulatory agency compliance. The Radiation
Safety Officer reviews plant procedures and equipment and develops and coordinates procedure
modifications for radiological protection and As Low As Reasonably Achievable ("ALARA")
policy adherence.
The Radiation Safety Officer is also responsible for safety compliance at the Mill. His duties
include oversight of the Mill's Safety Coordinator.
In addition to his responsibilities for radiation and occupational safety, the Radiation Safety
43
Officer is also responsible for providing necessary monitoring to comply with regulatory permits
and licenses. These responsibilities include Mill emission sources, solid and liquid waste
disposal systems, and off-site environmental concems. In addition, the Radiation Safety Officer
is responsible for the tailings reclamation technology and operating supervision of the tailings
cells.
The Radiation Safety Officer reports to the Mill Manager and is authorized to escalate concerns
to the Manager, Environmental Affairs, Executive Vice President, Operations, Vice President
and General Counsel, or President and Chief Operating Officer of Denison as the Radiation
Safety Officer deems necessary.
The Safety Coordinator is responsible for developing, implementing, monitoring, reporting and
coordinating safety affairs for the Mill. His duties include general safety training of personnel;
safety procedures and practices development and implementation; enforcement; industrial
hygiene monitoring other than radiation protection; and first aid instruction and fire protection
training. Compliance with MSHA and corporate safety standards are the responsibility of this
position. The Safety Coordinator reports to the Radiation Safety Officer with lateral reporting
functions to the Mill Manager.
The Radiation Safety Officer and Safety Coordinator have sufficient authority to enforce
regulatory compliance and ensure employee health and safety at the Mill. They have the
authority to cancel, postpone, or modify any operation or process which poses an immediate
radiological, safety, or environmental hazard. The positions have the authority to escalate
concerns to the Manager, Environmental Affairs, Executive Vice President, Operations, Vice
President and General Counsel, or President and Chief Operating Officer of Denison, as
necessary. These positions may be assigned support staff (such as Radiation Technicians and
Environmental Technicians) to maintain compliance with the applicable regulations. Such staff
will be assigned primarily health, safety, and environmental duties and will not be assigned
duties in areas where their authority or disposition to perform health, safety and environmental
protection duties is impaired.
6.I.2 Committees
Denison has established two committees that have a regulatory compliance oversite function at
the Mill: the ALARA Committee and the Safety and Environmental Review Panel ("SERP").
The ALARA Committee is comprised of key Mill and Denison operational and regulatory
personnel. The ALARA Committee meets quarterly and reviews all Mill public health, safety
and environmental matters to ensure that the Mill is operated safely, in a manner that is within
regulatory standards and that exposures to workers and the public are maintained as low as
reasonably achievable. See Section 6.3.2 below for a description of the Mill's ALARA Program.
The Mill's SERP is established pursuant to License condition 9.4 and determines whether or not
any proposed changes in the facility or process, changes in procedures not presented in the
License application and the proposed conduct of any tests or experiments not presented in the
License application meet the conditions set out in License condition 9.48 and can be made
44
without the need to file an application for a License amendment. The SERP membership
requirements are set out in License condition 9.4B. The SERP functions in accordance with the
SERP standard operating procedure included as Appendix H to this Application.
6.2 Qualifications
The minimum qualifications of radiation protection personnel associated with uranium
processing at the Mill are set out in the ALARA Program, included as Appendix I to this
Application.
6.3 Administrative Procedures
6.3.1 Management Controls
Activities at the Mill involving design, procurement, construction, pre-operational checkout,
operations and maintenance of safety or environmentally related equipment will be authorized by
written procedures approved by the Radiation Safety Officer, and/or the Safety Coordinator,
respectively. These procedures will comply with Denison's standards and conditions of
applicable permits, licenses and regulatory requirements. The Mill Manager is responsible to
ensure compliance.
Administrative policies and procedures are documented to clearly delineate the authorities and
responsibilities for each level within the facility with regard to environmental, radiation
protection, and safety related activities. See the Radiation Protection Manual included as
Appendix E to this Application for the current policies and procedures.
Appendices A and E delineate the current environmental monitoring and radiation protection
procedures. Appendices B, C, D and H include the Vanadium Blackflake Release and Shipping,
the Stormwater Best Management Practices Plan, Emergency Response Plan and SERP standard
operating procedures. Written operations procedures are detailed in Appendix F and G, Ore
Receiving, Feed and Grind and Uranium Precipitation, Drying and Packaging, for the radiation
protection and environmental control related aspects at the grinding and yellowcake circuits.
The remainder of the operations procedures are available for review at the Mill. These
procedures are reviewed annually by the Mill Manager and the Radiation Safety Officer.
6.3.2 ALARA Proeram
The program that Denison utilizes to ensure that employee radiological exposures and effluent
releases are "as low as reasonably achievable" (ALARA) and is the sum of all design barriers,
operating procedures, management controls, and personnel experience and expertise
incorporated in operation of the Mill facility.
The plant design, (see Sections 4.0 and 5.0), including the equipment to control and prevent
effluent releases and to sample and monitor the working environment, reflects proven technology
that is capable of meeting current regulatory standards. Potential releases, both in the plant and
to the environment, will be held within the performance capability of the control equipment
45
through regular inspection and maintenance of the equipment.
The ALARA Program, included as Appendix I to this Application, sets up procedures intended
to ensure that all operating procedures, management controls and personnel experience and
expertise are such that the Mill is operated in a manner that ensures exposure to workers and the
public are as Iow as reasonably achievable.
Under the ALARA Program, routine inspections are performed, minimum qualifications of key
personnel are established, training requirements are mandated, periodic reviews by the ALARA
committee of all matters relating to public health, safety and the environment are conducted, and
the scope of the arurual ALARA audit of the Mill and its activities are set out.
6.3.3 Training
The purpose of the in-house safety training program is to place in proper perspective for
employees the potential short- and long-term hazards associated with the job; to acquaint
employees with practices instituted by management to minimize occupational exposures; and to
ensure that employees have an understanding (both initially and over the duration of the
employee's employment) of the radiation, health, safety and environmental protection
procedures employees should be following.
Each person, upon reporting for employment at the Mill, will receive instruction in the following
to be updated after completion of Training Program and ALARA program:
. Employeelndoctrination. Statutory Rights of Miners. RegulatoryJurisdiction. TransportationandCommunication. Emergency Procedures. First Aid. Hazard Recognition. Hazard Communication. Radiation Protection Program. Prenatal Radiation Review. Radiation Protection Review. Respiratory Protection Program
The instruction will also include on-the-job demonstrations of proper safety precautions, and
measures to be taken to minimize radiation exposure. These instructions and precautions are
summarized in the Training Program, included as Appendix J to this Application. Each
employee will also be provided a safety manual which covers radiation safety and industrial
safety procedures including personal hygiene instructions for use of monitoring and safety
equipment, and procedures for handling spills and maintaining clean working conditions. Each
employee will be required to pass a written test on their understanding of radiation safety and
hygiene.
46
The employee's understanding and retention of proper practices will be validated by the
supervisor at the work location through use of periodic checks. If the employee does not exhibit
sufficient grasp of the safety procedures, they will receive further instruction from the
employee's supervisor. This procedure will be repeated until satisfactory retention is
demonstrated. On-the-job training and testing will be conducted and the results recorded to
ensure that each employee understands applicable safety and radiation protection practices.
In addition, a portion of monthly Mill safety meetings will be set aside for discussion of radiation
protection procedures and, on an annual basis, one of the monthly meetings will be set aside for
re-indoctrination of the Mill staff in radiation protection. Each employee will be tested annually
by the Radiation Safety Officer or another member of the radiation safety staff on the
employee's understanding of radiation protection as related to the employee's job. All
supervisors will be required to periodically attend specific training courses in radiation and
industrial protection, so that they will be better able to provide and evaluate specific job-related
training.
Employment at the Mill is comprised of Denison employees and employees of White Mesa Inc.("WMI"). WMI is an independent Native-American owned services company that provides
workers to the Mill on a contract services basis. All WMI personnel who work at the Mill are
provided the same training as Denison employees working at the Mill.
As a result of the Mill's training program and compliance with the qualification requirements for
key Mill personnel set out in the Mill's ALARA Program, included as Appendix I to this
Application, Denison and all personnel who will be handling radioactive materials under the
License are qualified by reason of training and experience to use such materials.
6.3.4 Securit),
The Mill and tailings area is fenced and posted with "Restricted Area" signs in accordance with
10 CFR 20.203. As set forth in License Condition 9.9, the Mill is exempted from the
requirements of R313-15-902(5) for areas within the Mill, provided that all entrances to the Mill
are conspicuously posted in accordance with R3l3-15-902(5) and with the words, "Any area
within this facility may contain radioactive material". Refer to Figure 4.1-2 showing a plot plan
of the Mill and tailings area delineated with the fence around the Restricted Area.
The Mill, During operating or stand-by periods, has personnel on site seven (7) days per week,
twenty-four (24) hours per day. All visitors are required to register at the office and are not
permitted inside the plant Restricted Area without proper authorization and escort. Access to the
Restricted Area by the public is controlled by physical barriers and operating personnel.
Contractors having work assignments are given security, safety and radiation protection
orientation prior to performing their duties without escort. The Mill's Security Program is
included as Appendix K to this Application.
47
6.4 Radiation Protection Program
The Radiation Protection program at the Mill consists of several layers of controls to ensure
conditions are maintained ALARA and to achieve corporate and regulatory agency compliance.
The program consists of management controls, administrative procedures, and monitoring
programs. Management controls and administrative procedures are designed to ensure the
existence of and adherence to a Mill program that is functional in achieving corporate and
regulatory agency compliance. The controls create a review process of operations, management
practices, and monitoring capabilities. The monitoring programs consist of personnel exposure
documentation, Mill effluent identification and control, process system operation documentation,
off-site environment exposure documentation, and quality control procedures, both analytical
and managerial.
6.4.1 Mill External Radiation Monitoring
The purpose of the personnel monitoring program
measurements of personnel exposures to direct radiation
maintain conditions ALARA. The program identifies
indicated to maintain potential exposures ALARA.
is to provide accurate and timely
and to provide managerial controls to
areas where managerial controls are
i. Personnel External Radiation Exposure
Luxel@ (OSL) badges or the equivalent, obtained from Landauer Corporation, or an equivalent
competent supplier, are utilized to determine individual external radiation exposures. Badge
recordings are made in compliance with UAC R3l3-15-1107 and 1111.
Badges are assigned to each worker working within the restricted area. Badges are issued within
thirty days of employment at the facility. The cumulative occupational dose of the workers will
be filed in accordance with UAC R313-15-1107 and 1111. Exposure exceeding 25 percent of
the UAC R3l3-15-201 limits will result in a modification of worker job assignments and a
review of conditions causing exposure to exceed that objective.
The badges will be analyzed on a quarterly basis. Further discussion is presented within the
personnel external radiation monitoring Section 1.3 of the Radiation Protection Manual, included
as Appendix E to this Application.
ii. Mill Area Extended Radiation Monitoring
Radiation area monitoring is used throughout the Mill site to protect plant personnel and to assist
in detecting abnormal operating conditions.
