DRC-2015-002247 - 0901a068805240d1

DRC-2015-002247
Energy Fuels Resources
(USA) Inc.
WHITE MESA MILL
0 MWH
BUILDING A BETTER WORLD
3665 JFK Parkway
Suite 206
Fort Collins, CO USA
Tailings Characterization and
Analysis Work Plan
October 2013
MWH Tailings Characterization and Analysis Work Plan
TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Scope of Document 1
1.2 Project Background 1
1.3 Plan Objectives 2
2.0 TAILINGS INVESTIGATION 4
2.1 Program Overview 4
2.2 CPT Soundings 4
2.3 Direct Push Sampling 4
2.4 Field Documentation 5
2.5 Sample Handling and Shipping 6
2.6 Geotechnical Laboratory Testing 6
2.7 Sample Disposal 6
3.0 HEALTH AND SAFETY 10
3.1 Health and Safety Requirements 10
3.2 Protection of Tailings Liner System 10
3.3 Minimize Exposure of Radioactive Materials 10
4.0 TAILINGS DATA ANALYSIS REPORT 12
5.0 SCHEDULE 13
6.0 REFERENCES 14
LIST OF TABLES
Table 1 Proposed Laboratory Testing Schedule
LIST OF FIGURES
Figure 1 Regional Location Map
Figure 2 Proposed CPT Locations
Figure 3 Existing and Proposed Settlement Monitoring Points
LIST OF APPENDICES
Appendix A Sample Field Forms
Appendix B MWH Health and Safety Plan for Energy Fuels White Mesa Mill Tailings
Investigation
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MWH Tailings Characterization and Analysis Work Plan
1.0 INTRODUCTION
The Utah Division of Radiation Control (DRC) requested that Energy Fuels Resources (USA),
Inc. (EFRI) collect site-specific tailings data to supplement existing data used for technical
analyses in the White Mesa Reclamation Plan, Version 5.0 (Denison, 2011) and the Infiltration
and Contaminant Transport Modeling (ICTM) Report (MWH, 2010). This request was part of
DRC's February 2013 review comments (DRC, 2013a, b) on EFRI's August and September
2012 responses to DRC's Round 1 interrogatories for the White Mesa Reclamation Plan Rev.
5.0 and the ICTM Report (EFRI, 2012a, b).
1.1 Scope of Document
This document is the work plan for the tailings characterization of Cells 2 and 3 at the White
Mesa site to be conducted for EFRI to address DRC's request to collect site-specific tailings
data. This work plan has been prepared by MWH Americas, Inc. (MWH) at the request of EFRI.
The tasks outlined in this work plan will be conducted for EFRI by or under the direction of
MWH.
1.2 Project Background
The White Mesa Uranium Mill (Mill) is located in San Juan County in southeastern Utah,
approximately 6 miles south of Blanding, Utah. The site is located on White Mesa, a flat area
bounded on the east by Corral Canyon, to the west by Westwater Creek, and to the south by
Cottonwood Canyon. A site location map is shown in Figure 1. The Mill is located at an
elevation of 5,600 ft above mean sea level. EFRI facilities consist of a uranium processing mill
and five lined tailings/process solution storage cells located within an approximately 686-acre
restricted area. The tailings cells are located south of the Mill and comprise the following:
• Cell 1 - 55 acres, used for the evaporation of process solutions
• Cell 2-65 acres, used for storage of barren tailings sands (filled with tailings
sands and covered with interim cover)
• Cell 3-70 acres, used for storage of barren tailings sands (partially covered with
interim cover, continuing to receive tailings in the northeast corner of the cell)
• Cell 4A - 40 acres, used for storage of barren tailings sands and evaporation of
process solutions
• Cell 4B - 40 acres, currently being used for evaporation of process solutions
The Mill was initially licensed by the United States Nuclear Regulatory Commission (NRC) in
August 1979, and the tailings system was licensed in May 1980 under NRC Source Material
License No. SUA-1358. After the State of Utah became an Agreement State for uranium mills
in August 2004, the NRC license was replaced with the current State of Utah License (License)
and the Ground Water Discharge Permit (GWDP).
EFRI (formerly Denison Mines USA Corp.) submitted an application to DRC for License renewal
on February 27, 2007 and for renewal of the GWDP on September 2, 2009. Among the
documents submitted to DRC in support of the license and permit renewals the most recent
EFRI documents reviewed by DRC for the license renewal include the Reclamation Plan,
Revision 5.0 (Denison, 2011) and the ICTM Report (MWH, 2010). The ICTM Report was
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MWH Tailings Characterization and Analysis Work Plan
originally submitted in support of the GWDP renewal. DRC provided interrogatories for these
documents in March 2012 (DRC, 2012a, b) in regards to the license renewal. EFRI provided
responses to these interrogatories for the Reclamation Plan, Revision 5.0 in May and August
2012 (Denison, 2012a; EFRI, 2012a) and for the Revised ICTM Report in May and September
2012 (Denison, 2012b; EFRI, 2012b). DRC provided review comments on EFRI's August and
September 2012 responses in February 2013 (DRC, 2013a, b).
On April 30, 2013, EFRI, DRC, MWH, and URS Corporation (URS) met at URS' office in
Denver, CO to discuss specific issues identified in DRC's February 2013 review comments,
including DRC's request for site-specific tailings data. EFRI proposed a tailings investigation to
address the request for additional information and committed to provide DRC with a work plan
for the investigation. This work plan for the proposed tailings investigation incorporates
information provided to DRC during the April 30, 2013 meeting.
1.3 Plan Objectives
The objectives for the tailings characterization are listed below:
• Address the DRC request for site-specific tailings data
• Characterize the tailings to clarify the tailings stratigraphy and measure the
physical properties associated with tailings consolidation, settlement, and pore
water drainage
• Conduct tailings characterization with Cone Penetration Test (CPT) soundings,
direct push sampling, and geotechnical laboratory testing on selected
representative tailings samples
• Conduct the CPT soundings and sampling in areas of Cells 2 and 3 that are
accessible for exploration, and in a manner that does not damage the underlying
drainage and liner system in the cells
The results of this investigation will be used to update technical analyses to address DRC
review comments on the Reclamation Plan Revision 5.0 and the revised ICTM Report.
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REFERENCE:
ADAPTED FROM FIGURE 1-1 IN DENISON MINES (USA)
CORPORATION. 2011. RECLAMATION PLAN WHITE MESA MILL
BLANDING, UTAH. VERSION 5.0. SEPTEMBER.
ENERGY FUELS
PROJECT
WHITE MESA MILL TAILINGS CHARACTERIZATION
REGIONAL LOCATION MAP
Q MWH
DATE
MAY 2013 FIGURE 1
1009740 LOC MAP
MWH Tailings Characterization and Analysis Work Plan
2.0 TAILINGS INVESTIGATION
2.1 Program Overview
The tailings investigation program will include cone penetrometer test (CPT) soundings followed
by direct push sampling to confirm the CPT results and collect samples for geotechnical
laboratory testing. CPT is a relatively quick and efficient method for defining the subsurface
profile for the tailings cells. Direct push sampling allows for site-specific correlation of CPT
results, as well as sample collection for subsequent geotechnical laboratory testing.
The investigation will be conducted for Cells 2 and 3. The remaining cells (Cells 1, 4A and 4B)
cannot be accessed with the CPT rig. Cell 1 and 4B contain process solutions only and Cell 4A
receives tailings and process solution across the entire cell. In addition, there is a small area in
the center of Cell 3 that is currently receiving tailings and cannot be accessed with a CPT rig.
2.2 CPT Soundings
Seven CPT soundings will be conducted at locations adjacent to select settlement monuments
in both Cell 2 and Cell 3. Figure 2 shows the proposed CPT locations. These locations were
selected to represent the range of materials across the cells. The thickness of tailings and
interim cover, as well as settlement monitoring results, was evaluated as part of selection of the
CPT sounding locations. The inaccessible area within Cell 3 that is currently receiving tailings is
in the area where the settlement monuments are listed as proposed on Figure 3.
A track-mounted CPT rig will be used to advance the CPT probe into the tailings. The
equipment will have the capability to measure cone resistance, sleeve friction, dynamic pore
pressures, and in-situ shear wave velocity of the tailings. Equipment will include the CPT rig
and one support vehicle.
The CPT probe will be advanced into the subsurface vertically at a constant rate to obtain a
continuous profile of the tailings at each location. If the CPT probe encounters refusal prior to
termination of the push, the rig will be moved approximately 5 feet and the CPT probe will be
advanced again until the anticipated depth at that location is reached. Maximum acceptable
probe depths are shown on Figure 2 and discussed in Section 3.2. Cone resistance, sleeve
friction, and dynamic pore pressure measurements will be made at 8-inch maximum intervals
during continuous pushing. Pore pressure dissipation tests will be performed to estimate water
levels and pore pressure dissipation rates near bottoms of soundings where saturated
conditions are encountered. Shear wave velocity measurements will be performed using
seismic CPT at 5-foot intervals at each CPT sounding location. It is anticipated that much of the
hole created during CPT soundings will cave upon retraction of the probe. Upon completion of
the CPT soundings, any remaining open hole that has not caved will be backfilled using
bentonite pellets from the ground surface and hydrated.
2.3 Direct Push Sampling
Direct push sampling will be completed after CPT soundings. Two locations per tailings cell
(four total) will be selected during the field program based on the results of the CPT soundings.
The sampling locations will be selected to span the range of material responses (e.g. pore
pressures, soil behavior types) measured during CPT testing. Samples depths will be selected
based on the CPT results and are anticipated to have an average frequency of one sample per
5 feet of depth.
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MWH Tailings Characterization and Analysis Work Plan
Piston-type samplers will be used to collect relatively undisturbed samples without generating
soil cuttings. The direct push samplers will be deployed from the CPT rig. Figure 4 depicts
how the samples are collected. The soil sampler is initially pushed in a "closed" position to the
desired sampling interval. The inner cone tip portion of the sampler is then retracted
(approximately 12-18 inches, depending on the sampler) leaving a hollow sampler with an inner
liner containing soil sample tubes (1 -1.5 inches in diameter). The hollow sampler is then
pushed in a locked "open" position to collect a soil sample. The filled sampler and push rods
are then retrieved to the ground surface.
Each sample will be assigned a designation based on the tailings cell number, site location,
identification number and the depth interval. The sample designation, date, and time will be
recorded on the sample tube. It is anticipated that much of the hole created during direct-push
sampling will cave upon retraction of the sampling equipment. Upon completion of direct push
sampling, any remaining open hole that has not caved will be backfilled using bentonite pellets
from the ground surface and hydrated.
The direct push sampling will be used to provide site-specific correlation of CPT results (e.g.
material types, density, fines content). Geotechnical laboratory testing will be conducted on
selected samples.
