DRC-2008-002581 - 0901a06880aee4f6

J
DENIS
MINES
August 8, 2008
VIA PDF AND FEDEX
Mr. Dane L. Finerfrock
Executive Secretary
Utah Fladiation Control Board
State of Utah Department of EnvironmentalQuality
168 North 1950 West
Salt Lake City, UT 84114-4850
I
"J)l
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : 303 62&7798
Fax : 303 389*4125
www.denisonmines.com
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Dear Mr. Finerfrock:
Re: October 12,2OO7 Draft Contingency Plan for Denison Mines (USA) Corporation, as Required Under
Part 1.H.16 of State of Utah GWDP No. UGW370004: Conditional Approval
As requested, please find enclosed a draft-revised Contingency Plan for your review.
The draft includes revisions to incorporate the recent changes to the White Mesa Mill's Groundwater Discharge
Permit relating to Cell 44, as well as some minor clean-up changes resulting from other changes to the Permit.
lf you have any questions or require any further information, ptJas" contact the undersigned.
Yours very truly,
Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
White Mesa Mill - Stand?
Ooeratins Procedures
DU/08 Revision: DUSA-I
Book # l9-Groundwater
Discharge Permit Plans and
Procedures
Page I of 13
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Required Un{6r Part I.H.165
State of Utah Groundwater Discharge Permit No.UGW370N42oaa l? struzoog
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
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Denver
White Mesa Mill - Stand?
Oneratino Procedures
DU/08 Revision: DUSA-I
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Paee 2 ol13
TABLE OF CONTENTS
INTRODUCTION
PURPOSE
3. GROUNDWATER CONTAMINATION
3.1. Notification
3.2. Continuation of Accelerated Monitoring
3.3. Submission of Plan and Timetable
3.4. Groundwater Remediation Plan
4. MILL DISCHARGB VIOLATIONS - INCLT]DING
UNAUTHORIZED DISCHARGE OR RELEASE OF PROHIBITED
CONTAMINANTS TO THE TAILING CELLS
4.1. Notifications
4.2. Field Activities
4.3. Request for Approvals and/or Waivers
5. DMT VIOLATIONS
5.1. Tailings Cell Wastewater Pool Elevation Above the Maximum
Elevations
5.2. Excess Head in Tailings Cells 2 and 3 Slimes Drain Systems
5.3. Excess Cell4A Leak Detection Fluid Head or Daily Leak Rate
$.$5.4. Excess Elevation For Tailings Solids
$45.5. Roberts Pond Wastewater Elevation
$55.6. Feedstock Storage Area
#5.7. Mill Site Chemical Reagent Storage
$.45.8. Failure to Construct as per Approval
$&5.9. Failure to Comply with Stormwater Management and Spill Control
Requirements
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Book# 19-Groundwater
Discharge Permit Plans and
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004
INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's") White Mesa Uranium Mill
(the "Mill"). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into groundwater.
n- fiu,lrly)N1 A;{*2. PURPOSE
This Contingency Plan (the "Plan") provides a detailed list of actions Denison will take to ^..-l EAI-regain compliance with GWDP limitsrand Discharge Minimization Technology ("DMT") ANC !)'
requirements defined in Parts LC and I.D of the GWDP. The timely execution of
contingency and corrective actions outlined in this Plan will provide Denison with the
basis to exercise the Affirmative Action Defense provision in Part I.G.3.c) of the GWDP
and thereby avoid noncompliance status and potential enforcement actionl.
The contingency actions required to regain compliance with GWDP limitsranfDMT, axrl BAT
requirements defined in Parts I.C and I.D of the GWDP are described below.
3. GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part LG.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
I Part I.G.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstratingthat it has made appropriate notifications, that the failure was
not intentional or caused by Denison's negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions ofUCA l9-5-107 have not been violated.
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White Mesa Mill- Standil
Oneratins Procedures
D!/08 Revision: DUSA-l
Book# l9-Groundwater
Discharge Permit Plans and
Page4ofl3
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
3.1. Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.
3.2. Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in thaAompliance
monitoring well pursuant to Part I.G.1 of the GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.@Peff
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If the accelerated monitoring demonstrates that the Mill is no longe$p!:tS1ffi ' slefus
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ameter,
with respect to a parameter in a well, then, with thervritten appro
Secretary, Denison will cease accelerated monitofpg fort#$kuSecretary, Denison will cease accelerated
r thervritten aoorovalbf the Executive
itori n s for +n3'ILumeter- and*sfurttrc taN{At< rJn,4.1v?
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3.3. Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill isNrt of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of r)a i-
potential remedial action to restore and maintain ground water quality to ensure that ) gr ul\l
permit limits will not be exceeded at the compliance monitoring point and that DMT will
be reestablished, as required undpr part [.G.4.c) of the GWDP. This plan willrcrmaltp-
includel l>t 'ri NoL io,:h-/ rt."
a) The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
b) A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
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White Mesa Mill - Stand?
Ooeratins Procedures
D!/08 Revision: DUSA-I
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Page 5 o:[ 13
d)
contamination. This willtormatlyinclude a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and
If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions to
restore and maintain groundwater quality to ensure that permit limits will not ig
exceeded at the compliance monitoring point and thatDMTffiill be reestablished,
as well as actions that merely allow natural attenuation to operate and actions that
involve applying for Alternate Concentration Limiis ("
remediation is required, Denison will prepare and
Secreiary a Ground Water Remediation Plan, as described in Section3.4below.)/
4n:
3.4. Groundwater Remediation Plan S.tblif ,4.Awnuxl
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive SecretaryT, The Gropqd lVater Remediation Plan will
nsrma*tyincludel blt is fit 1;q;1J* 7e Tulo*)ry\.-k)
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a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
lprels o4lCl-s at the compliance monitoring point(s) or other locations approved
place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonstrate the
effectiveness ofthe plan; and
c) Descriptions of how conective action will apply to each source of the pollution.
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison und u
4. MILL DISCHARGE VIOLATIONS - INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
PartLC.Z. of the GWDP provides that only lle.(Z) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
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White Mesa Mill - Standil
Oneratins Procedures
DU/08 Revision: DUSA-l
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Page 6 o:[_!3
Part t.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as 11e.(2) material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1. Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal
hours of discovery followed
discovery.
4.2. Field Activities
notification to the Executive Secretary within 24
by a written notification within five days of
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a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill personnel
will nevertheless mark or record the location of the Unauthorized Materials in the
tailings cells;
c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from the
tailings cells; and
d) Denison will dispose of the Unauthorized Material under applicable State and
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4.3. Request for Approvals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will:
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White Mesa Mill - Standil
Onerat'ins Procedures
Du/08 Revision: DUSA-I
Book# l9-Groundwater
Discharse Permit Plans and
Page 7 pI_I3
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a)
b)
Submit a written ,"r#r"Tn*il*ecutive Secretary analyzingthe health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
Apply to the Executive ,""i{*#;,$y *"noments that may be required to the
GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment; and 0ft
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c) Make all applications required under the United States
Commis sion' s ("NRC' s") " Non- 1le-(2)Disposal Policyli ncludin g obtainin g
approval of the Department of Energy as the long term custodian of the Mill's
tailings, in order to obtain approval to permanently dispose of the Unauthorized
Material in the Mill's tailings cells.
5. DMT VIOLATIONS
5.1. Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d) of the GWDP provides that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner ("FML").
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following processl
( a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary wrthin24
hours of discovery followed by a written notification within five days of
discovery;
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.t\ or' c) Upon discovery, Mill personnel will cease to discharge any further tailings to the
o\hpu -"u .. J subject tailings cell, until such time as adequate freeboard capacity exists in the
)'Su,)**{n' subject tailings cell for the disposal of the tailings;
t\ .,r V' 0t ,
o$' -w1,rd d) To the extent reasonably practicable, without causing a violation of the freeboard
!o'td" [mit in any other tailings cell, Mill personnel will promptly pump fluids from the
subject tailings cell to another tailings cell until such time as the freeboard limit
for the subject tailings cell is in compliance. If there is no room available in
4
White MesaMill- Stand?
Ooeratins Procedures
DU/08 Revision: DUSA-l
Book# l9-Groundwater
Discharge Permit Plans and
Procedures
Page 8 ol_13
another tailings cell, without violating the freeboard limit of such other cell, then,
as soon as reasonably practicable, Mill personnel will cease to discharge any
further tailings to any tailings cell until such time as adequate freeboard capacity
exists in all tailings cells;
e) If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject tailings
cell will be reduced through natural evaporation; and
0 Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change elisting ppocedures to minimize the chance of a
recurrence. ""; ;,;;;i'"' li,;1,;;;"" 2;:';:;"";)::i:iu wr 4,,
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5.2. Excess Head in Tailings Cells 2.3,and34A Slimes Drain Systems * y.|[\-x
ri*
Part I.D.3.b)1) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accor(ance with a DMT Monitoring Plan approved by the Executive
Sec pursuant t6Part I.H.13 of the GWDP, and that for Cell 3, this requirement shall
apply only after initiation of de-watering operations. Similarl)r. Part I.D.6.c) of the
GWDP provides that after Denison initiates pumping conditions in the slimes drain layer
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laver. in a manner equivalent to the requirements found in Part I.D.3.b). Z\ au"l ^ At)u'6li YcAn c'z'
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell4,A, exceeds the levels specified in the DMT Monitoring Plan,
4 Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell, or
other appropriate containment or evaporation facility approved by the Executive
Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
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White Mesa Mill- Standt!
