DRC-2007-001825 - 0901a06880afdc09

WHITE MESA URANIUM MILL
LICENSB RENEWAL APPLICATION
STATE OF UTAH RADIOACTM MATBRIALS LICENSE No. UT1900479
February 28,2007
Prepared By:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO E0265
Volume Zof 5
(License Renewal Application)
(Appendices A-I)
|t Book 12, ALARA Program,
To:
From :
Date :
For the week of:
The following areas of the White Mesa Mill were inspected. A description of the potential safety hazards,
housekeeping, operational and radiological conditions are described. The color code breakdown is for those
departments I feel are responsible, but not limited to for repair of said items:
Red - Maintenance Green - Safety Blue - Operations/Labor Crew
If an item is underlined, that item must be corrected immediately.
Leach Tank Area:
a cCD Area:
Control Room and Lunch Area:
Administration Building:
Soda Ash:
Labor Change Room:
Denison Mines Supervisors
Vanadium Circuit:
Book 12, ALAR.{ Program, Appendix B
Page Two
Weekly Mill Inspection
Ore Storage:
Tailings:
SX Building:
Wareh ouse/lVlain ten ance :
Miscellaneous/Comments :
2/07 Revision: DUSA-l
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BOOK #11
BNVIRONMENTAL PROTECTION MANUAL
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White Mesa Mill - Standard Operating Procedures
Book #l 1, Environmental Protection Manual, Section l.l
Date'- 2lO7 Revision: DUSA-3
Page I of6
AIR MONITORING - PARTICULATE RADIONUCLIDES
PART I AIR MONITORING PLAN
1.0 PARTICULATE RADIONUCLIDE AIR MONITORING
Air samples for monitoring particulate radionuclides are taken at the following four
locations: (See Attachment A)
BHV-I
BHV-2
BHV-4
BHV-5
BHV-6
Northeast of the Mill at the meteorological station.
Approximately 2.5 miles north of the Mill.
Approximately 400 yards south of Cell No. 4.
Approximately 100 yards south of the inrersection of State Highway 191
and the Mill access road.
Approximately 0.5 miles south of BHV-5 along Highway 191.
Air samples are collected on a weekly basis. A composite of 13 weekly samples from
each of the above locations is prepared to form a quarterly sample for each location.
2.0 QUALITY ASSURANCE
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in this SOP (Section 6.0).
Quality assurance of the analytical results is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percent recovery. The laboratory will
also follow U.S. NRC Regulatory Guides 4.14 and 4.15 when analyzing the air filter
samples. The laboratory is committed to meet the LLD values for radionuclides listed in
these guidance documents, and will perform re-runs on all samples not meeting these
limits.
3.0 ANALYTICAL REQUIREMENTS
Each quarterly sample will be analyzed for U-nat, Ra-226,Th-23O and Pb-210. Results
will be expressed in picocuries per milliliter (pCi/ml).
PART II STANDARD OPERATING PROCEDURES
1.0 EQUIPMENT
The equipment used in monitoring levels of particulate radionuclides consists of high
volume air samplers equipped with mass flow controllers and vacuum switch controlled
timers. The samplers are capable of collecting air through the sample filter at a
volumetric flow rate of approximately 40 standard cubic feet per minute (scfm). The
White Mesa Mill - Standard Operating Procedures
Book #l I, Environmental Protection Manual, Section l.l
Date: 2/07 Revision: DUSA-3
PageZ of 6
2.0
mass flow controller varies the actual air flow rate as dictated by changing temperature,
filter loading, and barometric pressure to maintain a constant standard air flow rate. The
actual rate is read directly from the analog gauge located on the front panel. The timer is
turned off when no vacuum exists in the system, i.e., when the motor/blower assembly is
disconnected or otherwise malfunctions.
Particulates are trapped on an 8 x lO-inch glass microfiber filter such as one of the
following, or equivalent:
1. WhatmanEPM 1000
2. Whatman EPM 2000
3. Schliecher & Schuell #1 HV.
MONITORING METHODOLOGY
The air samplers are mounted on towers approximately 2 meters above ground plane.
The samplers run continuously except for calibration, mechanical or electrical failure, and
maintenance down time. Target flow rate will be 32 scfm.
Air filters are replaced weekly due to particulate loadings. Maximum filter use duration
will be weekly unless weather conditions prohibit safe access to one or more of the air
monitoring station locations.
Each filter is stamped by the manufacturer with a unique number. The blank filters are
weighed to the nearest 0.0001 gram using a Sartorius Model 2432 analytical balance or
equivalent. The filters are kept in manila folders for support during transportation. The
weights are then recorded on the filter folders along with the location, filter number, start
date, and start time. When the filters are collected in the field, the stop date and time are
entered on the folder. On retum from the field, the filters are again weighed and the gross
weights are recorded on the folders. Filters and folders are kept in resealable plastic bags.
Samples are collected continuously for approximately one week. The "loaded" filters are
removed from the shut down samplers, folded, and placed in the folders in the plastic
bags. If any part of the filter remains on the seal gasket, it is removed and added to the
folder. The new filters are removed from their folders and placed on the vacuum head
with the filter holder frame tightened enough to seal, but not tight enough to rupture the
filters. The samplers are then turned on.
Each station's filters are composited on a quarterly basis (13 weeks) by the environmental
staff. The samples are forwarded, along with an analytical sheet and Chain of Custody
(COC) form (provided by the contract laboratory), to the contract laboratory in sealed
plastic bags.
3.0
3.1
CALIBRATION
Orifice Plate
The orifice plates shall be calibrated every year as recommended by the EPA. A certified
calibration laboratory that will use the EPA or an EPA-approved method will do the
calibration. Calibration records are kept in the environmental files.
3.2 Sampler
Sampler airflow rates are checked weekly by visual observation of the analog meter,
graduated in standard cubic feet per minute.
Calibration of the equipment occurs during the first Monday of each month. If a non-
scheduled motor replacement is necessary, the sampler is re-calibrated.
An orifice plate assembly and U-tube manometer are used for monthly calibrations.
The sampler flow rate is regulated to a standard air volume that is recorded on the field
calibration sheet using zO"C. (298 K) and 29.2 inches (760 mm) of mercury as standard
conditions. A monthly calibration worksheet (Attachment C) is completed for each air
sampling station and retained in the files.
The monthly calibration task involves the following:
White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section l.l
1.
2.
J.
4.
5.
Date: 2107 Revision: DUSA-3
Page 3 of 6
4.O
Before visiting each monitoring location, the air temperature and barometric
pressure are recorded.
The motors are replaced as required. The replacement motors are prepared at the
Mill office.
The new filter is placed on the vacuum head, and the orifice plate is secured on
top of the filter.
The orifice plate is connected to the U-tube manometer and the initial inches H2O
is recorded.
The control screw is adjusted as necessary to advance or slow the vacuum motor
to reach the desired flow rate. The final flow rate must be at least 32 scfm on the
analog meter and reach 757o on-stream time for the quarter to meet the required
LLD for the radionuclide parameters.
The U-tube manometer level, in inches, is then recorded and a flow rate
calculated.
CALCULATIONS
Using inches of water from the U-tube, refer to the following subsections to perform the
calculation of flow rate. Section 4.1 provides the equation used to compute the flow rate
at field conditions, and the "actual" flow rate, in cubic meters per minute. Actual flow
rate must be corrected to standard flow rate using the flow rate equation in Section 4.2.
The standard flow rate is then converted to standard cubic feet with the conversion
equation in Section 4.3.
White Mesa Mill - Standard Operating Procedures
Book #l l , Environmental Protection Manual, Section L I
Date: 2107 Revision: DUSA-3
Page 4 of 6
4.1 Orifice Equation
Using the inches of water determined from the U-tube, the following equation is used to
calculated the flow rate at field conditions using:
Qa = a x (inches of water) b
Where
Qa = flow rate at field conditions, in cubic meters per minute (m3 / min).
a = orifice constant
b = orifice constant.
The constants a and b in the above equation are provided by the calibration laboratory for
each specific calibrated orifice (Attachment D). Each orifice will have unique
performance properties which relate to design and those measured performance properties
are incorporated into the flow equation as specific constants. The flow equation
demonstrates the relationship between measured vacuum pressure in inches of water to
actual flow rate utilizing this device.
4.2 Standard Conditions Flow Rate Equation
The flow rate at standard conditions is calculated by adjusting the field condition flow
rate, calculated above, by the following equation:
Qs=Qax [PaxTsl
lPs x Tal
where
Ts = Absolute temperature at orifice calibration (298 K)
Ta = Absolute temperature at air sampler calibration (273"C + measured "C)
Ps = Atmospheric pressure at orifice calibration (760 mm Hg)
Pa = Atmospheric pressure at air sampler calibration (measured mm Hg)
Qs = Flow rate at standard conditions in cubic meters per minute (m3 / min).
Qa = Flow rate at field conditions in cubic meters per minute(m3 / min).
4.3 Correction Equation
To convert the standard flowrate, Qs, from cubic meters per minute to
standard cubic feet per minute, use the following equation:
Q r,*.o.urn*"rp€,Minute = 35'341 x Qs
White Mesa Mill - Standard Operating Procedures
Book #l I, Environmental Protection Manual, Section l.l
Date'. 2/07 Revision: DUSA-3
Page 5 of 6
5.0 RECORD KEEPING
The records are kept on the filter folders, which are retained in the environmental files in
the environmental office, and are also into the computer files, after the data have been
reviewed. The following information will be entered in computer files (see Attachment
E):
6.0
. Filter number. Start date. Start time. End date. Stop time. Total time. Total liters. Loading in mg/cubic meter. Percent on-stream. Weekly average flow rate in cubic feet per minute
QUALITY ASSURANCE
Installation and Removal of f ilters
Field methods to assure quality of air sample collection include the following:
lnspection of all new filters for aberrations and discarding damaged ones.
Maintaining seals on equipment connections.
Careful installation and removal of filters, retaining all abraded filter media.
Proper sequential handling of all filters.
Filters are inspected for fingerprint contamination by visual observation.
6.2 Sample Duration
Maintenance of sample duration is assured by:
l. lnstallation of a vacuum-actuated timer which operates the timer only when
the motor is running and pulling the minimum allowable vacuum.
2. Weekly monitoring of stations and inspecting wear on the motors and proper
change-out at appropriate intervals (monthly).
6.3 Sample Flow Rate
Quality assurance of sample flow rate is accomplished by weekly visual checks of the
analog read-out. Monthly checks of flow controller operation and documentation thereof
6.1
White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section L I
also provide quality assurance. Samplers are checked
intervals (monthly).
Date: 2107 Revision: DUSA-3
Page 6 of 6
for calibration at motor rotation
6.4 Calculations
Calculations are checked on a random basis for inconsistencies, and such checks are
documented.
Upon retrieval of the data analytical sheet from the contract laboratory, the date of receipt
is noted, along with the date of transcribing to the sample station log sheet and the
transcriber's initials. The transcription of data is reviewed by another person in the
Environmental Department to minimize transposition of numerical values. Calculation
and data storage is by computer program.
6.5 Sampler Performance
A record of sampler operation time versus total possible duration time is maintained as a
flag against excessive equipment downtime. Sampler performance is reviewed monthly.
6.6 Quality Control Methodology
Blanks are weighed each week and submitted alongside the actual filters. The filters and
blanks are recorded on an analytical sheet which is sent to the vendor, and this sheet is
returned with the results.
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White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-0
Book #11, Environmental Protection Manual, Section 1.2 Page I of 2
1.
1.1
AIR MONITORING -- RADON
RADON MONITORING PLAN
Locations and Frequency of Samples
STANDARD OPERATING PROCEDURES
Equipment
Radon samples are taken at the following locations:
BHV-1
BHV-2
BHV-3
BHV-4
BHV-5
BHV-6
See Attachment A to Section 1.1 of this Environmental Protection Manual for the
locations of these monitoring stations.
Samples are collected on a quarterly basis
1.2
1.3 Analytical Requirements
Each quarterly sample will be analyzed for Radon-222.
Quality Assurance
Quality assurance of the samples is met by collecting samples in accordance with the
conditions and guidelines set forth in Section 2 of this procedure. In addition, the
following steps will be followed:
a) Detector locations will be monitored periodically to ensure the detectors have
not been lost;
b) Detector shipments will be inspected to ensure that all detectors are present
when receiving or shipping detectors; and
c) Monitoring data will be reviewed for consistency and data transportation.
)
2.1
Samples will be collected using the Radtrak@ (Trac-Etch) Outdoor Air Radon Detector,
or equivalent.
1)
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-O
Book #11, Environmental Protection Manual, Section 1.2 Page 2 of 2
Monitoring Methodology
The following monitoring procedures will be followed:
a) Remove detector from package - The Radtrak@ radon detectors are supplied
in aluminum bags which prevent radon exposure. Open the aluminum bag and
remove the clear plastic cup which has a Radtrak@ detector fastened to the
bottom. Detectors, before, during or after exposure should not be in locations
which exceed a temperature of 160'F (70"C). There is no low temperature.
b) Fill in the enclosed Detector Log Sheet with the serial number on the detector
label. Also fill in the date installed and the location information in the
location/comments area.
c) Attach a field canister to a post or other location using the metal bracket with
the open mouth of the canister facing down. The canister may be placed at any
desired height (typically 3-6 feet) and preferably in a location minimizing animal
damage or tampering. Remove the clear acrylic retaining ring from the canister
by removing the wing nuts. lnstall the assembled cup inside the canister and
replace the retaining ring and wing nuts in order to hold the cup in place.
d) Leave the detector undisturbed for the duration of the three month monitoring
period.
e) At the end of the monitoring period, remove the Radtrak@ detector from the
plastic cup. Peel off the gold seal provided with the shipment and cover all the
holes on the top of the detector. This stops the monitoring period. Record the
ending date on the Detector Log Sheet.
0 Return the detector(s) along with a copy of the Detector Log Sheet using the
enclosed label for shipment back to supplying organization.
RECORD KEEPING
Data maintained in record form for environmental radon is:
a) Sample period;
b) Sample location; and
c) Radon levels.
3.
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White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 1.3
Date: 02101 Revision: DUSA- I
Page I of I
l.
METEOROLOGICAL DATA MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
MONITORING METHODOLOGY
1.1 Monitoring Equipment
The collection of meteorological data is accomplished on a daily basis through the use of a
Campbell Scientific Data Logger Model #SM 192, or equivalent. The meteorological station
retrieves the data continuously and the information is downloaded into the aforementioned data
logger.
1.2 Weekly Function Check
On a weekly basis, a function check of the system is performed. The function check includes
checking of the data logging process, amount of data points being stored, wind direction, wind
speed, and battery voltage. This information is tabulated on tle form "A" attached.
1.3 Weekly Downloading of Data
see form "B" for specifications on the downloading and data retrievar.
1,4 Monthly Exchange of Data Module
On the first Monday of each month, after the downloading and data retrieval, exchange the data
module with another data module and send the older module in for downloading and data
verification by the independent meteorological contractor.
After the contractor has downloaded all data and verification of the data has been established, the
contractor will then return the data module for exchanging the next month.
Record Keeping
All paperwork generated through the downloading and verification process will be maintained
in the Environmental Department.
1.5
FORI,,I A
WEERI,Y UETEOROLOGICAL STAT,ION CHECK - WHITE MESA MILL
HARD'rt/ARE col'fl,lEllT.l
SOLAR PANEL:
BATTERY CHARGE
STATION CONDITION:
pENSQEs,
WIND VANE:
WINO SPEED:
TOWER CABLES:
DATA MODULE:Eytes:
UIASEIBETIAT
DATE:
sroRAGE LocArtoN srARr:'--
STORAGE LOCATION END:
DATA TRANSFER OK (TECH INITIALS):
fll,lEoFoAY(Ms>
FORM B
Toual dump of daE,a from datalogger E,o st.orage module:
Kev Display*8 0B:007L 08;71AA 03:rcoo<
B 02:rcoo<
AA 04:00
Ix-
*0
Procedure Eo check
sEorage module:
Key Di-spl"av*9 09:01-L 09:1A 91:007 9L:'1A 07:00A O7:rcxxpc
Disnlav_
06:0000
01:xxxx
02:xxxx
03;xxxx
:LOG1
Explanation
*0
Manual dump7 for 'sEorage module L for modules address
advance Eo location Ehree, wriEe this number
down and add L Eo iE. Backup Eo locaeion 02:
using Lhe b key and enter Ehis new number in
locaE,ion 02;AfEer enEeringr the nurnber, advance E,o location
4 and enEer.a 'L' and, E.hen 'A' Eo begin Ehb
dunrp. The display should incremenE rather
quickly while the dump proceeds.exie and reEurn to normal logging mode.
on the nunrber of data points stored in a
E:<plapationgnter storag'e module command mode
1 is the storag'e module address
ready to accepE commandEnter command*? (DTSPLAY DAtA)
Dump pointer Eo SRPthi! is the number of daEa poinEs sEored in
E,he sEoragre module. If this number Ls > 2,
Ehen bhe logger is st,oring data correct'ly E'o
the sEorage module.Exit and reEurn Eo normal loggring mode.
Push
*6
A
A
A
,t0
*6 COilUtIID SUrltARy
Com!ent
Enter display node
tlisplays rind direction
displays wind speed (n/s)
displays battery voltageExits prograln
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rn
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White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 1.4
Date: 2107 Revision: DUSA-2
Page I of6
STACK EMISSION MONITORING PROCEDURES
WHITE MESA GAS STACK EMISSIONS
INTRODUCTION
White Mesa uses scientifically approved reference methods to determine gas stack
emissions release concentration for radionuclide particulates. These methods
conform to principles that apply to obtaining valid samples of airborne radioactive
materials, using prescribed acceptable methods and materials for gas and
particulate sampling. See American Standard Guide to Sampling Airborne
Radioactive Materials in Nuclear Facilities ANSI N13.1-1969. These sampling
methods are also consistent with guidance contained in the U.S. Nuclear
Regulatory commission's Regulatory Guide 4.14, "Radiological Effluent and
Environmental Monitoring at Uranium Mills."
SAMPLING METHODOLOGIES
The sampling methods for airborne radionuclide particulates, from the yellowcake
dryer and other mill effluent control stacks, are identical to methods published in
the EPA's manual, Gas Stream sampling Reference Methods for New source
Performance standards; they are found in the EPA Manual in Appendix No. 5,
"Determination of Particulate Emissions from Stationary Sources" ("EpA Method
#5") and Appendix No. 17, "Determination of Particulate Emissions from
Stationary Sources (ln-Stack Filtration Method)" ("EPA Method #17). copies of
EPA Method #5 and #r7 are attached to this SoP. Sampling is performed as per
the methods, to ensure that the sampling and results are: (1) isokinetic; (2)
representative; and (3) adequate for determination of the release rates and
concentrations of U-Nat, Th-230, Ra-226 and Pb- 2 1 0.
Sampling Equipment
Sampling equipment used to collect airborne radionuclide particulates from point
source emission stacks at the Mill consists of equipment manufactured by
Research Appliance company (RAC), (or other equivalent apparatuses), as
follows:
1. RAC Model 201009 Model 2414 stack sampler.2. Two each, RAC Model 201044 modular sample cases. one heater box and
one glassware box.
3. One each, RAC Model201019 umbilical cord.
1.0
2.O
2.1
White Mesa Mill - Standard Operating Procedures
Book #l I : Environmental Protection Manual, Section 1.4
Date: 2lO7 Revision: DUSA-2
Page2 of 6
4. Three each, RAC Model 201013 - l00mm diameter filter holders.
5. One each, RAC Model 201005 standard pilot tube, three feet length,
stainless steel/S-type probe.
6. Barometer.
7. Psychrometer.
8. Satorius Model 2432balarce or equivalent.
9. Triple beam balance.
Equipment instruction and operating manual(s) provided by the manufacturer(s)
are retained at the Mill and used for specific guidance and reference.
2.2 Sample Collection
Gas stack samples are collected from emission control systems used in Uranium
Recovery Operations at the Mill. These samples are collected from process stacks
when the emission control systems are operating. They are sampled for
radionuclide particulate concentrations at a frequency in accordance with Table 5-
1. Sample collection methods are described in detail in EPA Method #5 and EPA
Method #17, Determination of Particulate Matter Emissions From Stationary
Sources. It is necessary to read and understand all procedures described in the
methods and in the equipment manual. The operation of the equipment requires
"hands-on" instruction from the Radiation Departmental Staff from individuals
who are experienced in using sample collection equipment and applying sample
collection methods. The following steps are described for stack sample
collection.
1. Check equipment listed in Section 2.1 of this SOP. Consult the
manufacturers equipment operations manual for details.
2. Assemble equipment as described in the operations manual for sample
collection EPA Method #17 .
3. Follow the calibration procedure listed in the manual. If the
calibration measurements are not obtained, consult the trouble
shooting section of the manual for corrective instruction. Once the
collection apparatus is calibrated, proceed to the next step.
4. Weigh a new glass fiber filter, record the weight, and place in the
filter holder assembly.
5. Check the sample collection system for leaks.
6. Cap ends of sample probes to prevent contamination and transport
sample unit to the sample location.
7. Uncap sample end and insert 3/8-diameter sample probe into the stack
in the midsection of the exhaust stream.
8. Tum sample apparatus on and observe unit operation to insure a
sample is being collected and the apparatus is functioning properly.
White Mesa Mill - Standard Operating procedures
Book #l l: Environmental Protection Manual. Section 1.4
Date: 2107 Revision: DUSA-2
Page 3 of6
collect the stack sample for at least one hour during periods of routine
process operation. Note the collection time.
Record the information described in the manufacture's operations
manual. This information is also described in the EpA Methods #5
and, #17 for point source particulate emissions.
After sample collection is complete, turn off unit. obtain sample
filter from filter housing and place in a new plastic petri dish. Send to
outside laboratory for radionuclide analysis in accordance with rable
5-1.
Sample Handling and Shipping
1. During preparation and assembly on the sampling train, keep all
openings where contamination can occur covered until just prior to
assembly or until sampling is about to begin.2. Using a tweezer or clean disposable surgical gloves, place a labeled
(identified) and weighed filter in the filter holder. Be sure that thefilter is properly centered and the gasket properly placed so as to
prevent the sample gas stream from circumventing the filter. Check
the filter for tears after assembly is completed.3. Before moving the sampling train to the cleanup site, remove the
probe from the sample train, wipe off the silicone grease, and cap the
open outlet of the probe. Be careful not to lose any condensate that
might be present. Wipe off the silicone grease from the filter inlet
where the probe was fastened, and cap it. Remove the umbilical cord
from the last impinger, and cap the impinger. If a flexible line is used
between the first impinger or condenser and the filter holder,
disconnect the line at the filter holder, and let any condensed water or
Iiquid drain into the impingers or condenser. After wiping off the
silicone grease, cap off the filter holder outlet and impinger inlet.
Either ground-glass stoppers, plastic caps, or serum caps may be used
to close these openings.4. Transfer the probe and filter-impinger assembly to the cleanup area.
This area should be clean and protected from the wind so that the
chances of contaminating or losing the sample will be minimized.5. Save a portion of the acetone used for cleanup as a blank. Take 200
ml of this acetone directly from the wash bottle being used, and place
it in a glass sample container labeled ..acetone blank.',6. Carefully remove the filter from the filter holder, and place it in its
identified petri dish container. Use a pair of tweezers and/or clean
disposable surgical gloves to handle the filter. If it is necessary to fold
the filter, do so such that the pM cake is inside the fold. Using a dry
Nylon bristle brush and/or a sharp-edged brade, carefully transfer to
9.
10.
11.
2.3
3.0
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 1.4
4.0
Date: 2107 Revision: DUSA-2
Page 4 of 6
the petri dish and PM and/or filter fibers that adhere to the filter
holder gasket. Seal the container.
7. Send to the laboratory for radionuclide analysis.
RECORD KEEPING
Records of gas stack effluent sampling events and results of analysis are retained
at the Mill. The following information is recorded:
1. Stack and Run ID
2. Date and Sampler
3. Sampled Air Volume at standard conditions
4. Sampled Water Volume at standard conditions
5. Moisture Content (volume basis)
6. Stack Gas Molecular Weight (wet basis)
7. Stack Gas Velocity
8. Stack Gas Volumetric Flow Rate (dry basis, at standard conditions)
9. Particulate Concentration
10. Percent Isokinetics
11. Emission Rates for Particulates U-Nat, Th-230, Ra-226, and Pb-210.
The data are used to calculate emission rates in pounds and
for radionuclide particulate concentrations.
MONITORING LOCATION AND FREQT]ENCY
curies per hour
Stack sampling must be performed during any quarter or semi-annual period that
the stacks operate in accordance with the schedule in Table 5-1. During non-
operational periods, stack sampling is not performed.
YELLOWCAKE STACKS
The exhaust stack for the drying and packaging equipment associated with the
yellowcake calciner is sampled on a quarterly basis during operations. The
sample ports are located on the roof of the main Mill building.
Feed Stacks
The grizzly feed stack is located on the north end of the grizzly structure. This
stack is accessible from a stack platform and is sampled on a semi-annual basis if
this system is operating.
plco
4.1
4.2
5.0
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 1.4
Feed Stack
Quarterly: None
Semi-Annual: If operating, U-nat, Th-230
Dare: 2107 Revision: DUSA-2
Page 5 of 6
Stack for Y.C. Dryer and Packaeing
Quarterly: If operating, U-nat
Semi-Annual: If operating, U-nat-
Th-230,Ra-226,
Pb-210
ANALYSIS RBQUIREMENTS
All gas stack samples are collected at the Mill according to the calendar year
schedule shown below in Table 5-1. The samples will be sent to an off-site
laboratory for the analysis detailed below.
TABLE 5.1
Sampling Frequency and Analysis
6.0
6.1
QUALITY ASSURANCE METHODOLOGY
Equipment Operation
Prior to performing an emission point sampling run, the sampling equipment is
subjected to a dry run test to determine leakages or equipment malfunction.
Calibration of equipment is checked on a periodic basis. Probe tips are protected
by a protective cap while not in use to protect accuracy determinations. During
transport of equipment, all openings are sealed to prevent contamination.
Calculations utilized during runs to maintain isokinetic conditions are reviewed
and dry run tested prior to the actual run. All containers and probes are washed
prior to each usage.
Malfunction of sampling equipment, excessive malfunctions of normal operations
being monitored, or percent isokinetic sampling rates greater than + l\Vo error,
indicate mandatory voiding of the run or data involved.
0perations
If samples are collected from the operation of any unit which appears, in the
judgment of the sampler, to be functioning in a manner not consistent with normal
operations, then the sample will be voided and the system will be resampled.
Chemical Sample Control
Analyses on each period's sample shall include blanks for the filters, impinger
solutions, and the rinse solutions. A field logbook shall be maintained listing data
6.2
6.3
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 1.4
Calculations
All calculations
files.
be retained at the
Date'. 2107 Revision: DUSA-2
Page 6 of 6
both a hard copy and computer
generated, determinations of volumes measured, and net gain weights of filters to
provide a back up to summary data records. Filters are transmitted within plastic
enclosed petri dishes. Handling of filters is only done using tweezers.
6.4
The gas stack effluent concentrations (C) are calculated as follows:
Lab Result pci (A) I Volume Sampled (V) = Effluent Concentration (C)
where
Volume Sampled (V) = Flow rate (Q) * Time of sample collection in minutes (t)
and
Lab Result pci (A) = Radioisotopic activity, in pCi on air filter
v,trao,oo
€q,
o
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 2.1
PART I
1.0 MONITORING METHODOLOGY
1.1 FIow Measurement
Date: 21 07 Revision: DUSA- I
Page I of5
SURFACE WATER MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
SURFACE WATER MONITORING PLAN
1.2
No flow measurements are taken at the two drainage creeks sample locations: Westwater
Canyon and Cottonwood Creek.
(
Water Quality
Westwater Canyon and Cottonwood Creek are monitored at two locations west of and
adjacent to the White Mesa Mill facility (See Figure 1). Samples are obtained amually
from Westwater and quarterly from Cottonwood using grab sampling and analyzed in
accordance with Table 1.
QUALITY ASSI]RANCE
Quality assurance for surface water monitoring includes an annual review of procedures
used to measure field parameters; review of procedures for sample preservation;
precautions applied to use of sample containers and equipment; and semi-annual
submittal of one site split sample for analysis as a blind duplicate.
PART II SURFACE WATER STANDARD OPERATING PROCEDURES
r.0 EQUTPMENT
Equipment used for monitoring surface water quality includes:
1. Hydrolab Surveyor 4 meter and probe, or equivalent;
2. 2 one gallon sample containers
2.0 SAMPLING PROCEDURE
Two one gallon samples using clean unused sample containers that are provided by the
analytical laboratory, are obtained. Specific conductivity, temperature and pH data are
2.0
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 2.1
Date: 2107 Revision: DUSA-l
Page 2 of5
obtained in the field as an in-stream measurement, and recorded on the field water
analysis data form (Attachment A). One of the samples is sent off to the laboratory and
the other remains on site in the environmental sample refrigerator as a backup sample for
the analytical laboratory. Suspended samples are not filtered.
Samples are submitted to the analytical laboratory on a quarterly basis. See Table I for
analytical data to be requested on the surface samples.
2.1 Sample Labeling
Sample containers are labeled with:
1. Project/facility
2. Date and time of sample
3. Filtered or unfiltered
4. Preservation method
5. Sampler's initials
6. Sample location
3.0 CALIBRATION
Equipment used to measure field parameters will be calibrated in accordance with SOP
PBL-EP-12.
4.0 RECORD KEEPING
Radiological and chemical quality data is maintained in the Mill files in the
Environmental Office. Records will include field and laboratory data as follows:
1. Sample location
2. Sample date
3. Field pH
4. Field temperature
5. Field conductivity
6. Total Suspended Solids Concentration
7. Total Suspended Radionuclide Concentrations
8. Dissolved Radionuclide Concentrations for U-nat, Th-230, Ra-226
5.0 MONITORING LOCATIONS AND FREQIIENCY
As shown on Table 1, surface water samples are collected from two locations west of the
Mill property:
1. Lower Cottonwood Creek;
2- Lower Westwater Creek.
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 2.1
Date; 2107 Revision: DUSA- I
Page 3 of5
6.0
Samples are obtained four times a year on Cottonwood Creek with the semi-annual list of
parameters analyzed twice, and the quarterly list analyzed twice per year. Westwater is
sampled once on an annual basis and analyzed for the list of semi-annual parameters
shown on Table l.
ANALYSIS PROCEDURE
The contract laboratory analytical procedures are in accordance with their respective
established quality assurance and quality control programs.
Field sampling procedures are discussed in Section 2.0. Measurement of field parameters
is performed using instruments which have been calibrated in accordance with SOP PBL-
EP-12.
QUALITY ASSURANCE METHODOLOGY
Field Quality
Review of pH, temperature, and conductivity procedures performed in accordance with
SOP PRL-EP-12 is done each year. Review of procedures involved with sample
preservation is checked each sampling period. Sample collection bottles are not re-used
and sample contents are maintained in a cooler.
Water Quality
On a semi-annual basis, one site sample is split in the field and submitted as a blind
duplicate for analytical and sample collection quality assurance. Deviations greater than
ten percent result in review ofprocedures.
Data is reviewed and graphed on a semiannual basis to observe abnormalities.
7.0
7.1
7.2
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 2.1
Semiannual*
One gallon Unfiltered and raw
One gallon Unfiltered
and preserved to pH <2 with
HNO3
Total dissolved solids
Total suspended solids
Gross Alpha
Suspended U-nat
Dissolved U-nat
Suspended Ra-226
Dissolved Ra-226
Suspended Th-230
Dissolved Th-230
Table 1
Operational Phase Surface Water Monitoring Program
Monitoring Sites
Westwater and Cottonwood Creeks
Field Requirements
1. Temperature oC
2. Specific Conductivity, trrmhos at25 oC
3. pH at 25 oC
4. Sample date
5. Sample ID
Vendor Laboratory Requirements
Date: 2107 Revision: DUSA- I
Page 4 of 5
Ouarterly
One gallon Unfiltered and Raw
One gallon Unfiltered and preserved
to pH <2 with HNO3
Total dissolved solids
Total suspended solids
*semiannual sample must be taken a minimum of four months apart.
s*Annual Westwater Creek sample is analyzed for semi-annual parameters.
Radionuclides and LLDs reported in Cilml
White Mesa Mill - Standard Operating Procedures
Book #l I : Environmental Protection Manual, Section 2.1
Date: 2lO7 Revision: DUSA- 1
Page 5 of5
Attachment A
FIELD WATER ANALYSIS SURFACE WATER
WHITE MESA MILL
LOCATION (Circle one):Cottonwood Creek Westwater Canyon Other (describe)_
DATE:
(Sampler's initials)
pH BUFFER 7.0 pH BUFFER 4.0
SPECIFIC CONDUCTIVITY UMHOs
STEAM DEPTH:
pH of WATER TEMP
BY:
COND umhos coND p!oher--
pH unitspH Units
Temp oC
COND plshqs
Temp oC
COND p
pH units
Temp oC
mhos
pH units
Temp oC
Comments:
{
3
=GIo
=GIt+
U,
o
o3
White Mesa Mill - Standard Operating Procedures
Book l l : Environmental Protection Manual, Section 3. 1
9/08 Revision: Denison-6
Page I of 36
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1. INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan") for the White Mesa Mill (the "Mill") provides procedures for monitoring of the tailings cell
system as required under State of Utah Radioactive Materials License No. UT1900479 (the
"Radioactive Materials License"), as well as procedures for operating and maintenance of monitonng
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No. 370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability, liner integrity, and transport
systems, as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill. The Plan requires daily, weekly, quarterly, monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2. DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
Daily Comprehensive Tailines Inspection
On a daily basis, including weekends, all areas connected with the four tailings cells will be
inspected. Observations will be made of the current condition of each cell, noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspectrons, except on weekends when the Shift Foreman will perform the weekend tailings
inspections. The Radiation Safety Officer may designate other individuals with training, as
described in Section 2.4 below, to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data f orm (a copy of
which is attached in Appendix A). The Daily Inspection Dataformcontains an inspectton checklist,
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 2 of 36
which includes a tailings cells map, and spaces to record observations, especially those of immediate
concern and those requiring corrective action. The inspector will place a check by all inspection
items that appear to be operating properly. Those items where conditions of potential concern are
observed should be marked with an "X". A note should accompany the "X" specifying what the
concern is and what corrective measures will resolve the problem. This observation of concern
should be noted on the form until the problem has been remedied. The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following: Cell 1,2,3, and 44, Dikes 1,2,3,4A-S, and 4A-W,
wind movement of tailings, effectiveness of dust minimization methods, spray evaporation , Cell2
spillway, Cell 3 spillway, Cell 3 and 4A liquid pools and associated liquid return equipment, cell
leak detection systems, and the wildlife ponds.
Operational features of the tailings area are checked for conditions of potential concern. The
following items require visual inspection during the daily tailings inspection:
a) Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s), and pool return pipeline and pumps.
i)
Daily inspections of the tailings lines are required to be performed when the Mill
is operating. The lines to be inspected include the: tailings slurry lines from CCD
to the active tailings cell; SX raffinate lines that can discharge into Cell 1, Cell 3
or Cell 4A; the pond return line from the tailings area to the Mill; and, lines
transporting pond solutions from one cell to another.
Cell 1.
Cell2.
Cell 3.
Cell4A.
Dike structures including dikes 1,2,3,4A-S, and 4A-W.
The Cell 2 spillway, Cell 3 spillway, Cell 3 and Cell 4,{ liquid pools and
associated liquid return equipment.
Presence of wildlife and/or domestrcated animals in the tailings area, including
waterfowl and burrowing animal habitations.
Spray evaporation pumps and lines.
b)
c)
d)
e)
s)
h)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9i08 Revision: Denison-6
Page 3 of 36
j)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation of preventative dust minimization measures for cells containing tailings
sand. During tailings inspection, general surface conditions will be evaluated for
the following: l) areas of tailings subject to blowing and/or wind movement, 2)
liquid pool size, 3) areas not subject to blowing and/or wind movement,
expressed as a percentage of the total cell area. The evaluations will be reviewed
on a weekly basis, or more frequently if warranted, and will be used to direct dust
minimization acti vities.
Observation of flow and operational status of the dust control/spray evaporation
system(s).
Observations of any abnormal variations in tailings pond elevations in Cells 1, 3,
and 4,{.
Locations of slurry and SX discharge within the active cells. Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
n) An estimate of flow for active tailings slurry and SX line(s).
An estimate of flow in the solution return line(s).
Daily measurements in the leak detection system (LDS) sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in the Cell I and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours. The
solution level in Cell 4A leak detection is not allowed to be more than 1.0 foot
above the lowest point on the bottom flexible membrane liner (elevation 5556.14
feet amsl). If any of these observation are made, the Mill Manager should be
notified immediately and the leak detection system pump started.
k)
r)
m)
o)
p)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page 4 of 36
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording, a notation of the date and the time will be recorded on the
Daily Inspection Dataform. This data will be used in accordance with License
Condition 11.3.B through 11.3.E of the Mill's Radioactive Materials License, to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
q) An estimate of the percentage of the tailings beach surface area and solution pool
area is made, including estimates of solutions, cover areas, and tailings sands for
Cells 3 and 4A.
Items (a), (m), (n), and (o) are to be done only when the Mill is operating. When the Mill is down,
these items cannot be performed.
2.2. Daily Operations Inspection
During Mill operation, the Shift Foreman, or other person with the training specified in Section 2.4
below, designated by the Radiation Safety Officer, will perform an inspection of the tailings line and
tailings area at least once per shift, paying close attention for potential leaks and to the discharges
from the pipelines. Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3. Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and2.2 above, a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues, such as leaking pipes or unusual wildlife activity or incidences.
No record of these patrols need be made, but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4. Training
All individuals performing inspections described in Sections 2.1 and2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure, which is
attached as Appendix B. This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed. In addition, each
individual, after reviewing the training pack, will sign a cerlification form, indicating that training
has been received relative to hrs/her duties as an inspector.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 5 of 36
2.5.Emergencies
Inspectors wrll notify the Radiation Safety Officer and/or Mill management immediately if, during
their inspection, they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency. Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer, inspectors will have the authority to direct resources during tailings
emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Colporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
3. WEEKLY TAILINGS AND DMT INSPECTION
Weekly Tai lin es Inspections
Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the
following:
a) Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry. If marked wet, the liquid levels need to be measured and
reported. In Cell I and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system. The Cell44. leak detection system is monitored on
a continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector. The pressure transducer is calibrated
for fluid with a specific gravity of 1.0. The water levels are measured every hour
and the information is stored for later retrieval. The water levels are measured to
the nearest 0.10 inch. The data collector is currently programmed to store 7 days
of water level information. The number of days of stored data can be increased
beyond 7 days if needed. The water level data is downloaded to a laptop
computer on a weekly basis and incorporated into the Mill's environmental
monitoring data base, and into the files for weekly inspection reports of the
tailings cell leak detection systems
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page 6 of 36
If sufficient fluid is present in the leak detection system of any cell, the fluid shall
be pumped from the LDS, to the extent reasonably possible, and record the
volume of fluid recovered. Any fluid pumped from an LDA shall be returned to a
disposal cell.
If fluid is pumped from an LDS, the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded, whichever is the
more recent. This calculation shall be documented as part of the weekly
inspection.
Upon the initial pumping of fluid from an LDS, a fluid sample shall be collected
and, analyzed in accordance with paragraph 1 1.3 C. of the Radioactive Materials
License.
For Cell 44, under no circumstance shall fluid head in the leak detection
system sump exceed a l-foot level above the lowest point in the lower flexible
membrane liner. To determine the Maximum Allowable Daily LDS Flow
Rates in the Cell 4A leak detection system, the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector, and that information will be used to calculate an average volume
pumped per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table 1 in
Appendix E, to determine the maximum daily allowable LDS flow volume for
varying head conditions in Cell 4,{.
b) Slimes Drain Water Level Monitoring
(i) Cell 3 is an active tailings cell while Cell2 is partially reclaimed with approximately
90Vo of the surface covered by platform fill. Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii) Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain. As taken from actual measurements, the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe, at the ground surface level. This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell2, which, based on construction reporls. is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 7 of36
(iii)The shmes drain pump in Cell 2 is on a timed system, under which it pumps for 15
minutes each hour, thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again. Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of 38 feet after each pumping, in each
case measured below the water level measuring point on the slimes drain access pipe.
The average wastewater head in the Cell2 slimes drain is therefore about 5 feet. The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell2, which is at a depth of about 20 feet below the water level measuring
point on the slimes drain access pipe. As a result, there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system. Mill management
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable. Based on past experience, cycling the pump more than 15 minutes every
hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly, which is noted on the Weekly Tailings Inspection Form.
If at any time the pump is observed to be not working properly, it will be fixed or
replaced within 15 days;
(v) Depth to wastewater in the Cell2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle, respectively. All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe), and made to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis, the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours. Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (l) hour apart) the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form, by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
No process liquids shall be allowed to be discharged into Cell 2;
If at any time the most recent average annual head in the Cell 2 slimes drain is
(vii)
(viii)
found to have increased above the average head for the prevrous calendar year, the
Licensee will comply with the requirements of Part I.G.3 of the GWDP, including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Cell 4A are currently active, no pumping from the Cell 3 or Cell
4A slimes drain is authorized. Prior to initiation of taihngs dewatering operations for
Cell 3 or Cell 4A, a similar procedure will be developed for ensuring that average
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page 8 of 36
head elevations in the Cell 3 and Cell 4,A. slimes drains are kept as low as reasonably
achievable, and that the Cell 3 and Cell 44' slimes drains are inspected and the results
reported in accordance with the requirements of the permit."
c) Wind Movement of Tailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d) Tailings Wastewater Pool Elevation Monitoring
Solution elevation measurements in Cells l, 3 and 4A and Roberts Pond are to be taken by
survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor") with the assistance of another Mill worker (the "Assistant");
(ii) The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet, such as a Sokkai No. 821, or equivalent, together with a
survey rod (the "Survey Rod") having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells l, 3 and 44, and Roberts
Pond are known points established by professional survey. For Cell I and Roberts
Pond, the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1. The elevation of the metal disk (the "Reference Point
Elevation") for Cell I and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL"). For Cell 3 and cell 4,A., the Reference Point is a piece of metal rebar
located on the south dike of Cell 3. The elevation at the top of this piece of rebar
(the Reference Point Elevation for Cell 3 and cell 4A) is at 5,607.83 FMSL;
(iv) The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond surface are visible. For Cell I and Roberts
Pond, this is typically on the road on the Cell 1 south dike between Cell I and
Roberts Pond, approximately 100 feet east of the Cell l/Roberts Pond Reference
Point. For Cell 3 and Cell 44, this is typically on the road on the Cell 3 dike
approximately 100 feet east of the Cell 3 Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(vr)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 3 and cell 4,A. Reference Point. The Assistant will ensure that the
Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor
has established a level reading;
(vii)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Ref'erence Point Reading"), which
White Mesa Mill - Standard Operating Procedures
Book I l': Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page 9 of 36
represents the number of feet the Survey Instrument is reading above the
Reference Point;
(viii) The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in the Cell or Roberts Pond, as
the case may be. These designated locations, and the methods to be used by the
Assistant to consistently use the same locations are as follows:
A. Cell 3
A stake has been place in the central area of the south dike of Cell 3. The
Assistant will walk perpendicular to the dike from the stake to the nearest point
on the liquid surface of Cell 3 and place the Survey Rod at that location;
B.Cell 44'
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
C. Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1. The Assistant will place the Survey Rod against that mark
and hold the rod vertically, with one end just touching the liquid surface; and
D Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond. The
Assistant will place the Survey Rod against that mark and hold the rod
vertically, with one end just touching the liquid surface.
Based on the foregoing methods, the approximate coordinate locations for the
measuring points for Roberts Pond and the Cells are:
These coordinate locatrons may vary somewhat depending on solution elevatrons
in the Pond and Cells:
Northine Eastins
Roberts Pond 323,041 2,579,691
Cell 1 322,196 2,579,271
Cell 3 320,508 2.577,760
Cell 4A 320,300 2,579,360
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l0 of 36
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond surface. The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(x) The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod, and record the number (the "Pond Surface Reading"), which
represents the number of feet the Survey Instrument is reading above the pond
surface level.
The Surveyor will calculate the elevation of the pond surface as FSML by adding the
Reference Point Reading for the Cell or Roberts Pond, as the case may be, to the Reference
Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for
the Cell or Roberts Pond, and will record the number accurate to 0.01 feet.
e) Summary
In addition, the weekly inspection should summarize all activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspectiotx
form. An example of the Weekly Tailings and DMT Inspection form is provided in Appendix A.
3.2. Weekly Inspection of Solution Irvels in Roberts Pond
On a weekly basis, solution elevations are taken on Roberts Pond, in accordance with the procedures
set out in Section 3.1 d) above. The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspection form. Based on historical observations, the FML at the Pond
Surface Reading area for Roberts Pond, is approximately six inches above the lowest point on the
pond's FML. If the pond solution elevation at the Pond Surface Reading area is at or below the FML
for that area, the pond will be recorded as being dry.
3.3. Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department, to
confirm that:
a) the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP, as indicated on the map attached hereto as Appendix D; and
b) all alternate f-eedstock located outside the defined Feedstock Area are maintained within
water tight containcrs.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page ll of36
The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report, a copy of which is contained in Appendix A. Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4. MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Dataforrn, an example of
which is contained in Appendix A. Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable. The following items are to be inspected:
a) Tailings Slurry Pipeline
When the Mill is operating, the slurry pipeline will be inspected at key locations to
determine pipe wear. Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staff or other trained designees. The critical points of the
pipe include bends, slope changes, valves, and junctions, which are critical to dike
stability. These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
Diversion Ditches
Diversion ditches l, 2 and 3 shall be monitored monthly for sloughing, erosion,
undesirable vegetation, and obstruction of flow. Diversion berm 2 shouldbe checked
for stability and signs of distress.
Sedimentation Pond
Activities around the Mill and facilities area sedimentation pond shall be summarized
for the month.
Ov e rspray Dust Minimization
The inspection shall include an evaluation of overspray minimization, if applicable.
This entails ensuring that the overspray system is functioning properly. In the event
that overspray is carried more than 50 feet from the cell, the overspray system should
be immediately shut-off.
b)
c)
d)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 12 of36
e) Remarks
A section is included on the Monthly Inspection Dataform forremarks in which
recommendations can be made or observations of concern can be documented.
fl Summary of Daily, Weekly and Quarterly Inspections
The monthly inspection will also summaize the daily, weekly and, if applicable,
quarterly tailings inspections for the specific month.
In addition, settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5. QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department, having the training specified in Section 2.4 above, once per
calendar quarter. A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection, an Operations/Maintenance
Review, a Construction Review and a Summary, as follows:
a) Embankment Inspection
The Embankment inspection involves a visual inspection of the crest, slope and toe
of each dike for movement, seepage, severe erosion, subsidence, shrinkage cracks,
and exposed liner.
bI Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c) Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
White Mesa Mill - Standard Operating Procedures
Book ll: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 13 of 36
d)Summary
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted, the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data f orm. An example of the Quarterly Inspection Data
form is provided in Appendix A.
6. ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1. Annual Technical Evaluatron
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE), who has experience and training in the area of geotechnical aspects of
retention structures. The technical evaluation includes an on-site inspection of the tarlings
management system and a thorough review of all tailings records for the past year. The Technical
Evaluation also includes a review and summary of the annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion, subsrdence,
shrinkage, and seepage. The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3) were performed for the receipt of
alternate feed material during the year, the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate. The
amount of tailings added to the system since the last evaluatron will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist of daily, weekly, monthly, and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached. Records will also be reviewed to summarize observations of potential concern. The
evaluation also involves discussion with the Environmental and./or Radiation Technicran and the
Radiation Safety Officer regarding activrties around the taihngs area for the past year. Dunng the
annual rnspection, photographs of the tailings area will be taken. The training of individuals will be
reviewed as a part of the Annual Technical Evaluation.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page 14 of36
The registered engineer will obtain copies of selected tailings inspections, along with the monthly
and quafierly summaries of observations of concern and the corrective actions taken. These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September I't of every year to:
Directing Dam Safety Engineer
State of Utah, Natural Resources
1636 West North Temple, Suite 220
salt Lake city, utah 84116-3156
6.2. Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter of each year. The movement monitor survey consists of surveying monitors along dikes 3-S,
4A-W, and 4A-S to detect any possible settlement or movement of the dikes. The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3. Freeboard Limits
a) Tailings Cells I and 4A
The freeboard limits are as per January 10, 1990 Drainage Report for Cells l
and 4A and are stated below:
(i) A liquid maximum elevation of 5,615.4 feet mean sea level in Cell 1.
(ii) A liquid maximum elevation of 5,596.4 feet mean sea level in Cell 4A,.
b) Tailings Cell3
The freeboard limit for Cell 3 is determined annually using the following
procedure:
(i) From a survey of Cell 3, the pool surface will be determined.
An estimate of the maximum tons of dry tailings to be generated during
the next l2 months will be made. This estimate is multiplied by 1.5, a
factor of safety, to yield the Maximum Mill Production.
The Maximum Mill Production is divided by the number of tons required
(ii )
(iii)
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision; Denison-6
Page 15 of36
to reduce the pool size by one acre and then subtracted from the pool
surface (determined in Step i), yielding the Reduced Pool Area.
(iv) The PMP Flood Volume Requirement, as per the January 10, 1990
Drainage Report, is 123.4 acre feet. The PMP Flood Volume
Requirement is divided by the Reduced Pool Area to determine the PMP
Freeboard Level.
(v) The Wave Run Up of 0.78 feet (as specified in the January 10, 1990
Drainage Report) is added to the PMP Freeboard Level to determine the
Total Required Freeboard.
The calculation of the Total Required Freeboard for Cell 3 will be calculated
annually and the calculation sheet filed in the Mill Central File.
c) Tailings Cell4A
The freeboard limit for Cell 44, is determined annually using the following
procedure:
The Cell 44. design includes a concrete spillway between Cell 3 and Cell 4,{,
with the inveft elevation 4 feet below the top of the Cell 3 dike, at an elevation
of 5604.5 feet amsl. Should Cell 3 receive the full PMP volume of L23.4 acre
feet of water, approximately 62 acre feet of that volume would flow through
the spillway into Cell 4A.
The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of
water (40 acres, plus the adjacent drainage area of 3.25 acres, times the PMP of
10 inches). This would result in a total flood volume of 98 acre-feet, including
the 62 acre-feet of solution from Cell 3. The freeboard depth required for Cell
4,{ from the PMP event would be2.44 feet, plus a wave run-up depth of 0.77 feet
(from the 1990 Drainage Report), for a total freeboard requirement of 3.2 feet.
This calculation is illustrated on Attachment 4. The Groundwater Quality
Discharge Permit, No. UGW310004, for the White Mesa Mill requires that the
minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2
. feet below the top of Iiner. The freeboard for Cell 4A would therefore be 5595.3
amsl (top of liner 5-598.5 - 3.2 feet).
The calculation of the Total Required Freeboard for Cell 4A, will be calculated
annually and the calculation sheet filed in the Mill Central File.
White Mesa Mill - Standard Operating Procedures
Book I 1: Environmental Protection Manual, Section 3.I
9/08 Revision: Denison-6
Page l6 of 36
d) Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of 5,624.0
feet above mean sea level, as specified in the GWDP.
6.4. Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system, a sample will be collected on an
annual basis. This sample will be analyzed according to the conditions set forth in License
Condition 11.3.C. The results of the analysis will be reviewed to determine the origin of the
solution.
7. OTHER INSPECTIONS
All daily, weekly, monthly, quarterly and annual inspections and evaluations should be performed as
specified in Sections 2, 3, 4,5 and 6 above. However, additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8. REPORTING REQUIREMENTS
In addition to the Daily Inspection Data,Weekly Tailings Inspection, Monthly Inspection Data and
Quarterly Inspection Dataforms included as Appendix A and described in Sections 2,3,4 and 5
respectively, and the Operating Foreman's Daily Inspection and Weekly Mill lnspection forms
described in Sections 2 and 3, respectively, the following additional reports shall also be prepared:
8.1. Monthly Tailines Reports
Monthly tailings reports are prepared every month and summaize the previous month's activities
around the tailings area. If not prepared by the Radiation Safety Officer, the report shall be
submitted to the Radiation Safety Officer for review. The Mill Manager will review the report as
well before the report is filed in the Mill Central File. The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections. Corrective measures
taken during the month will be documented along with the observations where appropriate. All daily
and weekly tailings inspection forms will be attached to the report. A monthly inspection form will
also be attached. Quarterly inspection forms will accompany the report when applicable. The repoft
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 17 of36
8.2. DMT Reports
Quarterly reports of DMT monitoring activities of all required information required by Part 1.F.2 of
the GWDP relating to the inspections described in Section 3.1(b) (Slimes Drain Water Level
Monitoring), 3.1(d) (Tailings Wastewater Pool Elevation Monitoring), 3.2 (Weekly Inspection of
Solution Lcvels in Roberts Pond) and 3.3 (Weekly Feedstock Storage Area Inspections) will be
provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP. An annual
summary and graph for each calendar year of the depth to wastewater in the Cetl2 slimes drain must
be included in the fourth quarter report. After the first year, and beginning in 2008, quarterly reports
shall include both the current year monthly values and a graphic comparison to the previous year.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page l8 of 36
APPENDIX A
FORMS
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White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page23 of 36
l. Pond elevations (msl,ft)
2. Slimes Drain Liquid Levels Cell2
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Inspectors:
Cell l: (a) Pond Solution Elevation
(b) FML Bottom Elevation
(c) Depth of Water above FML ((a)-(b))
Cell 3: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
Cell 44': (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML ((a)-(b))
5597
5570
5564
_5612.34-
Pump functioning properly
Pumo Timer set at l5min on 45 min off
_Depth to Liquid pre-pump
Denth to Liouid Post-oumo
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38' -Depth to Liquid Post-
DUmD =
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
3. Leak Detection Systems
4. Tailings Area Inspection (Note dispersal of blowing tailings):
9/08 Revision: Denison-6
PageZ4 of 36
Observation:
Cell I Cell2 Cell3 Cell4.A
Is LDS wet or dry?wet drv
-wet-dry
_wet dry
-wet-dry
If wet, Record
liquid level:
Ft to
Liquid
Ft to
Liouid
Ft to
Liouid
Ft to
Liquid *
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume
Flow Rate-
Volume
Flow Rate_
Volume
Flow Rate_
Volume
Flow Rate_
Was fluid sample
collected?
ves no ves no ves no ves no
5. Control Methods Implemented:
6. Remarks:
7. Contaminated Waste Dump:
'i'Doesl-evel exceed l2inchcsabovetholorvestpointonthebottomfleriblerlernbranelincr(elevatiorr
5.5-5$. 1 -1 amsl)'l , _.. _. * ,,- no =_* yes
lf L-clt4A Ieak detection svstcnr lcr'*l ercceds l2 inches ittrove thc lou,est point on thc botlorrr f lcxihlc
nremhraue liner (elevltion 55.i(r. l.l amsl), notify supelvisol or Mill rrtanager irnmecliatclv.
White Mesa Mill - Standard Operating Procedures
Book 1l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 25 of 36
APPENDIX A (CONT.)
MONTHLY INSPECTION DATA
Inspector:
Date:
l. Slurry Pipeline:
Pipe Thickness:_(To be measured only during periods when the Mill is operating)
2. Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditches:
Diversion Ditch I
ves no
ves no
VCS NO
ves no
Diversion Ditch 2
ves no
ves no
ves no
_yes_no
Diversion Ditch 3
ves no
ves no
ves no
ves no
Diversion Berm 2
ves no
ves no
Sloughing
Erosion
Undesirable
Vegetation
Obstruction of Flow
Diversion Berm:
Stability Issues
Signs of Distress
Comments:
3. Summary of Activities Around Sedimentation Pond:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3
4. Overspray Dust Minimization:
Overspray system functioning properly:
Overspray carried more than 50 feet from the cell:
If "yes", was system immediately shut off?
9/08 Revision: Denison-6
Page26 of 36
ves no
ves no
ves no
Comments:
5. Remarks:
6. Settlement Monitors
Cell
Cell
Cell
Cell
Cell
Cell
Cell
Cell
Cell
2 Wt:
2W2:
2 W3:
2W4:
2W7-C:
2 W7N:
2W6C:
4A-Toe:
3-2C:
Cell2W3-S:
Cell2El-N:
Cell2El-lS:
Cell2El-2S:
Cell2 East:
Cell2 W7S:
Cell2 W6S:
Cell2 W4S:
Cell3-2S:
Cell3-lN:
Cell3-1C:
Cell3-lS:
Cell3-2N:
Cell2W5-N:
Cell2 W6N:
Cell2 W4N:
Cell2 W5C:
7. Summary of Daily, Weekly and Quarterly Inspections:
8. Monthly Slimes Drain Static Head Measurement for Cell2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual. Section 3.1
9/08 Revision: Denison-6
Page27 of36
APPENDIX A (CONT.)
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:
Date:
1. Embankment Inspection:
2. Operations/Maintenance Reyiew:
3. Construction Activites:
4. Summary:
White Mesa Mill - Standard Operating Procedures
Book l l : Environmental Protection Manual. Section 3. 1
Week of
-
through Date of Inspection:
Inspector:_
Weather conditions for the week:
9/08 Revision: Denison-6
Page 28 of 36
APPENDTX A (CONT.)
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
ves: no:
comments:
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
ves: no:
Conditions of storage areas for materials:
Other comments
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page29 of 36
APPENDIX B
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections. Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department. Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan. The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections. Tailings
inspection forms will be included in the monthly tailings inspection reports, which summarize the
conditions, activities, and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory, requiring no
action) or that conditions of potential concern exist (requiring action). A "check" mark indicates no
action required. If conditions of potential concern exist the inspector should mark an "X" in the area
the condition pertains to, note the condition, and specify the corrective action to be taken. If an
observable concern is made, it should be noted on the tailings report until the corrective action is
taken and the concern is remedied. The dates of all corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify Corporate
Management. If dam failure occurs, notify your supervisor and the Mill Manager immediately. The
Mill Manager will then notify Corporate'Management, MSHA (303-231-5465), and the State of
Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the darly tailings
inspection form. The inspection form consists of three pages and is summarized as follows:
1. Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline joints
are to be monitored for leaks, and loose connections. The pipeline supports are to be
White Mesa Mill - Standard Operating Procedures
Bclok I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 30 of 36
inspected for damage and loss of support. Valves are also to be inspected particularly for
leaks, blocked valves, and closed valves. Points of discharge need to be inspected for
improper location and orientation.
2. Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks, severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items of concern for ponds and
covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 4,{ solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented. In Cells I and 3, the
PVC liner needs to be monitored closely for exposed liner, especially after storm events. It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner. Small areas of exposed liner should be covered by hand. Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these conditions
have been noted to the Radiation Safety Officer, a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department. All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
Dikes and Embankments:
Inspection items include the slopes and the crestvof each dike. For slopes, areas of concern
are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas, and areas of
seepage outbreak. For crests, areas of concern are cracks, subsidence, and severe erosion.
When any of these conditions are noted, an "X" mark should be placed in the section marked
for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely for
mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
burrow in deep, possibly to the liner. If any of these conditions exist, the inspectron report
should be marked accordingly.
Flow Rates:
3.
4.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 3l of36
Presence of all flows in and out of the cells should be noted. Flow rates are to be estimated
in gallons per minute (GPM). Rates need to be determined for slurry lines, pond return, SX-
tails, and the spray system. During non-operational modes, the flow rate column should be
marked as "0". The same holds true when the spray system is not utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill. If possible, the inspection should include observation of the entire discharge line and
discharge spill point into the cell. If "fill to elevation" flags are in place, the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 44. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should be
documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or ice
should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section. Corrective
action should follow each area of concern noted. All work orders issued, contacts, or
notifications made should be noted in this section as well. It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the following
items where applicable.
l.
2.
3.
4.
Cover area
Beach/tailing sands area
Solution as it exists
Pump lines
5.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 32 of 36
5.
6.
7.
Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
Slurry discharge when operaLing
Over spray system when operating
Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These rules
meet the required MSHA regulations for the tailings area. Please pay particular notice to the
following rules:
1. The posted speed limit for the tailings area is l5 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in the
area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles must
be worn at all times. There must also be an approved safety watch with a two-way hand-
held radio on shore. A portable eyewash must be present on site as well.
Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area. All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift. Waterfowl seen near the tailings cells should be discouraged from landing
by the use of noisemakers.
Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authonzes certification. Refer to the Certification
Form, Appendix C. This form should be signed and dated only after a thorough review of the
tailings information previously presented. The form will then be signed by the Radiation
Safety Officer and filed.
9.
10.
11.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 33 of 36
APPENDIX C
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 34 of 36
APPENDX D
FEEDSTOCK STORAGE AREA
Senison Minss ( USlg Corp.f'"jY wHlrg luEsn rrrlr-r-
Feedslock Storage Area Map
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. q4lLt dsPEcrrolt REPORTTATUII{GS SLURRY DISCHAR6' IOiNTIOH
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I
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 35 of 36
APPENDIX E
TABLES
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.1
9/08 Revision: Denison-6
Page 36 of 36
Table I
Calculated Action leakage Rates
for Various head Conditions
Cell4A White mesa Mill
Blanding, Utah
Head above Liner System (feet)Calculated Action leakage Rate
( sallons I acre / dav )
5 222.04
t0 3r4.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
31 604.01
09/08 Revision Denison 1.3
Cell 4A BAT Monitoring, Operations and Maintenance Plan.
Introduction
Construction of Cell 4,{ was authorized by the Utah Department of Environmental
Quality, Division of Radiation Control ("DRC) on June 25,2007 . The construction
authorization provided that Cell 4A shall not be in operation until after a BAT
Monitoring, Operations and Maintenance Plan is submitted for Executive Secretary
review and approval. The Plan shall include requirements in Part F.3 of the Groundwater
Discharge Permit No. UGW370O04 ("GWDP") and full fill the requirements of Parts
LD.6, I.E.8, and LF.8 of the GWDP.
Cell Design
Tailings Cell 4A consists of the following major elements:
a) Dikes - consisting of earthen embankments of compacted soil, constructed
between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these
dikes have slopes of 3H to lV. The west dike has a interior slope of 2H to
1V. Width of these dikes varies; each has a minimum crest width of at least
15 feet to support an access road. Base width also varies from S9-feet on the
east dike (with no exterior embankment), to 2ll-feet at the west dike.
b) Foundation - including subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils,
compaction of imported soils to a maximum dry density of 907o. Floor of
Cell 4,{ has an average slope of l7o that grades from the northeast to the
southwest corners.
c) Tailings Capacity - the floor and inside slopes of Cell 44. encompass about 40
acres and have a maximum capacity of about 1.6 million cubic yards of
tailings material storage (as measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems - including the following layers, in
descending order:
l) Primary Flexible Membrane Liner (FML) - consisting of impermeable 60
mil high density polyethylene (HDPE) membrane that extends across both
the entire cell floor and the inside side-slopes, and is anchored in a trench
at the top of the dikes on all four sides. The primary FML will be in direct
physical contact with the tailings material over most of the Cell 4,{ floor
area. In other locations, the primary FML will be in contact with the
slimes drain collection system (discussed below).
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
Leak Detection System - includes a permeable HDPE geonet fabric that
extends across the entire area under the primary FML in Cell 4,{, and
drains to a leak detection sump in the southwest corner. Access to the leak
detection sump is via an 18-inch inside diameter (ID) PVC pipe placed
down the inside slope, located between the primary and secondary FML
liners. At its base this pipe will be surrounded with a gravel filter set in
the leak detection sump, having dimensions of 10 feet by 10 feet by 2 feet
deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to
serve as a filter.
Secondary FML - consisting of an impermeable 60-mil HDPE membrane
found immediately below the leak detection geonet. Said FML also
extends across the entire Cell 4,A. floor, up the inside side-slopes and is
also anchored in a trench at the top of all four dikes.
Geosynthetic Clay Liner - consisting of a manufactured geosynthetic clay
liner (GCL) composed of 0.2-inch of low permeability bentonite clay
centered and stitched between two layers of geotextile. Prior to disposal
of any wastewater in Cell 4,{, the Permittee shall demonstrate that the
GCL has achieved a moisture content of at least 50Vo by weight. This
item is a revised requirement per DRC letter to DUSA dated September
28,2007
e) Slimes Drain Collection System - including a two-part system of strip drains
and perforated collection pipes both installed immediately above the primary
FML, as follows:
1) Horizontal Strip Drain System - is installed in a herringbone pattern
across the floor of Cell 4A that drain to a "backbone" of perforated
collection pipes. These strip drains are made of a prefabricated two-part
geo-composite drain material (solid polymer drainage strip) core
surrounded by an envelope of non-woven geotextile filter fabric. The strip
drains are placed immediately over the primary FML on 5O-foot centers,
where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection
pipe. A series of continuous sand bags, filled with filter sand cover the
strip drains. The sand bags are composed of a woven polyester fabric
filled with well graded filter sand to protect the drainage system from
plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone"
piping system of 4-inch ID Schedule 40 perforated PVC slimes drain
collection (SDC) pipe found at the downgradient end of the strip drain
lines. This pipe is in turn overlain by a berm of gravel that runs the entire
diagonal length of the cell, surrounded by a geotextile fabric cushion in
immediate contact wrth the primary FML. In tum, the gravel is overlain
2)
3)
4)
Page 2
Cell 4,A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison L3
by a layer of non-woven geotextile to serve as an additional filter material.
This perforated collection pipe serves as the "backbone" to the slimes
drain system and runs from the far northeast corner downhill to the far
southwest corner of Cell 4A. where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe - consisting of an 18-inch ID Schedule 40 PVC
pipe placed down the inside slope of Cell 4,A at the southwest corner,
above the primary FML. Said pipe then merges with another horizontal
pipe of equivalent diameter and material, where it is enveloped by gravel
and woven geotextile that serves as a cushion to protect the primary FML.
A reducer connects the horizontal l8-inch pipe with the 4-inch SDC pipe.
At some future time, a pump will be set in this lS-inch pipe and used to
remove tailings wastewaters for purposes of de-watering the tailings cell.
Dike Splash Pads - A minimum of eight (8) l0-foot wide splash pads are
installed on the interior dike slopes to protect the primary FML from abrasion
and scouring by tailings slurry. These pads will consist of an extra layer of 60
mil HDPE membrane that will be placed down the inside slope of Cell 4A,
from the top of the dike and down the inside slope. The pads on the north side
of the Cell will extend to a point 5-feet beyond the toe of the slope to protect
the liner bottom during initial startup of the Cell. The exact location of the
splash pads is detailed on the As-Built Plans and Specifications.
Emergency Spillway - a concrete lined spillway constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 44.
This spillway will be limited to a 6-inch reinforced concrete slab set directly
over the primary FML in a 4-foot deep trapezoidal channel. No other spillway
or overflow structure will be constructed at Cell 4,A.. All stormwater runoff
and tailings wastewaters not retained in Cells 2 and 3, will be managed and
contained in Cell 4A, including the Probable Maximum Precipitation and
flood event.
CellOperation
Solution Discharge
Cell 44, will initially be used for storage and evaporation of process solutions
from the Mill operations. These process solutions will be from the
uranium/vanadium solvent extraction circuit, or transferred from Cell 1
evaporation pond or the free water surface from Cell 3. The solution will be
pumped to Cell 44' through 6 inch or 8 inch diameter HDPE pipelines. The initial
solution discharge will be in the southwest corner of the Cell. The discharge pipe
will be routed down the Splash Pad provided in the corner of the Cell to protect
the pipeline running from the solution reclaim barge. The solution will be
discharged in the bottom of the Cell, away from any sand bags or other
installation on the top of the FML. Building the solution pool from the low end of
s)
Page 3
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
the Cell will allow the solution pool to gradually rise around the slimes drain
strips, eliminating any damage to the strip drains or the sand bag cover due to
solution flowing past the drainage strips. The solution will eventually be
discharged along the dike between Cell 3 and Cell 4,A., utilizing the Splash Pads
described above. The subsequent discharge of process solutions will be near the
floor of the pond, through a discharge header designed to discharge through
multiple points, thereby reducing the potential to damage the Splash Pads or the
Slimes Drain system. At no time will the solution be discharged into less than 2
feet of solution. As the cell begin to fill with solution the discharge point will be
pull back up the Splash Pad and allowed to continue discharging at or near the
solutron level.
Initial Solids Discharge
Once Cell 4A is needed for storage for tailings solids the slurry discharge from
No. 8 CCD thickener will be pumped to the cell through 6 inch or 8 inch diameter
HDPE pipelines. The pipelines will be routed along the dike between Cell 3 and
Cell 4A, with discharge valves and drop pipes extending down the Splash Pads to
the solution level. One or all of the discharge points can be used depending on
operational considerations. Solids will settle into a cone, or mound, of material
under the solution level, with the courser fraction settling out closer to the
discharge point. The initial discharge locations are shown on Figure 1. Figure 2
illustrates the general location of the solution and slurry discharge pipelines and
control valve locations. The valves ate 6" or 8" stainless steel knife-gate valves.