A combination of beta and gamma radiation measurements are obtained monthly at locations in
the Restricted Area as described in Table 6.4-1. A combination of fixed and removable alpha
radiation measurements are obtained weekly at lunch locations in restricted and unrestricted
areas.
48
Identification
Number
wM-1
wM-2
wM-3
wM-4
wM-5
wM-6
wM-7
wM-8
wM-9
wM-10
wM-11
wM-12
wM-13
wM-14
wM-15
wM-16
wM-17
wM-18
wM-19
wM-20
wM-21
wM-22
wM-23
wM-24
wM-25
wM-26
wM-27
wM-28
wM-29
wM-30
wM-31
wM-32
wM-33
wM-34
wM-35
wM-36
wM-37
Table 6.4-1
Beta-Gamma Survey Locations
Description of Possible Source of Area of
Exposure
Mill Feed Hopper and Transfer chute
SAG Mill Intake-Feed Chute
Screens-Area Floor Between Screens
Leach Operators Desk
Leach Tank Vent No. 3
Leach Tank No. 3 Wall
Counter-Current Decantation Thickeners
Pumphouse Tailings Discharge
Oxidant Makeup Room - Sump Pump
Shift Foreman's Office-Work Desk
SX Operator's Area
Precipitation Tanks No. I Tank, Wall
Precipitation Section "Lab Bench"
Precipitation Vent
Yellowcake Thickener No. 1, Wall
Centrifu ge Discharge-Chute Wall
Yellowcake Thickener No. 2, Wall
Yellowcake Packaging Room
Yellowcake Dryer
Yellowcake Dust Collector
Solvent Extraction Uranium Mixer No. 1 Extractor
Solvent Extraction Uranium Mixer No. 1 Stripping
Solvent Extraction Vanadium Mixer No. 1
Stripping
Vanadium Dryer
Mill Laboratory Fume Hood
Chemical Laboratory Work Area
Metallurgical Laboratory Work Area
Lunchroom Eating Area
Lunchroom Wash Area
Maintenance Shop - Work Area
Maintenance Shop - Rubber Coating Area
Tailings Impoundment Discharge Area
Tailings lmpoundment Dike I
Tailing Impoundment Dike 2
Tailings Impoundment Dike 3
Scalehouse
Tailings Impoundment Dike 4
Distance From
Source in Feet
I
1
1
1
49
These areas may change from time to time as considered appropriate by the Radiation Safety
Officer to reflect any changes to Mill operations or facilities.
These locations may vary in number depending upon the staffing during operating and non-
operating periods. For further monitoring procedure information see Sections 1.3 and 2.4 of the
Radiation Protection Manual, included as Appendix E to this Application.
6.4.1 Mill Airborne Radionuclide Monitoring
i. Uranium Dust
Several forms of airborne radionuclide sampling are utilized to determine personnel exposure to
dust. Area monitoring on a monthly basis during production periods, for those areas listed in
Table 6.4-2 and shown in Figure 6.4-1, provides the main approach to determining persorurel
exposure. Areas associated with yellowcake are monitored weekly. These areas may vary in
number depending on the staffing during operating and non-operating periods.
Table6.4-2
Airborne Radiation Sample Locations
Code Location/Description
BA-1
BA-2
B4-6
BA-7
BA-7A
BA-8
BA-9
BA-IO
BA-11
BA-I2
BA-12A
BA-I28
BA-I3
BA-13A
BA-14
BA-15
BA-16
BA-17
BA-18
BA-I9
BA-20
BA-2I
BA-22
BA-22A
Ore Scalehouse
Ore Storage
Sample Plant
SAG Mill Area
SAG Mill Control Room
Leach Tank Area
CCD Circuit Thickeners
Solvent Extraction Building/Stripping Section (North Area)
Solvent Extraction BuildingiControl Section (South Area)
Yellowcake Precipitation and Wet Storage Area
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Precipitation and Wet Storage Area
Yellowcake Packaging Enclosure
Packaged Yellowcake Staging Area
Met. Lab. Sample Preparation Room
Lunch Room Area (New Training Room)
Change Room
Administration Building
Warehouse
Maintenance Shop
Boiler
Vanadium Panel
Vanadium Dryer
50
Code
BA-23
BA-24
BA-25
BA-26
BA-27
BA-28
BA-29
BA-30
Filter Belt/Rotary Dryer
Tails
Control Room
Shifters'Office
Operations Lunch Room
Dump Station
Filter Press
Truck Shop
These areas may change from time to time as considered appropriate by the Radiation Safety
Officer to reflect any changes to Mill operations or facilities.
Area monitoring for natural uranium in dust in the air is accomplished utilizing air samplers
calibrated to 40liters per minute with a sample duration of a minimum of sixty minutes and then
counted using a Ludlum Model 2200 with a Ludlum Model 43-lO probe for gross alpha, or the
equivalent. Further details are presented in the appropriate section of the Radiation Protection
Manual. Personnel time exposure to the monitored areas is recorded on a daily exposure time
sheet by the employee. Using this information and the monitored air concentrations, an
employee exposure record is developed. The Derived Air Concentrations ("DAC") to be used in
the various areas of the Mill are described in Section 4 of the Radiation Protection Manual,
included as Appendix E to this Application.
Sampling will be performed under conditions typical of employee exposures. A record of the
state of operation of both process and effluent control equipment and ventilation conditions will
be maintained along with area sampling results.
5l
Figure 6.4-1
Airborne Radiation Sample Locations
OCC U PATIONAL AIRBORNE ACTIVITY MON ITO RING LOCATTONS
(PARTICULATE & RADON) AT THE WHTTE MESA M|LL
l€A-71
ORE STORAGE
f BA-l I
SCALEHOUSE
rrr>
I BA4ol
ffimml'i..s.r-';@;. <x(@r,a.sv. i.i;;;;. r*€
*6:,
Gr*;i:,i::
lrlLl l{rLor&
'St- Eurorucala { t+
52
Yellowcake drying and packaging operators are required to wear individual air samplers at leastevery two weeks which will then be counted for gross alpha exposure. Individual air samplerswill consist of breathing zone monitors.
Mill operating and maintenance personnel working in processing areas, where the potentialpersonnel exposure is projected to exceed 25 percent of UAC R313-15-201 limits to uraniumdust, will be monitored with individual air samplers on a periodic basis during the time workedin those areas to establish typical uranium dust exposu."r fo, those individuals. Individual airsamplers consist of a sampling pump and lapel filter holder capable of sampling at a rate of 4liters per minute for eight hours.
License condition 11.4 requires that annually the Mill shall collect a set of air samples covering g
hours of sampling, at a high collection flow rate (i.e., greater than or equal to +o liters ferminute), in routinely or frequently occupied areas of ttre Mitt. These .r*pi., are analyzed iorgross alpha. The results of this sampling are set out in the Mill's Semi-Annual Effluent ft."portr,which accompany this Application. In addition, License condition 11.4 requires that, with eachchange in Mill feed material or at least annually, the Mill shall analyze the Mill feed or finalproduct for U-nat, Th-230, Ra-226, and Pb-210 and use the analysis results to assess thefundamental constituent composition of air sample particulates.
For further air particulate monitoring procedure information see Sections 1.1 and 2.1 of theRadiation Protection Manual, included as Appendix E to this Application.
Section 3.13.1.8(d) of the Accompanying Environmental Report shows historic results for airparticulate exposure to workers at the Mill.
ii. Radon Progeny
Radon progeny is measured on a monthly basis with weekly sampling being performed at areasabove 25Vo Maximum Permissible Exposure ("MPE") during prodr"iion perioos at the sampleareas listed on Table 6.4-2. The locations may vary in numbir-depending on ttre staffing duringoperating and non-operating periods. Sampling will be accompliihed uiing a SKC AIRCI{EKpump and filter unit or equivalent, with levels measured using a Ludlum-M odel ZZO0 with aLudlum Model 43-10 probe, or equivalent. The modified kusnetz sampling and analysisprocedure will be utilized. Exposure levels for employees are calculated using resuliantconcentration and time records, based upon employee ti*" card information. For furtherprocedure information see Section 2.2 of the Radiation Protection Manual included as AppendixE to this Application.
6.4.3 Radioactive Material Intake - CEDE
When routine work is performed, assessment of an individual's exposure to airborne naturaluranium and radon daughters, which together comprise the worker's bommitted Effective DoseEquivalent (CEDE), is calculated using the results of the prescribed sampling in each area andthe time spent in each area of exposure as determined by careful observation of the task
53
performed by each individual exposed. Quarterly breathing zone samples using prescribed
portable samplers are taken to ensure reliability of this procedure. Individuals wearing samplerswill be determined by analysis of routine samples and their likelihood of reaching the action
level of 25 percent MPC.
When non-routine maintenance is performed, accurate time records are kept to calculate
exposure to natural airborne uranium. Dust samples taken while work is being done are used in
this exposure assessment. Periodic breathing zone samples, using prescribed portable samplers,
are taken [o ensure accurate assessment of exposure during non-routine work assignments.
The observed time spent in each area where routine work is performed, and where exposure
beyond the 25 percent MPC action level is likely, are recorded and the accuracy of the
observation reviewed quarterly, or when major changes are made in job assignments.
If a worker reaches an action level of 25 percent of MPC based on Time Weight Exposure
("TWE") over a period of one quarter, the Radiation Safety Officer will institute an investigation
of their work record and exposure history to identify any problem areas. If any problem areas
are noted, they are studied and necessary corrective measures taken to ensure that the exposure is
ALARA.
Section 3.13.1.8(h) of the accompanying Environmental Report shows historic results for CEDE
measurements for workers at the Mill. The Environmental Report concludes that all doses were
well below the 5 Rem maximum exposure limit and that the average was well below the ALARA
goal.
6.4.4 Total Effective Dose Equivalent
Total Effective Dose Equivalent ("TEDE") is the combination of direct radiation exposure and
CEDE, and represents the total dose for the worker. R313-15-201 prescribes a maximum TEDE
for adult workers of 5,000 mrem per year. The Mill has set an ALARA goal for TEDE of 25Vo
of this prescribed limit, or 1,250 mrem per year.
Section 3.13.1.8(h) of the accompanying Environmental Report shows historic results for TEDE
for workers at the Mill. The Environmental Report concludes that all doses were well below the
5 Rem maximum exposure limit and the average was well below the ALARA goal. In addition,
Table 13.13.17 of the Environmental Report showed that the TEDE for workers while processing
either Arizona Strip ores or Colorado Plateau ores were well below the ALARA goal.
6.4.5 Bioassav Prosram
The bioassay program conforms to the urinary uranium program outlined in Revision I
Regulatory Guide 8.22. Where the word "should" appears in the Regulatory Guide, it is
interpreted as meaning "shall". For further procedure information see Section 1.4 of the
Radiation Protection Manual included as Appendix E to this Application.