Oneratins Procedures
IU/08 Revision:DUSA-l
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Paee 9 orl-13
e) If not due to an identified equipment failure, Denison will perform a root cause ,- A*rrliryranalysis of the exceedance and will implement new procedures or change. J pst'r - r ';:.
exisiing procedures to minimize the chance of a r".uo"r... X frY +'Ar; i*i,
5.3. Excess Cell4,A' l,eak Detection Svstem Fluid Head or Daily Leak Rate
Part I.D.6.a) provides that the fluid head in the Leak Detection System ("LDS") for Cell
44, shall not exceed I foot above the lowest point in the lower membrane liner. and Part
I.D.6.b) of the GWDP provides that the maximum allowable daily leak rate measur.ed in
the LDS for Cell 4A shall not exceed 24.160 gallons/day. a o a t 1,)l*t$
fKo}',u''exceeds 24.160 gallons/day. Denison will. subject to any specific requirements of the
Executive Secretary as set forth in any notice. order. remediation plan or the equivalent.
implement the following process:x
a) Upon discovery. the Mill Manager or RSO will be notified immediately:
b) Mill personnel will promptly pump the excess fluid into an active tailings cell. or
other appropriate containment or evaporation facility approved by the Executive
Secretary. until such time as the cause of exceedance is rectified or until such
time as otherwise directed by the Executive Secretary:
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c) If the exceedance is the result of equipment failure. Mill personnel will attempt
to r"puir o. r"ptuo iii" "q;i;m"ni:- ffi^rr
d\ If the cause of the exceedance is not rectified withir&-heurs. Denison will
(5n'-, '' '
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ification to the E Za lzou.-y,
e) If not due to an identified equignent failure. Denison will perform a root cause
analysis ofthe exceedance and
exi*tip.I procedures t of a _.€lEiiEF
S.*5.4. Excess Elevation For Tailings Solids
Part I.D.3,$q)D of the GWDP provides that upon closure of any tailings cell, Denison
shall ensure that the maximum elevation of the tailings waste solids does not exceed the
top of the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
a
White Mesa Mill - Standat!
Ooeratine hocedures
DU/08 Revision: DUSA-l
Book# 19-Groundwater
Discharee Permit Plans and
Paee l0O[_!3
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
To the extent reasonably practicable, without causing a violation of the freeboard
limit in any other tailings cell, Mill personnel will promptly remove tailings
solids from the subject tailings cell to another tailings cell, or other location
approved by the Executive Secretary, until such time as the maximum elevation
of the tailings waste solids in the subject tailings cell does not exceed the top of
the FML; and
Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurrence.
$.45.5. Roberts Pond Wastewater Elevation
Part I.D.3.+e) of the GWDP provides that the Permittee shall operate Roberts Pond so as
to provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell I within 72
hours of discovery, as specified in Part I.D.3.+q) of the GWDP.
In the event that, Denison fails ,fl*;X;,i, hu'S,r[, -f
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a)Upondiscovery,theMillManagerorRSowillbenotifiedimmediately;and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
555.6. Feedstock Storage Area
Part LD.3.dfl and Part I.D.11 of the GWDP provides that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
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White Mesa Mill- Standil
Ooeratine Procedures
Df/08 Revision: DUSA-l
Book# l9-Groundwater
Discharge Permit Plans and
Pagellof13
eastern portion of the Mill site area described in Table 4 of the GWDP, and that storage
of feedstock materials at the facility outside that area shall be performed and.main*ained
inersin accordance with an approved Feedstock
Manasement Plan Dursuant to Part l.H.zl of the GWDP.
In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.J0 and Part LD.l1 of the GWDP, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary wrthin24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in elos€4
water tight eentainer'^ccordance with the approved Feedstock
Management Plan; and(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers q
otherwise dealt with in accordance with the approved Feedstock
Management Plan, and any impacted soils will be removed and will be
deposited into the Mill's active tailings cell; and
d) Denison will perform a root cause analysis of the non-compliant activity and will
implement new procedures or change existing procedures to minimize the chance
of a recurrence.
5.*5.7. Mill Site Chemical Reagent Storage
Part I.D.3.-eg) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
&'lr'/-
In the event that Denison.does-neeprovide the required secondary containment required
under Part I.dp.3.,+g) of the GWDP, Denison will, subject to any specific requirements
(ii)
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Oneratins Procedures
IU/08 Revision: DUSA-I
Book# 19-Groundwater
Discharee Permit Plans and
Procedures
Page 12 o:Ll3
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
c) Denison will promptly remediate any spilled re-agent resulting from the failure to
provide the required secondary containment under Part I.dp.3.eg) of the GWDP,
by removal of the contaminated soil and disposal in the active lailings cell. . ,.k ,.br+ i glela--1' u-t-A rtnl.(y{t* ('"r-(f' 1>du'N1
5*5.8. Failureio Construct as per Ap-proval ('.4 Att b.ou , korJ -P
Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5*5.9. Failure to Comply with Stormwater Management and Splll Control Requirements
Part I.D.8]Q of the GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with an
approved. Sto.rmwater Best Management Practices Plan, pursuant to Part I.H.176 of the
GWDP. X
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
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White Mesa Mill - Stand!
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Book# 19-Groundwater
Discharge Permit Plans and
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Paee 13 of l3
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discoveryi and
To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
b)
c)
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WHITh MESA TTRAMUM MILL
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ICONTINGENCY PLAI\
I
lAs Contemplated by Part LG.4(d)
I
Stat€ of Utah fr**a*"rcr Disoharge PcrmitNo.UGW370004
I
Prepared by:
Denison Mines (USA) Corp.
1050 lTth SheeL Suite 950
DenverCO 80265
*f
4,b,
White Mesa Mill - Standard
Operating Procedures
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Date: JJ.rll.l nevisio$4,-:
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TABLE OF CONTENTS
1. INTRODUCTION
2. PURPOSE
3. GROUNDWATER CONTAMINATION3.1. Notification3.2. Continuation of Accelerated Monitoring3.3. Submission of Plan and Timetable3.4. Groundwater Remediation Plan
4. MILL DISCHARGE VIOLATIONS - INCLUDING
UNAUTHORIZED DISCHARGE OR RELEASE OF PROHIBITED
CONTAMINAIITS TO THE TAILINGCELLS4.1. Notifications4.2. Field Activities4.3. Request for Approvals and/or Waivers
5. DMT VIOLATIONS5.1. Tailings Cell Wastewater Pool Elevation Above the Maximum
Elevations5.2. Excess Head in Tailings Cells 2 and 3 Slimes Drain Systems5.3. Excess Cell4,A, Leak Detection Fluid Head or Daily Leak Rate5.4. Excess New Decontamination Pad Leak Detection Fluid Head5.5. Excess Elevation For Tailings Solids5.6. Roberts Pond Wastewater Elevation5.7. Feedstock Storage Area5.8. Mill Site Chemical Reagent Storage5.9. Failure to Constuct as per Approval
5.10. Failure to Comply with Stormwater Management and Spill Control
Requirements
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White Mesa Mill - Standard
Operating Procedures
Book# l9-Groundwater
Discharge Permit Plans and
Procedures
Date: J lLLl Reuirlgr}4,;r-, -
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Detetedr and
WHITE MESA URANIUM MILL
CONTINGENCY PLATI
State of Utah Groundwater Discharge Permit
No. UGW370004
1. INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's') White Mesa Uranium Mill
(the "Mill'). The GWDP specifies the
requirements for all facilities at the Mi
operation, and monitoring
havg a potential to discharge pollutants
directly or indirectly into
Julv I
approved Mav 2. 2008.) apf inol
PURPOSE
This Contingency Plan (the "Plan") provides a detailed list of actions Denison will take
regain compliance with GWDP limits,jbs Pischarge Minimi
("DMT") and the Best Available Technology Plan (."defined in Parts
I.C, I.D, and I$.4 o{$_e GWDP. Thg time_fy _e1e_c_ut1og_of_cg{tqqg.er-rgy and corrggtive ,
actions outlined in this Plan will provide Denison with the basis to exercise the
Affirmative Action Defense provision in Part I.G.3.c) of the GWDP and thereby avoid
noncompliance status and potential enforcement actionl.
The contingency actions required to regain compliance with GWDP limits and DMT 3!d
BAT requirements defined in Parts I.C, I.D, and I$.4 of the GW-Df are desggbe{ be-lo1v,
3. GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to Part I.G.2 of the GWDP.
' Part LG.3.c; of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison's negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions ofUCA l9-5-107 have not been violated.
White Mesa Mill- Standard
Operating Procedures
Book# 19-Groundwater
Discharge Permit Plans and
Procedures
Date:J t)rl I Revisiorle-r Deletedr 9/lo
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When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part LG.4.a) of the GWDP.
Continuation of Accelerated Monitorins
Denison will continue accelerated sampling for the parameter in that particular
compliance monitoring well pursuant to Part LG.1 of the GWDP, unless the Executive
Secretary determines that other periodic sampling is appropriate, until the facility is
brought into compliance, as required under Part I.G.4.b) of the GWDP.
lgomPliance w-ith
the Executive
Secretary, Denison will cease accelerated monitoring for&qlpirameiier, iiay,tlL.z'
continue routing monitoring ftrr that pa.rameter.
3.3.Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT qfl-
BAI will be reestablished, as required under part I.G,4.c) of the GWDP. This plan will
jnc lude-bUL,b nslUlu(sd_lq : .,,'
The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
If the accelerated monitorin g demonstrates jhat the IEq, te t_u;
respect to a parameter in a well, then, witK,written approval
a)
b)
Deleted: Mill is no longer out of
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Deteted: the
Del€tedr no further steps will be
followed by Denison with respecdsuch
parameter.
White Mesa Mill - Standard
Operating Procedures
Book # 19 - Groundwater
Discharge Permit Plans and
Procedures
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c) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will jnclude_a_d_eggqptlo_n-qlqny-qd_dltlo-nal wells to be used
or installed to characterizathe piume ana ttre nyAiog"olog," charactenstrcs-of tt . -
affected zone, the analytical parameters to be obtained, the samples of ground
water to be taken, and any other means to measure and characterize the affected
ground water and contamination zone; and
d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions to
restore and maintain groundwater quality to ensure that permit limits wjll not be
exceeded at the compliance monitoring point and that DMT and RA'f/will be
reestablished, as well as actions that merely allow natural attenuation to operate
and actions that involve applying for Altemate Concentration Limits ("ACLs").
ACLs require approval of the Water Ouality Board prior to becoming eff'ectivc/
If groundwater remediation is;:equired, Denison will prepare and submitJbr./
Executive Secretary appr,:vaIa Ground Water Remediation Plan, as described in
Section 3.4 below.
3.4. Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation PIan will
jlclude,hut=is not limited to:
a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations approved
by the Executive Secretary, by removing the contaminants, treating them in
place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonsEate the
effectiveness ofthe plan; and
c) Descriptions of how corrective action will apply to each source of the pollution.