The initial discharge of slurry will be at or near the toe of the Cell slope and then
gradually moved up the slope, continuing to discharge at or near the water
surface. This is illustrated in Section A-A on Frgure 2. Because of the depth of
Cell 4A, each of the discharge points will be utilized for an extended period of
time before the cone of material is above the maximum level of the solution. The
discharge location will then moved further to the interior of the cell allowing for
additional volume of solids to be placed under the solution level. The solution
level in the cell will vary depending on the operating schedule of the Mill and the
seasonal evaporation rates. The tailings slurry will not be allowed to discharge
directly on to the Splash Pads, in order to further protect the FML. The tailings
slurry will discharge directly in to the solution contained in the Cell, onto an
additional protective sheet, or on to previously deposited tailings sand.
Equipment Access
Access will be restricted to the interior portion of the cell due to the potential to
damage the flexible membrane liner. Only rubber tired all terrain vehicles or foot
trafflc will be allowed on the flexible membrane liner. Personnel are also
cautioned on the potential damage to the flexible membrane liner through the use
and handling of hand tools and maintenance materials.
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
Reclaim Water System
A pump barge and solution recovery system will be installed in the southwest
corner of the cell to pump solution from the cell for water balance purposes or for
re-use in the Mill process. Figure 3 illustrates the routing of the solution return
pipeline and the Iocation of the pump barge. The pump barge will be constructed
and maintained to ensure that the flexible membrane liner is not damaged during
the initial filling of the cell or subsequent operation and maintenance activities.
The condition of the pump barge and access walkway will be noted during the
weekly Cell inspections.
Interim Solids Discharse
Figure 4 illustrates the progression of the slurry discharge points around the east
side of Cell 4,A.. Once the tailings solids have been deposited along the north and
east sides of the Cell, the discharges points will subsequently be moved to the
sand beaches, which will eliminate any potential for damage to the liner system.
Liner Maintenance and QA/OC
Any construction defects or operational damage discovered during observation of
the flexible membrane liner will be repaired, tested and documented according to
the procedures detailed in the approved Revised construction Quality
Assurance PIan for the Construction of the Cell 4A Lining System, May
2007, by GeoSyntec Consultants.
BAT Performance Standards for Tailinss Cell4A
DUSA will operate and maintain Tailings Cell 4,{ so as to prevent release of wastewater
to groundwater and the environment in accordance with this BAT Monitoring Operations
and Maintenance Plan, pursuant to Part LH.19 of the GWDP. These performance
standards shall include:
l) Leak Detection System Pumping and Monitoring Equipment - the
leak detection system pumping and monitoring equipment, includes a
submersible pump, pump controller, water level indicator (head
monitoring), and flow meter with volume totalizer. The pump controller
is set to maintain the maximum level in the leak detection system at no
more than I foot above the lowest level of the secondary flexible
menbrane. A second leak detection pump with pressure transducer, flow
meter, and manufacturer recommended spare parls for the pump controller
and water level data collector is maintained in the Mill warehouse to
ensure that the pump and controller can be replaced and operational within
24 hours of detection of a failure of the pumping system. The root cause
Page 5
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
of the equipment failure will be documented in a report to Mill
management with recommendations for prevention of a re-occurrence.
Maximum Allowable Head - the Permittee shall measure the fluid head
above the lowest point on the secondary flexible membrane by the use of
procedures and equipment specified in the White Mesa Mill Tailings
Management System and Discharge Minimization Technology
(DMT) monitoring Plan,3/07 Revision: Denison-3, or the currently
approved DMT Plan. Under no circumstance shall fluid head in the leak
detection system sump exceed a 1-foot level above the lowest point in
the lower flexible membrane liner.
Maximum Allowable Daily LDS Flow Rates - the Permittee shall
measure the volume of all fluids pumped from the LDS on a weekly
basis, and use that information to calculate an average volume pumped
per day. Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day. The maximum daily LDS flow volume will
be compared against the measured cell solution levels detailed on the
attached Table I to determine the maximum daily allowable LDS flow
volume for varying head conditions in the cell. .
3-foot Minimum Vertical Freeboard Criteria - the Permittee shall
operate and maintain wastewater levels to provide a 3-foot Minimum of
vertical freeboard in Tailings Cell4A. Said measurements shall be
made to the nearest 0.1 foot.
Slimes Drain Recovery Head Monitoring - immediately after the
Permittee initiates pumping conditions in the Tailings Cell 4,{ slimes
drain system, monthly recovery head tests and fluid level measurements
will be made in accordance with a plan approved by the DRC Executive
Secretary. The slimes drain system will pumping and monitoring
equipment, includes a submersible pump, pump controller, water level
indicator (head monitoring), and flow meter with volume totalizer.
Routine Maintenance and Monitoring
Trained personnel inspect the White Mesa tailings system on a once per day basis. Any
abnormal occurrences or changes in the system will be immediately reported to Mill
management and maintenance personnel. The inspectors are trained to look for events
involving the routine placement of tailings material as well as events that could affect the
integrity of the tailings cell dikes or lining systems. The daily inspection repofts are
summarized on a monthly basis and reviewed and signed by the Mill Manager.
Solution Elevation
2)
3)
4)
s)
Page 6
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
Measurements in Cell 44' are to be taken by survey on a weekly basis as follows:
(i) The survey will be performed by the Mill's Radiation Safety Officer or
designee (the "Surveyor") with the assistance of another Mill worker (the
"Assistant"),
(ii) The survey will be performed using a survey instrument (the "Survey
Instrument") accurate to 0.01 feet, such as a Sokkai No. 82l, or
equivalent, together with a survey rod (the "Survey Rod") having a visible
scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points") for Cells 4A are known
points established by Registered Land Surveyor. For Cell 4A, the
Reference Point is a piece of metal rebar located on the dike between Cell
3 and Cell 4A. The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell4,A is at 5,607.83 feet above mean sea
level ("amsl");
(iv) The Surveyor will set up the Survey Instrument in a location where both
the applicable Reference Point and pond surface are visible. For Cell 4A.,
this is typically on the road between Cell 3 and Cell4A, approximately 100
feet east of the Cell 44. Reference Point;
(v) Once in location, the Surveyor will ensure that the Survey Instrument is
level by centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Cell 44,
Reference Point. The Assistant will ensure that the Survey Rod is vertical
by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii)The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Reference Point
Reading"), which represents the number of feet the Survey Instrument is
reading above the Reference Point;
The Assistant will then move to a designated location where the Survey
Rod can be placed on the surface of the main solution pond in Cell 4,\.
The designated location for Cell 4,A. is in the northeast corner of the Cell
where the side slope allows for safe access to the solution surface.
The approximate coordinate locations for the measuring points for Cell 44.
is 2,579,360 east, and 320,300 north. These coordinate locations may vary
somewhat depending on solution elevations in the Cell.
The Assistant will hold the Survey Rod vertically with one end of the
Survey Rod just touching the pond surface. The Assistant will ensure that
the Survey Rod is vertical by gently rocking the rod back and forth until
the Surveyor has established a level reading;
(viii) The Surveyor will focus the cross hairs of the Survey Instrument on the
scale on the Survey Rod, and record the number (the "Pond Surface
PageT
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
Reading"), which represents the number of feet the Survey Instrument is
reading above the pond surface level.
The Surveyor will calculate the elevation of the pond surface in feet amsl
by adding the Reference Point Reading for the Cell and subtracting the
Pond Surface Reading for the Cell, and will record the number accurate to
0.01 feet.
Leak Detection System
The Leak detection system is monitored on a continuous basis by use of a
pressure transducer that feeds water level information to an electronic data
collector. The water levels are measured every hour and the information
is stored for later retrieval. The water levels are measured to the nearest
0.10 inch. The data collector is currently programmed to store 7 days of
water level information. The number of days of stored data can be
increased beyond 7 days if needed. The water level data is downloaded to
a laptop computer on a weekly basis and incorporated into the Mill's
environmental monitoring data base, and into the files for weekly
inspection reports of the tailings cell leak detection systems. Within 24
hours after collection of the weekly water level data, the information will
be evaluated to ensure that: l) the water level in the leak detection sump
did not exceed the allowable level (5556.14 feet amsl), and 2) the average
daily flow rate from the LDS did not exceed the maximum daily allowable
flow rate at any time during the reporting period. For Cell 4A, under no
circumstance shall fluid head in the leak detection system sump exceed a
l-foot level above the lowest point in the lower flexible membrane liner.
To determine the Maximum Allowable Daily LDS Flow Rates in the Cell
4,A. leak detection system, the total volume of all fluids pumped from the
LDS on a weekly basis shall be recovered from the data collector, and that
information will be used to calculate an average volume pumped per day.
Under no circumstances shall the daily LDS flow volume exceed 24,160
gallons/day. The maximum daily LDS flow volume will be compared
against the measured cell solution levels detailed on the attached Table 1,
to determine the maximum daily allowable LDS flow volume for varying
head conditions in Cell 4A. Any abnormal or out of compliance water
levels must be immediately reported to Mill management. The data
collector is also equipped with an audible alarm that sounds if the water
level in the leak detection sump exceeds the allowable level (5556.14 feet
amsl). The current water level is displayed at all times on the data
collector and available for recording on the daily inspection form. The
leak detection system is also equipped with a leak detection pump, EPS
Model # 25505-3 stainless steel, or equal. The pump is capable of
pumping in excess of 25 gallons per minute at a total dynamic head of 50
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
feet. The pump has a l 5 inch diameter discharge, and operates on 460
volt 3 phase power. The pump is equipped with a pressure sensing
transducer to start the pump once the level of solution in the leak detection
sump rs approximately 2.25 feet (elevation 5555.89) above the lowest
level of the leak detection sump (9 inches above the lowest point on the
lower flexible membrane hner, to ensure the allowable 1.0 foot (5556.14
feet amsl) above the lowest point on the lower flexible membrane liner is
not exceeded). The attached Figure 6, Leak Detection Sump Operating
Elevations, illustrates the relationship between the sump elevation, the
lowest point on the lower flexible membrane liner and the pump-on
solution elevation for the leak detection pump. The pump also has manual
start and stop controls. The pump will operate until the solution is drawn
down to the lowest level possible, expected to be approximately 4 inches
above the lowest level of the sump (approximate elevation 5554.0). The
pump discharge is equipped with a 1.5 inch flow meter, EPS Paddle
Wheel Flowsensor, or equal, that reads the pump discharge in gallons per
minute, and records total gallons pumped. The flow rate and total gallons
is recorded by the Inspector on the weekly inspection form. The leak
detection pump is installed in the horizontal section of the 18 inch,
horizontal, perforated section of the PVC collection pipe. The distance
from the top flange face, at the collection pipe invert, to the centerline of
the 22.5 degree elbow is 133.4 feet, and the vertical height is
approximately 45 feet. The pump is installed at least 2 feel beyond the
centerline of the elbow. The bottom of the pump will be installed in the
leak detection sump at least 135.4 feet or more from the top of the flange
invert. A pressure transducer installed with the pump continuously
measures the solution head and is programmed to start and stop the pump
within the ranges specified above. The attached Figure 5 illustrates the
general configuration of the pump installation.
A second leak detection pump with pressure transducer, flow meter, and
manufacturer recommended spare parts for the pump controller and water
level data collector will be maintained in the Mill warehouse to ensure that
the pump and controller can be replaced and operational within 24 hours
of detection of a failure of the pumping system. The root cause of the
equipment failure will be documented in a report to Mill management with
recommendations for prevention of a re-occuffence.
Slimes Drain Slystem
(i) A pump, Tsurumi Model # KTZ23.7-62 stainless steel, or equal, will be
placed inside of the slimes drain access riser pipe and a near as possible to
the bottom of the sHmes drain sump. The bottom of the slimes drain sump
is 38 feet below a water level measuring point at the centerline of the
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Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
slimes drain access pipe, near the ground surface level. The pump
discharge will be equipped with a 2 inch flow meter,ElH Model #33, or
equal, that reads the pump discharge in gallons per minute, and records
total gallons pumped. The flow rate and total gallons will be recorded by
the Inspector on the weekly inspection form.
(ii) The slimes drain pump will be on adjustable probes that allows the pump
to be set to start and stop on intervals determined by Mill management.
(iii)The Cell 44. slimes drain pump will be checked weekly to observe that it
is operating and that the level probes are set properly, which is noted on
the Weekly Tailings Inspection Form. If at any time the pump is observed
to be not working properly, it will be repaired or replaced within 15 days;
(iv)Depth to wastewater in the Cell 4A slimes drain access riser pipe shall be
monitored and recorded weekly to determine maximum and minimum
fluid head before and after a pumping cycle, respectively. All head
measurements must be made from the same measuring point, to the
nearest 0.01 foot. The results will be recorded as depth-in-pipe
measurements on the Weekly Tailings Inspection Form;
(v) On a monthly basis, the slimes drain pump will be turned off and the
wastewater in the slimes drain access pipe will be allowed to stabilize for
at least 90 hours. Once the water level has stabilized (based on no change
in water level for three (3) successive readings taken no less than one (1)
hour apart) the water level of the wastewater will be measured and
recorded as a depth-in-pipe measurement on the Monthly Inspection Data
form, by measuring the depth to water below the water level measuring
point on the slimes drain access pipe;
The slimes drain pump will not be operated until Mill management has
determined that no additional process solutions will be discharged to Cell 4A, and
the Cell has been partially covered with the first phase of the reclamation cap.
The long term effectiveness and performance of the slimes drain dewatering will
be evaluated on the same basis as the currently operating slimes drain system for
Cell2.
Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately
if, during their inspection, they discover that an abnormal condition exists or an event has
occured that could cause a tailings emergency. Until relieved by the Environmental or
Radiation Technician or Radiation Safety Officer, inspectors will have the authority to
direct resources during tailings emergencies.
Any major catastrophic events or conditions pertaining to the tailings area should be
reported immediately to the Mill Manager or the Radiation Safety Officer, one of whom
Page l0
Cell 4,A. BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
will notify Corporate Management. If dam failure occurs, notify your supervisor and the
Mill Manager immediately. The Mill Manager will then notify Corporate Management,
MSHA (303-231-5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Cell 4A Solution Freeboard Calculation
The maximum tailings cell pond wastewater levels in Cells 1-I, Cell 2, Cell3 and Cell 4,A
are regulated by condition 10.3 of the White Mesa Mill 1le.(z) Materials License.
Condition 10.3 states that "Freeboard limits for Cells 1-1, and 3, shall be set
periodically in accordance with the procedures set out in Section 3.0 to Appendix E
of the previously approved NRC license application, including the October 13, 1999
revisions made to the January 10, 1990 Drainage Report. The freeboard limit for
Cell 3 shall be recalculated annually in accordance with the procedures set in the
October l3r 1999 revision to the Drainage Report." The 1990 Drainage Report uses
the Local 6-hour Probable Maximum Precipitation (PMP) event for calculating the
freeboard requirements for each of the tailings cells. The PMP for the White Mesa site is
l0 inches.
Based on the PMP storm event, the freeboard requirement for Cell I is a maximum
operating water level of 5615.4 feet above mean sea level (amsl). The Cell I freeboard
limit is not affected by operations or conditions in Cells 2,3 or 44.
Cell 2 has no freeboard limit because the Cell is 997o full of tailings solids and all
precipitation falling on Cell 2 and the adjacent drainage area must be contained in Cell 3.
The flood volume from the PMP event over the Cell2 and Cell 3 pond areas, plus the
adjacent drainage areas, is 123.4 acre-feet of water. According to the freeboard
calculation procedures, this volume currently must be contained in the existing 24-acre
pool area in Cell 3. This results in a maximum operating water level in Cell 3 of 5601.6
feet amsl.
The Cell 44 design includes a concrete spillway between Cell 3 and Cell 4A with the
invert elevation 4 feet below the top of the Cell 3 dike, at an elevation of 5604.5 feet
amsl. Once Cell 44, is placed in operation, the cell would be available for emergency
overflows from Cell 3, but as long as the freeboard limit in Cell 3 is maintained at 5601.6
it is extremely unlikely that Cell 44. would see any overflow water from Cell 3 unless the
full PMP event were to occur. Should Cell 3 receive the full PMP volume of 123.4 acre
feet of water, approximately 62 acre feet of that volume would flow through the spillway
rnto Cell 4A'.
The flood volume from the PMP event over the Cell 4,A. area is 36 acre-feet of water (40
acres, plus the adjacent drainage area of 3.25 acres, times the PMP of l0 inches). This
would result in a total flood volume of 98 acre-feet, including the 62 acre-feet of solution
from Cell 3. The freeboard depth required for Cell 4A from the PMP event would be
2.44 feet, plus a wave run-up depth of 0.71 feet (from the 1990 Drainage Report), for a
Page ll
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
total freeboard requirement of 3.2 feet. This calculation is illustrated on Attachment 4.
The Groundwater Quality Discharge Permit, No. UGW310004, for the White Mesa Mill
requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell
construction, but based on the above calculation the freeboard would be set 3.2feet
below the top of liner. The freeboard for Cell44. would therefore be 5595.3 amsl (top of
liner 5598.5 -3.2 feet). Figure 7, Hydraulic Profile Schematic, shows the relationship
between the Cells, and the relative elevations of the solution pools and the spillway
elevations.
If Cell 4,A. were required to store the entire PMP event for Cell 2, Cell3 and Cell 44, the
required storage volume would be approximately 160 acre-feet of solution. This would
increase the necessary freeboardto 4.77 feet.
The required freeboard for Cell 4,A. will be recalculated annually along with the re-
calculation of the Cell 3 freeboard requirement. A calculation of the current freeboard
calculation for both Cells is attached to this Plan.
Page 12
Cell 4A BAT Monitoring, Operations and Maintenance Plan 09/08 Revision Denison 1.3
Attachments
l) Figure l,Initial Filling Plan, GeoSyntec Consultants
2) Figure 2,lnitial Filling Plan, Details and Sections, GeoSyntec Consultants
3) Figure 3, Initial Filling Plan, Solution and Slurry Pipeline Routes, GeoSyntec
Consultants
4) Figure 4, Interim Filling Plan, GeoSyntec Consultants
5) Figure 5, Leak Detection System Sump, GeoSyntec Consultants
6) Figure 6, Leak Detection Sump Operating Elevations
1) Figure 7, Hydraulic Profile Schematic
8) Cell 3 and Cell 4A Freeboard Calculation
9) Table l, Calculated Action leakage Rates for Various Head Conditions,
Cell4A,, White Mesa Mill, Blanding, Utah, GeoSyntec Consultants
10) White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT) Monitoring Plan,3107 Revision: DUSA-2, 32 pages, or
currently approved version of the DMT
Page 13
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5555.89 feet amsl
Lowest Level on Secondary Liner - 5555.14 feet amsl
Leak Detection Sump
Elevation - 5553.64 feet amsl
Denison Mines (USA) Corp.
Figure 6
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Calculated Action Leakage Rates
for Various Head Conditions
Cell 4A White Mesa Mill
Blanding, Utah
GeoSyntec Consultants
Head Above Liner
Svsfom ffeafl
Galculated Action Leakage
Rate {oallons/acre/dav}
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
!!9p6N
=
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page I of6
APPENDIX C
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
TAILINGS INSPECTION TRAINING
This document provides the training necessary for qualifying management-designated
individuals for conducting daily tailings inspections. Training information is presented by the
Radiation Safety Officer or designee from the Environmental Department. Daily tailings
inspections are conducted in accordance with the White Mesa Mill Tailings Management System
and Discharge Minimization Technology (DMT) Monitoring Plan. The Radiation Safety Officer
or designee from the Radiation Safety Department is responsible for performing monthly and
quarterly tailings inspections. Tailings inspection forms will be included in the monthly tailings
inspection reports, which summarize the conditions, activities, and areas of concern regarding
the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory,
requiring no action) or that conditions of potential concem exist (requiring action). A "check"
mark indicates no action required. If conditions of potential concern exist the inspector should
mark an o'X" in the area the condition pertains to, note the condition, and specify the corrective
action to be taken. If an observable concern is made, it should be noted on the tailings report
until the corrective action is taken and the concern is remedied. The dates of all corrective
actions should be noted on the reports as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or the Radiation Safety Officer, one of whom will notify
Corporate Management. If dam failure occurs, notify your supervisor and the Mill Manager
immediately. The Mill Manager will then notify Corporate Management, MSHA (303-231-
5465), and the State of Utah, Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form. Refer to Appendix A for an example of the daily
tailings inspection form. The inspection form consists of three pages and is summarized as
follows:
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page2 of 6
Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks, damage, and sharp bends. The pipeline
joints are to be monitored for leaks, and loose connections. The pipeline supports are to
be inspected for damage and loss of support. Valves are also to be inspected particularly
for leaks, blocked valves, and closed valves. Points ofdischarge need to be inspected for
improper location and orientation.
Operational Systems:
Operating systems including water levels, beach liners, and covered areas are items to be
inspected and noted on the daily inspection forms. Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas of concern and should be noted. Beach areas that are observed as having cracks,
severe erosion or cavities are also items that require investigation and notation on daily
forms. Exposed liner or absence of cover from erosion are potential items of concern for
ponds and covered areas. These should also be noted on the daily inspection form.
Cells 1, 3 and 44 solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last
inspection. All pumping activities affecting the water level will be documented. ln Cells
1 and 3, the PVC liner needs to be monitored closely for exposed liner, especially after
storm events. It is important to cover exposed liner immediately as exposure to sunlight
will cause degradation of the PVC liner. Small areas of exposed liner should be covered
by hand. Large sections of exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action. After these
conditions have been noted to the Radiation Safety Officer, a work order will be written
by the Radiation Safety Officer and turned into the Maintenance Department. All such
repairs should be noted in the report and should contain the start and finish date of the
repairs.
Dikes and Embankments:
lnspection items include the slopes and the crests of each dike. For slopes, areas of
concern are sloughs or sliding cracks, bulges, subsidence, severe erosion, moist areas,
and areas of seepage outbreak. For crests, areas of concem are cracks, subsidence, and
severe erosion. When any of these conditions are noted, an "X" mark should be placed in
the section marked for that dike.
In addition, the dikes, in particular dikes 3, 4A-S and 4A-W, should be inspected closely
for mice holes and more importantly for prairie dog holes, as the prairie dogs are likely to
1.
2.
3.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page 3 of6
burrow in deep, possibly to the liner. If any of these conditions exist, the inspection
report should be marked accordingly.
Flow Rates:
Presence of all flows in and out of the cells should be noted. Flow rates are to be
estimated in gallons per minute (GPM). Rates need to be determined for slurry lines,
pond return, Sx-tails, and the spray system. During non-operational modes, the flow rate
column should be marked as "0". The same holds true when the spray system is not
utilized.
Physical Inspection of Slurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of
the mill. If possible, the inspection should include observation of the entire discharge
line and discharge spill point into the cell. If "fill to elevation" flags are in place, the
tailings and build-up is to be monitored and controlled so as to not cover the flags.
Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3, and 4A. Other
observations to be noted include a brief description of present weather conditions, and a
record of any precipitation received. Any dusting or wind movement of tailings should
be documented. In addition, an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis. Daily
measurements should be made as near to 8:00 a.m. as possible every day. Weekend
measurements will be taken by the Shifter as close to 8:00 a.m. as possible. All snow or
ice should be melted before a reading is taken.
Observations of Potential Concern:
All observations of concern during the inspection should be noted in this section.
Corrective action should follow each area of concem noted. All work orders issued,
contacts, or notifications made should be noted in this section as well. It is important to
document all these items in order to assure that the tailings management system records
are complete and accurate.
4.
5.
6.
7.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page 4 of 6
8. Map of Tailings Cells:
The last section of the inspection involves drawing, as accurately as possible, the
following items where applicable.
1- Cover area
2. Beach/tailing sands area
3. Solution as it exists
4. Pump lines
5. Activities around tailings cell (i.e. hauling trash to the dump, liner repairs, etc.)
6. Slurry discharge when operating
7. Over spray system when operating
9. Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area. These
rules meet the required MSHA regulations for the tailings area. Please pay particular
notice to the following rules:
1. The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2. No food or drink is permitted in the area.
3. All personnel entering the tailings area must have access to a two-way radio.
4. Horseplay is not permitted at any time.
5. Only those specifically authorized may operate motor vehicles in the restricted area.
6. When road conditions are muddy or slick, a four-wheel drive vehicle is required in
the area.
7. Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket. A portable eyewash must be present on site as well.
8. Anytime the boat is used to perform any work; an approved life jacket and goggles
must be worn at all times. There must also be an approved safety watch with a two-
way hand-held radio on shore. A portable eyewash must be present on site as well.
10. Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering
the tailings area. All wildlife observed should be reported on the Wildlife Report
Worksheet during each shift. Waterfowl seen near the tailings cells should be
discouraged from landing by the use of noisemakers.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page 5 of 6
11.
Following the review of this document and on-site instruction on the tailings system
inspection program, designated individuals will be certified to perform daily tailings
inspections. The Radiation Safety Officer authorizes certification. Refer to the
Certification Form, Appendix C. This form should be signed and dated only after a
thorough review of the tailings information previously presented. The form will then be
signed by the Radiation Safety Officer and filed.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.2
2/07 Revision: DUSA-2
Page 6 of 6
APPENDIX D
CERTIFICATION FORM
Date:
Name:
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.3
2/07 Revision: DUSA-l
Page I of3
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
DUST MINIMIZATION
Operational Procedure for Dust Minimization:
ln an effort to keep wind movement of tailings sand to a minimum, the following dust
minimization procedures will be utilized.
1.1.when blowing tailings sand or dusting is observed on cell 3 beaches, the spray
system should be operated until a crystal crust develops on the sands surface. The
spray lines will be moved as necessary. As soon as the crystal surface develops, the
spray system will be shut off. The Radiation Safety Officer along with the Mill
Foreman and Shift Foreman will be responsible for the operational decisions
regarding dust minimization. The spray lines require periodic cleaning because they
tend to crystallize over a period of time. The spray system should be operated if there
is evidence of excessive blowing sands indicating surface crust deformation or
otherwise on an as needed basis.
During times of strong winds, the Radiation Safety Officer will ensure that no spray
is being carried out of the cells. If spray is leaving the confines of the cell, all
spraying will cease immediately.
Additional snow fencing and straw bales will be assembled to form windbreaks, as
needed on Cell 3 beaches.
As 11e.(2) by product material is placed in Cell 3, interim cover can be advanced in
an effort to minimize dusting on Cell 3.
The effectiveness of the above methods will be documented on the weekly tailings inspection
form. Documentation will include observed wind movement of tailings sand, if any, and the
steps taken the preceding week for dust control. Wind movement of tailings sand is noted on
every daily inspection form along with an estimate of the percentage of dusting from Cells 2
and 3. The areas of blowing dust will be noted as well on Monday's daily inspection form.
Procedure: Tailings Dust Control System:
There are five methods of control of blowing tailings dust: Spraying raffinate solution,
creating wind breaks with straw bales and snow fencing, flooding with slurry, using
chemical stabilization agents and covering with interim cover. During operation of the
mill, Cell 2 will not require any dust control measures since the cell consists of cover area
t.2.
1.3.
t.4.
)
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.3
2/07 Revision: DUSA-l
Page 2 of 3
and a slimes area. In addition to these areas, cover will be advancing along the slimes
area as the disposal of waste at the Cell 2 dump expands. This advancement of cover will
also reduce the amount of exposed tailings sand on Cell 2's surface; thereby eliminating
the need for dust control measures. If dusting is observed on Cell 2, similar dust control
measures to those implemented for Cell 3 will be taken. The entire control activities will
be focused on Cell 3 beaches unless the above conditions are modified.
At present, there are four general areas in Cell 3:
1. Thepond.
2. The 11e.(2) by product material disposal area.
3- The cover area.
4. The tailings beaches.
The area of concern regarding dusting is the tailings beaches. These beaches will need to
be sprayed in order to minimize dusting. The sprays should continue until a crust
develops on the tailings surface. Once a crust develops, the spray system can be shut
down.
Another method of dust control for Cell 3 beaches is the use of straw bales and snow
fencing, which are used as wind breaks. These breaks should extend at least three feet
above the existing sands and should be extended in lines to form barriers. These
windbreaks will be monitored daily and repaired or replaced as needed.
The use of interim cover as a means of dust control in Cell 3 beaches will be utilized only
in the area in which the l1e.(2) by product materials are placed, or in areas of Cell 3
where the tailings sand is up to final grade and is dewatered sufficiently enough to
support the use of equipment for placement of the interim cover. As the material is
placed, the cover can be advanced; thus, reducing the amount of tailings sand subject to
dusting.
Once the mill is operating and tailings are deposited in Cell 3, the area where tailings
sand is deposited becomes inaccessible to equipment. After a period of two to three
weeks, the sand surface will be stable enough to walk or work on. Tailings will be
deposited through two lines until the sands are at the final deposition elevation. At this
time, the lines will be moved to another area.
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.3
2/07 Revision: DUSA-l
Page 3 of 3
3. Procedure: Dust Minimization for Ore Stockpiles:
Dusting from the ore stockpiles have not been observed to be a problem as a hard crust has
developed, which has inhibited dusting. The primary dust control techniques will utilize water
application to the roadways on an as needed basis. If dusting is observed while transferring ore
to the Gizzly from either roadways or stockpiles, water applications will be applied to minimize
dusting. The number of applications, time of application, and location of application is
documented and kept on file in the Radiation Office. Weekly inspections of the stockpile area
are conducted to evaluate the effectiveness of dust control measures.
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White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.4
2/07 Revision: DUSA-l
Page I of 2
MANAGEMENT SYSTEM
1.
WHITE MESA MILL TAILINGS
TAILINGS LINE DETECTION
Procedure: Tailings Line Rupture Detection System
The following method detects line rupture of a tails line at the White Mesa Mill.
There are four major pipelines that transport solution and slurry from the Mill to the tailings
Cells and from the tailings Cells back to the Mill. One six inch line and one eight inch line
transport slurry from the Mill to impoundment Cell 3. One eight inch line transports tails
solution from the solvent extraction process to impoundment Cell l-I. Solution is returned
back to the mill in a pond return line from either Cell 1-I or Cell 3.
Each of the above mentioned lines will have separate sensing systems that will be tied into a
common alarm system. Each line will have a sensor at its discharge to determine the flow
condition in the line. There will be a total of four (4) sensors.
The type of sensors will be a conductivity detection device, which will detect the presence or
absence of material in the pipe. They will be positioned at high points in the line so thar a
"no flow" condition will not produce a high conductivity reading. If they were positioned at
a low point in the line, the material would always present a false reading.
A time delay device will be incorporated in both tailings slurry lines that will activate the
alarm after approximately 30 seconds of no flow condition, or a time determined by
operational practice. This is necessary because of surges in the tailings slurry lines. It is not
anticipated that delay devices will be necessary for the pond retum line or SX tails line. The
rupture detection alarm will be both optical and auditory, and will activate in the Central
Control Room. An alarm indicator will be installed in the Central Control Room along with
an "on-off' switch so that the Shift Foreman will have immediate control over the pond
retum pump.
The Central Control Room will have an alarm panel that will show lights corresponding to
the different lines. The lines not in use will be shown as "no flow" conditions by the lights.
When a line goes from a "flow" to a "no flow" condition, an alarm horn unique to the tailings
system will sound and the corresponding light to the line will then blink intermittently. The
Shift Foreman can then acknowledge the alarm. This will turn off the horn, but the light will
remain on and cease to blink.
The Shift Foreman under the direction of the Mill Foreman will perform the daily test of the
White Mesa Mill - Standard Operating Procedures
Book I l: Environmental Protection Manual, Section 3.4
2/07 Revision: DUSA-l
Page 2 of 2
2.
rupture detection system during the day shift. The Shift Foreman will shut down each
running pump under his control and observe the alarm board in the Central Control Room.
When the appropriate alarm sounds, he will acknowledge the alarm and restart the pump,
making sure the alarm light goes out. This will be recorded in the daily Shift Foreman's
report.
The Radiation Safety Officer will review these reports to ensure that the rupture detection
system is functioning properly. [n the event of a failure of the rupture detection alarm system
or rupture of a line, the Mill Foreman will be notified immediately.
Operational Procedure for Tailings Rupture Detection System - Central Control Room
2.1.Every day on the day shift the Shift Foreman will test the rupture detection system.
This test will show alarms at the rupture detection system panel board located in the
Central Control Room.
2.2. Any alarm will suggest a line rupture and will be investigated and treated as such.
2.3. Line ruptures will be reported immediately to the Mill Manager and the Radiation
Safety Officer. The Mill Manager will also inform corporate management
immediately.
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White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section 4.1
PART I
Date: 2l0l Revision: DUSA-l
Page I of4
1.0
SI]RFACE SOIL MONITORING
SOIL MONITORING PLAN
SOIL MONITORING
Surface soils are sampled at the five air monitoring sites. The sampling locations, shown in
Figure 1, are as follows: BHV-1, BHV-2, BHV-3, BHV-4, BHV-5 and BHV-6. Soil samples
are taken once per year during August or as soon as possible thereafter, but no later than
September 30 of the year. ln addition, a soil sample could be taken from Westwater Creek,
in the place of a water sample. However, a sediment (soil) sample would only be taken at
Westwater Creek if water was not available. In the event that a soil sample is collected in
place of a water sample for Westwater Creek, the sample should be analyzed for the same
parameters as those called for in this SOP (Radium-226 and U-nat). Refer to SOP No. PBL-
EP-3 for details regarding collection of a water sample from Westwater Creek.
SAMPLING AND ANALYTICAL QUALITY ASSURANCE
The sample bags are marked for location identification and are submitted to the analyical
laboratory accompanied by Chain-of-Custody forms. (Attachment A)
Analytical quality assurance for soil monitoring is based on the contract laboratory's quality
controls such as blanks, duplicates, and standard percentage recovery. The laboratory is
committed to meet the LLD values for radionuclides contained in U.S. NRC Regulatory
Guides 4.14 and4.15 and will perform re-mns on all samples not meeting these limits, as per
EPA SW-846. Appropriate laboratory control and quality assurance data will be provided by
the contract laboratory, or equivalent, including LLD information.
ANALYTICAL REQUIREMENTS
All soil samples will be analyzed, on a dry basis for the following radionuclides: Ra-226 and
U-Nat. Analytical results will be reported in appropriate radiological units such as pico curies
per gram or micro curies per kilogram.
PART II SOIL MONITORING STANDARD OPERATING PROCEDURES
SURFACE SOIL SAMPLING
Equipment
Equipment used for soil sampling is as follows:
1. Tape measure or measuring stick calibrated to I foot and to one centimeter.
2.0
3.0
1.0
1.1
White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section 4
Date'. 2107 Revision: DUSA- I
Page 2 of 4
1.2
2. Clean trowel or shovel.
3. Clean sample containers.
Soil Sampling Procedure
Soil samples are collected using a clean trowel or shovel to excavate a soil sample evenly
across a one square foot area at a depth of one centimeter. The one centimeter excavation
depth is maintained by using the tape measure or other suitable calibrated measuring stick.
As the soil is being collected, it is placed directly into the sample container. The sample
container is then identified with a label (see Section 2.1 below).
SAMPLING QUALITY ASSURANCE
Sample Labeling
Each sample must be labeled and all sample labels must be filled out in ink and numbered.
The following information must be contained on the label:
Project and facility.
Company name
Date and time of sample collection.
Sampler's initials.
Sample location.
Requested Analyical Parameters
Sample Chain-of-Custody
During sampling activities, traceability of the sample must be maintained upon sample
collection until the laboratory data is issued. lnformation on the custody, handling, transfer,
and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The
sampler is responsible for filling out the COC form. The COC form will be signed by the
sampler when the sampler relinquishes the samples to anyone else. A COC form is to be
completed for each set of samples placed in a sample shipping container and is to include the
following:
Sampler's name.
Date and time of collection.
2.0
2.1
1.
2.
J.
4.
5.
6.
2.2
l.
2.
White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section 4. I
Date: 210'l Revision: DUSA- I
Page 3 of4
Sample location.
Sample type.
Analysis requested.
Signatures of persons releasing custody.
Signatures of persons accepting custody, dates, and times.
Copies of the COC forms and all custody documentation when received will be retained in
appropriate files at the Mill. The original COC form remains with the samples until disposal
of the samples. The samples are kept at the laboratory for a period of three months after
analyses are complete. After sample disposal, the COC form will be sent to the
Environmental Department along with the analyses.
Sample Handling and Shipping
Samples will be placed in shipping containers and transported to the contract laboratory.
COC forms will be placed inside a resealable bag and placed inside the sample shipping
container.
Record Keeping
All soil sample data are retained in the files and when analytical results are available the
results are entered into a computer file and retained in the files. Laboratory analytical data
are stored in the soil files after the data has been entered on a computer file.
ANALYTICAL QUALITY ASSURANCE
Data Validation and Quality Control
Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in
results noted and investigated. Appropriate measures to confirm or disaffirm results will be
pursued, such as laboratory conversation, analytical sample rerun, or trend analysis.
Quality Assurance and Data Validation
The contract laboratory will prepare and retain a copy of all analytical and quality control
documentation. The laboratory will provide hard copy information in each data package
submitted in accordance with quality assurance objectives for the surface soil quality
assurance project plan that is: COC forms, cover sheets with comments, narratives, samples
analyzed, reporting limits and LLD values for analytes, and analytical results of quality
control samples. The data reduction and laboratory review will be documented, signed, and
dated by the analyst.
3.
4.
5.
6.
7.
2.3
2.4
3.0
3.I
3.2
White Mesa Mill - Standard Operating Procedures
Book #l l, Environmental Protection Manual, Section 4.1
Date: 21 07 Revision: DUSA- I
Page 4 of 4
Corrective Action
Corrective action will be taken for any deficiencies or deviations noted in the procedures or
anomalous results, such as but not limited to additional sample collection, sample re-run,
laboratory inquires, or other actions as appropriate.
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White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 4.2
Date: 2107 Revision: DUSA-l
Page I of4
2.0
VEGETATION MONITORING
PART I VEGETATION MONITORING PLAN
I.O VEGETATION MONITORING PLAN
Vegetation is sampled in early spring, late spring, and late fall at three locations around the
Mill. These locations are: Northeast Area (near BHV-l), Northwest Area (Vz mile west of
BHV-I) and the Southwest Area (West of BHV-4 and sourh off Cell3).
QUALITY ASSURANCE
Quality assurance for vegetation monitoring is based on the contract laboratory's quality
controls such as duplicates, blanks, standard percent recovery, and spike percent recovery.
The laboratory will also follow U.S. EPA Guide SW-846 and U.S. NRC Regulatory Guides
4.14 and4.15 when analyzing the vegetation samples. The laboratory is committed to meet
the LLD values for radionuclides addressed in these guidelines and will perform re-runs on
all samples not meeting these limits.
ANALYTICAL REQUIREMENTS
Each vegetation sample will be analyzedforRa-226 and Pb-210 radionuclide concentrations.
Results will be expressed in units of picocuries per gram (pcilg) or micro curies perkilogram
(ttci/kg), on a wet basis.
PART II VEGETATION MONITORING STANDARD OPERATING PROCEDURES
YEGETATION SAMPLING
Equipment
Equipment used for vegetation sampling is as follows:
l. Scissors
2. Large plastic sample bags
Vegetation Sampling Procedure
Vegetation samples are collected and removed at the surface with scissors at each sampling
location. The vegetation sample is enclosed in a large plastic bag. Each sample will be
weighed upon return to the office and must weigh at least three kilograms in order for the
3.0
1.0
1.1
1.2
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 4.2
Date:2/07 Revision: DUSA- I
Page2 of 4
laboratory to meet the required LLD values outlined in U.S. NRC Regulatory Guide 4.14. In
addition, as vegetation samples are collected efforts will be made to minimize the amount of
soil in the samples. The sample bag is then labeled (see Section 2.1).
2.0 SAMPLING QUALITY ASSURANCE
2.1 Sample Labeling
All sample labels must be filled out in waterproof ink and numbered. The date, time,
sampler's initials, and the sample location will be completed at the time the sample is
collected. The following information will be included on the label:
1. Project and facility.
2. Sampler's company affiliation.
3. Date and time of sample collection.
4. Sampler's initials.
5. Sample location.
6. Weight of sample.
7. Requested analytical parameters.
2.2 Sample Chain-of-Custody
During sampling activities, traceability of the sample must be maintained upon sample
collection until the laboratory data is issued. lnformation on the custody, handling, transfer,
and shipment of the samples will be recorded on a Chain-of-Custody form (COC). The
sampler is responsible for filling out the COC form. The COC form will be signed by the
sampler when the sampler relinquishes the samples to anyone else. A COC form is to be
completed for each set of samples placed in a shipping container and is to include the
following:
1. Sampler's name.
2. Date and time of collection.
3. Sample location.
4. Sample type.
5. Analysis requested.
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 4.2
Date: 2lO7 Revision: DUSA- I
Page 3 of4
6. Signatures of persons releasing custody.
7 . Signatures of persons accepting custody, dates, and times.
Copies of the COC forms and all custody documentation when received will be retained in
appropriate files at the Mill. The original COC form remains with the samples until analysis of the
samples. After sample analysis, the COC form will be sent to the Environmental Department along
with the analyses.
2.3 Sample Handling and Shipping
Sample bags will be packaged in large shipping boxes and transported to the contract
laboratory. COC forms will be placed inside a sealed bag and placed inside the shipping
box.
2.4 Record Keeping
All vegetation sampling data will be retained in a file. When analytical data becomes
available, the data is entered into a computer file and retained in the files. All laboratory
analytical data is stored in the vegetation files after the data has been entered into the
computer file.
3.0 ANALYTICAL QUALITY ASSURANCE
3.1 Data Validation and QC Review
Laboratory analyses will be reviewed by the technical staff and any identifiable anomalies in
results noted and investigated. Appropriate measures to confirm or disaffirm results will be
pursued, such as laboratory conversation, analytical sample rerun, or trend analysis.
3.2 Quality Assurance and Data Validation
The contract laboratory will prepare a copy of and retain all analytical and QC
documentation. The laboratory will provide the Mill with paper copies of the following in
each data package, in accordance with QA objectives for the Surface Soil QA Project Plan:
1. COC forms
2. Cover sheets with comments
3. Narrative
4. Samples analyzed5. Reporting limits and LLD values for analytes6. Analytical results of QC samples
The data reduction and laboratory review will be documented, signed, and dated by the
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, Section 4.2
contract laboratory analyst.
3.3 Corrective Action
Date: 2107 Revision: DUSA- I
Page 4 of 4
Corrective action will be taken for any deficiencies or deviations noted in the procedures or
anomalous results, such as but not limited to additional sample collection, sample re-run,
laboratory inquires, or other actions as appropriate.
o0,33A'3o
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a
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual. SOP Section 4.3
1.
1.1
External gamma
year at all BHV
locations).
1.2
1.3
Date: 02107 Revision: DUSA- I
Page I of2
EXTERNAL GAMMA MONITORING PLAN
AND STANDARD OPERATING PROCEDURES
EXTERNAL GAMMA MONITORING PLAN
Locations and Frequency of Monitoring
measurements are taken over a quarterly interval for the twelve months of the
locations and selected areas around the mill site (see Attachment #1 for those
Quality Assurance
Analytical Requirements
Values reported are in millirems per week average for the monitor period (supplied by Landauer)
along with a counting error term. The counting error term is calculated by:
[(sample 2 sigma) - (control mrem/week)] / (*fweeks)
Quality assurance for external gamma measurements consists of:
a) Monitoring the container locations to ensure the TLDs have not been lost;
b) Ensuring that all containers are present when receiving or shipping to Landauer; and
c) Reviewing Landauer data for consistency and data transportation.
STANDARD OPERATING PROCEDURES
Equipment
gamma is monitored at the ambient air sampling sites and other selected areas around
site, using the spherical container TLD badges from Landauer, Inc., or the equivalent.
Monitoring Methodology
a) The containers, each containing five TLD chips, are mounted approximately one
meter above ground plane at each site with one container per site.
1.4
1.5
Extemal
the mill
1.6
White Mesa Mill - Standard Operating Procedures
Book #l l: Environmental Protection Manual, SOP Section 4.3
Datq.02107 Revision: DUSA- I
Page 2 of 2
first of each quarter from Landauerb) The containers loaded with TLDs are received the
and exchanged with those in the field.
c) A background TLD is stored in the Administration Vault as a transportation control.
d) The TLDs are retumed to Landauer for processing.
1.7 Record Keeping
Data maintained in record form for external gamma is:
a) Sample period;
b) Sample location; and
c) External gafirma levels for total radiation.
Attachment #1
Location of Spherical
Badge
Number
0
I
,
3
4
5
6
7
8
9
r0
l1
t2
13
t4
15
t6
l7
l8
19
2A
2L
22
23
24
25
26
27
28
29
30
3l
32
33
34
Environmental Monitors Fourth Quarter 2AA6
Location of Monitors
Front Gate
Vanadium Conhol Roorn - Located on South Wall
BHV.6
Ore Storage - Cameco Barrel Storage Area
Vanadium Precipitation - Located on Agitator Start Stop Button
Yellowcake Drying Area - Located on North Yellowcake Dryer Alarm
Leach Area - Located at #2 Leach Tank Eyewash Station
SAG Mill Control Room
Yellowcake Precip. - Located on S. Wall by Yellowcake Precip Redissolve Tank
Central Control Room - Located on Shiftefs Bulletin Board
Ore Pad Trommel Screen - Located on Power Distribution Panel
Barrel Dump Station - Located at OperatorJs Panel
Metallurgical Laboratory - Hanging From Ceiling
Filter Press Room - Located on North Wail
BHV.I
BHV.2
BHV-3
BHV4
BHV-5
SAG Mill - Located Outside SAC Mill Control Room Door (North Side)
Tails - Located on Cell 2 at the PowerDistribution Center
CCD - Located Ouside MCC On North Wall on Breaker Box
North SX - Located on Regen. Pump StarUStop Switch
Administration Building - Located on Main Bulletin Board
In Tree By Picnic Bench Outside Administration Building
Yellowoake Packaging - Hung on Wall outside Door
North Yellowcake Dryer Area 2nd Level on N. Dryer Temp. Ctrl. Box
Bucking Room - Located on East Wall Behind Crusher
Mill Lunch Room - Located on Projection Screen on West Wall
South SX - Located on Column #10
Maintenance Supertintendent's Office - Located on North Wall
Ore Feed Gizzly - Located on North Wall at Power Distribution Boxes
Scalehouse - Located in Office at Northeast Comer
OBS (Sample Plant) - Located on South Side of Southwest Entrance Door
Administration Building - Vault (Control)
!
IDraEI'ot
N
White Mesa Mill - Standard Operating Procedures
Book: #l I Environmental Protection Manual
Date:2107 Revision: DUSA- I
Page I of4
SPECIFIC CONDUCTIYITY, pH METER, AND
TEMPERATURE FIELD INSTRUMENT CALIBRATION
STANDARD OPERATING PROCEDURES
1.0 SPECIFIC CONDUCTIVITY, pH, AND TEMPERATURE FIELD INSTRUMENT
CALIBRATION STANDARD OPERATING PROCEDURE
1.1 Introduction
A critical element in the White Mesa Mill's Groundwater and Surface Water
Monitoring Program is the measurement of each Monitoring Location's field
parameters (i.e., pH, temperature, and conductivity). The instrument utilized at
the Mill to perform these measurements is the Hydrolab Surveyor 4 with multiple
parameter probe called the Minisonde. It is important that all instruments used in
these measurements be calibrated and inspected prior to each use, to ensure that
they are functioning properly and have no obvious, visible damage or
contamination present.
1.2 Equipment
l. Hydrolab Surveyor 4 with Minisonde or equivalent
2. NBS traceable thermometer.
3. pH 7.0 and 4.0 buffer solutions.
4. Ecologic lnstrument Division of Industrial Municipal Equipment Inc.
stock conductivity solution of 3000 mhos or equivalent
5. Deionized water.
2.0 CALIBRATION OF PROBES FOR CONDUCTANCE, PH, AND
TEMPERATURE
2.1 pH Probe Calibration
The following describes the procedures for calibration of the Hydrolab Surveyor 4 /
Minisonde pH probe.
1. Prior to calibration ensure that the Surveyor 4's battery is fully charged.
White Mesa Mill - Standard Operating Procedures
Book: #l I Environmental Protection Manual
9.
10.
11.
t2.
13.
Date: 2107 Revision: DUSA- I
Page 2 of 4
lnspect probes for visible damage and contamination.
Rinse the probes with distilled water prior to placing them in the sample
container.
Fill the Minisonde's sample container with pH 7.0 buffer solution. If the
Minisonde's sample container is not used and the probe is placed directly
into a sample container place the probe protector over the probes prior to
measurement.
From the Surveyor 4 main menu choose calibrate and press "Enter".
At the next prompt choose "Ions-1", and press "Enter".
Typte "'7" after "standard:<<".
Thoroughly rinse the probes and sample container with deionized water.
Rinse sensors with a small amount of the pH 4.0 buffer. Fill the sample
cup with the pH 4.0 buffer solution. Allow 1-3 minutes for the readings to
stabilize.
ln the Main Menu move the cursor to "Calibrate" and press "Enter."
Next move the cursor to "Ions" and press "Enter."
Place the cursor on "pH: units" and press "Enter."
Now type the 4.0 after "standard: <<, followed by "Enter."
The pH sensor is now calibrated. If further problems are encountered refer
to the DataSonde4\MiniSonde manual or retum instrument to the
manufacturer for repair or calibration if required.
The Hydrolab Surveyor 4 / Minisonde temperature probe is calibrated at
the factory and typically does not require any calibration for temperature.
However, a check to ensure that it the probe functioning properly should
be performed prior to each use.
Place the probe in distilled water and allow the temperature reading to
stabilize (1-3 minutes), record the reading.
2.
-r-
4.
5.
6.
7.
8.
,)Temperature Probe Calibration
The following describes the procedures for calibration of the Hydrolab Surveyor
4 / Minisonde temperature probe:
1.
2.
White Mesa Mill - Standard Operating Procedures
Book: #l I Environmental Protection Manual
Date: 2/07 Revision: DUSA-l
Page 3 of4
with a NBS traceable3.
4.
Monitor the temperature of the solution
thermometer, recording this reading.
Comparison of these two temperature readings should not vary more than
0.5 degrees Celsius between the two readings. No reference checks of
temperature readings are retained.
5. At this point sample collection and monitoring of groundwater and surface
water field temperature may proceed.
Specifi c Conductance Probe Calibration
The following describes the procedures for proper calibration of Surveyor 4 /
Minisonde for specific conductance measurements :
1.Rinse probes with de-ionized water.
Fill sample container with conductivity standard solution.
Allow conductivity readings to stabilize (1-3 minutes).
Record reading on the Groundwater/Surface Water Field Sampling Sheet.
Repeat previous steps monitoring deionized water (less than 10 mhos). If
conductivity standard reading is within two-percent of the standard and the
deionized water reading is less than l0 mhos, proceed to field
measurements.
If the readings do not meet the conditions stated in the previous step,
calibrate the instrument using the conductivity standard.
To calibrate choose "Calibrate".
From the menu choose "Specific Conductance" and press "Enter."
Enter the value of the standard solution in mhos/sq. cm and press "Enter."
The Surveyor 4 display will indicate whether or not the calibration was
successful. If display indicates the calibration was successful proceed
forward with field measurements. If display indicates that calibration was
not successful repeat calibration procedures until indication that
calibration was successful is given.
2.3
2.
-r-
4.
5.
6.
7.
8.
9.
White Mesa Mill - Standard Operating Procedures
Book: #l I Environmental Protection Manual
Datei 2107 Revision: DUSA- I
Page 4 of 4
QUALITY ASSURANCE
Following the steps outlined in procedures above and using the prescribed equipment will
produce accurate and repeatable results of groundwater and surface water field
parameters. HS/EA Department Manager will review technician performance
periodically.
3ztogoEB>
at#t-ee:!E x*g@e6ooo{r:o
No.: PBL-15
Rev. No.: R-l
Book No. 8
Date: February
25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Release and Shipping of Vanadium Blackflake
Page 1 of4
1. Purpose
The following procedure applies to the release and shipping of all vanadium in the form
of blackflake from the restricted area of the White Mesa Mill (the "Mill"). Denison
Mines (USA) Corp. ("DUSA") produces or has produced vanadium in three forms:
blackflake, vanadium pregnant liquor ("VPL") and ammonium metavanadate ("AMV").
This procedure addresses release of vanadium blackflake only. Release of VPL or AMV
may only be accomplished in accordance with separate procedures relating specifically to
those forms of vanadium. The purpose of this procedure is to ensure that no lot of
vanadium blackflake is released from the Mill's restricted area unless: a) it has an
average source material content of less than0.05Vo; and b) the applicable requirements of
NRC Regulatory guide 1.86 and l0 CFR Part20 are satisfied,
2. Form of Container
2.1. Vanadium blackflake shall be packaged in 55 gallon metal drums, each drum
containing approximately 550 pounds of vanadium.
3. Samplins and Analysis for Source Material Content
3.1. Drums shall be assembled into lots for shipment.
3.2. A composite sample of all of the drums in each lot must be taken and analyzed as
follows:
a)
b)
Obtain an equal volume sample from each individual drum in the lot
and composite them into a single sample;
Submit the composite sample to the Mill laboratory for sample
preparation;
c) Perform a radiological analysis on the composite sample for total
uranium and total thorium;
d) Upon receipt of the analysis, record the combined percentage of
uranium and thorium on the attached Source Material Assay and
Radiological Survey of Vanadium Form; and
e) Attach copies of the assay results to the attached Source Material
Assay and Radiological Survey of Vanadium Form.
3.3. Under no circumstances may a lot of vanadium that has a composite sample with
a combined weight percent uranium and thorium of 0.05Vo or greater be released from the
Mill's restricted area, unless it is released to a facility that has an appropriate source
material license and the material is being released to such licensee in accordance with
that license.
No.: PBL-15
Rev. No.: R-l
Book No. 8
Date: February
25,2001
DENISON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 2 of 4
Title: Release and Shipping of Vanadium Blackflake
4. Preparine Blackflake Drums and Shippine
4.1. Move all drums from stacked lots and place them on the ground so that the sides
and tops can be easily inspected and prepared as necessary. The bottoms of the drums
are to be inspected by lifting the drums with a barrel grab and visually checking for leaks
and rust. Do not get under the drums when checking or cleaning and painting the
bottoms.
4.2. After the drums are placed on the ground, check that lids and rings are properly
secured and tightened.
4.3. Ensure strong, tight packaging - i.e., no holes in any of the containers. Notify
your supervisor ifthere are any holes in the containers.
4.4. Paint drums if necessary.
4.5. Ensure that appropriate labeling is properly attached to each drum.
4.6. Check the drum number, date, lot number, gross weight, tare weight, and net
weight on the tops and/or sides of each drum against the numbers on the drum list that
will be attached to the Bill of Lading. If numbers do not match exactly, notify your
supervisor.
5. Product Shipment Survevs
5.1. Prior to shipment release, the Radiation Safety Department will survey
blackflake product shipments from the facility. No shipments will be released prior to
the Radiation S afety Department' s authorization.
5.2. Equipment, scanning procedures and equipment calibration used for blackflake
product shipment surveys is detailed in the Radiation Protection Manual, Book 9.
5.3. Drums shall be cleaned prior to the radiation surveys.
5.4. Drums requiring repair shall be repaired prior to the radiation surveys.
5.5. The following surveys shall be performed:
5.5.1. Alpha Surveys:
a) Perform a fixed alpha survey of each drum. The release limits for fixed alpha
radiation contamination is an average of 5,000 dpm/100 cm2 and a maximum
of 15,000 dpm/100 c*'. Any drumthat exceedJ 1,000 dpm/100cm2 fixed
No.: PBL-15
Rev. No.: R-l
Book No. 8
Date: February
25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 3of4
Title: Release and Shipping of Vanadium Blackflake
5.5.2.
alpha contamination requires a removable alpha smear/wipe test to be
performed;
Perform a removable alpha survey on any barrel exceeding 1,000 dpm/100
cm2 fixed alpha contamination. The release limit for removable alpha
contamination is 1,000 dpm/100 cm2. Perform a smear/wipe test and analyze
filters for removable alpha on257o of the barrels at a minimum, and perform a
smear/wipe test and analyze the filters for removable alpha on any barrels that
exceed 1,000 dpm/100 cm2 fixed contamination;
Record the results of the foregoing alpha surveys on the attached Source
Material Assay and Radiological Survey of Vanadium Form; and
Any drums with visible contamination are to be cleaned prior to release.
Gamma Surveys:
Perform a gamma survey of each drum on contact with the surface of the
drum and record the results on the appropriate spaces on the attached Source
Material Assay and Radiological Survey of Vanadium Form. No drum that
has an average contact gamma radiation exposure rate in excess of 2 mradlhr
shall be released from the restricted area of the Mill;
Calculate the average contact gamma dose rate for the lot by summing the
value calculated for each drum in the lot under paragraph 5.5.2 a) above and
by dividing the sum by the number of drums in the lot. Record this average
contact gamma dose rate for the lot on the appropriate space on the attached
Source Material Assay and Radiological Survey of Vanadium Form; and
No lot of sixty-six 55 gallon blackflake drums will be permitted to be released
from the Mill's restricted area unless the average contact gamma dose rate for
the lot, calculated over all drums in the lot pursuant to paragraph 5.5.2b),
does not exceed 0.907 mrad/hr. If a lot size is different than sixty-six 55
gallon drums of blackflake, then the RSO will determine an equivalent
calculation, based on the analysis used to determine the 0.907 mrad/hr, to be
used as the permitted average contact gamma dose rate for such lot.
5.6. If any lot is shipped in more than one shipment, the RSO shall ensure that the
average contact gamma dose rate for the drums in each shipment is comparable to the
average contact gamma dose rate for the lot.
6. Loadins Drums Onto the Truck
6.1. After the drums have been surveyed, load the drums into the transport vehicle
using appropriate Mill mobile equipment.
b)
c)
d)
a)
b)
c)
Brace the load of drums as may be required for transport.
No.:PBL-15
Rev. No.: R-l
Book No. 8
Date: February
25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 4 of 4
Title: Release and Shipping of Vanadium Blackflake
6.3. If the transport vehicle has entered the Mill's restricted area, then prior to the
truck leaving the restricted area, the truck will be scanned as per PBL-Z,Intermodal
Container Acceptance, Handling & Release.
6.4. Ensure that the shipment has been properly placarded.
6.5. Fill out the appropriate transportation paperwork for the shipment. Provide a
copy of the shipping packet to the driver and maintain a copy for the Mill. The
paperwork to be provided to the driver shall not include the Source Material Assay and
Radiological Survey of Vanadium Form.
7. Hazard Identification and Safety
7.1. All safety precautions for material loading operations must be observed,
including: securing the loading ramp, and using mobile equipment, and drum stacking
precautions.
8. Paperwork Tracking
8.1. The attached Source Material Assay and Radiological Survey of Vanadium Form
shall be completed for each lot that is shipped, and shall be maintained in the Mill's
central files for inspection. Do not permit any vanadium to leave the restricted area
unless:
a) the attached Source Material Assay and Radiological Survey of Vanadium
Form has been completed, with assay results attached;
b) the Source Material weight percent, as indicated on the Form, is less than
0.05Vo;
c) the Average Dose Rate/Lot, as indicated on the Form, does not exceed 0.907
mrad/hr, or such other value as may be determined by the RSO under Section
5.5.2 c) above;
d) the Maximum Dose Rate/Lot, as indicated on the Form, does not exceed 2
mrad/hr; and
e) the alpha survey results indicated on the Form comply with the release
standards described in Section 5.5.1 above.
Source Material Assay
Radiological Survey of Vanadium
DUSA Lot #:
Source MaterialAssay
Total Weight % U:
TotalWeight % Th:
TotalSource Material:
&
Date:
Surveyed By:
lnstrument:
SN ESP-1 / AC-3
02299 I 1
Cal. Date: 02286 I 2
Function Check ( 5 x 1 min.)
Th 230 @ 30300 dpm
Bkg Average:
Dpm Average:
Total
Dose
Model#:
SN:
Cal. Date:
Source:
Efficiency:
Note:
Total
Alpha Removable
Alpha
Model:
SN:
Cal. Date:
Alpha Bkg Ave:
Alpha eff:
Alpha Factor:
Total
Gamma
Model#:
SN:
Cal. Date:
Source:
Efficiency:
Laboratory assay results for this lot of vanadium product are attached.
DATE LOT NO.
BACKGROUND EFFICIENCY FACTOR
Averaqe Gamma Dose Rate/Lo
Maximum Gamma Dose Rate/Lot-
Drum
Number
TotalAlpha
dom/100cm2
Removable Alpha
dpm/100cm2
Dose Rate mr/hr
Tops
Dose Rate mr/hr
Sides
1
2
3
4
5
6
7
8
I
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
DATE LOT NO.
BACKGROUND EFFICIENCY FACTOH
Removable Alpha Dose Rate mrlhr
Sides
U,
oJ>
ST
EE@g
=x!6'o
!,:
STORMWATER
BEST MANAGEMENT PRACTICES PLAN
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
February 2007
for
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
1.0 Purpose2.0 Scope
3.0 Responsibility4.0 Best Management Practices
4.1 General Management Practices Applicable to All Areas4.2 Management Practices for Process and Laboratory Areas4.3 Management Practices for Maintenance Activities
4.4 Management Practices for Ore Pad, Tailings Area, and heavy Equipment
Operations
Figures
Figure I White Mesa Mill Site Map
Figure 2 Mill Site Drainage Basins
Figure 3 ruSA Mill Management Organization Chart
Figure 4 ruSA Corporate ManagementOrganization Chart
Tables
Table I White Mesa Miii Management Personnei Responsibie ior Impiementing
This BMPP
Appendices
Appendix I White Mesa Mill Spill Prevention, Conhol, and Countermeasures Plan
Appendix 2 White Mesa Mill Emergency Response Plan
""'ix?I:ffi il'iJ;:i:"ff ,,#;
1.0 INTRODUCTION/PURPOSE
Denison Mines (USA) Corp. ("DUSA") operates the White Mesa Uranium Mill ("the Mill) in
Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect to
water effluents. That is, no water leaves the Mill site because ttre Mill has:. no outfalls to public stormwater systems,o Jlo surface runoff to public stormwater systems, .
. no discharges to publicly owned treatment works ('.pOTWs,'), and. no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW37O0O4 to DUSA on March g,
2005. As a part of compliance with the Permit, DUSA is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spills of chemicals or hazardous materials, which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes. Although the Mill, by design, carxnot directly impact stormwater, surface water, or
groundwater, the Mill implements lhese practices in a good faith effort to minimize all sources of
nnllrrfinn af fha oifat/v^r sr^vr^
Page I
2.0
Best Management Practices PIan
Revision I . l: February 2007
SCOPE
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations,laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMpp.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. ln addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that carurot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure 1. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
washdown to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
l) the number and size of material spills, and2) the amount of unrecovered spilled material and washwater that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
Requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are addressed in the DUSA White Mesa Mill Spill Prevention, Control and
countermeasures ("sPCC") Plan Revised February, 2007, the Emergency Response plan
("ERP"), also revised in February,200'7, and the housekeeping procedures incorporated in the
White Mesa Mill Standard Operating Procedures ("SOPs"). The SPCC plan and the Epp are
provided in their entirety in Appendices I and 2, respectively.
Page2
Best Management Practices PIan
Revision l.l: February 2007
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMpp. DUSA
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3.The DUSA Corporate
Management Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table 1.
Page 3
"*'#;,:?ffT:1'ff:jffi;11;
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all Iiquid and solid materials managed at the Mill is provided inTables 2 through 5.
4.1 General Management practices Appticabre to Alr Areas
4.l.lKeepPotentiatPoIlutantsfromContactwith@:
o Store hazardous materials and other potential pollutants in appropriate containers.o Label the containers.. Keep the containers covered when not in use.
4.1.2 Keep Potential poilutants from contact with precipitation
o Store bulk materials in covered tanks or drums.o Store jars, bottle, or similar small containers in buildings or under covered areas.. Replace or repair broken dumpsters and bins.
' Keep dumpster lids and large container covers closed when not in use (to keepprecipitation out).
4.1.3 Keep Paved Areas from Becoming pollutant Sources
o sweep paved areas regularly, and dispose of debris in the solid waste dumpsters ortailings area as appropriate.
4'l'4 Inspection and Maintenance of Diversion Ditches and Drainage Channets within theProcess and Reagent Storage Area
o Diversion ditches and drainage channels will be inspected during the regularly scheduledinspections required by Groundwater Discharge permit No. ucfr3 n064, andByproduct Materials License #uTtgoo479. Areas requiring maintenance or repair willbe report to site management and maintenance departments for necessary action. statusof maintenance or repairs will be documented during follow up inspections.
4.1.5 Recycle Fluids Whenever possible:
o When possible, select automotive fluids, solvents, and cleaners that can be recycled orreclaimed.o When possible, select consumable materials from suppliers who will reclaim emptycontainers.
' Keep spent fluids in properly labeled, covered containers until they are picked up forrecycle or transferred to ttre tailings area for disposal.
Page 4
Best Management Practices plan
Revision l.l: February 2007
4.2 Management Practices for process and Laboratory Areas
Clean Up Spills Properly
clean up spills with dry cleanup methods (absorbents, sweeping, collection drums)instead of water whenever possible.
clean spills of stored reagents or other chemicals immediately after discovery.(Groundwater Discharge permit No. uGW3 7 oo04,s ecrion t.b. s. c. )Recover and re-use spilled material whenever possible.
Keep supplies of rags, sorbent materials (such as cat litter), spill collection drums, andpersomel protective equipment ("ppE") near the areas where they may be needed forspill response.
If spills must be washed down, use the minimum amount of water needed for effectivecleanup.
4.2.1
a
o
a
a
4.2.2 Protect Materials Stored Outdoors
If drummed feeds or products must be stored outdoors,store them in covered or diked
4.2.3
areas when possible.
If drummed chemicals
when possible.
must be stored outdoors, store them in covered or diked areas
Make sure drums and containers stored outdoors are in good condition and securedagainst wind or leakage- Place any damaged containerslnto an overpack drum or secondcontainer.
Water Management
When possible, recycle and reuse water from flushing and pressure testing equipment.When possible, wipe down the outsides of containers instead of rinsing G*ofi i, tt "sink.
!T"n possible, wipe down counters and work surfaces instead of hosing or rinsing themoff to sinks and drains.
Materials Management
Purchase and inventory the smallest amount of laboratory reagent necessary.
Do not stock more of a reagent than will be used up before itJexpiration date.All new construction of reagent storage facilities will include secondary containmentwhich shall control and prevent any contact of spilled reagents, or otherwise releasedreagent or product, with the ground surface. (Groundwater Discharge permit No.UGW370004, Section I.D.3.e.)
a
a
a
a
a
4.2.4
Page 5
Best Management Practices Plan
Revision 1.1: February 2007
a
o
4.3 Management Practices for Maintenance Activities
4,3.1, Keep a Clean Dry Shop
4.3.2
4.3.4
Sweep or vacuum shop floors regularly.
Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in
those areas.
Clean up spills promptly. Don't let minor spills spread.
Keep supplies of rags, collection containers, and sorbent material near each work area
where they are needed.
Store bulk fluids, waste fluids, and batteries in an area with secondary containment
(double drum, drip pan) to capture leakage and contain spills.
Manage Vehicle Fluids
Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon aspossible. use drip pans or plastic tarps to prevent spillage and spread of fluids.
Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle,
or disposal.
Recvcle automotive fluids. if possihle, when their useful life is finished.
Use Controls During Paint Removal
Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust.
Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to adisposal location in the tailings area authorized to accept waste materials from
maintenance or construction activities.
Use Controls During Paint Application and Cleanup
Mix and use the right amount of paint for the job. Use up one container before opening a
second one.
Recycle or reuse leftover paint whenever possible.
Never clean brushes or rinse or drain paint containers on the ground (paved or unpaved).
Clean brushes and containers only at sinks and stations that drain to the process sewer tothe tailings system.
Paint out brushes to the extent possible before water washing (water-based paint) or
solvent rinsing (oil-based paint).
Filter and reuse thirmers and solvent whenever possible). Contain solids and unusable
excess liquids for transfer to the tailings area.
4.3.3
Page 6
Best Management Practices Plan
Revision l.l: February 2007
4.4 Management Practices for ore Pad, Tailings Area, and Heavy Equipment
Detailed insffuctions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in proper Areas
o Wash down trucks, trailers, and other heavy equipment only in areas designated for this
purpose (such as washdown pad areas and the truck wash station).o At the truck wash station, make sure the water collection and recycling system is working
before turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
o Water spray the ore pad and unpaved areas at appropriate frequency in accordance withMill SOPs.o Water spray stockpiles as required by opacity standards or weather conditions.o Don't over-water. Keep surfaces moist but minimize runoff water.
4-L a Keen E'qr"fhntrt.rinry A ofi,itiac f,^.- a^^^-:-^ D^rl,-.^..4 e^---^^^,[^uv' rrrs r r!.i i.fi-s i i uiia uLLuiiiiiix, -a-uii ulaii i Dour ces
o Schedule excavation, grading, and other earttrmoving activities when extreme dryness and
high winds will not be a factor (to prevent the need for excessive dust suppression).o Remove existing vegetation only when absolutely necessary.o Seed or plant temporary vegetation for erosion control on slopes.