2.4 Field Documentation
Observations and documentation of field activities will be entered into field logbooks and on
project-specific field forms. Field forms applicable to this project include a Tailgate Safety
Meeting Form and Subsurface Exploration Log. Sample field forms for direct push sampling are
provided in Appendix A. The field logbook will be maintained throughout all field activities and
will be a weatherproof, bound survey-type book, with non-removable, consecutively numbered
pages. All data generated during the investigation and any deviations from the work plan will be
recorded in detail in the field logbook. All field documentation shall be accurate, legible and
written in indelible black or blue ink. Incorrect entries in the field books, logs, or on forms that
need to be deleted will be crossed out with one line, initialed, and dated. At a minimum, the
date, weather conditions, personnel on site, type of activities performed, and any unusual
conditions encountered during the investigation will be recorded in the logbook.
A detailed sampling log will be recorded for each direct push location. Field logs of CPT
soundings will be obtained electronically in real time during soundings. The log will record an
approximate location and depth (0.2 foot accuracy) of the direct push location. The log will
document tip and sleeve resistances, pore pressures, and other measured parameters at a
maximum depth interval of no more than 8 inches. In addition, the logs will contain
interpretations of CPT measurements using published correlations (e.g. for soil behavior type) to
aid in selecting direct push sampling locations.
Photographs will be taken as necessary to supplement written descriptions of field activities
entered in the field logbook and on field forms.
Each CPT and direct push sampling location will be marked using a wooden lath labeled with
the corresponding location identification number. At the completion this investigation, locations
will be surveyed by EFRI.
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2.5 Sample Handling and Shipping
Each sample tube will have the end caps secured with wax. The sealed sampling tubes will
then be wrapped in multiple layers of bubble wrap and placed in a (vertical axial orientation, i.e.
upright) in a 5-gallon bucketcontaining sufficient packing materials in order to limit the shifting of
the samples while in transit to the geotechnical laboratory.
The samples will be shipped to eone of the laboratories listed below. Both laboratories have a
radioactive materials license for testing of uranium mill tailings samples. The final laboratory will
be selected by October 18, 2013. The geotechnical laboratory address, phone number, and the
laboratory contact for each lab are:
Ms. Chanley Morgan
Geotechnical Laboratory Manager
CB&I Federal Services, LLC
304 Directors Drive
Knoxville, TN 37923
[phone]
Mr. N. Randy Rainwater
Laboratory Department Manager
S&ME 1413 Topside Road
Louisville, TN 37777
[phone]
2.6 Geotechnical Laboratory Testing
The geotechnical laboratory sampling program has been developed to provide sufficient
numbers and quantities of samples for anticipated future testing for the parameters identified in
Table 1. Laboratory testing will be conducted according to applicable ASTM standards. This
schedule will be updated based on review of actual samples collected.
Table 1 Proposed Geotechnical Laboratory Testing Schedule
Geotechnical Laboratory Test
Estimated
No. of Tests ASTM Standard
Natural Moisture Content and Density 24 ASTM D2216 and D2937
Particle Size (sieve and hydrometer) 12 ASTM D422
Particle Size (sieve and No. 200 wash) 12 ASTM D6913
Specific Gravity ASTM D854
Atterberg Limits 10 ASTM D4318
Permeability Test ASTM D5084
Consolidation Test ASTM D2435
2.7 Sample Disposal
After completion of the geotechnical laboratory testing, the tailings samples will be returned to
the Mill for disposal in the tailings cells.
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CELL 1
A2W4-N
LX(22.9) A A2W5-N
"(27 8)
A2E1-N
"(25.4) 2W3
(21.7) A 2W6-N
"(24 3) A A2W1
"(7 7.8) 2W2
(20.4)
APPROXIMATE EXTENT OF CELL (TYP) A 2W7-N
"(27 0) CELL 2
A A 2W4-C
A 2W5 2E1 ^2W3 30 . 3 ^,2W6 •21 0,164,000
A A 2W7
iAi2W4 ^2W5 A2.!1 :2J
A A
25 2W6 8N 29 A 2W7 A3 7N
(13
A 6N
AfJ, 2S '76 A.3 SC
A3 7C
A 3-4N
|27
A3 BS A3 3N A 7S
A3 2N
f-3 CELL
A3 A3 3C
A 2C
33
A A3 3S
23
A3 2S
A
CELL 4B
CELL 4A
N 10.162.000
LEGEND
GROUND SURFACE CONTOUR AND ELEVATION
"ROM 2012 LIDAR SURVEY. FEET
EXISTING SETTLEMENT MONITORING POINT A 2W7-S
^ (24 4) MAXIMUM CPT PROBE DEPTH (MINIMUM
BUFFER ABOVE LINER OF 3 AND 5 FEET
-OR CELLS 2 AND 3, RESPECTIVELY)
=ROPOSED CPT SOUNDING
APPROXIMATE SUMP AND DRAIN
ACCESS LOCATION
NOTE:
JEPTH OF TAILINGS AND INTERIM COVER IS
CALCULATED FROM JULY, 2012 TOPOGRAPHY AND
AS-BUILT EXCAVATION DRAWINGS FOR CELLS 2
AND 3 (D'APPOLONIA, 1982; ENERGY FUELS, 1983)
PROJECT LOCATION DESIGNED SY y. DAWS BLANDING. UTAH
Q MWH DRAWN BY A. MIRANDA 05-3 PROJECT *00 FT • 200
CONTOUR INTERVAL = 2 FEET CHECKED BY C. 5TRACHAN 05-13 ENERGY FUELS - WHITE MESA fif Energy Fuels Resources (USA) Inc APPROVED BY
PROJECT MANAGER TITLE -EVUCN FIGURE 2 CLIENT APPROVAL PROPOSED CPT LOCATIONS - ILE NAME
1009740 CPT
DATE
MAY 2013 CLIENT REFERENCE NO I0U9/4C
CELL 1
A2W4-N
"-0.30 A 2W5-N
"0.10 A 2E1-N
"-0.20 A 2W3
"-1.80
(24 J)
(25.9) A 2W6-N
"-0.10 30 8 28 4 A 2W1
"-1.00
(20.8)
APPROXIMATE EXTENT OF CELL (TYP) A 2W2
"-1.30
(23.4)
A 2W7-N
"O.OO ',27.3)
CELL 2 30.0)
A 2W4-C
"-1.20 A 2W5-C
"-0.40 A2E1
"-0.80 A 2W3-S
"-1.20 ;29.6) A 2W6-C
"-0.20 (33.2) 0.164.000 31.1) (24 8) A 2W7-C
"-0.20 31.7
(31.1) A 2W4-S
"-0.50 A 2W5-S
"-0.60
A 2E1-1S
"-0.20 24.6 A 2W6-S
"-0.40 32.1 8N 31.1 A A 2W7-S
"-0.10
(31.4)
7N 32 2) A (20
(18 6N A A2E1-2S
"-0.30 A2 8C (23
• 31.0 7C 5N A
(19
6C
3S (26 A 3N A 5C 7S A (20 •24 2N A [22 3-4C • CELL 3S (23 A 3C A A 5S 21 (26 A3 2C
4S
(25
A 3S A3
(20 4B-3N ;28 A3 2S
• 4B-2N (26 A3
• 4B-1N
•22
• 4B-3C • 4A 3N
4B-2C
4A 2N
4B-1C CELL 4B 4A-1N
4B-3
4A 3C
• 4B-2
4A 2C
4B-1 CELL 4A • 4A-1C
• 4B-3S • 4A
• 4B-2S LEGEND: N 10.162.000 4A
4B GROUND SURFACE CONTOUR AND ELEVATION
FROM 2012 LIDAR SURVEY. FEET • 4A-1
• 4A-3S EXISTING SETTLEMENT MONITORING POINT A 2W7-S
" 0.0 — I 1 4A-2S TOTAL MEASURED SETTLEMENT (FT)
\27 4) DEPTH OF INTERIM COVER AND TAILINGS
A3-4C PROPOSED SETTLEMENT MONITORING POINT
\ APPROXIMATE SUMP AND DRAIN
r ACCESS LOCATION
NOTE
I. DEPTH OF TAILINGS AND INTERIM COVER IS
CALCULATED FROM JULY, 2012 TOPOGRAPHY AND
AS-BUILT EXCAVATION DRAWINGS FOR CELLS 2
AND 3 (D'APPOLONIA, 1982; ENERGY FUELS, 1983)
PROJECT LOCATION DESIGNED BY U DAVIS BLANDING, UTAH
35-13 DRAWN BT D. MIRANDA MWH 200 0 200
CONTOUR INTERVAL = 2 FEET
100 FT
0'EL>ED BY C, STRACHAN 35-13 ENERGY FUELS - WHITE MESA Energy Fuels Resources (USA) Inc APPROVED BY
PROJECT MAIiA'Ah^ TITLE FIGURE 3 EXISTING AND PROPOSED
SETTLEMENT MONITORING POINTS CLIENT APPROVAL DATE MAY 2013 CLIENT REFERENCE NO 1009/40
® MWH Tailings Characterization and Analysis Work Plan
Retract Piston
Push to
Desired Sample
Depth
11
Push to
Obtain Soil
Sample
Figure 4 CPT Direct Push Sampling (from Steiner, 2013)
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MWH Tailings Characterization and Analysis Work Plan
3.0 HEALTH AND SAFETY
3.1 Health and Safety Requirements
The work will conform to applicable Federal, State, County, and EFRI environmental and safety
regulations. The work will conform to applicable conditions in the Radioactive Materials License
with the Utah DRC. Safety practices, procedures, and monitoring will be conducted as specified
by the Mine Safety and Health Administration (MSHA), the current EFRI health and safety
procedures for the Mill, and the MWH Health and Safety Plan (provided as Appendix B).
3.2 Protection of Tailings Liner System
A significant concern for the tailings investigation is protection of the tailings liner system in Cells
2 and 3. Preparation for the tailings investigation included defining the elevation of the liner and
top of interim cover at proposed test locations. This information was used to calculate the
maximum acceptable probe and direct push sampling depths at each location using a minimum
buffer above the top of liner of three to five feet. Liner elevations were defined using as-built
drawings for Cell 2 and 3 (D'Appolonia, 1982; Energy Fuels, 1983) and the July 2012 aerial
topography provided by EFRI. The as-built contours for Cell 2 (D'Appolonia, 1982) were
lowered 1.5 feet to tie-in to control point BM-4 on the July 2012 topography. A control point was
not provided on the Cell 3 as-built drawing (Energy Fuels, 1983). For Cell 3, the elevations
along the berms for the as-built contours were compared to EFRI's July 2012 topography. The
comparison indicated that an adjustment to the as-built contours is not needed. However, due
to the lack of a control point provided for the Cell 3 as-built drawing, in addition to the relatively
low quality image for the drawing, a minimum of buffer above the liner of 5 feet is
recommended.
Measured settlement from July 2012 to September 2013 ranges from 0 to 1.6 inches. An
adjustment to the July 2012 topography was not made to account for settlement due to the
small measured values since that date.