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4. MILL DISCHARGE VIOLATIONS - INCLUDING UNAUTHORIZED
DISCIIARGE OR RELEASE OF PROHIBITED CONTAMINAI\TS TO THE
TAILING CELLS
White Mesa Mill - Standard
Operating Procedures
Book # 19 - Groundwater
Discharge Permit Plans and
Procedures
P3sg; I0,]I,l ,R-eririofSa f
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Commcnt [rjt2]: The GWDP do€s
not cont€mplat€ hadling non-l le.(2)
w6te
Comment [rrtr]: Pleas€ be morc
ific. Which
Comment [qrt4lr Tk G\ryDP does
not conterplat! hsrdling non-l le.(2)
ffit€
Partl.C.2. of the GWDP provides that only I 1e.(2) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
Part LC.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as I le.(2) material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1. Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery.
4.2. Field Activities
Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of ttre Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill personnel
will nevertheless mark or record the location of the Unauthorized Materials in the
tailings cells;
To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from the
tailings cells; and
Denison will dispose of the Unauthorized Material under applicable State and/
Federal regulations.i
4.3.[equest for AoJrrovals and/or Walverd ,/-
a)
b)
c)
d)
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Operating Procedures
Book # l9 - Croundwater
Discharge Permit Plans and
Procedures
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If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will:
a) Submit a written report to the Executive Secretary arlalyztngthe health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b) Apply to the Executive Secretary for any amendments that may be required to the
GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment;_a_nd
c) Make all applications req-uired under the United States Nuclear Regulatory
Commission's ("NRC's") Non-l 1e.(2) Disposal Policy, incJuding obtaimng
approval of the Department of Energy as the long term custodian of the Mill's
tailings, in order to obtain approval to permanently dispose of the Unauthorized
Material in the Mill's tailings cells.
5. DMT VIOLATIONS
5.l. Tailines Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d) of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorizedby the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet, as measured from the top of the flexible
membrane liner ("FML").
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirements of the Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, implement the following process:
a) l.Jpon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Upon discovery, Mill personnel will cease to discharge any further tailings to the
subject tailings cell, until such time as adequate freeboard capacity exists in the
subject tailings cell for the disposal of ttre tailings;
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Operating Procedures
Book # l9 - Groundwater
Discharge Permit Plans and
Procedures
Date:J 0l,l I Reri.iofe-:
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Comm€nt [rrtl0]: Can we defim this
morc clcnrp
d) To the exteqt re?soilably practicable, without causing a violation of the freeboard
Uqrit in any other tailings cell, Mill personlel will promptly pump fluids from the
subject tailings cell to another tailings cell until such time as the fi.eeboard limit
for the subject tailings cell is in compliance. If ttrere is no room available in
another tailings cell, without violating the freeboard limit of such otler cell, then,
as soon as reasonably practicable, Mill personnel will cease to discharge any
further tailings to any tailings cell until such time as adequate freeboard capacity
exists in all tailings cells; I
If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject tailings
cell will be reduced through natural evaporation; and
Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurrence. Denisou,will submit the findrnes of the root cause analysis to thg
Executive Secretary.,
5.2. Excess Head in Tailings Cells 2. 3 and 4.A, Slimes Drain Systems /
Part LD.3.b)l) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be [s low as reasonably
achievablq !l qgcgrdance with ttre Mill'g cq{rg4lly 4ppr9ye4 P}4J llg4itoring Upl , pn4 -that for Cell 3, this requirement shall apply only after initiation of de-watering operations.
Similarly, Part I.D.6.c) of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell4A, Denison will provide: l) continuous
declining fluid heads in the slimes drain layer, in a manner equivalent to the requirements
found in Part LD.3.b); and2) a maximum head of 1.0 feet in the tailings (as measured
from the lowest point of the upper FML) in 6.4 years or less.
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell3 or initiation of pumping conditions in the
slimes drain layer in Cell 4.A exceeds the levels specified in the DMT Monitoring Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set forth
in any notice, order, remediation plan or the equivalent, implement the following process:
a) jUpon discovery, the Mill Manager or RSO will be notified immediately;
e)
b)
c)
Mill personnel will promptly pump the excess fluid iato an;active tailings cell, or
other appropriate containment or evaporation facility approved by the Executive
Secretary;
If tle exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replaoe the equipment;
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Operating Procedures
Book#19-Groundwater
Discharge Permit Plans and
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lf the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implemant new procedures or change
existing procedures to minimize the chance of a recurrence. Denison will submit
the firrlirrgs of the root caore unaly.i, to the Executiue Sec.IE]I]--
5.3. Excess Cell4A Leak Detection System Fluid Head or Daily Leak Rate
part t.O.O.al provides that the fluid head in the Leak Detection System (.'LDS") for Cell
4A shall not exceed I foot above the lowest point in the lower membrane liner, and Part
I.D.6.b) of the CWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell44' shall not exceed 24,160 gallons/day.
In the event that the fluid head in the LDS for Cell4A excceds I foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirements of the
Executive Secretary as sst forth in any notice, order, remediation plan or the equivalent,
implement the following process: ,
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Mill personnel will promptly pump the excess fluid into an active tailings cell, or
other appropriate containment or evaporation facility approved by the Executive
Secretary, until such time as the cause of exceedance is rectified or until such
time as otherwise directed by the Executive Secretary;
c) If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
d) If the cause of the exceedance is not rectifiedJhe Sfllne yqQ.*ing day, Denison ,
will provide verbal notification to the Executive Secretary withinf4 hours
followed by a written notification within five days; and
e) If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedancq
\4iF'*.".*Ce1t4B[eakT)etecfirrnSvsf€mFhridH'eadorI)ailvT.eakRatd<
5.5. Excess New Decontamination Pad Leak Detection System Fluid Head
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maximum head abovc tbc LDS ransdr.Eor
of2.28 fcct
d)
e)
lomm€nt [rrt11]: Tinrclirc rcquircd
C,ommGnt [rrtl2]l Bullets a) t]nough
e) not idontified in dre CWDP
procedures or change existing procedures
to rcmediate the exceedance and to
Commcnt [fi14]: Add sectiou to
addrcss Ccll48.
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Discharge Permit Plans and
Procedures
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In order to ensure ttrat the primary containment of the New Decontamination Pad water
collection system has not been compromised, and to provide an inspection capability to
detect leakage from the primary containment in each of the three settling tanks, a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.
Section 3.1(e) of the Mill's DMT Monitoring Plan provides that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any of ttre three standpipes.
In the event that the fluid head in the standpipe for a settling tank exceeds 0. 10 feet above
the concrete floor in the standpipe, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;
c) Mill personnel will promptly pump the fluid from the settling tank's LDS as well
as the fluids in the settling tank into another settling tank or into an active tailings
cell, or other appropriate containment or evaporation facility approved by the
Executive Secretary, until such time as the cause of the exceedance is rectified or
until such time as otherwise directed by the Executive Secretary; and
d) Denison will perform a root cause analysis of the exceedance and, if appropriate,
will implement new procedures or change existing procedures to remediate the
exceedance and to minimize the chance of a recurrence. De.qiSpq will SULmit the
findinss of the root cause analvsis to the Exeoutive Sbcretarv.l
5.6, Cracks or Physical Discrepancies on the New Decontamination Pad Wash Pad. + "
In the event that cracks or other physical discreoancies are observed on the concrete wash
pad. Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
Drocess:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) The EDP shall be taken out of service and the cracks or deficiencies will be
repaired utilizing industry standard materials and procedures appropriate for the
defect. Following recommended cure times, the cracks or deficiencies will be re-
inspected and, if acceptable, the EDP will be placed back into service.
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Operating Procedures
Book# l9-Groundwater
Discharge Permit Plans and
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c) A record of the repairs will be maintained as a part of the inspection records at
the White Mesa Mill.
5.7. Excess Elevation For Tailines Solids
Part I.D.3.c) of the GWDP provides that upon closure of any tailings cell, Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailiirgs
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) To the extent reasonably practicable, without causing a violation of the freeboard
limit in any other tailings cell, Mill personnel will promptly remove tailings
solids from the subject tailings cell to another tailings cell, or other location
approved by the Executive Secretary, until such time as the maximum elevation
of the tailings waste solids in the subject tailings cell does not exceed the top of
the FML;and
d) Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurTence. ilJelusoil w
Executive Secretar.vi
5.[i. Roberts Pond Wastewater Elevation
Part I.D.3.e) of the GWDP provides that ttre Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell I within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDP.
Comrnent [rft161: Eshblish a
tirnelire for rhis subrnittsl.
Formatted: Bullets and
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Operating Procedures
Book#19-Groundwater
Discharge Permit Plans and
Procedures
,"/
In the event that, Denison fails to;emove,the excesq wastewaterlqgfl:iq J|[qggg[ /
clip-c_gverv, Denison will, subject to any specific requirements of the Executive Secretary
as set forth in any notice, order, remediation plan or the equivalent, implement the
following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5,9. Feedstock Storase Area .
Part LD.3.f) and Part I.D.l 1 of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion of the Mill site area described in Table 4 of the GWDP, and that storage
of feedstock materials at the facilify outside that area shall be performed in accordance
with the provisions of Part LD.l l of the GWDP.
In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f) and Part I.D.l I of ttre GWDP, Denison will,
subject to any specific requirements of ttre Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
(D move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;(iD ensure that any feedstock materials that are stored outside of the area
described in Table 4 of ttre GWDP are stored and maintained in
accordance with the provisions of Part I.D.l I of the GWDP; and(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance with the provisions of Part I.D.1 I of
the GWDP, and any impacted soils will be removed and will be deposited
into the Mill's active tailings cell; and
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d) Denison will perform a root cause analysis of the non-compliant activity and will
implement new
of a recurrence.
res or change existing procedures to minimize the chance
5.10. Mill Site Chemical Reaeent Storaee .
Part I.D.3.g) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction ofreagent storage facilities, the secondary containment and control
shall prevent any contact ofthe spilled reagent with the ground surface.
In the event that Denison{dh'1g prqvide- the reguired qecgn{ary conlaiqrpent reguired
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
c) Denison will promptly remediate any spilled re-agent resulting from the failure to
provide the required secondary containment under Part LD.3.g) of the GWDP, by
removal of the contaminated soil and disposal in the active tailings cell.