PageT
Personnel
Rich E. Bartlett
Wade Hancock
Scot Christensen
David E. Turk
Wally Brice
Personnel
Ron F. Hochstein
David C. Frydenlund
Interim Mill Manager
Maintenance Foreman
Mill Foreman
Radiation SafeW Offrcer
Vice President and
General Counsel
435-678-2221
Ext. 105
43s-678-2221
Ext.l66
435-678-2221
435-678-2221
Ext. 113
435-678-2221
Ext.122
Table I
White Mesa MiIl Management Personnel
Responsible for Implementing This BMPP
Mill Staff
Title Work Phone Home Phone/
Other Contact Number
435 678-2495
43s 678-2753
435 678-2015
435 678-7802
Environmental Technician
Corporate Management Staff
Title Work Phone
President/ Chief Operating 604 806-3589
Officer
435 678-2309
Home Phone/
Other Contact
Number
Cell: 604 377-1167
303 389-4130 303 221-0098
Cell: 303 808-6648
TABLE 2
REAGENT YARD LIST
I:REAGENT CAPACIT/...',r:
t*utn*t'"'"t
ADOGEN 2382
ADVANTAGE lO1M
AMERSITE 2
AMINE 2384
AMMONIUM SULFATE (BULK)
AMMONIUM SULFATE (BAGS)
ANHYDROUS AMMONIA
CHEMFAC 1OO
CI.ARIFLOC N-101P
DECYI-ALCOHOL
DIESEL FUEL
FLOCCULENT M1OllN
FLOCCULENT M13O2C
GRINDING BALLS
ISODECANOL
rtrDnqtrNttr
MACKANATE
MILLSPERSE 802
NALCO 2458
NALCO 8815
PERCOL 351
PERCOL 406
PERCOL 745
POLOX
POLYHALL YCF
PROPANE
SALT (BAGS)
SALT (BULK)
soDA ASH (BAGS)
soDA ASH (BULK)
SODIUM CHLOMTE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
6,L20
2,475
0
L9,440
54,000
4,300
107,920
12,800
3,000
45,430
30,550
3,550
48,290
45,430
1 ?/LA,
3,150
1,410
0
0
1,500
13,950
0
10,360
0
39,280
0
39,280
84,100
101,128
0
4,90L,440
;
-;
1
1
i
1
1
1
I
1
2
1
1
31,409
250
6,000
1n 1tr?
30,000
L6,92L
9,530
L7,700
10,500
L9,9M
1,600,ooo
269,t60
3,000
s.000
1.
2.
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST1
Chloroform 4.54 ko 55 oal
Hvdrochloric acid 2.270 ko 58 qal
Nitric acid 454 kq 5L
Phosphoric acid 2.270 kq 101
Sulfuric acid 454 ko 25L
Hydrofluoric Acid 45.4 ko 1L
Ammonium hvdroxide 454 ko 181
This list identifies chemicals which are regulated as hazardous substances under the
Federal water Pollution control Act 40 cFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Parl117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
Quantitv ln,stock
Ii,{n:fiill ii?l
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassiu m tartrate
n-Butylacetate
Carbon tetrachloride
Cyclohexane
Ferric chloride
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Zinc acelale
2,270 kg
45.4 kg
2,270 kg
2,270 kg
2,270 kg
45.4 kg
2,270 kg
4.54 kg
454 kg
454 kg
454 kg
4.54 kg
45.4 kg
2,270 kg
454 ko
1.8 kg
2.27 kg
2.27 kg
6.8 kg
7.8 kg
0.454 kg
4L
1.0 L
24L
6.810 kg
0.57 kg
0.114 kg
2.5 kg
1.4 kg
0.91 ko
Quantitv ln Stock. .,,lfffi fr,.],:
. -"1r: ;', : ,, .: r.i ;1 . : ;:;, :.- . ...s,:, ,
Chloroform 4.54 kq 8L
Formaldehvde 45.4 ko <1L of 37% solution
Nitrobenzene 454 ko 12L
Toluene 454 ko 12L
1.
2.
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
This list identifies chemicals which are regulated as hazardous substances
under the Federal Water Pollution Control Act 40 CFR Part 117. Materials
in this list are stored in a locked storage compound near the bulk storage
tank area. The Mill also stores small quantities of other materials that are
not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
li:
Acetic Acid, Glacial 1,000 lbs 4 qal
Ammonium Hvdroxide 1.000 lbs 5L
Carbon Disulfide 100 lbs 0 lbs
Calcium Hvpochlorite 10 lbs 2 kq (4.4 lbs)
Chlorine 10 lbs 0 lbs
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kq (11lbs)
Hydrochloric Acid 5,000 lbs 60 gal of 40%
solution
Nitric Acid 1,000 lbs 101
Potassium Permanoanate 0.1 N 32 c,al 5 kq (11 lbs)
Sodium Hypochlorite 5.5%100 lbs 2 kg (11 lbs) of
E Eit -^t..a:--C.O-lo SUIUtlul I
Silver Nitrate 1tb 0 lbs
Trichloroethylene 100 rb 2L
Xylene (Mixed lsomers)100 lbs 0lbs
REAGENT , RQ1.,.
, .t . -t:l AUANTIW IN
REAGENT,Y,,ARD
I Sulfuric Acid
I Floc #sot
I Hyperfloc 102
I Ammonia - East Tank
I Ammonia - West Tank
I Kerosene
I s.tt (Bags)
! Ammonium Hydrogendifluoride
I Soda Ash Dense (Bag)
I Phosphoric Acid
I Polyox
I Mitlsperse
I Nalco TX760
I Nalco 7200
I friUutyl phosphate
I Distillates
Diesel
Gasoline
Alamine 336 drums
Floc 109
Floc 208
Floc 904
Hyperfloc 624
Salt (Bulk solids)
Salt (Bulk solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
Alamine 335 Bulk
Alamine 310 Bulk
lsodecanol
Vanadium Pentoxide3
Yellowcake3
Ammonia Meta Vanadate
1,000 lbs
None
None
100 lbs
100 lbs
100 gal
None
None
None
5,000 lbs
None
None
None
None
None
None
100 gal
100 gal
None
None
None
None
None
None
None
1,000 lbs
None
None
None
None
None
1000 lbs
None
1000lbs
9,000,000 lbs
1,200 tbs
1,500 lbs
0 lbs'
105,000 lbs
500 gal
2,000 lbs
20,450 lbs
0lbs
6,300 lbs
490 lbs
1,410 lbs
9 barrels
1,590 lbs
9,450 lbs
100 gal
Approx. 3300 gal
Approx. 6000 gal
0 lbs
0 lbs
0 lbs
0lbs
0lbs
0 lbs
0 lbs
0 lbs
0lbs
20,000 lbs
0lbs
0 lbs
0lbs
30,000 lbs
< 100,000 lbs
0 lbs
1.
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardoussubstances under the Federal water pollution control Act 40 cFR p*t ttl .
Reportable Quantities are those identified in 40 CFR Parl 117 Table 117.3: 'Reportable euantitiesof Hazardous Substances Designated pursuant to section 31 1 of the clean waier Act.,,
Vanadium Pentoxide and Yellowcake, the Mill's products, are nol stored in the Reagent yard itself,but are present in closed containers in the Mill Building and/or Mill yard.
2.
3.
1.
2.
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
T,.QUANTITY'.IINi:iffiffiGl,,
Lubricating Oils in 55 gallon drums
Transmission Oils
Water Soluble Oils
Xylene (mixed isomers)
Toluene
VarsolSolvent
(2% trimethvl benzene in petroleum distillates)
100 gal
1 00 gal
100 gal
100 lbs
1000 lbs
100 gal
1,540 gallons
0 gallons
30 gallons
0 gallons
0 gallons
0 gallons
FIGURES
Figure 1
White Mesa MilI
MiII Site Layout
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=FzrPL)
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2
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16?r\3ii
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Figure 2
White Mesa Mill
Mill Site Drainage Basins
I
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t_,.,..,^...-<--
ir'o-' -l- t I, rt)e. rf:\ :;lri) ". 'l
)/'o I'lr"' I{.' I/l
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Figure 3
White Mesa MiIl
Mill Management Organization Chart
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Figure 4
Corporate Management Organization Chart
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APPENDIX 1
WIIITE MESA MILL
SPILL PREVENTION, CONTROL, Ai\D COIINTERMEAST RES
PLAII
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN
FOR CHEMICALS AND PETROLEUM PRODUCTS
White Mesa Uranium Mill
6425 South Highwa_y 1.9'!
P. O. Box 809
Blanding, Utah 84511
February 2007
for
Prepared by:
Denison.Mines (USA) Corp.
1050 17'n Street, Suite 950
Denver, Colorado 80265
TABLE OF CONTENTS
SECTION
1.1 Objective
1.2 Responsibilities
1.3 Drainage Basins, Pathways, and Diversions
1.4 Description of Basins
1.4.1 Basin A1
1.4.2Basin M
1.4.3 Basin B1
1.4.4 Basin 82
1.4.5 Basin 83
1.4.6 Basin C
1.4.7 Basin D
1.4.8 Basin E
1.5 Potential Chemical Spill Sources And Spitl Containment
1.5.1 Reagent Tanks
1.5.2 Ammonia
1.5.3 Ammonium Meta Vanadate
1.5.4 Caustic Storage (Sodium Hydroxide )
1.5.5 Sodium Carbonate
1.5.6 Sodium Chlorate
1.5.7 Sulfuric Acid
1.5.8 Vanadium Pentoxide
1 .5.9 Kerosene (Organic)
1.6.0 UsedMaste Oil
PAGE
1
2
3
3
3
3
3
3
4
4
4
4
5
5
5
5
5
5
6
6
6
6
7
SECTION
1.6.1 Propane
1.7 Potential Petroleum Sources And Containment
1.7.1. Petroleum Storage Tanks
1.7 .1.1. Diesel
1.7.2 Aboveground Fuel Pump Tanks
1.7 .2.2 Unleaded Gasoline
1.7.2.3 Pump Station
1.7.2.4 Truck Unloading
1.8 Spill Discovery And Remedial Action
1.9 Spill lncident Notifications
1.9.1 External Notification
1.9.2 lnternal Notification '
1.10 Records And Reports
1.11 Personnel Training And Spill Prevention Procedures
1.11 .1 Training Records
1.1 1.2 Monitoring Reports
1.12 Revision
1.13 Summary
1.14 Mill Manager Approval
1.15 Certification by Registered Professional Engineer
PAGE
7
7
7
7
8
I
8
8
8
I
I
11
12
12
12
13
13
13
14
14
Table 1.0
Table 2.0
Table 3.0
Table 4.0
Table 5.0
Table 6.0
Figure 1
Figure 2
Mill Organization Chart
Reagent Tank List
Laboratory Chemical lnventory List
Reagent Yard/Small Quantity Chemicals Lisl
Reagent Yard/Bulk Chemicals List
Petroleum Products and Solvents List
LIST OF FIGURES
MillSite Layout
Mill Site Drainage Basins
1.1
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASIJRES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
OBJECTIVE:
The objective of the splll Prevention, control, and countermeasures (spcc)
Plan is to serve as a site-specific guideline for the prevention of and response tochemical and petroleum spills, and as a guidance document for compliance withGroundwater Discharge Permit No. UGW370004. The plan ouflines spillpotentials, containment areas, and drainage characteristics of the white MesaMillsite. The plan addresses chemicalspill prevention, spillpotentials, spill
discovery, and spill notification procedures. The Oil Pollution prevention Sections
of the clean water Act (40 cFR 112 to 117), also referred to as the spill
Prevention, control, and countermeasures ("spcc") rules, establish
requirements that apply to facilities which could reasonably be expected to
ciischarge oii in quaniities thai may be harmfui, as described in that Act, into or
upon the navigable waters of the United states or that may affect natural
resources of the United States. Section 112 states that the Act is not applicable
to facilities that are not subject to the authority of the U. s. Environmenial
Protection Agency ("EPA") for one of the following reasons:
1- Due to its location, the facility could not reasonably be expected to
discharge oil into navigable waters of, or impact natural resources of, the
U.S. or
2. The facility is subiect to authority of the Department of Transportation asdefined in a Memorandum of Understanding (,,MOU,,) between the
Secretary of Transportation and the EpA Administrator, or
3. The facility does not exceed either the underground or the above ground
storage capacity (42,000 gallons and 1,820 gallons, respectively)
prescribed in the rules.
The Millcould not reasonably be expected, as described in the SpcC regulation,
to discharge oil into the navigable waters, or impact natural resources, oitneU.S. The Millsite was constructed with an overall grade and diversion ditch
system designed to channel the non-recovered portion of any material spillto the
tailings management system. Hence, it is not reasonable to expect that surfacespills will ever reach navigable waters or natural resources of the U.S. or Utah.
Therefore, the sPCC reporting requirements in the clean water Act are not
applicable to the Mill. However, as good environmental management practice,
the Mill has implemented the spill management program, desc-ribed in this
1.2
document, which is consistent with the intent of the clean water Act to theextent practicable. Although the Mill, by design, cannot direcfly impact navigablewaters of the U.s., and as a result, spills thathay occur but are retained withinthe site would not be "reportable", the Mill implements these fractices in a goodfaith effort to minimize all potential sources oi pollution at the,1t..
.
- - "---
Storage of ores and alternate feeds on the ore pad, and containment of tailingsin the Milltailings impoundment system are not'considered ,,spills', for thepurposes of this SPCC.
Ammonia is the only chemicalthat has the potentialto leave the site, and woulddo so as a vapor.
Figule 1, Site Layout Map shows a map of the mill site including the locations ofthe chemicaltanks on-site. Figure 2 shows the basins and drai-nage ditch areasfor the mill site. Table 1.0 is an organization chart for Mill opeiations. Table 2.0lists the reagent tanks and their respective capacities. Table 0.0 lists thelaboratory chemicals, their amounts, and theii reportaute quantities. Table 4.0lists the operations chemicals. Table 5.0 lists the chemicais in the reagent yard,their amounts, and their: reportable quantities. Table 6.0 lists the petroleumproducts and solvents on site.
RESPONSIBILITIES:
Person in charge of facirity responsibre for spiil prevention:
Mr. Richard E. Barilett, lnterim Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
(43s) 459-2495 (home)
Person in charge of follow-up spill record keeping and/or reporting:
Mr. David E. Turk, Department Head, Health , safety, and Environmentar
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Refer to section 1.9 spill tncident Notification for a list of company personnelto be notified in case of a spill. ln addition, an organizationa inai is providedin Table 1.0.
1.3 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS:
1.4
The main drainage pathways are illustrated in Figure 2. The map shows
drainage basin boundaries, flow paths, constructed diversion ditches, tailings
cells, the spillway between cell2 and 3, dikes, berms, and other relevant
features. The white Mesa Mill is a "zero" discharge facility for piocess liquid
wastes. The mill area has been designed to ensure that all spills or leaks
from tanks willdrain toward the lined tailings cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 10o% of the PMP (probable Maximum precipitation).
This allows for a maximum of 10 inches of rain at any given time.
DESCRIPTION OF BASINS:
1.4.1
1.4.2
1.4.3
1.4.4
Precipitation and unexpected spills on the mill property are contained within
their respective drainage basins. Runoff would ultimately drain into one of
the three (3) lined tailings cells.
Basin A1
Basin A1 is north of Cell 1-l and Diversion Ditch No. 1. The basin
contains 23 acres, all of which drain into westwater creek. This area is
not affected by milloperations.
Basin A2
Basin ,A2 contains all of Cell 1-l including an area south of the Diversion
Ditch No. 1. The basin covers 84 acres. Any runoff from this basin
would be contained within Cell 1-1.
Basin 81
Basin 81 is north of the mill property and is not affected by mill
operations. The basin contains 45.4 tributary acres. Runoff from this
basin drains into a flood retention area by flowing through Diversion Ditch
No. 2. Diversion Ditch No. 2 drains into Westwater Creek.
Basin 82
Basin 82 is northeast of the mill and contains only 2.6 acres. Runoff from
this basin would drain into Diversion Ditch No. 3. Diversion Ditch No. 3
ultimately drains into Diversion Ditch No. 2. This basin is not affected by
milloperations.
1.4.s
1.4.6
1.4.7
1.4.8
Basin 83
Basin 83 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normaldirection of flow in this basin is from the
northwest to the southwest. Any runoff from this basin would drain intocell 1-1. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 1OO% of the pMp (probable Maximum
Precipitation). This allows 10 inches of rain for any given storm event.
Basin C
Basin c contains allof cell2. The basin consists of 90.7 acres. This
basin contains earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All runoff in this basin
would be channeled along the southern edge of the basin. Runoff would
then flow into Cell 3 via the spillway from Cell2 to Cell3.
Basin D
Basin D contains all of Cell 3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains allflows, including those caused by the pMF.
Basin E
Basin E contains Cell44 and consists of 43.3 acres. All anticipated flowsincluding those caused by the PMF will be contained within the basin andwillflow directly into Cell4A.
1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTA!NMENT
This section details potential sources of chemical spills and "reportable quantities,,. Forpurposes of this SPCC, a "reportable quantity''will be defined as quantities listed belowwhich could be expected to reach navigable waters of the United States. ReportableQuantities are those identified in 40 CFR Part 1 17 Table 112.3: ,,Reportable euantitiesof Hazardous Substances Designated Pursuant to Section 811 of the Clean Water Act.,,It is not expected that any spillwould reach navigable waters of the United States.However, if a spill of a volume listed below occurs, and remains on the mill site, which isthe more likely scenario, then management is to be notified so that proper internalevaluations of the spill are made.
1.5.1
1.5.2
1.5.3
1.5.4
Reagent Tanks ( Tank list included in Table 2.0 )
Ammonia
The ammonia storage tanks consist of two tanks with a capacity of31,409 gallons each' The tanks are located southeast of t'he tvtitt ouitoing.
Daily monitoring of the tanks for leaks and routine integrity inspections will beconducted to minimize the hazard associated witn amrioriia.' rne reportablequantity for an ammonia spill is 7 gallons.
Ammonia spills should.be treated as gaseous. Ammonia vapors willbemonitored closely to minimize the hazird associated witn in-rialation. lfvapors are detected, efforts will be made to stop or repair the leakexpeditiousty. Ammonia is the onty chemicat ( as ,rpii) tnai nas tnepotential to leave the site.
Ammonia Meta Vanadate
Ammonia meta vanadate is present in the sX buirding as the processsolutions move through llg circuit to produce tne van"aoiu, Lho product.But, the primary focus will be on the transportation of this chemical. Thereportable quantity for an ammonia meta vanadate spirt is i,ooo pounds.
Caustic Storage (Sodium Hydroxide)
The caustic storage tank is located on a splash pad on the northwest cornerof the sX building. The tank has a capacity ot r's,so+ g"i6.r. The tanksupports are mounted on a concrete curbed catchment-pad that directs spillsinto the sand filter sump in the northwest corner of the dx uuitoing. Thereportabre quantity for a sodium hydroxide spi[ is gs garrons.
1.s.5 Sodium Carbonate (Soda Ash)
1.5.6
1.5,7
1.5.8
The soda ash solution tank has a capacity of 16,921 gallons and is located in
the northeast corner of the sX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and is located in the SX building. Spills willbe
diverted into the boiler area, and would ultimately drain into cell 1-1. There is
no reportable quantity associated with a sodium carbonate spill.
Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity ol 17,7O0 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable quantity for a
sodium chlorate spill is 400 gallons.
Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1,6000,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin 83 and is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
spill. Allflows resulting would be channeled to cell 1-1. The tank is equipped
with a high level audible alarm which sounds prior to tank overflows. A
concrete spill catchment with a sump in the back provides added
containment around the base of the tank. However, the catchment basin
would not be able to handle a major tank failure such as a tank rupture. The
resulting overflow would flow towards Cell 1-1.
The two smaller storage tanks are located within an equalvolume spill
containment dike east of the mill building. The tanks are not presenfly in
use, but are equipped with high levelaudible alarms.
The reportable quantity for a sulfuric acid spill is 65 gallons (1,000 pounds).
Vanadium Pentoxide
Vanadium pentoxide is produced when vanadium is processed through the
drying and fusing circuits and is not present in the vanadium circuit until after
the deammoniator. Efforts willbe made to minimize leaks or line breaks that
may occur in processes in the circuit that contain vanadium pentoxide.
Special care will be taken in the transportation of this chemical. The
reportable quantity for a vanadium pentoxide spill is 1,000 pounds.
1.5.9 Kerosene (Organic)
The kerosene storage area is located in the central mill yard and has a
combined capacity of 10,152 gallons in three tanks. Any overflow from these
three tanks would flow around the south side of the SX building and then into
Cell 1-1. These tanks have drain valves which remain locked unless
personnel are supervising draining operations. The reportable quantity for akerosene spillis 100 gallons.
1.6.0
1.5.1
1.7
Used/ Waste Oil
Used/ waste oilfor parts washing is located north of the maintenance shop
in a tank and has a capacity of 5,000 gallons. The tank is contained within a
concrete containment system. Ultimate disposal of the used oil is to an EpApermitted oil recycler. Any oil escaping the concrete containment system willbe cleaned up. soilcontaminated with used oilwill be excavated anddisposed of in Cell2.
Propane
The propane tank is located in the northwest corner of the millyard and hasa capacity of 30,000 gallons. Daily monitoring of the tank for leaks andinlnaril., ina^^^+i^^^ ...:tl L^ ^--r..-!- -r r-rrrrvv,,ty trrDPst LrvttD wtlt uc uuttuuuteu [u Ilttrllrlllze polenUal nazafos
associated with propane leaks. propane leaks willbe reported immediately.There is no reportable quantity associated with a propane spill.
POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
This section details potential sources of petroleum spills and "reportable quantities,,. Forpurposes of this SPCC, a "reportable quanti$'will be defined as quantities listed below
which could be expected to reach navigable waters of the United States. lt is not
expected that any spill would reach navigable waters of the United States. However, if a
spill of a volume listed below occurs, and remains on the mill site, which is the more
likely scenario, then management is to be notified so that proper internal evaluations of
the spillare made.
1.7.1 Petroleum Tanks
1.7.1.1 Diesel
Two diesel storage tanks are located north of the mill building. The tankshave capacities of 250 gallons each. One of the diesel tanki is for the
emergency generator. The other tank is located in the pumphouse on anelevated stand. Spillage from either tank would ultimately flow into Cell 1-1.The reportable quantity for a diesel spill is 100 gallons.
1.7.2 Aboveground Fuel Pump Tanks
1.7.2.1 Diesel
The dieseltank is located on the east boundary of Basin 83 and has acapacity of 6,000 gallons. The tank is contained within a concrete catchmentpad. The reportable quantity for a diesel spill is 100 gallons.
1.7.2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the dieseltank. The unleadedgasoline tank has a capacity of 3,000 gallons and is contained within the
same containment system as the dieseltank. The reportable quantity for anunleaded gasoline spill is 100 gallons.
1.7.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
company vehicles used around the mill site. The pump station is equipped
with an emergency shut-off device in case of overflow during fueling. 'ln
addition, the station is also equipped with a piston leak deteitor and
emergency vent. Check valves are present along with a tank monitor
console with a leak detection system. The catchment is able to handle acomplete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. ln this case, atemporary berm would need to be constructed. Absorbent diapers or floorsweep would be used in an effort to limit and contain the spill. The soilwould
be cleaned up and placed in the authorized disposal area in cell 2.
1.7. 2.4 Truck Unloading
ln the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or dieselfuel is spilled. proper clean-upprocedures will be followed to minimize or limit the spill. The spill may betemporarily bermed or localized with absorbent compounds. Any soill
contaminated with diesel fuel or oilwill be cleaned up and placed in the
authorized disposalarea in Cell2.
1.8 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is important to take
measures to limit additionalspillage and contain the spillthat has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, if
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personaldanger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Environmental Health and Safety
Manager.
The Mill Manager will assess the spilland related damage and direct
remedialactions. The corrective actions may include repairs, clean-
up, disposal, and company notifications. Government notifications
may be necessary in some cases.
lf a major spill continues uncontrolled, these alternatives will be considered.:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
o
1,9 SPILL INCIDENT NOTIFICATION
1.9.1 ExternalNotification
As stated in Section 1.1, spills are not expected to reach navigable waters ofthe United States. lf a spill of a "reportable quantity''occurs, then mill and
corporate management must be notified and they will evaluate whether or notthe following agencies must be notified:
1. EPA National Response Center 1_gOO_424_BgOz
2. State of Utah, Department of Environmental
Quality, Division of Radiation Control gO1/536-4250
3. State of Utah 801/SgB-7200
Water Quatity Division 801/598_6146
ln case of a tailings dam failure, contact the following agencies:
1. State of Utah, Department of Environmental
Quality, Division of Radiation Control 801/536_4250
2. State of Utah, Natural Flesources 801/53g-7200
1.9.2 lnternal Notification
lnternal reporting requirements for incidents, spills, and significant spills areas follows:
Report lmmediatelv
Event Criteria:
1. Flelease of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement
actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by
management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding 91,000,000
10
3. Government investigation or enforcement action which limits
operations or assesses penalties of 9100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report At The Beqinninq Of The Next Dav
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding the reportable quantities listed in section 1.5, for
each specific process material, waste, or by-product
ln the event of a spill of a reportable quantity, the Mill Manager is required to
callthe corporate Environmental Manager or the president and chief
Executive Officer. The individual first discovering the spill will report it to the
Shift Foreman, Production Superintendent or Maintenance Superintendent,
who will in turn ensure that the Mill Manager is notified. The Environmental
Health and Safety Manager will also be contacted by the Mill Manager.
Name
Mi!! Personnel:
Richard E. Bartlett
Wade Hancock
David E- Turk
N/A
N/A
Scot Christensen
Corporate Personnel:
Ronald F. Hochstein
David C. Frydenlund
Title Home Phone
[phone]
[phone]
[phone]
lnterim Mill Manager
Maintenance Foreman
Environmental Health and
Safety Manager
Production Superintendent
Maintenance Foreman
MillShift Foreman [phone]
President and Chief Operating Officer [phone]
Vice President and General Counset [phone]
ln the event the next person in the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Table 1.0 shows the
organizational chart for the mill site.
11
1 .10 RECORDS AND REPORTS
The following reports and records are to be maintained in Central Files by theEnvironmental Health and safety Manager for inspection and review for iminimum of three years:
Record of site monitoring inspections
a. Daily Tailings lnspection Data
b. Weekly Tailings lnspection and Survey
c. Monthly Tailings lnspection, pipeline thickness
d. Quarterly Tailings lnspection
Tank to soil potential measurements
Annual bulk oil and fueltank visual inspections
Tank and pipeline thickness tests
Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation inspections
7. Spill lncident Reports
B. Latest revision of SPCC plan
1.11 PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed andtrained. They are briefed on chemicaland petroleum spiliprevention'andcontrol. They are informed that leaks in piping, valves, and suddendischarges from tanks should be reported immediately. Abnormalflows fromditches or impoundments are of immediate concern. in addition, a safetymeeting is presented annually by the Environmental Health and'safety '
Manager to review the SpCC plan.
1.11.1 Training Records
Employee training records on chemicaland petroleum spill prevention aremaintained in the general safety training files.
1.11.2 Monitoring Reports
Shift logs shall provide a checklist for inspection items.
1.
2.
3.
4.
5.
12
1.12 REVISION
This procedure is to be reviewed by the mill staff and a registeredprofessional engineer at least once every three years, and'' updated whencircumstances warrant a revision.
1 .13 Summary
Below is a table listing the specific reportable quantities associated with themajor chemical and petroleum products on_site.
CHEMICAL REPORTABLE
QUANTITY (RO)
AMMONIA
AMV
SODIUM
HYDROX!DE
SODA ASH
SODIUM
CHLORATE
SULFURIC ACID
VANADIUM
PENTOXlDE
KEROSENE
otL
PROPANE
DIESEL &
UNLEADED
FUEL
1OO POUNDS
1,OOO POUNDS
1,OOO POUNDS
No Reportable
Quantity
4OO GALLONS
1,OOO POUNDS
1,OOO POUNDS
1OO GALLONS
No Reportable
Quantity
No Reportable
Quantity
1OO GALLONS
13
1.14 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the lnternational Uranium (USA)
Corporation White Mesa Millfacilities, and attest that this SPCC plan has
been prepared in accordance with the Standard Operating Procedures
currently in effect.
Richard E. Bartlett
lnterim MillManager
1.15 CERTIFICATION BY
REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the lnternational Uranium (USA)
Corporation White Mesa Millfacilities, and attest that this SPCC plan has
been prepared in accordance with good engineering practices.
Registered Professional Engineer
State of Utah No. 165838
14
TABLES
o
i''
I
! rabre I
White Mesa Mill Management personnel-: Responsible for Implementing This BMpp
Mill Staff
personnel Tifle Work phong Home phone/
_. Other Contact Number
Rich E. Bartlett Interim Mill Manager 435-678-222t 435 61g-2495*i
Ext. 105
Wade Hancock Maintenance Foreman 435-678-2221 435 67g-2753.,'i Ext.166
Scot Christensen Mill Foreman 435_67g_2221 435 67g_2015
T\^.;JE T'..-r- n--r.,ruoy ri -D. i. .nn a.aoralron sarery urncer 4J5-6ig_zz2L 435 679_7902
Ext. 113
WallyBrice Environmental Technician 435-67g-222t 435 67g_2309
Ext.122
I
-1
i Personnel Tifle Work Phone Ifome Phone/
o
qi
1ll
ii
Corporate Management Staff
Other Contact
Number
Ron F. Hochstein President/ Chief Operating 604 806-3589 Cell: 604 377-1167
Officer
David c. Frydenlund vice president and 303 3g9-4130 303 z2l-o0g}
l,jr
iit
i-i
I
General Counsel Cell: 303 808-6648
TABLE 2.0
REAGENT TANK LIST
QUANTITY REAGENT CAPACIIT (GAI)
2
3
1
1
1
1
2
1
1
1
1
1
I
2
DIESEL
KEROSENE
USEDMASTE OIL
DIESEL
UNLEADED
PROPANE
AMMONIA
SODIUM HYDROXIDE
SODA ASH SOLUTION
SODA ASH SHIFT
SODIUM CHLORATE
SODIUM CHLORATE
SULFURIC ACID
SULFURIC ACID
250
10,152
5,000
6,000
3,000
30,000
31,409
19,904
16,921
8,530
17,700
10,500
1,600,000
269,160
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LISTI
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassium tartrate
n-Butyl acetate
Carbon tetrachloride
Cyclohexane
Ferric chloride
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tribasic
Zinc acetate
2,270 kg
45.4k9
2,270 kg
2,270 kg
2,270 kg
45.4 kg
2,270 kg
4.54 kg
454 kg
454k9
454 kg
4.54k9
45.4 kg
2,270 kg
454 kq
1.8 kg
2.27 kg
2.27 kg
6.8 kg
7.8 kg
0.454 kg
4L
1.0 L
24L
6.810 kg
0.57 kg
0.114 kg
2.5 kg
1.4 kg
0.91 kq
1.
ROi
Chloroform 4.54ko 55 qal
Hvdrochloric acid 2.270 ko 58 qal
Nitric acid 454 kq 5L
Phosphoric acid 2,270 ko 101
Sulfuric acid 454 kq 25L
Hvdrofluoric Acid 45.4 ko 1L
Ammonium hvdroxide 454 ko 181
This list identifies chemicals which are regulated as hazardous substances under the
Federal water Pollution controlAct 40 cFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above regulation.
Reportable Quantities are those identified in 40 CFR Parl117 Table 1 17.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
g
Chloroform 4.54 ko 8L
Formaldehvde 45.4ko <1L of 37% solution
Nitrobenzene 454 kq 12L
Toluene 454 ko 12L
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
1. This list identifies chemicals which are regulated as hazardous substances
under the Federal Water Pollution Control Act 40 CFR Part 117. Materials
in this list are stored in a locked storage compound near the bulk storage
tank area. The Mill also stores small quantities of other materials that are
not hazardous substances per the above regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Acetic Acid, Glacial 1,000 lbs 4 sal
Ammonium Hydroxide 1,000 lbs 5L
Carbon Disulfide 100 lbs 0 lbs
Calcium Hypochlorite 10 lbs 2 kq (4.4 lbs)
Chlorine 10 lbs 0 lbs
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kq (11lbs)
Hydrochloric Acid 5,000 lbs 60 gal of 40%
solution
Nitric Acid 1,000 lbs 101
Potassium Permanqanate 0.1 N 32 qal 5 kq (11 lbs)
Sodium Hypochlorite 5.5%100 lbs 2 kg (11 lbs) of
5.5% solution
Silver Nitrate 1rb 0lbs
Trichloroethylene 100 lb 2L
Xylene (Mixed lsomers)100 lbs 0 lbs
1.
2.
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR Parl 117.
Reportable Quantities are those identified in 40 CFR Parl 117 Table 1 17.3: "Reportable Quantities
of Hazardous substances Designated Pursuant to Section 311 of the clean water Act."
Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent Yard itself,
but are present in closed containers in the Mill Building and/or Mill Yard.
3.
REAGENT g ,QUANTITY lN
REAGENT YARD
Sulfuric Acid
Floc #301
Hyperfloc 102
Ammonia - East Tank
Ammonia - West Tank
Kerosene
Salt (Bags)
Am monium Hydrogendifluoride
Soda Ash Dense (Bag)
Phosphoric Acid
Polyox
Millsperse
Nalco TX760
Nalco 7200
Tributyl phosphate
Distillates
Diesel
GasolineAt^*;^^ ooe A-,,^^nlcll I lll lE \r\rt, \Jl Llt I lD
Floc 109
Floc 208
Floc 904
Hyperfloc 624
Salt (Bulk solids)
Salt (Bulk solutions)
Caustic Soda
Ammonium Sulfate
Sodium Chlorate
Alamine 335 Bulk
Alamine 310 Bulk
lsodecanol
Vanadium Pentoxide3
Yellowcake3
Ammonia Meta Vanadate
1,000 lbs
None
None
100 lbs
100 lbs
100 gal
None
None
None
5,000 lbs
None
None
None
None
None
None
100 gal
100 gal
1l.l^^^IIUI IE
None
None
None
None
None
None
1,000 lbs
None
None
None
None
None
1000 lbs
None
1000 lbs
9,000,000 lbs
1,200 lbs
1,500 lbs
0 lbs
105,000 tbs
500 gal
2,000 lbs
20,450 lbs
0 lbs
6,300 lbs
490 lbs
1,410 tbs
9 barrels
1,590 lbs
9,450 lbs
100 gal
Approx. 3300 gal
Approx. 6000 gal
n lL-U IUs
0lbs
0 lbs
0lbs
0lbs
0lbs
0 lbs
0lbs
0lbs
20,000 tbs
0 lbs
0lbs
0lbs
30,000 lbs
< 100,000 lbs
0lbs
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
Lubricating Oils in 55 gallon drums
Transmission Oils
Water Soluble Oils
Xylene (mixed isomers)
Toluene
VarsolSolvent
(2% trimethyl benzene in petroleum distillates)
100 gal
100 gal
100 gal
100 lbs
1000 lbs
100 gal
1,54O gallons
0 gallons
30 gallons
0 gallons
0 gallons
0 gallons
2.
This list includes allsolvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
FIGI]RES
Figure I
White Mesa Mill
Mill Site Layout
I
o
a
o
-\ ,' t/-
\tl
)
L\,\-*---]]
oO< F ...LZ- Ind LI Io -l Idt t.?Lra
<=oo@-
I
4vlz6SE'
Sv
=*.
n
E
EeEz
dF
,18)
\\-\I\i\. I-\l \J\vF
o-\-2
-
F:
Figure 2
White Mesa Mill
Mill Site Drainage Basins
L-i
I
I
Il
d
EsiRs6t.lF
5AEdgE
=UiE2E
at
2=E646
Sufrace Water Flow
Drainage Basins
Diversion Ditches
rm o 1m0 2000#
oEnsdBY: Bottumur M
2
APPENDIX 2
WIIITE MESA MILL
EMERGENCY RESPONSE PLAN
EMERGENCY RESPONSE PLAN
REVISION 1.1
Denison Mines (USA) Corp.
White Mesa Mill
Blanding, Utah
April 14, 1986
REVISED
February 16,2007
Distribution List:
Ron F. Hochstein
Rich E. Bartlett
David Turk
Michael Spillman
Mill Shift Foremen
Blanding Fire Department
San Juan County EMS Coordinator
State of Utah, Department of Radiation Control
l.
2.
J.
4.
5.
6.
7.
8.
Revision Date: January 16,2006
TABLE OF CONTENTS
Page
Number
7.0 Evacuation Procedure ................17.1 Notification ....................17.2 Assembly... .....................17.1^ -. Specific Procedures for Operations personnel...........................................18.0 Off-Site Emergency Equipment/Personnel Release ........1
EXHIBITS:
1. Emergency Notification List2. Internal Notifications3. Site Layout Map4. Main Shut-off Valves
E-l
E-2
E-3
E-4
A-l
A-2
A-3
A.
B.
C.
APPENDICES:
Emergency Procedure Response to Fire
Emergency Procedure Response to Chemical or Gas Release
Emergency Evacuation Procedure
FIGURES:
l. Fire System Schematic F-1
t1
TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29, 2005 I WHITE MESA MrLL EMERGENCY RESrONSE rLAN I rug. I of 13
1.INTRODUCTION
This- Emergerrcy Response Plan is written not only to comply with Federal, State and localregulations, . but even more importantly to reduce ihe risk tb -our employees and that of thecommunity in regards to Health, Safety and Environmental Emergencies.
This plan includes the following:
o evaluation of.the potential risks- for. fire, explosions, gas releases, chemical spills andfloods (including tailings dam failure);. spe_cifi9 emergency programs for each potential event;o definition of administrative response actions; and,o definition of the emergency response contacts - both internal and extemal.
The white Mesa Mill (the "Mill") operates under the following regulatory agencies:
o Utah State Department of Environmental Quality, Division of Radiation Control;. Mine Safety and Health Administration;o EnvironmentalProtectionAgency;o Utah State Departmenl-of pnvilonmental Quality, Division of Air euality; and,. utah state Division ofNatural Resources Bureau of Dam Safety.
2. WHITE MESA MILL OVERVIEW
The Mill plocesses conventional uranium or uranium/vanadium ores to recover uranium andvanadium. In addition to the processing of conventional ores, the Mill also processes altemate
leed:naterials using similar process steps and chemicals. The conventional ore is stored on theOre Pad (qho-w1 in Exhibit 3).- Altemate feed materials are also stored on the Ore pad
"nd m|tbe stored in bulk form,.lined burrito-.bags, liners or drums. The descriptions of each alternatefeed material are maintained by the Mill'i Radiation safety officer.
The Mill utilizes a semi-autogenous grind circuit followed by a hot sulfuric acid leach and asolvent extraction process to extract ulanium and vanadium fiom ores, using large amounts ofsulfuric acid, sodium chlorate, kerosene, 1ryines, ammonia and caustic'sodaln th?process Thereagent storage tank locations are described in further detail in Section 4.6.
Emissions from the Mill process are in the form of air emissions from exhaust stacks andsolid/liquid tailings which are stored in the Mill's tailings cells locateA wesUsouitrwest of thimain Mill building. The major exhaust stack parameters aie shown in the following tubl..
Descriotion
Height(ft from surface)
Diameter
(inches)
Estimated Flow Rate(cfm)
Leach Exhaust -100 36 13,700
Yellow Cake Drying
(3 stacks)-85 l8 4,000 per stack
Vanadium Roasting &
Fusion -85 38 4100
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INTERNATIONAL URANIUM (USA) CORPORATION
WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 2 of 13
There are also smaller exhaust stacks associated with the Laboratory in the Mill Administrationbuilding and the boiler exhaust stack.
The Mill'slailings cells.are comp_rised gf-{o-ur below grade engineered cells, Cell l-I, 2,3 and4A Liquids are-stored in Cell l-I and CgJl 3, the actiie tailing"s cell. The liquid i" tti. i.ifirgtcells is very acidig. In addition to the tailings- cells, there is allo u, "."rg..rc1y lined catchmeitbasin west of the Mill building. Solutions in this basin or the tailings
""ffr"rfroirfJ not be used tofight fires in the Mill facility.
T!!-Products--of the Mill include ammonium metavanadate (AMV), vanadium pregnant liquor(vf!),1*adi.um pentoxide (vr9.r), and-yellowcqke, or uraniumcon""ntrut; aubrl] frrrVro,and.UrO, products are.pac\1ged- in sleel. dryr1s. for shipment. The AMV ir iad[dg"a in eitftisteel drums or super-saks while the vPL is sold in riquid'form in bulk.
Master files containing Material Safety Data Sheets for all materials in use at the Mill aremaintained at the S{fe,y Office, Mill Maintenance Office, Mill Laboratory una Vfiff CentralControl Rg9T. Copies are also on file althe Blanding Qh1ic, Doctor's Offi."r, gfunding fii;House and office of the San Juan county Emergency Midical ioordinator.
The nearest residence |o the Mill is approximately one mile to the north of the Mill, the next is aresidence- app.roximately two miles north of theivli[ followed by the .il*r"ity "iWfrit" M"raabout 3.5 miles to the south. The City of Blanding is located upp.o*I-uffi -6 miles to thennr*heacf
The Mill site is near lJtah Stare Highway l9l and can be accessed by a paved access road fromthe highway to the Mill facilities.
3. PLAN OBJECTIVES
The primary objectives of this plan are:
1. To save lives, prevent i-njuries,.prevent panic, and minimize property/environmental
damage to the lowest possible level.
2. To evacuate and account for all people in the area including visitors, truck drivers,contractors, etc.
3. To provide assembly areas that are as safe as possible and which can be reached withouttraveling through a hazardous area.. Assemblyareas will be properly -*"a to deal withsick or injured persons, and provisions will 6e made to evacuaie ttirr. f"irons to propershelter.
4. To make adequately.trained personnel available to cope with rescue and recoveryoperations as directed by the InCident Commander.
4. DESCRIPTION OF FACILITIES
The Mill facilities are shown on the site Layout Map included as Exhibit 3.
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TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-1
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4.1 Fire Water Supply and Alarm Systems
4.1.1 Fire Water Supply
The fire water supply facilities include:
. !00,0p^0 ga-llo-1 Stgtugg Tank of which 250,000 gallons are reserved for fire emergencieso Centrifu.Bal- diesel driven pump. rated_at 2,000 gpm at 100 psi. This pump starts
automati_cally w!e.n the pressure in the fire main drops below 100 psi (See Figur6 l, Fire
System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm'.
4.1.2 Alarm System
The alarm systems include the following:
. public address system. hand held radios. siren.
l a nfc-- D--:tl:--- _---r r t ,+.,L l,rrtutsDullut_!lB_4!!e!499f4!9fy
4.2.1 Office Building
Thg 9ffic9 building (approximately 10,000 square feet) contains the administration offices,radiation health and safety offices and the Mill laboratory. The central file vault and the maincomputer system are also-in this building. The ambulance is kept on the west side of the officebuilding near the safety office entrance.
4.2.2 Laboratory
The laboratory facilities contain the following:
o three flammable cabinets (keys required)r chemical storage room south of main lab
six fume hoods - hoods 1,2,3 and 4 are in the center of the laboratory and hoods 5 and 6are along the west wall. Hoods I and 2 are no longer in service. Hbods 3 and 4 are on
the wesl side, I and 2 ue on the east side of the center cluster of hoods with 2 being infront. Only hoods 5 and 6 may be used for perchloric acid.
outside laboratory chemical slorage north of office building (key required)perchloric acid storage vault located underground west of office buiiding (key required)
A wide^variety.of chemicals i! small quantities are located in the laboratory. These chemicals
range from acids to bases. along .with flammable metal compounds and peroxide formingcompounds. Oxidizers anq organic ,chemicals, which have a strong poteniial of producin[h*{"1 vapors if the containers are damagld to the point that the cfiemicals are exposed arEstored.in a storage room..inlhe laboratory. There are no acids stored in this storage room. The
acids.(including-but not limited to sulfuric, nitric, acetic, perchloric, phosphoric ana'hydrochloric
acids) are stored in the main laboratory area in2.5litei 61 500-ml'6otttes. VTSOS books for all
a
a
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INTERNATIONAL URANIUM (USA) CORPORATION
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chemicals in the laboratory are located in the Laboratory, Safety Department, Mill Maintenanceoffice and Mill Central Control room.
4.2.3 Electrical
Electrical transformers and electrical switches are located
chemical storage room.
4.2.4 Fire Protection System
in the laboratory at the east end of the
The fire protection systems in the office building and laboratory include:
. a fire hose station located on the east end of the office building. The station includes two
sets of turnout gear, two SCBA units and Incident Commander-materials.o automatic "wet" sprinkler system which is actuated at2l2 Fo portable dry chemical extinguishers strategically located throughout the building.
4.3 Solvent Extraction Building
The solvent extraction (SX) buildine (apploxlmately 21,000 square feet) houses the uranium andvanadium solvent extraction circuits and-the ELUEX circuit. tne qX circuits may contain uf to200,000 gallons kerosene (757,000liters ) which has a flash point of l g5. F.
Associaled^equipment in- !h9 SX building includes a temporary boiler located at the southwestend of the SX building which maintains the temperature fo? the hre system.
Chemicals which may be encountered in the SX building include:
o Keroseneo Caustic Sodao Anhydrous Ammoniao Sulfuric Acido Salt (Brine)o Soda Asho Ammonium Sulfateo Amineso Alcohol. Sodium Chlorate. Sodium Vanadateo Propane
The VPL product is stored in the SX building.
4.3.1 Electrical
All electrical switches are located outside in the MCC room north of the SX building.control panel for all of the equipment is located in the Central Control Room in thebuilding.
4.3.2 Fire Protection System
The SX building fire protection systems include:
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The main
main Mill
INTERNATIONAL URAMUM (USA) CORPORATION
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Date: Sept 29,2005 | WHITE Mf,SA MILL EMERGENCY RESPONSE PLAN I Page 5 of 13
o a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212"F.o portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure I in this Plan.
4.4 MiU Buildine
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
o Caustic Soda. Anhydrous Ammoniao Sulfuric Acido Soda Ash. Arnmonium Sulfate. Sodium Chlorate
- o^l:--* \ r^-^J^+^v Duurulll v aratu4ltr. Propane
The finished products which are contained in the mill building include AMV, VrO, and UrO, (or
yellowcake).
4.4.1 Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west corner of the mill building. Circuit control panels are located in the SAG mill control room,
the central control room, the vanadium roaster control room and the AMV area.
4.4.2 Fire Protection System
The main mill building fire protection systems include:
o portable dry chemical extinguishers strategically located throughout the building.o water hoses throughout the building.
For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System
Schematic included as Figure I of this Plan.
4.5 MaintenanceShopAMarehouse/ChangeRoomBuilding
This building (approximately 20,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located on the south end of the
building) and the personnel change rooms and lunch/training room (located on the extreme south
end ofthe building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
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INTERNATIONAL URANIUM (USA) CORPORATION
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o the main maintenance shop area contains welding and cutting equipment, lathes, presses,
and drill presses.o a 91rye1t9r shop which conlains various saws and planes. Fiberglass work is also done
within this shop area 3ld.it-is located at the northweit end of the mlintenance shop area.. an electrical shop which is located south of the carpenter shop.. a heavy equipment maintenance shop area is loca[ed at the north end of the maintenance
shop in the center of the building.. a rubber room for rubber lining of equipment is located east of the equipment shop area.o the maintenance shop offtce, instrument shop and tool room are located at the south endof the maintenance shop area.
The warehouse area contains orimarily dry good storage for repair parts and consumables for the
lPeration of the Mill. There is an electrical water heater for thb change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in thefollowing locations:
. small qutrntities of flammable material such as starting fluid and spray paint are kept in
the warehouse.
drums of new oil and anti-freeze are stored along the east wall of the equipment
-^i-e^-^-^^ --^^ ^-^l --- rl-- ---1 : I f ,trrrarrllcu(ulvE iartra i,ulu Ull tlltr trAst SlUc Ur tne WafenOUSe On Oll SIOfage faCKS.
used oil is stored in a tank located northeast of the equipment Jhop. The tank has a
capacity of approximately 5,800 gallons.
in the main maintenance shop area and the rubber room there are flammable storage
cabinets and east of the warehouse there is a trailer which is used to store flammab'ie
items such as rubber cements, paints and fiberglass resins.. compressed gas cylinder storage, both empty and full is located outside, east of the
maintenance shop.
4.5.1 Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is locatedon the east wall inside the Maintenance shop. Auxiliary electrical panels for the c[ange room
and warehouse are located in the southwest comer of the warehouse area.
4.5.2 f ire Protection System
]h9 lre protection system within the maintenance shop/warehouse/change room building
includes:
o "wet" automatic sprinkler system that releases at2l2" F.o portable {rY chemical extinguishers strategically located throughout the maintenance
area, warehouse area and the change room and lunch room.
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure l).
4.6 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
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INTERNATIONAL URANIUM (USA) CORPORATION
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. a sulfuric acid tank located northwest of the mill building which has a capacity of
approximately 1.4 million gallons.. a storage tank for propane is located on the north edge of the mill site, northwest of the
mill building. It has a storage capacity of 30,000 gallons.. four sodium chlorate tanks located east of SX bullding, north of the office building and
east of the pulp storage tanks. The two tanks east oi the SX building are for so?ium
chlorate storage and the other two tanks are for dilution of the sodium chlorate.o two anhydlous ammonia tanks located east of the SX building, with capacity of 31,409gallons each.. three kerosene tanks located east of the SX building, with a capacity of 10,152 gallons
each.. one caustic soda tank north of the SX building, with acapacity of 19,904 gallons.o three soda ash tanks which are located east of the SX buildiig. One tanli is the dry soda
ash tank with a capacity of 70,256 gallons. Two of the tankiare soda ash dilution tanks
with capacities of 16,921gallons each.. diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad.
The gasoline storage capacity is 3,200 gallons, while diesel storage capacity is S,OOO
gallons.
-Otlt"l reaglnts are stored in steel barrels or super sacs in a reagent yard located east of the officebuilding. Typical reagents which are stored in this yard include:
- -^1.,-^-^ ^-J fl^^^.-l^..r^- PUrJ rrrur D (ftlu ll\rv9lrr(lllt}. boiler feed water chemicals. methanolo tributyl phosphate. "dirty" soda ash and ammonium sulfateo SX amines and emulsion breakers. decyl alcohol. minimal amounts of acid in barrels. used oil in drums and overpacks
4.7 Boiler Facilities
The main building (approximately 12,400 square feet) is located on the west side of the Mill site
and contains air compressors and water treatment facilities. To the north of the main building isa -building which houses a propane-fired boiler. The vanadium oxidation tank, oxidation
thickener, and pH adjustment tank are located south of the boiler house facilities.
4.7.1 Electrical
The main electrical panel for the boiler house is located outside of the building, on the southwall.
4.7.2 Fire Protection System
Jhe lre protection system for the boiler facilities is comprised of strategically located portable
dry chemical extinguishers.
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INTERNATIONAL URANIUM (USA) CORPORATION
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4.8 Sample Plant
The sample plant building (approximately 8,000 sqlare feet) is located on the ore pad, east of the
ryai-ntglpce shop/warehousg building. The sampling plant equipment has been-removed from
the building and it is currently used as a storage area for maintenance.
4.8.1 Electrical
The electrical panel for this building is located on the east wall upstairs.
4.8.2 Fire Protection System
There are no extinguishers or sprinkler systems in the sample plant.
5. ORGANIZATION AND RESPONSIBILITIES
The organizational chart for an emergency situation is illustrated in Figure 2.
5.1 MillManager/IncidentCommander
The Incident Commander has the responsibility for:
o preparing an Emergency Plan. communicating the Plan,o directing activities during emergencies; and,. reporting to local, State and Federal authorities.
The Incident Commander will stop routiqe radio usage upon leaming of an emergency and set upthe base station in a safe location for directing activiti-es. Radio -usage will b-e tiririteO to ttemergency. The Incident Commander has the responsibility to contact a-il outside services.
The Incident Commander has the responsihility to account for all employees at the Mill, usingthe assistance of sLpervisors and/o1 any Intemational Uranium (USA) -Corporation
1"f-lsa')personnel. - Tle Iryident Commander [ras the responsibility for'the n"*r il"Oiu *b refort6directly to the President of IUSA.
5.2 MiIl General Superintendent
The Mill General S ,Perintendent has the responsibiflty of directing outside emergency personnelgd la_q-lhgrespon{bility fo. plant security and will ieport directl--y to the Incide-nt Cbmmander.The Mill General Superintendent will act as Incident-Commandlr in the absence of the MillManager.
5.3 Radiation Safety OfficerlFire Chief
The-Radiation Safety Officer will direct re.scue operations and provide the necessary emergency
medical personnel and facilities to cope with theimergency. Adequately trained fiie crew-s and
operable emergency equipment will be maintained at all tim-es.
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TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 I WHITE MESA MrLL EMERGENCY RESpoNsE PLAN I pun" 9 of t3
As Fire Chiel the Radiatiol Slfety Officer has the responsibility to maintain trained fire crews
and operable equipment, mobilize and direct the fire crews and eluipment in a fire emergency or
one containing the threat offire, and to assist in evacuation and rescue or recovery operutio.rs.
In the absence of the Radiation Safety Officer, the Mill Safety Coordinator.will assume theseduties.
5.4 Maintenance Supervisor
The Maintenance Supervisor will direct all.personnel in evacuation and in activities to cope withthe.emergency, including isolation of utilities and providing technical advice as needed. The
Maintenance Supervisor will be assisted by the Mill Safety coordinator.
5.5 Laboratory Supervisor
The.Laboratory. Superviso{ hq the_responsibility to direct and account for all office personnel(including IUSA persorurel and office visitors) in evacuation and in activities to cope with theemergency. In.case of a mill tour the Supervisor accompanying the tour will be responsible for
evacuation of visitors.
5.6 Shift Foremen
QhiR E'^.o- ;- ^!.---- .,-+il +L^ I-^iJ^-r /.\^---^--.r^-- - ----t- -. , rurrrrr r vrvrrrvrr 6v rrr vrraEw wMr Lrrv rlrvlurrlr \-url[tlilllutrI 4lrlvtrs itllu arg rgsponslDlg Ior allfunctions listed above. Shift Foremen haye lhe responsibility to account for all oith"ir people inaddition to any v^isito_rs, contractors, etc., in their ar-eas and report to the Incident Commander; or,in the absence of the Incident Commander, to administer all of the above duties.
5.7 Scale House Personnel
Scale house person on shift will be responsible to account for ore truck drivers and reagent truckdrivers.
5.8 Emergency Response Teams
The response cleJv Ql gugh operatingshift will normally consist of the following operators underthe direction of the shift foreman. This organization may be changed for individirai shifts subject
to the approval of the Fire Chief.
5.8.1 Operational Mode
Leach Operator
CCD Operator
Solvent Extraction Operator
Mill Trainee
5.8.2 Non-Operational Mode
Shift Foreman
Operations Personnel
Maintenance Personnel
P:\AdminMaster SOPs\Book I6_Emergency Response Plan\Emergency Response plan Rev I (09.29.05).doc
INTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29, 2005 I WHITE MESA MILL EMERGENCY RESPONSE PLAN I taee l0 of 13
Figure 2
Emergency Response Organizational Structure
6. SPECIFIC EMERGENCIES
The follorving details procedures to be followed during specific emergencies but are not limitedto the following.
6.1 Fire
Sh-guld a lre occur, the procedure outlined in Appendix A for reporting and responding to fireswill be followed. Particular areas of concern include:
o Solvent Extraction Building. Propane Tanks. Lab or Lab Storage Area
6.2 Chemical or Gas Release
The procedures for response to a chemical or gas release are outlined as Appendix B.
6.3 Earthquake
Although tht: i:.lighly unlikely, an earthquake could occur at the Mill. A severe earthquakecould.cause buildings and other structures to collapse, chemical and/or gas releases, majoifires
as well as.geryra.l-p-anic. In the event of a major earthquake the evacuatlon procedures "outlined
in Appendix C will be followed.
0perationalMode
Leach 0perator, CCD 0perator
SX 0perator, Mill Trainee
Non0perational Mode
Shifi Foreman, Openations Personnel
Maintenance Personnel
P:\AdminMaster SOPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev I (09.29.05).doc l0
INTERNATIONAL URANIUM (USA) CORPORANON
Rev. No.: R-l
Date: Sept 29,2005 WTIITE MESA MILL EMERGENCY RESPONSE PLAN Pase 1l of 13
6.4 TerroristlBomb Threat
In the event that any--person should receive a threat of a bomb, the following evacuationprocedure should be followed:
' Notiff .{-n{ Person of authority, i.e., Superintendent, Foreman, Radiation Safety Officer,who will immediately notiff law enfoicement autfrorities and evacuate the tireatened
area.. Evacuate all persons from the affected area and stop all radio transmissions.
6.5 Tailinqs Dam Break and Maior Floods
Flood water breaching tailings. embankments presents one of the greatest dangers for the suddenrelease of tailings solids a1r9 i*pgynded water. The tailings ".[r *" desigiled with sufficientfreeboard (1hre9 &qt)_1o^ryithstand back-to-back 100-year siorm events o, [oo of m" f.otuUi"maximum fpog (P.\4ry foilowed by the.-1.00-ygar storm event. The flood design is equiiAent to15 inches of rainfall. In addition, the tailings dikes were designed in accordanE" *itn U.S. NnCregulations and allow a sufficient margin oflafety even in theivent of an earthquake.
The possibility^of floods resulting from Westwater Creek, Cottonwood Creek, and Corral,Creek
causing a dam failure is extremely remote.
Tha fqifinoo nplle o-J AiVa- o-^ i--^^^+^J ^- L^+L ^ J-:t-. ^-J -r-:& !---:-vvrro Hru srrtwr qv urDPwwLUu ull uuLll ar Lrarl) alru srllrt oasls.
Discharges to- l djke failure would extend three miles before leaving IUSA's property. In theevent of a dam failure, large operating equipm^e$ yiU be mobilize"cl to construit temporaryearthen dikes or berms downgiadient-to -thb failed dike. In addition, the State of'Uiali,Department_olRadiation Control Executive Secretary (the "Executive Seiretary), MSHA, andState of Utah, Department ofNatural Resources, Division of Dam Safety shall be notified.
In the event of a seismic.ryptutg of tailing.s slurry pipelines, the released slurry will be containedin the tailings cells regardless of the quanlity releastd.
7. EVACUATION PROCEDURE (See Appendix C)
7.1 Notification
Employees will be notified to evacuate thg T."l by dialing 184 on any area telephone andannouncing that the Mill should be evacuated. This *nounceirent will be iepeated t,vice. Whenthe paging system cycles.through,lhe evacuation siren (continuous frequency) will automaticallysound f9r 3Rnro-ximately forty-five seconds, and ihen automatiialty'Jhut off, uiio*i;!communications by radio from.that -point. If the 184 number is dialed accid6ntally ihEevacuation alarm may b9 caqcgled by disconnecting the phone until the page cycle ends, then re-dial 184. (SeeExhibits 1 and2.)
7.2 Assembly
When the evacuation alarm sounds or
means, all personnel will assemble at:
when personnel are verbally notified by radio or other
. The parking lot south of the office,
P:\Admin\N4aster SOPs\Book l6-Emergency Response PIan\Emergency Response plan Rev I (09.29.05).doc ll
TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGINCY RESPONSE PLAI\ I pue. 12 of t3
The scalehouse,
North side of Tailings Cell l, or
North of the Mill
Assel?bly_site-will depend upon conditions, i.e. nature of the emergency, wind conditions, etc.
The Fire chief or Shift Foreman will specifr the appropriate assembly site.
7.3 Specific Procedure for Operations Personnel
1. See specific emergenly shutdown procedure for Operations by area under the relevant
Operating Procedure for your area.
2. All emplo-yees not mentioned under Operating Procedures are to immediately report tothe assembly area and congregate by ciew so that all persons can be accounted for. Asemployees leave their work areas, they must pass the, word to evacuate to any persons
who may not be aware of the emergency.
3. After the Mill has been determined to be safe for re-entry, employees will be verballynotified to return to their work stations.
8. Off-siteEmergencvEquipment/PersonnelRelease
Any-emergexcy response equiJ'ment or- persorurel that enter the Restricted Area in response to anincident will be scanned and decontaminated prior to leaving the site according to the proceduresincluded in PBL-9, End Dump Trliler Acceptance,-Handling and Release. A-ny equipment willbe decontaminated alc.ording to the requirernents found in Table I of the Nuitedr itegulatorybe decontaminated according to the requirements found in Table I of the Nu-ctedrCommission's INRC's) Policv and Guidance Direcrive FC-R5-?? ..GrrirCommission's (NRC's)licy and Guidance Directive FC-85-23, "Guidehnles fo.Decontamination of Facilities and Equipment Prior to Release for tinrestricted Use orTermination of Licenses for Byproduct, Source, or Special Nuclear Material" issued Mav 1987.Termination of Licenses for Byproduct,or Special Nuclear Material" issued May 1987.
Injured.personnel should be evaluated for radiation contamination, if there was a potential forcontamination, at the earliest convenience. Should it be necessary, contaminated articles will begathere-d by the radiological staff_after medical treatment has been rendered. If the personnel
cannot be decontaminated, notify the clinic/hospital personnel in advance.
9. EMERGENCY EQUIPMENT
Emergency equipment for the Mill is provided as follows.
9.1 Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-112" hose,two spanner wrenches, spray nozzles and one hydrant wrench.
. South of SX. West of CCD. North of Mill Building. East of pulp storage tanks. Northwest of Maintenance Shop. West of Warehouse
P:\Admin\Master SOPs\Book 16 Emergency Response Plan\Emergency Response PIan Rev I (09.29.05).doc 12
INTERNATIONAL URAMUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WHITE MESA MILL EMERGENCY RESPONSE PLAN I pre" 13 of 13
. East of office building
9.2 Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus are located at each of the following locations:
. Hose station east of office building. Hose Station South of SX. North End SX Outside Wall. North end of Mill building, outside wall
9.3 Spill Clean-up Equipment
Barrels of soda *h q" 19ryled tlyogs\yt the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near theIaboratory. The laboratory also contains acid spill kits and absorbent materials to be used in caseof a spill.
9.4 Fire Fighting PPE
Jwqgory_nlete-sets of turnout gear for fire fighting and/or emergency extrication are located in
the Fire Hose Station located on the east side of the office building.
9.5 Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
lafety- Cgo-rdinator perform.s regular spot checks on the emergency equiphent locations to ensure
that all of the equipment is in place.
10. EMERGENCY TRANSPORTATION
One fully-equipped First Responder Unit (Ambulance) located west of the office building.
Other motor pool v^ehicles orr the property will be utilized as needed in emergency situations withsupport as needed from the local Emergency Medical Services.
11. EMERGENCY DRILLS AND TRAINING
Quarterly drills, as required by MSHA, are prepared by the Safety and Radiation Departments tomonitor performance of personnel responding to emergency iituations. Each drill will beenacted upon one or more of the potential scenarios by thii plan. The drill and evacuation
activities are documented-by the Mill's Safety Coordinator and maintained within plant files.
Management will review all drills at quarterly ALARA committee Meetings.
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev I (09.29.05).doc l3
EXHIBIT 1
EMERGENCY NOTIFICATION LIST
ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR:
Give artifi cial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
scan the. injlo-"d F excessive alpha prior to transporting if time allows.(If alpha is excessive or there is no time to scan, notifu the clinicihospital personnel and theRadiation Safety Offi ce).
THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED:Blan_ding 9Iinic........... 679-2254 or 678-3434 (930 N. 400 W.)san Juan Hospital, Monticello .... 67 8-2830 or 597 -21 16 064 w. I st N.)'
EMT and CPR TRAINED - The following pelsonnel should be contacted, if they are on-site, in theevent of an emergency to aid in the event of anyinjuries to personnel.
David Turk - EMT and CPR trained
Mike Spillman - CPR trained
AMBULANCE SERVICEBlanding ...............:...Dial 911
If the COmnanv Am!-rulance is rrscrl q, ettcnAqnt mrrcr #rlo r,i+L rL- i-i,,--,I ;- ^J,t:+:^- +^ aL^ r-:-.^-
"*.Lpt;h#tft i,j;;;a;;;il;;;1yffiil;;;H; il;;;;iffi"1"'"" iii i'iuuiiiuii io ine onver,
OTHER EMERGENCY NUMBERS
Fire Department.......... Dial 91
County Sheriff....... ... Dial gl
Highway Patro1......... Dial 9l
Blanding Police ........ Dial gl
or 678-2313
or 587-2237
or 587-2000
,678-2916 or 678-2334
MANAGERS
The Supervisor will notifu one of the following of all incidents:
R.E. Bartlett 435-678-2495
D. Turk ..435-678-7802 or 435-4Sg-tO6BM. Spillman 435-678-2761
A MEMBER OF NIANAGEN4ENT WILL NOTIFY THE PROPER REGULATING AGENCIESAS REQUIRED TOR ETEHTNEIDENT:
state of Utah, Department of Radiation contro1.............901-53 6-42s0MSHA Field Off.-- 801 -524-3 450 Dist. Off. ............ ...... 303 -23 I -5 465MSHA, Arlington... 800-746-1553
State Emergency Response Comm. g0l-53g_3400
S-tate of Utah, Natural Resources, Dam Safety g0l-53g-7200
National Response Center....... ..800-424-gg02
Utah Poison Control Center ...... g00-456 -7707
Notification of surrounding communities and or residences will be handled by the appropriate agencies asrequired by EPCRA (Emergency Planning and community Right to Know Act). '
RevisionDate: January 16,2006 E-l
EXMBIT 2
INTERNAL NOTTFICATIONS
lnternal reporting requirements for lncidents, Spills and Significant Events are as follows:
Report Immediately:
Release of toxic or hazardous substanced.
Fire, explosions or other accidents.
Govemment investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or government requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $ 1,000,000.
Government investigation or enforcement action - limiting operation or penaltiesof $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled down time of more than}4 hours.
D^-^..a ^a 4L^ D--:__:_- - -Q L, L,r\Er,r,r r aL f,flC pEElllilrilE Ul r,ItC I\eX!, D)llslnesri frav:
lncident Criteria:
Was reported to a government agency as required by law.
Worker (ruSA or contractor) recordable injury or iliness associated with a release.Community impact - reported or awareness.
Publicity resulted or is anticipated.
Releas_e of process material, waste or product in
Quantities listed in Section 1.5 o-f the Spill
Countermeasures Plan.
excess of the Reportable
Prevention, Control, and
The local manager in charge is to call Ron Hochstein or Dave Frydenlund.
Name Title Office Phone Home Phone
Ron Hochstein (President and COO) ......303-628-7798 (office)
604-931-6334 (home)
604-377-r167 (cell)
David Frydenlund (v.P. and General counsel) .........303-3 8 9 -4r3o (office)
303-221-0098 (home)
303-808-6648 (cell)
Master soPs\Book l6-Emergency Response Plan\Emergency Response plan Rev 0 (02.14.07).E-2
EXHIBIT 3
SITE LAYOUT MAP
P:\AdminWlaster SOPs\Book l6-Emergenry Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-3
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EXHIBIT 4
MAIN SHUT-OFF VALVES
During an emergency this list should be used along with
tanks and valves associated with these tanks.
REAGENT SHUT-OFF VALVE LOCATIONS
Sulfuric Acid
Site Layout Map @xhibit 3) to locate
4" Main located south side of acid tank
East acid pump discharge valve
West acid pump discharge valve
3" Main (leach area) located 25 feet west of Derrick screens next to walkway
l-I12" Main (SX area) located south of Central Control room
Ammonia
4" Main (east tank) located on end at bottom
4" Main (west tank) located on end at bottom
2" Yalve located on top of tank (east tank)
2" Yalve located on top of tank (west tank)
Kerosene
2" Main valve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
2" Main valve located at bottom of tank (south tank)
Pump discharge 2" valve
Soda Ash
Main valve located at bottom of tank (dry storage)
4" Main valve located at bottom of tank on30Yo dilution tank
4" Main valve locate at bottom of tank on dilution tank
Salt
3" Main valve located at bottom of tank
Caustic Soda
3" Main valve located at bottom of tank east and west between supports
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-4
EXHIBIT 4
MAIN SHUT-OFF VALVES
Sodium Chlorate
3" Main valve located at bottom of tank (east tank)
3" Main valve located at bottom of tank (north tank)
3" Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3" Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
PLANr urrl,rry sHUr-oF',F VALVEIQCATIQNQ
Process Water
Main valve located on west side of water storage tank
Discharge valve offservice water pump east
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Main valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2" Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Steam
Main discharge valve for superior boiler located at top of boiler
Main steam valve located south side of boiler house
P:WdminMaser SOPs\Book l6-Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-4
EXHIBIT 4
MAIN SHUT.OFF VALVES
Plant Air
Main valve located at receiver tank in compressor room at boiler house
Main valve to mill building located south of Central Control room
PROCESS SHUT-OFF VALVE LOCATIONS
Pulp Storage
No. I valve located on west side of tank
No. 3 valve located on west side of tank
Preleach (old No. 2 pulp storage) valve located on west side of tank
Preleach Thickener
Main valve located underneath at center cone
Clarifier
Main valve located underrieath at center cone
Main valve located undemeath at center cone
CCD Thickeners
Main valve located undemeath at center cone of each thickener
P:\AdminWaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-4
2.