Figure 3 provides the estimated depth to liner for all the existing settlement monuments in Cells
2 and 3. The proposed CPT sounding locations are all located next to existing settlement
monuments. During the field investigation, the maximum CPT probe and direct push sampling
depths will be at least 3 and 5 feet above the top of liner for Cells 2 and 3, respectively. If the
CPT probe encounters refusal prior to termination of the push, the rig will be moved
approximately 5 feet. For the new location, an additional 0.5' buffer above the liner (based on
the depths shown in Figure 2) must be added above the top of the liner.
Recently, additional interim cover up to 1' in thickness was placed and compacted in select
areas on Cell 2. Due to lack of survey data for this change in cover surface elevation, Figures 2
and 3 conservatively do not include this change.
3.3 Minimize Exposure of Radioactive Materials
During the tailings investigation, procedures will be followed to minimize exposure of radioactive
materials. These procedures include:
• Replacement of cover materials in areas of tailings investigation
• Scanning of investigation equipment in contact with tailings prior to release from site in
accordance with EFRI standard procedures for the Mill
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MWH Tailings Characterization and Analysis Work Plan
• Handling and shipping of samples in accordance with EFRI standard procedures for the
Mill
• Testing of samples at qualified geotechnical laboratory (with radioactive materials
license)
• Return of samples from geotechnical testing laboratory to the Mill for disposal
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4.0 TAILINGS DATA ANALYSIS REPORT
The tailings data analysis report will include:
• A site plan showing the CPT soundings and direct push sampling locations
• Presentation of field results including raw data outputs from the CPT
measurements (i.e. tip resistance, friction ratio, dynamic pore pressures, and
pore pressure dissipation readings)
• Presentation of laboratory testing results
• Interpretation of results including correlation of CPT and direct push samples,
estimation of water levels, and development of subsurface profiles
• A summary of estimated soil properties based upon CPT soundings using
established correlations and direct push sampling information
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MWH Tailings Characterization and Analysis Work Plan
5.0 SCHEDULE
The tailings characterization field investigation is scheduled for October 15 through October 17,
2013. Laboratory testing of select samples from the investigation will be initiated after samples
are received by the testing laboratory. Data analyses and the summary report will be completed
within 4 weeks of receipt of the final laboratory testing report.
The results of this investigation will be used to update technical analyses to address DRC
review comments on the Reclamation Plan Revision 5.0 and the revised ICTM Report. Update
of technical analyses is not included as part of the tailings characterization and analysis work
plan.
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6.0 REFERENCES
Steiner, Shawn (ConeTec), 2013. "Revised ConeTec Proposal" Email to Melanie Davis, MWH
Americas, Inc.. Attachment to email included CPT direct push soil sampling figure. May 15.
D'Appolonia, 1979. Engineer's Report: Tailings Management System, White Mesa Uranium
Project. Prepared for Energy Fuels Nuclear, Inc., June.
D'Appolonia, 1981. Engineer's Report: Second Phase Design - Cell 3, Tailings Management
System, White Mesa Uranium Project. Prepared for Energy Fuels Nuclear, Inc., May.
D'Appolonia, 1982. Construction Report, Initial Phase - Tailings Management System, White
Mesa Uranium Project. Prepared for Energy Fuels Nuclear, Inc., February.
Denison Mines (USA) Corp. (Denison), 2011. Reclamation Plan White Mesa Mill, Blanding,
Utah, Version 5.0. September.
Denison Mines (USA) Corp. (Dension) 2012a. Responses to Interrogatories - Round 1 for
Reclamation Plan, Revision 5.0, March 2012. May 31.
Denison Mines (USA) Corp. (Dension) 2012b. Responses to Interrogatories - Round 1 for the
Revised Infiltration and Contaminant Transport Modeling Report, March 2010. May 31.
Energy Fuels Nuclear, Inc. (Energy Fuels), 1983. Construction Report, Second Phase, Tailings
Management System. March.
Energy Fuels Resources (USA) Inc. (EFRI), 2012a. Responses to Interrogatories - Round 1 for
Reclamation Plan, Revision 5.0, March 2012. August 15.
Energy Fuels Resources (USA) Inc. (EFRI), 2012b. Responses to Interrogatories - Round 1 for
the Revised Infiltration and Contaminant Transport Modeling Report, March 2010.
September 10.
MWH Americas, Inc. (MWH), 2010. Denison Mines (USA) Corp. Revised Infiltration and
Contaminant Transport Modeling Report, White Mesa Mill Site, Blanding, Utah. Report
prepared for Denison Mines. March.
Utah Department of Environmental Quality, Division of Radiation Control (DRC), 2012a.
Denison Mines (USA) Corp's White Mesa Reclamation Plan, Rev. 5.0, Interrogatories -
Round 1. March.
Utah Department of Environmental Quality, Division of Radiation Control (DRC), 2012b.
Denison Mines (USA) Corp's Revised Infiltration and Contaminant Transport Modeling
Report, Interrogatories - Round 1. March.
Utah Department of Environmental Quality, Division of Radiation Control (DRC), 2013a.
Radioactive Material License (RML) Number UT 1900479: Review of September 10,
2012 Energy Fuels Resources (USA), Inc. Responses to Round 1 Interrogatories on
Revised Infiltration and Contaminant Transport Modeling (ICTM) Report, White Mesa
Mill Site, Blanding, Utah, report dated March 2010. February 7.
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October 2013
MWH Tailings Characterization and Analysis Work Plan
Utah Department of Environmental Quality, Division of Radiation Control (DRC), 2013b. Review
of August 15, 2012 (and May 31, 2012) Energy Fuels Resources (USA), Inc. Responses
to Round 1 Interrogatories on Revision 5 Reclamation Plan Review, White Mesa Mill,
Blanding, Utah, report dated September 2011. February 13.
Energy Fuels Resources (USA) Inc.
15
MWH Americas, Inc.
October 2013
APPENDIX A
Sample Field Forms
TAILGATE SAFETY MEETING FORM
Date: Time: Job Number:.
Client: Address:
Site Location:
Scope of Work:
Today's Tasks:
SAFETY TOPICS PRESENTED
Chemical Hazards:
1. Chemicals of concern.
2 Warning properties:
3 PPE needed.
Physical Hazards:
1. Equipment dangers.
2 Pinch.
3 Heat/cold stress
4. Vehicle traffic hazards.
5. Slip, trip, and fall hazards
6. Mechanical and electrical hazards.
7 Noise hazards.
8 Other
9 Work limitations (temperature, weather conditions, light):.
Monitoring:
1 Equipment to be used.
2 Chemical/physical hazards being monitored
3 Action levels for upgrading/evacuating-
4. Frequency of readings/logging in field book:
o
PROJ. NUM.:
PROJ. LOC:
MWH
CLIENT: SUBSURFACE
EXPLORATION
LOG
LOG N":
NO.
SHEET N°: OF
CONTRACTOR INFORMATION CPT RIG INFORMATION SUBSURFACE EXPLORATION INFORMATION
CPT COMPANY: CPT RIG: HOLE DIAM.: LAT. N-START DATE:
OPERATOR: SAMPLING METHOD: DIRECT PUSH CORE DIAM.: LONG. W-FINISH DATE:
HELPER: ELEVATION (FT): LOGGED BY:
TOTAL DEPTH (FT):
FIELD SAMPLE RECOVERY DATA LABORATORY TEST DATA
CO
t
O
^ LJJ XZ
O LLI CL D_
DESCRIPTION
o
CO
O o
1
2
3
4
7
8
9
11
-12
13
14
16
17
18
19
21
22
23
24
26
27
s
| -28
9 I -29
31
32
33
34
NOTES:
E.O.B = XXfeet.
APPENDIX B
MWHA Health and Safety Plan for Energy Fuels White Mesa Mill Tailings Investigation
MWH HEALTH AND SAFETY
PLAN
Rev 1
for
Energy Fuels Resources (USA), Inc.
White Mesa Mill
Blanding, Utah
Tailings Investigation
October 9, 2013
Approved:
Project Manager
10/9/2013
Date
MWH EHS Representative
10/9/2013
Date
© MWH
EFRI White Mesa Mill Tailings InvestigationRev 2
MWH Health and Safety Plan
Table of Contents
1.0 INTRODUCTION 1
1 1 Health and Safety Plan Objective 1
1.2 Policy Statement 2
1.3 Employee Empowerment 2
14 Safety Management 2
1.5 Modifying the Health and Safety Plan 2
1.6 H&S Training for Site Access 2
1.7 MWH Subcontractors Site Health and Safety Plan 3
2.0 PROJECT DESCRIPTION, ORGANIZATION, AND SCOPE OF WORK 5
2.1 Project Description, Location, and Scope of Work 5
2.2 General Site Information 5
2.3 Project Organization 5
3.0 PROJECT ROLES AND RESPONSIBILITIES 6
3.1 Roles and Responsibilities 6
3.2 Health and Safety Responsibilities 6
3.2 1 Project Manager 6
3.2.2 EHS Director or Designated Representative 6
3.2.3 Site Safety and Health Officer (SSHO) 6
3.2.4 MWH Subcontractor Safety Personnel 6
3.2.5 Site Visitors 7
3.2.6 Accident Incident Investigation and Reports 7
4.0 STANDARD OPERATING GUIDELINES 8
4.1 Recordkeeping 8
4.2 Guidelines for Observed or Identified Hazards 8
4.2.1 Hazards Created By Or Identified During Work Controlled By MWH
or MWH Subcontractors 8
4.2.2 Hazards Identified with Client or other Third Party Work Activities 9
5.0 HEALTH AND SAFETY TRAINING REQUIREMENTS 10
5 1 General Health and Safety Training 10
6.0 REQUIRED MEETINGS 11
7.0 PROJECT/SITE HAZARDS AND THEIR CONTROL 12
7 1 Site Hazards 12
7.2 Field/Site Visits 12
7.2.1 Field Site Access 12
7.2.2 Inclement Weather. 12
7.2.3 Uneven Walking Surfaces 13
7.2.4 CPT Sounding and Direct Push Safety. 13
7.2.5 Biological Hazards 14
7.2.6 Radiologic Hazards 14
7.2.7 Chemical Hazards 14
7.2.8 Heavy Equipment Traffic in Tailings Area 14
7.2.7 Hand Tools 15
7.2.8 Lifting 15
7.2.9 Temperature Extremes 15
7.2.10 Sunburn Prevention 15
8.0 PERSONAL PROTECTIVE EQUIPMENT (PPE) 16
9.0 DOCUMENTS AND POSTINGS 16
Rev. 2 October 9, 2013 iii (fg) MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
10.0 EMERGENCY CONTACT INFORMATION 17
APPENDICES
Appendix A - Acknowledgment Form
Appendix B - Incident Reporting Process
Appendix C - Monthly Injury/Illness Report
Appendix D - Pre Job Hazard Briefing
Appendix E - EFRI Contractor Safety Rules
Rev. 2 October 9, 2013 iv @) MWH
EFRI White Mesa Mill Tailings InvestigationRev 2
MWH Health and Safety Plan
CHANGE SUMMARY PAGE
Procedure/Plan No: Energy Fuels Resources (USA) Inc. (EFRI)
White Mesa Mill Tailings Investigation - HASP - 001
Change No. Date Affected Page
(s) Change Summary
REV. 0 6/24/2013 ALL Original Issuance
REV. 1 7/9/2013
Page 14 of main
text, pages 91
and 93 of
Appendix E
Correct minor grammatical errors as
requested by Utah Division of Radiation
Control in their letter dated July 2, 2013.