5.11. Failure to Construct as per Approval .
Part I.D.4 of the GWDP provides that any constuction, modification, or operation of new
waste or wastewater disposal, heatment, or storage facilities shall require submittal of
engineering desiga plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, heatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Consfuction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
White Mesa Mill - Standard
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Discharge Permit Plans and
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Date: ,l.oil I R-eviriofe-r
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D€l€ted3 9/10
Formatted: BulleE and Numbering
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery,
5.12. Failure to Comply with Stormwater Management and Spill Conhol Requirements. -
Part LD. l0 of the GWDP provides that Denison will manage all contact and non-contract
stormwater and control contaminant spills at the Mill facility in accordance with the
currently approved Stormwater Best Management Practices Plan.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and
c) To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
manage any such spill, Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
Part I
Permit No. UGW370004
Executive Secretary requires additional information, the Permittee will provide all
requested information within a time frame approved by the Executive Secretary. Upon
Executive Secretary approval of the final infiltration and contaminant transport report, the
Reclamation Plan may be modified to accommodate necessary changes to protect public
health and the environment.
I l. Plan for Evaluation of Deep Supply Well WW-2 -the purpose of this plan is to evaluate
the annular casing seal in water supply well WW-2, and to ensure adequate well casing
and annular seals, in compliance with the regulations of the Utah State Engineer (UAC
R655-4-9), with special emphasis on creating both a physical barrier and hydraulic
isolation between the shallow unconfined and the deep confined aquifers. Prior to
Executive Secretary approval of this plan the Permittee shall resolve all issues within a
timeframe approved by the Executive Secretary. After Executive Secretary approval of
the plan, the Permittee shall completely execute all provisions of the plan on or before
decommissioning of the White Mesa mill.
12.Liner Maintenance Provisions - within 90-days of issuance of this Permit, the Permittee
shall submit Liner Maintenance Provisions to be incorporated into the existing DMT
Monitoring Plan for Executive Secretary approval. The purpose of said provisions shall
be for the equipment, material, training and procedures to be used for the timely detection
of any openings in the polymer liners, and the reliable repair and quality assurance testing
of any such repairs to the polymer liners for Cells 1,2 and 3 and the Roberts Pond.
13 <Reserved>
ithin 180 days of issuance of this Permit, the Permittee shall
ingency Plan that provides a detailed list of actions the Permittee will
-gain compliance with Permit limits and DMT or BAT requirements defined in
Parts I.C and I.D of this Permit. At a minimum, the Contingency Plan will include, but is
not limited to measures to resolve the following general categories of non-compliance:
a) Groundwater Contamination - as shown by any contaminant concentrations in
compliance monitoring wells that exceed their respective groundwater compliance
limit found in Part I.C.1 and Table 2 of this Permit.
b) Mill Discharge Violations - including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to Partl.C.2 and I.C.3; and
c) DMT and BAT Violations - which include several types of non-compliance,
including but not limited to:
1) Excess tailings cell wastewater pool elevation above the maximum elevations
mandated by Part I.D.3;
2) Excess head in the Tailings Cells 2 and 3 slimes drain system, pursuant to Part
I.D.3 and as defined by the DMT Monitoring Plan in Part I.H.l3; and
3) Excess elevation for tailings solids as required by Part I.D.3.
If after review of the plan, the Executive-Secretary determines that additional information
JJ
15. Contingency Pla
4il1 .a*'l;": rrl
Permit No. UGW3700O4
is required, the Permittee shall provide all requested information, resolve all issues
identified, and re-submit the plan for Executive Secretary review and approval within a
timeframe approved by the Executive Secretary.
16. Revised Stormwater Best Management Practices Plan - on or before May 15, 2008, the
Permittee shall submit for Executive Secretary review and approval, a revised Stormwater
Best Management Practices Plan to address the effects of Tailings Cell 44. construction
and operation. Said plan shall comply with the requirements of Part I.D.l0 of this permit.
Upon Executive Secretary approval, the Permittee is to immediately implement all
provisions of such plans.
17. <Reserved>
18. Repair of Monitor Well MW-5 - on or before May 1, 2008, the Permittee shall submit an
As-Built report to document said repairs for Executive Secretary review and approval.
19. Cell4A BAT Monitoring, Operations and Maintenance Plan. - the Permittee will submit
an Operations and Maintenance Plan for Cell 44 for Executive Secretary review and
approval. Commencement of wastewater or tailings discharge to Cell 4,A. is prohibited
without prior written approval from the Executive Secretary. Said Plan shall include
requirements in Part F.3 of the Permit and include, but is not limited to the following:
a. Operation and Maintenance Procedures - including operational sequences,
transporting methods, equipment operation / maintenance, safety and emergency
procedures,
b. Operation, Maintenance, Monitoring, and Recordkeeping - for evaluation of the
following in accordance with the requirements of Parts I.D.6, I.E.8, and I.F.8:
i. Irak detection system - including operational statue of equipment, daily
wastewater head, daily flow rates, etc.
ii. Slimes drainage system - including operational status of equipment, daily flow
rates, monthly wastewater recovery head monitoring, etc,
c. Freeboard limits on dikes - including monitoring and proper management and volume
inventory controls to prevent release of wastewater to the environment.
20.<Reserved>- QAP
2l.Feedstock Material Stored Outside the Feedstock Storage Area Management Plan - within
30 days of issuance of this Permit the Permittee shall submit for Executive Secretary
review and approval a management plan for the feedstock material stored outside the
feedstock ore storage area.
22- QAP Revision - on or before April 30, 2008 the Permittee shall modify the QAP and
submit a revised revision for Executive Secretary review and approval. Said changes
shall require that all non - conformance with QAP requirements discovered in a given
quarterly ground water monitoring period will be corrected and reported to the Executive
Secretary on or before submittal of the next quarterly ground water monitoring report as
required in Part I.E.1(a).
34
I whitc Mesa Mill - Standard
Opcrating Itroccdurcs
llook # I9-Oroundwsler
I)ischargc Pcnnil Plans attd
Itroccrlurcs
Date: 3!/10 Rcvision: DUSA-?J
Pagc I ot'14
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Contemplated by Part I.G,4(d)
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
I)enison Mines (USA) Corp.
1050 l7'h Street, Suite 950
Denver CO 80265
Marel*2.$gp_tg.$:,ber 2, 20 I 0
Whitc Mcsl Mill - Standard
Opcr'atirrg Proccdurcs
llook # l9 - crourldwater
Dischargc l)snnit [>lans and
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Dalc: 'r9/10 Rcvision: DUSA-?il
Pagc 2 o['14
.[ABI,E OIT CONTENTS
INTRODUCTION
PURPOSE
3. GROIJNDWATf,RCONTAMINATION3.1. Notification3.2. Continuation of Accelcrated Monitoring3.3. Submission of Plan and Timetable3.4. GrpundwaterRentediationPlan
4. MILL DISCHARGE VIOLATIONS - INCLUDING
UNAUTHORIZED DISCUARGE OR IIDLEASE OIT PROHIBITIID
CONTAMINANTS TO TI,ID'T'AILING CIILLS4.1. Notifications4.2. l'ield Activities4,3. Request for Applovals and/or Waivers
5. DMT VIOLATIONS5.1. 'l'ailings Cell Wastewater Pool Elevation Above the Maximurn
Lllevations5.2. Excess Head in Tailings Cells 2 and 3 Slimes Drain Systerns5.3, Excess Cell 44. Leak Detection lrluid llead or Daily Leak Rate5.4. Excess New Decontarnination Pad Leak Detection Fluid Head5.5. Excess Elevation For Tailings Solids5.6. Itoberts Pond Wastewater Elevation
5.'1 . Feedstock Storage Area5,8. Mill Site Chemical Reagent Storage5.9. fjailurB to Con$truct as per Approval5.10. Failure to Comply with Stortnwater Managernent and Spitl Contr.ol
Requirernents
Paue
No.
Jl.
)
J
4
4
4
5
6
6
(r
7
7
8II
l0
II
l1t)
l3
l3
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WHI'I'II MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Grorrndwatcr Discharge permit
No. UGW370004
I. IN'I'RODUCTION
The State of utah has granled Ground water Discharge perrnit No. uGW370004 (the"cwDP") for Derrison Mine.s (USA) corp.'s ("Denison's") white Mesa uraniurn Mill
(the *Mill"). 'l'he CWDP specifies the const*rction, opel.ation, and nronitoring
requilernents for all facilities at the Mitl that have a potential to discharge pollutantri
dilectly or indirectly into groundwater.,
2, PURPOSE
'l'his Contingency Plan (the "Plan") pr'ovides a detailecl list of actions Denison will take to
regain cornpliance witlr GWDP lirnits and Discharge Minimization'technology ("DMT")
requirernents defined in Parts I,C, l.D, and I.l-1.4 of'ths GWDp. The timely eiecution of
contingency and corrective actions outlined in this Plan will provide Deniion with the
basis to exercise the Affinnative Actiorr l)el"ense provision in parr I.G,3.c) of the GWDI)
and thereby avoid noncompliance status ancl potential eulorcement actionl.
'fhe contingency actions required to regain cornpliance with GwDI, lirnits and DMT
requiremerts defined in Parts I.c, LD, and Lll.4 of the GwDp are described below.
3. GROUNDWATER CONTAMINATION
since there are many different possible scenalios that coutcl potentially give rise togroundwatel contamination, and since the developrnont and irnplerlentation of a
remediation progl'am will normally be specific to each palticulal scenario, this Plan cloes
not outline a definitive remcdiation program. Rather, this Plan describes the steps thatwill be followed by Denison in the event l)enison is found to be out of cornpliance with
respect to any constituent in any rnonitoring well, pursuant to part I.G.2 of the owDp.
when the concenh'ation ol'any pararneter in a compliance morritor.ing well is out ofl
compliance, Denison will, subject to slrcific lequirelnents of the Executive Secretary as
' Part.l.G.3.c) of thc CWDI'ploviclcs thrt, in thc cvent n conrptinnce action is irritiatcd agahrst Dcnison lbr.violation ollrcrrnit condititns rclatilrg to bcst avrilablc tcchntllogy or DM-l', t)cnison nriy allirrnntivcly
dclbnd against that action by dcrnonstr'atirrg that it llas rnaclc appropriatc notilications. that thc Ihiku'e wns
uot intcntiorral orcaused by Dcnison's negligcrrcc, tlral l)cnison has takon arlcquatc ulcasur.cs to rncetpcnttit conrlilions irt a tinrely rttanncr or has subrrrittcri an atlcquatc plan rutd scircdulc !'<lr.n:ecting pcr.nrit
corrditions, nlld that thc provisions ol'UCA I9-5-107 have no( bccn violated.