APPENDIX A
EMERGENCY PROCEDURE RESPONSE TO FIRE
The fire will be reported by dialing 185 on any telephone in the area and announcing the
location of the fire over the paging system. This announcement will be repeated twice,
for a total of three announcements. When the paging system cycles through, the fire siren
(alternating frequency) will automatically sound for approximately forty-five seconds
then automatically shut off, allowing radio communications to resume.
Mobilize the fire crew.
Evacuate all personnel.
Rescue any victims of the fire; do this only with properly trained and equipped personnel.
Isolate utility lines affected by the fire.
Extinguish the fire and post a fire watch for flare-ups.
Report the fire to proper local, State, Corporate and Federal agencies.
In cases where the fire is not extinguished within thirty minutes of discovery. the area
must be barricaded off after extinguishing and left undisturbed until released by MSHA
and IUSA management.
Emergency off-site centers - Blanding Fire House and Sheriffs office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 9l I
Sheriff s Office
50 West 100 South, Blanding
Phone number is 9l I or [phone]
5.
6.
7.
8.
A-IP:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc
APPENDIX B
EMERGENCY PROCEDURE
RESPONSE TO CHEMICAL OR GAS RELEASE
A chemical or gas release would most likely occur very suddenly. The person who would first
witness a chemical or gas release should immediately contact his supervisor who would initiate
the procedures outlined below:
l. Activate evacuation alarm by using the "dial l84" notification system. Evacuate and
account for all personnel.
2. Mobilize trained personnel and emergency equipment such as SCBA's, first aid
equipment, etc.
3. Initiate rescue operations for any people who may be trapped by the release.
4. Provide first aid and emergency medical care for any ill or injured persons.
5. Initiate necessary steps to contain and/or neutralize the release, such as spraying with
water fog, turning off valves, etc.
6. Guard against possible fires by shutting off electrical circuits, isolatins eas lines and
eliminating ignition sources from the affected area.
P:\Admin[\4aser SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
APPENDIX C
EMERGENCY EVACUATION PROCEDURE
1. Activate evacuation alarm by using the "dial 184" notification system. Evacuate and account
for all personnel.
2. Personnel are to assemble in one of the following areas:. The parking lot south of the office building. The scalehouse. The north side of Tailings Cell 1, or. North of the Mill
3. Mobilize trained personnel and emergency equipment such as SCBA's, first aid equipment,
etc.
4. Initiate rescue operations for any people who may be trapped.
5. Provide first aid and emergency medical care for any ill or injured persons.
6. Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from the affected area.
P:\AdminWaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
FIGURE 1
r.IRE SYSTEM SCHEMATIC DRAWING
P:\Admin\lrlaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
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EMERGENCY RESPONSE PLAN
REYISION 1.1
Denison Mines (USA) Corp.
'v'vlhite lvf e s a ivf ill
Blanding, Utah
April 14, 1986
REVISED
February 16,2007
Distribution List:
1.
2.
J.
4.
5.
6.
7.
8.
Ron F. Hochstein
Rich E. Bartlett
David Turk
Michael Spillman
Mill Shift Foremen
Blanding Fire Department
San Juan County EMS Coordinator
State of Utah, Department of Radiation Control
Revision Date: January 16,2006
TABLE OF CONTENTS
1.0
2.0
3.0
4.0
Evacuation Procedure ................17.1 Notification ....................17.2 Assembly... .....................1
7 -3 Specific Procedures for Operations Personnel...........................................1
Off-Site Emergency Equipment/Personnel Release ........1
Page
Number
E-l
E-2
E-3
E-4
5.0
6.0.
7.0
8.0
9.0
10.0
I 1.0
EXHIBITS:
l. Emergency Notification List2. Intemal Notifications3. Site Layout Map4. Main Shut-off Valves
APPENDICES:
A. Emergency Procedure Response to FireB. Emergency Procedure Response to chemical or Gas ReleaseC. Emergency Evacuation Procedure
FIGURES:
l. Fire System Schematic
A-l
A-2
A-3
F-l
I1
TNTERNATIONAL URANIUM (USA) CORPORATION
Rev. No.: R-l
Date: Sept 29,2005 | WIIITE MESA MILL EMERGENCY RESPONSE PLAN I Paee 1 of 13
l.INTRODUCTION
This Emergency Response Plan is written not only to comply with Federal, State and local
regulations, but even more importantly to reduce the risk to our employees and that of the
community in regards to Health, Safety and Environmental Emergencies.
This plan includes the following:
o evaluation of the potential risks for fire, explosions, gas releases, chemical spills and
floods (including tailings dam failure);. specific emergency programs for each potential event;. definition of administrative response actions; and,. definition of the emergency response contacts - both internal and external.
The White Mesa Mill (the "Mill") operates under the following regulatory agencies:
o Utah State Department of Environmental Quality, Division of Radiation Control;. Mine Safety and Health Administration;o Environmental ProtectionAgency;o Utah State Department of Environmental Quality, Division of Air Quality; and,. Utah State Division of Natural Resources Bureau of Dam Safety.
2. WHITE MESA MILL OVERVIEW
The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and
vanadium. In addition to the processing of conventional ores, the Mill also processes alternate
feed materials using similar process steps and chemicals. The conventional ore is stored on the
Ore Pad (shown in Exhibit 3). Alternate feed materials are also stored on the Ore Pad and may
be stored in bulk form, lined burrito bags, liners or drums. The descriptions of each alternate
feed material are maintained by the Mill's Radiation Safety Officer.
The Mill utilizes a semi-autogenous grind circuit followed by a hot sulfuric acid leach and a
solvent extraction process to extract uranium and vanadium from ores, using large amounts of
sulfuric acid, sodium chlorate, kerosene, amines, ammonia and caustic soda in the process The
reagent storage tank locations are described in further detail in Section 4.6.
Emissions from the Mill process are in the form of air emissions from exhaust stacks and
solid/liquid tailings which are stored in the Mill's tailings cells located west/southwest of the
main Mill building. The major exhaust stack parameters are shown in the following table.
Descriotion
Height
(ft from surface)
Diameter
(inches)
Estimated Flow Rate
(cfm)
Leach Exhaust -100 36 13,700
Yellow Cake Drying
(3 stacks)
-85 t8 4,000 per stack
Vanadium Roasting &
Fusion
-85 38 4100
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev I (09.29.05).doc
INTERNATIONAL URANIUM (IJSA) CORPORATION
Rev. No.: R-l
Date: Sept 29, 2005 I WHITE MESA MrLL EMf,RGENCY RESPONSE PLAI\ | nug" 2 of 13
There are also smaller exhaust stacks associated with the Laboratory in the Mill Administrationbuilding and the boiler exhaust stack.
The Mill's_tailings cells.are comprised of four below grade engineered cells, Cell 1-I, 2,3 and4A Liquids are-stored in Cell l-I and Cgll 3, the active tailings cell. The liquid in the iailingscells is very acidi_c.- In addition to the tailings cells, there is alio an emergency lined catchmeit
basin west of the Mill building. Solutions in this basin or the tailings ceilJshoirld not be used tofight fires in the Mill facility.
The_products-.of the Mill include ammonium metavanadate (AMV), vanadium pregnant liquor(vll:),^vanadium pentoxide (vr9.r), and yellowclke, or uranium concentrate 0;o8). The Vro,
and-U-rO, products are-packaged in-gleel. drums for shipment. The AMV is pa6kdged in eitirei
steel drums or super-saks while the VPL is sold in liquid- form in bulk.
Master files containing Material Safety Data Sheets for all materials in use at the Mill aremaintained at the Safety Office, Mill Maintenance Office, Mill Laboratory and Mill Central
C_ontrol RggT. Copies are also on file althe Blanding Clinic, Doctor's Offices, Blanding Fire
House and office of the San Juan county Emergency Medical coordinator
The nearest residence to the Milt is approximately one mile to the north of the Mill, the next is a
residen^ce_ app.roximately two. mills north of $e Mill, followed by the community of White Mesa,about 3.5 miles to the south. The City of Blanding is located approximately 6 miles to the
northeast.
The Mill site is near_lftah State Highway l9l and can be accessed by a paved access road fromthe highway to the Mill facilities.
3. PLAN OBJECTIVES
The primary objectives of this plan are:
1. To save lives,. prevent inj-uries,_prevent panic, and minimize property/environmental
damage to the lowest possible level.
2. To evacuate and account for all people in the area including visitors, truck drivers,
contractors, etc.
3. To provide assembly areas that are as safe as possible and which can be reached withouttraveling lhroqgh a hazardous area. Assemblyareas will be properly manned to deal withsick or injured persons, and provisions will be made to evaiuate those persons to proper
shelter.
4. To make adequately.ttuln"9 personnel available to cope with rescue and recovery
operations as directed by the Incident Commander.
4. DESCRIPTION OF FACILITIBS
The Mill facilities are shown on the Site Layout Map included as Exhibit 3.
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4.1 Fire Water Supply and Alarm Systems
4.1.1 Fire Water Supply
The fire water supply facilities include:
. !00,0p^0 ga-llo-1 Storage Tank of which 250,000 gallons are reserved for fire emergencies. Centrifu.gal- diesel driven pump rated at 2,000 gpm at 100 psi. This pump starts
automati_cally w!e.n the pressure in the fire main drops below 100 psi (See Figure l, Fire
System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm.
4.1.2 Alarm System
The alarm systems include the following:
o public address system. hand held radios. siren.
4.2 C)ffice Buildinq and Laborator,v
4.2.1 Office Building
Th-g gffic-e building (approximately 10,000 square feet) contains the administration offices,radiation health and safety offices and the Mill laboratory. The central file vault and the main
computer system are also in this building. The ambulance is kept on the west side of the offrcebuilding near the safety office entrance.
4.2.2 Laboratory
The laboratory facilities contain the following:
. three flammable cabinets (keys required)o chemical storage room south of main lab. six fume hoods - hoods 1,2,3 and 4 are in the center of the laboratory and hoods 5 and 6
are along the west wall. Hoods I and 2 are no longer in service. Hbods 3 and 4 are on
lhe wes] side, I and2 arc on the east side of the center cluster of hoods with2 being infront. Only hoods 5 and 6 may be used for perchloric acid.o outside laboratory chemical storage north of office building (key required). perchloric acid storage vault located underground west of offrce buiiding (key required)
A wide^variety.of chemicals in small quantities are located in the laboratory. These chemicalsrange from acids -to bases- along .with flammable metal compounds and peroxide formingcompounds. Oxidizers unq organic chemicals, which have a strong poteniial of producin[
t *FJ vapors if the containers are damaggd to the point that the cfiemicals are exposed arEstored.in a storage room .in.the laboratory. There are no acids stored in this storage room. The
acids.(including-but not limited to sulfuric, nitric, acetic, perchloric, phosphoric and'hydrochloric
acids) are stored in the main laboratory area in 2.5 liter or 500-ml Sottles. MSDS books for all
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chemicals in the laboratory are located in the Laboratory, Safety Department, Mill Maintenanceoffice and Mill Central Control room.
4.2.3 Electrical
Electrical transformers and electrical switches are located in the laboratory at the east end of thechemical storage room.
4.2.4 Fire Protection System
The fire protection systems in the office building and laboratory include:
o a fire hose station located on the east end of the office building. The station includes twosets of turnout gear, two SCBA units and Incident Commandeimaterials- -
o automatic "wet" sprinkler system which is actuated at2l2. Fo portable dry chemical extinguishers strategically located throughout the building.
4.3 Solvent Extraction Building
The solvent extraction (SX) building (ap-proximateJy 21,000 square feet) houses the uranium andvanadium solvent extraction circuits anitltre ELUEX ciicuit. ffr. SX .i..riir -uV "ortui;;il;200,000 gallons kerosene (757,000liters ) which has a flash point of l g5. F. -"'J
Associated^equip.m-ent in th: SX. building includes a temporary boiler located at the southwestend of the sX building which maintains tfie temperature roi ttre hr",vrt*.
chemicals which may be encountered in the SX building include:
o Keroseneo Caustic Soda. Anhydrous Ammoniao Sulfuric Acido Salt (Brine)o Soda Asho Ammonium Sulfateo Amineso Alcoholo Sodium Chlorateo Sodium Vanadate. Propane
The VPL product is stored in the SX building.
4.3.1 Electrical
All electrical switches are located outside in the MCC room north of the SX building.golt{9l panel for all of the equipment is located in the Central Control nootn i" it "building.
4.3.2 Fire Protection System
The SX building fire protection systems include:
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o a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212F.o portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure I in this Plan.
4.4 Mill Building
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
o Caustic Sodao Anhydrous Ammonia. Sulfuric Acido Soda Ashr Ammonium Sulfate. Sodium Chlorate. Sodium Vanadateo Propane
The finished products which are contained in the mill building include AMV, VrO, and UrO, (or
yellowcake).
4.4.1 Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west comer of the mill building. Circuit control panels are located in the SAG mill control room,
the central control room, the vanadium roaster control room and the AMV area.
4.4.2 Fire Protection System
The main mill building fire protection systems include:
r portable dry chemical extinguishers strategically located throughout the building.. water hoses throughout the building.
For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System
Schematic included as Figure 1 of this Plan.
4.5 Maintenance Shop/Warehouse/ChangeRoom Buildinq
This building (approximately 20,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located on the south end of the
building) and the personnel change rooms and lunch/training room (located on the extreme south
end ofthe building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
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o the main maintenance shop area contains welding and cutting equipment, lathes, presses,
and drill presses.
a carpenter shop which contains various saws and planes. Fiberglass work is also done
within this shop area and it is located at the northwest end of the maintenance shop area.
an electrical shop which is located south of the carpenter shop.
a heavy equipment maintenance shop area is located at the north end of the maintenance
shop in the center of the building.
a rubber room for rubber lining of equipment is located east of the equipment shop area.
the maintenance shop office, instrument shop and tool room are loCated at the south end
of the maintenance shop area.
The warehouse area contains primarily dry good storage for repair parts and consumables for the
operation of the Mill. There is an electrical water heater for the change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in the
following locations:
. small quantities of flammable material such as starting fluid and spray paint are kept in
the warehouse.
drums of new oil and anti-freeze are stored along the east wall of the equipment
maintenance area and on the east side of the warehouse on oil storage racks.
used oil is stored in a tank located northeast of the equipment shop. The tank has a
capacity of approximately 5,800 gallons.
in the main maintenance shop area and the rubber room there are flammable storage
cabinets and east of the warehouse there is a trailer which is used to store flammable
items such as rubber cements, paints and fiberglass resins.
compressed gas cylinder storage, both empty and full is located outside, east of the
maintenance shop.
Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is located
on the east wall inside the Maintenance shop. Auxiliary eltctrical panels for the c[ange room
and warehouse are located in the southwest comer of the warehouse area.
4.5.2 Fire Protection System
The fire protection system within the maintenance shop/warehouse/change room building
includes:
. o'wet" automatic sprinkler system that releases at212" F.o portable dry chemical extinguishers strategically located
area, warehouse area and the change room and lunch room.
a
a
a
a
a
4.5.1
throughout the maintenance
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure l).
4.6 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
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' a sulfuric acid tank located northwest of the mill building which has a capacity ofapproximat ely 1.4 million gallons.o a sl91ag.9 1"rk pI propane is located on the north edge of the mill site, northwest of themill building. -It has a storage capacity of 30,000 galldns.
' four sodium chlorate tanks located east of SX bulilding-, north of the office building andeast of the pulp storage tanks. The two tanks east o-f the SX buildine aie for ro?i.nnchlorate storage and the other two tanks are for dilution of the sodium chiorate.' tw-g anhydrous ammonia tanks located east of the SX building, with capacity of 31,409gallons each.o three kerosene tanks located east of the SX building, with a capacity of 10,152 gallonseach.
' one caustic soda tank north of the SX building, with a capacity of 19,904 gallons.o three soda ash tanks which are located east oTthe SX Uriitaing. OnJt-anfiis tfre dry sodaash tank with a rypqcllv of 70,256 gallons. Two of the tankiare soda urn aitrtion turttwith capacities of 16,921gallons each.
' diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad.The gasoline storage capacity is 3,200 gallons, while dieset storage ;apacity is S;000gallons.
9tlt"-t reagents are stored in steel barrels or super sacs in a reagent yard located east of the officebuilding. Typical reagents which are stored inthis yard include:
. polymers and flocculants. boiler feed water chemicalso methanolo tributyl phosphate. "dirty" soda ash and ammonium sulfateo SX amines and emulsion breakers. decyl alcohol. minimal amounts of acid in barrels. used oil in drums and overpacks
4.7 Boiler Facilities
The main.building (approximately 12,400 square feet) is located on the west side of the Mill siteand contains air compressors and water treafment facilities. To the north of the *ui" U"ifOi"g-i,a .building *-hig!, houses a propane-fired boiler. The vanadium oxidation
-iunt,
o*iAutionthickener, and pH adjustment iank are located south of the boiler house acitities. -
4.7.1 Electrical
The main electrical panel for the boiler house is located outside of the building, on the southwall.
4.7.2 Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically located portabledry chemical extinguishers.
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4.8 Sample Plant
The sample plant buildilB (appro.ximately 8,000 square feet) is located on the ore pad, east of themaintenance shop/warehouse building. The sampling plant equipment has been'removed fromthe building and it is currently used as a storage aiea for maintenance.
4.8.1 Electrical
The electrical panel for this building is located on the east wall upstairs.
4.8.2 Fire Protection System
There are no extinguishers or sprinkler systems in the sample plant.
5. ORGANIZATION AND RESPONSIBILITIES
The organizational chan for an emergency situation is illustrated in Figure 2.
5.1 MillManagerflncidentCommander
The Incident Commander has the responsibility for:
. preparing an Emergency Plan. communicating the Plan,o directing activities during emergencies; and,o reporting to local, State and Federal authorities.
The Incident Commande^r will stop routine radio usage.upon Earning of an emergency and set upthe base station in a safe locatioh for directing activiti^es. Radio "usage will b"e tiririted to thiemergency. The Incident Commander has the responsibility to contact a'il outside services.
The Incident Commander has the responsibility to account for all-employees at the Mill, usingthe assistance. of-superviso:s and/or -any Intemational Uranium (USA) 'Corporation 1'ffuSaipersonnel. - The Incident Commander has the responsibility for'the news media anb report(directly to the President of IUSA.
5.2 Mill General Superintendent
The lvlill.General Superintendent has the responsib.i-l-ity of directing outside emergency personnelga !a-q.pl responsjbilify for plant security and will ieport directiy to the Incideit C"ommander.The Mill General Superintendent will acf as Incident-Commander in the absence of the MillManager.
5.3 Radiation Safetv Officer/T'ire Chief
The.Radiation Safety Officer will direct re.sgug operations and provide the necessary emergencymedical personnel and facilities to-cope with the emergency. Adequately trained fire crews andoperable emergency equipment will be maintained at all tim-es.
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1,1
As,Fire Chief, the Radiatiol !{ety Officer has the responsibility to maintain trained fire crewsand operable equipment, mobilize and direct the fire crews and equipment in a fire emergency orone containing the threat of fire, and to assist in evacuation and reicue or recovery op..utlom.' --
In the absence of the Radiation Safety Officer, the Mill Safety Coordinator will assume theseduties.
5.4 Maintenance Supervisor
The Maintenance Supervisor will direct all.personnel in evacuation and in activities to cope withthe.emergency, including !-lolation of utiliiies and providing technical advice as needed. TheMaintenance Supervisor will be assisted by the Miil Safety cdordinator.
5.5 Laboratory Supervisor
The. Laboratory. Supervisor has. the responsibility to direct and account for all office personnel(including IUSA personnel and office visitors) in evacuation and in activities to copei with theemergency. In.case of a mill tour the Supervisor accompanying the tour will be resfonsiUi foievacuation of visitors.
5.6 Shift Foremen
Shift Foremen are in charge until the Incident Commander arrives and are resrronsible for alltunctions listed above. Shlft Foremen have the. responsibiliiy i; ;.;;;i f"r uil #i't.ir p"opl" inaddjtion to any visito_rs, contractors, etc., in their a:ras and report to the Incident ComminaJr; oi,in the absence of the Incident Commander, to administer all of the above auti.r. - -
5.7 Scale House Personnel
Scale house person on shift will be responsible to account for ore truck drivers and reagent truckdrivers.
5.8 Emergency Response Teams
The response crew f91 9a9h operating shift will normally consist of the followine operators underthe direction of the shift foreman. This organization may be changed for individ"u"irfrim rrUj".ito the approval of the Fire Chief.
5.8.1 Operational Mode
Leach Operator
CCD Operator
Solvent Extraction Operator
Mill Trainee
5.8.2 Non-OperationalMode
Shift Foreman
Operations Personnel
Maintenance Personnel
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Figure 2
Emergency Response Organizational Structure
6.SPECIFIC EMERGENCIES
The following details procedures to be followed during specific emergencies but are not limited
to the following.
6.1 Fire
Should a fire occur, the procedure outlined in Appendix A for reporting and responding to fires
will be followed. Particular areas of concem include:
r Solvent Extraction Building. Propane Tanks. Lab or Lab Storage Area
6.2 Chemical or Gas Release
The procedures for response to a chemical or gas release are outlined as Appendix B.
6.3 Earthquake
Although this is highly unlikely, an earthquake could occur at the Mill. A severe earthquake
could cause buildings and other structures to collapse, chemical and/or gas releases, major fires
as well as general panic. In the event of a major earthquake the evacuation procedures outlined
in Appendix C will be followed.
Operational Mode
Leach 0perator, CCD 0perator
SX 0perator, Mill Trainee
Non0perational Mode
Shift Foreman, Operations Personnel
Maintenance Personnel
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o
6.4 Terrorist/Bomb Threat
In the event that any..person should receive a threat of a bomb, the following evacuationprocedure should be followed:
. Notify .{.n{ Person of authority, i.e., S^uperintendent Foreman, Radiation Safety Officer,who will immediately notiff law enfoicement authorities and evacuate the t'hreatened
area.. Evacuate all persons from the affected area and stop all radio transmissions.
6.5 Tailings Dam Break and Maior Floods
Flood water breaching tailings embankments presents one of the greatest dangers for the suddenrelease of tailings solids uT4 i-pgqrded water. The tailings ceils are desiglea wittr sufficientfreeboard (!|""q p9t)_to-ryithstand back-to-back 100-year slorm events or {oyo of the frotablemaximum n^oo{ Q-tvtQ followed by the.1.00-ygar storm event. The flood design is equivalent io15 inches of rainfall. In addition, the tailings dikes were designed in accordani" *ittrU.S. NnCregulations and allow a sufficient margin of safety even in theivent of an earthquake.
The possibility^o.f floods resulting from Westwater Creek, Cottonwood Creek, and Corral,Creekcausing a dam failure is extremely remote.
The tailings cells and dikes are inspected on both a daily and shift basis.
Discharges to- l dike failure would extend three miles before leaving IUSA's property. In theevent of a dam failure, large operating equipment will be mobilizelcl to consiruct temporaryearthen dikes or berms downgradient-to -the failed dike. In addition, thi Siate "f-Ut"fiDepartm_e_nt olRadiation Control Executive Secretary (the "Executive Sefreta.y), VSUa, *.iState of Utah, Department of Natural Resources, Division of Dam Safety stratt Ue'riotineO.
In the event of a seismic .rupture of tailing.s slurry pipelines, the released slurry will be containedin the tailings cells regardless of the quantity releijed.
7. EVACUATION PROCEDURE (See Appendix C)
7.1 Notification
Employees will be notified to evacuate th9 g-.1 by dialing 184 on any area telephone andannouncing that the Mill should be evacuated. This announceirent will be iepeated twice. Whenthe paging system cycles.through, the evacuation siren (continuous frqquencf; wiliautomaticallysound for approximately forty-five seconds, and then automatiially "Jfr"i off, ;1i;ffi4communications by radio from-that-point. If the 184 number is dialed accid6ntaily -t-hE
evacuation alarm may be canceled by disconnecting the phone until the page cycle ends, then re-dial 184. (See Exhibits I and 2.)
7.2 Assemblv
When the evacuation alarm sounds or when personnel are verbally notified by radio or othermeans, all personnel will assemble at:
. The parking lot south of the office,
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. The scalehouse,. North side of Tailings Cell l, or. North of the Mill
Assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions, etc.
The Fire Chief or Shift Foreman will speciff the appropriate assembly site.
Specific Procedure for Operations Personnel
l. See specific emergency shutdown procedure for Operations by area under the relevant
Operating Procedure for your area.
2. All employees not mentioned under Operating Procedures are to immediately report to
the assembly area and congregate by crew so that all persons can be accounted for. As
employees leave their work areas, they must pass the word to evacuate to any persons
who may not be aware of the emergency.
3. After the Mill has been determined to be safe for re-entry, employees will be verbally
notified to return to their work stations.
Off-Site Emergency Equipment/Personnel Release
Any emergency response equipment or personnel that enter the Restricted Area in response to an
incident will be scanned and decontaminated prior to leaving the site according to the procedures
included in PBL-9, End Dump Trailer Acceptance, Handling and Release. Any equipment will
be decontaminated according to the requirements found in Table I of the Nuclear Regulatory
Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines for
Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Injured personnel should be evaluated for radiation contamination, if there was a potential for
contamination, at the earliest convenience. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, notifu the cliniclhospital persorurel in advance.
9. EMERGENCY EQUIPMENT
Emergency equipment for the Mill is provided as follows.
9.1 Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-l/2" hose,
two spanner wrenches, spray nozzles and one hydrant wrench.
. South of SX. West of CCD. North of Mill Building. East of pulp storage tanks. Northwest of Maintenance Shop. West of Warehouse
8.
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. East of office building
9.2 Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus are located at each of the following locations:
. Hose station east of office building. Hose Station South of SX. North End SX Outside Wall. North end of Mill building, outside wall
9.3 Spill Clean-up Equipment
Barrels of soda ash are located throughout the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near the
laboratory. The laboratory also contains acid spill kits and absorbent materials to be used in case
of a spill.
9.4 Fire Fighting PPE
Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in
the Fire Hose Station located on the east side of the office building.
9.5 Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure
that all of the equipment is in place.
10. EMERGENCY TRANSPORTATION
One fully-equipped First Responder Unit (Ambulance) located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations with
support as needed from the local Emergency Medical Services.
11. EMERGENCY DRILLS AND TRAINING
Quarterly drills, as required by MSHA, are prepared by the Safety and Radiation Departments to
monitor performance of personnel responding to emergency situations. Each drill will be
enacted upon one or more of the potential scenarios by this plan. The drill and evacuation
activities are documented by the Mill's Safety Coordinator and maintained within plant files.
Management will review all drills at quarterly ALARA Committee Meetings.
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EXHIBIT 1
EMERGENCY NOTIFICATION LIST
ATTEND TO ANY INJURED PERSONS AND NOTIF'Y THE SUPERVISOR:
Give artificial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
Scan the injured for excessive alpha prior to transporting if time allows.
(If alpha is excessive or there is no time to scan, notify the clinic/trospital personnel and the
Radiation Safety Office).
THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED:
Blanding Clinic ........678-2254 or 678-3434 (930 N.400 W.)
San Juan Hospital, Monticello ....678-2830 or 587-2116 (364 W. lst N.)
EMT and CPR TRAINED - The following personnel should be contacted, if they are on-site, in the
event of an emergency to aid in the event of any injuries to personnel.
David Turk - EMT and CPR trained
Mike Spillman - CPR trained
AMBULANCE SERVICEBlanding Dial9l I
If the Company Ambulance is used, an attendant must ride with the injured in addition to the driver
except where the injured could normally be transported in a car or pickup.
OTHER EMERGENCY NUMBERS
Fire Department............. Dial 9l
County Sheriff....... ... Dial 9l
Highway Patro1......... Dial9l
Blanding Police ........ Dial 9l
or 678-2313
or 587-2237
or 587-2000
,678-2916 or 678-2334
MANAGERS
The Supervisor will notifr one of the following of all incidents:
R.E. Bartlett 435-678-2495
D. Turk ..435-678-7802 or 435-459-1068
M. Spillman 435-678-2761
A MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING AGENCIESAS REQUIRED FO-R EAEHINEIDENT:
State of Utah, Department of Radiation Control. 801-536-4250
MSHA Field Off.--801 -524-3450 Dist. Off. ............ ...... 303 -23 I -5465
MSHA, Arlington... 800-746-1553
State Emergency Response Comm. 801-538-3400
State of Utah, Natural Resources, Dam Safety 801-538-7200
National Response Center........ .800-424-8802
Utah Poison Control Center ......800-456-7707
Notification of surrounding communities and or residences will be handled by the appropriate agencies asrequired by EPCRA (Emergency Planning and Community Right to Know Act).
Revision Date: January 16,2006 E-l
EXHIBIT 2
INTERNAL NOTIFICATIONS
lntemal reporting requirements for lncidents, Spills and Significant Events are as follows:
Report Immediately:
Event Criteria:
Release of toxic or hazardous substances.
Fire, explosions or other accidents.
Government investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or govemment requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $ 1,000,000.
Government investigation or enforcement action - limiting operation or penalties
of $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled down time of more than 24 hours.
Report at the Beqinninq of the Next Business Dav:
Incident Criteria:
Was reported to a govemment agency as required by law.
Worker (ruSA or contractor) recordable injury or illness associated with a release.
Community impact - reported or awareness.
Publicity resulted or is anticipated.
Release of process material, waste or product in excess of the Reportable
Quantities listed in Section 1.5 of the Spill Prevention, Control, and
Countermeasures Plan.
The local manager in charge is to call Ron Hochstein or Dave Frydenlund.
Name Title Office Phone Home Phone
Ron Hochstein (President and COO) .........................303 -628 -7 7 98 (office)
604-931-6334 (home)
604-377-1167 (cell)
David Frydenlund (V.P. and General Counsel) ..... -...303 -3 8 9 -4130 (office)
303-221-0098 (home)
303-808-6648 (cell)
Master SOPs\Book l6-Emergency Response Plan\Emergency Response Plan Rev O (02-14.07).E-2
l,)r.trrl'rl J
SITE LAYOUT MAP
P:\AdminWaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-3
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EXHIBIT 4
MAIN SHUT.OFF VALYES
During an emergency this list should be used along with Site Layout Map (Exhibit 3) to locate
tanks and valves associated with these tanks.
REAGENT SHUT-OFF VALYE LOCATIONS
Sulfuric Acid
4" Main located south side of acid tank
East acid pump discharge valve
West acid pump discharge valve
3" Main (leach area) located 25 feet west of Derrick screens next to walkway
l-112" Main (SX area) located south of Central Control room
Ammonia
4" Main (east tank) located on end at bottom
4" Main (west tank) located on end at bottom
2" Ya'tve iocateci on top of tank (east tank)
2" Valve located on top of tank (west tank)
Kerosene
2" Mainvalve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
2" Main valve located at bottom of tank (south tank)
Pump discharge 2" valve
Soda Ash
Main valve located at bottom of tank (dry storage)
4" Main valve located at bottom of tank on30Yo dilution tank
4" Main valve locate at bottom of tank on dilution tank
Salt
3" Main valve located at bottom of tank
Caustic Soda
3" Main valve located at bottom of tank east and west between supports
P:\AdminWlaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-4
EXHIBIT 4
MAIN SHUT.OFF VALVES
Sodium Chlorate
3" Main valve located at bottom of tank (east tank)
3" Main valve located at bottom of tank (north tank)
3" Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3" Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
PLANT UTILITY SHUT.OFF VALVE LOCATIONS
Process Water
Main valve located on west side of water storage tank
Discharge vaive offservice waier pump east
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Main valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2" Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Main discharge valve for Superior boiler located at top of boiler
Main steam valve located south side of boiler house
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E-4
EXHIBIT 4
MAIN SHUT-OFF VALVES
Plant Air
Main valve located at receiver tank in compressor room at boiler house
Main valve to mill building located south of Central Control room
PROCESS SHUT-OFF VALVE LOCATIONS
Pulp Storage
No. I valve located on west side of tank
No. 3 valve located on west side of tank
Preleach (old No. 2 pulp storage) valve located on west side of tank
Preleach Thickener
Main valve located underneath at center cone
Clarifier
Main valve located
Main vaive iocated
CCD Thickeners
Main valve located undemeath at center cone of each thickener
undemeath at center cone
uncierneath at center cone
P:\Admin\Master SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc E4
t.
2.
J.
4.
APPENDIX A
EMERGENCY PROCEDURE RESPONSE TO FIRE
The fire will be reported by dialing 185 on any telephone in the area and announcing the
location of the fire over the paging system. This announcement will be repeated twice,
for a total of three announcements. When the paging system cycles through, the fire siren
(altemating frequency) will automatically sound for approximately forty-five seconds
then automatically shut off, allowing radio communications to resume.
Mobilize the fire crew.
Evacuate all personnel.
Rescue any victims of the fire; do this only with properly trained and equipped personnel.
Isolate utility lines affected by the fire.
Extinguish the fire and post a fire watch for flare-ups.
Report the fire to proper local, State, Corporate and Federal agencies.
In cases where the fire is not extinguished within thirty minutes of discovery, the area
mi:st be bariicaded off after extingiiishing and left undisturbed iintil released by I"f SHA
and IUSA management.
Emergency off-site centers - Blanding Fire House and Sheriff s office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 9l l
Sheriff s Office
50 West 100 South, Blanding
Phone number is 911 or [phone]
5.
6.
7.
8.
9.
A-tP:\Admin\Master SOPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc
APPENDIX B
EMERGENCY PROCEDURE
RESPONSE TO CHEMICAL OR GAS RELEASE
A chemical or gas release would most likely occur very suddenly. The person who would first
witness a chemical or gas release should immediately contact his supervisor who would initiate
the procedures outlined below:
1.
2.
Activate evacuation alarm by using the "dial 184" notification system. Evacuate and
account for all personnel.
Mobilize trained personnel and emergency equipment such as SCBA's, first aid
equipment, etc.
Initiate rescue operations for any people who may be trapped by the release.
Provide first aid and emergency medical care for any ill or injured persons.
Initiate necessary steps to contain and/or neutralize the release, such as spraying with
water fog, turning off valves, etc.
Guard against possible fires by shutting off electrical circuits, isolating gas lines and
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3.
4.
5.
6.
P:\AdminMaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
4.
5.
6.
APPENDIX C
EMERGENCY EVACUATION PROCEDURE
l. Activate evacuation alarm by using the "dial 184" notification system. Evacuate and account
for all personnel.
2. Personnel are to assemble in one of the following areas:. The parking lot south of the office building. The scalehouse. The north side of Tailings Cell 1, or. North of the Mill
3. Mobilize trained personnel and emergency equipment such as SCBA's, first aid equipment,
etc.
Initiate rescue operations for any people who may be trapped-
Provide first aid and emergency medical care for any ill or injured persons.
Guard against possible fires by shutting off electrical circuits, isolating gas lines and
eliminating ignition sources from the affected area.
P:\Admin\N,Iaster SOPs\Book l6_Emergency Response Plan\Emergency Response Plan Rev 0 (09.29.05).doc A-l
FIGURE 1
F'IRE SYSTEM SCHEMATIC DRAWING
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DENISON MINES (USA) CORP
BOOK #9
RADIATION PROTECTION
MANUAL
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White Mesa Mill - Standard Operating Procedures
SOPPBL.RP-I
Book 9: Radiation Protection Manual. Section I
1.0 RADIATION MONITORING - PERSONNEL
Date: 2107 Revision: DUSA-2
Page I of l8
This section contains the following procedures for personnel radiation monitoring
including: (1) airborne particulates (2) alpha surveys (3) beta/gamma surveys and (4)
urinalysis surveys.
1.1 AIRBORNE PARTICULATES
Sampling for personnel exposure to airbome particulate radionuclides, other than for
radon progeny, will be done utilizing two distinct sampling protocols: (1) personnel
breathing zone samplers, and (2) ambient air high volume samplers. Specific standard
operating procedures for these two collection methods are described in Section 1.1.2 and
1.1.3 below.
1.1.1 Frequency
For work where there is the potential to cause airbome radiation doses to site personnel,
the frequency and type of air sampling to be conducted is determined from measured air
concentrations:
O.OI DAC _ O.I DAC
> 0.1 DAC
Quarterly or monthly area air sampling and/or bioassay
measurements
Continuous sampling is appropriate if concentrations are
likely to exceed 0.10 DAC averaged over 40 hours or
longer.
The RSO will determine the exact frequency of area air sampling, breathing zone
sampling and/or bioassay measurements and determine how many workers in a group of
workers performing similar jobs are to be equipped with breathing zone air samplers.
Higher airborne concentrations warrant more frequent use of area air samplers, bioassay
measurements, and breathing zone air samplers. Area air samplers may be used where
documentation exists showing the sample is equivalent to a breathing zone sample.
Breathing zone samples taken within one foot of the worker's head are considered
representative without further documentation. Breathing zone air samplers are preferred
under work conditions of higher airborne concentrations. Table 1.1.1-1 below, from
Regulatory Guide 8.25, provides additional guidance for the RSO in designing and
implementing air sampling programs for specific jobs.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-I
Book 9: Radiation Protection Manual, Section I
Date: 2107 Revision: DUSA-2
Page 2 of l8
Table 1.1.1-1
Air Sampling Recommendations Based on Estimated Intakes and Airborne Concentrations
Worker's Estimated
Annual Intake as a
Fraction of ALI
Estimated Airborne
Concentrations as a
Fraction of DAC
Air Sampling Recommendations
< 0.1 < 0.01
> 0.01
Air sampling is generally not necessary.
However, monthly or quarterly grab samples or
some other measurement may be appropriate to
confirm that airbome levels are indeed low.
Some air sampling is appropriate. Intermittent or
grab samples are appropriate near the lower end
of the range. Continuous sampling is appropriate
if concentrations are likely to exceed 0.1 DAC
averaged over 40 hours or longer.
> 0.1 < 0.3
> 0.3
Monitoring of intake by air sampling or bioassay
is required by l0 CFR 20. I 502(b).
A demonstration that the air samples are
representative of the breathing zone is appropriateif (l) intakes of record will be based on air
sampling and (2) concentrations are likely to
exceed 0.3 DAC averaged over 40 hours (i.e.,
intake more than l2 DAC-hours in a week).
Any annual intake >l
>5
Air samples should be analyzed before work
resumes the next day when potential intakes may
exceed 40 DAC-hours in I week. When work is
done in shifts, results should be available before
the next shift ends. (Credit may be taken for
protection factors if a respiratory protection
program is in place.)
Continuous air monitoring should be provided if
there is a potential for intakes to exceed 40 DAC-
hours in I day. (Credit may be taken for
protection factors if a respiratory protection
prosram is in place.)
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual. Section I
Date: 2107 Revision: DUSA-2
Page 3 of l8
1.1.2
1.1.2.1
Breathing Zone Sampling
General
Breathing zone samplers (SKC pumps and accessory kits, or equivalent) are used to
determine airbome exposure to uranium while individuals are performing specific jobs.
The units consist of a portable low volume pump that attaches to the individuals belt,
tygon tubing and filter holder that is attached to the individual's lapel or shirt collar. The
unit monitors airbome uranium in a person's breathing zone. Pumps must be recharged
after 6 to 8 hours ofuse.
1.1.2.2 Applicability
Breathing zone samples are required:
a
a
for all calciner maintenance activities,
at least quarterly during routine operating and maintenance tasks on
representative individuals performing these tasks,
when radiation work permits are issued in which airborne concentrations may
exceed 25Vo of l0CFR20limits,
weekly for yellowcake operations, or
at the discretion of the RSO.
1.1.2.3 Procedure
The procedure for collecting a breathing zone sample is as follows:
1. Secure the breathingzone sampler, which has been charged and loaded with a filter
paper from the radiation department.
2- Secure the pump to the worker's belt and the filter holder to the shirt collar or lapel.
Try to secure pump tubing to minimize restriction of motion.
3. Turn pump on (record the time pump was tumed on) and continue monitoring until
the work being monitored is completed and the worker no longer is in the "*posurearea. Record the time at which the job is complete.
4. Return the pump and accessories to the RSO, who will remove the filter paper foranalysis. Be sure to indicate accurately the total time taken by the work being
monitored.
5. Analysis of filter samples will be performed using a sensitive alpha detector. The
procedure is as follows: (a) count a background sample for ten minutes; (b) divide the
a
a
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-I
Book 9: Radiation Protection Manual, Section I Page 4 of l8
background count by ten to obtain the background count rate in cpm; (c) Place the
breathing zone sample in the instrument and count the sample again for ten minutes;
(d) divide the sample count by ten to obtain the count rate in cpm; (e) subtract the
background count rate from the sample count rate; and, (f) record all data on the
Breathing Zone sampling analysis form (a copy of which is attached).
Record the total hours of exposure that are being assigned to the employee on the
Employee Exposure form, which is maintained in personnel folders. Be sure to
consider protection factors permitted by respirator use if the employee was also
wearing respiratory protection during the job.
The number of DAC hours assigned is calculated using the following formula:
DAC hours = Measured air concentration x Total hours of exposure
of exposure (DACXPF)
where:DAC = Derived Air Concentration (for uranium; l0 CFR Parr 20,
Appendix B)
PF = protection factor for respirator
protection was used PF =1.
The measured air concentration must be in uCi/cc.
If no respiratory
1.1.2.4 Calihration
Prior to use, calibration of the breathing zone samplers will be done using the Bubble
Tube Calibration method, described in Section 3.2.1.
1.1.2.5 Equipment - Breathing Zone Sampler
The equipment used for breathin E zofie samples consists of:
l. Personal sampling pumps
2. Gelman 37 mmDelrin filter holders, or equivalent
3. Gelman 37 mm type AIE glass fiber filters, or equivalent
4. Kurz Model 543 air mass flow meter, or equivalent
1.1.2.6 Data Record
Data maintained on file includes:
1. Time on and off for each sample pump.
2. Sampling location(s).
Date'. 2107 Revision: DUSA-2
6.
7.
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-2
SOPPBL-RP.I
Book 9: Radiation Protection Manual, Section I page 5 of l g
3. Individual's name, identification number, etc.4. Date and sample number.
5. Sample count rate.
1.1.2.7 Calculations
The airborne concentration in uCilcc is equal to the sample count rate minus the
background count rate in cpm divided by the instrument alpha efficiency, the sample flow
rate in cclminute, the sample time in minutes and a conversion factor converting dpm to
uCi.
The calculation is:
Equation Number l:
Airborne concentration = (Count Rate)
(Time)((eff)(conversion factor)(Flow Rate)
i.e. uCi = (cpm-Bke) I uCi (l) (1)
cc ((eft)(Z.22x106dpm)(cclmin)(min)
where: (eff = cpm/dpm for counting instruments
cpm = counts/min
dpm = disintegrations/min
conversion factor I uci = Z.22xlA6 dpm
Flow Rate = cclmin
Collection time = min
Once the airbome concentration has been calculated it is possible to calculate personnel
exposure in microcuries (uCi). Personnel exposure is determined for an individual who is
working in an area at a known air concentration (uCi/cc) for a given amount of time
(hours) breathing the area air at an assumed rate. The breathing rate for a standard person
(Handbook of Radiological Health) is 1.20 cubic meters per hour 1m3/hr;.
The calculation for personnel exposure is:
Equation Number 2:
Exposure uci = (uci/ccX 1.2Om3lhr;lhours of exposure)(conversion rate)
where: uCi/cc = air concentration from Equation 1
l.2O m3lhr = breathing rate for standard man (ICRp)
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-I
Book 9: Radiation Protection Manual, Section I Page 6 of l8
hours of exposure = hours
conversion factor = 106cc/m3
It is also possible to determine the percent or fraction of the Derived Air Concentration
(DAC) for a particular radionuclide using the information obtained from the exposure
calculation and dividing this value by the regulatory limit DAC listed in 10 CFR Parr20.
VoDAC = Exposure in uCi/uCi limit 10 CFR Part 20
For the natural uranium (U-NaO the DAC limits from 10 CFR Part 20 for insoluble Class
Y compounds are as follows:
Date: 2107 Revision: DUSA-2
. Weekly
. Quarterly. yearly
1.0 x 10-3 uCi/week
1.25 x 10-2 uCi/Qt
5.0 x 10-2 uCi/yr
1.1.2.8 ALARAlQuality Control
The RSO reviews each monitored result and initiates action if levels exceed 257o of lO
CFR 20 limits. At a minimum, ten percent (lo7o) of the air samples collected in a given
quarter will be recounted using the same instrument or using a different instrument and
these results will be compared to the original sample results. Deviations exceeding 307o
of the original sample results will be reviewed by the RSO and the samples will be
recounted again until the sample results are determined to be consistent. Additional QA
samples consisting of spiked air samples, duplicate samples and blank samples will be
submitted to the radiation department for counting. This will be based on ten percent
(lUVo) of the number of samples collected during a quarter. The sample results will be
compared to the spiked values, duplicate values, or blank (background) values of the
prepared sample. Deviations exceeding 30Vo of the determined spiked, duplicate or blank
value will be recounted. If no resolution of the deviation exceeding 3O7o is made the QA
samples preparation will be repeated. Periodic reviews by the RSO and the ALARA
audit committee will be made and documented to ensure quality maintenance and
ALARA control.
1.1.3 Airborne Uranium High Volume Sampling
Grab air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airbome
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sample pump will be
used for this purpose. Samples will be analyzed as per standard gross alpha analysis
procedures using a sensitive alpha detector.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-I
Book 9: Radiation Protection Manual, Section I Page 7 of l8
1.1.3.1 Frequency and Incations
The following principles used for the collection of area grab samples must be considered
when collecting a sample in order to obtain a representative air concentration that workers
may be exposed to during their assigned work tasks.
1. The locations selected for sampling should be representative of exposures to
employees working in the area.
2. For special air sampling, the sampling period should represent the conditions during
the entire period of exposure. This may involve sampling during the entire exposure
period.
3. For routine sampling, the sampling period must be sufficient to ensure a minimum
flow rate of 40 liters per minute for at least 60 minutes.
4. Sample filters will be analyzed for gross alpha using a sensitive alpha detector.
5. Grab sampling procedures may be supplemented by use of Breathing Zone Samples
for special jobs or non-routine situations.
1.1.3.2 Sampling Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40
liters per minute for one hour or longer. Equipment utilized will be and Eberline RAS-I,or a Scientific lndustries Model H25004, or equivalent. Filter media will have a
maximum of 0.8 micron pore diameter. Equipment is calibrated prior to each usage as
per Section 3.6 of this manual.
1.1.3.3 Sampling Procedure
Steps for collection of area airborne grab samples are as follows:
1. A high volume pump will be used for sample collection.
Check sample pump calibration.
Locate sampler at designated site.
holder on the sampler. Do not
operating conditions at the site.
Date: 2107 Revision: DUSA-2
lnsert a clean filter, using tweezers, into the filter
contaminate the filter. Log start time and Mill
2.
J.
4. Collect a sample for a minimum of 60 minutes at a flow rate of 40 liters per minute.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I
5. After sampling is completed, carefully remove the
filter holder and place it in a clean glassine envelope,
with the filter.
Datei 2107 Revision: DUSA-2
Page 8 of l8
filter, using tweezers, from the
or in the plastic casing furnished
6.
7.
Log all sample data on the log sheet.
A. Sample location and number (also on the envelope).
B. Time on, time off and date.
C. Mill operating conditions at the site.
D. Sampler's initials.
Analyze for gross alpha
1.1.3.4 Calculations
Perform calculations as described in Section 1.1.2.7.
1.1.3.5 Records
Logs of all samples taken are filed in the RSO's files. Data are used to calculate radiation
exposures as described in Section 4.0.
Whenever grab sampling results indicate that concentrations in work locations exceed
257o of the applicable value in 10 CFR Part20, Appendix B, time weighted exposures of
employees who have worked at these locations shall be computed. Calculations will
reveal an individual's exposure in DAC hours. This value shall be assigned to the worker
and logged onto the worker's "Employee Exposure to Airborne Radionuclides" form.
This form is in Section 4. Whenever special air sampling programs (as required for
cleanup, maintenance, decontamination incidents, etc.) reveal that an employee has been
exposed to airborne radioactive material, the calculated value shall also be entered on the
individual's exposure form.
1.1.3.6 Quality Assurance
Calibration checks on each air sampler, prior to field use, ensure accurate airflow
volumes. Use of tweezers and new filter storage containers minimizes contamination
potential. Field logging of data during sampling and logging of identifying data on
sampled filter containers minimizes sample transposition. Quality control samples will be
analyzed as described in Section 1.1.2.8
Review of data by the RSO and by the ALARA Audit committee further assures quality
maintenance.
1.2
1.2.1
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-I
Book 9: Radiation Protection Manual. Section I
Date: 2107 Revision: DUSA-2
Page 9 of l8
500 to 750 dpm/100 cm2 to
the low efficiency of this
ALPHA SURVEYS
Restricted Area
The Restricted Area is defined as:
1. The property area within the chain link fence surrounding the mill property and the
area enclosed to the north and east of the facility by the posted Restricted Area fence.
2. The active tailings and liquid waste disposal areas.
All personnel who enter the Restricted Area will monitor themselves each time they leave
the Restricted Area and at the end of their shift. The Radiation Safety Department will
review the monitoring information. All personnel exiting the Restricted Area must initial
a record of their monitoring activity.
1.2.2 Instrumentation
The instrumentation utilized for personnel alpha scanning is listed in Appendix I at the
end of this manual. Personnel alpha survey instruments are located at the exits from the
Restricted Area.
1.2.3 Monitoring Procedures
The monitoring procedure includes the following steps:
1. The alarm rate meter is adjusted within the
ensure a margin of 250 dpm/100 "*'instrumentation.
range of
due to
2. An individual monitors himself by slowly passing the detector over their hands,
clothing and shoes, including the shoe bottoms, at a distance from the surface of
approximately V+ inch. An area that is suspected of possessing any contamination (i.e.
hands, boots, visible spotting/stain on clothing etc.) should be carefully monitored by
placing the detector directly on the surface and note the measurement.
3. Should
should:
a.
b.
an alarm be set off indicating the presence of contamination, the individual
Resurvey themself to verify the contamination.
If contamination is present the individual must wash the affected area and
again resurvey themself to ensure the contamination has been removed.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I Page l0 of l8
If the decontamination efforts by the individual are not successful, then the Radiation
Safety personnel will be contacted to assess the situation. Further decontamination
may be required.
If an individual's clothing cannot be successfully decontaminated, they must obtain
clothing from the warehouse to use and must launder the personal clothing in the
laundry room.
Individual surveys are to be logged and initialed.
t.2.4 Training
All employees will be trained on the proper scanning procedures and techniques.
1.2.5 Records
Log sheets will be collected daily and filed by the Radiation staff. Records will be
retained at the Mill. Contamination incidents will result in a written record, which is
maintained on file.
1.2.6 Limits/ALARA
Contamination limits for personnel scans are set at 1,000 dpm/100 square centimeters.
Records will be reviewed by the RSO to maintain levels noted as low as reasonable
achievable.
1.2.7 Quality Assurance
A random check of an individual's scarming technique provides quality assurance of the
monitoring procedures. Daily function checks using calibrated sources assures
instrumentation performance. Periodic review by the RSO and the ALARA audit
committee document and ensure quality control and ALARA maintenance.
BETA-GAMMA SURVEYS
Site employees working within the Restricted Area will be required to wear a personal
monitoring device (such as a TLD, LUXEL badge or other NVLAP approved device
which has been approved by the RSO and the SERP) during their work period. The
personal monitoring devices are normally issued to each employee quarterly; however,
during pregnancy or if the radiological potential for exposure to an individual is
anticipated to be elevated and requires quick assessment the badges may be issued
monthly.
Datei 2107 Revision: DUSA-2
4.
5.
6.
1.3
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP.I
Book 9: Radiation Protection Manual, Section I Pagellofl8
1.3.1 Monitoring Procedures
The monitoring procedures consist of:
1. Personnel issued personal monitoring devices will wear the device on the trunk
(torso) of the body or visibly on the exterior of their hard hat. The personal
monitoring device records beta/gamma radiation as well as other forms of penetrating
radiation such as x-rays. A personal monitoring device is an exposure record of an
individual's personal exposure to radiation while on the job. Therefore, personal
monitoring devices are to remain at the Mill in the personal possession of each
individual, in a locker or other secure area. All exposure records obtained by a
personal monitoring device which are not consistent with the exposure rates of work
tasks or work location measurements made throughout the Mill will be evaluated by
the RSO. This evaluation will result in an investigation by the RSO and a written
explanation of the findings. These written records will be maintained at the Mill.
2. Personal monitoring devices will be issued at a minimum quarterly and will be
exchanged by the Radiation Safety Department. Missing or lost badges will be
reported to management.
3. Female employees that become pregnant and continue to work during the course of
their pregnancy will be placed on a monthly personal monitoring device exchange
during this period. NRC Regulation Guide 8.13 provides guidelines to be followed
during pregnancy and is made part of this procedure.
1..3.2 Records
The Radiation Safety Department will maintain all occupational exposure records in the
departmental files:
l. Occupational exposure records are a part of an individual's health record and, as such,
will be considered private information.
An individual may examine his/her exposure record upon request.
An employee terminating his/her employment with Denison Mines (usA) corp. may
request a copy ofhis/her occupational exposure records.
The Radiation Safety Department on the signature of the employee will request prior
occupational exposure records.
Occupational exposure records will be made available to authorized company or
regulatory personnel.
Date: 2/ 0l Revision: DUSA-2
2.
3.
4.
5.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I
Date: 21 07 Revision: DUSA-2
Page 12 of l8
1.3.3 Quality Assurance
Periodic reviews by the RSO and the ALARA audit committee document and ensure
quality control and maintenance of conditions ALARA.
1.4
1.4.1
URINALYSIS SURYEYS
Frequency
Urinalyses will be performed on those employees that are a) exposed to airborne
yellowcake or involved in maintenance tasks during which yellowcake dust may be
produced, or b) routinely exposed to airborne uranium ore dust. Baseline urinalyses will
be performed prior to initial work assignments.
Urine samples are collected on a routine basis from mill employees as required in
Regulatory Guide 8.22. Urine samples will be collected from employees who have
worked in yellowcake packaging, yellowcake precipitation, grind area (SAG mill), ore
feed, sample plant, scale house, and the sample preparation room every two weeks during
production periods. Samples will be collected from all other employees monthly during
production periods. During non-production periods, bi-weekly samples will be collected
if individual exposures are expected to exceed 25Vo of the DAC value otherwise samples
will be collected from all employees quarterly. Non-routine urinalyses will usually be
performed on employees who have been working on assignments that require a Radiation
Work Permit, and always on any individual that may have been exposed to airbome
uranium or ore dust concentrations that exceed the 25Vo of the DAC level.
I.4.2 Specimen Collection
Clean, disposable sample cups with lids will be provided to each employee that will be
required to submit a urine specimen. The containers will be picked up at the
administration building before the individual enters the Restricted Area.
The container, filled with specimen, will be returned to the bioassay laboratory prior to
reporting to work. The name of the employee and the date of collection will be indicated
on the specimen cup.
A valid sample must be collected at least 40 hours, but not more than 96 hours, after the
most recent occupancy of the employee's work area (after two days, but not more than
four days off).
The specimen should be collected prior to reporting to the individual's work location. To
prevent contamination, the hands should be carefully washed prior to voiding.
White Mesa Mill - Standard Operating procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I
Under unusual circumstances where specimens cannot
worker will shower immediately prior to voiding.
1.4.3 Sample Preparation
Equipment required:
Date: 2107 Revision: DUSA-2
Page 13 of 18
be collected in this manner, the
. 15 ml disposable centrifuge rubes with lids. l0 ml pipette. 5 ul pipette. 10 ul pipette. Disposable tips for the above pipettes. Spiking solution - 0.03 or 0.02 g/l of uranium in de-ionized water
After the specimens are received, they will be stored in a refrigerator until they areprepared for analysis.
Sample preparation will be done in an area decontaminated to less than 25 dpm alpha(removable) per 100 cm2 prior to preparation of samples. All of the equipment that is
used in sample preparation will be clean and maintained in such condition.
A log will be prepared and the following information will be kepr for each urinalysis
performed:
S ample identification number
Name of employee submitting the specimen
Date of sample collection
Date the sample was sent to the laboratory
Date the results were received
Results of the urinalysis in ug/l
Indication of any spike used in ug/l
The centrifuge tubes will be marked with a sample identification number. 10 millilitersof urine will then be pipetted into the centrifuge tube using the pipette device. (To
prevent contamination, a new tip must be used for each specimen.) After each step of theprocedure, the proper entry must be made in the logbook.
The samples that are to be spiked for quality assurance purposes will then be prepared.
The spikes will be introduced into the sample with 5 ul or l0 ul pipettes. A new tip mustbe used with each spike- with the standard spike solution (0.03 g/l of U), a 5 ui spikewill result in a 15 ug/l concentration for the 10 ml sample; the l0 ul spike will give 30ug/l). The proper entry must be made in the logbook for each sample spiked.
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-2
SOPPBL-RP.I
Book 9: Radiation Protection Manual, Section I Page 14 of l8
After preparation has been completed, the QA samples are securely packaged as soon as
practicable and sent to the contract laboratory for analysis.
The samples that are to be analyzed in-house will be placed in the chemistry laboratory's
refrigerator until the analysis can be completed. A copy of the in-house analytical
procedure is described in Section I.4.7.6.
1.4.4 Quality Assurance
To assure reliability and reproducibility of results, at least 25Vo of the samples that are
submitted for analysis will be used for quality assurance purposes. These samples will
consist of spikes, duplicates, and blanks (samples collected from individuals known to
have no lung or systemic uranium burden).
Spiked samples will be prepared as stated under sample preparation of this procedure.
Duplicates will be identical samples of the same specimen and/or spikes of identical
concentrations.
To assure reliability of the in-house analytical procedure, l0Vo of the samples will be sent
to a contractor laboratory for analysis. These samples will contain quality assurance
items designed to provide intra-laboratory comparisons.
1.4.5 Analysis
After the samples are collected as outlined in Guide 8.22,they are identified to the lab by
collection date and number. Urinalysis results must be completed and reported to the
Radiation Safety Department within seven days of the sample collection.
1.4.5.1 Equipment List
l. Specimen collection cups with disposable lids (VWR No. 15708-711 or equivalent)
2. Screw cap, disposable, graduated 15 ml centrifuge tubes (Coming No. 25310 or
equivalent)
3. Micro-pipettes I each 5, 5 each 10 microliters (Oxford Model7000 or equivalent)
4. 20 ml Scintillation Vials
5. Disposable micro-pipette tips for micro-pipettes (Oxford No. 910A or equivalent)
6. Lab Oven
7. Hot Plate
8. Fume Hood
9. Ultrasonic Cleaner
IO. ICP-MS
White Mesa Mill - Standard Operating procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual. Section I
Date: 2107 Revision: DUSA-2
Page 15 of l8
reagent
11. Forceps with curved tips
1.4.5.2 Reagent List
1. l%otoZVoNitricAcid
2. Concentrated Nitric Acid
3. Perchloric Acid, Concentrated TOVo4. Wetting Agent
5. 1,000 ug/ml Uranium Stock Solution, certified vendor prepared6. Dilutions of the above stock solution, replaced bi-annually. Used for eA/ec.7. Appropriate Cleaning Solution for Ultrasonic Cleaner
Ensure that all reagents used are within their expiration dates listed on each
package, if applicable.
1.4.5.3 Premise
A portion of urine is digested in the presence of a strong oxidizer, and the sample is
heated at 550 degrees Celsius for Yz hour to destroy all organics and insure proper
oxidation state of any uranium present to allow the uranium to solubilize in a dilutematrix mix.
1.4.5.4 Safety Precautions
I Follow laboratory guidelines when working with acids.
L Utilize all appropriate PPE.
2- All digestions must be done under a working fume hood.
3- Working with perchloric acid in the presence of organic material can be hazardous.
Do not overheat to dryness. Excess nitric acid is required to insure all organic material
is destroyed prior to perchloric phase of digestion.
1.4.5.5 SamplePreparationProcedure
1. Compare sample numbering with bioassay result sheet to insure order and eliminate
discrepancies.
2. To 20 ml scintillation vials, add 5 mls instrument grade concentrated nitric acid and I
ml concentrated perchloric acid.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I Page 16 of l8
3. Maintaining sample order of left to right, front to back, lowest sample number to
highest sample number in the set, add 5 ml to 10 ml of sample to the scintillation vial.
4. Swirl the vial and place on hot plate, again maintaining the above stated sample order.
Hot plate should be set to allow sample to cook down for approximately 2 hours prior
to perchloric phase of digestion.
5. Cook samples down to perchloric salts. If there is any brown color left in the sample,
repeat digestion. It is important that wet ashing of sample is complete to insure
oxidation of the uranium.
6. Place the samples in oven at 550'C for at least Vzhour.
7. Remove samples from the oven, allow to cool and add 10 ml of lVo or 2Vo nitric acid
that has 0.27o wetting agent to the samples.
8. Heat the samples to digest salts.
9. Analyze using procedure on the ICP-MS described in section 1.4.7.6.
1.4.5.6 ICP-MS Procedures
Special considerations: Because of the high salt content of the samples, it is necessary to
clean the skimmer and sampler cones after each use.
1. Turn the argon on at the tank and set the delivery pressure at 80 pounds per square
inch (psi).
2. The ICP-MS is in a continuous standby mode because it is necessary to maintain a
vacuum on the detector. To move from the standby mode to the operating mode press
the ON button.
Special considerations: Because of the high salt content of the samples, it is necessary to
There are two turbo vacuum pumps that need to come up to speed prior to operating
the ICP-MS. While waiting for the pumps, purge the interface area with argon by
pressing the + and - buttons. The argon light will come on while the argon is
purging. It is a good idea to purge at least 3 times.
Turn on the exhaust fan and the water supply to the ICP-MS. The water supply has to
have a delivery pressure of 70 psi. It may be necessary to change the filters on the
water supply in order to achieve sufficient water supply pressure. The ICP-MS will
not operate below this pressure.
Turn on the computer and enter the Spectro program.
Date: 2101 Revision: DUSA-2
J.
4.
5.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I Page 17 of l8
6. Press the START button to start the ignition sequence. The ignition step is 60
seconds. At l0 seconds the vacuum pump for the interface starts. If the exhaust fan
is not on, the plasma will shut off a few seconds after ignition.
7. After the plasma ignites, the electronics go through a check loop. Avoid any input to
the computer during this time.
8. Under the instrument window in the generator parameters turn the pump on and setthe nebulizer flow to the appropriate amount determined from previous set up
operations.
9. Under Utilities, select the Scan Manager window. From this window, select the time
scan that has previously been set up for your operation.
10. Using the instrument settings, adjust or verify that the Rh Iine is about 3 X l6s counts.
Close and exit Scan Manager.
11. Under Measure, select Quantitative and then Bioanalysis.
12. After entering this window under Function, select Stand ardize Method and followprompts. After verifying standardization values are close to previous operation, begin
sample analysis.
13. Because of the nature of the sample, it is necessary to aspirate a blank in between
each sample. After 5 to 7 samples, the blank needs to be aspirated for a sufficient
time to clean the salt build up.
14. To begin sample analysis, press F2 or click the Start button at the bottom left side of
the window. Record the value and move to the next sample.
15' After the last sample, exit window and aspirate the blank long enough to clean the
lines and chambers.
16. Allow the pump to run long enough without aqueous uptake to void all lines and
chambers.
17. Tum the pump off and relax lines off of pump.
18. Push the STOP button to go back to the standby mode.
19. After 5 to 10 minutes turn off the water supply, exhaust fan and argon.
Date: 2107 Revision: DUSA-2
White Mesa Mill - Standard Operating Procedures Date:21O7 Revision: DUSA-2
SOPPBL-RP-I
Book 9: Radiation Protection Manual, Section I Page l8 of l8
All bioassay samples need to be analyzed three (3) working days from receipt in the
laboratory. Samples are extremely susceptible to contamination. Precautions should be
taken to minimize traffic and fugitive dust while samples are digesting.
Volume additions are made with an auto-pipette for which the calibration has been
checked.
1.4.6 Reporting and Corrective Actions
As soon as the analytical results are received, they are entered in the logbook and the
entries are checked for correctness and completeness.
The lab report is retumed to the Radiation Safety Department with results reported as
micrograms/liter of uranium. The information must be placed in the individual
employee's exposure file and maintained as directed by the DRC.
The Radiation Safety Department is notified immediately of any sample with a
concentration greater than 35 micrograms/liter of uranium. Corrective actions will be
taken when the urinary uranium concentration falls within the limits listed in Table I
(attached).
The Radiation Safety Department should compute the error on the control spiked samples
and advise the lab if the results are more than + 30Vo of the known values. If any of the
results obtained for the quality assurance control samples are in error by a + 3OVo, the
analysis must be repeated.
1.5 IN.VIVO MONITORING
ln-vivo body counting for lung burdens of U-natural and U-235 will not be routinely
conducted. Monitoring will be conducted at the discretion of the RSO in consultation
with DUSA management should potential exposure to an individual warrant.
!o Urinary Uraniunn
con6€ntrf,tion
Tabte I
COREECTTVE ACTIONS BASED ON MONT}ILY'UEINARY UBANTUM RESULTSA
lnterprerilion Actions
Less than t5 Ue/L
15 to 35 us/L
Uranium confi,ncment and air
sampling prcgrams iue
indicated to be adequate.b
Uranium confincment and air
samplirrg may not provide in
adequate s16gin of safety.b
Uranium con(inemcn! and
perhaps air sampling prosrEms
are not acceptable.c
Greatcr than 35 pg/L
Contirmed to be Ereater Workcr 6ay havc exceedcd
rhan 35 Ugill for two reguletory limit on intake-
consecutivc specimcns,
contirmcd to be
Cfeatcr than 130 pg/L
for eny single specimen,
or air sampling indica-
rion of rnore than a
qugrrerly limir of
inuke
None. Continuc ro rcyiew further bioasgy results-
1. Confirm rcoults (repeat ruinalysis)-
2- ldentify the causc of elcvgterl urinary urarrium and initi-
ate additional coarol rneasues if thr rcsult is confirmcd.3. E:camine air sampling data to detc$nfure the source aad
concentralion of intake. U air sempling fesults are
aflomalous, Llvesugatc sampling Procedures. Make correc-
rions if necessory-
4, Determine whether other work"o "6ul{ hgve been exposGd
and perform bioessay mensurEments for thern.
5- Consider work assignment limitatiorts until the worker's
urinary uranium concentration falls below t5 uell.6- Improve uranium contitrcmerrr controls or respiratory
protectron proSrem as invesdgarion indicates.
Ta](e the actiens givcrr above.
Cottinue operetions only if it is virtually certsin rh8n no
other worker will excocd a urinary uranium concentr&
tion of 35 ;rBlL
Fi$tablish work restriorions for affected employees or
increase uranium con-finement controls if ore dust ot
high-renperature-dricd yellowcake are involved-
Anelyze bioassuy samples wcckly-
l. Take the actions given above-7- Havc rrrine specirncn rested for albuminuria-
3. Obtairr an in vivo count if workcr ntay have becn cxposcd
to Class Y matcrial or ore dusi.4, Evrluatc exposures,
5. Estfblish further uranium confinenrent controls or
respiratory protection requirements as hdicated-6. Consider continucd work resuictions on sffected
employecs until rrrirary conccntrations are bclow 15 pell.
tsnd hboratory tests for albumlnuria are ncgative.
t..,
3-
oura Flgure t-, to idjutt etion tcwlS tot olhcr ftequcncier of biousy Brnpfisr& fhc modcl ued in NIJREG{E"4 (Ref. t) mDloyrtnctional composition vrluel (Fr 1 F, F=) for Cl*r D. Clrs W. and Ouss Y componenr: of yqUowcah+ eompouadc. Tha aesignad Yrlu€r
is NUREO{E?4 are bred oa dato frtm dvsilrbls liicrdtwB- Thc Ofe of alrstrathra irlues of F., Po, rnd F, Spminc for a partianler ogen-tion :re lcceDtaulc prouidcd (l) dctrits re8;rrding rteir dctermimtioGora &$d!cd and mcrrrlotrcdln empldycc rrDoturc teco3dr (se. pur-
Sriph 2o-4ol(cxt) of lo cFR Plrr 20) and (2) the flodcl a rublishcc ia NUREG{,8?{ is (r.n uEcdin rhc drrcrmistion of altmrtiw
urinslysit trequeacias snd scrion lev€ls.
bgo*"r"r, it ! pcsorl ir cxporad to rrronium ora duEt or ortcr mltatisl o( Closs W or Y alonc. rafcr lo Scctioa 6 of NUREC-o8?4ibout rhs poriibility of rtrc seed for corrducrirg il vivo luog counu oa' sclectcd personncl or Ebout using altcrttotlvc urin! stmplinE t'has
and aBosisled actio0 levcls Cortlputcd usrltg NUREG.08?{.
cunle$ thc rrsslt wos onricipured and coused by conditions alrard, cotrccted ;
t
eo,
F r.,=oo
(ct
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page I of20
RADIATION MONITORING . AREA
HIGH VOLUME AIRBORNE AREA AIR SAMPLING
Area air sampling involves passing a representative sample of air through a filter paper
disc via an air pump for the purpose of determining the concentration of uranium in
breathing air at that location. Although the process is only measuring airborne
concentrations at a specific place and at a specific time, the results can often be used to
represent average concentration in a general area. A high volume sampler or similar high
volume pump will be used for this purpose. Samples will be analyzed as per standard
gross alpha analysis procedures using a sensitive alpha detector.