Rev. 2 October 9, 2013 v © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
1.0 INTRODUCTION
This Health And Safety Plan (HASP) has been prepared for MWH Americas Inc. (MWH) for a
field investigation at Energy Fuels Resources (USA), Inc.'s (EFRI's) White Mesa Mill near
Blanding, Utah, in San Juan County. The project is being performed under contract with EFRI.
MWH does not have responsibility for initiating, maintaining, monitoring, supervising, or
determining the adequacy or implementation of the safety precautions, programs, or plans of
EFRI or of any other contractor which EFRI elects to directly employ. The information in this
HASP should not be used for advising, issuing direction, or assuming control over any safety
precautions or programs of EFRI.
Where this HASP addresses safe practices for various specific activities, this information is
provided solely as directives or guidelines for protecting MWH employees and establishing
minimum requirements for MWH Subcontractors. Any questions on implementation of this plan
should be addressed to the designated project Site Safety and Health Officer (SSHO) or the
MWH Director of Environment, Health, and Safety (EHS).
MWH Subcontractors are contractually responsible for assuring the safety and health of their
own employees Any precautions, programs or HASP of any MWH Subcontractor must, at a
minimum, meet the requirements of this HASP. However, this HASP is not intended to in any
way be a substitute for any subcontractor's own risk analysis or to otherwise relieve any
subcontractor of any applicable contractual and regulatory responsibilities and requirements for
health and safety. MWH Subcontractors that are provided with this HASP shall acknowledge
that it is only intended as minimum HASP requirements, and shall provide their own HASP,
including any changes or revisions specific to their activities and scope of work.
1.1 Health and Safety Plan Objective
This HASP is issued by MWH to establish the work practices necessary for the protection of
MWH employees during the performance of their work activities. The scope of services for
MWH work activities is described in Section 2.
The objective of this HASP is to address known and reasonably anticipated health and safety
hazards to the MWH employees providing services under MWH's contract with EFRI for the
White Mesa Mill Tailings Investigation project. In particular, this HASP provides information
designed to prevent and minimize personal injuries and/or illnesses to any MWH employees,
and physical damage to equipment, supplies and property MWH requires MWH Subcontractors
to have their own HASP. The MWH Subcontractor's HASP must at least meet the minimum
requirements of this HASP.
All project activities will be performed in accordance with applicable Federal, State, and County
environmental and safety regulations. Work activities will conform to applicable conditions in
the Radioactive Materials License with the Utah Division of Radiation Control for EFRI's White
Mesa Mill. Safety practices, procedures, and monitoring will be conducted as specified by the
Mine Safety and Health Administration (MSHA), current EFRI health and safety procedures for
the White Mesa Mill, and this HASP. All MWH employees and visitors must comply with this
HASP.
Rev. 2 October 9, 2013 1 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
1.2 Policy Statement
It is MWH's policy to conduct all work activities in a manner that protects employees, the public,
and the environment; provides for a safe and healthful work environment; and to comply with
applicable regulations and contractual requirements. EHS is given primary importance in
planning and conducting all work activities MWH believes that any accident or injury should be
considered preventable and MWH management is committed to achieving and sustaining zero
accidents.
1.3 Employee Empowerment
Employees are MWH's most valuable asset; their safety is of vital concern. It is the intent on this
project for employees to accept responsibility and ownership of the EHS Program. This HASP is
a living document, and the goal of MWH is that employees are involved in the development and
evolution of the HASP.
1.4 Safety Management
The objective of safety management is to integrate safety, health, and environmental protection
into all work practices. MWH will accomplish this objective by involving all employees in the
work planning process, development of the EHS Program, and development and updating of
procedures The EHS program is tailored to project specific activities and is critical to the
success of this project.
1.5 Modifying the Health and Safety Plan
This HASP must be modified if new hazards are identified, the scope of work is revised, or the
provisions specified in the HASP are not adequate to protect the health and safety of all
personnel. Modifications will be accomplished by consultation with all project Health and Safety
personnel, who in turn shall recommend appropriate modifications after approval by the MWH's
Director of EHS or her designee. All changes to the HASP shall be documented with the
appropriate revision number. The Director of EHS or designee and the Project Manager must
approve changes to this document This process is to be documented in the HASP and the
project files. The Project Manager will be responsible for informing staff and MWH
Subcontractors of changes.
1.6 H&S Training for Site Access
MWH employees are required to have current MSHA certification for work activities at White
Mesa Mill. If MWH employees do not have current MSHA certification, then employees must be
escorted while on the Mill property. MWH employees performing work on the site must also be
familiar with the requirements of this HASP, including emergency contact information. This will
be documented by completion of the Acknowledgement Form (Appendix A) MWH visitors will
be briefed in accordance with Section 3 2.5.
Work at White Mesa Mill will be conducted within the Restricted Area at the site MWH
employees, MWH Subcontractors and visitors will be required to attend site-specific safety
training on the first day prior to being allowed to enter the Restricted Area. MWH employees,
Rev. 2 October 9, 2013 2 (ffj) MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
MWH Subcontractors and visitors will be supervised by EFRI personnel while on site. The EFRI
safety rules for contractors, including training requirements for short-term work, are provided in
Appendix E.
All employees working under this HASP will comply with appropriate procedures and training
requirements outlined here.
1.7 MWH Subcontractors Site Health and Safety Plan
MWH Subcontractors are responsible for preparing a project specific Health and Safety plan as
applicable to their scope of work. Their HASP shall provide for the means and methods to
identify hazards, implement controls, and enforce the precautions and requirements for ensuring
the health and safety its employees and property. At a minimum, the MWH Subcontractor must
meet the requirements of this HASP. The Subcontractor(s) shall provide a copy of their HASP
to MWH.
Rev. 2 October 9, 2013 3 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
2.0 PROJECT DESCRIPTION, ORGANIZATION, AND SCOPE OF
WORK
2.1 Project Description, Location, and Scope of Work
The EFRI White Mesa Mill Tailings Investigation includes geotechnical Cone Penetration
Test (CPT) soundings and sampling of site soils The project includes approximately
fourteen (14) CPT soundings and four (4) direct push sampling locations spread over
approximately 135 acres in the areas of two existing tailings cells. It is estimated that the
field (on-site) portion of the project will be 3 days. The primary project location is
approximately 6 miles south of Blanding, in San Juan County, Utah. The objectives of the
investigation include characterization of the tailings materials for geotechnical properties by
conducting CPT soundings, and collecting samples to send to a laboratory for geotechnical
testing.
The general site location map and proposed CPT sounding locations are shown on Figure 1
and Figure 2 of the MWH Tailings Characterization and Sampling Analysis Work Plan. This
HASP will be provided as an Appendix to the Work Plan. Direct push sampling locations will
be selected in the field after completion of CPT soundings and will be located adjacent to
CPT sounding locations. The work is within the site's Restricted Area and will require an
escort representative from the EFRI at all times As listed in Section 1.6, site safety
requirements for work within the Restricted Area will be outlined by a representative of EFRI,
on-site, prior to entering the Restricted Area.
2.2 General Site Information
The EFRI White Mesa Mill is a fully-licensed and operating uranium processing mill facility.
EFRI facilities consist of the mill and five lined tailings/process solution cells located within
an approximately 686-acre Restricted Area. The tailings cells are located south of the mill.
The mill processes conventional ores and alternative feeds to extract uranium (U308) and
vanadium (V205). The mill was initially licensed by the United States Nuclear Regulatory
Commission (NRC) in May 1980 under NRC Source Material License No SUA-1358. Upon
the State of Utah becoming an Agreement State for uranium mills in August 2004, the Mill's
NRC license was replaced with the mill's current State of Utah License and the mill's Ground
Water Discharge Permit
2.3 Project Organization
MWH is contracted to EFRI for this scope of work. The subcontractor to MWH is ConeTec
(Salt Lake City, Utah) for CPT and direct push sampling services. Contact information for
ConeTec is listed in Section 10.
Rev. 2 October 9, 2013 5 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
3.0 PROJECT ROLES AND RESPONSIBILITIES
3.1 Roles and Responsibilities
MWH is responsible to EFRI for verifying that project activities are carried out in accordance
with the agreed upon scope of work and related contract documents. Along with this
responsibility, MWH will verify that MWH's project activities are carried out in a manner
consistent with applicable health and safety regulations, MSHA standards, client EHS
requirements, corporate EHS procedures, and this HASP.
3.2 Health and Safety Responsibilities
3.2.1 Project Manager
The MWH Project Manager, Melanie Davis, PE, has overall responsibility and authority for the
project and therefore the safety of MWH's employees working on this project
3.2.2 EHS Director or Designated Representative
The MWH EHS Director through the EHS Leader for E&l West (Keith M Groth, CIH, CSP) will
provide corporate oversight of the project from a Health and Safety standpoint The EHS
Director will interact with the MWH SSHO and the MWH Project Manager on a regular basis.
3.2.3 Site Safety and Health Officer (SSHO)
Jason Cumbers, PE, will serve as the SSHO for this project, and will be responsible for
implementing this HASP.
The SSHO has the authority to stop work activities and to remove our employees (or
Subcontractors) from the site when their actions are considered dangerous. His duties include,
but are not limited to:
• Serve as the project lead for all issues related to health and safety.
• Conduct a daily safety meeting.
• Maintain necessary project health and safety documentation and records.
• Verify that employees wear the prescribed level of personal protective equipment
• Prepare incident reports for near miss accidents and actual work-related injuries, illnesses or
losses involving the environment or property.
3.2.4 MWH Subcontractor Safety Personnel
Each MWH Subcontractor shall designate a competent person (capable of recognizing hazards
and with the authority to immediately correct hazards) in a supervisory position, to administer its
HASP. Should the MWH Subcontractor's safety effort be considered inadequate, MWH has the
option to request replacement of the designated safety representative.
Rev. 2 October 9, 2013 6 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
3.2.5 Site Visitors
Personnel visiting the site who are invitees (visitors), employees, or subcontractors will be
permitted to enter the EFRI work area only with prior approval by Mill Management, and the
Project Manager or designee The Project Manager or site SSHO must adequately inform the
visitors of the current hazards and controls including the protective equipment required
3.2.6 Accident Incident Investigation and Reports
Accidents and incidents, including near misses, involving MWH and/or MWH Subcontractor
employees will be investigated.