54
6.4.6 Contamination Control Prosram
All personnel working within the Mill area are provided with change room, shower, and laundry
facilities. Personnel working in the yellowcake product areas or performing maintenance on
equipment from these areas are provided coveralls and are required to change and shower prior
to leaving the Mill. All workers are also required to monitor themselves with an alpha survey
meter prior to leaving the Mill. Alpha contamination on skin or clothes greater than 1,000
dpm/100 cm shall be cause for additional showering or decontamination and an investigation by
radiation protection staff. Spot checks with a survey meter also are made at least quarterly.
Coveralls and contaminated clothing are laundered on site.
6.4.7 RespiratoryProtection Program
A respiratory protection program includes written procedures and personnel training in the use,
care and selection of respirators as outlined in ANSI-288.2-1980. The Mill's Respiratory
Protection Program is included as Appendix L to this Application.
6.4.8 Summar.v of Effectiveness of Mill Controls and Radiation Protection Program
As mentioned above, the Mill's radiation protection program consists of Mill design, Mill
process control, and monitoring and other radiation protection practices. As is evident from the
historic monitoring results for worker exposures at the Mill, the Mill equipment, facilities and
procedures have been very successful in maintaining occupational radiation exposures within
regulatory limits and within the Mill's ALARA goals and are adequate to minimize danger to
workers.
6.5 Environmental Monitorin g Program
The environmental monitoring program is designed to assess the effect of Mill process and
disposal operations on the unrestricted environment. Delineation of specific equipment and
procedures is presented in the Environmental Protection Manual, included as Appendix A to this
Application.
6.5.1 Ambient Air Monitoring
i. Ambient Particulate
Airbome radionuclide particulate sampling will continue at the five locations currently
monitored, termed BHV-I, BHV-2, BHV-4, BHV-5 and BHV-6. With the approval of the NRC
and effective November, 1995, BHV-3 was removed from the active air particulate monitoring
program. At that time, tle Mill proposed (and NRC determined) that a sufficient air monitoring
data base had been compiled at station BHV-3 to establish a representative airborne particulate
radionuclide background for the Mill. BHV-6 was installed by the Mill at the request of the
White Mesa Ute Community. This station began operation in July of 1999 and provides airbome
particulate information in the southerly direction between the Mill and the White Mesa Ute
Community. Figure 6.5-1 shows the locations of these air particulate monitoring stations.
55
I
I'll[2m7ue@Rffil &Dlloton\FlguB\fl9@ 6.'l.dw9, FCrc 65'1, 0223/tO7 10:37:10 r}t,
I 1'fr I'r, t:*+- *J- It.,=,?l=!\.'n I!\. !qL _A !'1 t t-l--
.=* f zi,
#1. -tj i*ou-"* i
\ '\^ -\ ,--
y"?
\ | t,*,.\-,
SCALE IN FEET
-JO!7"-Tl)tti if*L I
I
I
_t
I
I
Ijr t f ./'{r r fI i (' Jif ={ei--i
I lt /0tZi;\i,a.-tN_,t irl /--
\..1-'' ..*" )' ..j
i ir\"E )\, r_ ,.
i ..*,! t
.--!-
I nt-' .J| .-' -1l. l_' .-t )
-t-IIa
I
I
i.'
,
I
lr
,le
orea,2r8ro.
2LolE
I
li'
l-
I
I
l_
i
I
I
I
I
It_
tr,tlr.
.
IIt,-'f-"? IltL
:
I
T,rr
lr -tlt,iIII
l.
ll:Ys
?
iart
f,,r
a,J qr'
ar-
tt
,ilul,'
iiIs-I--I
CJ.i,lrf
F llr
Property Boundary Air Monitor
StationsReservation Boundary
rrrrrrr Canyon Rim
Denison Mines (USA) Corp.
Figure 6.5 - 1
Locations of High Volume Environmental
Air Particulate Monitoring Stations
The present sampling system consists of high volume particulate samplers utilizing mass flow
controllers to maintain an air flow rate of approximately 32 standard cubic feet per minute.
Samplers are operated continuously with a goal for on-stream operating period at ninety percent.
Filter rotation is weekly with quarterly site compositing for particulate radionuclide analysis.
Analysis is done for U-natural,Th-23O,Ra-226, and Pb-210. For further procedure information
see Section 1.1 of the Environmental Protection Manual, included as Appendix A to this
Application.
See Section 3.13.1.7(a) of the accompanying Environmental Report for a summary of historic
monitoring results for airborne particulate. As indicated in the Environmental Report, airborne
particulate is well controlled at the Mill. The data obtained since program inception in 1981
indicates that only one individual quarterly measurement has "r"r i*.""ded the Effluent
Concentration Limit (ECL) at the Mill. With regard to that particular single measurement, while
it is important to consider and evaluate an individual measurement exceeding the ECL, for public
dose estimation purposes it is the annualized data that are of primary significance. In that
instance, the annualizedTh-Z3} data for that monitoring station for that year are well below the
ECL for the annual period. In addition to these observations, evaluation of the data by
comparison to the Mill's ALARA goals reveals that, with very few exceptions (9 out of 1,944
individual measurements), the gross (background inclusive) measurements also do not exceed
the site's ALARA objectives which have been established at25Vo of the ECL.
ii. Ambient Radon
With the approval of the NRC, Radon-222 monitoring at the BHV stations was discontinued in
1995, due to the unreliability of monitoring equipment available at that time to detect the new 10
CFR standard of 0.1 pCi/I. From that time until the present, the Mill demonstrated compliance
with the requirements of R313-15-301 by calculation authorized by the NRC in September 1995
and as contemplated by R313-15-302 (2) (a).
This calculation was performed by use of the MILDOS code for estimating environmental
radiation doses for uranium recovery operations (Strenge and Bender 1981) in 1991 in support of
the Mill's 1997 license renewal and more recently in 2003 by use of the updated MILDOS
AREA code (Argonne 1998). The analysis under both the MILDOS and MILDOS AREA codes
assumed the Mill to be processing high grade Arizona Strip ores at full capacity, and calculated
the concentrations of radioactive dust and radon at individual receptor locations around the Mill.
Specifically, the modeling under these codes assumed the following conditions:
. 730,000 tons of ore per year. Average grade of 0.53Vo U3Os. Yellowcake production of 4,380 tons of U3O8 per year (8.8 million pounds U3Os per
year).
Based on these conditions, the MILDOS and MILDOS AREA codes calculated the combined
total effective dose equivalent from both air particulate and radon at the current nearest residence
(approximately 1.2 miles north of the Mill), i.e., the individual member of the public likely to
receive the highest dose from Mill operations, as well as at all other receptor locations, to be
57
below the ALARA goal of l0 mrem/yr for air particulate alone as set out in R313-15-101(4).
Mill operations are constantly monitored to ensure that operating conditions do not exceed the
conditions assumed in the above calculations. If conditions are within those assumed above,
radon has been calculated to be within regulatory limits. If conditions exceed those assumed
above, then further evaluation will be performed in order to ensure that doses to the public
continue to be within regulatory limits. Mill operations to date have never exceeded the License
conditions assumed above.
Detection equipment has improved since 1995, and the Mill has decided that, commencing with
the first quarter of 2007, it will re-institute direct measurements of radon at the five air
particulate monitoring locations currently utilized for air particulate sampling. System quality
assurance will be determined by placing a duplicate monitor at one site continuously.
Monitoring methodology will consist of a Trak Etch monitoring system, or the equivalent.
lntegration duration will be continuous for one quarter with quarterly exchange canisters for
analysis. For further procedure information see Section 1.2 of the Environmental Protection
Manual included as Appendix A to this Application.
6.5.2 External Radiation
TLD badges, as supplied by Landauer, lnc., or equivalent, are utilized at BHV-1, BHV-2, BHV-
3, BHV-4, BHV-5 and BHV-6 to determine ambient external gamma exposures. System quality
assurances are determined by placing a duplicate monitor at one site continuously. Exchange ofTLD badges are on a quarterly basis. Badges consist of a minimum of five TLD chips.
Measurements obtained from location BHV-3 have been designated as background due to BHV-
3's remoteness from the Mill site (BHV-3 is located approximately 3.5 miles west of the Mill
site). For further procedure information see Section 4.3 of the Environmental Protection Manual
included as Appendix A to this Application. See Section 3.13.1.7(c) of the accompanying
Environmental Report for a summary of historic monitoring results for external radiation.
6.5.3 Soil and Vegetation
Soil Monitoring
Soil samples from the top one centimeter of surface soils are collected annually at each of BHV-
1, BHV-2, BHV-3, BHV-4 and BHV-5. A minimum of two kilograms of soil is collected per
site and analyzed for U-natural and Ra-226. For further procedure information see Section 4.1 of
the Environmental Protection Manual included as Appendix A to this Application. See Section
3.13.1.7.1of the accompanying Environmental Report for a summary of the historic results for
soil monitoring. The Environmental Report concludes that the results of sampling since the
previous licensure (1997) were low, less than the unrestricted release limits.
ii. Vegetation Monitoring
Forage vegetation samples are collected three times per year from animal grazinglocations to the
northeast (near BHV-I (the meteorological station)), northwest (to the immediate west of the site)
and southwest (by BHV-4) of the Mill site. Samples are obtained during the grazing season, in
58
the late fall, early spring, and in late spring. A minimum of three kilograms of vegetation are
submitted from each site for analysis of Ra-226 and Pb-210. For further procedure information
see Section 4.2 of the Environmental Protection Manual included as Appendix A to this
Application. See Section 3.13.7(d) of the accompanying Environmental Report for a summary
of the historic results for vegetation monitoring. The Environmental Report concludes that the
most recent (2006) results indicate no increase in uptake of Ra-226 and Pb-210 in vegetation.
6.5.3 Meteorological
Meteorological monitoring is done at a site near BHV-I. The sensor and recording equipment
are capable of monitoring wind velocity and direction from which the stability classification is
calculated. Data integration duration is one-hour with hourly recording of mean speed, mean
wind direction, and mean wind stability (as degrees sigma theta).
The data from the meteorological station is retrieved monthly by down loading onto a Campbell
Scientific data module, or the equivalent. The data module is sent to an independent
meteorological contractor where the module is downloaded to a computer record, and the data is
correlated and presented in a Semi-Annual Meteorological Report.
Monitoring for precipitation consists of a daily log of precipitation using a standard NOAA rain
gauge, or the equivalent, installed near the administrative office, consistent with NOAA
specifications.
Windrose data is summarized in a format compatible with MILDOS and UDAD specifications
for 40 CFR 190 compliance. For further procedure information see Section 1.3 of the
Environmental Protection Manual included as Appendix A to this Application. A windrose for
the site is set out in Section 3.3.1.2 of the accompanying Environmental Report. Meteorological
Reports for2004,2005 and 2006 also accompany this Application.
6.5.4 PointEmission
Stack emission monitoring from yellowcake facilities follows EPA Method 5 procedures and
occurs on a quarterly basis, during operation of the facility. Particulate sampling is analyzed for
Unat on a quarterly basis and for Th-230, Ra-226, and Pb-210 on a semi-annual basis. Demister
and ore stack emission monitoring follows EPA Method 5 procedure on a semi-annual basis,
during operation of the facility. Particulate samples are analyzed for Unat, Th-230,Ra-226, and
Pb-210. Monitored data includes scrubber system operation levels, process feed levels,
particulate emission concentrations, isokinetic conditions, and radionuclide emission
concentrations. For further procedure information see Section 1.4 of the Environmental
Protection Manual included as Appendix A to this Application. Historic stack emission data are
summarized in Section 3.I3.1.7(e) of the accompanying Environmental Report.