2.1.1 Equipment
Monitoring equipment will be capable of obtaining an air sample flow rate of 40 lpm or
greater for one hour or longer. A variety of equipment may be used for area air sampling,
however normally the equipment used is an Eberline RAS-I, Scientific Industries Model
H25004, or equivalent. Filter media will have a maximum of 0.8 micron pore diameter.
Equipment is calibrated prior to each usage as per Section 3.6 of this manual.
2.1.2 Frequency/Locations
Area uranium dust monitoring frequency is monthly for the locations shown in Table2.r.2-t.
Table 2.1.2-l
Airborne Radiation Sample Locations
Darei 2107 Revision: DUSA- I
2.0
2.1
Code
BA1
BA2
BA7
BATA
BA8
BA9
BAIO
BA11
BA12
BAI24
BAI28
BA13
BAl3A
BA14
Location/Description
Ore Scalehouse
Ore Storage
SAG Mill Area
SAG Mill Control Room (radon only)
Leach Tank Area
Washing Circuit CCD Thickness
Solvent Extraction Building/Stripping Section
Solvent Extraction Building/Control Room
Yellowcake Precipitation & West Storage Area
North Yellowcake Dryer Enclosure
South Yellowcake Dryer Enclosure
Yellowcake Drying & Packaging Area
Yellowcake Packaging Enclosure
Packaged Yellowcake Storage Room
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date:2107 Revision: DUSA- I
Location/Description
Metallurgical Laboratory Sample Preparation Room
Lunch Room Area (New Training Room)
Change Room
Administrative Building
Warehouse
Maintenance Shop
Boiler
Vanadium Panel
Vanadium Dryer
Filter Belt/Rotary Dryer
Tails
Central Control Room
Shifter's Office
Operator's Lunch Room
Dump Station
Filter Press
Truck Shop
Page 2 of 20
Code
BAI5
BA16
BA17
BA18
BA19
BA2O
BA21
BA22
BA22A
BA23
BA24
BA25
BA26
BA27
BA28
BA29
BA3O
Areas BA-10 and BA-12 are soluble uranium exposure areas. These areas are areas
where the uranium compounds that are produced are soluble in lung fluids and are
comparatively quickly eliminated from the body. All the other areas are insoluble
exposure areas. lnsoluble uranium areas are areas where the uranium compounds are not
readily soluble in lung fluids and are retained by the body to a higher degree.
Temperature of drying operations has a significant impact on solubility of uranium
compounds. High drying temperatures produce insoluble uranium compounds. Area
uranium dust monitoring, during production periods, is weekly in the designated
yellowcake production areas. Monitoring increases to weekly in other monitored areas
with the observance of levels exceeding 257o of 10 CFR 20 limits and reverts to monthly
upon a continued observance of levels below 25Vo of 10 CFR 20 limits as determined by
the RSO.
The RSO will designate those areas involved in area monitoring during non-production
periods. Non-production period monitoring becomes effective one month following the
cessation of production.
Annually, the licensee shall collect, during mill operations, a set of air samples covering
eight hours of sampling, at a high collection flow rate (i.e., greater than or equal to 40
liters per minute), in routinely or frequently occupied areas of the mill. These samples
shall be analyzed for gross alpha. In addition, with each change in mill feed material or at
least annually, the licensee shall analyze the mill feed of production product for U-Nat,
Ra-226 and PB-210 and use the analysis and results to assess the fundamental constituent
composition of air sample particulates.
White Mesa Mill - Standard Operating procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 2107 Revision: DUSA-l
Page 3 of20
3.
4.
2.1.3 Sampling Procedures
l- A RAS-I or similar high volume pump shall be used for area grab sampling. Insure
the pump has been recently calibrated within the past month.
2. The locations selected for area air samples should be representative of exposures to
employees working in the area.
For routine sampling, the sampling period should be for a minimum collection
duration of 60 minutes at a flow of 40 lpm or greater.
lnsert a clean filter into the filter holder on the sampler. Note start time of pump and
record unusual mill operating conditions if they exist.
A. Stop sample collection and note time. Normally, an automatic timer is
connected to the sampler and a I hour sample collection time is used.
6. Remove the filter from the sampler and place in a clean glassine envelope or the
package supplied by the manufacturer for delivery to the Radiation Department.
7 - Count the sample by gross alpha counting techniques and enter the result and
sampling information into the record.
2.1.4 Calculations
Perform calculations as specified in Section 4.0.
2.1.5 Records
Logs of all samples taken are filed in the Radiation Safety Officer's files. Data is utilized
to calculate radiation exposures as specified in Section 4.0.
2.1.6 Quality Assurance
Calibration checks on each air sampler are made at least monthly to ensure accurate
airflow volumes are being collected. Usage of tweezers and new filter storage containers
minimizes contamination potential. Field logging of data during sampling and logging of
identifying data on sampled filter containers minimizes sample transposition. Samptes
may periodically be submitted for chemical analysis and a comparison of these results to
the radiometric measurements will be made.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Review of data by the RSO and by the ALARA audit committee
maintenance.
Date: 2lO7 Revision: DUSA- I
Page 4 of 20
further assure quality
))
2.2.1
RADON PROGENY
Definitions
Working Level:
A. The exposure to 1.3E + 05 MEV of alpha energy or the potential alpha energy
in one liter of standard air containing 100 pCi each of RaA (Polonium-218), RaB
(l-ead-214), RaC (Bismuth-214), and RaC prime (Polonium-214). (Exposure
level, not a dose rate)
Kusnetz Method: Method of radon progeny measurement and calculation based
upon a 10 liter sample and at least 40 minutes decay time before counting.
2.2.2 Equipment
The equipment utilized consists of the following, or appropriate equivalents:
. Portable personal sampler. Gelman 25 mm filter holder with end cap. Gelman Type A/E 25 mm diameter glass fiber filters. Counter-Scaler - Eberline MS-3 with SPA-I probe
2.2.3 Frequency/Location
Radon progeny samples are obtained monthly at those locations included for area
particulate uranium monitoring during production periods. Monitoring is increased to
weekly upon observance of levels exceeding 25Vo of l0 CFR 20 limits. Monitoring is
reduced to monthly upon the continued observance of levels below 257o of 10 CFR 20
limits. During non-production periods, monitoring is done monthly for only those
locations occupied by personnel where exposures may have the potential of exceeding
25Vo of 10 CFR 20limits. The RSO shall so designate those areas to be monitored during
non-production periods.
2.2.4 Procedures
The procedures to be utilized are as follows:
1. Assemble filter trains.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP.2
Book: Radiation Safety Manual, Section 2
2. Ensure pump batteries are fully charged.
3. Calibrate pump (see Section 3.5).
Datei 2107 Revision: DUSA-l
Page 5 of20
4. Attached filter trains at sample locations; disconnect end plug.
5. Collect sample in the breathing zone of the employee.
6. Collect sample for five minutes at 4.0lpm.
7. Log sample site, time started, time stopped, and filter pump number prior to leaving
each site on the field log notebook.
8. Samples are counted between 40 minutes and 90 minutes after collection using
sensitive alpha detector.
9. Check the calibration and function check information to ensure the detector is
calibrated and operating.
If the calibration check correlates, proceed with sample analysis.
Radon progeny samples are normally counted for three minutes, however any sample
count time may be selected for counting.
Run background detector count prior to running sampled filters.
After counting, calculate working levels.
Equation:(CPM - BKs)
Where:
(creffl (20 liters) (Time Facror) = w'L'
CPM - sample count per minute
BKg - counter-detector background count per minute
cr Efficiency - :The efficiency of the counting system (See Section
3.2.3.3\
Time Factor - Values determined from Kusnetz method (See
attached Table 2.2.4-l)
W.L. - Working Levels
10.
11.
t2.
13.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date 2lO7 Revision: DUSA- I
Page 6 of 2O
TABLE 2.2.4-I
Time Factors
Min. Factor
40 150
4t 14842 146
44 142
45 14046 138
47 136
48 13449 132
50 130
51 t28
52 12653 r2454 t22
55 120
56 118
57 11658 1t4
59 ll2
60 r10
6t 10862 106
63 104
64 102
65 10066 98
67 96
68 94
69 92
70 90
Min. Factor
7t 89
72 8773 85
75 83
76 8277 8r
78 78
79 7680 75
81 7482 73
83 7t
84 6985 68
86 6687 65
88 6389 61
90 60
2,2.5 Exposure Calculations
The personnel exposure calculations are a job-weighted average of those areas and
concentrations that an individual is exposed to. The procedure is:
1. Determine areas and durations (hrs.) each individual worked during the period (month
and quarter).
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page7 of20
2. Determine monitored concentrations (W.L.) for each area so noted.
3. The multiplication of the hours worked in each area by the area concentration (W.L.)
noted is added to the result for each area involved in the period.
The result is the Working Level Hours exposed (\YI-H) for the period.
The working level hours (WLH) divided by 173 (30 CFR 57.5-40 note); or hours per
month gives the working level months (WLM) exposure. (The limit is 4 working
level months exposure per year.)
If calculated per quarter, the working level hours summed for the quarter are divided
by 519 (173 X 3) to obtain the working level quarter exposure.
See Section 4.0 for details on how to perform exposure calculations and maintain the
exposure records.
2.2.6 Records
Data records, which are filed in the Radiation Safety files, include:
1. Sample location
2. Date and time of sample
3. Time on and off of sample pump
4. Counts per minute of sample
5. Elapsed time after sampling
6. Background detector count
7. Appropriate Kusnetz time factor
8. Working level
9. Sampler identification
Employee exposure records include:
l. Month monitored
2. Areas and duration worked
3. Employee identification
4. Concentrations (W.L.) observed
5. Calculated WLMs
2.2.7 Quality Assurance
Calibration checks each month assure proper calibration of the counting equipment.
Documented semi-annual calibrations of the counting equipment using certified alpha
Date: 210'l Revision: DUSA- I
4.
5.
6.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 8 of20
calibration and pulse meter sources ensure proper calibration of the equipment over the
anticipated ranges. The air sampling system has documented calibration prior to each
use, ensuring sampling the appropriate air volumes. Duplicate counts of select data may
be counted to assure instrument precision. Field documentation is maintained for each
sample during monitoring. This methodology provides assurance in data quality.
Review of data by the RSO and the ALARA audit committee further assures quality
maintenance.
Date: 2101 Revision: DUSA- I
2.3
2.3.1
ALPHA SURVEYS
Equipment
Equipment to be utilized in area alpha surveys are shown in Appendix 1. Pre-use
function checks will be performed on all radiation survey equipment as specified in
Section 3.1.2.3.2.
2.3.2 Frequencyllocations
Fixed and removable alpha surveys are made at those general locations on the Table
2.3.2-1, "Alpha Area Survey Locations." Surveys are completed weekly during
production periods. During non-production periods, only those areas designated by the
RSO as authorized lunchroom/break areas are monitored.
Table 2.3.2-l
White Mesa Mill
Alpha Area Survey Locations
Scale House Table
Warehouse Office Desks
Maintenance Office Desks
Change Room Lunch Tables
Maintenance Lunchroom Tables
Mill Office Lunchroom Tables
Metallurgical Laboratory Desks
Chemical Laboratory Desks
Administrative Break Room Counter
Administrative Office Desks
White Mesa Mill - Standard Operating procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 2/07 Revision: DUSA- I
Page 9 of 20
2.3.3 Procedures
2.3.3.1 Respirators
Respirators are monitored utilizing a sensitive alpha meter such as a Ludlum Model 3meter with a 43-2 detector or other equivalent radiological instruments. As an example,
the 43-2 detector's active surface area is 11.6 square centimeters. Metered readings are
adjusted from x dpm per 11.6 square centimeters to y dpm per 100 square centimeters.Each cleaned respirator is monitored inside the face seal with the detector located Vc inchfrom the respirator surface. Readings exceeding 100 dpm/100 square centimeters resultin re-cleaning or discarding of the respirator. Respirator cleaning and monitoring is afunction of the Radiation Safety staff assigned to this duty. The detector's surface andperformance is checked prior to each use period.
2.3.3.2 Fixed Alpha Sur-veys
Alpha surveys for fixed alpha contamination are performed using a variety of alphadetecting instruments, as listed in Appendix 1 Each instrument is checked using acalibrated alpha source for proper function and operation prior to use, as described inSection 3.1.2.3.2.
Adjustments to the surface area being measured must be made to convert from theparticular detector's surface area to the commonly used surface area of 100 squarecentimeters' Therefore when converting a measurement to the commonly used unit ofdpm/100cm2, a multiplying area factor-rnust be applied to the measurement. For theLudlum instrument with a 43-l detector of 75 cm2 surface, multiply the value by 1.33 (i.e.
100cm2 divided by 75cm2). For an ESp-l with a derector,"rr"J"'"iJg;;;:;'ril;ty themeasured value by 1.70, again the l00cm2 divided by 59cm2 for the detector,s surface
area.
The procedures are:
Turn the meter on and check the meter battery condition.
Check alpha detector mylar surface for pinholes, etc. Replace if necessary and repeat
calibration.
As specified in Section 3.1.2.3.2, perform a function calibration check usingcalibrated alpha source.
1.
2.
J.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
5. At each designated site, monitor designated
rAinchof the surface.
Date: 2107 Revision: DUSA- I
Page l0 of20
surfaces, table tops, etc., holding within
6. Record data, location, cpm/cm2 monitored on data sheet.
7. At the conclusion of the survey, transpose results to the file log, correcting to
dpm/100 cm2, using correction for detector's surface area and cpm/dpm conversion
factor.
2.3.3.3 Removable Alpha Sumeys
The Ludlum Model 2200 scaler with 43-17 detector, or a variety of other sensitive alpha
detection instruments such as Model 2929 or equivalent, counts wipe samples collected
during removable alpha surveys. Glass fiber filters, sized to fit the detector sample slot,
are utilized as the wipe medium. A template having a 100 square centimeter surface area
maybe used to standardize the surface area wiped.
The procedure is:
1.Perform function check calibration of the scaler/detector. Ensure that this
measurement is within + IOTo of the value obtained from the calibration laboratory.
If so proceed with the survey and counting.
Obtain clean filters and clean envelopes for filter storage.
At a location to be surveyed, remove the filter from the envelope and wipe the surface
covering approximately 100cm2. This is easily accomplished by making a "S" shaped
smear for approximately 10 inches using normal swipes (approximately 2.5 cm
diameter).
5. Record on envelope the date and location of the sample.
Upon returning to counting lab, place an unused filter in the counting unit for at least
I minute and obtain a background count rate.
Repeat procedure for each used filter, extracting filter from envelope, immediately
prior to counting, using tweezers and placing in the detector slot with the wiped
surface facing the detector, and count for at least 1 minute.
Convert results from cpm/filter to dpm/filter (100 cm2 wiped) after subtracting the
blank background count.
2.
3.
4.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP.2
Book: Radiation Safety Manual, Section 2
9. Record on the alpha survey form the following information:
A. Sample location and conditions
B. Sample date
C. Sampler identification
D. Wipe count dpm/100 cm2
10. Discard the filters and envelopes
Date; 2107 Revision: DUSA- I
Page I I of20
2.3.4 Action Limits
2.3.4.1 Respirators
Levels greater than 100 dpm/100 cm squared require re-cleaning or discarding of a
respirator.
2.3.4.2 Fixed Alpha Surveys
Levels greater than 1,000 dpm/100 cm squared require remedial action by management.
ALARA criterion ensures that the RSO takes action where necessary to maintain levels aslow as reasonably achievable.
2.3.4.3 Removable Alpha Surveys
Levels greater than 1,000 dpm/100 cm squared require remedial action and
decontamination. ALARA criteria ensures that the RSO takes action where necessary to
maintain levels as low as reasonably achievable.
2.3.5 Records
Records of fixed and removable alpha surveys are maintained in the Radiation Safety
office files. Records include:
1. Sample location/conditions
2. Sample date
3. Sampler identification
4. Fixed alpha determination - dpm/100 cm25. Removable alpha determination - dpm/100 cm26. Remedial action taken, where necessary
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date: 2/07 Revision: DUSA- I
Page 12 of 20
2.3.6 Quality Assurance
Calibration function checks of detector performance and visual observation of detector
surfaces prior to each survey ensures counting reliability and consistency. Usage of clean
containers and tweezers minimizes contamination of wipe samples. Field logs of sample
I.D.'s on sample containers minimizes transposition of samples. Data review by the RSO
and by the Audit Committee further assures quality maintenance.
2.4
2.4.1
BETA-GAMMA SURVEYS
Equipment
Beta/Gamma surveying instruments used for beta-gamma surveys are listed in Appendix
I and the sources used are listed in Appendix 2.
Some instruments read directly in MREM/hour while others read in CPM (with a
conversion to MREM/trour). The model 44-6 detector has a removable beta shield
allowing discrimination between beta and gamma contributions. Each instrument has a
manufactures user's manual which describes the function, use and capability of each
instrument. These manuals must be understood before surveying proceeds. Calibration
of Beta/Gamma and functional checks are performed using calibrated CS-137 or SR-Y 90
sources
2.4.2 Frequency/Locations
The sites noted on Table 2.4.2-l are monitored on a monthly basis by of the Radiation
Safety staff during production periods. During non-production periods, only areas
routinely occupied by personnel are monitored as designated by the RSO.
Table 2.4.2-l
Beta-gamma Survey Locations
Description of Possible
Identification Number Source of Area of Exposure
WM-l Mill Feed Hopper & Transfer ChuteWM-2 SAG Mill Intake-Feed Chute
WM-3 Screens-Area Floor Between ScreenWM-4 Leach Operator's Desk
WM-5 Leach Tank Vent #3
WM-6 Leach Tank#3 - WallWM-7 CCD Thickeners
WM-8 Pumphouse Tailings DischargeWM-9 Oxidant Makeup Room-Sump Pump
WM-I0 Shift Foreman's Office-Work Desk
Distance from Source in cm
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date:21O7 Revision: DUSA- I
Page 13 of 20
Distance from Source in cmIdentification Number
wM-l I
wM-12
wM-13
WM-I4
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
Description of Possible
Source of Area of Exposure
SX Operator's Area
Precipitation Tanks #l Tank; Wall
Precipitation Section "Lab Bench"
Precipitation Vent
Yellowcake Thickener #l; Wall
Centrifuge Discharge-Chute Wall
Yellowcake Thickener #2; Wall
Yellowcake Packaging Room
Yellowcake Dryer
Yellowcake Dust Collector
SX Uranium Mixer #l Extractor
SX Uranium Mixer #l Stripping
SX Vanadium Mixer #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
Tailings Impoundment Discharge
Tailings Impoundment Dike I
Tailings Impoundment Dike 2
Tailings Impoundment Dike 3
Scalehouse
Tailings Impoundment Dike 4
2.4.3 Procedures
The monitoring procedures are:
Check meter battery condition.
Check detector using a check source.
If the calibration function check indicates that the instrument is operating within
calibration specifications, proceed with monitoring.
4. Survey each designated location on Table 2.4.2-l and record in the field log:
A. Site location/condition
B. Date
C. lnstrument used
l.
2.
3.
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 14 of 2A
D. Sampler's initials
E. Meter reading (beta + gamma)
F. Meter reading (gamma)
5. Upon returning to the office, record the mr/hr reading into a permanent file which is
maintained for beta-gamma exposure evaluation.
2.4.4 Action Levels
The ALARA concept is utilized in action levels. Responses include operative cleaning of
the area or isolation of the source. The Radiation Safety Department will ensure levels
ALARA.
2.4.5 Records
Records maintained in the Radiation Safety office files include:
1. Date monitored
2. Site location/condition
3. lnstrument used4. Sampler's initials
5. Beta/Gamma level, mr/hr
6. Remedial action taken, if necessary
2.4.6 Quality Assurance
Quality of data is maintained with routine calibration and individual function checks of
meter performance. Personnel utilizing equipment are trained in its usage. Records of
the operational checks and calibrations are maintained in the files. The RSO routinely
reviews the data and the ALARA audit committee periodically analyzes the performance
of the management of the monitoring and administrative programs.
2.5 EXTERNAL GAMMA MONITORING
External gamma area monitoring is conducted at various locations around the Mill site in
order to provide Radiation Safety Staff with area-specific gamma measurements. The
procedures applicable to such monitoring are set out in Section 4.3 of the Mill's
Environmental Protection Manual.
Datei 2107 Revision: DUSA-l
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2
Date:. 2107 Revision: DUSA- I
Page 15 of20
2.6
2.6.1
2.6.3
EQUIPMENT RELEASE SURYEYS
Policy
Materials leaving a Restricted Area going to unrestricted areas for usage must meet
requirements of NRC guidance for "Decontamination of Facilities and Equipment Prior
to Release for Unrestricted Use" (dated May 1987).
All material originating within the restricted area will be considered contaminated until
checked by the Radiation Safety Department. All managers who desire to ship or release
material from the facility will inform the RSO of their desires. The RSO has the authority
to deny release of materials exceeding NRC guidance for "Decontamination of Facilities
and Equipment Prior to Release for Unrestricted Use" (dated May, 1987). No equipment
or materials will be released without documented release by the RSO or his designee.
2.6.2 Limits
The release limits for unrestricted use of equipment and materials is contained in the
NRC guidance listed above in Section 2.6.1 and are summarized as follows:
Limits for Alpha emissions for U-Nat and its daughter products are:
Average
Maximum
Removable
5,000 dpm/100 cm2
15,000 dpm/100 cm2
1,000 dpm/100 cm2
Limits for Beta-gamma emissions (measured at a distance of one centimeter) for
Beta/Gamma emitting radioisotopes are:
Average 0.2 mrhr or 5,000 dpmll00 cm2
Maximum 1.0 mr/trr or 15,000 dpm/I00 cm2
Equipment
Radiological survey instruments are listed in Appendix l.
2.6.4 Procedures
Upon notification that materials are requested for release, the Radiation Safety
Department shall inspect and survey the material. Surveys include fixed and removable
alpha surveys and beta-gamma surveys. An equipment inspection and release form is to
be prepared and signed by the RSO or his designee. Any material released from the mill
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-2
Book: Radiation Safety Manual, Section 2 Page 16 of 20
will be accompanied with the appropriate release form. If contamination exceeds levels
found in NRC guidance "Decontamination of Facilities and Equipment Prior to Release
for Unrestricted Use", dated May, 1987 , then decontamination must proceed at the
direction of the RSO. If the material cannot be decontaminated, then it will not be
released.
2.6.5 Records
Documented records for each released item are filed in the Radiation Safety Department
files.
2.6.6 Quality Assurance
The RSO and the ALARA Audit Committee periodically review the policy and
documented release forms to ensure policy and regulatory compliance.
PRODUCT SHIPMBNT SURVEYS
Policy
Datei 21 07 Revision: DUSA- I
vanadium shipments were detailed in the
These procedures have been replaced with
March 9, 2004 "Release and Shipping of
2.7
2.7.1
The Radiation Safety Department, prior to shipment release, will survey product
shipments from the facility. Product shipments include uranium concentrate and solid
vanadium products.
The Radiation Safety Department is to be notified in advance of each shipment. The
shipment will not be released prior to the Radiation Safety Department's authorization.
2.7.2 Equipment
Equipment used for product shipment surveys is the same as equipment used for material
release surveys and is listed in Appendices I and2.
2.7.3 Frequency
All barrels are fixed alpha and gamma scanned prior to shipment. A minimum of 25
percent of the barrels consigned are also wipe tested.
2.7.4 Solid Vanadium Shipments
The procedure to be followed for solid
Radiation Safety Manual in Section 2.7.4.
procedures No.: PBL-15 Book 10 Dated
Vanadium Blackflake".
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP.2
Book: Radiation Safety Manual, Section 2
2.7.5 Uranium ConcentrateShipments
Date: 2101 Revision: DUSA- I
2. Barrels requiring repair shall be repaired prior to the radiation survey.
3. Perform a fixed alpha survey of each barrel. The release limits for fixed alpha
radiation contamination is an average of 5,000 dpm/100 cm2 and a maximum of
15,000 dpm/100 cm2. Any barrel that exceeds 1,000 dpm/100 cm2 fixed alpha
contamination requires a removable alpha smear/wipe test to be performed.
Perform a removable alpha survey of each barrel exceeding 1,000 dpm/100 cm2 fixed
alpha contamination. The release limit for removable alpha radiation contamination is
1,000 dpm/100 cm2. Perform a smear/wipe test and analyzifilters for removable alpha on
25Vo of the barrels at a minimum, and perform a smear/wipe test and analyze
Page 17 of20
The procedures for exclusive use uranium concentrate shipments are:
1. Inspect each product barrel that makes up the consigned shipment for leaks, holes in
the barrels, cleanliness, etc.
2.7.6 Records
The attached form serves as a record of shipment and is retained in the Radiation Safety
files.
2.7.7 Quality Assurance
Periodic reviews of transport forms and policies by the RSO and the ALARA Audit
Committee ensures quality assurance for product shipment surveys.
fuea Airborne Sampling Location's Field
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EMPLOYEE NAME:
WEEK BEGINNING:
AREA
EMPLOYEE SIGNATURE:
EXPOSURE TIME SHEET
COMPANY ID:
WEEK ENDING:
SUN MON TUE WED THU FRI SAT TOTAL
TOTAL
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BA 1 SCALEHOUSE
BA 2 ORE STORAGE
BA 7 SAG MILL
BA 8 LEACH
BA 9 CCD C]RCUIT
BA 10 SX BUILDING
BA 12 YC PRECIP
BA 12A NORTH YC DRYER ENC
BA 128 SOUTH YC DRYER ENC
BA 13 YC PACKAGING
BA 13A YC PKG ENCLOSURE
BA 15 BUCKING ROOM
-a /a I a rta^a, hAArrDf\ r0 Lr,,l\ur] tll.r\.4vt
BA 17 CHANGE ROOM
BA 18 ADMINISTMTION BLDG
BA 19 WAREHOUSE
BA 20 MAINT SHOP
BA2l BOILER
BA22 VANADIUM PANEL
BA22A VANADIUM DRYER
BA 23 VANADIUM BELT SCRN
BA24 TAILINGS
BA 25 CONTROL ROOM
BA 26 MILL OFFICE
BA27 OPERATIONS LUNCH RM
BA28 DUMP STATION
BA 29 FILTER PRESS
BA 31 OXIDATION
o White Mesa Mill Weekly Alpha Survey
t\
Alpha Survey Instruments
Removable
Model #:
Serial #:
Calibration:
Efficiency:
Factor:
IVIDA:
Model #:
Serial #:
Calibration:
Efficiency:
Factor:
Background
r,^lIVIIJA:
Notes:
*All fixed readings are in DPIvI/100 cm2-
T or t = Total or Fixed Alpha Reading in DPIWI0O cm2
R: Removable Alpha Reading per Swipe or Filter (Approximately 100 cm2)
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SHIPMENT SURVEY
CONTRACT NO.
TMCTOR NO.
LOT NO.
TRUCK CARRIER
TRAILER NO.
1.0
= FACTORw rc
ALPHA SU RVEY INSTRUMENTS
TOTAL REII,IOVEABLE
MODEL NO.MODEL NO.
$ERIAL NO.SERIAL NO.
]ALIBRATION }ALIBRATION
EFFICIENCY EFFICIENCY
FACTOR FACTORat l r^tl^raat tr I llrlTa /trlYtrn] t n n nDi, a\r 4tr nnn nDl, rr^v /E ErrnrrE^Dt E\ .t ^^^ r\rllt
-LLvy inPbL Lrryr! . v lr rr\LU, vrvvv 9t rva nY v. r g.vvv u! tvl lgr,,,n t l\l-lYt\, y l-ruJLf-., I .t uU LrF lvl
GAMMA SURVEY (49 CFR 173.441 &) (1))
INSTRUMENT NO.MEASURED IN MILLIREMSI HOUR
ffiR/HR)
SERIAL NO.
CALIBRATION
TRAILER SURFACE 2OO MRYHR ALLOWABLE
SIX FEET DISTANCE 10 MR'HR ALLOWABLE
DRIVERS SEAT 5 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING. ALL DRUMS WERE TIGHTLY
SEALED. NONE LEAKED AND THERE WAS NO LOOSE MATERIAL !N THE VEHICLE.
BARREL
NUMBER
FIXED ALPHA
DPM/1OOcm'?
REMOVEABLECPM DPM
DATE
BACKGROUND
TRAILER SAMPLE #1
LOT NO.
EFFICIENCY FACTOR
BARREL
NUMBER
FIXED ALPHA
DPM/100cm2
REMOVEABLECPM DPM
mlt
s.!,3o3
o*cr
!,f.o
White Mesa Mill - Standard Operating Procedures Date:21O7 Revision: DUSA- I
SOP-PBL-RP.3
Book: Radiation Protection Manual, Section 3 Page I of 14
3.0 EOTIIPMENT/CALIBRATION
All radiation detection instruments used at the Mill are sent to a qualified independent
laboratory for calibration every six months. If necessary, Radiation Safety Staff can use
the procedures outlined below to verify calibration.
3.1 Counters/Detectors
3.1.1 General
All radiation detectors require determination of detector optimal voltage performance or
plateau operating point. The graph of voltage applied to a detector versus detector
response is referred to as a plateau curve. The plateau curve typically has two rapidly
sloping sections and a stable, flat region. The optimal operating point is typically located
at the beginning of the flat, or flatter, section of the graph. The plateau curve is specific
for a particular detector and its accompanying readout, or measuring meter, and may vary
over time depending upon electronic component condition.
The equipment used to determine detector plateau curves includes:
1. Appropriate radiation sources
2. Electrostatic voltmeter
3. Radiation detecting instrument
4. Graph paper
5. Manufacturer's technical manual
The procedure is:
l. Ensure instrument batteries are fresh or fully charged, if applicable.
2. Tum the instrument on.
3. Adjust the instrument voltage control starting at voltage of 600 using electrostatic
voltmeter to monitor voltage setting.
4. Expose detector to a radiation source applicable to the type of detector and in the
appropriate setting.
5. Record voltage and instrument response for each adjustment of voltage applied;
increments of 50 volts are adequate.
White Mesa Mill - Standard Operating Procedures
SOP.PBL-RP-3
Book: Radiation Protection Manual, Section 3 Page2 of 14
Repeat steps 4 and 5 until instrument response rapidly increases versus voltage level.
At this point, the detector is approaching potential differentials across the electrode
that may damage the detector.
Graph instrument response versus voltage applied.
Set equipment high voltage control to the optimum operating point. Record on graph
voltage selected.
Retain graph with calibration records.
3.1.2 Function Checks
Calibration function checks are required prior to use of radiation detection instruments
used at the Mill for the purpose of verifying that the instruments are operating at the same
efficiency as when they were calibrated by the calibration laboratory (i.e., within +l-107o).
Function checks are also used for verifying repeatability, reliability, and comparability of
an instrument's measurements from one period to another. By performing function
checks for extended time periods, or on a larger sample size, these goals are met.
Function checks involve two basic elements:
calibration laboratory efficiency is compared to the instrument's efficiency on the
date of the function check; and
the function check is verified with a check source having similar isotopic
composition as the one that was used by the calibration laboratory to calibrate the
instrument.
Function checks are made for all types of radiation survey instruments. The basic
principle in performing a function check is measuring the radiation field using a survey
instrument against a known amount of radiation from a calibrated source. These
measurements are made for the specific type of radiation occurring. For example, when
performing a beta/gamma survey, the instrument function check is performed using a
beta/gamma check source, such as a (SrY)-90. When performing an alpha survey, use an
alpha check source, such as Th-230 or Pu-239 for performing the function check.
Function checks are documented on the Calibration Check Forms (see Attachment A for
copies of forms to be used) for each specific instrument. They will be maintained in the
instrument's' calibration and maintenance file.
A number of radiation detection instruments are used at the Mill. An lnstrument Users
Manual for each instrument is maintained in the calibration files, together with calibration
documentation. The Users Manuals are to be considered the primary reference for
Date: 2107 Revision: DUSA-l
6.
7.
8.
9.
(1)
(2)
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
Date'. 2107 Revision: DUSA- I
Page 3 of 14
operating a particular instrument. This Standard Operating Procedure (SOP) is not
intended to replace the Users Manual, but rather to supplement the Manual by providing
steps to be performed for function checks. Before operating an instrument, personnel
should read the Users Manual and become familiar with the instrument's operation,
capabilities, and special features. Persormel will also receive on the job training on each
instrument.
3.1.3 Alpha Monitors
Alpha particles travel very short distances in the air due to their high ionization ability -typically YqtoVz inch. Due to this limitation, alpha monitoring must be done at a distance
of Vq inch or less between the detector face and the source. Alpha monitoring, to be
consistent, requires ensuring a consistent distance be utilized between the detector face
and the source. Alpha detectors read out in counts per minute (cpm). A correlation
relationship, known as the efficiency factor, between the meter response and the actual
disintegration rate of the source is used to determine actual calibration of the meter.
Radioactivity is measured in curies (Ci), which, by definition, is 3.7 x 1010 disintegrations
per second (dps), or 2.2 X l0l2 disintegrations per minute (dpm). Another measurement
unit is the Becquerel, or one dps. Alpha radiation is usually monitored as dpm, per
surface area measured.
Radiation survey equipment used at the Mill for alpha surveys are listed in Appendices 1
and2.
3.1.3.1 Calibration and Function Check Frequency
The frequency of calibration is specified in individual
manufacturer' s specifications.
During production periods, the following frequencies are
function checks of radiation detection instruments:
instrument user manuals and
and
Tvre
l. Employee scans2. Radon progeny
3. Respirator checks4. Area fixed scans5. Area wipe scans
Calibration
Frequency
6 month
6 month
6 month
6 month
6 month
observed for calibratron
Function
Checks
5 days/week
each use
each use
Daily or each use
Daily or each use
During non-production periods, the following frequencies are observed:
White Mesa Mill - Standard Operating Procedures
SOP-PBL.RP-3
Book: Radiation Protection Manual, Section 3
Type
1. Employee scans
2. Radon progeny
3. Respirator checks
4. Area fixed scans
5. Area wipe scans
Date: 2loi Revision: DUSA- I
Page 4 of 14
Calibration
Frequency
6 month
6 month
6 month
6 month
6 month
Function
Checks
bi-monthly
each use
each use
Daily or each use
Daily or each use
J.
4.
3.1.3.2 Function Check Procedures - Alpha Counters and Scaler Instruments
The following steps will be used for function checks for alpha counters and alpha scaler
instruments.
1. Turn the instrument on and place a calibrated alpha check source in the detector
holder on or the face of the detector.
2. Count the source for 1 minute and record this value in cpm.
Repeat step 2 four more times.
Average the five readings and divide the average in cpm by the know activity on the
alpha source. This is the efficiency of the instrument and detector.
5. Compare this efficiency with the efficiency obtained from the calibration lab. If the
efficiency comparison is within +lO7o deviation the instrument needs is calibrated if
not the instrument needs to be recalibrated.
6. If this efficiency comparison is within +10Vo deviation the instrument is in calibration.
7. Proceed with monitoring activities.
3.1.3.3 Function Check Procedures - ESP-I
There are special performance considerations when using the Eberline Smart Portable
(ESP-l) instrument with an Eberline AC-# alpha detector because the ESP-I contains a
microcomputer to perform its intemal calculations. Once the user has adjusted the
calibration constant (CC), which is a special feature of the ESP-I, the value obtained
during a measurement event will be converted to l00%o and displayed as such. Adjusting
the CC of the ESP-I in no way changes the laboratory calibration performed on the
instruments. The calibration constant is set to a value of "one" at the laboratory and
calibration proceeds as detailed by the manufacturer specifications.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
The following steps will be used for function checks
Date: 2107 Revision: DUSA-l
2.
3.
4.
Page 5 of 14
for the ESP-1.
l. Tum the instrument on and set the calibration constant (CC) to 1.00. This is the
setting the calibration laboratory uses for performing calibration of the instruments.
Place a calibrated alpha check source on the face of the detector and count the source
for one minute and record this value in cpm.
Repeat step 2 four more times.
Average the five readings in cpm and divide by the known activity of the alpha check
source. Note: use an alpha check source which is the same radioisotope, i.e.) Th-230
or Pu-239 or one of equivalent energy emission for this procedure. The instrument
efficiency is now established.
Compare the efficiency to the value obtained from the calibration lab. If the
efficiency comparison is within +10Vo deviation the instrument is calibrated; if not the
instrument requires recalibration.
Set the calibration constant (CC) to the efficiency value obtained in step 4. For
instance if the efficiency value is 20Vo from step 4 change the CC from 1.00 to 0.20.
This setting changes the calibration constant to the efficiency of the detector, by
introducing a multiplier into the microprocessor. Then, individual measurements are
obtained at a 1007o lev el.
Place a calibrated alpha check source on the detector and take five readings. Average
the five readings and divide this value by the known activity of the check source.
This value should be lO}Vo +5Vo of the known activity of the check source. If it is not
within this range (lA}Vo+SVo) readjust the CC (fine tune) slightly and count the source
five times and average. Compare the average value to the check source keeping in
mind you want to be within 100+ 5.OVo of the total activity of the check source.
Continue this step until that objective is achieved. The instrument is not only in
calibration as observed by step 5; it is now functionally capable of measuring at 1007o
efficiency. Proceed with use.
3.1.3.4 Calibration Procedures
5.
6.
7.
All radiation detection instruments used
laboratory every six months for calibration.
required the calibration procedures are:
1. Set the detector high voltage at the
electrostatic voltmeter.
at the Mill are sent to a qualified offsite
However, if additional onsite calibration is
prior determined operating point using an
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3 Page 6 of 14
For counter/scalers (radon progeny/wipes), close the detector, without source present,
obtain a reading for a set time. This is a background reading.
Place a calibrated source for the type of radiation being measured in the source holder
and obtain reading.
Observe the counts per minute for both the background and the source.
Subtract the cpm value of background from the cpm value of the source to obtain the
net cpm.
Divide the net cpm value by the known dpm of the source. This is the percentage
efficiency of the instrument system for this energy source.
By dividing 100 by this efficiency, an efficiency factor is obtained.
Dpm equals the cpm divided by the efficiency of the instrument detector system:
Note:I curie = 2.22 E + 12 dpm
1 microcuie = 2.22 E + 6 dpm
1 picocurie = 2.22 dpm
3.1.4 Beta-gamma Monitors
Equipment utilized for beta-gamma monitoring is listed in Appendices I and 2.
3.1.4.1 Function Check Procedure
The following steps will be used for function checks on beta/gamma instruments:
1. Turn the instrument on and place the calibrated beta/gamma (SR-Y)-90 check
on the face of the detector.
Let the reading stabilize to a constant value.
Record this value in cpm.
Divide this value by the known activity on the check source. This is the efficiency of
the instrument and detector.
Date: 2107 Revision: DUSA- I
4.
5.
2.
J.
6.
7.
8.
2.
4.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
5. Compare this efficiency to the efficiency obtained
the efficiency comparison is within +lOVo deviation
if not the instrument needs to be recalibrated.
Date'. 2107 Revision: DUSA- I
Page7 of 14
from the calibration laboratory. If
the instrument needs is calibrated
6. If this efficiency comparison is within +lOVo deviation the instrument is in calibration.
7. Proceed with monitoring activities.
3.1.4.2 Calibration
All beta-gamma survey instruments are sent out every six months for calibration.
Additional calibration, if necessary, may be performed on site using techniques described
in Reg. Guide 8.30, Appendix C - Beta Calibration of Survey Instruments for calibration
performed by a qualified calibration laboratory using the indicated source as listed in
Appendix 2.
3.1.5 Gamma Monitors
lnstruments for gamma measurements are listed in Appendix 1.
3.1.5.1 Calibration
lndependent calibration service laboratories perform calibration every six months.
Meters are calibrated to Cesium-137 or other radioisotopes as suggested by the calibration
laboratory or manufacturer. Most calibration service laboratories calibrate Beta/Gamma
instruments electronically in accordance with their standard calibration procedures.
However, electronic calibration basically consists of the steps described below:
Connect survey instrument to be calibrated to the model 500.
Tum both instruments on.
3. Record high voltage reading on model 500.
4. Set cpm and the range multiplier on the model 500 to the desired meter deflection.
The model 500 frequency controls consist of the three-digit readout, range selector,
coarse tuning know, and the fine tuning knob. The three-digit readout is in cpm times
the frequency multiplier.
1.
2.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
5. Calibrating survey instruments in cpm:
A. Set model 500 frequency to value that will provide a
survey instrument's highest count scale. Set pulse
Date: 2107 Revision: DUSA- I
Page 8 of 14
3/q meter deflection on the
height/amplitude to twice
instrument input sensitivity.
B. Adjust the range calibration potentiometer on the survey meter to provide correct
reading record.
De-code model 500 frequency to next lower value; then do the same for the
survey instrument.
Adjust the range calibration potentiometer for correct reading on survey
instrument. Record readings.
Repeat process until all ranges have been calibrated at 3/a meter deflection. Record
readings.
F. Retum to highest count scale on survey meter.
G. Set model 500 for Vc scale deflection readings.
H. Survey instrument should read within + lU%o of model 500 frequency. Record
readings.
l) If readings are outside of the tolerance, re-calibrate for 3/c meter deflection.
2) Tap instrument meter lightly to check for sticky meter. Meter tolerance is
+ 3Vo from the initial readings to the final reading.
I. Decode M 500 to next lower scale. Check survey instruments for 7n scale reading.
Record.
6. Record input sensitivity.
A. Select the most sensitive amplitude range 0-5 mv on the model 500.
B. Observe meter on survey instrument.
C. Increase pulse amplitude, switching to next higher range, if necessary, until the
rate meter indicates a stable reading (i.e., further increase of pulse amplitude does
not cause an increase in meter reading). Now, decrease pulse height until the
C.
D.
E.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3 Page 9 of 14
survey instrument meter reading drops 15 + 57o. Record this pulse height as the
instrument sensitivity.
D. If your instrument has a gain or threshold control to set instrument sensitivity, set
pulse height on the model 500 to desired sensitivity level. Now adjust your
instrument threshold or gain control until the rate meter reading is within 85 + 5Vo
of its stable reading value (see step C). Record the pulse height as instrument
sensitivity.
7. Calibrating survey instrument to cps.
A. Set frequency in model 500. Divide model 500 readings by 60 to convert to counts
per second.
Date: 210'l Revision: DUSA- I
B.
3.1.5.2
Repeat calibration steps as in item 5 above.
F requency of Calibration
3.2
If electronic calibration is performed using the above method by the Radiation Safety
Department, the model 500 pulse generator will be sent out for calibration on an annual
basis.
PERSONNEL AIR SAMPLERS
The calibration procedure for personnel air samplers involves primary and secondary
calibration procedures. Samplers will be calibrated prior to each use by either of two
methodologies: bubble tube or mass flow determinations. Air samplers may be calibrated
to standard air conditions.
3.2.1 Bubble Tube Calibration Method
The Bubble Tube Calibration Method is a primary calibration method and does not
require corrections to or from standard conditions for temperature and pressure. Personal
air samplers are calibrated for the flow rate for the sampling being performed, typically 2-
4liters per minute.
The equipment utilized is as follows:
l. Burette - 1,000 ml capacity, 10 ml divisions
2. Support, iron, rectangular base, with rod
3. Burette clamps - 2
4. Soap solution, dish
5. Tubing, Gelman filter holder, filter media (0.8 micron glass fiber Gelman type A/E)
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-I
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3 Page l0 of 14
6. Stopwatch
7. Small screwdriver
8. Sample pump
The procedures utilized are:
1. Assemble a filter train - place a filter in an in-line filter. Attach two lengths of tubing
to each comector of the in-line filter holder.
2. Make sure the Burette is clean. Clamp the 1,000 ml Burette upside down on the ring
stand with the Burette clamps.
3. Attach the pump to be calibrated to one end of the filter train, connect the other end of
the filter train to the small end of the 1,000 ml Burette, as per Figure 1.
4. Check all tubing connections for air tightness.
5. Pour approximately Vzinch (12 mm) of soap solution into the dish.
6. Start the pump.
7. Raise the dish up under the Burette opening, and then immediately lower the dish.
This should cause a film of soap to form over the Burette opening (i.e., a bubble).
Repeat this procedure until the film (bubble) will travel up the inverted Burette the
length of the graduation marks on the Burette without breaking.
8. When the film (bubble) has wetted the Burette inside and will travel the entire length
of the graduated area of the Burette, proceed with the actual calibration run.
9. Quickly form three bubbles and start the stopwatch when the middle bubble is at the
bottom graduation line (actually the 1,000 ml mark, but for purposes here, it will be
called the "zero" line).
10. Time the travel of the bubble from the zero line to the top line of the graduated
distance (0 ml). Since the capacity of the Burette is 1,000 ml (1.0 liter), then the
volume of air that is displaced above the bubble (i.e., needed to raise the bubble) is
1.0 liter. Stopping the stopwatch at the top mark is the time elapsed for the pump to
accomplish this. The rate of rise of the bubble through the apparatus is the flow rate
of air being pulled by the pump.
ll.lncrease or decrease the pump collection rate by adjusting the appropriate screw or
knob designed for this purpose.
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-I
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3 Page I I of 14
12. Set the pump flow collection rate to the desired valued usually between 2 and 4 liters
per minute for low volume collection pumps and between 30 and 80 liters per minute
for high volume collection pumps.
3.2.2 Mass Flow Method
Mass flow meters are manufactured equipment designed to measure air collection flow
rates for a variety of purposes. Mass flow meters may be subject to temperature and
pressure corrections of air movement depending on whether th"y are
calibrated/manufactured for standard conditions.
Utilizing an air mass flow meter, traceable to NBS, the airflow rate of pumps can be
quickly adjusted to correct standard flow rate conditions. However, the mass flow meter
must be calibrated annually using a primary calibration method.
The equipment consists of the following:
1. Kurz air mass flow model 543 or equivalent
2. Suitable filter head adapter connections
3. Filter heads with filter media
4. Pump to be calibrated
Note: The meter is calibrated directly in standard air conditions - 25o C., 29-82" Hg.
The procedures utilized are:
1. Ensure pump batteries are fully charged.
2. Ensure flow meter batteries are fully charged.
3. Assemble filter train.
4. Connect (with a suitable adapter) the Kurz probe onto the filter train. Ensure an
airtight seal with tape, if necessary.
5. Set the meter function switch to the highest range: 40 std liters per minute.
6. Turn the pump on.
7. Select appropriate range on the meter. (Do not allow meter needle to be forcibly
pegged.)
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP.3
Book: Radiation Protection Manual, Section 3
Date:2107 Revision: DUSA- I
Page t2of t4 O
8. Adjust the pump flow rate as necessary to desired flow rate. Allow the meter to
stabilize before adjustment of the pump.
9. Meter reads directly in standard air conditions, conecting for temperature and
barometric pressure.
Pump is now calibrated. Low volume pumps are set atZlo 4lpm.
3.3 AREA AIR SAMPLERS
The calibration procedure for area air samplers involves one of the following procedures;
Kurz Mass Flow, Wet Test Gas Meter or Bubble Tube Method.
3.3.1 Kurz Mass FIow Method
Repeat procedures discussed in3.2.2 - except - airflow rate is adjusted to 40 slpm and
samplers utilized are:
1. Eberline RAS-I
2. Scientific Industries Model H25004
3. Equivalent
3.3.2 Wet Test Gas Meter Method
The wet test gas meter method utilizes a Precision Scientific wet test meter rated at one
cubic foot per revolution of the main dial. This method is used to calibrate the Kurz air
mass flow meter in addition to direct calibration of the area air samplers.
The procedures are:
1. Attached coupling to sampler filter assembly; secure it with tape.
2. Connect wet test meter hose to coupling.
3- Check water level of wet test meter. The needle should be on slightly above the water
level.
4. Check the thermometer temperature of the wet test meter. Record this on the
calibration sheet. Assume that the wet and dry bulb temperatures are the same.
5. Tum on the sampler. Check the west test meter's manometer reading. This reading is
obtained by adding the left and right column values. (A typical reading might be .3).
Log these values for each ball height on the "Static pressure ... H2O" column.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual. Section 3 Page 13 of 14
6. For the following sampler approximate settings, pull one cubic foot of air through the
wet test meter and record the time (in seconds) for each: 20,30,40, and 50 lpm.
Sampler Calibration Procedures - Calculations and Equations
To convert the static pressure (of the manometer attached to the wet test meter) from
inches of water to inches of mercury, divide the number of inches to water by 13.6.
Example: 0.4/ 13.6-0.0294117 6" Hg
To compute the actual flow rate ("Q rate act. lpm"), first divide the number of cubic
feet by the number of seconds. Example: I ft.3/go sec = .01111 ft.3/awx. Convert
the cubic feet to liters. The conversion factor is28.317. Example: .01111ft.3/sec x
28.317 L ft.3 = .3146lJsec. Multiply this by 60 to convert from seconds to minutes.
Example: .3146Usec x 60 sec = 1888 [-/m or 18.88 lpm.
Using the "Vapor Pressures of Water" chart, find the vapor pressure inside the wet
test meter by matching the wet bulb temperature with the corresponding vapor
pressure. This number is the vapor pressure at the standard wet bulb (Pvpstw).
Find the vapor pressure at dewpoint using this formula: Pv dewpoint = Pvpstw =
0.0003613 (td-tw) Bp (Where +d = dry bulb temp; rw = wer bulb temp; bp =
barometric pressure in inches of mercury.) Assume that the dry bulb temperature
and the wet bulb temperature are the same, so the difference between them will
always be zero. Thus, Pv dewpoint will equal Pvpstw.
Determine the actual air density (D act) with this formula:
D act = 1.327
td + 459.67 t(Pg-Sp) - 0.378 (Pv dewpoint)l
(Where td - dry bulb temp in degrees F.; Bp = barometric pressure in inches of
mercury; Sp = static pressure of wet test meter in inches of mercury.)
Date: 2l0l Revision: DUSA-l
t.
2.
-r-
4.
5.
White Mesa Mill - Standard Operating Procedures
SOP-PBL-RP-3
Book: Radiation Protection Manual, Section 3
Example:
D act = I.327
70.5 + 459.67
Dale:210'7 Revision: DUSA- I
Page 14 of 14
[(24,8031 - 0.029411'76) - 0.378 (.875)]
530.17 (24,773688 - o.33o7s)
= (0.00250297) (24.442938)
D act = 0.06117996
Log this in "Air Density lbs/ft3" column of log sheet.
6. Find the flow rate of the sampler at standard conditions (Q std) using this formula:
Q std= Q act
(Where D std =.075
(i.e.,Qstd= 18.88
D act
D std
lbs/ft3)
(0.061r7996)
0.075
(0.81s7328)= 18.88
= 15.40
Q std = 15.40 (write this down for each position in the Q 0.075 column)
3.3.3 Bubble Tube Method
Refer to Section 3.2.1to perform this method.
Figure I - Apparatus for bubble method of pump calibration
Double filter holder
1000 ml
Burette
Soap solution in dish
Flow indicator
to be calibrated
Denison Mines (USA) Corp.
},HITE HESA }'IILL
Area Air Samoler Calibratjon Record
ilethod: Yet $qs I'lPter
l{onth &
Baronetrlc Pressure (Inches of ilercury)-
Alr Temperature: Dry Bulb-9F Heter Alr
tlet Bulb oF
Callbrated bY,
Sampler Jlo.
Fllter TYPe: -
Temp. Dry BuIb-oF
tlet Bulb-oF
Calc.
lqeter Static Act' Vol' Calc' Std
Volume Estlmate Time^ Pressure at SE+' Het Vslume
O'
carcurations' It:lJ::i?il Bili'i.'li.ill'il'Tiiil,I:lX3'..iiii -iii-iensttv and volume sampled'
is at l00fi humldltY.
to be done to get
Eouivqrents' lr.Bzh; B:Birl'BlirirlillrlltiHri.i.'uot"
root std' Arr ' TooF'
-4-
.\ I A,\ L'.rnu
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:ll!it,t:!xtrc o:ratlT Eit
rrta.tl r.tt3. l.lrr lot(
of Dust Concentraticn
in Gas Streaa;3.4n2
PAGE I 6 oF 19
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count for tinrc
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2
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Attachment A
Calibration Check Form
Instrument Serial Number:
CalCheck.xls
Date of Functior
Check
Calibration
Constant
Setting at
Cal. Lab.
2Pi
Efficiency at
Calibration
Laboratorv
4Pi
Efficiency at
Calibration
Laboratorv
uallDratron
Constant
Setting at
WMM Rad.
Office
,2PI
Efficiency at
This Date's
Function
Check
4yt
Efficiency at
This Date's
Function
Check
Meet lU%o
Deviation
Standard (yes
or no)
Attachment A
Eberline ESP-1 Calibration Check Form
o'
Instrument Serial Number:
Date of
Function Check
Calibration
Constant
Setting at
Cal. Lab.
2Pi
Efficienry at
Calibration
Laboratorv
4Pi
Efficiency at
Calibration
Laboratow
ualrDrauon
Constant
Setting at
WMMRad.
Offrce
zYt
Effrciency at
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Function
Check
+rt
Efficienry at
This Date's
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Check
Meet l0%
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CALCHECKformstosOPl 21 500 Page 1
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White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 210'l Revision: DUSA- I
Page I ofll
and
4.
4.t
4.1.1
PERSONNEL EXPOSURE CALCULATIONS
DACs for Conventional Ores
4.1.1.1 Solubility Classes
The solubility class, chemical form and abundance of conventional ores at the
the resulting DACs to be used are as set out in the following table:
Table 4.l.l.l-l
Solubility Class, Chemical Form And Abundance of Conventional Ores
I l0 CFR Part 20, Appendix B2 I',IUREG/CR-0S30, PNL-2870, D.R. Kalkwarf, 1979, "Solubility Classifications of Airbome Producrs from Uranium Ores
and Tailings Piles"
Location DAC U-t Th-230 Ra-226 Pb-2r0
Ore-Grind
6.00E-l I DAC is specified in l0 CFR Part2O
Leach l.1E-10 lzOre,
lzPrecipitation
Y, Ore,
% Precipitation
/, Ore,
% Precipitation
lz Ore,
% Precipitation
CCD t.zE-n Class D
Sulfate
257o
Class W
Sulfate
25Vo
Class W '
Sulfate
257o
Class D
Sulfate
25Vo
SX l.2E-lt Class D
Sulfate
257o
Class W '
Sulfate
25%o
Class W
Sulfate
257o
Class D I
Sulfate
25Vo
Precipitation 5.00E-10 Class D'
Diuranate
l00Vo
NA NA NA
Yellowcake
Packaging
2.20E-tt Class Y: 90 7a
and Class W: 10
4o
Oxide
lOOTo
NA NA NA
Tailings 1.70E-l I Class Y
Oxide
4Vo
Class Y
Oxide
32Vo
Class W '
Oxide
327o
Class W '
Oxide
32Vo
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 210'l Revision: DUSA- I
Page2 of ll O
4.1..1.2 Application of Conventional Ore DACs to Workplace Locations
The Conventional Ore DACs will be applied as follows to the various locations in the
Mill site:
Table 4.1.1.2-l
Application of Conventional Ore DACs to Workplace Locations
Type ofDAC DAC (pCi/ml)Individual Location
Ore/Grind 6.00E-l I Ore Scalehouse
Ore Storage
Maintenance Shop
Warehouse
Lunch Room
Change Room
Administration Bldg
Ore/Grind 6.008-l I Dumo Station
Ore/Grind 6.00E-r I SAG MiII
SAG Mill Control
Shifter's Office
Operations Lunch Rm
Filter Press
t.each l.lE-10 Leach Tank Area
CCD r.20E-l I CCD Circuit Thickeners
sx 1.20E- I I SX Building South
Boiler
Ore/Grind 6.00E-l I Control Room
Yellowcake Precipitation 5.00E-r0 YC Precipitation &Wet
Storase
Yellowcake Packaging 2.20E-ll North YC Dryer Enc
South YC Dryer Enc
YC Pkg Enclosure
YC Drying & Packaging
Area
Packaged YC Staging
Area
Tailings r.70E- r I Truck Shop
Tailines
Yellowcake Precipitation 5.00E-10 Vanadium Circuit
4.1.2 DACs for Alternate Feed Materials
ln determining the applicable DACs for altemate feed materials, the following procedures
will be followed:
White Mesa Mill - Standard Operating Procedures
SOPPBL-RP-4
Book: Radiation Protection Manual, Section 4
Datei 2107 Revision: DUSA-l
Page3ofll
a) Ore/Grind DAC
If the generator of the alternate feed material is regulated by the NRC or an
Agreement State under a source material or 11e.(2) byproduct material license and
such regulatory authority has approved a DAC in connection with handling the
material in the same form as it will be received at the Mill, then that DAC may be
used as the Ore/Grind DAC. If such a DAC has not been so approved, then a
DAC will be calculated based on the mixture rule set out in Section 4.1.3-3 below
if the solubilities and relative activities of radionuclides in the mixture are known
or can be determined. If not known or determined, the mixture will be assumed to
be comprised entirely of the most restrictive radionuclide and solubility class,
until the relative activities and solubilities of the radionuclides in the mixture
become known or determined.
b) Leach
The Leach DAC will be a DAC equal to one half of the Ore/Grind DAC and one
half of the Yellowcake Precipitation DAC.
c) CCD
The CCD DAC will be calculated based on the mixture rule set out in Section
4.1.3.3 below if the solubilities and relative activities of radionuclides in the
mixture are known or can be determined. If not known or determined, the mixture
will be assumed to be comprised entirely of the most restrictive radionuclide and
solubility class, until the relative activities and solubilities of the radionuclides in
the mixture become known or determined, provided that the solubility class of
uranium can be assumed to be Class D Sulfate.
d) sx
The SX DAC will be the same as the CCD DAC.
e) YellowcakePrecipitation
The Yellowcake precipitation DAC will be the same as for conventional ores, that
is 5.00E-10.
0 Yellowcake Packaging
The yellowcake packaging DAC will be the same as for conventional ores, that is
2.208-tt.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Date: 210'7 Revision: DUSA- I
Page4ofll O
g) Tailings
The tailings DAC will be the same as for conventional ores, that is 1.70E-11,
unless it is expected that the addition of tailings from the alternate feed material
will significantly impact the radiological make-up of the exposed tailings, in
which case the mixture rule set out in sections 4.1.3.2 (where the radionuclide
with the most restrictive DAC is assumed to comprise l00Vo of the tailings) and
4.1.3.3, as applicable will be applied.
Once calculated, the foregoing DACs will be applied to the areas set out in Table 4.1.1.2-
1 above.
DACs will be calculated in accordance with the foregoing procedure prior to receipt or
handling of the alternate feed materials. If additional characterization information
becomes available at a later date, the DACs may be adjusted to reflect such additional
characterization information.
4.1.3 DACs for Mixtures
Both uranium ore and uranium mill tailings consist of a mixture of radionuclides each
with their individual DAC's. Unless otherwise specified or determined in accordance
with Section4.l.L or 4.1.2 above, the DAC for a mixture is as follows:
4.1.3,1 Ore Prior to Leach
6E-l1uCiof grossalphafromU-238,U-234, Th-230, andRa-226 permlof air,or3E-11
uCi of natural uranium per ml of air
4.1.3.2 Tailings When the Concentration of the Radionuclides in the Mixture is
Unknown
6E-12 uCi/ml = DAC for Th-230
4.1.3.3 Tailings or Other Mixture When the Identity and Concentration of Each
Radionuclide is Known
.The DAC for the mixture is calculated by the following (see Regulatory Guide 8.30, page
2\.
DAC,= [ f, + f, + ... + f,- ]'
DACr DAC2 DACn
where DAC* - DAC for the mixture of radionuclides I through n.
White Mesa Mill - Standard Operating Procedures
SOP PBL_RP-4
Book: Radiation Protection Manual, Section 4
DACI -
DACn -
f1
fn
For example:
Date;2107 Revision: DUSA- I
DAC for the first radionuclide in the mixture.
DAC for the nft, the last, radionuclide in the mixture.
Fraction of alpha activity from the first radionuclide in
the mixture.
Fraction of alpha activity from radionuclide n in the
mixture.
Page5ofll
10 uCi/ml
12 uCi/ml
l0vo of the DAC by solving for sampling
Ra-226
Th-230
DACm -80
DAC=38-
DAC=2E-
20
100 -' -l
J
2E-12
80 pCi/g
20 pCrlg
+
r 100t--
3E-10
4.1.4
fz.ons +l.ooErl ]'
I
1.0E11
9.78-12uCi
ml
Sampling Time
Calculate the sampling time required to detect
time in the following equation:
LLD
(Sampling Time) (Flow Rate = 0.1 DAC
of Sampler)
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
For example:
To detect l07o of. the DAC for U-nat, a 40
minutes, assuming the sample counter has a
background, i.e.:
Date:2101 Revision: DUSA- I
Page6ofll
Ipm air sampler would have to operate 57
lower level of detection of 10 dpm above
(10 DPM) (__!ei_J (E-6 uci)
2.22DPY PCi =
(X min.) CA-UO 103m1min. lit
ZE-IZuCi
ml
X = 56.8 minutes
4.1.5 Dose Calculations (10 CFR 20.1201-20.1202)
l. Analytical results of airbome particulate samples may be obtained in several different
units that need to be converted into mg soluble natural uranium to determine the
weekly exposures and into uCi-hr/ml or WLlu to determine annual exposures. The
following table presents a summary of the conversions that may be necessary. The
first row of the table presents the operations to be performed in the conversions.
Enter the measured weight or activity, the sampler flow rate, the sampling time, and
the exposure time into the first four columns. Divide the values in column I by the
values in column 2 and column 3, and then mtrltiply by the values in columns 4 and 5
to obtain the units in column 6, or:
(Column 1) (Column 4) (Column 5) = Column 6
(Column 2) (Column 3)
UNIT CONVERSION TABLE
2 3 4 5 6
OPERATION DIVIDE DIVIDE MULTIPLY MULTIPLY ANSWER
MEASI.JRED
VALI-]E
SAMPLER
FLOW RATE
SAMPLING
TIME
EXPOSURE
TIME
CONSTANT ANSWER
ug soluble
U-natural
[/min mln hrs 1.2 mg soluble
U-natural
pCi soluble
U-natural
I-lmin mln hrs 1.77 mg soluble
U-natural
pci
sross alpha
[-/min mln hrs E-9 UCi-trs
ML
ug
U-nat
Umin mtn hrs 6.77E-tO UCi-hrs
ML
uCi
mL
Radon
hrs E7 WL-hrs
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual. Section 4
For example:
(10 ue Soluble U-nat) (10 hrs) (1.2) - 2 mg Soluble U-nat
(2Umin) (30 min)
Datei 2101 Revision: DUSA-l
2.
3.
4.
5.
6.
7.
8.
PageTofll
See notes for a description ofthe unit conversions.
The table on the following page is divided into four quadrants. Different quadrants
are for soluble uranium, insoluble uranium, tailings dust, and radon. Select the proper
quadrant for the type of airborne particulate being sampled. Enter the area, particulate
concentration, and hours of exposure in the labeled columns of the selected quadrant.
The protection factors are whole numbers, e.g., 10, 50, 1,000. Divide I by the
protection factor and enter the quotient in the fourth column of each quadrant, e.g., for
a protection factor of 1,000, enter 1/1,000 or 0.001 in the column. The l/pF values
are unit-less.
Enter the product of the airborne concentration, the hours of exposure, the time, and
l/PF in the fifth column of each quadrant. Add these values and enter the total at the
bottom of the column.
On the dose calculations form which follows, enter the total for Soluble Uranium in
the equation and calculate the corresponding mg. If a value exceeds 10 mg, an over-
exposure may have occurred. If verified by a high uranium in urine results, an over-
exposure has probably occurred and needs to be reported to the NRC.
Enter the totals for Soluble Uranium. lnsoluble Uranium. Tailings Dust. and Radon in
their respective equations. Perform the indicated calculations, add the fractions
together, and record as the subtotal. (use the DAC for Th-230 or the DAC for
tailings dust to determine the contribution of tailings dust to the subtotal.) If a
subtotal exceeds 1, an over-exposure may have occurred. If verified by a high
uranium in urine result, an over-exposure has probably occurred and needs to be
reported to the NRC.
Enter the TLD determinations of whole body dose as the Deep Dose Equivalent on
the form. If the Deep Dose Equivalent exceeds 5 rems, an over-exposure may have
occurred and needs to be reported to the NRC.
If the Deep Dose Equivalent exceeds 0.5 rem and the subtotal exceeds 0.1, calculate
the Total Effective Dose Equivalent by adding the Deep Dose Equivalent to the
product of 5 rems times the subtotal and enter on the form. If the total effective dose
equivalent exceeds 5 rems, an over-exposure may have occurred and may have to be
reported to the NRC.
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4
Name
Date'. 2107 Revision: DUSA- I
Pagesofll I
DOSE CALCULATIONS (10 CFR 20.1201 +20J2021
Soc. Sec. No. Co. l.D. No. Week Year
AREA SOL. U
uCi/ML
HR 1
PF
UCFHR
ML
AREA INSOL. U
uCi/ML
HR 1
PF
uCFHR
ML
TOTAL TOTAL
AREA TAILINGS
DUST
uCi/ML
HR l_
PF
uCi-HR
ML
AREA RADON
WL
HR !.
PF
WL-HR
TOTAL TOTAL
White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-4
Book: Radiation Protection Manual. Section 4
Name
Weekly Soluble
Uranium
Soc. Sec. No.
(uCi-hr) (1.77E9)
(mL)
Co.I.D. No. Week
Limit
Date: 2107 Revision: DUSA- I
Page9ofll
mg
l0 mg
DOSE CALCULATIONS (10 CFR 20.120L+20.1202)
Arurual Soluble
Uranium
Annual lnsoluble
Uranium
Annual Tailings
Dust
Annual Radon with
Daughters Present
uCi-hr)
mL
(2000 hr) (sE-10)
( uCi-hr)
mL
(2000 hr) (2E-11)
uCi-hr)
mL
(2000 hr) ( *)
* - DAC for Th-230 = 6E-12:
or = DAC for tailings dust.
( wl-hr)
(2000 hr) (0.33 wL)
Deep Dose Equivalent = TLD Whole Body Dose in
If the Deep Dose Equivalent is > 0.5 rem
and
the Subtotal is > 0.1, then
Subtotal
Limit
rem =
Limit
+ Committed Effective
Dose Equivalent
5 rem
Total Effective
Dose Equivalent
= Deep
Dose Equivalent
rem) + (5 rem)Subtotal) =
Limit 5 rem
White Mesa Mill - Standard Operating Procedures
SOPPBL.RP-4
Book: Radiation Protection Manual, Section 4
Date: 2107 Revision: DUSA-l
o
DOSE CALCULATIONS (10 CFR 20.120r+20.1202)
Notes:
1. PF = Respiratory Protection Factor.
2. The 10 mg soluble uranium per week limit in 10 CFR Part 20.1201 is more
restrictive than the (40 hour) (DAC) limit for natural uranium, thus compliance is
based on l0 mg per week.
3. The conversion of uCi-hr/ml to mg natural uranium is the product of:
(air concentration ) (hours of exposure) (breathing rate for light work)
(conversion of minutes to hours) (specific activity of natural uranium)
(conversion of ug to mg) which is:
(uCihr) @-n,l-) (60 mtd ( ug ) G-3 me) =mL min hr 6.778-7 uCi ug
(uCi-hr) (1.77F9)
mL = mg U natural
Thus to obtain mg natural uranium, multiply the uci-hr/ml by 1.77E9.
4. soluble Uranium DAC (class D) = 5E-10 uci/ml
lnsoluble Uranium DAC (class Y) = zB-ll uci/ml
Thorium-230 DAC (class Y) = 6E-12 uci/ml
Radon with Daughters DAC = 3E-8 uCilmL = 0.33 WL
Tailings Dust DAC is a Site Specific Value = uCi/ml
5. Description of unit conversions:
a. ug soluble U-nat + mg soluble U-nat
( us-) G:3 nqg) (60 min) (hr exposure) =
( L ) (min sampler) (83 mL) ug hr
min L
( ue ) (hr exposure) (1-2) = mg soluble U-nat.
( L )(min sampler)
min
White Mesa Mill - Standard Operating Procedures
SOP PBL.RP-4
Book: Radiation Protection Manual, Section 4
Date'. 2107 Revision: DUSA- I
Pagellofll
(_________ rng) @_nL) ->
6.77E-7 mCi min
b.pCi soluble U-nat -+ mg soluble U-nat
( pCi ) (E-9 mCi)
( L ) (min sampler) (E3 mL) pci
min L
c.
6q lq!g) (hr exposure)
hr
(_______+gi_) (hr exposure)( L )(min sampler)
mln
pCi gross alpha -+ uCi-hr
(pCi)
( L ) (min sampler) (E-3sD
min L
(1.77) = mg soluble U-nat.
G-6rei)
pci
(hr exposure) =
( pCi ) (hr exposure)
(L)(minsampler)
min
ug U-nat -+ uCi- hr
mL
us)
(E-9) = uCi-hr
mL
d.