For incidents invovmg an injury, the Mill Environmental, Health and Safety Manager will take the
lead in conducting the investigation. The investigation will be documented using the Mill MSHA-
required forms, as well as an MWH incident report form or the MWH Subcontractor's form. The
original investigation report form will be filed at the Mill and copies wil be furnished to the MWH
EHS Director, the MWH Project Manager, and the MWH SSHO.
For incidents which do not involve an injury, the Project Manager or designee will take the lead
in conducting the investigation. If the Project Manager requires assistance, she will seek it from
the EHS Director or her designee. The investigation will be documented either using a MWH
incident report form (contact the MWH EHS Director or designee, as needed) or the MWH
Subcontractor's form. The original investigation report form for MWH employees, and a copy of
the form for subcontractor employees will be forwarded to the MWH EHS Director (refer to
Appendix B for MWH incident reporting process and forms). A copy of the report shall be
provided to the MWH SSHO and Mill Management, and maintained in the project file and the
Mill's safety files.
At the conclusion of the field work, a summary of hours worked by MWH or MWH
Subcontractors on the project, accidents and injuries or other incidents will be provided to the
MWH EHS Director (Appendix C) and Mill Management. This information is required no later
than the 7th calendar day of the month.
Rev. 2 October 9, 2013 7 O MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
4.0 STANDARD OPERATING GUIDELINES
All project activities will be performed in accordance with applicable Federal, State, County and
EFRI environmental and safety regulations. All MWH employees, MWH Subcontractors, and
visitors must comply with the requirements of this HASP.
4.1 Recordkeeping
The Project shall establish reporting and recordkeeping requirements in accordance with
Federal and/or State law, MWH EHS and Procedure 402 (Occupational Injury and Illness
Reporting and recordkeeping), and EFRI contractor safety rules (Appendix E). Examples of
reports or records are:
• Incident Reporting (Appendix B)
• Routine MSHA Reporting
• Safety and Health Records (i.e., training records, medical surveillance, exposure monitoring)
4.2 Guidelines for Observed or Identified Hazards
4.2.1 Hazards Created By Or Identified During Work Controlled By MWH or MWH
Subcontractors
• When apparent non-compliance to the HASP or unsafe conditions or practices are
observed, the MWH Project Manager / SSHO and Mill Management will be notified and
corrective actions completed For MWH Subcontractor's, the subcontractor's SSHO or
Project Manager will be notified and corrective actions will be required. For work activities
performed by the subcontractor, the subcontractor is responsible for determining and
implementing necessary controls and corrective actions
• When MWH employees or Subcontractors may be exposed to an apparent imminent
danger, immediately stop work and alert all affected individuals. Remove all affected MWH
and MWH Subcontractor employees from the danger and notify Mill Management, the
Project Manager / SSHO, and the Subcontractor's SSHO or Project Manager where
appropriate. Do not allow work to resume until Mill Management has determined conditions
are acceptable for resumption of work, and adequate corrective measures are implemented
and documented and accepted by the SSHO or her designee
Rev. 2 October 9, 2013 8 ® MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
4.2.2 Hazards Identified with Client or other Third Party Work Activities
In carrying out MWH's responsibilities of assuring safety compliance for MWH and MWH
Subcontractor employees, the following guidelines are implemented when employees identify
hazardous conditions created by the Client or Contractors (third party) within or adjacent to their
work area'
• If a condition is identified that could immediately result in an accident causing severe injury
or death.
• Take appropriate measures to ensure your own safety and all other MWH and MWH
Subcontractor employees by immediately removing everyone from the immediate
danger of the hazard zone.
• Advise others in the area of your concern This would include notifying the client
representative. Do not advise how to correct the immediate hazard, only that one
appears to exist.
• If the potential concern is not addressed, the MWH employee should notify the
Project Manager or her designee, who then may notify the Client of the potential
concern It is the Client's responsibility to determine, and implement if appropriate,
the issuance of a stop work order or to suspend the affected activity. Additionally,
only the Client can authorize a restart of the suspended work activity following
mitigation of the immediate hazard.
• If a condition is identified that may not be an immediate danger, but could result in an
accident involving less serious or minor injury, damage to equipment, or environmental
release.
• Take appropriate measures to ensure your own safety and the safety of all other MWH
and/or MWH Subcontractor employees in immediately removing yourself/them from the
immediate hazard zone
• Advise others in the area of your concern. This would include notifying the client
representative. Do not advise how to correct the deficiency; only that it appears that one
exist
In either case, notify the Project Manager /SSHO. The situation will be evaluated and protective
actions taken to ensure the safety of MWH and MWH Subcontractor employees during the
performance of their work activities.
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EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
5.0 HEALTH AND SAFETY TRAINING REQUIREMENTS
It is important to start each meeting with a safety topic. This practice helps foster the
incorporation of safety into all MWH activities.
5.1 General Health and Safety Training
Health and safety training is an integral part of the total project health and safety program.
The objectives of such training are to educate workers about the potential health and safety
hazards associated with working at the project site. The Project Manager is expected to
instruct employees about the hazards of the project and site before allowing them to perform
work on site The site orientation should include an overview of this HASP, emergency
information, and other relevant information that would provide the worker with safety and
health information prior to entering the project site
Health and safety training that applies to work activities include:
• 24-hr Metal/Nonmetal MSHA Training with appropriate 8-hr Annual Refesher
• Site-specific safety training by EFRI to be conducted prior to entering Restricted Area
(see Appendix E)
• Hazard Communication
• Hearing Protection
• Personal Protective Equipment
If the work scope changes and new training requirements are identified, they will be
incorporated into the program.
Employees and Subcontractors are required to verify that their employees have received the
necessary training and that documentation is available
Prior to commencement of site activities, the SSHO will ensure that all employees and
Subcontractor's employees engaged in a work activity are informed of the nature and
degree of exposure to chemical and physical hazards that are likely to result from
performance of work.
Rev. 2 October 9, 2013 10 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
6.0 REQUIRED MEETINGS
MWH and MWH Subcontractor employees are to attend a project safety orientation, as well
as periodic safety meetings.
MWH meeting safety topics discussed are to be documented accompanied with an
attendance signature sheet The MWH meetings to be conducted are as follows:
Meeting Type Purpose Length Frequency
Contractors Site
Safety Training
To acquaint employees with
site specific hazards,
procedures, and
requiremetns
One hour Once prior to first
day of site work.
Project Orientation
To acquaint employees with
the MWH Project scope of
work and field activities.
Approximately
one hour.
At time of first
assignment to the
Project.
Safety Meeting or
Pre-Task review of
field work.
To cover specific safety
topics; or to review hazards
and safety practices
required for field walk
downs
Approximately
10-30 minutes.
At beginning of field
activities
Daily Safety
Tailgate Meeting
with Mill Safety
Staff
To cover changes in
operations or conditions
each work day
Approximately
10 minutes
At beginning of
each on-site work
day
The Pre-Job Hazard Briefing form (Appendix D) is included as a means of documenting
these meetings
Rev. 2 October 9, 2013 11 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
7.0 PROJECT/SITE HAZARDS AND THEIR CONTROL
7.1 Site Hazards
Field personnel may be subject to the hazards posed by various activities taking place. This
section of the HASP is meant to provide a brief description of the controls that should be
taken to prevent injury to employees observing or participating in such tasks The following
types of activities are anticipated on the project. Additional information concerning the
prevention and control of injury or illness related to these hazards is included in the MWH
Health and Safety Procedures
• Inclement Weather
• Uneven walking surfaces
• CPT Sounding and Direct Push
Sampling Safety
• Biological Hazards
• Radiological Hazards
• Chemical Hazards
• Heavy equipment traffic in
tailings area
• Hand tools
• Lifting
• Temperature Extremes
• Sunburn Prevention
7.2 Field/Site Visits
Staff making a single day or occasional field or facility visit will receive a project site/safety
briefing regarding site conditions and safety practices Appendix D will be completed to
document briefings. Staff shall wear the proper personal protective equipment (PPE) while
performing their tasks Safety vests are required for all field activities where staff is exposed
to equipment operation or vehicle traffic.
7.2.1 Field Site Access
Any staff member entering a project area managed by the Client or Client's Construction
Contractor will comply with their health and safety requirements. Staff will inquire as to the
work activities being performed, potential hazards, policies and site requirements and the
protocol for site visitors entering the site.
A site briefing will be provided by the Client or Contractor prior to entering the site.
7.2.2 Inclement Weather
• This project may be conducted during months of the year in which severe storms occur at
a high frequency and develop rapidly. Personnel are to check the weather forecast for the
day and pay attention to signs of changing weather that indicate an impending storm.
Signs include towering thunderheads, darkening skies, or a sudden increase in wind. If
stormy weather ensues, field personnel should discontinue work and seek shelter until the
storm has passed
• Protective measures during a lightning storm include seeking shelter; avoiding projecting
above the surrounding landscape (don't stand on a hilltop or stand under a lone tree -
Rev. 2 October 9, 2013 12 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
instead seek low areas); staying away from open water, metal equipment, wire fences,
and metal pipes; and positioning people several yards apart.
• Remember that lightning may strike several miles from the parent cloud, so work should
be stopped/restarted accordingly. If you feel your hair stand on end lightning may be about
to strike you. Immediately drop to your knees and bend forward—do not lie flat on the
ground.
• Flash floods are also a concern near the river and drainages. Pay close attention to
thunderstorms and be aware of flash flood potential. Look for signs of floodplains.
• High winds can cause unsafe surface water conditions, and sampling activities should be
halted until wind dies down. High winds can also knock over trees, so walking through
forested areas during high-wind situations should be avoided. If winds increase, seek
shelter or evacuate the area. Proper body protection should be worn in case the winds hit
suddenly, as body temperature can decrease rapidly.
7.2.3 Uneven Walking Surfaces
Employees walking in ditches, swales, and other drainage structures adjacent to roads or
across undeveloped land must use caution to prevent slips and falls that can result in
twisted or sprained ankles, knees, and backs. Whenever possible, observe the conditions
from a flat surface and do not enter a steep ditch or side of a steep road bed. If steep terrain
or uneven ground must be negotiated, sturdy shoes or boots that provide ankle support
should be used The need for ladders or ropes to provide stability should be evaluated. Be
aware of slips, trips, and falls on uneven ground. Wear sturdy footwear appropriate for site
walk activities (work boots).
7.2.4 CPT Sounding and Direct Push Safety
• PPE including hearing protection, safety glasses, hard hats and steel-toed boots must
be worn while working within the Restricted Area.
• Decontamination procedures will be outlined by EFRI personnel prior to beginning the
field work.
• All vehicles are required to be scanned to assure proper decontamination when leaving
the Restricted Area.
• Remain clear of CPT probe and direct push equipment at all times.