59
6.5.5 Water
S urfac e W at er M onitorin g
Surface water monitoring is conducted at two locations adjacent to the Mill facility known as
Westwater Canyon and Cottonwood Creek. Samples are obtained annually from Westwater and
quarterly from Cottonwood using grab sampling. For Westwater Creek, samples will be of
sediments if a water sample is not available. Field monitored parameters and laboratory
monitored parameters are listed in Table 6.5-1. For further procedure information see Section
2.1 of the Environmental Protection Manual included as Appendix A to this Application. See
Section 3.7.4 of the accompanying Environmental Report for a summary of the historic results
for surface water monitoring.
Table 6.5-1
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater Creek and Cottonwood Creek
Field Requirements
temperature C;
Specific Conductivity umhos at25 C;
pHat-25 C;
Sample date;
Sample ID Code;
Vendor Laboratory Requirements
*Semiannual sample must be taken a minimum of four months apart.xxAnnual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuclides and LLDs reported in pCilml
Semiannualx Ouarterlv
One gallon Unfiltered and Raw One gallon Unfiltered and Raw
One gallon Unfiltered, Raw and preserved to
pH<2 with HNOr
One gallon Unfiltered, Raw and Preserved to
pH<2 with HNOr
Total Dissolved Solids Total Dissolved Solids
Total Suspended Solids Total Suspended Solids
Gross Alpha
Suspended Unat
Dissolved Unat
Suspended Ra-226
Dissolved Ra-226
Suspended Th-230
Dissolved Th-230
60
ii. Groundwater Monitoring
At the time of renewal of the Mill license by the NRC in March 1997, and up until issuance of
the Mill's GWDP in March 2005, the Mill implemented a groundwater detection monitoring
program to ensure compliance with 10 CFR Part 40, Appendix A, in accordance with the
provisions of Mill License condition 11.34. The detection monitoring program was in
accordance with the report entitled, "Points of Compliance, White Mesa Uranium Mill,"
submitted by letter to the NRC dated October 5, 1994. Under that program, the Mill sampled
monitoring wells MW-5, MW-11, MW-12, MW-14, MW-15 and MW-17 on a quarterly basis.
Samples were analyzed for chloride, potassium, nickel and uranium, and the results of such
sampling were included in the Mill's Semi-Annual Effluent Monitoring Reports that were filed
with the NRC up until August2004 and with the DRC subsequent thereto.
On March 8, 2005, the Co-Executive Secretary of the Utah Water Quality Board issued the
Mill's GWDP, which includes a groundwater monitoring program that supersedes and replaces
the groundwater monitoring requirements set out in Mill License Condition 11.3A. Under the
GWDP, 21 monitoring wells are monitored for 47 constituents. Sampling is performed under a
Groundwater Monitoring Quality Assurance Plan, prepared under Part I.H.6 of the GWDP, a
copy of which is included as Appendix M to this Application.
Groundwater monitoring under the Mill's GWDP commenced in March 2005, the results of
which are included in the Mill's quarterly Groundwater and DMT Perfornance Standard
Monitoring Reports that are filed with the Co-Executive Secretary of the Utah Water QualityBoard. A copy of each such Report since March 2005 is included with this Application.
On August 28, 2006, Denison received a Notice of Violation ("NOV") from the Co-Executive
Secretary of the Utah Water Quality Board which lists three violations of the Mill's GWDP.
Specifically, the NOV cited a number of constituents that had been detected in groundwater
monitoring wells in excess of the compliance limits set out in the GWDP. This NOV was not
unexpected, because the interim groundwater protection limits set out in the GWDP were set
prior to the establishment by the Co-Executive Secretary of background groundwater quality at
the site. Both Denison and the Co-Executive Secretary recognized at the time of issuance of the
GWDP that because background groundwater quality at the Mill had not yet been approved at
that time, the Co-Executive Secretary could not determine if any constituent in groundwater is
naturally occurring and therefore detectable or undetectable for purposes of selecting
groundwater protection limits in each monitoring well at the site. Consequently, the Co-
Executive Secretary initially assigned the groundwater protection limits as if all constituents
were "undetectable". However, in the Statement of Basis for the GWDP, the Co-Executive
Secretary acknowledged that after submittal and Co-Executive Secretary approval of the existing
well Background Groundwater Quality Report, pursuant to Part I.H.3 of the GWDP, the GWDP
can be reopened and the groundwater protection limits in the permit modified to reflect natural
background. The Co-Executive Secretary also acknowledged in the Statement of Basis that this
approach to set the initial limits in the GWDP, does not account for natural variations in
groundwater quality and that false positives in the groundwater monitoring data may occur until
the Background Groundwater Quality Report is submitted, approved by the Co-Executive
6t
Secretary, and the permit limits re-established in the GWDP. Recognizing that it is not possible
to determine whether or not an exceedance of any of the current GWDP limits is due to natural
causes prior to review and acceptance by the Co-Executive Secretary of the Background
Groundwater Quality Report, the Co-Executive Secretary and Denison agreed, in response to the
NOV, on a revised date of January 2,2007 to complete and submit the Background Groundwater
Quality Report.
The Background Groundwater Quality Report was prepared for Denison by Intera, Inc., an
engineering firm, and submitted to the Co-Executive Secretary on January 2, 2007. Intera
concluded in the Report that "[a]fter extensive analysis of the data, we have concluded that there
have been no impacts to groundwater from Mill activities." lntera based this conclusion on a
number of factors, including the following:
. There are a number of exceedances of permit limits in upgradient and far downgradient
wells at the site, which cannot be considered to have been impacted by Mill operations to
date. Exceedances of permit limits in monitoring wells nearer to the site itself are
therefore consistent with natural background in the area. In situations where the
constituent that exceeds the permit limit is not trending upward, the proper conclusion is
that it is representative of natural background.
. There are numerous cases of both increasing and decreasing trends in constituents in
upgradient, far downgradient, and Mill site wells, which provide evidence that there are
natural forces at work that are impacting groundwater quality across the entire site.
o In almost all cases where there are increasing trends in constituents in wells at the site,
there are more pronounced increasing trends in those constituents in upgadient wells.
Furthermore, and more importantly, in no case is there any evidence in the wells in
question of increasing trends in indicator parameters, such as chloride or fluoride, which
are considered the most mobile and best indicators of potential tailings cell leakage at the
site. Intera considered the combination of these factors to be conclusive evidence that all
increasing trends at the site are caused by natural forces and not by Mill activities.
The Background Groundwater Quality Report supports Denison's position that the exceedances
of GWDP limits referred to in the NOV are due to natural background forces and that the permit
limits must be adjusted accordingly, as contemplated by the GWDP.
6.5.6 Seeps and Springs Monitoring
As required by Part LH.9 of the GWDP, the Mill submitted to the Co-Executive Secretary of the
Utah Water Quality Board for approval of a plan for groundwater sampling and analysis of all
seeps and springs found downgradient or lateral gradient from the tailings cells at the Mill. This
Plan is currently under review by the Co-Executive Secretary. Part I.F.6 of the GWDP provides
that after approval of the work plan and report required by Part I.H.9, the GWDP may be
modified to require annual monitoring and reporting of selected seeps or springs in the vicinity
of the Mill. At the time of this Application, the GWDP had not been modified to require any
such monitoring or reporting. Some seeps and springs sampling data was gathered in 1977 , pior
62
to Mill construction, and in 2003-2004 by the Mill. These results are discussed in Section 3.7.4
of the accompanying Environmental Report.
6.5.7 Solid Waste
Section 3.1 of the Environmental Protection Manual included as Appendix A to this Application
sets out the monitoring procedures for the Mills tailings cells. Section 3.1 of the Environmental
Protection Manual also incorporates the Discharge Minimization Technology ("DMT")
Monitoring Plan requirements under Part I.H.13 of the GWDP. These procedures are designed
as a systematic program for constant surveillance and documentation of the integrity of the
tailings impoundment system including dike stability, liner integrity, and transport systems. The
scope of the surveillance program includes geotechnical, structural, hydraulic and
electricaVmechanical evaluations of the operations. The program also includes comprehensive
usage of procedures, documentation, management and engineering reviews of the surveillance
program and impoundment system' s performance.
The procedures detail training programs for surveillance personnel, inspection requirements and
frequencies, performance evaluation requirements and technical evaluation report format and
content.
The surveillance program includes daily, weekly, monthly, quarterly and annual documented
inspections and monitoring of the tailings impoundments and ancillary structures, such as
diversion structures and transport pipeline integrity. Annual technical stability and integrity
evaluations are performed by qualified professional engineers to ensure continued performanceof the system. These evaluations are submitted to and reviewed by both the Division of
Radiation Control and the State of Utah Dam Safety Engineer.
In addition, the management program monitors and evaluates the performance of liquid
evaporation systems, fugitive dust control generation, and waterfowl and burrowing animal
habituation.
Part I.D.3 of the GWDP sets out the DMT performance standards under the GWDP. These
requirements are required to be contained in a DMT Monitoring Plan, which has been
incorporated into Section 3.1 of the Environmental Protection Manual, included as Appendix A
to this Application. The DMT perfonnance standards relating to the Mill's tailings cells, Roberts
Pond, and the Mill's feedstock storage area are the following:
. The Mill shall at all times maintain the average wastewater head in the slimes drain
access pipe to be as low as reasonably achievable in each tailings disposal cell; for Cell 3,
this requirement shall apply after initiation of de-watering activities in that cell;
. Upon closure of any tailings cell, the Mill shall ensure that the maximum elevation of the
tailings waste solids does not exceed the top of the flexible membrane liner ("FML") for
the cell;
. The Mill shall operate Roberts Pond so as to provide a minimum 2-foot freeboard at all
63
times. Under no circumstances shall the water level in Roberts Pond exceed an elevation
of 5,624 feet above mean sea level. In the event that the wastewater elevation exceeds
this maximum level, the Mill shall remove the excess wastewater and place it in tailings
cell I within 72 hours of discovery. At the time of Mill site closure, Denison shall
reclaim and decommission Roberts Pond in compliance with the final Reclamation Plan
for the site; and
. Open-air or bulk storage of all feedstock materials at the Mill awaiting Mill processing
shall be limited to the eastern portion of the Mill site area, as delineated in Part I.D.3.d of
the GWDP and Section 3.1 of the Environmental Protection Manual. Storage of
feedstock materials at the Mill outside this area shall be performed and maintained only
in closed, water-tight containers. At the time of Mill site closure, Denison shall reclaim
and decornmission the feedstock storage area in compliance with the Reclamation Plan
for the Mill.