Whits Mcsa Mill - Standard
Opcratilrg Pmccdurcs
llook il {9 - Groundlatcr
!)isolrarge Pcrmit l)lans and
l\'occdurcs
set lbrth in any notice, order, reurediation plan
pfocess:
Datc: 19"/10 Rcvision: DUSA-21
I,agc 4 ol l4
or the equivalent, inrplernent the lollowing
3.1. Notification
Denison will notily the Executive Secretary of the out olrcompliance status within 24
hours after detection of that $tatus l'ollowed by a rvritten notice within 5 days after.
detection, as lequired undet' Part LG.4.a) of the CWDP.
3.2. Co-Ellinuation ofAccelelated Monitoring
Denison wilI continuc accelerated sampling fol the palanreter in that compliance
monitoring well pulsuant to Part LG.l ol'the GWDP, unless the Executive Secretary
detelrnines that other periodic sampling is approlrriate, until the flacility is lrrought inro
cornpliarrce, as lequiled urrder Part I.G.4.b) of the GWDP.
If tlre accelerated rnonitoring demonstrates that the Mill is no longer out of cornpliar.rce
with respect to a parameter in a wcll, then, with the written approval of the Executive
Sectetary, Denison will cease acceleratecl monitoring for the pararneter, and no further.
steps will be l'ollowed by Denison with respcct to such pal'alneter.
3.3. Subrli,s"qi.g.Jr of Plan and Tinretable
If the accelerated rnonitoring conlirrns that the Mill is out of cornpliance with respect to a
paranleter in a well, then, within 30 days of such confirrrlation, Denison will prcpare ancl
submit to the F.xecutive Secretary a plan and a tirne scheclule for assessment of the
soulces, extent and potential clispersion ofl the contarmination, and an evaluation of
polcntial I'emedial action to restole and maintain ground water quality to ensur.e tlrat
perrnit linrits will not be exceeded at the cornpliancc monitoring point and that DMT will
be rccstablished, as required undel part l.G.4.c) of the GWDP. 'lhis plan will normally
include:
'l'he requirernent for Denison to prepare a detailed and cornpr-ehensive
opcrational history of the facility and surrounding areas which explores all
activities that rnay have contributed to the contamination;
A t'equirernent for f)enison to colnplete an evaluation, which rnay include
gcochernical and hydrogeological analyses, to detetmine whether ol not the
contanrination was caused by Mill activities or was calrsed by natural lbrces or
offsite activities;
If it is concluded that the contarnination is the le-sult ol'current or past activities
at the Mill, Deni.son will prepare a Characterizatiorr Report, which character.izes
the physical, chernical, and radiological extent ofthe ground water'
a)
b)
c)
Whitc Mcsa Mill - Standard
0pcratirrg l'roccdurcs
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I)ischargc I)etrnit Plarrs and
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Pagc 5 ol' l4
contalninat,on. 'l'his will normally include a description of any additional wells
to be used or installed to characterize the pluurc and the hydrogeologic
characteristics ofthe affected zone, the analytical paralneter$ to be obtained, the
salnples of ground water to be taken, and any other means to rreasure and
characterize the affected ground water and contarnination zone; and
d) ll'it is concluded that the cotrtatnination i.s the result of culrent or pa$t activitics
at the Mill, Denison will evaluale potential remedial actions, including actions to
restore and tnaintairr groundwator quality to ensure that pelrnit liurits will not be
exceeded at the cornpliance rnonitoring point and that DMT will be ree.stablished,
as well as actions that rnelely allow natural attenuatioD to opemte and actions that
involve applying l"or Alternate Concentration Limits ("ACLs"). Ilgroundwater
rernediation is lequired, Denison will prepare and subrnit to the Executive
Secretary a Ground Water Rernediation Plan, as de.scribed in Section 3.4 below.
3.4. Cloundwater Remediation I>lan
Il'the Executive Secretary deter'rnines that ground water rcrncdiation is needed, Dcnison
will subrmit a Clound Water Rernediation Plan to the Executive Seclctary within the tirne
fi'arne requested by the Executive Secrctary. 'lhs Ground Water Itenrediation Plan will
normally include:
a) A description and schedule oflrow f)enison will inrplernent a corrective action
plogratn that plevents contatninants fi'om exceedirrg the ground wate| plotectiou
levels or ACLs at the cornpliance rnonitoring point(s) or othel locations approved
by the Executive Secretary, by rernoving the contatninants, treating thcnr in
place, or by other mean.s as approved by the Executive Secretary;
b) A description of the remediation rnonitoling prograrn to dernor)strate tho
effecliveness ofthe plan; and
c) Description.s of how couective action will apply to cach source of the pollution.
Deni.son will implement the Glound Water Rern<:diation Plan in accordance with a
schedule to be sulrntitted by Denison and approved by the Executive Secretaty.
4. MILL DISC[IAIIGE VIOLA'TIONS _ INCLUDING UNAUTTIORIZEI)
DISCI.IARGtr OR RELEASE OF PITOHI BI'I'ED CONTA M INANTS]'O'TI{E
TAILING CII,LLS
Part I.C,2. oflthe GWDP pt'ovides that only lle.(2) by-pt'oducr rnatelial authorized by the
Mill's State of [Jtah Radioactive Materials License No. UT-2300478 (the "Radioactive
Matcrials Licen.se") shall be discharged to or disposed of in the Mill's tailings cells.
Whitc Mcsa Mill- Standard
Opcrating Proecdurcs
llook /l t9 - Grrundwatcr'
Dischargc Pcnni( Plarrs and
['toccdulcs
Datc: .1r)/10 Rcvision: DUSA-2,]
Pagc 6 ol' l4
Part LC.3 of tho CWDP provides that discharge ol"other.compoutrds into the Mill's
tailings cells, such as paints, used oil, antifleeze, pqsticides, or any other oontarnioant not
defined as I Ie .(2) material is prohibited.
In the event ofany unauthorized disposal ofcontanrinants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific l.equiremonts
ofthe Executive Secletary as set forth in any noticq order, rernediation plan or the
equivalent, irnplernent the flol lowing prcce-ss:
4.1. Notifications
a) Upon discovery, the Mill Manager or RSO will be notified imrnediately; and
b) Derrison will plovide verbal notification to the Executive Secletary within 24
hours of discovery followed by a written norification within five day.s of
discovery.
4,2. field Activitiest
a) lJpon discovery, Mill personnel will irnrnediately cease placernent of
Unauthotized Matelials into the Mill's tailings cells;
b) 'fo the extent reasonably practicable and in a nlanner that can be accornplished
safely, Mill personnel will atternpt to segregate the Unauthorized Materials frorn
other tailings rnatelials and nrark or rccord the location ofthe Unauthorized
Materials in the tailings cells. If it is not reasonably practicable to safely
segregatc the Unauthorized Material frorn other tailings rnatelials, Mill personnel
will neveltheless mark or record the location of the ljnauthorized Materials in the
tailings cells;
c) 'fo the extent reasonably placticable and in a lnanner that can be accornplished
saf'ely, Mill personnel will attempt to rernove the Unautholized Material fi.om the
tailings cells; arrd
d) Denison will dispose of the Unauthorized Material under applicable State and
Fedelal regulations.
4.3. Recluest for Approvals and/or Wqivcrs
Il it is not reasonably practicable to safely rrcmove the Unauthorized Materials fiorn the
tailings cells, then Denison will:
White Mesa Mill* Slandard
Opcr'atirrg l,roccdurr:s
[]ook /l l9 * (iroulldwatcr
I)ischargc [)crrnit l'lans tnd
Pr <lcodrrrcs
Dalc: l9_/10 Revision: DUSA-Z,]
[>agc 7 of l4
Submit a written report to the Executive Secretary altalyzing the health, safety
and envilorlrnental irnpacts, if any, associated with the permanent disposal ofl the
Unauthorized Material in the Mill's tailings cells;
Apply to the Executive Secretary fol any atnendments that rnay be required to the
CWDP and the Radioactive Materials License to ploperly accornmodate the
perrnanent disposal of the Unauthorized Material in the Mill's tailings cells in a
nlannel that is protective ofhealth, safety and the environment; and
Make all applications required under the United States Nuclear llcgularory
Comrnission's ("NI{C's") Non-t le.(2) Disposal Policy, including obtaining
appl'oval of the Department of Energy as the long teun custodian of the Mill's
tailings, in order to obtain appl'oval to per$ancntly dispose of the Unauthorized
Material in the Mill's tailings cells.
DMT VIOLA'I'IONS
Tailing$..9sl Wastewater P.q9l--Elevation Above the Maxirnurrl.Elcvationi
Pam I.D.2 and Palt I.D.6.d) of the CWDP provide that authorized oper.ation and
tnaxirnum disposal capacity in each olthe existing tailings cells shali not excced the
levels authorized by the lladioactivc Matclials [,icense and that under no cilcurnstances
shall the fleeboard be less than three f'eet, as measurcd fi'orn thc top of the flexible
membrarre liner ("FML").
In the event that taitings cell wastewater pool elevation in any tailings cell exceeds the
rnaxirnurn elevations mandated by Part I.D.2 and Part I.D.6.d) of the GWDP, Denison
will, subject to any specific requirernents oflthe Executive Secretary as set forth in any
notice, order, remediation plan or the equivalent, inrplernent the Following pt.ocess:
a) Upon discovery, the Mill Manager or ltSO will be notified imrnediately;
t ) Denison will provide velbal notification to the Executive Secretary within 24
houls of cliscovcry lollowed l>y a written notification within five day.s of
discovely;
Upon discovely, Mill personnel will cease to discharge any further tailings to the
subject tailings cello until such tirne as adequate fi'eeboard capacity exists in thc
subjcct tailings cell fol the disposal ofthe tailings;
To the extent reasorably practicable, witlrout causing a violation of thc fi.eeboard
lirnit in any other tailings cell, Mitl pelsounel will pLornptly purnp fluids fi'orn the
subject tailings cell to anotlrer taitings cell until such tinre as the freeboard limit
for the subject tailings ccll is in cor"npliance. If there is no r.oorn available in
a)
b)
c)
5.