• Stand to the side while the crew is removing the probes and samplers, never stand
under the probe or between the rig and a service truck while probes are being removed
• Never work around or under probes while they are being hoisted.
• Probes shall not be stored standing up and shall be secured from rolling.
• Do not wear loose-fitting clothing or other items such as rings or watches that could
become caught in moving parts. Restrain long hair.
• Cover unattended probes to avoid the possibility of people tripping on them.
• The CPT rig shall have a "kill" switch that, when activated, will shut down the rig. The
switch should be identified to those working around the rig and should be tested daily to
confirm operational status.
Rev. 2 October 9, 2013 13 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
7.2.5 Biological Hazards
Potential biological hazards may include snakes (rattlesnakes have been seen on-site),
spiders, ticks, fleas, and poisonous plants (such as poison oak and poison ivy)
Spiders, snakes, and fleas exist in cool, dark, moist areas The potential for encounters exist
when reaching into dark, covered places. Field personnel should be aware of their
surroundings and avoid contact with all insects. An insect repellent with the active ingredient
DEET (no more than 35 percent) should be considered if insects are prevalent. The
repellent can be applied to clothing or hard hats if skin contact is undesirable.
Poisonous plants such as poison ivy and poison oak grow wild in dark, moist areas, and at
the base or surrounding seedling or adult trees. Some individuals are prone to break out in
dermal (skin) rashes upon contact with the plant oil A visual site inspection and
identification of the plants should be completed at the initiation of work at each new location
Precautions, including the use of barrier creams, should be taken to protect the skin from
contact with plant oils. In addition, personnel should wash exposed skin areas as soon as
possible after contact.
7.2.6 Radiologic Hazards
MWH personnel shall comply with the safety requirements set forth by EFRI's Radiation
Safety Officer and outlined in the site-specific safety training provided by EFRI for work
within the Restricted Area. The EFRI safety rules for contractors, including training
requirements for short-term work, is provided in Appendix E. MWH and subcontractor
personnel are required to be escorted the entire time while on site MWH and subcontractor
personnel and equipment must scan out prior to leaving the restricted area.
7.2.7 Chemical Hazards
Chemical hazards include contact with the acidic tailings during sampling. MWH personnel
shall comply with the EFRI safety requirements set forth by EFRI's Radiation Safety Officer
and outlined in the site-specific safety training provided by EFRI for working with
tailings. EFRI requires the use of two-way radios and portable eye wash stations. These
items will be provided by EFRI. Handling of the tailings should be minimized as much as
possible during sampling. Any additional PPE required by EFRI than listed in this HASP will
be provided by EFRI
EFRI requires a minimum buffer of 25 feet from the edge of standing tailings water to be
maintained at all times, otherwise additional protection is required. MWH will not be working
in the area of the standing tailings water and will maintain the minimum buffer. Wet tailings
sands are also considered a hazard. A minimum buffer of 25 feet from the edge of wet
tailings should be maintained at all times
7.2.8 Heavy Equipment Traffic in Tailings Area
MWH personnel shall comply with the EFRI safety requirements set forth by EFRI's
Radiation Safety Officer and outlined in the site-specific safety training provided by EFRI for
heavy equipment traffic in the tailings area. When working in areas with heavy equipment
Rev. 2 October 9, 2013 14 ® MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
traffic, MWH personnel should be aware of traffic, wear a high visibility safety vest, and
general safety precautions should be followed including: (a) not approaching machinery
while in operations; (b) making eye contact before approaching; and (c) not parking behind
heavy equipment.
7.2.7 Hand Tools
• When not in-use, all hand tools should be stored properly to protect the cutting edges
and prevent corrosion.
• Hand tools should be cleaned as needed and kept sharp to improve accuracy and
safety
• Hand tools are not to be used for anything other than their intended purpose.
• All handles must be tightly fitted. Wood handles should be checked and tightened as
needed. Handles should also be inspected for splitting and cracking
• Do not use a knife if a more appropriate cutting tool is available.
• If a knife is required, use one with a retractable blade.
• Always cut away from the body and make sure that you have adequate space to conduct
the task.
• Use appropriate hand protection.
• Do not use knives with dull or broken blades.
7.2.8 Lifting
Proper lifting techniques must be used when lifting any object, as follows:
• Split heavy loads into smaller loads
• Use mechanical lifting aids whenever possible
• Have someone assist with the lift, especially for heavy or awkward loads
• Make sure the path of travel is clear prior to the lift
7.2.9 Temperature Extremes
Hot or cold weather is generally a consideration at any site and cannot be controlled Site
workers need to be aware of controls that can reduce temperature stress, the signs and
symptoms of temperatures stress, and first aid measures for victims of temperature stress.
Refer to EHS Health and Safety Procedure 809, Heat and Cold Stress
7.2.10 Sunburn Prevention
Excessive sun exposure can cause your skin to age prematurely, become "leathery,"
wrinkled, and in some cases, may cause skin cancer. People with fair skin, freckles and red
or blond hair are most at risk but even those who tan easily need to be careful. When this is
not possible, wear protective clothing such as long sleeves and a full brim hard hat to cover
your neck, ears and face. Use a sunscreen with a sun protection factor of at least 15, and
reapply it often since perspiration can dilute its protective effects. Also take precautions on
cloudy days because even though the sun intensity seems diminished, 70 to 80 percent of
the sun's rays are still coming through the clouds. Some medications can also make you
more sun sensitive, so check with your doctor.
Rev. 2 October 9, 2013 15 <$) MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
8.0 PERSONAL PROTECTIVE EQUIPMENT (PPE)
In general, unless otherwise noted, the minimum protective equipment to be worn by MWH
employees for field activities are described in this HASP.
The following table outlines general personal protective equipment requirements; special
equipment may be required for a specific task as defined elsewhere in the HASP.
Item Specifications
Exterior garments Long pants, shirt with sleeves (no tank tops
or shorts)
Foot protection Safety toed footwear/boots (per ANSI Z41).
Gloves
Heavy work gloves (e.g., cotton or leather). If
the MWH employee will be required to
handle potentially contaminated soil or liquid,
nitrile gloves will be worn.
Eye and face protection Safety glasses with side shields (per ANSI
Z87.1).
Head protection Hard hats (per ANSI Z89 1). Hard hats shall
be worn with the brim pointed forward.
Hearing protection
Earplugs or muffs with a noise reduction
rating (NRR) of 25 dB, when working on or
near operating equipment or machinery.
Safety vest Brightly colored traffic-type safety vest when
working in around moving heavy equipment.
Rev. 2 October 9, 2013 16 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
9.0 DOCUMENTS AND POSTINGS
The following documents, as appropriate, are required to be accessible either at the Client's
office, and/or from an employee's home office:
The following documents are to be kept within the Project files:
• Safety meetings documentation.
• Signed acknowledgements of Site Specific Safety Training (Originals will be kept in
Mill Mill Safety Department files and copies will be provided to individuals completing
the training.)
• Accident/Incident investigations (Original copies of Accident/Incident investigations
must be forwarded to the EHS Director, copies will be provided to Mill Management
and will be maintained in MHWA project files and Mill Safety Department files.)
Rev. 2 October 9, 2013 16 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
10.0 EMERGENCY CONTACT INFORMATION
ALWAYS PROVIDE YOUR EXACT LOCATION TO THE 911 OPERATOR
The Project Manager, or designee, will be responsible for taking necessary action and
contacting the appropriate emergency contacts (e.g., MWH Project Manager, Client) and
MWH employees in the event of an emergency.
The following are contacts for emergencies that may occur during fieldwork activities in the
EFRI White Mesa Mill Facility area:
Please note that "9" must be dialed prior to the number if using a phone in the Mill
office.
24-Hour Emergency Hospital
Blue Mountain Hospital 435-678-3993
802 S 200 W.
Blanding, Utah 84511
Maps/directions to above location are are shown on page 19.
Emergency Contact Numbers
Ambulance
Fire Department
Police Department
Utah Poison Control
National Response Center
911
911 or 435-678-2313
911 or 435-678-2916 or 435-678-2334
800-456-7707
800-424-8802
Rev. 2 October 9, 2013 17 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
Project Contact Personnel
MWH Contact Persons Work Number Mobile
Melanie Davis, PE [phone] [phone]
Project Manager
Jason Cumbers, PE [phone] [phone]
Project SSHO
EFRI Contact Persons Work Number Mobile
David Turk 435-678-2221 x113 435-459-9786
Manager Environmental
Health and Safety
Other Contact Persons Work Number Mobile
ConeTec
Shawn Steiner 801-973-3801 801-598-6500
Regional Manager
Rev. 2 October 9, 2013 18 © MWH
EFRI White Mesa Mill Tailings InvestigationRev. 2
MWH Health and Safety Plan
HOSPITAL ROUTE
Map for direction from White Mesa Mill to Blue Range Hospital
(image from Yahoo Maps, 2013)
Directions: East on Mill Road to 1-191 (0.2 miles);
North (left) onto 1-191 (5.9 miles);
West (left) onto E 800 S (0.1 mile);
South (left) W 200 S (78 feet)
Rev. 2 October 9, 2013 19 © MWH
APPENDICES
APPENDIX A
ACKNOWLEDGMENT FORM
As a component of the Health and Safety Plan (HASP) designed to insure personnel safety
during project activities, you are required to read and understand the HASP before
commencing any work When you have fulfilled this requirement, please sign and date this
personal acknowledgment form.
I have been provided with a copy of the HASP for this field project and have become
familiar with it I understand the Emergency response actions, contact numbers and
locations of emergency facilities outlined in Section 10.
I will complete my tasks in a manner conforming to the HASP, MWH EHS
Procedures, and specific additional guidance provided during pre-job briefings, and
will inform the Health and Safety Representative/Project Manager of any conditions
affecting site safety.
Printed Name Signature Date
Rev 2 October 9, 2013 A-1 ©MWH
APPENDIX B
<£g) MWH
Occupational Incident Report Form
Page 1 of 2
BVfLDfWO A BETTER WORLD
EMPLOYEE INFORMATION (Electronically, double click on the box, click "checked")
OFFICE ADDRESS OFFICE PHONE HOME ADDRESS HOME PHONE
MWH EMPLOYEE (If not MWH employee, provide company
name, address, phone) ] YES ] NO
BUSINESS UNIT
JOB TITLE HIRE DATE BIRTH DATE SOCIAL
NO.
SECURITY GENDER | M | | F
SUBCONTRACTOR INVOLVED (If yes, provide company, address & phone)
• YES • NO ^
INCIDENT INFORMATION
LOCATION (name of facility or location identification, addres, specific site)
DATE and TIME INCIDENT OCCURRED EMPLOYEE'S WORK SCHEDULE ON DATE OF INCIDENT
TYPE OF INCIDENT: • INJURY ] ILLNESS
• PROPERTY DAMAGE • NEAR MISS
MOTHER INCIDENT
What was the employee doing j'ust before the incident occurred? Describe the activity, as well as the tools, equipment,
or material the employee was using. Be specific. Examples: climbing a ladder while carrying roofing materials; daily
computer key entry
What happened? Tell us how the injury occurred. Examples: when ladder slipped on wet floor, worker fell 4 feet; worker
developed soreness in wrist over time.