As required by Part I.E.6 of the GWDP, under the DMT Monitoring Plan, included in Section
3.1 of the Environmental Protection Manual, the Mill performs the following additional
performance monitoring:
The Mill monitors and records weekly the elevation of wastewater in tailings cells I and
3 to ensure compliance with the maximum wastewater elevation criteria mandated by
condition 10.3 of the License;
The Mill monitors and records weekly the depth to wastewater in the slimes drain access
pipes at tailings cells 2 and 3 to determine maximum and minimum fluid head before and
after a pumping cycle, respectively; for cell 3, this requirement shall apply upon
initiation of tailings de-watering operations in that cell;
The Mill monitors and records weekly wastewater levels at Roberts Pond to determine
compliance with the DMT operations standards in Part I.D.3; and
. The Mill performs a weekly inspection of the feedstock storage area to:- Confirm the bulk feedstock materials are maintained within the delineated feedstock
storage area; and- Verify that all feedstock materials located outside the delineated feedstock storage
area are maintained in water-tight containers.
These DMT performance standard monitoring results are reported in the Mill's quarterly
Groundwater and DMT Performance Standard Monitoring Reports, copies of which are includedwith this Application. Since, the DMT Monitoring Plan provisions of the Environmental
Protection Manual are just in the process of being approved at the date of this application,
weekly depth to wastewater in the slimes drains monitoring results are not included in those
reports.
64
6.5.8 MILDOS AREA Modeling
For purposes of this Application, the MILDOS AREA modeling for the Mill was updated,
assuming the Mill was processing high grade Arizona Strip ores at full capacity. Section
3.13.2.6 of the Environmental Report discusses this modeling in detail and conciudes that, based
on modeling predictions, even running at full capacity in high-grade Arizona Strip ores themaximum potential doses to the public are well within applicable regulatory standards andALARA goals.
6.5.9
As is evident from the various historic environmental monitoring results discussed in this
Section, the Mill has operated in compliance with all applicable regulatory standards and
ALARA goals and in a manner that has not resulted in any significant impacts to public health,
safety or the environment. The MILDOS AREA modeling confirms that, based-on modeling
predictions, the current design and operation controls at the Mill are sufficient to result in
operations at full capacity processing high-grade ores that are within the regulatory standards and
applicable ALARA goals.
As a result of these historic monitoring results and updated modeling, it is evident that the Mill's
equipment, facilities and procedures are adequate to minimize danger to public health or the
environment and that renewal of the Mill's License will not be inimical io the health and safety
of the public.
This page was revised on August 14,ZOO1,
65
7. MILL ACCIDENTS
A spectrum of potential Mill accidents ranging from insignificant to serious has been established
by probabilities of occurrence. These accidents were evaluated during each cycle of license
application and renewal. In addition, Denison received process risks February,2007. Table 7.0-
1 shows the results of all analyses for each type of accident with severity and probability ratings
as specified below. Emergency plans and countermeasures for coping with the accidents are also
described.
The severity classification of an accident is based on its potential impact on health, safety, and
the environment and is not a strict measure of dollar loss. The "severity" categories are as
follows:
2 Significant - Slight impact. Corrective actions would include steps to
address potential system deficiencies.
3 Serious - Corrective action necessary. Minor local and/or regional
impact, such as closing State Highway l9l for one to two hours.
4 Yery Serious - Corrective action necessary. Major local and/or regional
impact. An example would be the evacuation of any area resident.
The probability categories are defined as follows:
Severitv
1
Probability
I
2
3
4
Description
lnsignificant - No impact. Corrective actions would include steps to
correct symptoms.
Description
Highly Improbable - Frequency of occurrence is expected to be
over one hundred years.
Improbable - Frequency of occurrence is expected to be within ten
to one hundred years.
Possible - Frequency of occurrence is expected to be within one to
ten years.
Probable - Frequency of occurrence is expected to be within one
year.
66
of Accident
Table 7.0-1
Spectrum of Potential Mill Accidents
Unloading/storage of Ammonia
Unloading/storage of Propane
Leach Tank Failure
Ammonia Explosion
SX Fire
Yellowcake Dryer Fire / Explosion
Vanadium Roaster Fire Explosion
Acts of God
Tornado
Flood Water Breach
Seismic Damage
Tailings Accidents
Structural Failure
Transportation Accidents
Concentrate Shipments
Ore Shipments
3
3
2
3
3
3
3
2
2
)
2
2
2
2
6
6
4
6
6
6
6
4
3
3
9
6
9
1
1
I
I
3
J
3
4
3
3
J
2
J
*(Severity) x (Probability) = (Risk Category)
67
The product of the severity classification times the probability category, termed the riskcategory, can be used to determine what type of safeguards should be in piaci and functional. Arisk category of 8 or less can be handled by the normal training, audiiing, implementation ofprocedures, and administration functions set forth in this application. A potentiaiaccident with arisk category between 8 and 12 may have resources allocated to lower the risk. These resources
are properly defined and allocated during a normal budget cycle. A potential accident with a riskcategory of greater than 12 has greater impact and is reviewed and further evaluated within ashorter time frame-
7.1 Process Accidents
The following process accidents have been deemed to be credible and potentially capable ofsevere consequences.
7.1.1
A release of ammonia or propane could occur through tank failure, overfilling, and failures ofpiping, loading hoses, hose couplings, and emergency relief valves. These risks are mitigated byregular inspection and maintenance of the equipment and proper training of personnel.
No radiological impacts are foreseen from a release of ammonia or propane.
7.1.2 Leach Tank Failure
The rubber lined leach tanks contain the ore/sulfuric acid slurry. Tank failure due to corrosionand break-out is a possibility. Procedures and practices are in piace and functioning to minimizethis possibility. Failure due to loss of structural integrity ls also possible. ihe tanks areevaluated during each relining cycle to determine structural stability and the potential need forreplacement.
Radiological impacts are minimal from an
would be contained in the leach area or
designed.
occurrence of this type. Any release of material
would flow to Roberts Pond for containment, as
7.1.3 Ammonia Explosion in a Building
An ammonia-air explosive mixture could be formed inside the Mill and Solvent Extractionbuildings if a line ruptured. Existing controls include emergency powered vent fans, operatorpresence at all times for surveillance, one-half inch piping that minimizes potential ieleaseamounts, and emergency procedures.
Radiological impacts from the explosion would be minimal and most likely contained within therestricted area. Any contamination would be recycled or disposed of, as appropriate.
68
7.1.4 SX Fire
The possibility of a major fire in the solvent extraction building is remote, as very strict safety
precautions are adhered to. This part of the process is kept isolated and in separate buildings due
to the large quantities of kerosene present. These facilities are equipped with an independent fire
detection and protection system.
In spite of the safety precautions, if a major fire were to occur, the radiological environmental
effects would be confined within a few hundred feet of the buildings. Recovery of uranium that
would be scattered by the burning solvent would be accomplished and a survey of the site would
be required. Uranium-contaminated soil would be processed in the Mill circuit or disposed of in
tailings, as appropriate.
In the 1980s, two solvent extraction fires occurred at other uranium Mills in the U.S. Neither fire
resulted in appreciable release of uranium to the unrestricted environment, and essentially
complete recovery of the uranium was obtained. Consequently, the impact from such an event at
the Mill would be limited to (1) cleanup of contaminated material, (2) replacement of destroyedMill components, and (3) a short duration release of non-radioactive combustion products to the
atmosphere. In the event of a fire in the solvent extraction building, the fire suppression system
delivers foam to the affected area. The foam is designed to spray for 25 minutes, followed by
water at 100 psig and up to 2,000 gpm. See the Emergency Response Plan included as Appendix
D to this Application.
7.1.5 Uranium or Vanadium Dryer/Roaster Fire/Explosion
The possibility of a fire or explosion in the uranium dryer or vanadium roaster is remote due to
lndustrial Safety Codes, regular maintenance and operations inspection of the dryer and ancillary
equipment, instrumentation and control and fire system monitoring of the area. In the event afire were to break out, both the uranium dryer and vanadium dryers are within separate
enclosures in the Mill building, which will help to contain the fire. In the event of an expiosionof the uranium dryer there is the potential for a release; however, the dispersion of the
radioactive material will be very likely within the Mill property boundaries. In the event that the
contamination did go beyond the Mill boundaries, it is likely that the contamination would not
result in a significant increase over background levels in the area due to the limited amount of
material and dispersion.
Acts of God
7.2.1 Tornado
The environmental impacts from a tomado would be transport of tailings solids and liquids or
product from the Mill area into the environment. This dispersed material would contain some
uranium, radium, and thorium. An increase in background radiation could result, and, if
sufficient quantities are detected and isolated, they would be cleaned up.
7.2
69
7.2.2 Flood Water Breachins of Retention Sl/stem
In general, flood water breaching of tailings embankments presents one of the greatest dangersfor the sudden release of tailings solids and impounded water. Within tle tailing cellsthemselves, sufficient volume is available to store any flood which would occur, including theprobable maximum flood (PMF). Availability of freeboard volume is addressed in Section 3.1 ofthe Environmental Protection Manual included as Appendix A to this Application. If a storm
event greater than the PMF breached the dikes, there is the strong possibiiiiy that no increase inbackground levels would be observed due to the catastrophically large volumes of water whichwould be flowing in the area.
The possibility of floods in Westwater Creek, Corral Creek, or Cottonwood Wash causingdamage to the tailings retention facility is extremely remote. This is due to rhe approximablt200 foot elevation difference between the streambeds of the creeks and the toe oi-the tailingsdikes.
7.2.3 Seismic Damage
The seismic rupture of the tailings retention slurry pipeline would result in a minor impact on theenvironment. The tailings retention system pipe is in the same drainage basin as the retentionsystem. Any tailings slurry released by a pipe rupture, no matter what the cause, would flowdownhill where it would be impounded inside a tailings cell.
7.3 Tailings Accidents
7.3.t Structural Failure of Tailings Dikes
All tailings dikes have been designed with an ample margin of safety as per NRC staff guidance.This has included design calculations showing dike stability even when the dike is saturated withmoisture during a seismic event, the most severe failure mode. In addition, the tailings dischargesystem is checked at least once per shift during operation, or once per day during MiU rt*OU-y,
as outlined in Section 3.1 of the Environmental Protection Manuai included as Lppendix A iothis Application.
Although the discharge from a dike failure would soon cross the restricted area boundary, theflow path is over three miles in length before leaving the Mill property. Ample opportunitywould exist for construction of temporary dikes and berms to minimize off-site^contamination.The contamination from such an event would be cleaned up and returned to the tailings area.
7.4 TransportationAccidents
7.4.1 Concentrate Shipments
Concentrates will be shipped in sealed 55-gallon drums built to withstand normal handling andminor accidents- Each drum will contain approximately 900 pounds of yellowcake. Amaximum of 45 drums will be shipped in each closed van. The drums will be r"ul"d and marked
70
"Radioactive LSA" (low specific activity), and the trucks will be properly marked. Because
most of the radioactive daughter products of uranium are removed in the extraction process and
radioactive buildup of daughter products is slow, yellowcake has a very low level of
radioactivity and is therefore classified by the Department of Transportation as a low specific
activity material.
The environmental impact of a transportation accident involving release of the product would be
minimal. Yellowcake, having a high density, even in a severe accident in which multiple drums
are breached, would not easily disperse. More than likely, the drums and any released material
would remain within the damaged vehicle or in an area of close proximity of the accident site.
Driver or carrier instructions are given to each driver of each transport leaving the plant site witha load of yellowcake. These instructions will consist of an explanation of the product,
preliminary precautions at the accident site, whom to notify and what to do in case of fire. A
copy of these instructions is included in the Transportation Accidents Plan included as Appendix
N to this Application.
Mill persorurel would respond if requested for the initial spill response to handle any yellowcake
transport accident. A procedure for this likelihood is included in the Transportation Accidents
Plan included as Appendix N to this Application. Denison reserves the right to contract with a
carrier or firm properly trained to handle any yellowcake transport accident.
7.4.2 Ore Shipments
Ore is shipped in 20 to 25 ton shipments in highway trailers that are covered by tarpaulins. The
truck trailers are labeled "Radioactive LSA". Because the ore is large particles and is typically
wet (2 to 57o moisture), the potential for a release from an accident involving an ore shipment
truck is quite small. In the event of an accident, the ore transportation company will respond to
clean up any spilled material and ensure that the area is clean. Mill personnel will support the
transportation contractor in cleaning up the affected area and radiological scanning of the
impacted area.
7.4.3 Reaeent Shipments
Reagents are shipped in properly marked trailers and the drivers are trained in hazardous
materials transportation and accident procedures. In the event of an accident, all of the reagent
suppliers' transportation contractors are required to have emergency response contractors to
respond to an accident and a potential spill. Many of the reagents that are used at the Mill are
shipped on a daily basis to other industrial facilities throughout the U.S. The potential for an
accident is minimized due to quick response of the transportation contractor's emergency
response team and the training of many of the country's emergency response services.
7.5 On Site Spill Countermeasures
In the event of a transportation-related accident on the Mill property, immediate containment of
the product will be achieved by covering the spill area with a plastic sheeting or equivalent
7l
material to prevent wind and water erosion. If sheeting is not available and depending on where
the spill occurs, soil from the surrounding area may be used. Perimeter ditching will be used to
contain the spill if it should occur in an area where runoff could result from precipitation.
All human and vehicular traffic through the spill area will be restricted. The area would be
cordoned off if possible. All persons not participating in the accident response will be restricted
to 50 feet from the accident site. Local law enforcement officers will be notified and may be
asked to assist in controlling traffic and keeping unauthorized persons out of the spill area.
Covered containers and removal equipment, i.e., large plastic sheeting, radioactive signs, ropes,
hoses, shovels, vacuums, axes, stakes, heavy equipment (front-end loaders, graders, etc.), will be
available to clean up the yellowcake. A Radioactive Material Spill Kit is available and under the
control of the Radiation Department. If conditions warrant, water will be applied to the spilled
yellowcake in a fine spray to assist in dust abatement.
Gloves, protective clothing and any personal clothing contaminated during cleanup operations
will be encased in plastic bags and kept in the plant area for decontamination or disposal.
Any fire at the site will be controlled by local experienced fire fighting personnel wearing
appropriate respiratory protective equipment.
Response team members will have a thorough knowledge in basic first aid and of the physical
hazards in inhalation, ingestion, or absorption of radionuclides. Team members will adiquately
protect themselves.
As per R3l3-15 requirements, the DRC will be notified promptly of any accident of this type. A
copy of the Mill's Spill Response Plan what is attached as Appendix I to the Mill's Srormwater
Best Management Practices Plan included as Appendix c to this Application.
7.6 EmergencyProcedures
Emergency procedures are established by the Radiation Safety Officer for accidents that couldoccur. Personnel safety, environmental conditions and prompt corrective actions are taken as
well as notification of regulatory officials. Employees are indoctrinated as to emergency and
remedial measures in the event of an accident which poses a health and safety hazard. These
include evacuation procedures, clean-up measures, and follow-up medical examinations if
warranted.
Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow. Dikes and/or curbs are constructed around process and storagl
tanks (excluding the water tank) to confine the material in the event of a tank spill. In the event
of an ammonia tank spill, the material would be expected to evaporate quickly. A sulfuric acid
tank spill would flow via a specially excavated channel to the catchment basin where it would befully contained and subsequently cleaned up. Tank safety and containment is discussed in detail
in Section 4.1.12.
72
Due to the design of the tailings disposal system, a break or breach in the containment area is notlikely. In this event, however, any released material will be contained by the downstream
catchment dike. If a break occulrs, the pumping system would be shut off, personnel removed
from the immediate area, and the Executive Secretary notified. The break would be repaired and
the affected area cleaned up in the safest and most expeditious manner. The advice and direction
of the Executive Secretary would be sought and heeded throughout the episode.
Procedures for responding to other types of emergencies requiring removal or isolation of
personnel (e.g., evacuation in case of fire, protection of employees from various spills and pipe
breaks, and general first aid) are set out in the Mill's Emergency Response Plan attached as
Appendix D to this Application.
7.6.1 GWDP Contineency Plan
In addition to the foregoing procedures, Part I.H.16 of the GWDP requires that Denison submit a
Contingency Plan for Executive Secretary approval that provides a detailed list of actions theMill will take to regain compliance with GWDP limits and DMT requirements defined in parts
I.C and I.D of the GWDP. The Contingency Plan submitted by Denison is currently under
review by the Executive Secretary.
73
RECLAMATION PLAN
The Reclamation Plan, Revision 4.0, was transmitted to the Executive Secretary by letter dated
November 24,2009, and is hereby incorporated by reference as Appendix P to this Application.
The financial surety, including the amount for the long term care fund, currently required under
Mill License condition 9.5 is $15,807,429. This amount is reviewed annually by Denison and
the Executive Secretary, as required by Mill License condition 9.5.
Part LD.9 of the GWDP provides that, upon commencement of decommissioning, Denison shall
reclaim the Mill site and all related facilities, stabilize the tailings cells, and construct a cover
system over the tailings cells in compliance with all engineering design and specifications in the
Mill's Reclamation Plan.
ln that respect, Part I.D.S of the GWDP provides that before reclamation and closure of any
tailings disposal cell, the Mill shall ensure that the final design, construction, and operation of the
cover system at each tailings cell will comply with all requirements of the approved Reclamation
Plan, and will for a period of not less than 200 years meet the following minimum performance
requirements:
o Minimize infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barrier;
o Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML liner elevation internal to any disposal cell, i.e.,
create a "bathtub" effect; and
o Ensure that groundwater quality at the compliance monitoring wells does not exceed the
Groundwater Quality Standards or Groundwater Compliance Limits specified in the
GWDP.
Part LD.9 also provides that the Co-Executive Secretary reserves the right to require
modifications to the Reclamation Plan for purposes of compliance with the Utah Groundwater
Quality Protection Regulations, including but not limited to containment and control of
contaminants, or discharges, or potential discharges to Waters of the State.
In order to ensure that the Reclamation Plan meets the requirements of the Utah Groundwater
Quality Protection Regulations, Part I.H.10 of the GWEP requires that Denison submit for Co-
Executive Secretary approval an infiltration and contaminant transport modeling report that
demonstrates the long-term ability of the tailings cells cover system to adequately contain and
control tailings contaminants and protect nearby groundwater quality of the uppermost aquifer.
Such Report shall demonstrate how the tailings cell engineering design and specifications will
comply with the minimum performance requirements of Part I.D.S of the GWDP. Denison
submitted a work plan for such modeling report for Co-Executive Secretary approval on
September 9,2005, as required, and has submitted preliminary modeling results and calculations
for review by the Co-Executive Secretary. Additional testing and modeling is currently being
completed in response to comments and suggestions from DRC staff. Results of the additional
This Part 8 was amended and resubmitted to the Executive Secretary on November 24, 2009.
I
modeling will be submitted to the Co-Executive Secretary by March 31, 2010.
This Part 8 was amended and resubmitted to the Executive Secretary on November 24,2009.
9. LISTING AND DESCRIPTION OF YIOLATIONS,INCIDENT INYESTIGATIONS,
EXCURSIONS AND REGULATORY EXCEEDANCES AND LICENSE
AMENDMENTS
9.1 Regulatory Authorities
Denison is proud of its regulatory compliance record with regard to environmental, health and
safety performance. Operations at the Mill are regulated as follows:
Environmental Control and DRC
Radiation Safety
(August 2OO4 to present)
Environmental Control and NRC
Radiation Safety
(1980 through August 2004)
Occupational Safety and Health MSHA
Air Quality Utah Department of Environmental
Quality, Division of Air Qualiry
(DAQ)
Water Quality Utah Department of Environmental
Quality, Division of Water Quality(DWQ)
9.2 License Violations Identified During NRC or State of Utah Site Inspections Since
March 31,1997.
9.2.1 Environmental control and Radiation safety Notices of violation
The Mill operated under NRC Source Material License number SUA-1358 from its initial startup
through August 2004. At that time, Utah became an NRC agreement state and responsibility for
regulating licensed activities transferred from NRC to the state of Utah.
As a condition of the NRC Mill License, the Mill was subject to scheduled annual or semi-
annual compliance inspections by NRC, as well as periodic unannounced NRC inspections.
NRC assessed one of four levels of severity for each violation resulting from an inspection.
Level I violations are the highest level of severity; Level IV violations are the least severe and
are issued for administrative violations having virtually no environmental or health and safety
implications.
During the period from March 31, 1997 to August 2004, the Mill received only 7 Notices of
Violation (NOVs) from NRC, six administrative NOVs from inspections, and one administrative
NOV issued by the NRC Uranium Recovery Branch. A summary of NOVs is provided in Table
75
9.2-1. As indicated in Table 9.2-1, Denison did not receive an NOV with a severity higher than
level IV. All corrective actions have been completed, and all NOVs closed. The Mill has no
pending NOVs. Copies of the inspection reports and NOVs received since the last license
renewal in March 1997 are provided in Appendix O.
No violations under the License have been cited by DRC since August 2004.
Table 9.2-1
NRC and TIDEQ Inspections at White Mesa Mill
since March 31,1997
Inspection Date Agency NOVS Status
luly 15-17, 1997
January 13-15,1998
June 9-ll, 1998
August 18, 1998
March 25,1999
Ju,ly 29,1999
November 18, 1999
Iuly 25,200o
July 27,2000
April4, 2001
September 19,2001
July 23,2002
August 22,2N2
February 19,2004
I Violation May 8, 1997,
not as a result ofan inspection
3 Violations - All Severity Level [V
No Violations
No Apparent Violations
Dam Safety Audit
No Violations
I Violation - Severity Level IV
No Violations
No Violations
Dam Safety Audit
No Violations
2 Violations - Severity I-evel [V
No Violations
No Violations
Dam Safety Audit
No Violations
No Violations
No Violations
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
NRC
Closed
Closed
Closed
Closed
76
Inspection Date Agency NOVS Status
March 22,2005
September 20,2N5
DWQ
DWQ
DRC
DRC
DWQ
August 23,1999 Notice of Violation and
Groundwater Correction Order addressing
chloroform
Resulting from Split Sampling Event
October 25,2004 Review of Monitoring
Report
No Violations
Dam Safety Audit
No Violations
Dam Safety Audit
No Violations
8 Violations of GWDP July 17,2006,
not as a result of an inspection
3 Violations of GWDP August 24,2006,
not as a result of an inspection
Corrective Action
Plan in progress
3 withdrawn by
DWQ
5 Closed
Resulted in
Consent
Agreement of
October 23,2006
DWQ
December 13,2006 DRC No Violations
9.2.2 Air Ouality Notices of Violation
As described in Section I of this Application, the Mill holds Air Approval Order No. DAQE-
AN12005-06 issued by DAQ. Records which must be maintained as part of the compliance with
the Air Approval Order include fuel consumption, production rate, equipment maintenance
records, emission inventory, upset and breakdown episodes, and fugitive emission controls.
Stack testing to show compliance with emission limitations stated in the Air Approval Order,
which is observed by DAQ, is required to be conducted within 180 days of startup. To date, this
testing has indicated no exceedances of the permissible limits. Emission inventories submitted
annually to DAQ document that the facility has consistently operated within the emission limits.All of the records required to demonstrate compliance with the remaining Air Approval Order
conditions are maintained at the Mill and are available for review by DAQ. The Mill has never
received a citation or Notice of Violation under this permit.
9.2.3 Water Ouality Notices of Violation
In May 1999, DWQ participated in a groundwater split sampling event at the White Mesa Mill.
After reviewing results from the sampling event, DWQ issued a Notice of Violation and
Groundwater Corrective Action Order on August 23, 1999 requiring Denison to address elevated
chloroform levels identified in one monitoring well, MW-4. Denison is currently preparing a
77
colrective action plan to address this NOV, and the NOV remains open pending DWQ's
acceptance of the plan and subsequent corrective action.
As described in Section 1 of this Application, the Mill operates under GWDP No. UGW37OOO4
issued by the DWQ. Since August2004, the Mill has received two letters from the Co-Executive
Secretary of the Utah Water Quality Board under the GWDP which identify 1l violations. None
of these NOVs resulted from inspections; all resulted from the Co-Executive Secretary's reviewof groundwater monitoring report data. Eight of the violations, addressing groundwater
monitoring data reporting, were identified in the Co-Executive Secretary letter of July 17,2006.
Three of these were subsequently withdrawn by the Co-Executive Secretary and 5 were closed.
Three violations, addressing groundwater quality standards, were identified in the Co-Executive
Secretary's letter of August 24,2006. These violations resulted in development of a Consent
Agreement between Denison and DWQ which stipulated a revised date for submittal of the
Background Ground Water Quality Report for Existing Wells. This report was submitted in
January 2007 and is currently under review by the Co-Executive Secretary. These WDP NOVs
are also summarized in Table 9.2-1.
9.3 Occupational Safety and Health Citations
The Mine Safety and Health Administration (MSHA) oversees compliance with both the
occupational safety and health requirements of the Occupational Safety and Health
Administration (OSHA) applicable to above-ground operations such as milling, as well as
additional requirements applicable to below-ground hazards specific to mining operations.
The Mill has no predetermined schedule of MSHA audits, but is subject to unannounced MSHA
inspections approximately twice per year. In addition, Denison requests that MSHA provide
Courtesy Audit Visits (i.e., voluntary inspections) following installation or startup of major
capital modifications at the Mill.
Since March 1997, the Mill has received a total of 71 citations from MSHA, as outlined in Table
9.3-1. For some of the citations, the corrective actions were addressed on the same day as the
MSHA inspection, and the citations were terminated instantaneously. For other citations, the
corrective actions were implemented after the conclusion of the inspection visit and documented
in corrective action memoranda on file at the Mill. The Mill has one outstanding citation for
which the corrective action is still in progress. The MSHA inspection in February 2007 resulted
in 7 citations, of which 6 were closed within a day of the inspection. One remaining citation
requires the purchase and installation of additional shower equipment, which is currently
underway. The citation and corrective action will be closed when Denison confirms that
equipment installation has been completed.
78
Table 9.3-1
MSHA Citations at the Mill Since March 31,1997
Inspection Date Citations Status
4 Citations
10 Citations
2 Citations
l Citation
No Citations
No Citations
6 Citations
3 Citations
4 Citations
6 Citations
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
6 Closed
1 Open - Corrective
Action in Progress
9.4 Excursions, Incident Investigations or Root Cause Analyses, and Resultant Cleanup
Histories or Status since March3l,1997.
The Mill received one NRC request, on September 13,1999, to conduct an investigation to prove
or disprove four allegations regarding operational practices. Based on an investigation report
filed November 29,1999, all allegations were disproved and closed.
The Mill filed one Spill InvestigationlTransportation Accident Report to DRC on October 13,
1999. The independent transportation subcontractor overturned a truck hauling an intermodal
container ("IMC") from the Ashland I Tonawanda site, resulting in a spill of approximately
seven cubic yards of low specific activity alternate feed material. The material was removed,
transferred to another container, and shipped to the Mill. The area was surveyed for residual
contamination.
No lnspections 1997
January 1998
November 1998
August/September 1999
January 2000
March 2000
August 2000
January 2001
June 2001
July 2002
November 2002
No Inspections 2003
June 2004
December 2004
June 2005
November 15,2005
November 30,2005
April2006
February 2007
l Citation
5 Citations
4 Citations
3 Citations
3 Citations
12 Citations
7 Citations
79
ln October 1999, US Army Corps of Engineers contractor,IT Corporation, notified Denison that
they had mistakenly shipped one IMC of lead-contaminated soil from the Boston Artery Tunnel
Project to the Mill. The material in the mis-shipped IMC had already been received at the Mill
and incorporated in Ore Lot #78 on the Mill ore pad. Denison filed a Segregation Plan for Soil
Lot #78 on May 22,2000, which was approved by the Utah Division of Solid and Hazardous
Waste, and the NRC in June and July, 2000 respectively. The plan was implemented in July
2000.
Mill staff determined on March 27,2001 that the ffiltration rate into the leak detection system
of inactive tailings Cell 4,{ appeared to exceed the 1 gpm level prescribed in the Mill's license
condition 11.3.D. There is a one foot thick clay liner beneath the leak detection system in Cell 4-
A. Cell44 has since been cleaned out and is in the process of being re-lined.
Table 9.4-1 summarizes these exclusions, incident investigations, root cause analyses and
resultant clean-ups.
Table 9.4-1
Incident Investigations Since March 31,1997
DATE AGENCY INVESTIGATION STATUS
September 13,1999 NRC 4 NRC Allegations Investigated in closed
November 1999
O September 3O,I9gg DRC Transportation Accident
october 22,1999 NRC Mis-shipped inter-modal container from Closed
Boston Artery Tunnel project
March 27,2001 NRC Cell 4-A Leak Detection System Closed
9.5 Exeeedances of Regulatory Standards or License Conditions Pertaining to
Radiation Exposure, Contamination, or Release Limits Since March 31,1997.
The Mill has not incurred any exceedences of regulatory standards or license conditions
pertaining to radiation exposure, contamination, or release limits.
9.6 License Amendments Since March 1997
Since the last license renewal in March 1997, the License was amended 25 times by the NRC
and since August 2004, three times by the Executive Secretary. Table 9.6-1 and Table 9.6-2
summarize these amendments.
Closed
80
Table 9.6-1
Summary of NRC Mill License Amendments since March 3l,lgg7
License
Amendment
Number
Date
of
Approval
Subject of Amendment
1
2
3
4
April2,
1997
May 9,1997
June 13,
t997
August 15,
1997
April 17,
1998
June 23,
1998
August 28,
1998
September
25, l9gg
November
2, l99g
February 3,
1999
February
24,1ggg
July 28,
1999
February
10,2000
July 7, 2000
Processing of Cotter Concentrate Source Material
Financial Surety Update
Financial Surety Update
Processing of Source Material from Cabot
Performance Materials
Stack, Surface Water, and Groundwater Effluent
Sampling Requirements
Processing of Source Material from Ashland 2
FUSRAP Site
Annual 8-hour Air Sample Collection
Groundwater Points of Compliance Monitoring
Program; Leak Detection System Monitoring
Requirements
Processing of Source Material from Cameco
Processing of Source Material from Ashland 1 and
Seaway Area D FUSRAP Site
Increase in Volume of Source Material from Ashland
2 FUSRAP Site
Processing of Source Material from the St. Louis
FUSRAP Site
Financial Surety Update; Decommissioning
Radiological Monitoring
Processing of Source Material from the Linde
FUSRAP Site
9
10
ll
t2
t3
t4
81
License DateAmendment OfNumber Approval
Subject of Amendment
15 July 21, Financial Surety Update
2000
16 September Freeboard Limits for Tailings Cells
15,2000
17 December Processing of Source Material from W.R. Grace27,2000 ChattanoogaSite
18 December Processing of Source Material from Heritage29,2000 Minerals [nc.
19 April 6, Financial Surety Update
2001
20 December Processing of Source Material from Molycorp
11, 2001 Mountain Pass Site
21 September Financial Surety Update
5,2002
22 September Processing of Source Material from Maywood23,2002 FUSRAP SitE
23 December Financial Surety Update
31,2003
24 February 2, Financial Surety Update
2004
25 April 5, Financial Surety Update
2004
82
Table9.6-2
Summary of DRC Mill License Amendments since August,2004
License DateAmendment OfNumber Approval subject of Amendment
I August 10, Financial Surety Update
2005
2 August 24, Financial Surery Update for Mill and Tailings System
2006
3 June, 2006 Processing of Source Material From FMRI, Inc., and
ancillary amendments
83
10. CONCLUSIONS
This Application describes the activities undertaken at the Mill, and the facilities, equipment,
processes and procedures utilized to conduct such activities. This Application also describes the
key monitoring and DMT perfornance standard requirements and other protections contained in
the Mill's GWDP. Appended to this Application are the critical procedures and programs used
at the Mill, and also included with this Application are the relevant monitoring reports as well as
inspection reports and a listing and description of any violations, incident investigations,
excursions and regulatory exceedances and ancillary documentation since the last License
renewal in 1997.
Also accompanying this report is a detailed Environmental Report that presents a discussion of
the following:
An assessment of the radiological and non-radiological impacts to public health from the
activities to be conducted pursuant to the License;
An assessment of any impacts on the environment, including any impacts on waterways
and groundwater, resulting from the activities conducted pursuant to the License;
An assessment of any impacts on safety, including the safety of workers at the Mill,
resulting from the activities to be conducted pursuant to the License
Consideration of alternatives, including alternative sites and engineering methods, to the
activities to be conducted pursuant to the License; and
Consideration of the long-term impacts including decommissioning, decontamination,
and reclamation impacts, associated with activities to be conducted pursuant to the
License.