5. r.
c)
d)
Whitc Mcsl Mill - Standard
Opcratirrg l)roccdurcs
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I)isohargo l)cruit I)lans and
l)rcccdures
Datc: .i9l10 Revision: DUSA-7,1
Pagc 8 ol'l4
another tailings cell, without violating rhe fi'eeboald lirnit of such othcr cell, then,
as soorl as leasonably practicable, Mill per.sonnel will cease to discharge any
l'urther tailings to any tailings cell until such tilne as adequate fi.eeboard capacity
exists in all tailings cells;
If it is not reasonably practicable to pulnp sufficient .solutions fi.orn the subject
tailings cell ro another tailings cell, then the solution Ievcls in the subject tailings
cell will be reduced through natur.al evaporalion; and
Denison will pcrfolrn a root cause analysis of tlre excee<lance and will irnplement
new procedures or change cxisting procedures to mininrize thc chance ofa
l'ecuIIonce.
5.2, Excess Flead in .Iailinss Cells 2.,.:) and 4A glirncs Drain System.:
Part LD.3.b)l) of the GWDP provides that Deni.son .shall at all times maintairr the average
wastewatcl head in the slirnes drain access llipe in cell 2 to be as low as reasonably
achievable, in accordance with ihe Mill's currently approved DMT Monitoring plan , ancl
that for Cell 3, this leguirernent shall apply onty after initiation of de-watering operations.
Sirnilarly, Part LD.6,c) of the GWDP provides that al'tel I)enison initiates pun.'ping
conditions in the slinres dlain layer in Cell 44, Dcnison will provicle: l) continuous
declining lluid heads in the slirnes drain laycr, irr a rlanncr equivalent to the requirernent.s
Ibund in Palt LD.3.b); and 2) a rnaxirrum head of 1.0 lbet in the tailings (as rneasured
fi'orn the lowest point of the upper FML) in 6.4 years or less.
In the event that the average wastewater'head in the slirnes dtain access pipe for Cell 2 or,
af,ter initiation of tle-watering activities, Cell 3 or initiation of purnping conditions in rhe
slirnes dlain layel in cell 4A exceeds the levels specified in the DMT Monitor.ing Plan,
Denison will, subject to any specific requirements of the Executive Secretary as set for.th
in any notice, order, rernediatiorr plan or the eguivalent, implernent the fbllowing process:
a) Upon disoovely, the Mill Manager or IISO will be notified irnmediately;
b) Mill personnel will promptly punrp the excess fluicl into an active tailings cell, or
other appropriate containrnent ol evaporalion facility approved by the Exccutive
Secretary;
c) If theexceedance is theresult of equiplnent f'ailure, Mill pelsonnet will attenrpt
to repail ol' rcplace the equillncnt;
d) Iflthe cause of the exceedance is not rectified within 24 hours, Denison will
plovide verbal notification to the Executive Secreta.y within thc ensuing 24
hours followed by a wr,itten notification within five days; and
e)
Whits Mcsa Mill - Slandard
Operating Proccdures
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I)ischargc l)ctrrrit Plaos aud
l)roccclules
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l'rtgc 9 ol l4
e) If not due to an identified equipment failure, Denison will perfolm a root cause
analysis of the exceedar)ce atrd will irnplernent new procedules or change
existing procedules to rninirnize the chance ol'a recurrence.
5.3. Elqegq.Cg!l4A Leak Detection System Fluid Head oL Dailv Leak Rate
Part LD.6.a) pr<lvides that the fluid head in tlre Leak Detection Systern (*LDS") for Cell
44. shall not exceect I foot above the lowest poillt in the lower membrane liner, and Pad
LD.6.b) of the GWDP plovides that the maximum allowable daily leak rate measured in
the LDS fol Cell 44' shall not excoed 24,160 gallons/day.
In the event that the fluid head in the LDS for Cell 4A exceeds I foot above the lowest
point in the lower rnemblarre layel or the daily leak rate measuted irr the Cell 4A LDS
exceeds 24,160 gallons/day, Denison will, subject to any specific requirernents ofthe
Executive Sccretary as set forth in any notice, order, renrediation plan or the equivalent,
i nrplernent lhe following process:
Upon discovely, the Mill Manager or ttSO will be notified imrnediately;
Mill personnel will plornptly purnp the excess fluid into an active tailirrgs cell, ot'
othel appropriate containnrent or evaporation l'acility approved by the Executive
Secretary, until such tirne as tho cause ofexceedance is rectified or untiI such
time as otherwi.se directed by the Executive Secretary;
If the exceedance is the result of equipment failure, Mill personnel will atte tnpt
to repair ol replace the equiprnent;
If the cause ofthe exceedance is not rectified within 24 houls, Denison will
provide velbal notification to the Executive Secretary within the ensuing 24
hours I'ollowed by a written notification within five days; and
If not due to an identified equiprnent fhilurc, Denison will peLfbrm a l'oot cause
analysis of the exceedance and will irnplernerrt rrew procedures or change
existing procedules to lerne diatc the exceedance and to rninitniec the chance ofl a
IecuI[ence.
Excess Neg"[)..99--oI!autinati-qn-P-ad L.eak Detection.S\isJ.9m.Iluid Hcad
In order to en-sure that the plirnary contaiumcnt of the New f)ecorrtamittation Pad water
collection systern has not been cornprornised, and to plovide an inspection capability to
detect leakage fi'om the plirnary containment in each oIthe thlee settling tanks, a vertical
inspection portal has bcen installed between the plirnary and sccondaly containrnent of
each settling tank.
a)
b)
c)
d)
e)
5.4,
I Wlitc Mcsa Mill - Shndud Drtc: 39/10 Rcvision: DUSA+I
Operating Procedures
Book # 19 - Croundwater Page l0 of t4
Discharge Pcrmit Plans and
Procedures
Section 3.1(e) of the Mill's DMT Monitoring Plan providcs that the fluid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete floor in
any ofthc three standpipes.
In the event that the fluid hcad in the standpipe for a settling tank cxceeds 0. l0 feet above
the concrete floor in the standpipe, Denison will, subject to any specific rcquiremcnts of
the Executive Secretary as set forth in any notice, order, remcdiation plan or the
equivalcnt, implement thc following process:
a) Upon discovery, thc Mill Manager or RSO will be notilied immediately;
b) Denison will provide verbal notification to the Executive Secretary within the
ensuing 24 hours followed by a written notification within five days;
c) Mill personnel will promptly pump the fluid from the satling tank's LDS as well
as the fluids in the scttling tank into another settling tank or into an active tailings
cell, or other appropriate containment or cvaporation facility approved by the
Executive Secretary, until such time as the cause ofthe exceedance is rectified or
until such time as otherwise directed by the Executive Secretary; and
d) Denison will perform a root cause analysis of the exceedance and, if appropriate,
will implement new procedures or change existing procedures to remediate the
exceedance and to minimize the chance of a recurrence.
5.5. Cracks or Physical Discreoancies on the New Decontamination pad Wash pad.
In the event that cracks or other physical discrepancies are observed on the concrete wash
pad. Denison will. subject to any specific reqgirements ofthe Executive Secretary as set
forth in any notice. order. remediation plan or the equivalent. implement the following
process:
aI Upon discovery"the Mill Manager or RSO will be notified immediately:
b) lhe EDP shall be taken out of service and the cracks or deficiencies will be
repaired utilizing industry slandard materials and plocedures aporopriate for the
defect, Following recommended cure times. the cracks or deficiencies will be re-
Urspgq!e,_d_.and. if aSqgpfaile,lhs EDP will bs placed back into ;qvi!s.
c) A rccord of the reoairs will be maintained as a part of the inspgction records at
the White Mesa Mill.
$*5.6. Excess Elevation For Tailines Solids
Whitc Mesil Mill * Standard
Olrcrating l)roccdurcs
tlook Il l9 - Croundwater
I)ischarge Pcnnit I,larls and
Pr<rccdurcs
Dntc: 39/10 Rcvision: DUSA.a..l
I,agcllof14
Part I.D.3.c) of the GWDP provides that upon ctosure of any tailings cell, Derrison shall
ensuro that the maxinturn elevation ofthe tailings waste solids does not exceed the top of
tho FML.
hr the event that, upon closur'e of any tailings cell, the maxirnum slevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secletary as set forth in any notice, or.dei, rernediation plan
ol'the equivalent, irnplement the following t)locess:
a) Upon discovely, the Mill Manager or RSO will be notified irnmecliately;
b) Denison witl providc velbal notification to rhe Executive Secr-etary within 24
hours of discovery followed by a wr.itten notification within five clays of
discovely;
To the extent reasonably practicablq without causing a violation of the frEeboalcl
linrit in any other tailings csll, Mill personnel will prorrrptly rtrrlovc tailing.s
solids frorn the subject tailings cell to another tailings cell, or.other location
approvcd by tlre Executive secretary, untiI such time as the rnaxirnum elevation
ofl the tailings waste solids in the sub.iect taitings cell does not cxceed the top of
the FML; and
Denison will perform a root cause analysis ol'the exceedance and will irnplement
new procedures or change existing procedures to minimize the chance ofa
l'ecurTence.
1i,6,5,7,-Roberts Pond Wastewate!:_[ilevation
Pat I.D.3.e) of the GWDP prnvides that the Pelmittee shall operate Robelts Pontl so as to
provide a tninimurn 2-foot fleeboalcl at all tirnes ancl that under no circunrstances shall
the watet level in Robert.s Pond exceed an elevation of 5,624lbet above mean sea lcvel.
Irr the event that the wastewatel elevation exceeds this rnaximum level, Denison shall
remove the excess wastewater and place it into containment in 'tailings Cell I within 72
hours of discovery, as specified in Part I.D.3.e) of the GWDp.
In the evenl that, Denison I'ails to,so rernovc any such excess wastewater, Denison will,
subject to any specific requiretnents of the Executive Secretary as set forth in any notice,
order, remediation plan or thc equivaletrt, irnplement the following pr.ocess:
a) Upo. discovery, rhe Mill Manager or RSO will be notified irnneciiately; and
c)
d)
Whitc Mcsa Mill - Standard
Opcrating I)roccdurcs
B<tok ll l9 - (iroundwatcr'
l)ischargc l'cnnit l)lans and
Proccdur cs
t u,., ;r.1/10Ilcvision: DIJSA-21
l'agc 12 of'14
b) Denison will provide vofbal notification to the Executive Secletary within 24
lrours of discovet'y followed by a wlitten notitlcation and proposed col'rective
actions within five days of discovery.
5'jl'-5.,!.,. [:eedstock Storage Area
Part I.D.3.fl) and Part I.D.l 1 oF the CWDP provide that open-air. or bulk sroragc ofl all
feedstock rnaterials at tlre Mill lacility awaiting Mill processing shall be limited to the
eastern portion ol'the Mill site al'ea described in -fable 4 of the GWDP, and that storage
ol'feedstock rnatelials at the facility outside that alea shall be perflot'tned in accoldance
with the plovisions of Part I.D. I t of the GWDP.
In tlre event that, storage of any feedstock at the Mill is not in cornpliancc with the
requirements specified in l,art LD.3,l) and Part LD.l I of the GWDP, Denison will,
subject to any specific requirements olthe Executive Secretary as set lorth in any notice,
ofder, renlediatiorr plan or the equivalent, implenrerrt the following processi
a) Upon di.scovery, the Miti Manager or RSO will be noritjcd inrrnediately;
b) Donison will provide vcrbal notification to the Executive Sccr.etary within 24
hours of discovery followed by a wr.itten notification within five days of
discovery;
c) Millpersonnel will:
(i) move any open-ail or bulk stored feedstock materials to the pofiion o[the
Mill site area desclibed in'l'able 4 of the CWDP;(ii) ensure that any l'eedstock rnaterials that are stoled outside olths area
desclibed in'l'able 4 olthe GWDP ar.e stored and nraintained in
accordance with the plovisions of Part I.D.1t of ths GWDP; and(iii) to the extent that any such containcrs are obsel.ved to be lcaking, such
lcaking cot)tainers will be placed into watertight over-pack containers or
otherwise dealt with in accor-dance with the pr.ovisions of Part I.D.1 t of
the GWDP, and any inrpacted soils will be rentoved and will be deposited
into the Mill's active tailings cell; and
d) f)enison will pelfolm a root cause analysis of the non-cornpliant activity and will
irnplernent new plocedures ot changc cxistirrg plocedules to rninirnize tlre chauce
of a recurrence.
5.ti'5.t). Mill .$it"g Cl.hernical Reagent glqraqe
I'}alt I.D.3.g) ol'the GWDP provides that for all chernical reagenrs stol.ed at existing
storage facilities, Denison shall provide secondaly containrnent to capture and contain all
Whitc Mcsa Mill- Standard
Olrcrating Procodurcs
llook /l t9 * Croundwater
Dischargu Pcrrnit Plans ancl
l'roccdtncs
Datc: 11/10 Rcvision: DIJSA-?,3
Pagc l3 of'14
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction ofleagent $torago facilities, the secondary containtn€nt and control
shall prevant any contact ofthe spitled reagent with the ground surface.
In the event tlrat Denison does not provide the rrquirc'tl secondary containment required
under Part I.D.3.g) of the GWDP, Denison will, subject to any specific requirernents of
the Executive Secretary as set forth in any notice, order', r'ernediation plan or the
equivalent, i rnplement the fol lowing process:
a) Upon discovery, the Mill Managel or RSO will be notified irnrnediately;
b) Denison will providc velbal notification to the Executive Secretary witlrin 24
hours of discovely followed by a written notification within five days of
discovely; and
c) Denison will prornptly remediate any spilled re-agent resulting fi'orn the failure to
provide the required secondary containfient under Part Ltl.3.g) of the GWDP, by
rernoval ofthe contaminated soil and disposal in the active tailings cell,
5'9':i. 10. [ailure to Construct ?s,l)pJApprpy.Al.
Parl LD.4 ofl the CWDI' prtvides that any collstruction, rnodification, or olteration of new
waste or wastewater di.sposal, tleatrnent, or storage facilitics shall require subrnittal of
engineering design plans and specifications, and prior Executive Secrctaly review and
approval, and that a Construction Perrnit rnay be issued.
In tlre event tlrat, any new waste or wastewater disposal, tlcatment, or stot'age facilities
alc cotrstructed at the Mill facility without obtaining prior Executive Secretary rcview
and approval, or any such lhcilities aro not constl'ucted in accordance with the plovisiorrs
of any applicable Consh'uction Pelmit, Derrison will, subject to any specific lequirernents
of the Executive Secretaty as sef forth in any notice, order, r'emediation plan or.the
equi valent, i rnplernent the fol lowin g process:
a) [Jpon discovery, the Mill Managel or RSO will be notified immediately; and
b) Dcnison will pLovide verbal notification to the Executive Secretary within 24
hours ofdiscovery followed by a written notification and proposed corrective
actions within five days of cliscovery.
.i.10,5..1_1. ._ Failure to Cornply with Stolfi]WAtel:Marla,rcrlen! and Spilt Conrrol
I(erluirements
White Mcsa Mill - Standard
Opcr'atirrg l)toccdur r.:s
llook il l9 - Croundrvatct
l)ischarge Pelrnit Plans alld
l)roccdurcs
Datc: i1)/10 Revision: DUSA-3]
Pagc [4 ol'[4
Part l.D.l0 of the GWDP ptovide$ that Denison will manage all contact and non-contact
storD'rwator and conh'ol cotltatninant spills at the Mill facility in accordanco with the
cul'rently approved Stormwater Best Managernent Practices Plan.
In the event that any contact or non-contact stormwater ot corrtalninarlt spills are not
lnanaged in accordance with the Mill's approved Stonnwater Best Managernenl Practices
Plan, Deni.son will, subject to any specific requirernents of the Executive Secretal'y as set
forth in any notice, order, rernediatiorr plan or the equivalent, itnpletnent the following
procgss;
a)
1r)
c)
Upon discovery, the Mill Manager oI RSO will bc notifictl irnmediately;
Denison will provide verbal notification to the Executive Secretary within 24
hours ofdiscovery followed by a written notification and proposed corrective
actions within five days of discovct'y; and
'Io the extent still placticable at th€ time olcliscovery, f)enison will manage any
such contarninant spill in accordance with the Mill's approved Storrnwater Best
Management Plactices Plan. '[o the extent it is no longor practicable to so
lnallago any such spill, f)enison will agree with thc Executive Secretary on
appropriate clean up and other meafiufes,
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Required Under Part I.H.16
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver CO 80265
October 12,2007
Page
No.
31.
TABLE OF CONTENTS
INTRODUCTION
PURPOSE
GROUNDWATER CONTAMINATION
Notification
Continuation of Accelerated Monitoring
Submission of Plan and Timetable
Groundwater Remediation Plan
MILL DISCHARGE VIOLATIONS - INCLUDING
.,
3.
3.1.
3.2.
3.3.
3.4.
4.
J
4
4
4
5
6
6
6
7
7
8
8
9
9
10
11
11
UNAUTHORIZED DISCHARGE OR RELEASE OF PROHIBITED
CONTAMINANTS TO THE TAILING CELLS
4.1. Notifications
4.2. Field Activities
4.3. Request for Approvals and/or Waivers
5. DMT VIOLATIONS
5.1. Tailings Cell Wastewater Pool Elevation Above the Maximum
Elevations
5.2. Excess Head in Tailings Cells 2 and 3 Slimes Drain Systems
5.3. Excess Elevation For Tailings Solids
5.4. Roberts Pond Wastewater Elevation
5.5. Feedstock Storage Area
5.6. Mill Site Chemical Reagent Storage
5.7. Failure to Construct as per Approval
5.8. Failure to Comply with Stormwater Management and Spill Control
Requirements
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No. UGW370004
1. INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No. UGW370004 (the
"GWDP") for Denison Mines (USA) Corp.'s ("Denison's") White Mesa Uranium Mill
(the "Mill"). The GWDP specifies the construction, operation, and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into groundwater.
)PURPOSE
This Contingency Plan (the "PIan") provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology ("DMT")
requirements defined in Parts I.C and I.D of the GWDP. The timely execution of
contingency and corective actions outlined in this Plan will provide Denison with the
basis to exercise the Affirmative Action Defense provision in Part LG.3.c) of the GWDP
and thereby avoid noncompliance status and potential enforcement actionl.
The contingency actions required to regain compliance with GWDP limits and DMT
requirements defined in Parts I.C and I.D of the GWDP are described below.
3. GROUNDWATER CONTAMINATION
Since there are many different possible scenarios that could potentially give rise to
groundwater contamination, and since the development and implementation of a
remediation program will normally be specific to each particular scenario, this Plan does
not outline a definitive remediation program. Rather, this Plan describes the steps that
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well, pursuant to PartI.G.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance, Denison will, subject to specific requirements of the Executive Secretary as
set forth in any notice, order, remediation plan or the equivalent, implement the following
process:
t Part I.C.3.c) of the GWDP provides that, in the event a compliance action is initiated against Denison for
violation of permit conditions relating to best available technology or DMT, Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications, that the failure was
not intentional or caused by Denison's negligence, that Denison has taken adequate measures to meet
permit conditions in a timely manner or has submitted an adequate plan and schedule for meeting permit
conditions, and that the provisions of UCA 19-5-107 have not been violated.
3.1. Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection, as required under Part I.G.4.a) of the GWDP.
3.2. Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part I.G.1 of the GWDP, unless the Executive Secretary
determines that other periodic sampling is appropriate, until the facility is brought into
compliance, as required under Part I.G.4.b) of the GWDP.
If the accelerated monitoring demonstrates that the Mill is no longer out of compliance
with respect to a parameter in a well, then, with the written approval of the Executive
Secretary, Denison will cease accelerated monitoring for the parameter, and no further
steps will be followed by Denison with respect to such parameter.
3.3. Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well, then, within 30 days of such confirmation, Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources, extent and potential dispersion of the contamination, and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT will
be reestablished, as required under part I.G.4.c) of the GWDP. This plan will normally
include:
The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
A requirement for Denison to complete an evaluation, which may include
geochemical and hydrogeological analyses, to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will prepare a Characterization Report, which characterizes
the physical, chemical, and radiological extent of the ground water
contamination. This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone, the analytical parameters to be obtained, the
a)
b)
c)
samples of ground water to be taken, and any other means to measure and
characterize the affected ground water and contamination zone; and
d) If it is concluded that the contamination is the result of current or past activities
at the Mill, Denison will evaluate potential remedial actions, including actions to
restore and maintain groundwater quality to ensure that permit limits will not be
exceeded at the compliance monitoring point and that DMT will be reestablished,
as well as actions that merely allow natural attenuation to operate and actions that
involve applying for Alternate Concentration Limits ("ACLs"). If groundwater
remediation is required, Denison will prepare and submit to the Executive
Secretary a Ground Water Remediation Plan, as described in Section 3.4 below.
3.4. Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed, Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary. The Ground Water Remediation Plan will
normally include:
a) A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s) or other locations approved
by the Executive Secretary, by removing the contaminants, treating them in
place, or by other means as approved by the Executive Secretary;
b) A description of the remediation monitoring program to demonstrate the
effectiveness ofthe plan; and
c) Descriptions of how corrective action will apply to each source of the pollution.
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4. MILL DISCHARGE VIOLATIONS - INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
Part I.C.2. of the GWDP provides that only lle.(2) by-product material authorized by the
Mill's State of Utah Radioactive Materials License No. UT-2300478 (the "Radioactive
Materials License") shall be discharged to or disposed of in the Mill's tailings cells.
Part I.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells, such as paints, used oil, antifreeze, pesticides, or any other contaminant not
defined as l1e.(2) material is prohibited.
ln the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials") to the Mill's tailings cells, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
4.1. Notifications
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within24
hours of discovery followed by a written notification within five days of
discovery.
4.2. Field Activities
a) Upon discovery, Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Marerials in the tailings cells. If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials, Mill personnel
will nevertheless mark or record the location of the Unauthorized Materials in the
tailings cells;
c) To the extent reasonably practicable and in a manner that can be accomplished
safely, Mill personnel will attempt to remove the Unauthorized Material from the
tailings cells; and
d) Denison will dispose of the Unauthorized Material under applicable State and
Federal regulations.
4.3. Reouest for Anorovals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells, then Denison will:
a) Submit a written report to the Executive Secretary analyzing the health, safety
and environmental impacts, if any, associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b) Apply to the Executive Secretary for any amendments that may be required to the
GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health, safety and the environment; and
6
c) Make all applications required under the United States Nuclear Regulatory
Commission's ("NRC's") Non-I le.(2) Disposal Policy, including obtaining
approval of the Department of Energy as the long term custodian of the Mill's
tailings, in order to obtain approval to permanently dispose of the Unauthorized
Material in the Mill's tailings cells.
5. DMT VIOLATIONS
5.1. Tailinss Cell Wastewater Pool Elevation Above the Maximum Elevations
Partl.D.2 of the GWDP provides that authorized operation and maximum disposal
capacity in each of the existing tailings cells shall not exceed the levels authorized by the
Radioactive Materials License and that under no circumstances shall the freeboard be less
than three feet, as measured from the top of the flexible membrane liner ("FML").
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part 1.D.2 of the GWDP, Denison will, subject to any
specific requirements of the Executive Secretary as set forth in any notice, order,
remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
Upon discovery, Mill personnel will cease to discharge any further tailings to the
subject tailings cell, until such time as adequate freeboard capacity exists in the
subject tailings cell for the disposal of the tailings;
To the extent reasonably practicable, without causing a violation of the freeboard
Iimit in any other tailings cell, Mill personnel will promptly pump fluids from the
subject tailings cell to another tailings cell until such time as the freeboard limit
for the subject tailings cell is in compliance. If there is no room available in
another tailings cell, without violating the freeboard limit of such other cell, then,
as soon as reasonably practicable, Mill personnel will cease to discharge any
further tailings to any tailings cell until such time as adequate freeboard capacity
exists in all tailings cells;
If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell, then the solution levels in the subject tailings
cell will be reduced through natural evaporation; and
c)
d)
e)
0 Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurrence.
5.2. Excess Head in Tailings Cells 2 and 3 Slimes Drain Systems
Part I.D.3.b)1) of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable, in accordance with a DMT Monitoring Plan approved by the Executive
Secretary pursuant to Part I.H.13 of the GWDP, and that for Cell 3, this requirement shall
apply only after initiation of de-watering operations.
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
after initiation of de-watering activities, Cell 3 exceeds the levels specified in the DMT
Monitoring Plan, Denison will, subject to any specific requirements of the Executive
Secretary as set forth in any notice, order, remediation plan or the equivalent, implement
the following process:
a)
b)
c)
d)
e)
Upon discovery, the Mill Manager or RSO will be notified immediately;
Mill personnel will promptly pump the excess fluid into an active tailings cell, or
other appropriate containment or evaporation facility approved by the Executive
Secretary;
If the exceedance is the result of equipment failure, Mill personnel will attempt
to repair or replace the equipment;
If the cause of the exceedance is not rectified within 24 hours, Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days; and
If not due to an identified equipment failure, Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.
Excess Elevation For Tailings Solids5.3.
Part I.D.3 b)2) of the GWDP provides that upon closure of any tailings cell, Denison
shall ensure that the maximum elevation of the tailings waste solids does not exceed the
top of the FML.
In the event that, upon closure of any tailings cell, the maximum elevation of the tailings
waste solids exceeds the top of the FML, Denison will, subject to any specific
requirements of the Executive Secretary as set forth in any notice, order, remediation plan
or the equivalent, implement the following process:
a)
b)
c)
Upon discovery, the Mill Manager or RSO will be notified immediately;
Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
To the extent reasonably practicable, without causing a violation of the freeboard
limit in any other tailings cell, Mill personnel will promptly remove tailings
solids from the subject tailings cell to another tailings cell, or other location
approved by the Executive Secretary, until such time as the maximum elevation
of the tailings waste solids in the subject tailings cell does not exceed the top of
the FML; and
Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recuffence.
Roberts Pond Wastewater Elevation
d)
5.4.
Part I.D.3 c) of the GWDP provides that the Permittee shall operate Roberts Pond so as to
provide a minimum 2-foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event that the wastewater elevation exceeds this maximum level, Denison shall
remove the excess wastewater and place it into containment in Tailings Cell I within 72
hours of discovery, as specified in Part I.D.3 c) of the GWDP.
In the event that, Denison fails to so remove any such excess wastewater, Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order, remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately; and
b) Denison will provide verbal notification to the Executive Secretary within24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
5.5. Feedstock Storage Area
Part I.D.3. d) of the GWDP provides that open-air or bulk storage of all feedstock
materials at the Mill facility awaiting Mill processing shall be limited to the eastern
portion of the Mill site area described in Table 4 of the GWDP, and that storage of
feedstock materials at the facility outside that area shall be performed and maintained
only in closed, water-tight containers.
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In the event that, storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part LD.3. d) of the GWDP, Denison will, subject to any
specific requirements of the Executive Secretary as set forth in any notice, order,
remediation plan or the equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within24
hours of discovery followed by a written notification within five days of
discovery;
c) Mill personnel will:
(i) move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
(ii) ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in closed,
water-ti ght containers ; and(iii) to the extent that any such containers are observed to be leaking, such
leaking containers will be placed into watertight over-pack containers,
and any impacted soils will be removed and will be deposited into the
Mill's active tailings cell; and
d) Denison will perform a root cause analysis of the non-compliant activity and will
implement new procedures or change existing procedures to minimize the chance
of a recurrence.
5.6. Mill Site Chemical Reasent Storage
Part I.D.3. e) of the GWDP provides that for all chemical reagents stored at existing
storage facilities, Denison shall provide secondary containment to capture and contain all
volumes of reagent(s) that might be released at any individual storage area, and that for
any new construction of reagent storage facilities, the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
In the event that Denison does not provide the required secondary containment required
under Part I.d.3. e) of the GWDP, Denison will, subject to any specific requirements of
the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a) Upon discovery, the Mill Manager or RSO will be notified immediately;
b) Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery; and
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c) Denison will promptly remediate any spilled re-agent resulting from the failure to
provide the required secondary containment under Part I.d.3.e) of the GWDP, by
removal of the contaminated soil and disposal in the active tailings cell.
5.7. Failure to Construct as per Approval
Part I.D.4 of the GWDP provides that any construction, modification, or operation of new
waste or wastewater disposal, treatment, or storage facilities shall require submittal of
engineering design plans and specifications, and prior Executive Secretary review and
approval, and that a Construction Permit may be issued.
In the event that, any new waste or wastewater disposal, treatment, or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval, or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit, Denison will, subject to any specific requirements
of the Executive Secretary as set forth in any notice, order, remediation plan or the
equivalent, implement the following process:
a)
b)
Upon discovery, the Mill Manager or RSO will be notified immediately; and
Denison will privide verbal notification to the Executive Secretary within24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery.
Failure to Comply_with Stormwater Management and Spill Control Requirements5.8.
Part I.D.8 of the GWDP provides that Denison will manage all contact and non-contact
stormwater and control contaminant spills at the Mill facility in accordance with an
approved Stormwater Best Management Practices Plan, pursuant to Part I.H.17 of the
GWDP.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan, Denison will, subject to any specific requirements of the Executive Secretary as set
forth in any notice, order, remediation plan or the equivalent, implement the following
process:
Upon discovery, the Mill Manager or RSO will be notified immediately;
Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days of discovery; and
To the extent still practicable at the time of discovery, Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan. To the extent it is no longer practicable to so
a)
b)
c)
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manage any such spill, Denison will agree with the Executive secretary on
appropriate clean up and other measures.