What was the injury or illness? Tell what part of the body was affected and how it was affected. Be more specific than
"hurt", "pain" or "sore". Examples: strained back, carpal tunnel syndrome
What object or substance directly harmed the employee? Example: concrete floor; radial arm saw
INJURY / ILNESS TREATMENT INFORMATION
INJURY/ILLNESS TREATMENT: ] NOT APPLICABLE • ON-SITE FIRST AID
• OFFERED & REFUSED
I | OFF-SITE (If checked, list name of physician or other health care professional/facility,
address & phone
Was employee treated in an emergency room? Q YES ] NO
Was employee hospitalized as an in-patient? H YES ] NO
Was this a fatality? DYES • NO
WITNESS STATEMENTS ATTACHED:
Witness Names:
]YES ]NO
Rev. 2 October 9, 2013 B-1 ©MWH
APPENDIX B
<3J) MWH
Occupational Incident Report Form
Page 2 of 2
ANALYSIS OF CAUSES AND CORRECTIVE ACTIONS
WHAT CONDITIONS OR ACTIONS CAUSED OR CONTRIBUTED TO THE INCIDENT
CORRECTIVE ACTIONS TAKEN OR RECOMMENDED (Describe):
DISTRIBUTION
Supervisor and Business Unit Manager Print & sign name; Original is forwarded to EHS (DEN-2) Pauline Fox
What happened? Tell us how the injury occurred. Examples: when ladders lipped on wet floor, worker fell 4 feet;
worker developed soreness in wrist over time.
1. EMPLOYEE or INDIVIDUAL REPORTED BY: 2. EMPLOYEE'S DIRECT SUPERVISOR:
3. BUSINESS UNIT MANAGER: 4. HEALTH AND SAFETY DIRECTOR:
Cell & Emergency: 720-530-7274/866-469-4456
Facsimile: 303-410-4100
Email: [e-mail]
MSHA Log Case Number:,
5. 6.
Note: Attach additional sheets as necessary to document incident.
Rev. 2 October 9, 2013 B-2 (JJJ) MWH
APPENDIX B
Incident Reporting Process
Work-Related Injury / Illness or Vehicle Accident
1. Employee(s) should seek necessary medical attention at PRE-DESIGNATED Medical Provider as appropriate:
a. On-site first aid
b. Local clinic or Emergency room - e.g., Refer to posted list of pre-designated medical facilities. Contact
Americas EHS at 720-530-7274 prior to visiting if possible. ALL Offices and HASPs have medical clinics
pre-designated. Lists posted in common areas.
c. Via 911 - transport by ambulance if there is any uncertainty about severity of injury
If work related, inform medical personnel this is a work-related incident. // the medical provider asks for a
claim number, advise them that Travelers Insurance is your workers' compensation insurance carrier and
your policy number is:
VTRJUB5643B09510 (AZ, MA, OR, WI)
VTC2JUB5026L18110 (all other states)
Once an injury has been reported using the steps outlined below, a claims adjuster will be assigned by the
insurance company. They can address any concerns related to paperwork and/or billing.
2. MWH Employee(s) should immediately notify their supervisor and Mill Management. The MWH employee or
supervisor should then contact Americas EH&S at 720-530-7274 (cell) and their respective Business Unit
Leader the same day. Additionally, employees can utilize (866-469-4456) to report injuries or emergencies.
3. The MWH Occupational Incident and/or Vehicle Accident Report must be completed within 24 hours,
preferably ASAP. Submit forms via email to Americas EHS at EHS<S>mwhalobal.com and Mill Management at
DTurk(e>energyfuels. com.
4. Ensure that any client or state-specific forms and notifications are complete.
Rev. 2 October 9, 2013 B-3 ©MWH
APPENDIX B
INCIDENT
OCCURS
Employee Immediately
notifies their Supervisor.
Employee or Supervisor Immediately Calls:
Tamara Renkoskl, EHS Director
720-530-7274 (EHS cell)
or 866-4694456
And notifies
Business Unit Leader
Employee and/or supervisor
immediately notifies Mill
Management
VEHICLE ACCIDENT
Report Fleet Vehicle damage to
Pamela Taylor (PAS 1) at
626-568-6381
INJURY/ILLNESS
Local Management Team, EHS
Director and injured employee
perform an after Incident review
to determine root causes and
corrective actions I Supervisor Is
responsible for coordinating the
review.
WITHIN 24 HOURS:
Employee/Supervisor Completes MWH
Incident Report Form or Vehicle Incident
Report Form and submit to EHS via email to
EHS(S>mwhglobal.com
Local Management Team, EHS
Director and employee
Involved In vehicle accident
will perform an after incident
review to determine root
causes and corrective actions!
Swwryfrqr resmnflbte for
coor(Mooting the review.
Rev. 2 October 9, 2013 B-4 ©MWH
APPENDIX C
Monthly Injury/Illness Report
Form must be completed monthly and submitted to the EHS Manager
by the seventh working day of the following month.
SUBCONTRACTORS
Complete this table for each subcontractor on the project.
Company Name
ConeTec
Reporting Month Date of Report
Project Name.
EFRI White Mesa
Mill Tailings
Investigation
Contract ID Number Number of
Employees'
Month Total for Year to Date Total for Subcontract
Hours Worked
Number of First Aid
Cases
Number of OSHA
Recordable Cases
Number of Lost
Workday Cases
Lost Workdays
Restricted Cases
Restricted
Workdays
Fatalities
Rev. 2 October 9, 2013 C-1 (JjJ) MWH
APPENDIX D
Pre Job Hazard Briefing
Supervisor Date
Brief Job Description
Location Job No. (IF APPLICABLE)
Review hazards of job with each employee prior to start of job using the checklist
below.
Activities Yes No NA Additional
Information
1. Has work to be performed been explained"?
2. Proper safety equipment on job site?
3. Permit(s) issued-
n LO/TO • Hot Work • Other
4. Permit(s) reviewed?
5. Proper tools for job?
6. Communicated work with others in area?
7. MSDS reviewed?
Hazard Identification: List Job Step numbers
involved with each hazard
Yes No Hazard
Controls
1. Chemical (List chemicals here)
2. Thermal/burn exposure or heat/cold stress
3. Waste material (List material description here)
4. Elevated Work (List elevation source here)
5. Slipping/tripping hazard (List known hazards
here)
6. Overhead work (List type of work here)
7 Laceration, contusion, pinch point, crushing,
abrasion, etc
8. Electrical hazard (List electrical source here)
9. Traffic Safety
10. Animal & Insects
11. Poison Ivy Vegetation
Rev. 2 October 9, 2013 D-1 ©MWH
APPENDIX E
Appendix E - EFRI Contractor Safety Rules
Rev. 2 October 9, 2013 E-1 ©MWH
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
91 of 101
ENERGY FUELS
CONTRACTOR SAFETY RULES
Contractor shall be responsible for compliance with all local, State, Federal and Company safety,
health and environmental laws and regulations in effect. Contractor shall also be held to
understand that this site is a State of Utah Division of Radiation Control licensed facility and is
governed by the rules and regulations of the Owner, State of Utah DRC and MSHA. Owner
requires that all work conducted by Contractor and its employees be performed in a responsible
manner with special attention and mutual cooperation on the part of everyone involved including
Contractor, its employees and the employees of the Owner.
As part of its Contractual obligation, Contractor and its employees are expected to abide by all
applicable safety rules. Mandatory, (MSHA, OSHA, State or Company, etc.) safety and health
training must be received by all workers prior to starting any work on site. The rules listed
below are minimum basic Owner Safety Rules and Regulations; they do not in any way contain
every necessary rule. If the Contractor has questions concerning Safety Rules and Regulations,
Contractor shall consult with Owner's Representative before starting work.
The fact that other applicable rules, regulations or requirements (Federal, State or local) are not
printed herein will not be an excuse for any violation. Any violations of these rules and
regulations be it accidental or intentional may be cause for termination of this contract.
All contract employees must receive the training required by Owner prior to starting
work on site.
Hardhats, safety glasses, identification badges and steel toe shoes will be required
when entering the mill area. Whenever, work is performed in an environment, which
requires special protection, such as respirators, hearing protection, goggles or face
shield, wet suits, etc. this protection must be worn. If there is a question as to
whether this special equipment is required, contact the Owner's Representative.
OWNER SAFETY RULES AND REGULATIONS
I. TRAINING
II. PERSONNEL PROTECTION
Persons with hair that extends longer than two (2) inches below the tee shirt collar
must confine the hair.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
92 of 101
If respiratory protection is required a respirator fitness physical and fit test are
required. Any question regarding this subject shall be directed to the Owners
Representative.
Appropriate fall protection shall be worn at locations where there is a danger of
falling and/or where required by Owner.
III. RADIATION PROTECTION
The White Mesa Mill has a radioactive materials license with the State of Utah
Division of Radiation Control. Under that license, there are certain items that must be
observed by all parties on site. Those are, but not limited to:
a. Eating, drinking and chewing are only authorized in designated areas. These
areas are determined and posted by the Radiation Safety Officer. Potentially
contaminated PPE is not allowed in these areas.
b. All personnel, equipment and vehicles that enter into the restricted area, must be
surveyed for radiological release prior to leaving the restricted area. All mobile
equipment must travel through the decontamination wash station before being
presented for release from the site.
c. Before work assignments commence, the Contractor must present their job
assignment to the Radiation Department. The Radiation Department will
determine exposure potential and will issue a Radiation Work Permit if
applicable.
d. All Contractor personnel must submit to periodic bioassay monitoring for the
determination of potential uptake or ingestion of uranium.
e. Respiratory protection may be needed if there is determined that an area is
contaminated. If respiratory protection is required, the Contractor will provide
medical clearance for their personnel. Respiratory devices will only be issued
upon the successful completion of the medical evaluation and onsite respirator fit
testing.
f. Personnel must monitor him or her with the use of an alpha monitoring device
prior to leaving the restricted area. Monitoring locations are under surveillance to
ensure that proper techniques are being applied. Contractor personnel will be
trained in the proper use of these instruments.
g. Failure to comply with these items and others as deemed necessary by the
Radiation Safety Officer will be grounds for immediate termination of services at
the facility.
IV. HOUSEKEEPING AND STORAGE
Debris will not be allowed to accumulate. Regular removal to designated areas is a
requirement. Tools, equipment and materials will be stored in a safe and orderly
fashion that minimizes interference with operations or traffic. Upon completion of
the job, Contractor shall remove all construction debris and leave the site neat and
orderly.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
93 of 101
V. FIRE PROTECTION
a. Fire extinguishers are to be provided by Contractor and will be kept immediately
available when burning or welding in areas adjacent to combustible material.