As indicated in the various sections of this Application, the Environmental Report demonstrates
that there will be no significant impacts to public health, safety or the environment from
continued operation of the Mill under the existing terms and conditions of the License andGWDP. Environmental monitoring results for air particulate, direct radiation, radon,
groundwater, surface water, vegetation and soil sampling since the last License renewal in 1997
do not indicate any exceedances of applicable regulatory standards or ALARA goals. This
indicates that the existing facilities, equipment, procedures and training of personnel are
adequate to minimize danger to public health and safety or the environment. Furthermore, these
facilities, equipment, procedures and training are reviewed by Denison on an ongoing basis
under the Mill's ALARA Program to ensure that any impacts to public health, safety or the
environment are maintained as low as reasonably achievable. Furthermore, MILDOS AREA
modeling demonstrates that the facilities, equipment and procedures at the Mill are sufficient to
allow for the Mill to be operated at full capacity on high grade ores in full compliance with
regulatory standards and ALARA goals.
84
Similarly, the Environmental Report demonstrates that occupational exposures to radiation have
been maintained below regulatory standards and, with very few exceptions, below the ALARA
goals for exposures to workers. Again, this demonstrates that the existing facilities, equipment,
procedures and training of personnel are adequate to minimize exposures to workers and to
maintain such exposures as low as is reasonably achievable.
As a result, Denison believes that with this Application, the accompanying Environmental
Report and accompanying documentation, the Executive Secretary has been provided sufficient
information to determine that:
a) Denison and all personnel at the Mill are qualified by reason of training or
experience to perform their functions in a manner as to minimize danger to public
health and safety or the environment;
b) the existing equipment, facilities, and procedures at the Mill are adequate to
minimize danger to public health and safety or the environment;
the renewal of the Mill's license will not be inimical to the health and safety of
the public;
the applicable requirements of R3l3-24 and all other applicable regulations have
been satisfied;
renewal of the License will not significantly affect the quality of the environment;
and
to the extent that that original siting of the Mill has resulted in any environmental
costs, after weighing the environmental, economic, technical and other benefits
against such environmental costs and considering available alternatives, the action
called for is the issuance of the proposed license renewal.
c)
d)
e)
85
DENISOJ)//
frTINES
June 20, 2008
g1:nt VIA Electronic and Regular Mail
141. Dane L. Finerfrock
E*ecutivo Secretary
Utah Radiation Control Board
State of Utah Department of Environmental Quality
N8 North 1950 West
salt [^ake city, uT 84114-4850
Dear Mr. Finerfrock,
Donbon tlna (tl3A) Corp.
l0lr0 lTth gtn.t,sdb 9t0
omvtr, @ E02Ct
u3
Trl:303 32t77et
Fu:3033te-ll2t
rw.dmboilnhol.com
ltl,/'c r'/r/i//1
tt
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^. ^.. :, --. ^.!- . i - ., -;
;i:I
Re: White Mesa Mill-Containerized Alternate Feedstock Material Storage Procedure
Please firrd enclosed a new procedure entitled Containerized Alternate Feedstock Material Storage
Procedure. The procedure was developed in response to UDEQ correspondence dated April 29, 2008
and received by Danison on May 15,2008. Denison has determined that this procedure will be a
Standard Operating Procdure (SOP) under the Radioactive Materials License and will be added to
Book 10, x PBL 19 of that document. Accordingly, this procedure should be included at that location
for the purposes of the License Renewal Application submitted on February 28,2W7 and currently
under revi:w by the Division of Radiation Control.
If you should have any questions regarding this procedure please contact me.
Yours very truly,
.Lr1V,;t4fut[h./L_-'-foxrson Mrxus (USA) Conp.
Steve,n D. Landau
Manager, Environmental Affairs
Cc. Ron F. Hochstein
Harold R. Roberts
David C. Frydenlund
David E. Turk
2.4
No. PBL-19 I DENISON MINES (USA) CORP.
Rev. No.: R-0 | STANDARD OPERATING PROCEDURES I Page 1 of 3
Date: June 19,2008 | Title: Containerized Alternate Feedstock
Material Storese Procedure
1.0 Puroose
The purpose of this procdure is to assure that storage of feedstock material is conducted
in a manner so as to preclude the release of Mill feed material to the environment.
Scooe
Feed materials delivered to the White Mesa Mill must be stored in a manner which
precludes the release of the materials to the environment. In the case of bulk materials,
such as unrefined natural ores and alternate feeds delivered in inter-modal containerc,
these materials are oflloaded from the truck or shipping container directly onto the
approved ore pad where migration of material is precluded by the pad's design and
operating procedures (i.e. low permeability pad material, dust control procedures and
limited stockpile height). However, certain feeds are received in drums or other
containers which sqve to effectively contain the material during storage and, as such, are
amenable for storage either on the ore pad or at locations other than the ore pad. It is the
intent of this procodure to describe the environmental safety precautions utilized for
contained feed storage.
3.0 Procedure
3.1 Contained Feed Material Inspections
All contained feed materials received at the White Mesa Mill are inspected upon
arrival to determine that the containers are not leaking and to assure container
integrity prior to placing the material into storage. Each container will be
observed on all sides for damage or leakage of contents. All containers exhibiting
signs of leakage will be re-packd or placed in over-pack containers prior to
placing the materials into storage. Dented drums are acceptable if the dent is not
located near a seam or when the dent is not accompanied by a damage crease on
the drum surface. Drums damaged by dents near the seam, crease damaged
drums or containers that have been otherwise compromised during shipment are
re-packed or placed in over-pack containers prior to storage. Containers which
are not damaged at the time of receipt are kans1M directly for placement at the
storage location.
Storage Locations
3.1.1 Defined Feedstock Storage
Feedstock materials stored at the defined storage location indicated on the map
attached hereto as Attachment A (the "Defined Feedstock Area") can be stored in
containers or in bulk form and are subject to the routine inspections described by
3.2
No. PBL-19 I DENISON MINES (USA) CORP.
Rev. No.: R-0 | STANDARD OPERATING PROCEDURES I Page 2 of 3
Date: June 19,2008 | Title: Containerized Altcrnate Feedstock
Material Storase Procedure
the White Mesa Mill Tailings Managernent System Discharge Minimization
Technology (DMT) Monitoring Plan at Section 3.3. a) (the White Mesa Mill
Tailings Management System Discharge Minimization Technology (DMT)
Monitoring Plan is reproduced as Section 3.1 of the Mill's Environme,ntal
Protection Manual).
3.L.2 Storage of Contained Feeds in Locations Other Than the Defined
Fedstock Area
a) Over-packContainers
Materials received or transferred into over-pack containerc can be stored at
locations other than the Defined Feedstock Area absent a hardened ground surface
or containment berrns due to the fact that the over-pack container provides a
secondary containment for the packaged material. Over-pack materials are
subject to the routine inspections described by the White Mesa Mill Tailings
Managernent System Discharge Minimization Technology (DMT) Moniloring
Plan at Section 3.3. a).
b) Hardened Surface Storaee Locations
Contained feed materials, including materials in containers which have not been
provided with over-pack protection, can be stored at locations other than the
Defined Feedstock Area when a hardened ground surface storage location is used
and has been provided with containment berms. These materials are subject to the
routine inspections described by the White Mesa Mill Tailings Managernent
System Discharge Minimization Technology (DMT) Monitoring Plan at Section
3.3. a).
c) Single Lined Containers Stored Outside the Defined Feedstock Area
Where Hardened Surfaces and Containment Benns Are Not Utilized
Contained feeds can also be stored at locations, other than the Defined Feedstock
Areq that have been selected to avoid impact by site drainage and/or pooling.
Prior to storage at these locations, planks or pallets are placd beneath the drum
storage locations in order to raise the container from the ground surface and avoid
corrosion from water which may accumulate during precipitation events (despite
site selection) and from rusting due to soil moisture whe,n drums are stored
directly on the ground. These contained materials are subject to the more
particular storage protocols and inspections outlined below.
3.3
No. PBL-19 I DENISON MINES (USA) CORP.
Rev. No.: R-0 | STANDARD OPERATING PROCEDURES I Page 3 of 3
Date: June 19, 2008 | Title: Containerlzed Alternate Feedstock
Material Storage Procedure
Storage Protocol Sing!_e Lined Containers
In accordance with MSHA requirements, container storage must be implemented
in such a manner as to limit the potortial for a container to tip or fall onto a
worker. For drummed materials, the agency limits such stacks to three drums in
height due to stability considerations. In keeping with these concerns, Denison
will configure single lined storage drums (stored off the Designated Feedstock
Area) in rows no more than two containers wide at the base and may place a one-
container row either on top of a single row or in the middle of a lower two-
container row, in each case so as to straddle the tops of drums in the lower
container row(s). This stacking con{iguration dishibutes the single upper row
acrclss the bottom row(s) of containers in such a manner as to hold the bottom
row(s) from Ieaning and allowing for limited stacking on top of these lower
row(s). Accordingly, when stacking is necessary, this configuration minimizes
the risk of falling drums, limits stacking height for safety reasons and allows for a
thorough inspection of each of the individual containers from the outside of the
container row(s).
Sing{e-lined Container Stora& Area Inspections
The single-lined container storage area(s) that are offof the Designated Feedstock
Area will be inspected on a weekly basis (and after significant precipitation
events) on both sides of any row in order to assure that the stored materials
rernain intact, that standing water has not accumulated and that materials are not
leaking or migrating from the storage area.
Single-lined Container Storage Inspection Records
Denison will record all instances where single-lined containers are received
damaged (or leaking) and require re-packing or the provision of an over-pack
container. This information will be recordd on a container receipt form (see
Attachment B) which documents the receipt of drummed materials to be stored in
locations other than the Defined Feedstock Area. Similarly, each weekly
inspection shall be recorded on the inspection form referred to in the White Mesa
Mill Tailings Managernent Systern Discharge Minimization Technology (DMT)
Monitoring Plan at Appendix A and attached as Attachment C to this Procedure.
Such inspections require the documentation of container condition, the drainage
conditions in the storage location, the presence of leakage, if any, and any
corrective actions take,n due to leakage of containss or standing water at the
storage location.
3.4
3.5
o
Attachment A
o
o
Denison Mines ( US4 Corp.
Focdltocl StoragB Arsa Map
I
'r
o
Attachment B
o
o
Containerized Alternate Feed Receipt
Inspection
Number of containerVdrums in shipment:
Radiation Activity Levels:
Location of Storage:
Observations (note dented or damaged drums):
Corrective Action Taken for Damaged Drums:
lnspector Signature
Attaehment C
:r
Whitc Mesa Mill - Standard Opcrating Proccdurcs
Book 1l: Environnrcntel Protection Manual, Section 3.I
2/07 Revision: DUSA-3
Pagc2i of25
APPENDTX A (CONT.)
ORE STORAGEISAMPLE PLAiYT WEEKLY INSPECTION REPORT
Week of _ through _ Date of Inspection:
Inspector:
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions nccded or taken for the week:
ArE all bulk feedstock materials stored in the area irdicated on the attached diagram:y€s:_ no:
comments:
Are all alternate fcedstock materials located outside the area indicated on the attachd diagram maintainedwithin watcr-tight containem:Yes: no:
commcnts (e.g., curditions of containers):
Conditions of storage arcas for materials:
Ottrer cmrrrcnts:
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Atta*rrent I - Propg$ed Air$ffrnpling,51s11on Lroqflti0ns