(L)
min
(min sampler) (E3_UqD
L
6JlE-7_vCi)
ug
( hr exposure) =
uCi ( hr exposure)(6.77E-lO) = uCi-hr
mL(L)(minsampler)
min
uCi of Radon-222 -+ WL
mL
Gq, G6-pei) G3 rnl)mL uCi L
GeD (E7) = WL
mL
(L-wL)
E2 pCi
White Mesa Mill - Standard Operating Procedures
SOP PBL.RP-4
Book: Radiation Protection Manual, Section 4 Page 12 of I I
4.2 Personnel Exposure Files
Denison Mines (USA) Corp. will generate and maintain individual exposure records for
each employee that works at the White Mesa Mill. The record system will be designed to
meet the specifications of the Federal Code of Regulations 10 CFR Part2O.
When an employee is hired, a file will be generated specifically for that individual. All
records that are to be in the radiation exposure file will be maintained during the term of
employment. When the employee terminates, all records will be preserved until the
Nuclear Regulatory Commission authorizes their disposition.
Personnel exposure records will be maintained at the mill site and will be accessible only
to the employee and the Radiation Protection staff. No copy of the exposure history will
be furnished to anyone outside of the Radiation Protection Department without a signed
consent form from the employee.
Contents of the exposure file:
Each personnel exposure file will contain the following records:
1. lnformation Sheet - Each information sheet will include the following information:
A. Employee's full name
B. Birth date
C. Social Security number
D. Date of hire
E. Date of termination
Record of Urinalyses - A multiple entry log of all urinalyses conducted at this work site
will include the following information:
A. Employee's full name
B. Sample dates
C. Sample identification number
D. Concentration of uranium in ug/l
E. An entry for any quality assurance "spikes" entered in ug/l
3- lntemal personnel Exposure Records - These will be calculated and prepared using
the forms above or by the computer and the printout will be used as the permanent
record in the exposure file. The internal exposure records will contain the following
information:
Date: 2107 Revision: DUSA- I
A. Employee's full name
White Mesa Mill - Standard Operating Procedures Date'.2101 Revision: DUSA-l
SOP PBL-RP-4
Book: Radiation Protection Manual, Section 4 Page 13 of I I
B. Social Security number
C. Birth date
D. Exposure to airborne uranium expressed in both uCi and percent MPC
E. Any breathing zone samples collected for airborne uranium to be expressed in
uCi
F. Radon daughters expressed in working levels (WL) and period of exposure
(date)
4. Extemal Exposure Record (OSL, Dosimeter) - The date received from the Dosimeter
contractor will be posted to the Dosimeter record in the exposure file. The following
information will be included on the Dosimeter record:
A. Employee's full name
B. Birth date
C. Social Security number
D. Period of exposure (dates)
E. Exposure in millirems (MR) for a given period
F. Total accumulated exposure while at the White Mesa Mill
G. Identification number of the Dosimeter badge
5. Record of Exposure from Previous Employment (NRC form 4 or similar) - A record
of occupational exposures that occurred prior to employment at the mill must be
obtained for each employee. If no such exposure record is available, the employee
must sign a statement to that affect. If previous exposure records were kept, a copy
must be secured and placed in the individual's file.
6. Reports of Over-exposure - If an individual has been found to be over-exposed, the
Radiation Safety Officer will draft a letter of explanation. The report will explain the
circumstances and/or reasons for the over-exposure. It will also state any actions
taken to correct the problem or to prevent future over-exposures. The report must be
placed in the individual's exposure file.
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White Mesa Mill - Standard Operating Procedures
SOP PBL-RP-1
Book 9: Radiation Protection Manual, Section 5 Page I of 2
RADIATION WORK PERN4ITS
General
A Radiation Work Permit ("RWI"') system has been established for non-routine activities
where there is a potential for a significant radiation exposure, or for certain routine
activities where there is a potential to spread radioactive materials.
Specifically, an RWP is required for:
a) All non-routine maintenance work, or work for which there is no effective
operating procedure, which may, by the determination of the Radiation Safety
Officer, exceed 25Vo of the R313-15 limits;
b) All routine work, not covered by an operating procedure, that could involve
the spread of radioactive materials; and
c) The receipt, handling or processing of any alternate feed material or other
radioactive material, which has been determined by the Radiation Safety Officer,
not to fall within an existing operating procedure.
An RWP may also be used on a temporary basis for routine activities in lieu of an
operating procedure, while an operating procedure is being developed for the activity.
Date: 2107 Revision: DUSA-I
5.
5.1
5.2
Review
All Non-Routine Activities Require Radiation Safety Officer
5.3
All non-routine activities require review by the Radiation Safety Officer. The Radiation
Safety Officer will advise the Mill Manager on a regular basis of any activities that
require an RWP.
Radiation Work Permit
The RWP is a form that describes the work to be performed, the location, duration and
personnel involved, and the radiological controls needed, such as respirator, urine
samples, breathing zone monitoring, time limitations for the activity, etc. The form must
also have an area for the Radiation Safety Officer, or his designee's, signature. A copy of
a form of RWP is attached.
Procedure for Obtaining a Radiation Work Permit5.4
The procedure for obtaining an RWP is:
White Mesa Mill - Standard Operating Procedures Date:2107 Revision: DUSA-I
SOP PBL-RP-I
Book 9: Radiation Protection Manual, Section 5 Page 2 of 2
a) When RWP-type work is to be performed, the Shift Foreman, Maintenance
Superintendent or other supervisory personnel shall complete the top portion of
the RWP, which will provide information on the specific work locations,
estimated work duration, type of work to be performed, and personnel utilized,
and present it to the Radiation Safety Officer;
b) The Radiation Safety Officer will indicate the radiological controls needed
based on the information given and the safety of personnel. The Radiation Safety
Officer or his designee will provide the necessary surveillance and respiratory
protection equipment;
c) No work can be performed until the Radiation Safety Officer or his designee
has approved the RWP;
d) Any maintenance or RWP jobs done in the yellowcake dryer or packaging
enclosures will require a member of the Radiation Staff to be present for the
duration of the job;
e) All supervisors will be given training in and copies of the requirements for
using RWPs, with the permits remaining on file for five years; and
0 Any supervisor found to be knowingly and willfully violating these
procedures will be issued a written warning, and the situation will be reviewed by
appropriate management for remedial action.
t1'ofoooan
APPENDIX 1
Denison Mines (USA) Corp.
White Mesa MillRadiation Detection lnstrument List
Model Probe lnst. Ser. #Probe Ser. #
lype ot Haoralron
Monitored with
lnstrument
Model 177 43-5 41298 RN01'1964 Alpha
Model 177 43-5 1 16481 RN012992 Alpha
Model 177 43-1 41261 RN012833 Alpha
Model 177 43-5 12970 PR026346 Alpha
Model177 43-5 159117 PR168949 Alpha
Model 177 43-5 1 591 70 PR165054 Alpha
Model177 43-5 1 89581 PR192467 Alpha
l\4odel 177 43-5 185035 PR191566 Alpha
Model 177 43-5 189581 PA192467 Alpha
Model 3 HP 270 12658 RN01026 Beta/Gamma
Model 3 43-2 12661 PR3178 Beta/Gamma
Model 3 44-6 164493 167608 Beta/Gamma
Model 3 44-9 1 58587 PR163554 Aloha/Beta/Gamma
Model 3 44-9 235288 PR247246 AIpha/Beta/Gamma
Model3 44-9 1 58588 PH163578 Alpha/Beta/Gamma
Model2 44-6 4796 RN012171 Beta/Gamma
Model2 44-6 12859 12214 Beta/Gamma
ESP.1 AC-3-8 2286 RN012172 Alpha
ASP-1 HP21OL & HP26O 2972 718951 &718952 Alpha/Lleta/Gamma
Model 2929 43-'t0-1 146781 PH145343 AlDha/Beta/Gamma
E600 AC-3-7 1367 724663 AIoha/Beta/Gamma
Model 2350 43-90 175862 PR180506 Alpha
Model 2200 PR-3174 17534 15200-35 Alpha
Model 19 None 160104 None Beta/Gamma
APPENDIX 2
Denison Mines (USA) Corp.
White Mesa Mill Hadiation Detection lnstrument
Check Source List
lsotope Source Serial No.DPM or uCi Source Tvoe
StrontiumYttrium-9 98SR4700903 39.300 Beta/Gamma
Thorium-230 s-1738 30.300 Alpha
Thorium-230 1 1694 3,580 Alpha
Thorium-230 1 856/90 15,500 Alpha
Thorium-230 1 1693 1,630 Alpha
Thorium-230 s-2349 16,700 Alpha
Thorium-230 1 1695 6,180 Alpha
Thorium-230 11273 6,680 Alpha
Thorium-230 1 1964 6.670 Alpha
fechnetium-99 s-2350 11,600 Beta
Cesium-137 s-2351 0.72 uCi Beta/Gamma
Cesium-137 CS.7A #1 SuCi Beta/Gamma
Cesium-137 CS.7A #2 SuCi Beta/Gamma
Cesium-i37 U5-/A #J duul BeiarGamma
Cesium-137 s-2044 1.656 uCi Beta/Gamma
Plutonium-239 c. s.2039 38,000 Alpha
Uranium-238 1121189 234 mrlhr Alpha/Beta/Gamma
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DENTSON MINES (USA) CORP.
BOOK #1
ORE RECEIVING, FEE,D & GRINT)
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INTRODUCTION
Mill Process
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, will be fed at the rate of approximately 2,000 tons-per-day to the
semi-autogenous grinding (SAG) mill. The ground ore will be stored as a wet pulp in
three agitated tanks. The processing stages will include two-stage acid leaching, followed
by the recovery of uranium and vanadium bearing pregnant solution in a counter-current
decantation (CCD) system.
The uranium is recovered from the leach pregnant solution utilizing a
conventional solvent extraction system. Vanadium will be recovered from the barren
uranium raffinate also utilizing a solvent extraction circuit.
The pregnant uranium strip solution is precipitated with Anhydrous Ammonia and
the resultant yellowcake is dewatered, dried, and packaged.
The pregnant vanadium strip solution is precipitated with Ammonia Sulfate,
filtered, dried, and melted to produce a concentrated vanadium black flake for packaging.
White Mesa Mill - Standard Operating Procedures
Book I Section I
Process Controls
A process control panel is provided
vanadium product recovery (CP-4 and 5),
located in the central control room.
Date: O2107 Revision: DUSA I
Page I of2
in the grinding area (CP-l), and uranium and
areas. All other process control panels are
Denison Mines (USA) Corp. has outlined, and will implement, an on-going
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient manner and in accordance with approved procedures.
This radiation protection program is documented and administered by the
State of Utah Division of Radiation Control under the direction of the Executive
Secretary. These applicable regulations are detailed in Code of Federal Regulations Title
10 Energy and the State of Utah regulations.
White Mesa Mill - Standard Operating Procedures
Radiation Protection Operating Procedures are included in
Unit Operation.
Date:02107 Revision: DUSA I
Page2 of 2
this manual for each
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White Mesa Mill - Standard Operating Procedures
Book I Section 3
Ore Receiving
Date:02101 Revision: DUSA 2
Page I of8
1. Uranium and vanadium ores are received at the White Mesa Mill by truck and trailers.
Each load of ore weighs approximately 50,000 to 65,000 pounds (25 to 32 tons).
Truck scales will be checked for zero balance at beginning of each shift. Trucks
loaded with ore are weighed in at the scalehouse for gross weight. The truck driver
will be directed to dump in a specific area or stockpile by the scale house operator.
After the truck has dumped its load of ore, the empty truck and trailers are re-weighed
for a tare weight. Gross weight minus (-) tare weight equals (=) net weight of ore
received. An ore receipt slip is made for each load of ore which records:
a. Gross weight
b. Tare weight
c. Net weight
d. Mine from which ore is shipped
e. Truck and trailer numbers
f. Scale ticket number
g. Shipping lot numbers (stockpile numbers)
h. Mill lot number
i. Seller name (if applicable)
j. Transportation delivery number or tag number (If necessary)
k. Date
3. Each ore stockpile will be assigned a lot number.
4. Each Ore Receipt Slip will be assigned a Shipping Lot Number and a Mill
Number. A Shipping Lot will be approximately 1000 to 1500 tons of ore. A Mill
will be approximately 2000 to 5000 tons of ore.
Lot
Lot
5. Each Shipping Lot will be closed after receiving 1000 to 1500 tons of ore.
6.
White Mesa Mill - Standard Operating Procedures
Book I Section 3
Date;02107 Revision: DUSA 2
Page 2 of 8
After a load of ore is dumped, the Scalehouse Operator will take a hand sample of ore
from three different places and put it into a five (5) gallon sample buckets until the
Shipping Lot is closed. The lid is to be sealed tightly on a five gallon bucket after
each sample is taken to prevent losing moisture from the ore.
After the ore is sampled, the truckload will be probed a minimum of 15 times from
different locations in the pile, with the probe readings recorded on the attached Probe
sheet. The probe must be inserted to the minimum depth, which is marked on the
shaft of the T-Probe. The probe reading will be averaged and recorded on the Probe
sheet.
After the ore is sampled and a Shipping Lot is closed, the ore can be pushed up into a
designated Mill Lot pile. After a Shipping Lot has been closed, the sample bucket
containing the moisture sample of ore (with control number corresponding to the
Shipping Lot) will be crushed and dried to determine moisture content. Percent of
moisture will be calculated and recorded on Ore Receipt Slip and Moisture
Certificate.
Procedure to prepare ore sample for moisture calculation:
a. Contents of the ore sample bucket corresponding to the assigned control
number will be taken to the bucking room and be put through the jaw crusher
(set at about 3/8 inch opening).
b. Place an empty five gallon bucket under the jaw crusher. Pour contents of ore
sample bucket through the jaw crusher. The bucket(s) will be blended for at
least l5 minutes.
c. The mixed ore will then be poured through a splitter box. Place two empty
pans under the splitter box, pour ground sample of ore into top of splitter box.
When the two pans are full of ore, reject one pan of sample and pour ore from
the other pan into a clean bucket. Continue this procedure until ore sample is
split down to approximately 2,000 grams (5 pounds).
7.
8.
9.
White Mesa Mill - Standard Operating Procedures
Book I Section 3
Dale:02101 Revision: DUSA 2
Page 3 of 8
Using the 2,000 grams of ore sample, which has been collected through the
splitter, place an empty drying pan on the scales, push the tare button, add
2,000 grams (five pounds of sample to pan), push the clear button which will
give the gross weight of the pan and sample. Record on a Moisture
Certificate:
1. Wet weight
2. Pan tare weight
3. Date
4. Control number
5. Lot number
6. Mine from which the ore was received
Place the weighted pan of sample in the oven, dry the sample up to 150" C for
approximately 24 hours (no less than 16 hours).
After 24 hours, the dried sample will be removed from the oven and allowed
to cool for 30 minutes.
g. The cooled sample is then weighed and the percent of moisture calculated as
follows: Wet weight minus (-) dry weight equals (=) moisture loss in grams.
Calculation is as follows: Loss grams divided (+) by original weight times (x)
l$OVo = the percent of moisture.
h. All reject from the original truck load moisture samples will be retained for
later testing.
The dried moisture sample after being cooled and weighed is put into a plastic bag with
the third copy of the Moisture Certificate. The first two copies of the Moisture Certificate
are turned in with the Ore Receipt Slip for further distribution. Make sure all information
on the Moisture Certificate is correct and legible. The ore sample is filed as a future
assay and amenability sample. A portion of that moisture sample may be further prepped
for chemical analysis
9. When each ore truck driver and reagent truck driver enter the mill area for the first
time, the Scale house Operator on duty will give Hazard Training for Ore Delivery
d.
f.
White Mesa Mill - Standard Operating Procedures Date:02107 Revision; DUSA 2
Book I Section 3 Page 4 of 8
Personnel and Reagent Delivery Personnel. This procedure involves providing the
driver with a typed form. All drivers will be required to read the form and sign and
date the procedure form indicating that they understand and agree to follow Denison
Mines (USA) Corp.'s safety rules and procedures while on Company property. The
Scale house operator will sign the procedure form as the instructor for Denison Mines
(USA) Corp. Completed procedure forms will be turned in to the Safety Department
for future reference.
Ore Receivine Safety
1. Do not operate loaders near ore trucks dumping ore.
2. Be aware of heavy truck and equipment traffic.
3. Use caution when operating loader on slick and muddy ore pads.
4. Wear eye protection when crushing ore sample.
5. Practice and observe all Denison Mines (USA) Corp.'s safety rules.
White Mesa Mill - Standard Operating Procedures
Book I Section 3
Dale:02101 Revision: DUSA 2
Page 5 of 8
2.
J.
HAZARD TRAINING FOR ORE DELTVERY PERSONNEL
Revised: December 2006
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. ln order to assure your
safety while on our property, we would like to acquaint you with the safety rules and
procedures, which you will be required to follow while on our property.
1.0 General Safetv
1.Approved hard hats and safety glasses are required at all times except when inside the
cab of your truck.
This is a smoke free facility. No smoking is allowed on the property. Eating
anything, drinking, chewing candy, gum, or tobacco is not allowed in the Mill
Restricted Area, which encompasses the fenced and posted portions of the Mill, due
to radiation hazards.
Maintain a safe speed at all times when driving in the Mill Restricted Area. The
maximum speed limit is posted at 15 mph Denison Mines' equipment has the right of
way on the ore pad and Mill roadways.
Personnel other than direct employees of the trucking company are not allowed in the
Mill Restricted Area.
No person under 18 years of age is allowed in the Mill Restricted Area.
Check for potential overhead hazards prior to dumping.
Use caution when entering or exiting equipment.
Be aware of the possibility of a truck turning over while dumping. Keep yourself and
your truck clear of this possibility at all times and ensure brakes are set prior to
dumping.
9. If the trailer dumper is utilized to dump your load, check it thoroughly for safety
defects before operating. Do not attempt to operate unsafe equipment. Be sure to
utilize stabilizers properly.
10. If ore is hung up in the truck bed, it is not permissible to work in the bed while it is in
the dump position. If it is necessary to get in the bed of the truck to free a hang up,
the bed must be lowered.
4.
5.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book I Section 3
Date:02/01 Revision: DUSA 2
Page 6 of 8
l1.If the ore is frozen in the truck, it is not perrnissible to build fires under the bed in an
attempt to thaw it out. Do not use diesel fuel, antifreeze, or other petroleum-based
products to prevent ore from freezing to the trailer.
12.Be aware of slippery conditions on the ore pad during periods of inclement weather.
13. Be aware of the potential for ice build-up on and around the decontamination pad
during periods of cold weather.
2.0 Radiation Safety
1. All drivers will be required to scan for alpha radiation prior to leaving the Mill
Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving
the Mill's Restricted Area.
These standards will be strictly enforced and we expect your full cooperation in their
implementation. Failure to abide by these standards may result in denial of entry to the
property.
lnstructor:Date:
I have been fully informed of the above standards and agree to abide by them at all times
while on Denison Mines (USA) Corp. property.
Name:SS No.:
Date:Company:
Signature:
White Mesa Mill - Standard Operating Procedures
Book I Section 3
Date:02107 Revision: DUSA 2
Page 7 of 8
HAZARD TRAINING FOR REAGENT DELIVERY PERSONNEL
Revised: December 2006
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. ln order to assure your
safety while on our property, we would like to acquaint you with the safety rules and
procedures, which you will be required to follow while on our property.
1.0 General SafelX
l. Approved hard hats and safety glasses are required at all times except when inside the
cab of your truck. Approved safety shoes or boots may be required for certain
2. This is a smoke free facility. No smoking is allowed on the property. Eating
anything, drinking, chewing candy, gum, or tobacco is not allowed in the Mill
Restricted Area, which encompasses the fenced and posted portions of the Mill, due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The
maximum speed limit is posted at 15 mph Denison Mines' equipment has the right of
way on the ore pad and Mill roadways.
4. Use caution when entering or exiting equipment.
5. Respirators should be wom in dusty areas or where posted with signs.
6. Hearing protection should be wom when working around high noise levels.
7. Do not drink water from any source other than standard drinking fountains.
8. Do not look at the flash from welding operations.
9. Personnel other than direct employees of the trucking company are not allowed in the
Mill Restricted Area.
10. No person under l8 years of age is allowed in the Mill Restricted Area.
11. Be aware of slippery conditions on the ore pad during periods of inclement weather.
l2.Be aware of the potential for ice build-up on and around the decontamination pad
during periods of cold weather.
White Mesa Mill - Standard Operating Procedures
Book I Section 3
13. When unloading corrosive chemicals:
Date:02107 Revision: DUSA 2
Page 8 of 8
d.
a. Full protective equipment is required rn'hen working with corrosive chemicals.
This includes protective clothing, gloves, boots, chemical splash goggles, and face
shields in addition to the hard hat.
b. Prior to hooking up to unload, check the emergency eye-wash and shower to
assure that water is available in case of emergency.
c. Ensure that either a member of the Mill staff or another qualified delivery person
is present during the unloading of the shipment.
Never exceed 30 psi working pressure when using air pressure to unload trucks.
ln case of accidents, never remove your protective equipment until it has been
thoroughly washed off under the emergency shower. All incidents must be
reported to the Shift Foreman on duty as soon as possible.
Radiation Safetv
All drivers will be required to scan for alpha radiation
Restricted Area.
All equipment, i.e. trucks and trailers, will be scanned for
the Mill's Restricted Area.
to leaving the Mill
radiation prior to leaving
2.0
pnor1.
2.
These standards
implementation.
property.
lnstructor:
will be strictly enforced and we expect your
Failure to abide by these standards may result
full cooperation in their
in denial of entry to the
Date:
I have been fully informed of the above standards and agree to abide by them at all times
while on Denison Mines (USA) Corp. property.
Name:SS No.:
Date:Company:
Signature:
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ac
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Grind Circuit
Date'.02107 Revision: DUSA I
Page I of7
The purpose of the grind circuit is to grind the uranium and vanadium ores to the
proper size for maximum leaching, recovery, and accountability of the uranium and
vanadium in the ores.
Ore is segregated on the ore pad by mine name and stockpile number. Only one
stockpile of ore is fed to the grind circuit at a time and is normally fed in a minimum of
600 ton or a maximum of 2,400 ton lots. The reason for running one stockpile of ore at a
time and grinding a minimum of 600 ton lots is to get a good representative sample of
each stockpile of ore. The reason for a 2,400 ton maximum on lots is to prevent having
too much sample to blend. The mines are paid by the grades from the grind samples.
Also, the grind samples are used for mill accountability and recoveries.
Ore from the ore pad is fed to a grizzly by the feed loader operator. The grizzly
has 20"x20" openings to prevent rocks that are too big from falling into the ore hopper
and plugging the apron feeder. As the ore is dumped on the grizzly, it falls through the
20" opening into an ore hopper.
The ore hopper has a capacity of 50 tons. From the ore hopper, the ore is fed by a
hydraulic vara-speed drive apron feeder to a 54" conveyor belt. The speed of the apron
feeder drive controls the ore feed rate to the 54" conveyor. The 54" conveyor belt drops
the ore on to a vibrating feeder at the intake of the SAG mill. The vibrating feeder feeds
the ore into the SAG mill.
The SAG mill is a semi-autogenous grind mill. The mill is run by a 700 H.P.
electric motor through a gear box and air clutch. The bearings on the SAG mill are fed a
steady flow of oil from a hydrostatic recirculating oil pump. The oil recirculates through
a cooling water jacket for cooling. The water flows through the cooling jacket and
discharges into the SAG mill intake. There are sensors on all bearings to monitor the
bearing temperatures and flow of oil to the bearing. The SAG mill drive clutch will not
engage if oil flow is not going through the bearings. If the temperature gets too high or
oil flow to the bearings stop, an alarm on the conrol panel will sound and the air clutch
will disengage. If the alarm sounds, check the oil pump to be sure it is running. Shut off
ore feed to the mill. Shut down the SAG mill and notify your foreman immediately.
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Date:02107 Revision: DUSA I
Page 2 of 7
Grease for the ring gear and pinion is pumped by an automatic grease system at
the north side of the SAG mill.
All the lubrication to the SAG mill (oil to bearings and grease to the ring gear and
pinion) is very critical. Do not operate the SAG mill if lubrication is not operating
properly. Notify your supervisor immediately if there are any questions or doubts about
the mill getting proper lubrication.
The SAG mill has lifter plates around the inside and is charged with 3" grinding
balls. The mill rotates, lifting the balls and ore inside the mill with the lifter plates. As
the balls and ore inside the mill rotate to the top of the mill, they fall from the lifter plates
back to the bottom of the mill. When the balls and ore hit the bottom of the mill, the ore
is broken into smaller pieces. The mill continues to rotate breaking up the ore into
smaller and smaller pieces. Water is added to the ball mill at the intake and discharge
ends continuously while the ore is being crushed. As the ore inside the mill is crushed to
grain size, it is slurried with the water that is being added.
The slurry overflows the discharge end of the mill through grates and a reject
trommel screen, and into the mill discharge sump. If the overflowed slurry has any
oversized ore in it, the oversized ore (rock) is caught in an ore return chute and a stream
of water on the discharge end of the mill washes the oversized ore back into the mill to
re-grind. If the oversized ore is too big for the water stream to wash back into the mill, it
will discharge into a reject hopper. The amount of oversized ore is controlled by the
density of the slurry; if the density is too light or too heavy, there will be an excessive
amount of rejects from the mill. The density of the slurry should run approximately 70Vo.
The overflow slurry from the SAG mill discharge sump is pumped through a
direct drive pump to a splitter head tank. The splitter head tank splits the slurry evenly on
to three (3) Derrick screens. The Derrick screens have wire type mesh screens that
vibrate. As the slurry is vibrated down the screens, the properly ground slurry drops
through the screens. Any oversized sand in the slurry will not drop through the screens
and is vibrated down the screens to a launder and is washed back to the intake of the SAG
mill to be reground. The slurry that drops through the screens flows through a launder
and a primary sample is taken by a sample cutter bar moving through the slurry stream
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Date:02101 Revision: DUSA I
Page 3 of 7
flowing into the screen underflow sump. The slurry from the screen underflow sump is
pumped to a head tank and slurry can be diverted to pulp storage tanks by manually
controlled valves.
The slurry cut by the primary sampler (mentioned above) flows to a secondary
Vezin sampler where the sample is cut again. The portion of sample cut by the secondary
sampler is stored in a small mix tank where the sample is agitated until the ore lot is
finished or ore stockpile is changed. After the ore lot is finished or ore stockpile changed,
the agitated slurry stored in the mix tank is run through a tertiary Vezin sampler. The
slurry cut from the tertiary sampler goes to a five (5) gallon sample bucket. Sample
buckets are to be properly tagged with mine name, stockpile number, mill lot number,
and date. Completed sample buckets are to be tightly lidded. It is very important that
mill lot samples are properly taken. The finished mill lot sample is sent to the lab for
analysis and is used for accountability and ore recovery. After each sample has been
taken and put in a bucket, all samplers and mix tanks are to be washed with water before
starting a new sample.
Mill Lot Sample Equipment
Primary Sampler - Straight line, continuous sampler
13 cuts per minute, 36" travel, 7rh" per second cutter speed and adjustable cutter opening
Secondary Sampler - 16" Yezin, continuous cutter rotation, 2VzVo cut at 44 R.P.M.
Agitated Storage Tank - Plastic 36Y2"x38" I.D. Lightening agitator, 32" shaft, and 4"
two-blade impeller
Tertiary Sampler - Same as secondary sampler
The pulp tanks are located outside at the east side of the leach and grind building.
Each tank is 35 feet in diameter and 34 feet high and holds approximately 600 dry tons of
ore. Each tank has an agitator in it. The agitators are used to keep the slurry mixed so the
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Date'.0210'l Revision: DUSA I
Page 4 of 7
sand will not separate from the water. The agitator must be rururing when slurry is in the
tank or the sand will settle to the bottom and stop the agitator and plug the pre-leach feed
pumps. Minimum freeboard level on pulp storage tanks will be 18".
There is a bag house located northwest of the ore grizzly. The purpose of the bag
house is to collect dust from the apron feeder area and the 54" conveyor belt. Dust is
sucked through the bag house by a fan on top of the bag house. The bags inside the bag
house collect the dust. The bags are shaken periodically to drop the dust they contain. As
the dust drops to the bottom of the bag house, an auger carries it to the 54" conveyor belt
going to the SAG mill.
Do not feed the grizzly or run the apron feed unless the bag house is operating
properly.
Switches for the bag house fan and auger are located at the east side of the bag
house.
There is a fan located in the roof above the apron feeder to control radon in the
apron feeder area. This fan is to be running when the SAG mill is operating. The
start/stop switch is located below the bag house.
Also, there are two (2) wall fans on the bottom floor of the SAG mill. One of the
fans is located at the northeast side of the SAG mill and the other is located on the
southeast side of the SAG mill. There are two (2) exhaust fans: one is located above the
vibrating feeder and one is above the trommel reject screen. These fans are to be run
when the SAG mill is operating. The starUstop switches are located at the fans.
All controls, indicators, readouts, alarms, and starUstop switches for operating the
apron feeder, 54" feed belt, SAG mill, and related pumps are located on the CP-l panel in
the grinding control room. The main electrical disconnect panels are located in the MCC
room under the shifter's office.
Mill Feed Operatine Procedure
1. Before operating the loader or haul truck, check the engine water and cooling system,
engine oil, hydraulic oil, air filter, tires, and fuel.
2. Lubricate the loader and haul truck at the beginning of each shift.
White Mesa Mill - Standard Operating Procedures
Book I Section 4
3. After mobile equipment is started,
Mobile Equipment Checklist sheet.
can be used.
Date:02107 Revision: DUSA I
Page 5 of7
check the brakes and back up alarm. Fill out
Any defects must be corrected before equipment
4. Obtain ore stockpile name and stockpile number from your shift foreman.
a. Check ore stockpile identification sign to be sure ore stockpile name and
stockpile number correspond with the stockpile name and number obtained
from your shift foreman.
5. Start bag house dust control equipment, screw conveyor rotary valve and fan.
6. Start apron feeder area exhaust fan.
7. Moisture sample: Take one (1) dipper of ore from every fourth (4th) bucket of ore; if
a truck is used to haul ore, take one (1) dipper of ore from each truck load.
a. Sample is to be kept in a five (5) gallon bucket and tagged with the mine
name, stockpile number, mill lot number, and the date. Keep the sample
bucket cover on at all times.
b. Mill ore lots normally will be at least 600 tons and not more than 2,400 tons.
8. Clean up ore pad at the end of each stockpile. Do not mix ore stockpiles.
9. Clean up gizzly area after each mill lot.
a. Use safety cables and safety belts when cleaning the grizzly.
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Date'.02107 Revision: DUSA I
Page 6 of7
10. Keep the SAG mill rejects dumped north of the mill building, scraped up and piled
north of the gizzly.
ll.Always be cautious of traffic congestion, ore delivery trucks, reagent trucks, mill
vehicles, etc.
12. Good housekeeping is part of your job - see that it is done.
13. Observe safety rules and wear safety equipment at all times.
White Mesa Mill - Standard Operating Procedures
Book I Section 4
Date: OZl07 Revision: DUSA I
PageT of7
Vibratine Feeder
The vibrating feeder is used as a transient conveyor from the 54" conveyor belt to
the SAG mill intake.
The vibrating feeder is a type of feeder supported on coiled springs. The drive
mechanism is fitted with off-center mounted rotating weights driven through "V" belts by
an electric motor. By use of an adjustable pitch sheave, the drive speed can be changed.
The force developed by the rotating weights vibrate the entire feeder. The vibrating
feeder is equipped with adjustable counter weights and variable speed drive sheave to
allow the feeder to be timed. If the feeder is not properly timed and vibrates excessively,
the unit can be damaged. If the feeder does not vibrate enough, the ore will not move
down the chute to the SAG mill intake.
Proper timing of the feeder is very important for correct operation. The feeder can
only be timed by qualified personnel.
Any ore build up on the vibrating feeder unit will cause the timing of the feeder to
be off.
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White Mesa Mill - Standard Operating Procedures Date:02107 Revision: DUSA
Book I Section 5 Page I
Start Up Procedure for Grind Circuit
l. Get ore stockpile name and number from Shift Foreman.
2. Record starting belt scale reading on log sheet.
3. Check all panel alarms and indicator lights.
4. Start SAG mill motor (motor will warm up to operating temperature while making
circuit checks).
5. Check vibrating screens and vibrating screen lubrication system.
a. Check oil supply bottles for adequate supply of lubrication oil.
6. Check pulp tank levels and the valve settings from pulp head tank to pulp storage
tanks.
7. Check ring and pinion gear lubrication barrel to be sure there is an adequate supply of
grease.
8. Check all process sampling equipment.
a. All samplers will be cleaned before changing to a different ore stock pile.
9. Before starting any equipment, make sure all safety guards are in place and area is
clear of persormel.
10. Start grind mill oil circulating and hydrostatic oil pumps, turn on and check water
flow through oil tank heat exchanger.
I
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11. Turn on water to mill discharge and screen underflow pumps.
White Mesa Mill - Standard Operating Procedures
Book I Section 5
12. Turn on air supply valve.
Dat,s:A2l07 Revision: DUSA I
Page2of 2
13. Tum ring and pinion gear lubrication system switch to automatic position.
14. Start all three (3) vibrating "Derrick" screens.
15. Start direct drive pump.
16. Start screen underflow pump.
17. Pump up any water in floor sumps.
18. Turn main mill feed water valve on. If recycle grind water is used, start recycle grind
water feed pump.
a. Recycle grind water is metered and sampled. Before starting recycle grind
water pump, record meter reading on log sheet and place sample bucket under
sampler.
b. Start vibrating screen reject launder water.
19. Engage mill air clutch which, in turn, starts the SAG mill.
20. Start vibrating feeder.
21. Start 54" conveyor belt and belt cleaning brush.
22. Start apron feeder.
23. Start and adjust dust control sprays.
White Mesa Mill - Standard Operating Procedures
Book I Section 5
24. Adjust grind water to obtain as
underflow pumps will pump.
25. After SAG mill has been running for 15
the samplers and start all samplers.
Date:02107 Revision: DUSA I
Page 3 of 3
a density as the mill discharge and screen
put the mill lot sample bucket under
26. Good housekeeping is part of your job - see that it is done.
27. Observe all safety rules and wear safety equipment at all times.
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White Mesa Mill - Standard Operating Procedures
Book I Section 6
Shut Down Procedure for Grind Circuit
1. Clean up all ore around grizzly walls and grate.
Date;02107 Revision: DUSA I
Pagel of 2
2. Empty grizzly, run all the ore off the 54" belt and vibrating feeder.
3. Stop apron feeder, 54" conveyor belt, conveyor belt brush, and vibrating feeder.
4. Turn offdust control sprays.
5. Grind out SAG mill until the SAG mill motor drops to 50 amps.
6. Stop the SAG mill motor.
7 . Turn off the ring and pinion gear lubrication.
8. Tum off air supply valve.
9. Stop the SAG mill oil circulating and hydrostatic oil pumps; turn off the oil heat
exchanger cooling water.
10. Tum off the SAG mill grind water.
11. Stop the mill direct drive pump.
12. Stop the screen underflow pump.
13. Turn off the glad seal water to direct the drive and screen underflow pumps.
14. Stop the vibrating "Derrick" screens.
a. Check the "Derrick" screens for holes.
White Mesa Mill - Standard Operating Procedures Date.02107 Revision: DUSA I
Book I Section 6
15. Stop the ore samplers.
16. Record the ending belt scale reading on the log sheet.
17. Record the recycle grind water meter reading on the log sheet when the recycle grind
water is being used.
Page2of ,
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White Mesa Mill - Standard Operating Procedures
Book I Section 7
Emerqency Shut Down Procedures for Grind Circuit
1. Stop the apron feeder.
2. Stop the conveyor belt.
3. Stop the vibrating feeder.
4. Stop the SAG mill.
5. Stop the mill discharge pump.
6. Stop the "Derrick" screens.
7. Stop the screen underflow pump.
8. Close all water valves.
Power Outage
1. Close water valves.
Date:02107 Revision: DUSA I
Page I of I
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White Mesa Mill - Standard Operating Procedures
Book I Section 8
Datei 02107 Revision: DUSA I
Page I of 2
Shift Inspection - Grind Operator
1. lnspect all moving equipment for proper guards and guards in place once per shift.
a. Shut off equipment, lock out, and replace guard if not in place.
2. Inspect eye wash fountain for proper operation once per shift.
a. Repair immediately, if needed.
3. lnspect 54" feed belt condition during the first hour of the shift.
a. Immediately report to your supervisor if a tear is noted or splices are bad.
4. lnspect 54" feed belt tail pulley clearance during the first hour of the shift - ore
spillage around the tail pulley can damage the belt.
a. Notify your supervisor and shut off the belt, lock out, and clean up ore
spillage.
5. Inspect the trommel screen and rock return chute every four (4) hours for holes.
a. Notify your supervisor if any are noted.
6. Inspect the "Derrick" screens for holes and leaks at the beginning of the shift.
a. Replace screens as necessary and repair leaks.
7 . lnspect and calibrate density scales during the first hour of the shift.
8. lnspect vibrating feed every four (4) hours for ore build up or rocks jammed around
moving parts.
9. lnspect and test 54" feed belt emergency stop cable and switch at the beginning of the
shift.
a. Do Not operate the belt if the emergency stop is not operating properly.
White Mesa Mill - Standard Operating Procedures
Book I Section 8
Datei 02107 Revision: DUSA I
Page2 of 2
10. Inspect the pulp tank agitators for proper running conditions once a shift.
a. Notify your supervisor if any problems are noted.
11. Inspect sulfuric acid lines and valves on top of pre-leach tanks and the pulp tank for
leaks or seeps every four (4) hours.
a. Notify your supervisor immediately if any are noted.
12. lnspect roof fans every four (4) hours for proper operation.
a. Notify your supervisor immediately if problems are noted.
13. Inspect all wall and ventilating fans every four (4) hours for proper operation.
a. Notify your foreman if problems are noted.
14. lnspect agitator shafts and props in the pulp tanks for rubber damage each time the ore
slurry is below prop.
a. Notify your supervisor if damage is noted.
15. Inspect ore samplers every one (1) hour for plugs and proper operating conditions.
a. Unplug immediately if necessary.
b. If samplers are not operating properly, notify your supervisor immediately.
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White Mesa Mill - Standard Operating Procedures
Book I Section 9
Datet 02107 Revision: DUSA I
Page I of I
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chernicals are used in the
processing of uranium. These include such items as:
l. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
10. Fiberglassing Compounds
I l. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Material Safety Data Sheet (MSDS) provided in strategic locations throughout
the mill area. These can be found in the following locations; safety office, laboratory,
maintenance break room and central control room.
The MSDS supplies a description of the chemicals and reagents. The MSDS also
explains the hazards, spill procedures, safe use, and first aid procedures for each chemical and
reagent.
Each operator must read and understand the MSDS of all chemicals and reagents used in
his/her department, and be familiar with the chemicals and reagents used in all operating
departments.
White Mesa Mill - Standard Operating Procedures
Book I Section 9
times.
Date:0210'l Revision: DUSA I
Page2of 2
Each operator must know the location of all MSDS's for his/her operating circuit at all
White Mesa Mill - Standard Operating Procedures
Book I Section 9
Information Contained on Hazardous Material Safety Data Sheets
Hazardous Material
Datet 02107 Revision: DUSA I
Page 3 of 3
Shipping Name
DOT Hazard Class
Chemical Name
I.D. Number
S.T.C.C. Number
Vapor Density
Physical Description
Normal Physical State Physical state or form of the material at normal
Color
temperatures (68"F - 77"F).
The color of the material under normal conditions.
The odor of the material upon its release.Odor
Chemical Properties
Specific Gravity
The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Depanment
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "IIN" or
"NA."
The Standard Transportation Commodity Code number used in the rail
industry; a seven{igit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous
material, the S.T.C.C. number will begin with the digits "49."
ambient
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than l, the material is
lighter than water and will float; if the specific gravity is greater than l,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than l, the material is lighter than air and may rise; if the
vapor density is greater than l, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric
pressure.
Boiling Point
White Mesa Mill - Standard Operating Procedures
Book I Section 9
LCto
Ingestion Hazard
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
Date:02107 Revision: DUSA I
Page4of 4
Melting Point The temperature at which a solid changes to a liquid; this temperature is
also the freezing point depending on the direction of the change.
Vapor Pressure The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressurc it will exert at a given temperature.
Solubility The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend unifbrmly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Degree of Solubility Indication of the solubility of the material.
Other Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard Is there any hazard from breathing this material?
T.L.L./T.W.A. Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
The concentration in p.p.m. that kills 5AVo of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose - the dose that kills 5O7o of the test animals.
Is there any hazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value - an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value - maximum allowable concentration
or ceiling, not to be exceeded during a l5 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
White Mesa Mill - Standard Operating Procedures
Book I Section 9
Teratogen
Hazardous to
Aquatic Life
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic ProductsThe toxic by-products of the combustion process.
of Combustion
Date:021o1 Revision: DUSA 1
Page 5 of 5
A material that causes the production of a physical defect in a
developing embryo.
Is the material harmful to aquatic life?
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer ofany contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature - the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range - the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L.*
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
Other
Possible
Bxtinguishing
Agent
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
White Mesa Mill - Standard Operating Procedures
Book I Section 9
Date:02101 Revision: DUSA I
Page 6 of 6
Reactivity
Reactivity Will the material react with any other materials?
With what? What is this material reactive with in what ways?
Other Any additional pertinent information or data found.
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from 0 to 14.
Corrosive to what? Materials with which the material is corrosive, particularly skin and
steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity Will the material emit radioactivity?
Hazards
Type of Radiation Indicate the type of radiation emitted, either alpha particles, beta
Emitted particles, or gamma radiation.
Other Any additional pertinent information or data found.
Recommended Protection
For the Public Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
For Response Level of protection required for emergency response personnel
White Mesa Mill - Standard Operating Procedures
Book I Section 9
Date:02107 Revision: DUSA I
PageT of 7
Personnel working in the danger zone:
Ixvel A - Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B - Requires the highest level of respiratory protection, but a
lower level of skin protection. It is the minimum level recommended on
initial entries until the hazards have been further identified and defined
by complete monitoring, sampling, and evaluation.
Level C - Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D - Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.For the
Environment
Note: The back of the Hazardous Material Data Sheet can be used to collect additional
information of a more specific nature.
Feed and Grind
Some of the major chemicals used in the Feed and Grind process areas are listed as examples:
L Sulfuric Acid - -93 to 95Vo strength
2. Monowet
3. Gear Grease Compound - Surett Fluid 4K
4. Petroleum Lubricating Oil - Spartan EP22O
5. Petroleum Lubricating Grease - Ronex MP
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White Mesa Mill - Standard Operating Procedures
Book I Section 9,A,
Dale:02107 Revision: DUSA I
Page I of I
SpilUDisposal Procedures
Certain chemicals, when spilled or disposed of, have reporting requirements
associated with them. The M.S.D.S. forms for all chemicals used in Uranium Recovery
Operations are listed, along with an indication of which chemicals have reporting
obligations. The following is an explanation of the actions required of the Mill Operator
when dealing with these chemicals. Without exception, your supervisor will make any
required reports. Refer to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed.
The specific requirements will be delineated by the Environmental Department. If you
need to dispose of any chemicals, contact vour supervisor for instructions. The containers
that held these products may be disposed of in any rrash receptacle if:
l. The container has less than 5Vo left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reportine
Reportable spills of certain chemicals must be immediately reported to
governmental agencies, depending on the quantity and type of chemical spilled. A
reportable spill is basically when the chemical hits the ground (earth), as opposed to a
spill to a concrete pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your
supervisor. Your supervisor will determine if a report to an agency is necessary. your
supervisor will make the report, if needed. Do not attempt to make a report yourself. If
there is any doubt, contact your supervisor for advice and direction.
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White Mesa Mill - Standard Operating Procedures
Book I Section l0
Hazards - Ore Receiving. Feed. and Grind Circuit
1. Moving Mobile Equipment
Date'- 02/01 Revision: DUSA
Page I
Ore delivery truck
Front end loaders
Dump trucks
Pickup trucks
Water wagon
Fork lifts
g. Delivery and shipping vehicles
2. Uneven Ground
3. Cleaning OreGrizzly
4. Moving Conveyor Belts
5. Falling Rocks
6. Dust
7. Noise
8. Cleaning Plugged Feeders and Chutes
9. High Pressure Air Lines - 100 p.s.i.
10. Overhead Crane
11. Rotating SAG Mill
12. High Pressure Oil Lines
13. Slick Ore Pad Area When Wet
Items listed above can be hazards if not controlled properly. If controlled properly
and to operating standards, they are safe.
I
of6
a.
b.
c.
d.
e.
f.
White Mesa Mill - Standard Operating Procedures
Book I Section l0
Date:02/0'7 Revision: DUSA I
Page2of 6
Hazard Recognition - Scalehouse
1. Hazards
a. Delivery Trucks
b. Ore Haulers
c. Product Haulers
l. Must read and sign Hazard Training Sheet
2. Must be issued a hard hat and safety glasses
d. Loaders - Haulage Trucks (Denison Mines (USA) Co.p.)
e. Jaw Crusher and Drying Unit in Bucking Room - Pinch Points - Heat
f. Stockpile Hazards
l. Falling rocks on stockpiles
2. Tripping hazards during sampling operation
3. Radiation hazards from stockpiles
4. Lifting of sample buckets
5. Weather condition considerations
White Mesa Mill - Standard Operating Procedures
Book I Section l0
Hazard Recoenition - Mill Feed and Stockpiles
l. Hazards
Datet02l07 Revision: DUSA I
Page 3 of 6
e.
a. Delivery Trucks - Speed Limit of 15 M.P.H.
b. Ore Haulers - Speed Limit of 15 M.P.H.
c. Product Haulers - Speed Limit of 15 M.P.H.
d. Denison Mines (USA) Corp. equipment has the right of way.
AWARE OF ALL PERSONNEL AND TRUCKS IN YOUR AREA.
BE
f.
Grizzly
1. Safety belt must be used during work on the grizzly
2. Safety chain must be installed during maintenance work
Dust Collection
1. System must be stared before ore is fed to SAG mill - possible
electrical shock
Cleaning of Tunnel
l. Conveyor must be locked out to clean underneath
2. Respirator required - radiation and silica dust
3. Hearing protection must be worn when the dust collection system is
operating
4. Replace guards when finished cleaning
5. The biggest hazard in the tunnel is the moving conveyor
6. Radiation Work Permit will be required if it is determined that there is
a potential for elevated radiation exposure based on an assessment of
the work environment.
SAG Mill Area
1. Rotating mill
2. Moving conveyor
3. Vibrating feeder
4. Guards must be in place
5. Falling rocks from the SAG mill feed chute - above vibrating feeder
6. Hot oil system
o6'
h.
White Mesa Mill - Standard Operating Procedures
Book I Section l0
Date:02107 Revision: DUSA I
Page 4 of 6
7. Foaming of #l pre-leach tank
8. Traffic in north door of mill building
a. Using a forklift to remove rejects - BEWARE OF TRAFFIC
AND PERSONNEL
9. Lifting of sample buckets - using proper lifting techniques
2. Health Hazards
a- Silica and Nuisance Dusts and Mists
b. Hearing Protection
c. Radiation
1. Airborne uranium
2. Radon progeny
3. Beta gamma
White Mesa Mill - Standard Operating Procedures
Book I Section l0
Hazard Recosnition - SAG Mill Operator
1. Hazards
Health Hazards
a. Radiation
1. Radon progeny
2. Airborne uranium
3. Beta gamma
Date'.02107 Revision: DUSA I
Page 5 of
a. Conveyor
b. Rotating Mill
c. Vibrating Feeder - Apron Feeder
d. Hot Oil System
e. Falling Rock from SAG Mill Feed Chute Above Vibrating Feeder
f. Foaming of #1 Pre-leach Tank
g. Using Forklift to Empty Reject Bin - BE AWARE OF PERSONNEL AND
TRAFFIC in north door of the mill building
h. Acid Lines - Pump Storage
i. Steam Lines
j. High Pressure Air Lines
k. Guards
I. Pinch Points
1. Idlers and rollers
2. Head and tail pulley
3. All guards must be in place before running
4. Cleaning up around pumps
m. Overhead Crane During Loading Balls into SAG Mill
n. Overhead Crane During Relining SAG Mill (must be roped off)
o. Overhead Crane Must Not be Used when SAG Mill is Rotating
p. CAUTION - Wet Decks are Slick and Fall Hazard
2.
White Mesa Mill - Standard Operating Procedures
Book I Section l0
b. Silica and Nuisance Dusts, Mists and Fumes
c. Hearing Protection
Datgiozl}l Revision: DUSA I
Page 6 of 6
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White Mesa Mill - Standard Operating Procedures
Book I Section ll Date:02107 Revision: DUSA I
Page I of I
JOB PROCEDURES
This section covers job procedures for non-daily routine jobs that are performed
ORE RECEIVING, FEED, AND GRIND
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill - Standard Operating Procedures
Book I Section ll
Datei 02107 Revision: DUSA I
Page2of 2
Operator Procedure for Cleaning Ore Grizzlv
1. Safety cables are installed at the north and south sides of the grizzly.
a. One end of the cable is attached to the bin.
b. The other end of the cable is looped so that a safety belt can be attached.
2. Do not work in the grizzly area without a properly secured safety belt.
3. Before entering the grrzzly area:
a. Park the loader approximately 10 feet east of the ore bin with the brake set,
bucket down, and the engine off.
b. lnspect the safety cable to be sure it is attached securely to the grizzly wall.
c. Inspect the safety cable for defects. If defects are seen, do not use the cable.
Notify your foreman. Do not work in the grizzly area.
d. lnspect the safety belt and tie rope for defects. Do not use if defects are noted.
e. Put on the safety belt.
f. Attach the tie rope on the safety belt to looped end of the safety cable.
g. Check the length of the safety cable and tie rope so that if you slip or fall, you
will not fall between the grizzly bars.
4. Clean grizzly as needed.
5. After cleaning is completed, move out of the ore bin and away from the grizzly, and
take off the safety belt.
6. Hang cable away from the area so that the loader will not catch the cable when it is
dumping ore.
Hazards of the .Iob
1. Slipping on the gizzly and falling between the bars.
White Mesa Mill - Standard Operating Procedures
Bookl Sectionll
2. Stepping on ore material and twisting an ankle.
3. Pinch points when handling materials.
4. Potential foot hazards.
I have read and understand the above job procedures.
Date:021O7 Revision: DUSA I
Page 3 of 3
FaIi
a;sc9
BE
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Datei 02107 Revision: DUSA I
Page I of 13
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill - Standard Operating Procedures
Book I Section l3
Revision: DUSA I
Page2of 13
GENERAL RULES
Introduction
All safety rules are listed in the White Mesa Mill Safety Manual. However, several
general rules applicable to this process area are delineated below.
Reporting Unsafe Conditions and Iniuries
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries - no matter how slight - to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothins
1. Hard hats, safety shoes, and safety glasses with side shields must be wom at all times
in the plant area - except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certainjobs. Ifin doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Date 02101 Revision: DUSA I
Page 3 of 13
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Hair that extends below the T-shirt collar or extends two inches laterally from the
head (on a natural lay) must be contained by a net of other adequate means.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the Ladder
and Scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
ahazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
White Mesa Mill - Standard Operating Procedures
Book I Section 13
l. Violation of any safety rule.
Date:02107 Revision: DUSA I
Page 4 of 13
2. Entering the plant while under the influence of alcoholic beverage or drugs, or having
them in your possession while in the plant area.
3. Fighting, wrestling, or engaging in "horseplay''while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area without specific written permission.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Date:02/0'7 Revision: DUSA I
Page 5 of 13
OPERATIONS . SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical equipment repairs are to be completed by an
DMUSA approved electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected to
determine its condition.
7. All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Datg'02/07 Revision: DUSA I
Page 6 of 13
8. Safe operation ofconveyors requires that you shall:
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Date:02107 Revision: DUSA I
Page 7 of 13
ORE RECEIVING AND GRIND - SAFETY RULES
Ore Receivins and Samplins
1. Personnel shall stand well clear of trucks when the bed is inclined. Trucks can tum
over and there is always danger from falling rocks. When the dump trucks are
unloading, stand at least 50 feet away.
2. Loader and truck operators should be aware of personnel and equipment entering their
area, but people should be aware that the operator may not see them and, therefore,
should stay clear of the equipment.
3. Axle high berms shall be maintained on all stockpiles driven upon.
4. A Safe Work Permit and a confined space entry permit must be obtained before
entering any bin or hopper. A Radiation Work Permit will be required if it is
determined that there is a potential for elevated radiation exposure.
5. Safety belts and lines must be worn and tied off while working on the grizzly.
6. When sampling loads of ore, be careful not to step on rocks and tum your ankle or
fall.
Grind
1. No one shall go into the SAG mill until a Safe Work Permit and Confined Space
Entry Permit have been completed to cover the work to be done. The person entering
the mill must comply with these permits. A radiation work permit will be required if
it has been determined that there is a potential for elevated radiation exposure.
2. If the dust collector is inoperative, notify your supervisor at once.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Datet 02107 Revision: DUSA I
Page 8 of 13
3. Spills (i.e., ore, water, grease) must be cleaned up at once and the cause coffected as
soon as possible.
4. All safety guards, including dust hoods, must be replaced before a piece of equipment
is started.
5. A careful inspection shall be made before starting equipment to ensure that all
personnel and obstructions are clear.
6. Entry into the slurry storage tanks shall be covered by a Safe Work Permit and a
Radiation Work Permit.
7. Do not unplug the apron feeder or vibrating feeder by getting in chutes or inside
feeders. If plugs or rocks cannot be removed without getting inside feeders, notify
your foreman before continuing.
Conveyor Belts
1. Conveyor belts are sometimes called "silent killers." Be aware and alert at all times
when working around them.
2. Never attempt to clean conveyor idlers, head, or tail pulleys while the belt is in
motion. Never attempt any work on a conveyor unless the motor is shut off and the
lockout procedure has been followed.
3. Never ride on. cross over or under a moving conveyor. Use walkways and crossovers
that are provided.
4. Know the location of emergency stop cords and how to use them.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Date:02107 Revision: DUSA I
Page 9 of 13
5. Emergency stop cords on all conveyors must be tested for proper operation by the
operator on each shift and a notation entered on the Iog sheet that the test was
completed. All malfunctions must be reported and repaired before belt is operated.
Never operate the conveyor if the emergency stop cord is not working properly.
6. All guards must be kept in place, except when the conveyor is properly locked out.
7. Remember that a tool can be caught in a pulley or idler so quickly that you will not
have time to let go before it catches you. Be extremely cautious when working
around conveyors.
8. Always wear close fitting clothing that cannot become caught in moving parts.
9. When shoveling clean up material onto a moving conveyor, always face in the
direction of conveyor travel. Never shovel onto a conveyor that is moving toward
you.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
Date:02107 Revision: DUSA I
Page l0of 13
MOBILE EQUIPMENT - SAFETY RTJLES
General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. This needs to be documented on the forms
provided. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEYER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
10. Keep the cabs of equipment clean. Loose
other hazards are not allowed.
Date:02101 Revision: DUSA I
Pagellof 13
items which could jam controls or create
ll.Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs,
berms where required.
Dump Trucks
1. Do not move the truck until the air pressure
2. Do not overload the truck.
and unstable banks. Maintain adequate
is built up to normal.
3. Release the parking brake before moving the truck.
the truck without slipping the clutch.
Use a low enough gear to start
4. Except to shake out the load, no truck shall be driven until the bed is in the full down
position.
5. Never work under a raised bed of a truck unless it is securely blocked.
White Mesa Mill - Standard Operating Procedures Date:02107 Revision: DUSA I
Book I Section 13 Page 12 of 13
6. Park the truck in its designated parking place with the brakes set and engine off.
Front End Loaders
1. No one but the operator is permitted to ride on the loader.
2. Never leave the loader without dropping the bucket to the ground.
3. Do not jump off loaders. Use hand rails and steps when getting on or off equipment.
4. When stepping from the loader to the ground, be sure there are no rocks that you
could step on and turn your ankle.
5. Do not strike the dump truck with the loader bucket or wheels.
6. Avoid spinning or slipping the drive wheels of the loader as much as possible.
7. Do not move loaders equipped with air brakes until the air pressure is built up to
normal.
8. Park the loader out of the way or in the designated parking place with the brakes set
and engine off.
9. Always keep the bucket as low as possible when traveling.
10. When lubricating front end loaders, park the loader on flat ground, bucket down,
parking brake set, and the engine off.
White Mesa Mill - Standard Operating Procedures
Book I Section 13
d.
e.
f.
ob.
Date:02107 Revision: DUSA I
Page 13 of 13
Operator Procedure for Cleaning Ore Grizzlv
1. Safety cables are installed at the north and south sides ofthe grizzly.
a. One end of the cable is attached to the bin.
b. The other end of the cable is looped so that a safety belt can be attached.
2. Do not work in grizzly area without a properly secured safety belt.
3. Before entering the grizzly area:
a. Park loader approximately 10 feet east of the ore bin with the brake set, bucket
down, and the engine off.
lnspect the safety cable to be sure it is attached securely to the grizzly wall.
lnspect the safety cable for defects. If defects are seen, do not use the cable -
notify your foreman. Do not work in the grizzly area.
Inspect the safety belt and tie rope for defects. Do not use if defects are noted.
Put on the safety belt.
Attach tie rope on the safety belt to looped end of the safety cable.
Check length of the safety cable and tie rope so that if you slip or fall, you will
not fall between the grizzly bars.
4. Clean the grizzly as needed.
5. After cleaning is completed, move out of the ore bin and away from the grizzly and
remove the safety belt.
6. Hang cable away from the area so that the loader will not catch the cable when
dumping ore.
b.
c.
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White Mesa Mill - Standard Operating Procedures
Book I Section 14
Date:02107 Revision: DUSA I
Page I of I
1.
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have received.
Listed below are the Radiation Safety Procedures for ore receiving and grind which, when
followed, will maintain your exposures A.L.A.R.A. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained A.L.A.R.A.
Ore Receiving and Grind Radiation Safetv Procedures
A.L.A.R.A. Program Policy Statement
The policy of Denison Mines (USA) Corp. to maintain good radiation protection
practices is the expenditure of every reasonable effort to achieve and maintain low
levels of contamination and radiation in occupational exposures. By definition, the
A.L.A.R.A. program shall result in radiation exposures being maintained to levels as
far below any applicable limits of the N.R.C. regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
radiation safety personnel.
Denison Mines (USA) Corp. is committed to maintaining occupational exposures of
personnel at White Mesa to levels as low as reasonably achievable. This commitment
is supported by the training program conducted for facility personnel, and continuous
reviews of radiation, environmental, and industrial hygiene protection policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
potential radiation exposure will be made for those non-routine work activities which
2.
White Mesa Mill - Standard Operating Procedures
Book I Section 14
Date: O2l0'l Revision: DUSA I
Page2of 2
Work Permit. If it is determined, by this
for elevated radiation exposure, a Radiation
may require the issuance of a
initial assessment, that there is
Work Permit will be issued.
Radiation
a potential
A Radiation Work Permit will be issued by the radiation staff.
Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at ore receiving and grind will require a Radiation
Work Permit if is determined that there is a potential for elevated exposure
based on an assessment of the work environment.
1. Ore Receiving
a. Entry into the ore receiving bin for any repairs.
b. Clean up of ore spills in the SAG mill tunnel.
2. Grind
Entry into the SAG mill.
Any repairs to the discharge or screen underflow sumps.
c. Entry into the pulp storage tanks.
d. Clean up of spills around the pulp storage tanks.
This is not an all-inclusive list of jobs at ore receiving and grind that could require a
Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
As a part of A.L.A.R.A. practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
a.
b
a
b
White Mesa Mill - Standard Operating Procedures
Book I Section 14
Date:02107 Revision: DUSA I
Page 3 of 3
CAUTION - AIRBORNE RADIOACTM AREA This sign is posted in an area in
which airborne uranium or radon progeny concentrations are, or at above 25Vo of the
specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airbome concentrations are below 257o D.A.C. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon progeny concentrations above 25Vo
D.A.C.:
a. SAG Mill Tunnel
b. SAG MiII
c. Pre-leach Area
CAUTION - RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 2 mr/fu. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Our primary means of control for gamma or beta is limiting time spent in the
radiation area.
b. The ore stockpiles are the only current location within this circuit where
gamma radiation levels have been identified as being at 5 mr/hr.
4. Procedures to Follow Regarding the Use of Respirators
When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the shifters office. After the initial
fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
If you are using a respirator in a very dusty area, it may be necessary to change
the filter after two to three hours. When resistance to breathing becomes
uncomfortable, it is a sign that the filters have served their useful life and need
to be replaced.
At the White Mesa Mill facility, we use only one type of respirator cartridge
for the full-face respirators. The combination cartridge is acceptable for
nuisance dusts, chemical mists and radiological dusts..
b.
C.
5. Radiation Safety Procedures
White Mesa Mill - Standard Operating Procedures
Book I Section 14
These are practices that, if you follow, will
working at the White Mesa Mill:
Date:02/O7 Revision: DUSA I
Page 4 of 4
minimize your radiation exposure while
a. Practice good housekeeping to prevent build up of ore spills in the tururel and
around the SAG mill.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
Store your lunch box and eat only in a designated eating area.
Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
Always wear your dosimetry device when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while the SAG mill is operating (full-
face respirator).
f. If any of the equipment listed below is not operating, or if there is evidence of
excessive dusting, notify your shift foreman.
1. Baghouse atGrizzly
2. Tunnel Mine Fan
3. Conveyor Drop Fan
4. North Wall Fan
5. East Wall Fan
4.
5.
c.
d.
White Mesa Mill - Standard Operating Procedures
Book I Section 14
Datei 02107 Revision: DUSA I
Page 5 of 5
Electrostatic Precipitator in the SAG Mill Control Room
Roof Fan
g. If you are concerned or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
Routine urinalysis samples for operators at ore receiving and grind will be taken every
two weeks. Urinalysis samples are utilized to determine the uranium content
contained in the urine of the operator. The frequency of sampling is dependent on the
airbome concentrations and will be changed if airborne levels exceed 257o of the
airbome standards.
To minimize the chance of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
retuming from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing into
your work clothes or reporting to your work location. The samples can then
be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner, the
worker should shower immediately prior to voiding. When a shower is not possible,
disposable plastic or rubber gloves should be wom during voiding. Take all necessary
precautions to ensure that your urine sample is not contaminated.
6.
7.
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9.g
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1.
White Mesa Mill - Standard Operating Procedures
Book I Section 15
Date'.02107 Revision: DUSA I
Page I of I
OPERATOR'S RESPONSIBILITIES
Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
After the shift change has been made, the oncoming operator will read the circuit log
book at the begiruring of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
Operate equipment within specified parameters.
No alarms are to be blocked out or otherwise made to be inoperable at any
time.
Maintain a proper operating log sheet.
Collect and properly label all mill control samples and avoid sample
contamination.
2.
-r-
4,
b.
c.
d.
e.
White Mesa Mill - Standard Operating Procedures
Book I Section 15
Dalei 0210"1 Revision: DUSA I
Page2of 2
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
Communicate operating conditions in an accurate and timely manner.
Maintain and practice good housekeeping.
Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
5. All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building and bioassay laboratory.
6. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
7. All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required to
shower before leaving the mill. These operators will be paid vz hour of
overtime to shower.
f.
o
h.
White Mesa Mill - Standard Operating Procedures Date; A2fi7 Revision: DUSA I
Book I Section 15 Page 3 of 3
8. Prior to leaving the restricted area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house. If the alarm sounds, re-
survey. If the alarm sounds again, contact the Shift Foreman, Radiation Safety
Officer, or a radiation staff member.
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
11. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and maintained with the each piece of equipment. Any
equipment defects must be corrected before equipment is operated. The Mobile
Equipment Check List must be available for inspection at all times.
{ooIO
=E5-r9d-
-eF3EH!,J
f,'n'f
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2007
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Onerati
Page I of2l
1.0 PURPOSE
The alternate feed material received at the White Mesa Mill often will contain debris of
one sort or another. The debris ranges from large concrete chunks to limbs and branches,
and miscellaneous smaller forms of debris. The alternate feed material normally contains
uranium values on the surfaces of the large debris and/or is included in fine particles;
therefore, the alternate feed material generally does not require size reduction (e.g.
crushing or grinding) for liberation of values.
1.1 Trommel Operation
Processing of this type of material commences with sizing and washing of the material.
The sizing starts with the material being passed across a stationary grizzly having
approximately 6-inch spacing between the parallel bars. Large material and some of the
plastic liner is rejected from the smaller material. This oversize material may be passed
across the grizzly more than once to enhance separation by size. The oversize material is
periodically loaded onto a dump truck, which then proceeds to the debris-washing pad
(See Section 1.2).
Material passing the 6-inch stationary grizzly is conveyed to the trommel screen, which
has openings of approximately 3/8-inch. Water is applied to the material in the rotating
trommel screen to wash off the fines. The oversize material proceeds up the inclined
trommel and is discharged out the end, and stacked. This washed oversize material is
periodically loaded onto dump trucks to be hauled to a designated area for disposal. This
oversized material may be loaded onto the truck hauling the oversize material from the
grizzly,
Undersize material from the trommel is collected and pumped to feed the derrick screens
within the Mill building. The screen surfaces of the derrick screens can be changed for
screens with different sized openings. The usual screen size here, effects a size
separation at about 28-mesh.
The oversize material (plus 28-mesh) from the derrick screens is washed down a system
of troughs and piping to a collection area just outside the Mill building. The stacked
material is periodically loaded onto trucks to be hauled to the tailings area for disposal
(See Section 1.2).
The underflow from the derrick screen (minus 28-mesh) is collected and pumped to the
100-foot thickener (neutral thickener). Flocculant and, possibly coagulants, may be
added to assist the settling of solids within the thickener. The settled solids are
mechanically raked to the center to be discharged from the thickener. The underflow of
the neutral thickener is the feed to the leach circuit. The density of the leach feed is
controlled by the speed of the thickener underflow pump.
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,200'7
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris lrach & Trommel Ooerati
Page 2 of 2l
The solution overflowing the neutral thickener is pumped to a surge tank and is recycled
to be used for the washing of solids in the trommel and elsewhere. Fresh water is added
to make up for the water discharged with the solids at the thickener underflow and is
added to the trommel for solids washing and at various places (e.g. transfer points and
stationary grizzlies) for dust suppression.
Process control is provided both locally, within the circuit, and in the central control
room in the main Mill building.
1.2 Debris Leach Operation
At the debris-washing pad, the end gate of the truck is partially opened, the bed is raised,
and water is sprayed onto the debris. The elevated bed and the partially opened gate
retain the debris and allow the water and the fines to leave the truck bed. Other
equipment may be used for the washing of large debris, and may be altered to allow ease
of operation.
After draining, the truck may be directed to the collection points for the trommel oversize
and the Derrick screen oversize and this additional oversize can be loaded with the Iarge
washed debris. The load can then be taken to the designated area of tailings, in Cell 2 or
3, for disposal. Debris will be disposed of in a manner to minimize void spaces and
nesting and to enhance compaction. All drums or barrels will be crushed to minimize
void spaces. Random fill or tailings will be used to fill voids in and around the debris.
The fill and cover material will be compacted with at least one pass of the construction
equipment prior to advancement of any final reclamation cover layers.
The fine material washed from the coarse debris is collected into a sump and pumped to
join the trommel undersize and is pumped to the derrick screens for further sizing.
2.0 TROMMEL SCREEN PROCEDURES
2.1 Start-up Procedures
1. Perform a pre-operational inspection of the area and equipment to be operated.
Assure that all maintenance has been completed and those areas picked up and guards
reinstalled. Assure that all walkways are clear, hoses and tools picked up, and the
power to each unit is available (check MCC for lockout of starters).
2. Assure that sufficient flocculant and/or other reagents have been mixed and are
available for use.
3. Check that the downstream circuits are ready to have material sent to them and notify
your supervisor that you are ready to start-up.
No.: PBL-7
Rev. No.: R-l
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDIIRES I Page 3 of 2l
Date: Feb 25,2001 I Title: Debris Leach & Trommel Operation
4.Check the rake drive and lift on the neutral (100f0 thickener. The rakes can be
lowered until there is an increase in torque at which time the neutral thickener
underflow pump can be started and slurry delivered to the leach circuit. Before
stafting the pump, assure that gland water is on to the seal.
Start adding flocculant to the neutral thickener feed trough or center well.
Start the motors for the derrick screen(s).
Start the neutral thickener overflow pump to the water surge tank.
Start the water to the trommel screen and start the trommel screen drive motor.
Start the sump pump and the trommel undersize pump to feed the derrick screens.
Start the conveyor and belt feeder to feed the trommel screen.
Start the water sprays at the stationary grizzly and at the transfer points. During cold
weather periods, check with the shifters on the use of water sprays for dust
suppression.
5.
6.
7.
8.
9.
10.
11.
14.
15.
'r)
l.
2.
12. Start feeding the designated feed to the grizzly.
13. Remove materials from the collection points and load onto trucks for haulage to the
tailings area for disposal.
Adjust flows as needed.
Check that all equipment is functioning correctly.
Shut Down Procedures
Stop the feed to the grizzly and empty the hopper, conveyor and belt feeder.
Continue operating the trommel screen until the trommel screen is empty or near
empty, then stop the water to the trommel screen and shut down the trommel screen
drive motor.
Wash out the sump from the debris washing pad and flush the derrick screen feed
pump and lines, then shut down both pumps.
Shut down the water sprays at the stationary grizzly and transfer points.
Wash off the derrick screens and the oversize trough, then shut down the derrick
screen and the underflow pump feeding the neutral thickener
J.
4.
5.
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDTIRES
Title: Debris Leach & Trommel Ooeration
Page 4 of 2l
6. Stop the flocculant addition to the neutral thickener.
The feed to the neutral (100 f0 thickener is now off. The thickener rake drive and the
underflow pump should continue to operate until the underflow density is low and/or
instructions are given to shut the underflow pump down. Supervision will determine how
far the rakes should be lifted prior to shutting down the drive motor.
2.3 Emergencv Shut Down Procedures
1. Stop feedingthe grizzly.
2. Shut down the water supply to the trommel screen.
3. Shut down the sump pump and the derrick screen feed pump.
If time permits:
4. Shut down the derrick screen motors and the derrick screen underflow pump.
5. Raise the neutral thickener rakes to relieve the torque.
6. Shut down the conveyors and feeders.
7. Shut down the fresh water sprays.
8. Flush the line from the trommel screen underflow to the derrick screens.
2.4 General Inspection Procedures
The following are procedures that should be done on a regular basis throughout the shift.
1. Inspect reagent lines, feed lines and water lines for leaks and immediately notify
your supervisor if any leaks are noted.
lnspect motors on pumps to be sure they are not running hot and immediately
notify your supervisor if a motor is found to be running hot.
Assure that water sprays are functioning and wash water is sufficient in volume
and pressure.
Assure that the trommel is not over loaded.
Check that all equipment is rururing and there is no blockage at transfer points.
2.
-f.
4.
5.
3.0
3.1
No.: PBL-7 | DENISON MINES (USA) CORP.
Rev. No.: R-l I STANDARD OPERATING PROCEDURES I Page 5 of 2l
Dare: Feb 25,2007 | Title: Debris Leach & Trommel
CTIEMICALS AND REAGENTS
Introduction
Numerous inorganic and organic chemicals are used in the processing of uranium. These
include such items as:
. Inorganic Acids. Organic Acids. Petroleum Products. Fuels. Solvents. Ammonia. Inorganic Bases. Flocculants. Degreasing Agents. FiberglassingCompounds. Oxidizing and Reducing Agents. Other chemicals as required
Debris Leach and Trommel Screen Operation
Some of the major chemicals used in the debris leach and trommel process areas are
listed as examples:
. Sulfuric Acid - 93 to 95Eo strength. Monowet. Gear Grease Compound. Petroleum Lubricating Oil. Petroleum Lubricating Grease. Flocculants and Coagulants
3.3 Material Safety Data Sheets
All relevant safety, first aid handling procedures and physical chemical information, etc.,
is contained in the Material Safety Data Sheet (MSDS) provided in strategic locations
throughout the mill area. These can be found in the following locations; safety office,
Iaboratory, maintenance break room and central control room.
The MSDS supplies a description of the chemicals and reagents. The MSDS also
explains the hazards, spill procedures, safe use, and first aid procedures for each chemical
and reagent.
3.2
No.: PBL-7 I DENISON MINES (USA) CORP.Rev.No.:R-l I STANDARDOPERATINGPROCEDURES lpage6of2lDate: Feb 25,2007 | Title: Debris Leach & Trommel Operarion
Each operator must read and understand the MSDS of all chemicals and reagents used in
hisftrer department, along with the chemicals and reagents used in all operating
departments.
Each operator must know the location of all MSDS's for his/her operating circuit at all
times.
3.4 Information contained on Hazardous Material safety Data sheets
Hazardous Material
Shipping Name
DOT Hazard Class
Chemical Name
ID Number
STCC Number
The proper shipping name or other common name for the material;
also any synonyms for the material.
The hazard class designation for the material as found in the
Department of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous
material by the Department of Transportation; also includes the
prefix "IJN" or "NA."
The Standard Transportation Commodity Code number used in the
rail industry; a seven-digit number assigned to a specific material
or group of materials and used in the determination of rates; for a
hazardous material, the STCC number will begin with the digits
"49."
Phvsical Description
Normal Physical State Physical state or form of the material at normal ambient
temperatures (68"F - 77"F).
color The color of the material under normal conditions.
Odor The odor of the material upon its release.
Chemical Properties
Specific Gravity The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than l, the material
is lighter than water and will float; if the specific gravity is greater
than l, the material is heavier than water and will sink.
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Operation
PageT of21
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2007
Vapor Density
Boiling Point
Melting Point
Vapor Pressure
Solubility
Degree of Solubility
Other
LCso
Ingestion Hazard
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard Is there any hazard from breathing this material?
TLL/TWA
The weight of a pure vapor or gas compared with the weight of an
equal volume of dry air at the same temperature and pressure; if
the vapor density is less than 1, the material is lighter than air and
may rise; if the vapor density is greater than l, the material is
heavier than air and will stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e.,
the temperature where the pressure of the liquid equals
atmospheric pressure.
The temperature at which a solid changes to a liquid; this
temperature is also the freezing point depending on the direction of
the change.
The pressure exerted by the vapor within the container against the
sides of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of
the liquid evaporates or vaporizes. The lower the boiling point of a
liquid, the greater the vapor pressure it will exert at a given
temperature.
The ability of a solid liquid, gas, or vapor to dissolve in water; the
ability of one material to blend uniformly with another, such as a
solid in liquid, liquid in liquid, gas in liquid, or gas in gas.
Indication of the solubility of the material.
Any additional pertinent information or data found.
Threshold Limit Value/Time Weighted Average - concentration of
a material to which an average, healthy person may be repeatedly
exposed for eight hours per day, 40 hours per week, without
suffering adverse health effects.
The concentration in ppm that kills 507o of the laboratory animals
in a given length of time.
Is there any hazard from ingesting (eating) this material?
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2007
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Ooeration
Page 8 of2l
LDso
Absorption Hazard
Skin Absorption
Eye Absorption
IDHL Value
STEL Value
Chronic Hazard
Carcinogen
Mutagen
Teratogen
Hazardous to
Aquatic Life
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Lethal Dose - the dose that kills 50Vo of the test animals.
Is there anyhazard from absorbing this material into the body?
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value - an indication
of atmospheres that are immediately dangerous to life and health.
Within 30 minutes of exposure, death or irreversible health
implications to the person exposed are expected.
Short Term Exposure Limit Value maximum allowable
concentration or ceiling, not to be exceeded during a 15 minute
period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
A material that causes the production of a physical defect in a
developing embryo.
ls the material harmful to aquatic life?
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is
to prevent or reduce the physical transfer of any contaminants by
people or equipment from onsite to offsite locations. List methods
available for decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
No.: PBL-7 | DENISON MINES (USA) CORP.
Rev. No.: R-l J STANDARD OPERATING PROCEDURES I Page 9 of 2l
Date: Feb 25,2007 I tltte: Debris Leach & Trommel Operation
Flash Point The minimum temperature at which a liquid gives off
vapors to ignite and flash over, but will not continue
without the addition of more heat.
enough
to burn
Ignition
Flammable
Toxic Products
of Combustion
Other
Possible
Extinguishing
Agent
Reactivity
Reactivity
With what?
Other
Auto-ignition Temperature - the minimum temperature required to
ignite gas or vapor without a spark or flame being present.
Explosive Range - the range of a gas or vapor concentration
(percentage by volume in air) that will burn or explode if an
ignition source is present. Limiting concentrations are commonly
called the "LEL" (Lower Flammable Explosive Limit) and the
"uEL" (Upper Flammable Explosive Limit). Below the lower
flammable limit, the mixture is too lean to burn; above the upper
flammable limit, the mixture is too rich to bum.
The toxic by-products of the combustion process.
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
Corrosive Hazards
Corrosivity Hazards Is the material corrosive to other materials?
pH Acidic or basic corrosives are measured to one another by their
ability to dissociate in solution. Those that form the greatest
number of hydrogen ions are the strongest acids, while those that
form the hydroxide ion are the most potent bases. The
measurement of the hydrogen ion concentration in solution is
called the pH of the compound in the solution. Strong acids have
low pH values and strong bases have high pH values; the pH scale
ranges from 0 to 14.
No.: PBL-7 I DENISON MINES (USA) CORP.
Rev. No.: R-l I STANDARD OPERATING PROCEDURES I Page t0 of 2l
Date: Feb 25,2001 | Title: Debris Leach & Trommel Operarion
Corrosive to what? Materials with which the material is corrosive, particularly skin
and steel.
Other Any additional pertinent information or data found.
Neutralizing Agents Those materials that can be used to neutralize the effects of the
corrosive material.
Radioactivitv Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Recommended Protection
For the Public
For Response
Personnel
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles, beta
particles, or gamma radiation.
Any additional pertinent information or data found.
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone;
Level A - Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B - Requires the highest level of respiratory protection, but a
lower level of skin protection. It is the minimum level
recommended on initial entries until the hazards have been further
identified and defined by complete monitoring, sampling, and
evaluation.
Level C - Requires air purifying respirators with adequate
protection factors; coveralls and other protective equipment may
be required. This level is selected when types and concentrations
of respirable materials are knows to have adequate warning
properties.
No.: PBL-7
Rev. No.: R-l
Date:Feb 25,2001
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Onerati
Page I I of2l
For the
Environment
Level D - Requires no respiratory protection; basic work clothing
should be worn when sites are positively identified as having no
toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Hazardous Material Data Sheet can be used to collect additional
information of a more specific nature.
3.5 Spill/Disposal Procedures
Certain chemicals, when spilled or disposed of, have reporting requirements associated
with them. The following is an explanation of the actions required when dealing with
these chemicals. Without exception, your supervisor will make any required reports.
Refer to Emergency Response Plan for specific details regarding spill procedures.
Resqurce Conservation and Recovery Act (RCRA)
RCRA regulates the manner in which hazardous materials can be disposed. The specific
requirements will be specified by the Environmental Department. If you need to dispose
of any chemicals, contact your supervisor for instructions. The containers that held these
products may be disposed of in any trash receptacle if:
a.) the container has less than 57o left in the bottom, or
b.) the container has been triple rinsed into any mill sump.
Spill Reportinq
Reportable spills of certain chemicals must be immediately reported to governmental
agencies, depending on the quantity and type of chemical spilled. A reportable spill is
basically when the chemical hits the ground (earth), as opposed to a spill to a concrete
pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your supervisor. Your
supervisor will determine if a report to an agency is necessary. Your supervisor will
make the report, if needed. Do not attempt to make a report yourself. If there is any
doubt, contact your supervisor for advice and direction.
4.0 HAZARD RECOGNITION
1. Hazards
a. Moving Mobile Equipment - mobile equipment has the
aware of all personnel and equipment in your area.
1. Alternate feed IMC transfer trucks - speed limit of
2. Front end loaders
right of way.
15 mph.
Be
No.: PBL-7 I DENISON MINES (USA) CORP.
Rev. No.: R-l I STANDARD OPERATING PROCEDURES I Page t2 of 2t
Date: Feb 25,2W7 I Title: Debris Leach & Trommel Operation
3. Dump trucks
4. Pickup trucks
5. Water Wagon
6. Fork lifts
b. Cleaning Grizzly
c. Moving Conveyor
d. Rotating Trommel
e. High Pressure Air Lines
d. Guards
e. Pinch Points
1. Idlers and rollers
2. Head and tail pulley
f. All guards must be in place before running
g. Cleaning up around pumps
CAUTION - Wet Decks are Slick and Fall Hazard
2. Health Hazards
a. Radiation
1. Radon progeny
2. Airbome uranium
3. Beta gamma
b. Silica and Nuisance Dusts, Mists and Fumes
c. Hearing Protection
Items listed above can be hazards if not controlled properly. If controlled properly and to
operating standards, they are safe.
5.0 JOB PROCEDURES
All non-routine jobs will be initiated by your supervisor and will not be performed unless
directed by your supervisor. For any non-routine job a Radiation Work Permit and/or a
Safe Work Permit may be required.
6.0 SAFETY RULES
Safety rules will be followed without exception. Listed in this section are general safety
rules for Debris Leach and Trommel Screen operations. These rules do not cover all the
White Mesa Mill safety rules. Each operator is to know and understand all White Mesa
Mill safety rules that are described in the Safety Manual.
No.: PBL-7
Rev. No.:R-l
Date: Feb 25,2007
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Operation
Page 13 of 2l
2.
6.1
l.
6.2
1.
J.
4,
5.
6.
7.
8.
Debris Loading and Unloadins
Personnel shall stand well clear of trucks when the bed is inclined. Trucks can turn
over and there is always danger from falling rocks. When the dump trucks are
unloading, stand at least 50 feet away.
Loader and truck operators should be aware of personnel and equipment entering
their area, but people should be aware that the operator may not see them and,
therefore, should stay clear of the equipment.
Conveyor Belts
Conveyor belts are sometimes called "silent killers." Be aware and alert at all times
when working around them.
Never attempt to clean conveyor idlers, head, or tail pulleys while the belt is in
motion. Never attempt any work on a conveyor unless the motor is shut off and the
Iockout procedure has been followed.
Never ride on, cross over or under a moving conveyor. Use walkways and crossovers
that are provided.
Know the location of emergency stop cords and how to use them. Do not operate the
conveyor if the emergency stop cord is not working properly.
All guards must be kept in place, except when the conveyor is properly locked out.
Remember that a tool can be caught in a pulley or idler so quickly that you will not
have time to let go before it catches you. Be extremely cautious when working
around conveyors.
Always wear close fitting clothing that cannot become caught in moving parts.
When shoveling clean up material onto a moving conveyor, always face in the
direction of conveyor travel. Never shovel onto a conveyor that is moving toward
you.
General Safetv Rules
Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
2.
6.3
1.
2.
No.: PBL-7
Rev. No.:R-l
Date: Feb 25,2007
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDT]RES
Title: Debris Leach & Trommel Operation
Page 14 of 2l
3.
4.
5.
6.
Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and ho to defend against them.
If a valve refuses to open or close ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected
to determine its condition.
All personnel shall know the location of all main block valves for fuel, kerosene, gas,
steam, air, water, sulfuric acid and ammonia lines which pass through their area.
Even though the respective valve may not be in your area, you must know how to
shut off each line in case of an emergency.
Chemical or solvent splashes must be washed from skin and clothing to preventirritation. Know the effects of all materials you handle and wear protective
equipment to keep them from coming in contact with you.
7. A Safe Work Permit and a confined space entry permit must be obtained before
entering any bin or hopper. A Radiation Work Permit will be required if it is
determined that there is a potential for elevated radiation exposure.
6.4 Reportins Unsafe Conditions and Iniuries
1. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries to your supervisor immediately. Also, report all accidental
occurences or conditions that may have a potential for injuring someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
6.5 Personal Protective Equipment and Clothing
1. Hard hats, safety shoes and safety glasses with side shields must be worn at all times
in the plant area - except in control rooms, offices and change rooms.
2. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt contact your supervisor.
3. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc. to your supervisor.
No.: PBL-7 | DENISON MINES (USA) CORP.
Rev. No.: R-l J STANDARD OPERATING PROCEDURES I Page t5 of 2l
Date: Feb 25,2007 | Title: Debris Leach & Trommel Operation
4. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles.
b. Rubber coat, pants, gloves and boots.
c. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
5. The use of safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more.
7.0 MOBILE EOUIPMENT _ SAFETY RULES
7.1 General
1. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. This needs to be documented on the forms
provided. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
11.Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
No.: PBL-7
Rev. No.: R-l
DENISON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 16 of 2l
Date: Feb 25,2007 I Title: Debris Leach & Trommel Operation
12. Report all accidents to your supervisor regardless of how minor they are. [f property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required.
7.2 Dump Trucks
1. Do not move the truck until the air pressure is built up to normal.
2. Do not overload the truck.
3. Release the parking brake before moving the truck. Use a low enough gear to start
the truck without slipping the clutch.
4. Except to shake out the load, no truck shall be driven until the bed is in the full down
position.
5. Never work under a raised bed of a truck unless it is securely blocked.
6. Park the truck in its designated parking place with the brakes set and engine off.
7.3 Front End Loaders
1. No one but the operator is permitted to ride on the loader.
2. Never leave the loader without dropping the bucket to the ground.
3. Do not jump off loaders. Use hand rails and steps when getting on or off equipment.
4. When stepping from the loader to the ground, be sure there are no rocks that you
could step on and turn your ankle.
5. Do not strike the dump truck with the loader bucket or wheels.
6. Avoid spinning or slipping the drive wheels of the loader as much as possible.
7. Do not move loaders equipped with air brakes until the air pressure is built up to
normal.
No.: PBL-7
Rev. No.: R-l
Date: Feb 25.2W7
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Oneration
Page 17 ofZl
8.0
8. Park the loader out of the way or in the designated parking place with the brakes set
and engine off.
9. Always keep the bucket as low as possible when traveling.
10. When lubricating front end loaders, park the loader on flat ground, bucket down,
parking brake set, and the engine off.
RADIATION SAFETY PROCEDURBS
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have
received.
Listed below are the Radiation Safety Procedures for debris leaching and trommel
operation which, when followed, will maintain your exposures ALARA. Remember, you
are the person most responsible for controlling your radiation exposure. If the Radiation
Safety Procedures are followed and protective equipment is utilized correctly, your
exposure will be maintained ALARA.
8.1 ALARA Prosram Policy Statement
The policy of Denison Mines (USA) Corp. to maintain good radiation protection
practices is the expenditure of every reasonable effort to achieve and maintain low levels
of contamination and radiation in occupational exposures. By definition, the ALARA
program shall result in radiation exposures being maintained to levels as far below any
applicable limits of the NRC regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring and
an on-going review process between the radiation protection staff and plant operations
management with secondary audits performed by corporate environmental radiation
safety personnel.
Denison Mines (USA) Corp. is committed to maintaining occupational exposures of
persorurel at White Mesa to levels as low as reasonably achievable. This commitment is
supported by the training program conducted for facility personnel, and continuous
reviews of radiation, environmental, and industrial hygiene protection policies.
It is the policy that occupational exposure records of personnel at the White Mesa Mill
are readily available for review when requested. The radiation protection staff will
review and discuss any aspect of radiation safety at any time.
No.: PBL-7
Rev. No.: R-l
Date:Feb 25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDTIRES
Title: Debris Leach & Trommel Operation
Page l8 of2l
8.2 Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work is to
be performed in the mill area. The procedure ensures that radiation hazards, which
cannot be contained, will be controlled by the use of protective equipment. An initial
assessment of the work environment and associated work tasks as related to potential
radiation exposure will be made for those non-routine work activities which may require
the issuance of a Radiation Work Permit. If it is determined, by this initial assessment,
that there is a potential for elevated radiation exposure, a Radiation Work Permit will be
issued.
a. A Radiation Work Permit will be issued by the radiation staff.
b. Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
c. The permit must be signed in ink by all personnel involved in the work and posted
in the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
8.3 Postins of Specific Areas
As a part of ALARA practices and controlling your exposures, the following signs could
be posted in your work area. It is important that you understand what these signs mean.
CAUTION - AIRBORNE RADIOACTIVE AREA - This sign is posted in an area in
which airborne uranium or radon progeny concentrations are, or at above 257o of the
specified limits for airbome concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airbome concentrations are below 25Vo DAC. The following areas
have required that they be posted as an "airborne radioactivity area" requiring the use
of full-face respirators due to airborne or radon progeny concentrations above 25Vo
DAC:
CAUTION - RADIATION AREA - This sign is posted in an area where beta and
gamma radiation levels are at, or above 2 mrhr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
a. Our primary means of control for gamma or beta is limiting time spent in the
radiation area.
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2007
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Operation
Page 19 of 2l
8.4 Procedures to Follow Regarding the Use of Respirators
a. When issued a new respirator, the respirator shall be fit-tested with irritant smoke
and logged on the forms provided at the shifters office. After the initial fit-
testing, a positive-negative pressure test will be done each time the respirator is
donned to ensure a proper fit.
b. If you are using a respirator in a very dusty area, it may be necessary to change
the filter after two to three hours. When resistance to breathing becomes
uncomfortable, it is a sign that the filters have served their useful life and need to
be replaced.
c. At the White Mesa Mill facility, there is only one type of cartridge used for the
full face respirator. The combination cartridge is used for nuisance dust, chemical
mists and radiological dust.
8.5 Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the White Mesa Mill:
a. Practice good housekeeping to prevent build up of ore spills near the trommel
operation.
Follow good personal hygiene habits.
l. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. All Mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the Mill. All
coveralls and contaminated clothing will be laundered on the property.4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal conditions,
tell the person doing the surveys.
Always where your personal monitoring device when you are assigned one. Put it
in the designated area when leaving work.
Wear appropriate respiratory protection while the SAG mill is operating (full-face
respirator).
b.
c.
d.
No.: PBL-7
Rev. No.:R-l
Date:Feb 25,2001
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Operation
Page 20 of 2l
f. If you are concerned or have any questions about the amount of radiation you are
being exposed to, contact the Radiation Safety Officer.
8.6 Urinalysis Samplins
Urinalysis samples are utilized to determine the uranium content contained in the urine of
the operator. The frequency of sampling is dependent on the airborne concentrations and
'will be changed if airborne levels exceed 25Vo of the airbome standards.
To minimize the chance of contaminating a urine sample, the following practices should
be followed:
Urinalysis containers can be picked up at the administration building upon
returning from your scheduled days off. The sample containers should be filled
after washing your hands and prior to changing into your work clothes or
reporting to your work location. The samples can then be placed in the bioassay
laboratory.
Under unusual circumstances where specimens cannot be collected in this manner, the
worker should shower immediately prior to voiding. When a shower is not possible,
disposable plastic or rubber gloves should be worn during voiding. Take all necessary
precautions to ensure that your urine sample is not contaminated.
9.0 GENERALOPERATOR'SRESPONSIBILITIES
L It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
b. Operate circuits within specified parameters.
c. No alarms are to blocked out or otherwise made to be inoperable at any time.
d. Maintain a proper operating log sheet.
e. Collect and properly label all mill control samples and avoid sample
contamination.f. If a sample is contaminated, start a new sample and mark "contaminated sample"
on the item what was contaminated
g. Maintain and practice good housekeeping.
2. All operators will be provided with a change room, shower and laundry facilities so
that they may leave their work clothes at the Mill. All coveralls and contaminated
clothing will be laundered on the property.
3. All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
No.: PBL-7
Rev. No.: R-l
Date: Feb 25,2W7
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Debris Leach & Trommel Operation
Page2l of2l
4.Prior to leaving the Restricted Area, all operators will monitor themselves with an
alpha radiation survey meter located at the guard house and Mill administration
office. If the alarm sounds, re-survey. If the alarm sounds again contact the Shift
Foreman, Radiation Safety Officer, or a radiation staff member.
Operators of company vehicles must have a valid driver's license.
Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and tumed in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
5.
6.
7.
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DENISON MINES (USA) CORP.
BOOK #s
YELLOWCAKE PRECIPITATION
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White Mesa Mill - Standard Operating Procedures
Book 5 Section I
Date:02101 Revision: DUSA 2
Page I of I
INTRODUCTION
Mill Process
Operations at the White Mesa Mill begin with the weighing, receiving, sampling,
and stockpiling of the ore from the various mines. Mine run ore, as well as crushed ore
from the stockpile, will be fed at the rate of 2,000 tons-per-day to the semi-autogenous
grinding (SAG) mill. The ground ore will be stored as a wet pulp in three agitated tanks.
The processing stages will include two-stage acid leaching, followed by the recovery of
uranium and vanadium bearing pregnant solution in a counter-current decantation (CCD)
system.
The uranium is recovered from the leach pregnant solution utilizing a
conventional solvent extraction system. Vanadium will be recovered from the barren
uranium raffinate also utilizing a solvent extraction circuit.
The pregnant uranium strip solution is precipitated with Anhydrous Ammonia and
the resultant yellowcake is dewatered, dried, and packaged.
The pregnant vanadium strip solution is precipitated with Ammonia Sulfate,
filtered, dried, and melted to produce a concentrated vanadium black flake for packaging.
Process Controls
A process control panel is provided in the grinding area (CP-l), and uranium and
vanadium product recovery (CP-4 and 5), areas .All other process control panels are
located in the central control room.
Denison Mines (USA) Corp. has outlined, and will implement, an on-going
personnel radiation protection program to ensure that operations at the plant are
conducted in a safe and efficient mamer and in accordance with approved procedures.
This radiation protection program is documented and administered by the
State of Utah Division of Radiation Control under the direction of the Executive
Secretary. These applicable regulations are detailed in Code of Federal Regulations Title
l0 Energy and the State of Utah regulations at R313-15.
White Mesa Mill - Standard Operating Procedures
Book 5 Section I
Date:02107 Revision: DUSA 2
Page 2 of 2
manual for eachRadiation Protection Operating Procedures are included in this
Unit Operation.
.P<
='oGl!p'dr9.!"q,t, oo=xi,!r=:Glo
GI
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date:02107 Revision: DUSA I
Page I of 14
YBLLOWCAKE PRECIPITATION -
DRYING AND PACKAGING
Preface
Extreme care must be taken in the operation of the yellowcake precipitation,
drying, and packaging circuits to prevent spills and dust. Spills and dust can result in
over-exposure of operators and employees working in the Yellowcake area. All spills
must be cleaned up immediately. Scrubber systems must be in good operational
conditions and operating at required standards.
Good personal hygiene must be practiced at all times to prevent ingestion of
yellowcake. Keep all yellowcake washed off of your hands and clothing. Coveralls,
rubber boots, and gloves must be wom when working in the yellowcake area.
Full face respirators must be wom when in the yellowcake dryer enclosure,
Yellowcake packaging enclosure, and when placing lids and rings on filled yellowcake
drums to prevent over-exposure. No exceptions.
Full-face respirators may be required at designated times and in designated areas.
For your protection, they must be worn when required.
Following are descriptions and procedures that operators must leam and
understand. Notify your supervisor if you have any questions about operating procedures
or conditions.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date:02107 Revision: DUSA I
Page 2 of \4
Yellowcake Precipitation. Drving, and Packaginq Circuit
The purposes of the yellowcake precipitation and drying circuits are to precipitate
the uranium solution produced in the uranium SX, remove impurities from the
precipitate, dry the precipitate, and package the dried precipitate for shipping.
The yellowcake precipitation and drying circuits consist of two precipitation
tanks, two thickeners, one re-dissolve tank, two Bird centrifuges, two dryer with scrubber
systems, and all associated pumps and piping.
The feed solution for the yellowcake precipitation circuit is pumped from the
loaded strip tank in the uranium SX building to the number one yellowcake precipitation
tank. Ammonia is added and mixed with the loaded strip solution. As ammonia is
added, the pH is raised from 1.2 to the 7 .4 range causing the strip solution to precipitate.
The precipitate or yellowcake overflows through an outlet pipe in the number one
yellowcake precipitation tank to the centerwell of the number one yellowcake thickener.
Six to l0 gallons per minute of water is continuously added to the precipitate as it flows
into the thickener centerwell to wash sodium out of the yellowcake.
ln the number one yellowcake thickener, the heavy precipitated yellowcake settles
to the bottom of the thickener. The clear solution that separates from the yellowcake as it
settles overflows a launder and is pumped to either the strip makeup tank at SX, or the
overflow launder in the number one CCD thickener. The bottom of the thickener is cone-
shaped with an outlet at the bottom center of the cone. Rakes in the cone of the thickener
tum and push the yellowcake to the cone outlet where it is pumped out by a Moyno pump
to the re-dissolve tank. The Moyno pump is of variable speed and is set at a speed to
maintain a density of 1,700 spg, or above, in the bottom of the yellowcake thickener. The
density is obtained by letting the yellowcake build up in the thickener.
The purpose of the re-dissolve tank is to dissolve the yellowcake back into a
solution and remove contaminates (primarily sodium) from the dissolved yellowcake.
Sulfuric acid is added to the re-dissolve tank to drop the pH of the yellowcake to a 1.0
causing the yellowcake to go into the solution. Steam is added to bring the temperature
of the solution to 60"C which helps in separating the contaminates from the yellowcake.
Wash water is also added to wash out contaminates. As the yellowcake, acid, steam, and
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date: O2/0'l Revision: DUSA I
Page 3 of 14
water are added to the re-dissolve tank, the solution in the tank overflows into an
overflow pipe to the number two yellowcake precipitation tank.
Ammonia is added and mixed with the solution from the re-dissolve tank raising
the pH back up to a 7.8 to 8.2 pH. As the pH raises, the yellowcake in the solution will
precipitate as it did in the number one yellowcake precipitation tank. A saturated solution
of ammonium sulfate is added to the number two precipitation tank to remove impurities.
The precipitate, or yellowcake, overflows the number two yellowcake precipitation tank
through an overflow pipe to the centerwell of the number two yellowcake thickener.
Water is added to the yellowcake as it flows into the centerwell of the number two
yellowcake thickener.
The number two yellowcake thickener is identical to the number one yellowcake
thickener and operates the same. The heavy precipitated yellowcake settles to the bottom
of the thickener. The clear solution that separates from the yellowcake as it settles
overflows a launder and is pumped to the number one CCD thickener overflow launder.
The bottom of the yellowcake thickener is cone-shaped with an outlet at the bottom
center of the cone. Rakes in the cone of the thickener turn and push the yellowcake to the
cone outlet where it is pumped by a Moyno pump to the Bird centrifuges. Density is also
maintained in the number two yellowcake thickener. The Moyno pump is a variable
speed pump and the density is controlled by the speed of the pump.
The purpose of the Bird centrifuge is to wash the yellowcake to remove sodium
and then de-water the yellowcake so that it can be dried in the yellowcake dryer. The
Bird Soid Bowl centrifuge is a settling vessel with overflow weir and drainage deck
containing a conveyor which continuously picks up settled solids and discharges them
from the vessel by way of the draining deck. The settling vessel is made to rotate. Thus,
the settling forces acting on the solids particles can be many times gravity and ensure a
thorough separation of solids from the suspending liquid. The solids from the drainage
deck drop into an auger that feeds to the yellowcake dryer. The liquid overflows the
overflow weir and then flows to the number two yellowcake thickener centerwell.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date:02/01 Revision: DUSA I
Page 4 of 14
Yellowcake Drver Description
Two Yellowcake dryers are used. The dryers are designated as the North and
South dryers. The North dryer is 6'0" I.D. and the South dryer is 8'0" I.D. Both dryers
are Skinner dryers and the descriptions are the same, except for the size. The yellowcake
dryers are six hearth, refractory lined, multiple hearth unit with bumers on hearths two,
four, and six with a rotating central shaft with attached rabble arms and angled rabble
teeth used to move the yellowcake material down through the dryer. The arms and shaft
are cooled by air forced into the bottom of the shaft by the cooling air fan. After passing
through the arms and shaft, the cooling air will have been heated to a temperature of 300"
to 450'F and is vented out through the cooling air stack to the atmosphere.
There are two doors per hearth located 180" apart and directly in line with each
other.
The yellowcake is delivered to the dryer top hearth. The yellowcake material is
moved through the dryer by means of rabble arms with attached rabble teeth which are
angled so that, as the shaft rotates, the teeth distribute the cake over each hearth, in or out
as the case may be and down until it reaches the bottom hearth where the teeth plow the
dried cake into one product outlet. From here, the dried cake drops through a chute to the
lump breaker and then to the yellowcake packaging bin.
Air is drawn through the dryer by suction created by the exhaust gas system. The
actual amount of gas flow is determined by the fumace pressure. The fumace pressure is
automatically controlled by means of a pressure transmitter and controller. The dryer
pressure (or draft) is measured at the top hearth of the dryer. The dryer pressure (or draft)
controller operates a control damper located in the ductwork at the outlet of the gas
scrubber to control the pressure.
An increase in dryer pressure will result in an opening of the damper which will
increase the flow of gasses from the dryer and a decrease in pressure will, conversely,
decrease the damper opening and reduce the gas flow.
An increase in the feed rate or moisture content of the feed will increase the rate
of gas generation and, thereby increase dryer pressure. The control system will respond
by increasing the flow to the scrubber system. Thus, the dryer pressure controller acts to
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date:02101 Revision: DUSA I
Page 5 of 14
compensate for changes in the feed rate or moisture in the feed. The dryer works best
when the furnace draft (negative pressure) is between -0.1 and -0.2 inches water column,
but this is dependent on many variables.
The bumer system is designed to burn propane with gas pilots. There are a total
of six burners, two each on hearths two, four, and six. Both burners on each hearth are
controlled from a single set point controller and operate in unison. The installed capacity
of the six burners is approximately 1.6 million BTU/trour. The six bumers are equipped
with automatic, electrically ignited, intemrpted gas pilots. The bumer flame is monitored
by ultra violet flame scanners. Each burner can be started or stopped individually from
the panel mounted starUstop stations.
The gas systems incorporates the necessary safety valves, regulators, and pressure
switches. The flame safety equipment is housed in the main control panel which also
contains the necessary interlocks and controls for the rest of the system.
Ideal dryer temperatures are 1,000"F to 1,200"F in the number two hearth, 1,200"F
to 1,400"F in the number four hearth, and 1,400"F to 1,600"F in the number six hearth.
Hearth temperatures will vary due to moisture content of the centrifuged yellowcake and
the feed rate to the dryer. Hearth temperatures will normally be over 800"F for a low
hearth temperature and not over 1,600"F for a high hearth temperature.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date: O2l0l Revision: DUSA I
Page 6 of 14
Lump Breaker
Both North and South dryers use a lump breaking machine to break any lumps in
the yellowcake.
Yellowcake Storage and Package Bin
The packaging bin will hold approximately 17,000 pounds (or 20 drums) of dried
yellowcake. The package bin is equipped with a high level indicating probe and
indicating high level alarm and light on the yellowcake dryer control panel. The bin is
completely sealed with a Star Feeder at the bottom. The Star Feeder is designated to keep
the dried yellowcake from sifting through the bottom opening in the bin. Barrels are
filled from the bottom of the bin. A barrel is placed on a platform scale directly under the
Star Feeder. An adjustable barrel hood between the Star Feeder and the barrel form a
dust-tight seal.
The yellowcake packaging room is a negative pressure packaging room. Negative
pressure is controlled by the dust and gas handling scrubber system.
The drying of the yellowcake material in the dryer gives rise to water vapor and
gaseous products of combustion from fuel used, which are discharged through a gas
outlet on top of the dryer and into the exhaust gas handling system.
Exhaust Gas Scrubber System
Both North and South dryers have separate Exhaust Gas Scrubbers. The
Scrubbers are not identical in configuration, but both operate in the same manner
As the yellowcake dries, dust is formed in the dryer which follows the air and off-
gas flow out of the top of the dryer. The purpose of the scrubber system is to remove any
dust carried in the dryer exhaust stream before the gases are released to the atmosphere.
The off-gas scrubber is a large stainless steel cylinder with three intemal
compartments. Flow generated by the scrubber fan draws the exhaust gases from the
dryer. The dusty gas stream enters the scrubber near the bottom and at one side of the
circular scrubber to create a swirling pattern of the gas; a water spray dispenses a fine
spray to blend into a swirling mass. This is called the "humidification section" and serves
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date;02/01 Revision: DUSA I
PageT of 14
to wet the dust particles. The gas stream then passes upward through a stationary air vane
to amplify the swirling (or mixing) action, then into the fan inlet. The fan is a set-type fan
and a larger volume water spray introduces water particles into the turbulent atmosphere
of the fan where they wet all the dust particles, or scrub them from the gas screen. The
fan discharges the wet gas stream into the second compartment, or demister section of the
scrubber where an additional, low volume, fine water spray is again introduced into the
turbulent air stream. The second section, since it is on the discharge of the fan, is under
positive pressure while the first section on the fan intake is, of course, under suction or
negative pressure.
The second section (demister section) is equipped with a conical bottom and, at
the bottom of the cone, is located an orifice plate to discharge the dirty water (from
collecting the dust) into the modification section. The bottom of the first section (or
modification section) is also conical and is connected to a discharge pipe submerged in
the yellowcake scrubber tank to form an air seal (or barometric leg). The scrubber gases
are passed through a demister pad to remove entrained moisture before discharging
through the stack to the atmosphere. The demister pad is a six inch thick pad made of a
stainless steel material. The pad may become partially plugged and restrict air flow and
must be cleaned from the access door above the pad if this should occur. The entire
scrubber system and dryer will need to be shutdown during scrubber cleaning.
To achieve efficient scrubbing of the gases, certain conditions must be maintained
in the scrubber system, as well as meeting the normal operating conditions of the dryer
system.
Since the dryer needs to be maintained under negative pressure to prevent the exit
of dust and gas into the enclosure, a gauge is provided at the number six hearth (the point
furthest from the scrubber). This gauge is provided with an alarm that will sound, should
negative pressure drop below 0.04 inches water column. A gauge is provided that
measures differential pressure across the off-gas scrubber in inches of water column.
This gauge will sound an alarm and shut down the yellowcake dryer if the differential
pressure drops to 2.0 inches of water column. Normal differential pressure readings on
the off-gas scrubber are at three to four inches water column.
White Mesa Mill - Standard Operating Procedures Date:02107 Revision: DUSA I
Book 5 Section 3 Page 8 of 14
Additionally, water flow measurements to the sprays are measured by a flow
meter at each spray and should be controlled at the following:
l Modification Section
2. Scrubber Fan
3. Demister Spray
2-3 gpm
7 -9 gpm
3-4gpm
2.0 gpm
7.0 gpm
3.0 gpm
Typically, 16 to 17 gpm of water are utilized through the off-gas scrubber spray
system.
If the flow rate drops below 14 gpm water, a low water alarm will sound on the
control panel. The inner lock on the off-gas scrubber will shut the dryer down if water
flow to the scrubber drops to 12 gpm.
The following operating parameters are the limits, if reached, that require the off-
gas scrubber system be taken down and cleaned or inspected:
1. Negative pressure on the dryer below 0.04 inches water column.
2. Differential pressure on the yellowcake dryer off-gas scrubber manometer
readings at 2.5 inches water column.
3. If water flow drops below 14 gpm total, or if the flow rate to any spray drops
below the following settings:
a. Humidification Section
b. Scrubber Fan
c. Demister Spray
After the gas stream leaves the off-gas scrubber, it is ducted into the packed tower
demister scrubber. The purpose of the packed tower demister is to remove soluble gases
contained in the exhaust stream from the off-gas scrubber.
The exhaust from the off-gas scrubber enters the packed tower demister at the
inlet near the bottom. There is no scrubber fan with the packed tower demister so the
exhaust gas stream moves by force through the packing section. The packing section of
the tower is packed with seven feet of polypropylene saddles which are sprayed with
water at 35 gpm. The exhaust gas stream hits the wetted surface of the packing and
transfers the contaminates in the gas stream into the water. The bottom of the packing
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
1. Packed Section of the Tower
2. Demister Section
Date:02107 Revision: DUSA I
Page 9 of 14
tower is connected to a discharge pipe submerged in the scrubber tank which serves as an
air seal (or barometric leg) for the packing tower. The upper section of the packed tower
demister is the demister portion of the scrubber. Contained in the demister section of the
tower is a demister pad to remove any fine particulates of dust which may have passed
through the off-gas scrubber (or the packed section) of the tower and any entrained water
in the gas stream. The demister section of the tower utilizes a five gpm water flow rate of
clean water for flushing purposes. The gas stream then exits the packed tower demister
into the yellowcake stacks which is released into the atmosphere.
Since the off-gas scrubber and packed tower demister are in a series, if the packed
tower becomes partially plugged and restricts air flow, this will affect the negative
pressure reading on the dryer which will then sound the panel alarm, or increase the
differential pressure reading on the off-gas scrubber.
The upper differential pressure reading on the manometer at the off-gas scrubber
is set at six inches of water column. If the differential pressure reach six, an alarm will
sound on the panel and the packed tower will need to be cleaned.
Normal water flow to the sprays are measured by a flow meter and should be
controlled at the following:
30 - 40 gpm
4-6gpm
The yellowcake packaging and enclosure scrubbers' main function is to remove
any dust from the yellowcake packaging process and maintain a slight negative pressure
on the yellowcake dryer and packaging enclosures.
Flow generated by the scrubber fan draws the exhaust dust from the barreling
station and room atmosphere at the yellowcake enclosures. The dusty stream enters the
scrubber near the bottom in the spray section which serves to take out the large particles
from the incoming stream to cool and humidify, and wash the bottom of the impingement
plate stage to minimize build up. The impingement plate stages form droplets as the air
stream passes through, which creates an interaction between the gas stream and liquid.
The gas stream then passes through the impingement plates to a stationary, fixed blade
moisture eliminator which removes the water droplets in the gas stream. The scrubber
White Mesa Mill - Standard Operating Procedures Date:02101 Revision: DUSA I
Book 5 Section 3 Page l0 of 14
outlet of the scrubber is exhausted into the yellowcake stack and released to the
atmosphere. Differential pressure is measured across the yellowcake packaging and
enclosure scrubber with the following parameters utilized. The normal operating range is
between four and six inches of water column. When the manometer reading drops below
3.0 inches water column, the yellowcake scrubber system is shut down to be cleaned.
Normal water flow to the sprays is measured by a flow meter at each spray and
should be controlled at the following:
L Spray Section
2. Impingement Plates
Total Water Flow =
If water flow levels drop below 25
packaging scrubber will sound on the control
9-11gpm
14 - 16 gpm
25 gpm
gpm, a low water alarm to the yellowcake
panel and the scrubber should be cleaned.
White Mesa Mill - Standard Operating Procedures Date:02107 Revision: DUSA I
Book5 Section3 Pagellofl4
Yellowcake Packaging - Operating Procedures
1. Operator will wear coveralls and rubber boots.
2. Operator will wear rubber gloves when operating the circuit.
3. Operator will wear a full face respirator when in the yellowcake dryer enclosure or the
barreling enclosure.
4. lnspect and calibrate drum scales at the beginning of each shift before weighing
drums.
5. lnspect the packaging scrubber system for proper operating conditions.
6. Each drum is to be stenciled on one side and the lid with the following information:
a. Company name
b. Lot number
c. Drum number
d. Gross weight
e. Tare weight
f. Net weight
g. The term "Radioactive LSA"
7. Drums are to be inspected before each use for safe conditions.
a. No dents
b. No holes
c. Nobungs
d. Proper lids
8. Drum lids will be fitted with a new gasket.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Date:02107 Revision: DUSA I
Page 12 of 14
9. Drums will be tared before filling and the tare weight marked on the drum lid, on the
side, and on the Product Log Sheet.
10. Placed the tared drum on the roll conveyor at the west end of the packaging room and
move it through the self-closing doors into the packaging room.
11. Remove the lid from the tared drum.
a. Put the lid beside the drum on the scales so that the lid will be weighed with
the drum to get the gross weight of the lid and drum.
12. Position the tared drum directly below the yellowcake storage bin and in the center of
the drum scale.
13. Lower the drum hood down on the drum.
14. Fill the drum by activating the star feeder rotary valve.
15. Fill the drum to 950 to 1,000 pounds gross weight.
a. Do not exceed 1,000 pounds gross weight.
b. Do not overfill the drum and cause spillage.
16. Take a sample of the yellowcake from the top of the drum after it has been filled.
17. Split the sample of yellowcake into a one quart jar lbr the lot sample and a one pint
jar for the 10 drum composite sample. Jars are to be labeled as follows:
a. YC Sample
b. Date
c. Lot Number
d. Drum Numbers
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
18. A 10 drum composite sample is to be made from the lot.
a. The pint jar will contain yellowcake samples taken from each of 10 drums that
were filled.
b. Example of 10 drum composites as follows:
1. Drums I through 10
2. Drums 1l through 20
3. Drums 21 through 30
4. Drums 31 through 43
c. Number of drums in a lot may vary due to weight of yellowcake.
19. In addition to the above, a drum lot sample is to be made.
a. The quart jar will contain yellowcake samples taken from each of the drums of
yellowcake filled in a lot.
20. Place the lids on the filled yellowcake drums, activate the roll conveyor, and move the
filled drums through the self-closing doors at the east side of the packaging room.
21. Outside the packaging room, secure the lids on the filled yellowcake drums by
tightening the lid ring bolts.
22. After the lids have been tightened to the drums, place a wire seal on the drum lid ring
bolts.
23. Mark the gross weight, tare weights, drum number, lot number, and date on 1 side and
top of each drum.
24. Record the gross weight, net weight, lot number, drum number, and date on the
Product Log Sheet.
25. Yellowcake will be packaged in drum lots. Lot size will be determined by weight of
yellowcake being packaged.
Date:02/07 Revision: DUSA I
Page I3 of 14
White Mesa Mill - Standard Operating Procedures
Book 5 Section 3
Datet 02107 Revision: DUSA I
Page 14 of 14
a- A lot will consist of a designated number of drums as set by mill management.
b. After the designated number of drums in a lot have been filled, proceed to the
next lot number.
c. Each time a lot number is changed, start with drum number one and fill to the
designated drum number.
26. Wash down the packaging area once per shift, or as needed, to keep the area clean.
Safetv
1. Extreme care must be taken during the packaging operation to prevent spills and dust.
Any spills that might occur must be washed up immediately. Do not use air hoses to
clean.
2. Coveralls, rubber boots, and rubber gloves are required when packaging yellowcake.
3. Full-face respirators are required when entering the packaging enclosure and when
securing the lids on the yellowcake drums.
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White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Yellowcake Precipitation Start Up Procedures
1. Start the number one precipitation tank agitator.
Date:02107 Revision: DUSA I
Page I of7
2. Start the number one yellowcake thickener rake drive and lower the thickener rakes.
3. Set the number one precipitation tank pH controller for a pH of 7.0 to7.2.
4. Open the manual ammonia valve to the number one precipitation tank.
5. Turn on the instrument air to the number one precipitation tank automatic ammonia
control valve.
6. Turn on the mill air to the number one precipitation tank ammonia spargue.
7. Start
tank.
a.
10. Set the
a.
b.
C.
the uranium precipitation feed from the uranium solvent extraction loaded strip
Set the loaded strip flow to maintain a balance with the uranium solvent
extraction strip circuit.
8. Start the required wash water to the number one yellowcake thickener centerwell.
9. Maintain a pH of 7.0 to 7 .2 in the number one precipitation tank.
re-dissolve tank pH controller to maintain a pH of 1.0 to 1.2.
Start the re-dissolve tank agitator and air agitator.
Open the manual sulfuric acid valve.
Open the manual steam valve to the re-dissolve tank; maintain a temperature
of 55t - 80"C.
d. Start the wash water; maintain a ratio of 2:l wash water to the yellowcake
flow.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Date:02107 Revision: DUSA I
Page 2 of 1
ll.When the underflow density from the number one yellowcake is 1,700+, start the
Moyno underflow pump and pump yellowcake to the re-dissolve tank. Adjust the
underflow to the re-dissolve tank to maintain a 1,700 density in the number one
yellowcake thickener.
12. Start the number two yellowcake precipitation tank agitator.
13. Start the number two yellowcake thickener rake drive; lower the thickener rakes.
14. Start the required wash water to the number two yellowcake thickener centerwell.
15. Set the number two precipitation tank pH controller for a pH of 7.8 to 8.0.
16. Open the manual ammonia valve to the number two precipitation tank.
17. Turn on the instrument air to the number two precipitation tank automatic ammonia
control valve.
18. Turn on the mill air to the number two precipitation tank ammonia sparge.
19. Start the ammonia sulfate pump; set the ammonia sulfate flow to the number two
precipitation tank at 1.5 gpm.
20. Start the yellowcake dryer (see the yellowcake dryer start up procedures).
21. Start the Bird centrifuge and the yellowcake dryer feed auger (see the centrifuge start
up procedures).
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Date'.4107 Revision: DUSA I
Page 3 of 7
22. When the underflow density from the number two yellowcake thickener is at 1,700+,
start the Moyno underflow pump and pump yellowcake to the centrifuge, and adjust
the underflow to the centrifuge to maintain a 1,7@ density in the number two
yellowcake thickener.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Date:02107 Revision: DUSA I
Page 4 of 1
Yellowcake Dryer Start Up Procedures
l. Push the panel power switch to the "on" position on the panel face. Alarms will light
and the alarm horn will sound. The horn can be silenced by pressing the "silence"
button, but the lights will remain on until alarm conditions are cleared (i.e., equipment
start up).
a. Panel power will normally be on unless mill power failure has been
experienced. The alarm will have been silenced, but alarm lights will remain
on until the equipment is re-started.
2. Check and close all hearth doors, including the peep hole doors.
3. Start the dryer scrubber water flow and adjust the flow indicator to the scrubber as
required (normally 14 to 16 gpm). Proper water flow to the scrubber will clear the
alarm light for the "dryer-scrubber water-low flow."
Pursing
1. Close the draft control damper by setting the furnace draft controller at a +0.1 setting.
2. Start the induced draft (I.D.) fan. This will start as long as the scrubber water flow is
proper, the I.D. fan inlet temperature is not high, zmd the draft control damper is
closed. This will cause a differential pressure switch across the scrubber to cause the
alarm light for the "I.D. fan - low flow" to go out.
3. After the I.D. fan has reached full speed, set the fumace draft controller to a -0.2
setting.
4. Start the combustion air blower. This will cause the "Combustion air blower - low
pressure" alarm light to go out.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Date:02101 Revision: DUSA I
Page 5 of7
5.Open the temperature control valves by setting the three temperature controllers to a
temperature setting hieher than that indicated on the controller. This will cause the
valves to drive to the high fire position which is necessary to supply maximum purge
air.
Start the lump breaker. This will cause the "Lump breaker failure" alarm light to go
out.
Start the shaft drive. This will cause the "Shaft drive - low speed" alarm light to go
out after the shaft rotation sensor has been passed by the rotating plate attached to the
shaft.
Start the cooling air fan. The "Cooling air fan - low pressure" light will then go out.
This fan should never be stopped when dryer temperatures at any hearth exceed
500"F. (Damage to arms might occur by over-heating.)
Caution: The cooling air fan control is installed utilizing a latching relay. This
means that during a power failure, the fan will naturally turn off, but when power is
restored, the fan will automatically start unless the stop button has been pushed.
9. The low pressure switch will close and the "Fuel oil supply - low pressure" alarm
light will go out.
Note: As the equipment is started, the appropriate alarm lights will go out.
Equipment will not start if the appropriate interlock sequence is not made.
10. If all of the equipment is functioning properly and the temperatures on hearths two,
four, and six are not high (above the present alarm temperatures), the purge timer will
energize and the purge period will be initiated, and the amber purging light will come
on.
6.
7.
8.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Datei02107 Revision: DUSA I
Page 6 of 7
I 1. After the required purge time (this is set at the panel-mounted, key-operated purge
timer) has elapsed, the green "Purge complete" light will come on. The burners can
now be started.
12. Open the manual reset safety shut-off valve for the main fuel. The red fuel safety
valve "open" light will come on when the valve is manually opened.
13. Close the temperature control valves by setting the three temperature indicating
controllers to a temperature setting lower than that indicated on the controller. (This
will cause the valves to drive to the low fire position which is necessary before the
bumers can be started.)
14. Light the selected burner(s) by pushing in and holding the start button(s) of those to
be turned on. The pilot must light and be proven by the ultra violet flame scanner and
then the main fuel valve for the burner to automatically open to establish "main"
flame. When the desired bumers have started, the red burner "on" indicator light will
come on and the alarm light for that bumer will go out.
a. The burners will operate normally until they are shut off manually by
depressing the stop button, or until a power failure, limit action (including fan
failure), or flame failure at any burner.
b. ln the event of a power failure, all lights will go out and all fuel is cut off.
With restoration of power and after the equipment has been started up again as
outlined under the purging section, the "purging" light comes on and the
system automatically repurges. At the end of the purge period, the "purge
complete" light comes on and the system is ready for another start.
c. Set the three temperature indicating controllers to the desired hearth
temperature and the bumers will automatically modulate and vary the firing
rate, as required, to maintain the set-point temperature.
d. When any one of the six burners go off, the burner can be restarted by setting
the temperature indicating controller controlling the temperature on the hearth
White Mesa Mill - Standard Operating Procedures
Book 5 Section 4
Datet 021A7 Revision: DUSA I
PageT of7
of the burner to be started must be set at a temperature lower than indicated on
the controller. This is required to drive the temperature controller valve to the
low fire position. Start the burner that is off and then set the temperature
indicating controller to the desired temperature.
15. After operating temperatures have been reached, feeding of the yellowcake material
may start. (Minimum operating temperature on each fired hearth is 800"F.)
!c)doI3s'CLFOtrC,g:
White Mesa Mill - Standard Operating Procedures
Book 5 Section 5
Date:02107 Revision: DUSA I
Page I of I
Yellowcake Precipitation Shut Down Procedures
1. Shut off the loaded strip feed pump to the number one yellowcake precipitation tank.
a. Start/stop switches and pumps are located in the uranium SX building at the
south side of the loaded strip tank.
2. Wash out the loaded strip feed line with water.
3. Shut off the ammonia and air valves to the number one precipitation tank.
4. Shut off the wash water to the number one yellowcake thickener centerwell.
5. Shut off the number one yellowcake thickener underflow valve.
6. Wash out the number one yellowcake thickener underflow pump and line to the re-
dissolve tank with water.
7 . Shut off the number one yellowcake thickener underflow pump.
8. Shut off the acid, steam, and water valves to the re-dissolve tank.
9. Shut off the ammonium sulfate to the number two precipitation tank.
10. Shut off the ammonia and air valves to the number two precipitation tank.
11. Shut off the wash water to the number two yellowcake thickener centerwell,
12. Shut off the number two yellowcake thickener underflow valve.
13. Wash out the number two yellowcake thickener underflow pump and line to the Bird
centrifuge.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 5
Datet 02107 Revision: DUSA I
Page 2 of 2
14. Shut off the number two yellowcake thickener underflow pump.
15. Wash out the Bird centrifuge with water.
a. Add approximately 10 gallons per minute of water.
b. Qg[!q: If too much water is added when washing out the Bird centrifuge,
water will flood into the yellowcake dryer feed auger and put water into the
yellowcake dryer which could damage the dryer.
16. After the Bird centrifuge has washed out, shut off the wash water to the centrifuge.
17. Shut off the bowl wash water on the centrifuge
18. Shut off the Bird centrifuge.
19. Shut off the Bird centrifuge discharge auger that feeds the yellowcake dryer.
20. Shut down the yellowcake dryer as per the shut down procedures as outlined above.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 5
Date:02107 Revision: DUSA I
Page 3 of 3
Yellowcake Dryer Shut Down Procedures
1. Ensure that the product feed system has been shut down. (No additional yellowcake
can enter the dryer.)
2. Allow the equipment to operate under normal conditions until all of the yellowcake in
the dryer that can be rabbled out has been discharged into the packaging bin.
3. Lower the temperatures at a rate of 50"F per hour. This is accomplished by adjusting
the temperature indicating controllers on the control panel. Continue to decrease the
hearth temperatures at 50"F per hour until no hearth temperature is above 500"F.
4. Turn the temperature indicating controllers to a set point of 0"F.
5. Shut offall burners.
6. Propane gas maxie valve will close automatically.
7 . Shut off the combustion air blower.
8. Shut off the induce draft fan.
9. Shut off the scrubber water supply.
10. Shut off the shaft drive.
11. Shut off the lump breaker.
12. Allow the dryer heat to dissipate at its own rate.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 5
Date'.02107 Revision: DUSA I
Page 4 of 4
13. When all of the dryer hearth temperatures are 500"F maximum, the cooling air fan
may be tumed off.
Note: As equipment is shut down, the alarms will sound. Push the alarm "silence"
button.
14. Ensure the dryer is closed up (all doors, etc.) and let the heat dissipate at its own rate.
15. Note: Do not open dryer doors as this may result in thermal shock to the refractory.
aofrn;i soEr{q
White Mesa Mill - Standard Operating Procedures
Book 5 Section 6
Date:02101 Revision: DUSA 0
Page I of I
Yellowcake Precipitation and Drying Emergency Shut Down Procedures
1. Shut off the loaded strip feed pump.
2. Shut off the ammonia and air valves to the number one and two precipitation tanks.
3. Shut offthe ammonium sulfate to the number two precipitation tank.
4. Shut off the acid to the re-dissolve tank.
5. Shut off the steam to the re-dissolve tank.
6. Shut off the water to the re-dissolve tank.
7 . Shut off the water to the number one and two yellowcake thickener centerwells.
8. Shut off the underflow pumps under numbers one and two yellowcake thickeners.
9. Shut off the Bird centrifuge.
10. Shut off the wash water to the Bird centrifuge.
I l. Shut off the bumers on the yellowcake dryer.
12. Shut off the diesel fuel pump to the yellowcake dryer.
13. Shut off the scrubber fan on the yellowcake dryer.
14. Shut off the wash water to the yellowcake dryer scrubber.
Power Outages
1. Shut off the ammonia to the numbers one and two precipitation tanks.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 6
2. Shut off the acid to the re-dissolve tank.
3. Shut off the steam to the re-dissolve tank.
Datei 021A7 Revision: DUSA 0
Page 2 of 2
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White Ivlesa Mill - Standard Operating Procedures
Book 5 Section 7
Date:02107 Revision: DUSA I
Page I of I
Yellowcake Precipitation and Drvine - Shift Inspections
1. lnspect acid and ammonia lines every four hours for seeps and leaks.
a. Immediately notify your supervisor if any are noted.
2. lnspect for any yellowcake spillage.
a. Clean up all spills immediately.
3. lnspect guards on all moving equipment once per shift for condition and if in place.
a. If guards are not in place, shut off the equipment, lock out, and install the
guard.
b. Notify your supervisor if the guards are not in good condition.
4. lnspect all moving equipment for proper operating condition.
a. Notify your supervisor if problems are noted.
5. lnspect and test all panel alarms at the beginning of the shift and every four hours
thereafter.
a. Immediately notify your supervisor if the alarms are not operating properly.
b. Circuits are not to be operated unless all alarms are operating properly.
6. Inspect and calibrate the density scales once per shift.
7. lnspect the yellowcake thickeners and precipitation tanks once per shift for leaks.
a. Immediately notify your supervisor if the fans are not operating or problems
are noted.
8. lnspect the roof fans for proper operation every four hours.
a. Immediately notify your supervisor if the fans are not operating or problems
are noted.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 7
Date: O2107 Revision: DUSA I
Page 2 of 2
9. Inspect the yellowcake dryer bumers every two hours for fuel leaks.
a. Immediately notify your supervisor if any leaks are noted.
10. Inspect the yellowcake dryer scrubber system every two hours for proper water flow
and draft.
a. Adjust water flow as needed.
b. Adjust draft as needed.
c. If conditions caffiot be adjusted to the proper operating conditions, shut down
the dryer circuit, and notify your supervisor immediately.
I 1. lnspect the yellowcake dryer arms and rabbles every four hours for breaks.
a. If any are noted, shut off the feed to the dryer, shut off the shaft drive, and
notify your supervisor immediately.
12. Inspect the area for good housekeeping every four hours.
13. Clean areas as needed.
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White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
Datet 02107 Revision: DUSA I
Page I of
CHEMICALS AND REAGENTS
Introduction: Numerous inorganic and organic chemicals are used in the
processing of uranium. These include such items as:
l. Inorganic Acids
2. Organic Acids
3. Petroleum Products
4. Fuels
5. Solvents
6. Ammonia
7. Inorganic Bases
8. Flocculents
9. Degreasing Agents
I 0. Fiberglassing Compounds
I l. Oxidizing and Reducing Agents
12. Other chemicals as required
All relevant safety, first aid handling procedures and physical chemical information, etc., is
contained in the Material Safety Data Sheet (MSDS) provided in strategic locations throughout
the mill area. These can be found in the following locations; safety office, laboratory,
maintenance break room and central control room.
The MSDS supplies a description of the chemicals and reagents. The MSDS also explains the
hazards, spill procedures, safe use, and first aid procedures for each chemical and reagent.
Each operator must read and understand the MSDS of all chemicals and reagents used in
his/her department, along with the chemicals and reagents used in all operating departments.
times.
Each operator must know the location of all MSDS's for his/her operating circuit at all
Information Contained on Hazardous Material Safetv Data Sheets
Hazardous Material
Shipping Name The proper shipping name or other common name for the material; also
any synonyms for the material.
The hazard class designation for the material as found in the Department
of Transportation regulations.
The chemical name of the material and its chemical formula.
The four-digit identification number assigned to hazardous material by
the Department of Transportation; also includes the prefix "UN" or
"NA."
S.T.C.C. Number The Standard Transportation Commodity Code number used in the rail
industry; a seven-digit number assigned to a specific material or group of
materials and used in the determination of rates; for a hazardous
material, the S.T.C.C. number will begin with the digits "49."
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
DOT Hazard Class
Chemical Name
I.D. Number
Date: O2lA7 Revision: DUSA I
PageZof 6
material at normal ambient
Physical Description
Normal Physical State Physical state or form of the
Color
Odor
Chemical Properties
Specific Gravity
Vapor Density
temperatures (68"F - 77"F).
The color of the material under normal conditions.
The odor of the material upon its release.
The weight of a material as compared with the weight of an equal
volume of water; if the specific gravity is less than l, the material is
lighter than water and will floaq if the specific gravity is greater than l,
the material is heavier than water and will sink.
The weight of a pure vapor or gas compared with the weight of an equal
volume of dry air at the same temperature and pressure; if the vapor
density is less than l, the material is lighter than air and may rise; if the
vapor density is greater than l, the material is heavier than air and will
stay low to the ground.
The temperature at which a liquid changes to a vapor or gas; i.e., the
temperature where the pressure of the liquid equals atmospheric
pressure.
Boiling Point
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
Date:02/07 Revision: DUSA I
Page 3 of 6
Melting Point
Vapor Pressure
Solubility
Degree of Solubility
Other
The temperature at which a solid changes to a liquid; this temperature
also the freezing point depending on the direction of the change.
is
The pressure exerted by the vapor within the container against the sides
of a container. This pressure is temperature dependent; as the
temperature increases, so does the vapor pressure, thus, more of the
liquid evaporates or vaporizes. The lower the boiling point of a liquid,
the greater the vapor pressure it will exert at a given temperature.
The ability of a solid liquid, gas, or vapor to dissolve in water; the ability
of one material to blend uniformly with another, such as a solid in liquid,
liquid in liquid, gas in liquid, or gas in gas.
Indication of the solubility of the material.
Any additional pertinent information or data found.
Health Hazards
Are there any health hazards associated with the material?
Inhalation Hazard Is there any hazard from breathing this material?
T.L.L./T.W.A. Threshold Limit Value/Time Weighted Average
The concentration of a material to which an average, healthy person may
be repeatedly exposed for eight hours per day, 40 hours per week,
without suffering adverse health effects.
Absorption Hazard Is there any hazard from absorbing this material into the body?
LCso
Ingestion Hazard
LDso
Skin Absorption
Eye Absorption
I.D.H.L. Value
S.T.E.L. Value
Chronic Hazard
Carcinogen
Mutagen
The concentration in p.p.m. that kills 50Vo of the laboratory animals in a
given length of time.
Is there any hazard from ingesting (eating) this material?
Lethal Dose - the dose that kills 507o of the test animals.
Can material be absorbed through the skin?
Can material be absorbed through the eyes?
Immediately Dangerous to Life and Health Value - an indication of
atmospheres that are immediately dangerous to life and health. Within
30 minutes of exposure, death or irreversible health implications to the
person exposed are expected.
Short Term Exposure Limit Value - maximum allowable concentration
or ceiling, not to be exceeded during a l5 minute period.
Are there any chronic hazards associated with this material?
A material that can cause cancer in an organism.
A material that creates a change in gene structure that is potentially
capable of being transmitted to offspring.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
Teratogen
Hazardous to
Aquatic Life
Other
Decontamination
Procedures
First Aid
Procedures
Fire Hazard
Fire Hazard
Flash Point
Ignition
Flammable
Toxic ProductsThe toxic by-products of the combustion process.
of Combustion
Date: O2107 Revision: DUSA I
Page 4 of 6
A material that causes the production of a physical defect in a
developing embryo.
Is the material harmful to aquatic life?
Any additional pertinent information or data found.
Decontamination is the removal of hazardous materials from the
skin, clothing, equipment, etc.; the purpose of decontamination is to
prevent or reduce the physical transfer of any contaminants by people or
equipment from onsite to offsite locations. List methods available for
decontamination for this material.
What procedures should be followed for someone contaminated
with this material?
Will the material burn or support the combustion process of other
materials?
The minimum temperature at which a liquid gives off enough vapors to
ignite and flash over, but will not continue to burn without the addition
of more heat.
Auto-ignition Temperature - the minimum temperature required to ignite
gas or vapor without a spark or flame being present.
Explosive Range - the range of a gas or vapor concentration (percentage
by volume in air) that will burn or explode if an ignition source is
present. Limiting concentrations are commonly called the "L.E.L."
(Lower Flammable Explosive Limit) and the "U.E.L." (Upper
Flammable Explosive Limit). Below the lower flammable limit, the
mixture is too lean to burn; above the upper flammable limit, the mixture
is too rich to burn.
Other
Possible
Extinguishing
Agent
Any additional pertinent information or data found.
What extinguishing agents are suitable for control/extinguishment
of a fire involving this material?
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
Reactivity
Reactivity
With what?
Other
Corrosive Hazards
Corrosivity Hazards
pH
Corrosive to what?
Other
Neutralizing Agents
Date'.02107 Revision: DUSA I
Page 5 of 6
Will the material react with any other materials?
What is this material reactive with in what ways?
Any additional pertinent information or data found.
Is the material corrosive to other materials?
Acidic or basic corrosives are measured to one another by their ability to
dissociate in solution. Those that form the greatest number of hydrogen
ions are the strongest acids, while those that form the hydroxide ion are
the most potent bases. The measurement of the hydrogen ion
concentration in solution is called the pH of the compound in the
solution. Strong acids have low pH values and strong bases have high
pH values; the pH scale ranges from 0 to 14.
Materials with which the material is corrosive, particularly skin and
steel.
Any additional pertinent information or data found.
Those materials that can be used to neutralize the effects of the corrosive
material.
Radioactivity Hazards
Radioactivity
Hazards
Type of Radiation
Emitted
Other
Will the material emit radioactivity?
Indicate the type of radiation emitted, either alpha particles,
particles, or gamma radiation.
Any additional pertinent information or data found.
beta
Recommended Protection
For the Public
For Response
Personnel
Recommended action to protect public health and safety; indicate
evacuation distances for various amounts of the material.
Level of protection required for emergency response personnel
working in the danger zone:
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8
For the
Environment
Date:02107 Revision: DUSA I
Page 6 of 6
Level A - Requires the highest level of respiratory, skin, and eye
protection, that is, a fully encapsulating, chemically appropriate,
protective suit with its own self-contained breathing apparatus.
Level B - Requires the highest level of respiratory protection, but a
Iower level of skin protection. It is the minimum level recommended on
initial entries until the hazards have been further identified and defined
by complete monitoring, sampling, and evaluation.
Level C - Requires air purifying respirators with adequate protection
factors; coveralls and other protective equipment may be required. This
level is selected when types and concentrations of respirable materials
are knows to have adequate warning properties.
Level D - Requires no respiratory protection; basic work clothing should
be worn when sites are positively identified as having no toxic hazards.
Potential mitigation schemes to protect the environment.
Note: The back of the Hazardous Material Data Sheet can be used to collect additional
information of a more specific nature.
Yellowcake Precinitation and Drying
1. Sulfuric Acid - -93 to 95Vo strength
2. Ammonia
3. Ammonium Sulfate
4. Hydrochloric Acid
5. Propane
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=Eaioooql
White Mesa Mill - Standard Operating Procedures
Book 5 Section 8A
Date:02/07 Revision: DUSA I
Page I of I
SpilUDisposal Procedures
Certain chemicals, when spilled or disposed of, have reporting requirements
associated with them. The M.S.D.S. forms for all chemicals used in Uranium Recovery
Operations are listed, along with an indication of which chemicals have reporting
obligations. The following is an explanation of the actions required of the Mill Operator
when dealing with these chemicals. Without exception, your supervisor will make any
required reports. Refer to Emergency Response Plan for specific details regarding spill
procedures.
Resource Conservation and Recovery Act (R.C.R.A.)
R.C.R.A. regulates the manner in which hazardous materials can be disposed.
The specific requirements will be delineated with by the Environmental Department.
If you need to dispose of any chemicals, contact your supervisor for instructions.
The containers that held these products may be disposed of in any trash receptacle if:
1. The container has less than 5Vo left in the bottom, or
2. The container has been triple rinsed into any mill sump.
Spill Reportine
Reportable spills of certain chemicals must be immediately reported to
governmental agencies, depending on the quantity and type of chemical spilled. A
reportable spill is basically when the chemical hits the ground (earth), as opposed to a
spill to a concrete pad, asphalt pad, sump, etc. If a spill occurs, immediately notify your
supervisor. Your supervisor will determine if a report to an agency is necessary. Your
supervisor will make the report, if needed. Do not attempt to make a report yourself. If
there is any doubt, contact your supervisor for advice and direction.
State of Utah Division of Radiation Control
The DRC must be notified if a spill and/or accident causes more than $2,000.00 worth of
damage or 24 hours of down time. If either of these conditions exist and is unknown by your
supervisor, contact your supervisor immediately. Your supervisor will make any required
reports.
-o,N(01bCL@
White Mesa Mill - Standard Operating Procedures
Book 5 Section 9
Hazards in the Yellowcake Circuit
1. Sulfuric acid - 93Vo to 957o strength
2. High pressure steam lines - 100 psi
3. High pressure air lines - 100 psi
4. High pressure ammonia lines - 100 psi
5. Ammonia fumes
6. Elevated walkways
7. Propane gas
8. Yellowcake dust
9. Yellowcake ingestion
10. High yellowcake dryer temperatures - 1,400'F.
Date:021O7 Revision: DUSA 0
Page I of 4
11. Moving heavy yellowcake drums - 1,000 pounds gross weight
Items above can be hazards if not controlled properly. If controlled properly and
to operating standards, they are safe.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 9
Hazard Recognition - Yellowcake Precipitation and Packaging
l. Hazards
a. Sulfuric Acid Lines
l. Open slowly
2. Use personal protective equipment
Datei 02/07 Revision: DUSA 0
PageZof 4
b.
c.
d.
1. Open valve slowly
2. Use personal protective equipment
3. Report leaks promptly
4. Adjust pH properly so as not to use excessive ammonia
Steam Lines and Valves
1. Open valves slowly
2. Caution - hot valve handles
Air Lines and Valves
l. Open valves slowly
2. Whip checks on hose connections
3. Do not use to blow off clothing
Guards
1. Pump
2. Drive units
3. Centrifuges
4. Driven rollers
5. Augers
Bird Centrifuges
1. Lock out when operator changes keys
e.
f.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 9
Date'.02107 Revision: DUSA 0
Page3of 4
2. Check guards on auger before working on centrifuge
g. Health Hazards
1. Ammonia
2. Sulfuric acid - H2S in area
3. Airborne uranium
4. Beta - Gamma - Radon Daughters
a. Yellowcake precip
b. Enclosure
c. Centrifuge area
d. Packaging area
e. Scrubber - barometric tank
5. Radiation Work Permit will be issued for any work for any department
other than operations.
6. Sampling will be done in this area on a regular basis.
l.
a. Radon - monthly
b. Airbome
1. Weekly
2. Monthly
c. Ammonia
1. Monthly or whenever the need arises
d. Silica
1. At least two samples yearly
Decks and Walkways
1. Slippery after a washdown
2. Hoses in walkway and on deck
3. Sample cup is long-handled
Heat
1. Dryer enclosure - up to 150'F.
2. Scrubber deck - off gas drying ducting
h.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 9
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White Mesa Mill - Standard Operating Procedures
Book 5 Section l0
Datei 02lW Revision: DUSA I
Page I of 5
JOB PROCEDURES
This section covers job procedures for non-daily routine jobs that are performed
Y E LLOW C AKE PRE C I P ITAT I ON, DRY I N G, AN D PAC KAG I N G
All non-routine jobs will be initiated by your supervisor. Non-routine jobs will
not be performed unless directed by your supervisor.
White Mesa Mill - Standard Operating Procedures
Book 5 Section l0
Date:0210'l Revision: DUSA I
Page 2 of 5
Procedures for Preparing Yellowcake Drums and Shipping
Purpose: Cleaning, inspecting, preparing, and shipping drums of yellowcake.
1. Yellowcake lots are stored in drums which are stacked two high in the lntemational
Uranium Corporation's storage yards.
2. Each lot will have to be moved so that each drum can be inspected and prepared for
shipping and/or storage.
3. As an A.L.A.R.A. measure, lots will be isolated from other lots, or moved to the
equipment shop for preparation.
4. lnspecting and preparing drums consists of the following steps:
a. Check for any holes in the top, bottom, and sides of the drum. (Notify your
supervisor before repairing drums - a Radiation Work Permit will be
required.)
b. Check that lids and rings are properly secured and tightened.
c. All rust is to be cleaned from drums and when drums are repainted. (Wear a
face shield when using and electric wire brush; wear a leather jacket and
pants; use only heavy duty woven wire brushes when grinding.)
d. All drum numbers, lot numbers, dates, and weights are listed on each drum
and are legible.
e. All drum numbers, lot numbers, dates, and weights are correct.
5. Safety is the most important aspect of the job. Do not rush the job to be done.
a. Always keep people away from the drums when lifting the drums from a stack
or when moving the drums to prevent dropping them on someone or getting a
person in a pinch point.
b. Remember - the drums can weigh up to 1,000 pounds.
White Mesa Mill - Standard Operating Procedures
Book 5 Section l0
e.
f.
ob'
h.
i.
j
Date:02/07 Revision: DUSA I
Page 3 of 5
c.
d.
Do not use mobile equipment unless you have been trained and signed off by a
qualified instructor.
Do not use a blasting machine until you have been trained and signed off by a
qualified instructor.
Always wear proper protective equipment when performing the job.
Use ground fault receptacles on electrical equipment.
Do not use any defective equipment.
Always contact your supervisor with any problems or questions.
Read and understand all MSDS for paints and thinners used.
Mobile equipment will be inspected at the begiruring of each shift and a
Mobile Check List will be filled out and signed.
Procedures
1. Move drums from stacked lots and place on ground space so that sides and tops can
be easily inspected and prepared as necessary. The bottoms of the drums are to be
inspected by lifting the drums with a barrel grab and visually checking for leaks and
rust. Do not get under the drums when checking or cleaning and painting the
bottoms.
2. After the drums are placed on the ground, tap the lids and rings with a rubberhead
hammer and watch for any dusting. @pg4q!t: full-face respirators with a proper
canister must be worn during this procedure to prevent the inhalation of dust if there
is a leak.)
3. After the drums have been checked for leaks, remove any rust from the drums and
paint those areas. Paint any areas where the metal is bare.
4. lnspect stenciling and numbers on the tops and sides of each drum making sure all are
legible.
White Mesa Mill - Standard Operating Procedures
Book 5 Section l0
Date:02107 Revision: DUSA I
Page 4 of 5
5. Check the drum number, date, lot number, gross weight, tare weight, and net weight
on the tops and sides of each drum against the numbers on the master sheet given you
by the accounting department.
a. If numbers do not match exactly, note on the master sheet and notify your shift
foreman.
6. Loading of drums onto the truck:
a. Place the truck loading ramp up to the truck trailer.
b. Chain the ramp to the truck trailer after placing the ramp up to the trailer so
that the ramp cannot move away from the trailer.
c. Secure the truck trailer by chocking the rear wheels so that the trailer cannot
move.
d. Inspect the ramp after placing it at the trailer to be sure chains and blocks are
secure.
e. Do not use the ramp at any time if there are any defects in the ramp, chains, or
blocks.
f. Drums have to be scanned by trained personnel for surface contamination
prior to loading on the truck.
g. Prior to the truck leaving the yard area, scanning has to be done for gamma on
the truck cab and trailer. The trailer has to be placarded and the driver has to
receive our driver's shipping packet.
Precautions
1. Do not clamp barrel too tightly with the barrel grab.
a. It will bend the sides of the drums.
b. h will cause the lid to leak around the ring.
2. Do not clamp the barrel too lightly with the barrel grab.
a. It will fall and spill the material.
b. It will fall and could injure someone.
White Mesa Mill - Standard Operating Procedures
Book 5 Section l0
Datei 02107 Revision: DUSA I
Page 5 of 5
3. Always wear proper protective equipment.
4. Do not hurry or rush - use caution at all times.
5. Do not use defective equipment.
6. Always wear a face shield and leather jacket and pants when using the electric wire
brush to remove rust from the drums.
7. Always weil a respirator with the correct canister when blasting and painting. See
your supervisor for the correct canister.
8. Watch for pinch points. Fingers could be smashed between drums when moving them
by hand.
9. Follow all safety rules and procedures.
10. Report any spills of yellowcake to your supervisor immediately.
I have read and understood the abovejob procedures.
Date Names
0oUD3t-
gET
BE
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Datei 02/07 Revision: DUSA I
Page I of l0
SAFETY RULES AND PROCEDURES
Safety rules will be followed without exception. Listed on the following pages
are general safety rules and safety rules for Ore Receiving, Feed Operator, and Grind.
These rules do not cover all the White Mesa Mill safety rules. Each operator is to
know and understand all White Mesa Mill safety rules that are described in the White
Mesa Mill Safety Rules manual.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Date:02107 Revision: DUSA I
Page 2 of l0
GENERAL RT]LES
Reportine Unsafe Conditions and Iniuries
l. Correct or report all unsafe conditions to a supervisory person as soon as possible.
2. Report all injuries - no matter how slight - to your supervisor immediately. Also,
report all accidental occurrences or conditions that may have a potential for injuring
someone.
3. If you wish to see a physician for any occupational injury or illness, contact your
supervisor for an authorization slip before seeing the doctor.
Personal Protective Equipment and Clothing
l. Hard hats, safety shoes, and safety glasses with side shields must be worn at all times
in the plant area - except in control rooms, offices, and change rooms.
2. "Bump" caps, metal hard hats, and contact lenses are not permitted.
3. Other personal protective equipment includes, but is not limited to: ear plugs,
respirators, wet suits, welding helmets, goggles, gloves, and rubber boots. Face
shields and safety belts are required in designated areas and/or while performing
certain jobs. If in doubt, contact your supervisor.
4. Each employee is responsible for the condition of their protective equipment. Report
any defects, etc., to your supervisor.
5. The following equipment is required when working on pipelines or vessels containing
acids or caustics:
a. Face shield and chemical splash goggles
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Date:02/01 Revision: DUSA I
Page 3 of I0
b. Rubber coat and pants
c. Rubber gloves and rubber boots
d. Other equipment specified by the foreman for that particular job listed on the
Safe Work Permit
6. Should length of hair present a safety hazard, it must be contained.
7. Rings or other hazardous items of jewelry shall not be worn except while working in
the office.
8. The use of a safety belt and properly adjusted life line is required where there is a
danger of falling four feet or more, except while performing work under the ladder
and scaffold section of this manual. This rule applies when going beyond the
handrails of walkways on top of any tanks in the mill area.
9. Proper clothing shall be worn at all times. Loose, ragged clothing which could create
ahazard will not be permitted on the job.
10. It is a condition of employment that all personnel who may be required to wear a
respirator must be clean shaven to assure that the respirator fits properly. Personnel
will be fully trained prior to using respirators.
Conduct
Employees will be subject to disciplinary action, up to and including discharge,
for any of the following safety offenses:
1. Violation of any safety rule.
2. Entering the plant while under the influence of liquor or drugs, or having them in your
possession while in the plant area.
White Mesa Mill - Standard Operating Procedures
Book5 Section 12
Datet02lW Revision: DUSA I
Page 4 of l0
3. Fighting, wrestling, or engaging in "horseplay''while on the premises.
4. Water fights will not be tolerated.
5. Removal without authority, or destroying, or tampering with any safety device, sign,
or signal.
6. Removal of company property without specific written authorization.
7. Carrying firearms into the plant area.
8. Giving false information or testimony during an investigation of incidents.
9. When going down steps, do not slide down the handrails.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Datel.02107 Revision: DUSA I
Page 5 of l0
MOBILE EQUIPMENT - SAFETY RULES
General
l. Only trained and authorized persons may operate mobile equipment.
2. All mobile equipment shall be inspected by the operator and any safety defects
corected before the equipment is used. If safe to do so, the equipment may be driven
to the shop for repairs. Otherwise, the equipment must be towed or repaired at the
location.
3. Audible backup alarms shall be in operating condition.
4. Walk around any piece of equipment before starting or moving it. Make certain no
one is in a dangerous position and there are no obvious defects or hazards.
5. Use care when getting on or off equipment. Use the handholds provided. NEVER
JUMP from equipment.
6. No person shall get on or off of moving equipment.
7. Seat belts shall be used at all times when equipment is in motion.
8. Equipment shall be operated at a reasonable speed consistent with road and weather
conditions.
9. Equipment shall not be started or otherwise operated unless the operator is seated at
the controls of the equipment.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Date:02107 Revision: DUSA 1
Page 6 of l0
10. Keep the cabs of equipment clean. Loose items which could jam controls or create
other hazards are not allowed.
ll.Only those persons that can be seated safely in the operator's compartment will be
permitted to ride as passengers.
12. Report all accidents to your supervisor regardless of how minor they are. If property
damage or personal injury is involved, do not move the equipment until your
supervisor has released it.
13. All gasoline engines must be shut off when refueling.
14. Stunt driving and horseplay are strictly forbidden.
15. Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required
White Mesa Mill - Standard Operating Procedures
Book 5 Section l2
Date:02107 Revision: DUSA I
Page 7 of I0
OPERATIONS - SAFETY RULES
General
1. Operators are not to open electrical panels. Doors on electrical panels must be kept
closed at all times. All electrical work must be completed by a qualified electrician.
2. When lighting oil or gas-fired equipment of any type, follow the specific instructions
posted. If you smell gas or detect a leak, notify your supervisor at once.
3. Open steam valves slowly to permit condensation to escape. A sudden surge of
condensation may rupture the line and scald you.
4. Never "block in" magnetic switches. If the switch will not close, notify your
supervisor.
5. Know the location and how to use the exits, eye wash fountains, showers, protective
equipment, and fire extinguishers in your area. Know the hazards presented by
chemicals used in your area and how to defend against them. Material Safety Data
Sheets (MSDS) are available.
6. If a valve refuses to open or close, ask your supervisor to have it repaired. Do not use
a wrench or cheater to open or close a valve unless it has been thoroughly inspected to
determine its condition.
7 . All personnel shall know the location of all main block valves for fuel, kerosene, gas
steam, air, water, sulfuric acid, and ammonia lines which pass through their area.
Even though the respective valve may not be in the operator's area, he or she must
know how to shut off each line in case of an emergency.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Date:02107 Revision: DUSA I
Page 8 of l0
8. Safe operation ofconveyors requires that you shall:
a. Be sure everyone is clear of all belts and pulleys before starting the conveyors.
b. Lock out the main drive motor switch before cleaning or repairing head or tail
pulleys, idlers, or the belt. If guards must be removed to grease or use belt
dressing, the conveyor shall be locked out.
c. Never ride a conveyor belt.
d. Cross conveyors only at walkways provided.
e. Check and record each shift to be sure all emergency stop lines are operative.
Safety Rules - Yellowcake Precipitation. Drying. and Packasing
1. If any part of the dust collecting system for the drying and packaging facility is not
working, the operation shall be shut down at once.
2. Operators in this area are required to shower at the end of each shift.
3. All clothing used in the yellowcake area must be washed daily.
4. All spills and dust leaks shall be cleaned up at once and the cause corrected
immediately.
When any non-routine (i.e., maintenance, clean up work) is to be performed in the
yellowcake area, the radiation safety office shall be notified as far in advance of doing
the work as possible.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Date:02/07 Revision: DUSA I
Page 9 of l0
Time:
SAFE WORK PERMIT
Date:
In area:
Issued by:
For Dept.:
Task to be performed:
Permit good until:
Confined space hazard evaluation completed by:
REOUIRED PRECAUTIONS
Safety Dept. approval for confined space entry
Relieve vac/pressure
Equipment & lines drained, washed out, and
ventilated
Atmosphere checked for explosion, toxicity, and
oxygen (see Safety Department)
Continuous air monitor
Radiation work permit
Shower and eye wash checked
Drive mechanisms locked out
Chemical and gas inlets locked and blanked
Steam, air, and high volume lines locked
and disconnected
Special zero energy considerations
Openings roped off or guarded
Proper ladder tied off
Ground fault intem"rpter
Disconnect level indicators, etc.
Class I Division I explosion proof lights
Proper bonding and grounding of equipment and
material will be verified for permissible OHMS
resistance by a qualified electrician
Fire extinguisher and/or charged hose
Test welding hose for leaks
Qualified safety watch
Stay clear when lifting materials overhead
PERSONAL PROTECTIVE EOUIPMENT
Splash goggles O Face shield D Rubber suit O
Rubber boots D SCBA O F.F. respirator D
Cartridge type D Airline respirator C Safety belt & line D
Other equipment
COMPLETED BY
Latex nitrilgloves
Hearing protection
D
o
Special instructions
White Mesa Mill - Standard Operating Procedures
Book 5 Section 12
Job completed: Date
Reviewed by: Dept. Head
Datei 02107 Revision: DUSA I
Page l0of l0
Supervisor
Safety Department
7o!cLoqto 3.:OO(^t9= b\aoA'oe
White Mesa Mill - Standard Operating Procedures
Book 5 Section 13
Date:02107 Revision: DUSA I
Page I of 5
RADIATION SAFETY PROCEDURES
These rules do not cover all of the White Mesa Mill Radiation Safety Procedures, but are
supplied as a guide to be utilized as a supplement to the training which you have received.
Listed below are the Radiation Safety Procedures for ore receiving and grind which, when
followed, will maintain your exposures A.L.A.R.A. Remember, you are the person most
responsible for controlling your radiation exposure. If the Radiation Safety Procedures
are followed and protective equipment is utilized correctly, your exposure will be
maintained A.L.A.R.A.
Yellowcake Precipitation. Drving. and Packaqing Safety Procedures
1. A.L.A.R.A. Program Policy Statement
The policy of Denison Mines (USA) Corp. to maintain good radiation protection
practices is the expenditure of every reasonable effort to achieve and maintain low
levels of contamination and radiation in occupational exposures. By definition, the
A.L.A.R.A. program shall result in radiation exposures being maintained to levels far
below any applicable limits of the N.R.C. regulations as is reasonable.
This policy and program is to be achieved through systematic employee monitoring
and an on-going review process between the radiation protection staff and plant
operations management with secondary audits performed by corporate environmental
personnel.
Denison Mines (USA) Corp. is committed to maintaining occupational exposures of
personnel at White Mesa to levels as reasonably achievable. This commitment is
supported by the training program conducted for facility personnel, continuous
reviews of radiation, environmental and industrial hygiene protection policies.
It is the policy that occupational exposure records of personnel at the White Mesa
Mill are readily available for review when requested. The radiation protection staff
will review and discuss any aspect of radiation safety at any time.
2- Radiation Work Permit
The Radiation Work Permit is designed to provide a job procedure plan to prevent
unknown or excessive exposure when any non-routine (i.e., maintenance, etc.) work
is to be performed in the mill area. The procedure ensures that radiation hazards
which cannot be contained will be controlled by the use of protective equipment. An
initial assessment of the work environment and associated work tasks as related to
White Mesa Mill - Standard Operating Procedures
Book 5 Section 13
Date:02107 Revision: DUSA I
Page2 of 5
potential radiation exposure will be made for those non-routine work activities which
may require the issuance of a Radiation Work Permit. If it is determined, by this
initial assessment, that there is a potential for elevated radiation exposure, a Radiation
Work Permit will be issued.
a- The jobs mentioned below at yellowcake
will require a Radiation Work Permit:
b.Before work starts on the job outlined on the work permit, the radiation safety
staff must review and approve the permit after being certain there is no health
hazard to employees.
The permit must be signed by all personnel involved in the work and posted in
the work area.
d. After work has been completed, the permit will be sent to the radiation safety
office for calculations of exposures and filed for future reference.
e. The jobs mentioned below at yellowcake precipitation, drying and packaging
may require a Radiation Work Permit if the initial radiological assessment
indicates a potential for elevated radiation exposure:
Entry into thickeners or enclosed tanks.
Entry into the yellowcake dryer or packaging enclosures by anyone
other than the Operator unless covered by a written procedure.
Cleaning out the sumps.
Cleaning the yellowcake packaging and dryer scrubber system by
personnel other than the Operator. Repairs or cleaning of yellowcake
duct work. Repairs or replacement of process lines.
5. Addition of any clean up materials into the yellowcake sumps
6. Sandblasting the yellowcake dryer and packaging scrubber fans.
This is not an all-inclusive list of jobs at Yellowcake precipitation, drying and
packaging that could require a Radiation Work Permit, but is intended as a guide.
3. Posting of Specific Areas
1.
2.
3.
4.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 13
Datei02107 Revision: DUSA I
Page 3 of 5
As a part of A.L.A.R.A. practices and controlling your exposures, the following signs
could be posted in your work area. It is important that you understand what these
signs mean.
CAUTION - AIRBORNE RADIOACTM AREA This sign is posted in an area in
which airbome uranium or radon daughter concentrations are, or at above 25Vo of the
specified limits for airborne concentrations. Any time this posting is observed,
respiratory protection is required to minimize your exposure until conditions can be
corrected and airborne concentrations are below 25Vo D.A.C. The following areas
have required that they be posted as an "airbome radioactivity area" requiring the use
of full-face respirators due to airborne or radon daughter concentrations above 25Vo
D.A.C.:
a. Airborne uranium concentrations at the yellowcake dryer and packaging
enclosure average 300Vo D.A.C. Full-face respirators and protective clothing
are required when entering the yellowcake dryer and packaging enclosures.
CAUTION - RADIATION AREA This sign is posted in an area where beta and
gamma radiation levels are at, or above 5 mr/hr. Methods of controlling your
exposure to beta or gamma radiation are listed below.
Decreasing time of exposure.
lncreasing distance between you and the source.
lncreasing shielding.
Our primary means of control for gamma and beta radiation is limiting time spent in
the radiation area.
4. Procedures to Follow Regarding the Use of Respirators
When issued a new respirator, the respirator shall be fit-tested with irritant
smoke and logged on the forms provided at the shifters office. After the initial
fit-testing, a positive-negative pressure test will be done each time the
respirator is donned to ensure a proper fit.
If you are using a respirator in a very dusty area, it may be necessary to change
the filter after two to three hours. When resistance to breathing becomes
uncomfortable, it is a sign that the filters have served their useful life and need
to be replaced.
At the White Mesa Mill facility, there is only one cartridge used. The
cartridge is for nuisance dusts, chemical mist, and radiological dust.
a.
b.
c.
b.
c.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 13
Date:02107 Revision: DUSA I
Page 4 of 5
5. Radiation Safety Procedures
These are practices that, if you follow, will minimize your radiation exposure while
working at the white Mesa Mill:
a. Practice good housekeeping to prevent build up of contamination.
b. Follow good personal hygiene habits.
1. Wash your hands prior to eating and before leaving the plant.
2. Change and wash your clothes regularly and bathe regularly.
3. AII mill personnel will be provided with a change room, showers, and
laundry facilities so that they may leave their work clothes at the mill.
All coveralls and contaminated clothing will be laundered on the
property.
4. Store your lunch box and eat only in a designated eating area.
5. Scan your clothes, hands, and bottoms of your shoes with the alpha
scanner prior to leaving the restricted area.
c. Cooperate with the people making the radiation surveys by doing your job in a
normal manner. If you think sampling is being done under abnormal
conditions, tell the person doing the surveys.
d. Always wear your dosimetry device when you are assigned one. Put it in the
designated area when leaving work.
e. Wear appropriate respiratory protection while in potentially elevated radiation
areas. (full-face respirator), if required.
f. Check the equipment utilized to control the radon daughter levels, if
applicable. Take necessary precautions to reduce your radiation exposure if
there is evidence of excessive dusting and notify your shift foreman of any
equipment malfunctions.
g. If you are concemed or have any questions about the amount of radiation you
are being exposed to, contact the Radiation Safety Officer.
6. Urinalysis Sampling
White Mesa Mill - Standard Operating Procedures
Book 5 Section 13
Date'.02107 Revision: DUSA I
Page 5 of 5
Routine urinalysis samples for operators at yellowcake areas will be taken every two
weeks. Urinalysis samples are utilized to determine the uranium content contained in
the urine of the operator. The frequency of sampling is dependent on the airborne
concentrations and will be changed if airborne levels exceed 25Vo of the airborne
standards.
To minimize the change of contaminating a urine sample, the following practices
should be followed:
a. Urinalysis containers can be picked up at the administration building upon
retuming from your scheduled days off (two and four days). The sample
containers should be filled after washing your hands and prior to changing into
your work clothes or reporting to your work location. The samples can then
be placed in the bioassay laboratory.
Under unusual circumstances where specimens cannot be collected in this manner, the
worker should shower immediately prior to voiding. When a shower is not possible,
disposable plastic or rubber gloves should be wom during voiding. Take all necessary
precautions to ensure that your urine sample is not contaminated.
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2.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 14
Datei 02/07 Revision: DUSA 0
Page I of 3
1.
OPERATOR'S RESPONSIBILITIES
Shift change between operators will be made in assigned circuits. Shift change
between operators will not be made in the mill lunchroom or the mill change room.
An operator leaving his work station before being relieved will be leaving without
permission and will be subject to disciplinary action which could lead to termination.
After the shift change has been made, the oncoming operator will read the circuit log
book at the beginning of the shift for any operating changes or information pertaining
to the circuit since the last log book review. The operator will be required to initial
the log book stating he or she understands the information in the log book. If the
information concerning your operation is not clearly understood, contact your shift
foreman as soon as possible. Review the log book during your shift for any operating
changes made during your shift.
The first hour of each shift will be spent checking all equipment and conditions of the
circuit to determine that the circuit is operating safely and to operating parameters
stated in the circuit log book.
It will be the responsibility of each operator to:
a. Operate the circuit in a safe and efficient manner while following all company
safety rules.
Operate departments within specified parameters.
No alarms are to be blocked out or otherwise made to be inoperable at any
time.
Maintain a proper operating log sheet.
Collect and properly label all mill control samples and avoid sample
contamination.
3.
4.
b.
c.
d.
White Mesa Mill - Standard Operating Procedures
Book 5 Section 14
Date:02101 Revision: DUSA 0
Page2of 3
1. If a sample is contaminated, start a new sample and mark
"contaminated sample" on the item that was contaminated.
Communicate operating conditions in an accurate and timely manner.
Maintain and practice good housekeeping.
Practice assigned duties on equipment to be repaired by the maintenance
department.
1. Shut down equipment to be repaired.
2. Close all valves related to equipment to be repaired.
3. Properly bypass equipment if bypassing facilities are available.
4. After equipment has been repaired and turned back to operations, the
operator will open all equipment-related valves and all bypassed
systems and start equipment.
All operators will be required to submit bioassay (urine) samples. Normal sampling
frequency is every two weeks or monthly depending on your work locations and after
performing work requiring a Radiation Work Permit. To minimize contamination, all
operators will submit bioassay samples before reporting to their work station. Sample
containers will be placed in the administration building and bioassay laboratory.
All operators will wear personal sampling equipment when asked to do so by the
radiation or safety departments.
All operators will be provided with a change room, shower, and laundry facilities so
that they may leave their work clothes at the mill. All coveralls and contaminated
clothing will be laundered on the property.
a. Yellowcake precip and yellowcake packaging operators will be required
shower before leaving the mill. These operators will be paid 7z hour
overtime to shower.
f.
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5.
6.
7.
to
of
White Mesa Mill - Standard Operating Procedures
Book 5 Section l4
8. Prior to leaving the restricted area, all operators
alpha radiation survey meter located at the guard
survey. If the alarm sounds again, contact the
Officer, or a radiation staff member.
Darc:A2lO7 Revision: DUSA 0
Page 3 of 3
will monitor themselves with an
house. If the alarm sounds, re-
Shift Foreman, Radiation Safety
9. Operators of company vehicles must have a valid driver's license.
10. Operators will not operate mobile equipment until trained to operate mobile
equipment by a qualified trainer.
I 1. Mobile equipment is to be checked before use on each shift. A Mobile Equipment
Check List will be filled out and turned in to your shift foreman each shift. Any
equipment defects must be corrected before equipment is operated.
fiE@o
e=
No.: PBL-I I DENISON MINES (USA) CORP.
Rev. No.: R-4 | STANDARD OPERATING PROCEDURES lPage 1 of 4
Date: February 25, I Title: Safety and Environmental Review Panel
2007
1.0_Pu:pgSg:
The State of Utah Radioactive Materials License (the "License") for the White Mesa uranium
mill is a Performance-Based License ("PBL"). The License essentially allows Denison Mines
(USA) Corp. ("DUSA") to evaluate and implement certain changes in the licensed operation
without applying for and receiving a formal amendment to the License. The following
procedure outlines the procedural steps to follow when making changes to the operations
pursuant to the License or a Performance-Based License Condition ("PBLC").
2.0 Chanees Allowed Un :
Under Performance-Based Licensing, DUSA may make changes in licensed activities under
certain conditions as outlined in the License. Essentially, DUSA may:
Make changes in the facility or process, as presented in the License application,
Make changes in the procedures presented in the application, or
(3) Conduct tests or experiments not presented in the application, without prior approval
of the Executive Secretary of the State of Utah Radiation Control Board (the "Executive
Secretary"), if DUSA ensures that the following conditions are met:
. The change, test or experiment does not conflict with any requirement specifically
stated in the License (excluding material referenced in a PBLC), or impair DUSA's
ability to meet all applicable regulations;
. There is no degradation in the essential safety or environmental commitments in
the License application, or provided by the approved reclamation plan; and
. The change, test, or experiment is consistent with the conclusions of actions
analyzed and selected in the Environmental Assessment (EA) of February 1997.
(l)
(2)
Otherwise, DUSA is required to submit an application for a
Executive Secretary. The determinations whether the above
particular proposed change will be made by a Safety and
(SERP), described as follows.
license amendment from the
conditions are satisfied for a
Environmental Review Panel
No.: PBL-I I DENISON MINES (USA) CORP.
Rev. No.: R-4 STANDARD OPERATING PROCEDURES lPage 2 of 4
Date: February 25, I Title: Safety and Environmental Review Panel
2007
3.0 Safetv and Environm :
DUSA will form a SERP to evaluate each potential change under the License or PBLC. The
SERP will be responsible for reviewing the changes, tests, or experiments to determine
whether an amendment to the License is required.
The SERP shall consist of a minimum of three individuals. One member of the SERP shall
have expertise in management and shall be responsible for managerial and financial approval
changes; one member shall have expertise in operations and/or construction and shall have
responsibility for implementing any operational changes; and, one member shall be the
corporate radiation safety officer (CRSO), or equivalent, with the responsibility of assuring
changes conform to radiation safety and environmental requirements. Additional members
may be included in the SERP as appropriate, to address technical aspects such as health
physics, groundwater hydrology, surface-water hydrology, specific earth sciences, and other
technical disciplines. Temporary members or pernanent members, other than the three
above-specified individuals, may be consultants or other staff members.
4.0 SERP Review Procedurc:
In their documented review of whether a potential change, test, or experiment (hereinafter
called "the change") is allowed under the License or PBLC, without a License amendment, the
SERP shall consider the following:
(1) Current License Requirements: The SERP will conduct a review of the most current
License conditions to assess which, if any, conditions will have impact on or be impacted by
the potential SERP action. If the SERP action will conflict with a specific License
requirement, then a License amendment is necessary prior to initiating the change.
(2) Impacts on regulations: The SERP will determine if the change, test, or experiment
conflicts with applicable regulations (example: UAC R3l3-15 requirements). If the SERP
action conflicts with applicable regulations, a license amendment is necessary.
(3) Environmental Assessment: The SERP will review whether the change, test, or
experiment is consistent with the conclusions regarding actions analyzed and selected in the
Environmental Assessment of February 1997. If the change causes substantive safety or
environmental impacts that have not previously been evaluated in the environmental
report/assessment, the proposed action must be evaluated to determine if the change would
authorize or result in:
. a significant expansion of the Mill site;
No.: PBL-I I DENISON MINES (USA) CORP.
Rev. No.: R-4 | STANDARD OPERATING PROCEDURES I Page 3 of 4
Date: February 25, I Title: Safety and Environmental Review Panel
2007
a significant change in the types of effluents;
a significant increase in the amounts of effluents;
o a significant increase in individual or cumulative occupational radiation exposure; or
o a significant increase in the potential for or consequences from radiological accidents,
in which case an environmental report would be required. If an environmental report is
required, a License amendment would be necessary for the proposed action.
(4) Financial Surety: The SERP will review the proposed action to determine if any
adjustment to the financial surety anangement or approved amount is required (Condition No.
9.5 of the License). If the proposed action will require an increase to the existing surety
amount, the financial surety instrument must be increased accordingly. The surety estimate
must also be updated either through a License amendment or through the course of the annual
surety update to the Executive Secretary. The Executive Secretary incorporates the annual
surety update by license amendment.
(5) The SERP will assure that there is no degradation in the essential safety or
environmental commitment in the License application, or as provided by the approved
reclamation plan.
5.0 Documentation of R :
(1) After the SERP conducts the review process for a proposed action, it will document its
findings, recommendations and conclusions in a written report format. All members of the
SERP shall sign off in concurrence on the final report. If the report concludes that the action
meets the appropriate License or PBLC requirements and does not require a License
amendment, the proposed action may then be implemented. If the report concludes that a
License amendment is necessary prior to implementing the action, the report will document
the reasons why, and what course DUSA plans to pursue. The SERP report shall include the
following:
. A description of the proposed change, test or experiment (proposed action);
. A listing of all SERP members conducting the review, and their qualifications (if a
consultant or other additional member);
. The technical evaluation of the proposed action including all aspects of the SERP
review procedures listed above;
No.: PBL-1 I DENISON MINES (USA) CORP.
Rev. No.: R-4 I STANDARD OPERATING PROCEDURES lPage 4 of 4
Date: February 25, I Title: Safety and Environmental Review Panel
2W7
. Conclusions andrecommendations;
. Signatory approvals of the SERP members; and
. Any attachments such as approved procedures or plans, all applicable technical,
environmental or safety evaluations, reports or other relevant information
including consultant reports.
(2) All SERP reports and associated records of any changes made pursuant to the License
or PBLC shall be maintained through termination of the License.
3) On an annual basis, within sixty (60) days after the calendar year end, DUSA will
fumish to the Executive Secretary a report that describes all changes, tests or experiments
made pursuant to the License or PBLCs during the calendar year. The report will include a
summary of the SERP evaluation of each change. ln addition, DUSA will annually submit, as
part of such report, any pages of the License renewal application to reflect changes to the
August 23, l99l License Renewal Application, or supplementary information submitted by
letters dated December 13, 1991, July 25, October 5 and November 22,1994, and December
13,1996.
F3az
Ego-3
White Mesa Mill -
Book 12,ALARAProgram
2/07 Revision DUSA-l
Page I of20
ALARA PROGRAM
Denison Mines (USA) Corp.
White Mesa MilI
6425 South Highway 191
Blanding, Utah 84511
WhiteMesaMill
Book 12, ALARAProgram
2/07 Revision DUSA-l
Page 2 of 2O
TABLE OF CONTENTS
1. ALARA PHILOSOPHY .................... 4
1.1. Licensee Management .............. ...............4
1.1.1 Management Commitment.............. ...................... 4
1.1.2 ALARA Committee. .......5
1.1.3 Information and Policy Statements ....................... 5
1.1.4 ALARA Audit......... ........5
1.1.5 Continuing Management Evaluation ....................6
1.1.6 Briefings and Training in Radiation Safety ..........6
1.2. Radiation Safety Officer...... ....................6
1.3. Uranium Recovery Workers... ................7
1.3.1 Adhering to all Procedures.......... .......7
1.3.2 Reporting Promptly to the RSO and Mill Management .......... 8
1.3.3 Workers are Responsible for Suggesting Improvements............................ 8
2.1. Health Physics Authorities and Responsibilities.... ..................... 8
2.1.1 Health Physics Authorities and Responsibilities ..................... 8
2.2. Operating Procedures ...........9
2.2.1 Standard Operating Procedures Established ......... 9
2.2.2 Policy-for Eating - Restricted Area........... ............9
2.2.3 Up-to-Date Copy of All Procedures Kept Accessible ........... 10
2.2.4 Review by RSO and Documentation of Revisions................................... l0
2.2.5 Radiation Work Permits...... ............. 10
2.3. Surveillance: Audits andInspections.......... ........... l0
2.3.1 Daily Inspections .......... 11
2.3.2 Weekly Inspections ....... l l
2.3.3 Documentation of Problems and Violations ....... 11
2.3.4 Monthly Reports ........... 11
2.3.5 Radiation Protection and ALARA Program Audit ................12
2.4. Technical Qualifications of Health Physics Staff.......... ............ 14
2.4.1 Radiation Safety Officer ..................14
2.4.2 Radiation Safety Technicians ..........14
2.5. Radiation Safety Training... .................. 15
2.5.1 Periodic Radiation Training for the RSO........... .................... 15
2.5.2 Radiation Training for New Employees ............. 15
2.5.3 Hazard Training for New Employees ................. 15
2.5.4 Radiation Safety Refresher Training .................. 15
2.5.5 Radiation Safety Meetings... ............ 16
White Mesa Mill
Book 12, ALARA Program
2/07 Revision DUSA-l
Page 3 of 20
l8
2.5.6 Specialized Instruction. .................... 162.5.7 Acknowledgement of Training ........ 162.5.8 Contractors .................... 162.5.9 Visitors...... ....................17
2.6. Surveys..... ..-......l72.6.1 Responsibility to Perform............... .................... 172.7. Respiratory Protection ................ .......... 172.7.I Responsibility for the Respiratory protection program .........17
2.7 .2 Adequate Supplies of Respiratory Devices. ........ 172.7.3 Controlled Access ......... lg2.7.4 Medical Evaluations ...... lg2.7.5 RPP Complies with Regulatory Requirements................ ...... lg2.8. Bioassay Procedures ........... lg3. FACILITY AND EQUIPMENT DESIGN
3.1. Space Layout ....................... lg3.1.1 Change Rooms and Shower Facilities ................ lg3.1.2 Dispersion Control on Radioactive Materials................ ........1g3-l-3 Access to Airborne Radioactivity Levels controlled ............ 193.2. Fire Contro1............... .......... 193.3. Laboratory Design Features ................. 193.4. Ore and Product Storage...... ................. 194. CONTROL OF AIRBORNE URANIUM AND ITS DAUGHTERS...........,.....204.r.. Ore Storage, Handling, and Crushing Areas .........204.2. Precipitation, Drying, and Packaging Areas ........-.204.2.1 scrubber System on the concentrate Drying and packaging Area..... ......204.3. Interim Stabilization of Tai1inqs................. .............20
White Mesa Mill
Book l2,ALARAProgram
2/07 Revision DUSA-l
Page 4 of 2O
l.
1.1.
ALARA PHILOSOPHY
Licensee Management
1.1.1 Manasement Commitment
Denison Mines (USA) Corp. ("Denison") is committed to maintaining occupational
exposures of personnel, contractors and visitors and effluent releases at the White Mesa
Mill (the "Mill") as low as is reasonably achievable ("ALARA").
ln order to achieve this objective, Denison and its management provide a strong
commitment to and continuing support for the development and implementation of the
radiation protection and ALARA Programs at the Mill.
The program that Denison utilizes to ensure that worker exposures and effluent releases
are ALARA is the sum total of:
all the design barriers, operating procedures, management controls, and personnel
experience and expertise built into the Mill, including the equipment to control
and prevent effluent releases and to sample and monitor the working environment.
Potential releases, both in the Mill and to the environment, are held within the
performance capability of the control equipment through regular inspection and
maintenance of the equipment;
Extensive programs to monitor both the work environment and releases from the
Mill are conducted. These include monitoring of the work environment;
personnel monitoring programs; and Mill area monitoring programs, which
include both extemal radiation surveys and airborne radionuclide monitoring;
Bioassay programs;
Contamination control programs;
The qualifications of the staff. All management personnel involved with plant
radiation protection have extensive experience in similar positions, and are trained
to use appropriate technology.
Denison's commitment to this ALARA objective is supported by the training program
conducted for facility personnel, continuous reviews of radiation, environmental, and
industrial hygiene protection policies and procedures, and the adoption of procedures and
equipment that have been demonstrated to reduce occupational exposures and releases to
the environment.
This ALARA program is to be achieved through systematic worker monitoring and an
on-going review process between the radiation protection staff and plant operation
White Mesa Mill
Book 12, ALARA Program
2/07 Revision DUSA-l
Page 5 of 20
management with secondary audits performed by corporate environmental and health and
safety personnel.
1.1.2 ALARA Committee
Denison has established an ALARA Committee to review all matters relating to the
ALARA Program. The ALARA Committee meets as required, but generally at least
once per quarter. The Mill maintains a complete set of minutes from the ALARA
Committee meetings. The ALARA Committee maintains an ALARA Tracking List to
ensure that all matters raised by the Committee are dealt with in an appropriate and
timely fashion.
The members of the ALARA committee shall include at least the following:
e The Mill's Radiation Safety Officer ("RSO");
The Mill Manager;
Corporate management personnel in charge of Mill operations;
o Corporate management personnel in charge of environmental and regulatory
matters.
All Mill matters that impact or could potentially impact public health, safety or the
environment are reviewed by the ALARA Committee to ensure that exposures to the
public, workers and the environment are as low as reasonably achievable.
1.1.3 Information and Policy Statements
Denison provides information and policy statements to workers, contractors and visitors
as necessary. The underlying philosophy that radiation exposure to workers, the public
and to the environment will be maintained ALARA is a fundamental practice of ail Mill
operations, and this concept is clearly explained to all workers and contractor personnel
during Mill orientation and worker training sessions.
It is the policy of Denison that occupational exposure records of each worker at the Mill
are readily available for review by the worker. The RSO and his staff will review and
discuss any aspect of radiation safety at any time.
1.1.4 ALARA Audit
Mill License condition 11.6 requires that Denison, as Licensee, perform an annualALARA audit of the radiation safety program at the Mill, that reviews procedural and
operational efforts to maintain exposures ALARA, in accordance with Regulatory Guide
8.31. This requirement is implemented through Section 2.3.5 of this Program. TheALARA audit is performed each year by a member of the corporate environmental and
White Mesa Mill
Book 12, AI AIL{ Program
2/07 Revision DUSA-l
Page 6 of 20
regulatory compliance management personnel of the Licensee and an external consultant.
The results of this annual audit are summarized in the annual ALARA Report that is
provided to the ALARA Committee for review, and maintained on file at the Mill for
inspection.
1.1.5 Continuinq Management Evaluation
Through the ALARA Committee, Denison continually evaluates the Mill's radiation
safety (health physics) and environmental protection programs, including their staff and
whether or not adequate resources are allocated to the programs. Any issues relating to
radiation safety or environmental protection are reviewed by the ALARA Committee as
they arise. The ALARA Committee takes a pro-active role in scheduling periodic
reviews of various aspects of the Mill's radiation safety program to help ensure that any
potential areas of concem are identified and dealt with before a problem can arise.
1.1.6 Briefines and Trainins in Radiation Safety
Appropriate briefings and training in radiation safety, including ALARA concepts are
given to all uranium mill workers, both to new hires and to current Mill employees, as
part of their 40-hour training requirements under the Mine Health and Safety
Administration ("MSHA") for newly hired employees, and as part of their 8-hour
refresher training for all existing employees. In addition, appropriate training is provided
to contractors and visitors, as required. See Sections 2.5.8 and 2.5.9 below for further
details.
1.2. Radiation Safety Oflicer
The RSO has primary responsibility for the technical adequacy and correctness of the
radiation protection and ALARA program and has continuing responsibility for
surveillance and supervisory action in the enforcement of the progrcm. The RSO reports
directly to the Mill Manager, but also has the authority to report to the President or to a
Vice President, or to the Manager, Environmental Affairs of Denison if he feels the need
to do so in fulfilling his responsibilities.
Specifically, the RSO's authority and responsibilities include the following:
o Major responsibility for the development and administration of the radiation
protection and ALARA program;
o Sufficient authority to enforce regulations and administrative policies that affect
any aspect of the radiological protection program, including the following:
o the authority to order cessation, postponement or modification of any
operation at the Mill that he deems violates the radiation protection
program, industrial hygiene or environmental procedures or standards, or
the ALARA program. The RSO is directly responsible for developing,
White Mesa Mill
Book 12, AI ARA Program
2/07 Revision DUSA-l
PageT of20
implementing, monitoring and reporting activities that ensure that the Mill
radiation protection program, industrial hygiene practices and
environmental protection program meet applicable standards; and
o the authority to direct and participate in an investigation of any
circumstances of unusual exposures. Such investigation will include
recommended remedial action and documentation of corrective action;
o Responsibility to review and approve plans for new equipment, process changes,
Mill maintenance work, or changes in operating procedures, whether alone or as a
member of the Mill's SERP committee, to ensure that the plans do not adversely
affect the radiation protection program, or result in unsafe radiation safety,
industrial hygiene or environmental practices; and
o Responsibility to ensure that adequate equipment, supplies and laboratory
facilities are available, are well maintained in proper working order, and are used
properly in order to monitor relative attainment of the ALARA objective. To the
extent the Mill does not have adequate laboratory facilities or it would be
preferable to utilize an independent certified laboratory, the RSO has the authority
to utilize such an independent certified laboratory.
Demonstration of improvements in radiation safety, or in modifications sought,
considered, or implemented where reasonably achievable is the combined responsibility
of the RSO, Mill Manager and the ALARA Committee.
1.3. Uranium Recovery Workers
ln order to better ensure compliance with the Mill's radiation protection and ALARA
program, all workers at the Mill are responsible for the following:
1.3.1 Adherins to all Procedures
Adoption, approval, and adherence to the designated policies and recommendations is the
assigned responsibility of Mill management. Mill management is responsible for all
aspects of the Mill operation, including the onsite radiation protection program, and is
responsible for approval and adherence to procedures for operation of the Mill in
reference to the ALARA concept.
Mill workers are responsible for adhering to all rules, notices, and operating procedures
for radiation safety established by Denison management and the RSO. All Mill
employees are advised of this responsibility during their annual refresher training and
during specific training relating to the job tasks associated with the issuance of specific
Radiation Work Permits.
White Mesa Mill
Book 12, ALARA Program
2/07 Revision DUSA-l
Page 8 of 20
1.3-2 Reporting Promptly to the RSO and Mill Management
All workers are required to report promptly to the RSO, or Mill management, equipment
malfunctions or violations of standard practices or procedures that could result in
increased radiological hazard to any individual. This requirement is specifically
delineated in each standard operating procedure for all operating circuits at the Mill and
is emphasized in employee training sessions.
ln addition, Mill supervisory personnel are responsible for notification to the RSO
whenever activities are planned or instigated that may involve a potential significant
increase in exposure to airborne radioactivity or significant increase in extended gamma
radiation.
1.3.3 Workers are Responsible for Sueeesting Improvements
All workers are responsible for suggesting to the RSO or Mill management any
improvements for the radiation protection, environmental protection and ALARA
programs that arise from performing their jobs.
2. HEALTH PHYSICS ORGANIZATION AND ADN{INISTRATIVE
PROCEDURES
2.1. Health Physics Authorities and Responsibilities
2.1.1 Health Physics Authorities and Responsibilities
The RSO is responsible for conducting the health physics program and for assisting the
Mill Manager in ensuring compliance with applicable regulations and license conditions
applicable to worker health protection. The RSO reports directly to the Mill Manager,
but also has the authority to report to the President or to a Vice President or the Manager,
Environmental Affairs of Denison if he feels the need to do so in fulfilling his
responsibilities.
ln addition to the responsibilities and authorities delineated in Section 1.2 above, the
RSO has the following specific authorities and responsibilities:
o Directly responsible for supervising the health physics technicians, for overseeing
the day-to-day operation of the health physics program, and for ensuring that
records required by the State of Utah are maintained; and
. The responsibility and authority, through appropriate line management, to
suspend, postpone, or modify any work activity that is unsafe or potentially a
violation of the State of Utah's regulations or license conditions, including the
ALAITA program.
White Mesa Mill 2/07 Revision DUSA-I
Book l2,ALARAProgram Page9of}}
The RSO may have other safety related duties, such as responsibility for programs of
industrial hygiene and fire and safety, but will have no direct production-related
responsibility.
',',Operating Procedures
2.2.1 Standard Operating Procedures Established
The Mill is required to maintain written standard operating procedures or Radiation Work
Permits ("RWPs") for all activities that involve handling, processing, or storing
radioactive materials, as well as health physics monitoring, sampling, analysis and
instrument calibration.
All such procedures include consideration of pertinent radiation safety practices, to the
extent not covered in the Radiation Protection Manual, Respiratory Protection Manual or
Environmental Protection Manual.
2.2.2 Policy-for Eating - Restricted Area
Eating lunches or snacks, or chewing tobacco is not allowed within the Restricted Area of
the Mill except for those areas so designated by the RSO. Such noted activity, as
observed, results in a supervisory review of employee actions, documentation of the
incident, and retraining by the Radiation Safety Staff. Repeated occurrences shall be
cause for dismissal. This policy is in effect to ensure that radiation and uranium ingestion
exposures to Mill workers are maintained ALARA.
Smoking is not permitted anywhere within the Mill's Restricted Area.
The administrative office building, except for the metallurgical laboratory and sample
processing sections, is designated as an eating area.
The Restricted Area designated eating areas, are as designated by the RSO from time to
time and may include:
o Scalehouse,o Warehouse Office,r Maintenance Office,r Change Room,o MaintenanceLunchroom,o Mill Office Lunchroom,. Chief Chemist Office,r Met Lab Office,o Training Room
The designated areas are routinely monitored for alpha and beta-gamma contamination as
provided in the Radiation Protection Manual.
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Book 12, ALARA Program
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Page l0 of20
2.2.3 Up-to-Date Copv of All Procedures Kept Accessible
An up-to-date copy of each written procedure, including accident response and
radiological fire protection plans, are kept accessible to all workers under the Mill's
Document Control System.
2.2.4 Review by RSO and Documentation of Revisions
All written procedures involving radioactive material control have been compiled in a
manual (the SOP binders) that allows documentation of each revision and its date. In
accordance with the Mill's Radioactive Materials License condition 9.6, all written SOPs
for both operational and non-operational activities shall be reviewed and approved in
writing by the RSO before implementation and whenever a change in procedure is
proposed to ensure that proper radiation protection principles are being applied. In
addition, the Mill's Radioactive Materials License requires that the RSO shall perform a
documented review of all existing operating procedures at least annually, to ensure the
procedures do not violate any newly established radiation protection practices. The Mill
Manager also performs a documented review of all existing operating procedures at least
annually.
The Mill's Document Control System requires that the Master Control List (MCL) be
updated every time an SOP is revised or added. The revision date of the MCL is also
updated. A copy of the MCL is included in the front of every SOP book.
2.2.5 Radiation Work Permits
An RWP is designed to provide a job procedure plan to prevent excessive exposure when
any non-routine work is performed at the Mill.
When RWP's are issued, the Mill maintains employee exposure ALARA through
engineering controls and established management practices or by the use of respiratory
protection if no other means of controls are practical. Verification of the effectiveness of
these practices is monitored through various radiological samplings, including breathing
zone sampling, area airbome sampling, bioassay sampling, etc.
The procedure for issuance of RWPs is set out in Section 5.0 of the Mill's Radiation
Protection Manual.
2.3. Surveillance: Audits and Inspections
Daily, weekly, and monthly inspections of worker health protection practices serves to
provide management with the information necessary to conduct this ALARA program.
During non-operational periods, radiological monitoring may or may not be reduced in
frequency, depending on previous radiological trends or anticipated exposure potential.
Often such monitoring is conducted at the same frequency as but at fewer locations than
for operational periods.
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Book 12, ALARA Program
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Page I I of20
2.3.1 Dailylnspections
The RSO or designated radiation safety (health physics) technician conducts a daily
walk-through (visual) inspection of all work and storage areas of the Mill to ensure
proper implementation of good radiation safety procedures, including good housekeeping
practices that would minimize unnecessary contamination. The inspection includes
observations of housekeeping practices, ventilation equipment conditions, employee
observance of radiation protection signs and policies, and maintenance and operating
conditions present during the inspection. The inspection will include all work, storage,
and lunchroom areas of the facility. These inspections are documented and on file in the
Radiation Safety Office. A copy of the Daily Inspection of the Mill form is attached as
Appendix A. If not included on the inspection form, a report to the RSO on any items of
non-compliance with operating procedures, Iicense requirements, or safety practices
affecting radiological safety is also made.
2.3.2 Weekllr Inspections
Routine weekly inspections of all areas of the Mill are made by the RSO and Shift
Foremen or designees, to observe general radiation control practices and review required
changes in procedures and equipment. Particular attention is focused on areas where
potential exposures to personnel might exist and in areas of operation or locations where
contamination is evident. A copy of the Weekly Mill lnspection Report form is attached
as Appendix B.
In addition, the RSO, or his designee, will review the daily shift logs and work orders on
a weekly basis to determine that all jobs and operations having a potential to exposing
personnel to uranium were evaluated, either through a properly completed RWP or
authorized written job operating or maintenance procedure, or were approved by the
RSO, his staff, or designee prior to initiation of the work.
2.3.3 Documentation of Problems and Violations
Problems observed during all inspections are noted in writing in an inspection logbook,
inspection forms, or other retrievable record format. The entries are dated, signed, and
maintained on file for at least one year.
The RSO reviews all violations of radiation safety procedures or other potentially
hazardous problems with the Mill Manager or other Mill workers who have authority to
correct the problem.
2.3.4 Monthly Reports
At least monthly the RSO reviews the results of daily and weekly inspections, including a
review of all monitoring and exposure data for the month and provides to the Mill
Manager, and any other Mill department heads designated by the Mill Manager, for their
White Mesa Mill
Book 12, ALARA Program
2/07 Revision DUSA-l
Page 12 of20
review a monthly report containing a written summary of the month's significant worker
protection activities. The Monthly Report should contain, at a minimum, the following
information:
. a surlmary of the most recent personnel exposure data, including bioassays and
time-weighted calculations ;
a summary of all pertinent radiation survey records;
a discussion of any trends or deviations from the radiation protection and ALARA
program, including an evaluation of the adequacy of the implementation of
license conditions regarding radiation protection and ALARA; and
a description of unresolved problems and the proposed conective measures.
Emphasis is placed upon maintaining activities ALARA.
These monthly reports are maintained on file and readily accessible for at least five years.
The RSO performs an unannounced monthly documented walk-through inspection of all
work and storage areas to ensure the radiation safety program is working as required.
Appropriate actions are taken promptly by the RSO to correct any problems or
deficiencies noted during inspections by the RSO and his designees. When unusual
exposures have occurred, the RSO will direct and participate in an investigation to
determine the cause, and the remedial actions necessary. Mill operations management
will decide on action to be taken, and the RSO will document the resultant action for later
review. These are reviewed by Mill operations management on a monthly basis.
2.3.5 Radiation Protection and ALARA Program Audit
An arunual audit of the radiation protection, envirorunental protection and AI.ARA
program is performed, and a written report on the audit is submitted to the AI AIUq
Committee for review and action, if warranted.
All members of the ALARA audit team should be knowledgeable conceming the
radiation protection program at the Mill. In addition, one member of the team should be
experienced in the operational aspects of the Mill's radiation protection practices. One or
more of the audit team will be independent specialists. An example of an audit team is a
member of corporate environmental health and safety together with an independent
expert in radiation safety practices at uranium mills. The RSO should accompany the
team but should not be a member.
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Book 12, Ar.ARAProgram
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a) Radiation Protection Component of ALAMAudit
The audit report should summarize the following data relating to radiation protection at
the Mill:
(i) Worker exposure records (external and time-weighted calculations);
(iD Bioassay results;
(iii) Inspection log entries and summary reports of daily, weekly, and monthly
inspections;
(iv) Documented training program activities;
(v) Radiation safety meeting reports;
(vi) Radiological survey and sampling data;
(vii) Reports on overexposure of workers submitted to the Executive Secretary
or MSHA; and
(viii) Operating procedures that were reviewed during this time period.
The audit report should specifically discuss the following:
o Trends in personnel exposures for identifiable categories of workers and types of
operational activities;
o Whether equipment for exposure control is being properly used, maintained, and
inspected; and
o Recommendations on ways to further reduce personnel exposures from uranium
and its daughters.
b) Environmental Component of ALARA Audit
Utah Administrative Code R313-15-101 (2) provides that the Licensee shall use, to the
extent practicable, procedures and engineering controls based upon sound radiation
protection principles to achieve occupational doses and doses to members of the public
that are ALARA. As a result, in addition to occupational data, the annual ALARA audit
also addresses all environmental monitoring data for the year.
The audit committee will review and document in the annual ALARA report the
following items relating to environmental matters at the Mill:
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Documented inspection reports ;
Environmental radiological effluent and
quality assurance data as necessary; and
data,
(iii) Reviews of operating and monitoring procedures completed during this
time period.
(iv) The audit specifically addresses:
Trends in environmental radiological effluent and monitoring data;
Performance of effluent control equipment; and.
o Administrative controls and policies and ALARA management of
retention systems and release.
c) Timing of AI-ARA Audit and Review of Audit Report
The ALARA audit for a particular calendar year will be performed as soon as reasonably
practicable in the following calendar year as all of the monitoring data and dose
calculations for the subject calendar year become available, and will be performed
generally in the frst quarter of the next calendar year. The Audit Report will be
completed by April 30 of each year.
The ALARA report is reviewed by the ALARA Committee. The ALARA Committee
will make a determination whether or not any recommendations in the ALARA audit
report require follow-up or further actions. It will be the responsibility of the Mill
Manager to ensure that the decisions of the ALARA Committee are implemented.
The ALARA audit reports are maintained on file at the Mill.
Technical Qualifications of Health Physics Staff
2.4.1 Radiation Safety Officer
The RSO should have the level of education, training and experience recommended in
NRC Reg. Guide 8.31.
2.4.2 RadiationSafetyTechnicians
When the Mill is in full-scale operations, in addition to the RSO, there should be a
minimum of one full-time radiation safety (health physics) technician. The radiation
safety technician(s) should have the level of education, training and experience
recommended in NRC Reg. Guide 8.31. The radiation safety technician(s) should
demonstrate a working knowledge of the proper operation of health physics instruments
(i)
(ii)
2.4.
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personnel dosimetryused in the Mill, surveying and sampling techniques, and
requirements.
7<Radiation Safety Training
2.5.1 Periodic Radiation Training for the RSO
The RSO is required to have refresher training once every two years.
2.5.2 Radiation Trainine for New Employees
All new workers are trained by means of an established course on the inherent risks of
exposure to radiation and the fundamentals of protection against exposure to uranium and
its daughters before beginning their jobs. This training program, which is set out in the
Mill's Training Program, takes 24 hours for inexperienced personnel, of which
approximately 8 hours is devoted to radiation safety training, and 8 hours for experienced
personnel, of which approximately 3 hours is devoted to radiation safety training. The
topics listed in 2.5(l) to (6) of Reg Guide 8.31 are included in the Mill's Training
Program. In all cases, the training will be commensurate with the risks and hazards of the
task.
A written or oral test with questions directly relevant to the principles of radiation safety
and health protection in uranium milling is covered in the training course given to each
worker.
The instructor reviews the test results with each worker; workers who fail the test are
retested after items of confusion are discussed. The tests and results are maintained on
file.
2.5.3 Hazard Trainine for New Employees
All new workers receive hazard training in accordance with the Mill's Mine Safety and
Health Administration ("MSHA") training plan for new hires. This training takes 24
hours, which includes the 8 hour radiation training referred to in section 2.5.2 above.
2.5.4 Radiation Safetli Refresher Trainine
All Mill workers receive eight-hour refresher training in accordance with the Mill's
MSHA training plan each year. This training includes annual radiation safety training,
including relevant information that has become available during the past year, a review of
safety problems that have arisen during the year, changes in regulations and license
conditions, exposure trends and other current topics. Some of these topics are discussed
at various radiation safety meetings that are held during the year. The radiation refresher
training is set out in the Mill's Training Program. As part of this training, all workers are
required to retake the written test required of new hires.
White Mesa Mill
Book 12, ALARA Program
A list of all workers who completed the
maintained on file at the Mill.
2/07 Revision DUSA-l
Page 16 of 20
retraining and copies of the written tests are
2.5.5 Radiation Safety Meetines
ln addition to the 8-hour refresher training, relevant information that has become
available, a review of safety problems that have arisen and changes in regulations and
license conditions are discussed as they arise during radiation safety meetings. These
meetings are generally held once per month when the Mill is operating, and once per
quarter when the Mill is not operating.
2.5.6 Specializedlnstruction
All new workers, including supervisors, are given specialized instruction on the health
and radiation safety aspect of the specific job they will perform. All workers receive the
Z4-hour initial radiation and safety training when first employed. In addition, when the
employees get to their jobs, their supervisor gives them specific on-the-job training. This
training typically does not cover radiation protection, to the extent it is already covered in
the initial training. If specific radiation protection issues exist for any particular job, or
new job (such as may result from a new alternate feed material), such issues would
typically be addressed in a new procedure, RWP or Safe Work Permit ("SWp"1. The
RSO will determine any new procedures or actions that are required in order to ensure
radiation protection is ALARA. If the job is a one-time type of job, then an RWP or
SWP will typically be employed. If the job is to be a recurring job, then a new procedure
may be adopted, or an RWP will initially be adopted, followed by a new procedure.
Specific radiation protection training is given on any new procedure or permit either at a
regularly scheduled radiation and safety meeting or at a radiation and safety meeting held
for the affected employees.
2.5.7 Acknowledgement of Training
All employees sign an attendance sheet for each training session. This sheet is dated and
is co-signed by the instructor.
2.5.8 Contractors
Contractors having work assignments in the Mill are given appropriate training and safety
instruction. Contractor workers who will perform work on heavily contaminated
equipment will receive the same training and radiation safety instruction normally
required of all permanent workers. Only job-specific radiation safety instruction is given
for contract workers who have previously received full training on prior work
assignments at the Mill or have evidence of recent and relevant radiation safety training
elsewhere. Basic radiation training is given verbally, unless more specific training is
required, which would be addressed on a case-by-case basis. Contractors are provided
with an instructional packet and are required to acknowledge their acceptance thereof.
White Mesa Mill
Book 12, ALARA Program
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PagelT of20
2.6.
7.5.9 Visitors
All visitors who have not received training are escorted by someone properly trained and
knowledgeable about the hazards of the Mill, or have received instructions specifically on
what they should do to avoid possible radiological and non-radiological hazards in the
areas of the Mill they will be visiting. Typically, all visitors are escorted by trained
personnel. In addition, the RSO or a member of his staff will also provide a short safety
briefing about possible hazards that exist at the Mill before any visitor, who is
accompanied by trained personnel, is permitted to enter the Mill's restricted area.
Surveys
2.6.1 Responsibilityto Perform
The RSO and radiation safety office staff are responsible for performing all routine and
special radiation surveys as required by license conditions and by R313-15, in accordance
with NRC Regulatory Guide 8.30 (Health Physics Surveys in Uranium Mills). Under
certain SOPs (for example the Intermodal Container Acceptance, Handling & Release,
No. PBL-2 Rev. No. R-3 and End Dump Trailer Acceptance, Handling & Release,PBL-
9, Rev. No R-0), the RSO is given authority to delegate release surveys to other qualified
Mill personnel.
Radiological surveys are performed as set out in the Mill's Radiation Protection Manual
and Environmental Protection Manual-
2.7. RespiratoryProtection
2.7.1 Responsibility for the Respiratory Protection Proeram
The RSO is responsible for the implementation and direct control of the respiratory
protection program. This program is set out in the Mill's Respiratory Protection
Program.
2.7.2 Adequate Supplies of Respiratory Devices
It is the responsibility of the RSO to ensure that the Mill maintains adequate supplies of
respiratory devices to enable issuing a device to each individual who enters an airbome
radioactivity area, and that additional respiratory protection devices are located near
access points or airbome radioactivity areas.
White Mesa Mill
Book 12, AI ARA Program
2/07 Revision DUSA-l
Page l8 of20
2.7.3 ControlledAccess
All airborne radioactivity areas have controlled access. The controlled access is marked
with warning signs and is either a separate room that can only be entered through a door
or is a roped or taped off area that one must knowingly cross over.
2.7.4 MedicalEvaluations
The RPP provides that medical qualification will be required of each employee that might
be using a respirator in their normal work duties.
2.7.5 RPP Complies with Regulatory Requirements
The Mill's RPP must meet, at a minimum, the requirements of NRC Reg. Guide 8.15.
2.8. Bioassay Procedures
The RSO is responsible for implementing a bioassay program. The Mill performs
bioassays in accordance with U.S. NRC Regulatory Guide 8.22, "Bioassays at Uranium
Mills", which states that frequent bioassays are to be performed for employees that are
routinely exposed to yellowcake dust, uranium ore dust, or involved in maintenance tasks
in which potential yellowcake exposure may occur. Urinalysis measurements are
performed in accordance with the recommendations contained in Regulatory Guide 8.22.
The recommendations in Reg. Guide 8.22 provide corrective actions based on urinary
uranium concentrations. This program is set out in the Mill's Radiation Protection
Manual.
3. FACILITY AND EQUIPMENT DESIGN
3.1. Space Layout
As the Mill was licensed and constructed in 1980, it was designed to incorporate the
ALARA standards prevailing at that time, which generally are reflected in Reg Guide
8.31 (which was published in 1983). As a result, the space layout, access control,
ventilation systems, fire control, laboratory design features, ore and product storage and
general equipment considerations requirements specified in Section 3 of Reg. Guide 8.31
have been incorporated into the design of the Mill. Any new construction at the Mill
should observe these design features and considerations set out in Reg Guide 8.31.
3.1.1 Change Rooms and Shower Facilities
The Mill maintains change rooms and shower facilities so that all workers can remove
any possible radioactive contamination before leaving.
White Mesa Mill
Book 12, ALARA Program
3.1.2 Dispersion Control on Radioactive Materials
2/07 Revision DUSA-l
Page 19 of20
The Mill has dispersion control on radioactive materials moving from contamination
areas (e.g., grinding mill) to relatively contamination-free areas (e.g., grinding control
room). Lower contamination areas are isolated from higher contamination areas by self-
closing doors, and air flows are maintained from lower contamination areas into higher
contamination areas.
3.1.3 Access to Airborne Radioactivity Levels Controlled
Access to airborne radioactivity areas are controlled or restricted by the use of caution
signs and operational procedures, or security locks when permitted by fire regulations. In
particular access to the yellowcake drying area is restricted by the radiation staff. Access
to the drying and packaging areas are restricted by padlock on the doors.
3.2. Fire Control
The Mill maintains adequate firefighting equipment. Mill workers are trained in the
proper use of fire control equipment. This training is provided annually under the
MSHA-approved training plan and is also addressed biannually during an unannounced
fire drill.
As per MSHA requirements, fire detection systems are checked quarterly and fire
extinguishers are checked monthly.
3.3. Laboratory Design Features
Metallurgical. Bioassay and assay analyses are performed at the Mill site. In order to
prevent cross contamination of uranium from metallurgical analysis, there are different
laboratory facilities for metallurgical, bioassay and assay analyses.
Laboratory surfaces used for the preparation of bioassay samples are decontaminated to
Ievels as close to background as practicable but less than 200 dpmi10Ocml. The results
of these surveys are recorded on a log sheet that is kept in the bioassay lab.
3.4. Ore and Product Storage
Ore and yellowcake will be stored in areas so that the material does not cause
unnecessary exposure to workers and so that the material is not dispersed by wind and
rain.
Adequate space will be provided in the yellowcake storage and packaging areas to
conduct initial surveys and spot smear tests of yellowcake packages and to enable
decontamination of drums to avoid transporting a contaminated package through otherMill areas
White Mesa Mill
Book 12, ALARA Program
Yellowcake storage and shipping areas will be located to
required prior to shipment.
2/07 Revision DUSA-l
Page 20 of 20
the handling time
4.
4.1.
CONTROL OF AIRBORNE URANIUM AND ITS DAUGHTERS
Ore Storage, Handling, and Crushing Areas
Where ore is handled in the open the ALARA objective is to minimize blowing of dust.
The Mill's Utah Air Quality Approval Order specifies the steps the Mill must take for
fugitive dust management. Additional provisions are required under the Mill's license.
A weekly inspection of the ore piles for dust conditions will dictate if dust suppression
measures are necessary. This inspection is documented by the Radiation Safety Staff and
filed with the Radiation Safety Department. If dusty conditions are present, the roadways
and ore stockpiles will be sprayed with water or stabilizers to minimize dusting.
4.2. Precipitation, Drying, and Packaging Areas
4.2.1 Scrubber System on the Concentrate Drying and Packaeine Area
Drying and packaging of yellowcake is performed in an enclosure that is separated from
other areas of the Mill. Also, the drying and packaging enclosure is maintained under
negative pressure. An automatic malfunction alarm and interlock system has been
installed on the scrubber system for the yellowcake drying and packaging system
scrubber, to ensure that the yellowcake dryer will not operate unless the scrubber is also
operating. No modification to the system will be allowed to bypass the interlock system.
Operation of the yellow cake calciner will not be allowed to proceed without proper
scrubber operation.
Manometer readings or operation and instrument checks are recorded once per shift when
the system is operating and recorded in log books and operational data sheets
4.3. Interim Stabilization of Tailinqs
The active tailing retention system, when observed to be in a condition causing fugitive
tailing dust generation, will be treated using process liquor or other chemical dust
suppressant methods or engineering solutions to minimize tailing dust generation (See
Section 3.1 of the Mill's Environmental Protection Manual).
Book 12, ALARA Program, Appendix A
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