They must not be obtained by removing Owner's extinguishers from established
locations.
b. The White Mesa Mill is a smoke free work place. Therefore smoking is
prohibited in the administration building and the restricted area. It is necessary
however to post areas as no smoking areas wherever flammables are stored.
c. No person shall use open flames within 50 feet of where flammable materials are
stored.
d. Combustible material; i.e., grease, lubricants, flammable liquids, etc. shall not be
allowed to accumulate where they can create a fire hazard.
e. Personnel must be familiar with site emergency procedures; i.e. fire drills
evacuation drills, etc. as instructed by the Owner's Representative.
f. Fire alarm procedures will be provided by Owner's Representative.
g. Flammable liquids (flash points below 100°F) shall not be used for cleaning
purposes.
h. Containers of combustible or flammable liquids shall be bonded and grounded
whenever liquid is being transferred; hose must be in metallic contact during
transfer.
i. Flame permits will be used where required by Owner's Representative.
j. Flammable or combustible materials must be stored in spill proof containers and
properly labeled.
VI. GENERAL
a. Utilities - Connection to or disruption of service of any utility, such as electricity,
steam, water, gas, etc., requires notice to and approval of Owner's Representative
before action is taken.
b. Alcohol and Drugs - No person will be permitted to work while under the
influence of or in the possession of alcohol or drugs. Persons taking medication
will not be permitted to work if is affects their performance or judgment. A drug
and alcohol testing policy is in place at this facility. All Contractor personnel will
be subject to random and accident investigation samplings.
c. Signs and Warnings - Anytime work is performed which could present a hazard
to others; the area must be roped off or barricaded. All posted signs and other
warnings devices shall be strictly observed.
d. Horseplay - Horseplay will not be tolerated.
e. Eating Areas - Eating, drinking and chewing is permitted only in designated areas
by the Owner.
f. Restricted Area - A radiation survey must be performed on all personnel and
equipment prior to leaving the restricted area. The restricted area consists of all
operational and disposal areas.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
94 of 101
g. All contractors while working on Company property are subject to Energy Fuels
Resources (USA) Inc. Drug and Alcohol Testing Policy. Testing may include
accident investigation, behavioral changes or impaired job performance,
perceived drug or alcohol influence and random testing. A copy of the policy will
be provided for each contracting company.
VII. SPECIAL PROCEDURES
a. Lockout procedures - When work is to be performed on any equipment, tanks and
lines the "Zero Energy" concept will apply.
Each job, which requires lockout must be authorized by Owner's Representative
before any equipment is turned off or locked out. Owner's Representative will
assist Contractor to assure proper lockout procedure is followed.
To assure that the correct drive switch has been locked out; an attempt must be
made to start the equipment before work is started. The assurance can be gained
on interlocked systems by attempting to start the equipment at its local control
station. If this proves satisfactory, push the stop switch again.
Any gas or chemical lines that enter work locations must be blanked or have the
valve locked in the closed position. The valve must be locked or tagged so it can
easily be identified as a Contractor lockout. It will be the responsibility of the
Contractor, to assure lockout knowledge and compliance from their employees.
b. Flame Permits - A flame permit will be required and must be displayed when
welding or torching anywhere a fire hazard exists. A fire extinguisher and a
pressurized water hose must be ready at the job location during all welding and
torching. A person must be standing by and able to watch for any sparks which
could start a fire.
No welding or cutting will be done within 50 feet of fuel storage areas.
c. Confined Space Entry - Whenever work is done that involves entry into tanks,
bins or similar enclosures, a Confines Space Entry Evaluation and Safe Work
Permit will be required.
Other Safe Work Permit area include: working on chemical lines, working on any
high pressure system, operating equipment close to electrical lines or any
hazardous operation as determined by the Site Safety Coordinator.
Where a hazardous or oxygen deficient atmosphere is possible, special
precautions will be needed in addition the normal safety precautions, such as
lockout, air fans, respirators, safety ropes, etc. Safety precautions may be found
in the Safe Work Procedure, which will be furnished by the Owner's
Representative if applicable.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
95 of 101
d. Process Lines - Process lines which contain or may have contained hazardous
chemicals or gases can be worked on only with specific approval of the Owner's
Representative.
VIII. MOBILE EQUIPMENT
Equipment will be kept in safe operating condition and be checked frequently. All
equipment must be operated by experienced operators and will be confined to the
work areas or places designated by the Owner's Representative. Drivers must be
licensed if driving on public roads. Speed limits and traffic rules will be observed.
Owner's equipment has the right-of-way. Observe caution, yield to traffic control
signs. Speed limits on property shall not exceed 15 mph.
Cranes, power shovels and similar equipment will be directed by a responsible person
on the ground when being moved through congested areas. Special attention must be
paid to overhead wires, piping and other obstructions. (The ten-foot rule must apply)
All suspended loads which are being moved by mobile equipment; i.e., winch truck,
cherry picker, etc., shall be secured with a tagline to prevent it from swinging.
All persons shall ride inside the cab or truck bed; absolutely no one is to ride on the
fenders or running boards. All persons riding in a vehicle shall keep both body and
feet within the protective area of the vehicle frame.
Protruding material that extends (2) feet beyond the rear of the vehicle shall be
flagged.
Operators of gasoline powered vehicles shall stop the engines and place the ignition
in the off position when refueling.
Drilling equipment must not be operated within (50) feet of any energized power line.
IX. HEAVY EQUIPMENT
a. All self-propelled equipment shall have adequate overhead protectors (Roll-over
Protective Structures - ROPS) to insure worker protection.
b. All self-propelled equipment (except wheeled tractor scrapers) shall be equipped
with backup alarms and the alarms must function when equipment is in use. A
second person will be responsible to guide tractor scrappers when scrapers are in
reverse.
c. Buckets, lifts or blades shall be left down when equipment is not in use.
d. Dump truck beds shall be in the down seat position while traveling.
e. No person shall place any part of his/her body under a suspended load. Push,
never pull. A suspended load, thereby keeping one's feet and body in the clear.
Whenever possible, use a device to direct the load.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
96 of 101
f. After a piece of equipment has been down, the operator shall walk around and
inspect the equipment before moving it.
g. Persons shall not get on or off moving equipment.
h. Operators of equipment shall not work under overhanging walls until all safety
precautions have been taken and then only after a Safe Work Permit has been
issued.
i. Travel speed of equipment shall be consistent with road conditions.
X. TOOLS AND EQUIPMENT
Tools and equipment will be kept in safe condition with all safety devices and guards
kept operable. Electrical tools will be provided with grounding protections (separate
ground wire, double insulated and or Ground Fault Interrupter). All portable
electrical lights will be properly guarded. Extension cords hoses; etc. will be kept in
good condition and strung so as not to create a hazard. All electrical devices will be
checked prior to start of work for resistance to ground to insure proper grounding is
provided.
Compressed gas cylinders will be secured in an upright position. Gauged bottles will
be protected and guarded and shut off when unattended. Hoses and leads will be
checked for leaks prior to each use and repaired or replaced if found defective.
The "quick opening" coupling on compressed air, steam or any other high-pressure
hose must be pinned and whip checked. All bull hose must be securely chained.
XI. EXPLOSIVES AND BLASTING
a. All explosives shall be properly stored per ATF "Table of Distance" as to
distance. The construction of the magazine shall meet the ATF specifications.
b. All magazines shall be licensed.
c. No open flame shall be permitted in or within 100 feet of any explosive magazine.
d. Explosives and detonators (primers) shall not be transported together. When
being transported in the same vehicle, they shall be in different compartments,
with appropriate signs on vehicle (see local regulations).
e. All unused explosives and detonators shall be returned to their proper magazine.
f. All blasts shall be properly guarded.
g. Warning signs shall be used to halt use of two way radios during the loading and
blasting cycle when electrical blasting caps are used.
h. For blasting in open pit works, Owner's Representative shall be notified of each
blast prior to the blast. All blasting plans and guarding procedures shall be
approved by the Owner's Representative.
i. All blasting materials and magazines will be removed by Contractor upon
completion of job.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
97 of 101
XII. REGULATORY AGENCIES
Code of Federal Regulations specifies that independent contractors will be held
responsible for compliance with all standards. The regulations require that the
independent contractor provide Owner with the following;
a. Contractor's trade name, business address, telephone number, contractor's ID
number for MSHA/OSHA or State and name of person in charge of project.
b. A description of the work to be performed and the place where it will be
performed.
Contractor must provide Owner with the same information for each subcontractor
before each subcontractor begins work on Owner's Work Site.
XIII. ACCIDENT REPORTING
All accidents and/or injuries shall be reported to Owner's Representative
immediately.
XIV. TRAFFIC CONTROL
Only those vehicle authorized by the Owner's Representative will be permitted in the
restricted area. All Contractor vehicles, equipment and personnel will be scanned for
radiological release prior to leaving the restricted area.
XV. MONITORING CONTRACTOR'S EMPLOYEES
Owner may perform certain monitoring on Contractor's employees, from time to
time, to ascertain the exposure of such employees to various substances they may
encounter in the course of their work under Contractor's contract with Owner.
Owner will select the times, the conditions and the equipment to be used for such
monitoring. Owner will conduct such monitoring using its own personnel, but will do
so solely as an agent for the Contractor, and on the Contractor's behalf. Owner's
monitoring may have for the protection and surveillance of the Contractor's
employees and the performance of such monitoring shall not be deemed a waiver by
the Contractor or as an assumption by Owner of such responsibilities.
XVI. ADDITIONS OR CHANGES TO RULES
Additional area restrictions, rules or procedures not defined in the Special Rules, etc.,
will be provided by Owner's Representative or the department supervisor as
necessary and must be observed. Contractor personnel must immediately contact
Owner's Representative if there are any concerns about potential hazards or proper
methods before proceeding.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
98 of 101
XVII. ARCHAEOLOGICAL DETERMINATION
During the course of any work performed by Contractor, if any archaeological
evidence is discovered, i.e., artifacts or remains, the work must cease immediately
and Contractor must notify the Owner Representative immediately.
XVIII. LIGHTNING
If you hear thunder, lightning is close enough to strike you. Immediately stop what
you are doing and seek safety in a substantial building or metal topped vehicle with
the windows up. In the event that thunderstorm conditions develop, Energy Fuels
Safety Department will notify all on site personnel to seek shelter. Stay in until 30
minutes after you hear the last thunder or until the Safety Department determines it is
safe to resume work activities.
White Mesa Mill
Book #13 Training Manual
Date: 07/13 Revision: EFR 3.1
99 of 101
By signing this acknowledgement, each Contractor denotes acceptance of all of the above safety
requirements of this Contract and agreement to abide by all federal, state and local laws and
regulations.
Name: Date:
(Print)
Contractor:
Brief Job Description:
Signature: