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HomeMy WebLinkAboutDRC-2009-003583 - 0901a06880131fe4[yiy-ycryy^ogs^^ DENISON^/i MINES Denlson Mines (USA) Corp. 1050 17th Street, Suite 950 Denver, CO 80265 USA Tel: 303 628-7798 Fax:303 389-4125 www.denisonmines.com VIA FEDERAL EXPRESS August 18, 2009 Mr. Dane Finerfrock, Executive Secretary Utah Radiation Control Board Utah Department of Environmental Quality 168 North 1950 West P.O. Box 144810 Salt Lake City, UT 84114-4810 Dear Mr. Finerfrock: T^. Division cf Radiation Control •9 yy .cC/ ei_ieo3v" Re: Renewal Application for Radioactive Materials License (RML) No. UT1900479: Health Physics Interrogatories - Round 2; and Engineering Comment Interrogatories - Round 1 Further to our letter of August 14, 2009, enclosed please find a CD containing an electronic copy of Denison Mines (USA) Corp.'s. response to the above-captioned Interrogatories. If you should have any questions or require additional information, please contact the undersigned. Yours very truly, DENISON MINES (USA) CORP. By: David C Frydienlund Vice President, Regulatory Affairs and Counsel cc: Ron F. Hochstein Harold R. Roberts Steven D. Landau David E. Turk Denison Mines USA Corp 1050 17th Street Suite 950 DENISO Al Denver CO 80265 Ift1IES Fax303 389-4125 www.denisonmines.com August 14 2009 Mr Dane Finerfrock Executive Secretary Utah Radiation Control Board Utah Department of Environmental Quality 168 North 1950 West P.O Box 144810 Salt Lake City UT 84114-4810 Dear Mr Finerfrock Re Renewal Application for Radioactive Materials License RML No UT1900479 Health Physics Interrogatories --Round and Engineering Comment Interrogatories -- Round This letter is in response to the Executive Secretarys correspondence of July 2009 received by Denison Mines USA Corp Denison or DUSA on July 2009 with attached Health Physics Interrogatories Round and Engineering Conmient Interrogatories Round pertaining to the White Mesa Mills the Mills February 2007 License Renewal Application the 2007 License Renewal Application Each Interrogatory is shown in italics below followed by Denisons response to the question and/or request for information SECHON HEALTH PHYSICS INTEROGA TORIES -ROUND INTERROGATORY STA TEMENT ALTERNATE FEED Round One Interrogatory Statement 11 Provide the inspection procedure that discusses the inspection requirements of the alternate feed materials that are stored in containers other than drums from when the mill takes acceptance of the materials until they process the material and Statement 12 Provide the procedure that discusses how alternate feed material that is leaking from containers other than drums and is exposed to the wind will be containerized The issue is ALAR4 Demonstrate how mill workers and the General Public are protected from unnecessary inhalation exposure from alternate Feed Stocks that have 0.009 to 65%uranium content that are allowed to be exposed to the wind Denison Response Alternate feed materials are managed at the Mill in such manner as to keep potential exposures to the public and occupational exposures within the exposure levels for conventional ore operations at the Mill Conventional ores processed at the Mill range in grade from less than .05%to over 1.0%U308 on average from Arizona Strip ores The Mills State of Utah Radioactive Materials License No UT 1900479 the Mill License contemplates that conventional ores will be stockpiled in bulk on the Mills ore pad pending processing The MILDOS AREA modeling performed in 2007 and submitted with the 2007 License Renewal Application assumed full Mill operations of 2000 tons per day 365 days per year with Arizona Strip ores having an average grade of 0.64%U308 That modeling assumed that 730000 tons of ore would be handled at the Mill each year and that an average of approximately 300000 tons of 0.64%ore would be stored on the Mills ore pat at any given time These assumptions also result in an assumed production rate of 8.8 million pounds of U308 per year The 2007 MJILDOS AREA modeling was also performed assuming full operations with Colorado Plateau ores averaging 0.25%U308 resulting in the production of 3.5 million pounds of U308 per year The 2007 MILDOS AREA modeling demonstrated that such conventional ore operations and practices do not result in exposures to the public in excess of the regulatory standard of 100 mrem/yr in R3 13-15-30 or the ALARA goal of 10 mrem/yr excluding radon 222 and its decay products in R3 13-15-1014 In fact the 2007 modeling shows the Total Effective Dose Equivalent including radon and its decay products to the nearest resident under the foregoing assumptions for Arizona Strip ore production to be less than mrem/yr which is less than 2.0% of the regulatory standard of 100 mrems per year and Total Effective Dose Equivalent excluding radon and its decay products of less than mrem/yr which is less than 10%of the ALARA goal of 10 mrem per year In addition the 2007 modeling demonstrated that the Total Effective Dose Equivalent values both including and excluding radon and its decay products for full operations with Colorado Plateau ores are less than half of the values for the Arizona Strip ores described above The modeling also demonstrated that the doses to the nearest resident excluding radon and its decay products do not exceed 25 mremlyr to any organ as required by 40 CFR 190 In fact the results do not exceed mrem/yr which is less than 5%of the 40 CFR 190 standard See Section 3.13.2.6 of the 2007 License Renewal Application for discussion of this MILDOS AREA modeling for the Mill Occupational exposures at the Mill are kept within the regulatory standard of 5000 mrem per year and the Mills ALARA goal of 1250 mrem per year 25%of the regulatory standard through implementation of the Mills radiation safety program as set out in the Mills Radiation Protection Manual Air particulate in various areas of the Mill including various locations on the Mills ore pad is monitored and time weighted doses are calculated for workers who may be OENISONA MINES exposed to air particulate from ore stored on the ore pad and other ore pad activities Similarly time weighted exposures from radon and gamma are calculated The Total Effective Dose Equivalents for workers at the Mill even during Arizona Strip ore runs have historically been well below the Mills ALARA goal of 1250 mrem per year The assumptions in the MILDOS AREA modeling are verified by air particulate sampling at the five air particulate monitoring stations located in the areas surrounding the Mill Air particulate samples from the Mills inception have demonstrated that the Mill operates in manner that maintains exposures to the public at levels that are well within regulatory standards and ALARA goals It is evident from the foregoing that based on the modeled results and historic air particulate and occupational exposure monitoring data the Mill operates well within applicable regulatory standards and ALARA goals and without any significant impacts to public health safety or the environment The foregoing analysis for conventional ores sets the environmental envelope for Mill operations that can be performed without considering the need for further modeling Alternate feed materials are handled so as not to allow potential exposures to the public to exceed the potential exposures from processing Arizona Strip ores at full capacity without further modeling and if further modeling is required without exceeding the applicable regulatory standards and ALARA goal specified in R313-15-101 R313-15-301 and 40 CFR 190 Similarly alternate feed materials are only handled in manner that ensures that occupational exposures are kept within the Mills ALARA goal of 1250 mrem per year To date all alternate feed materials have fallen well within this envelope and no feed-specific modeling has been required In order to meet these requirements the following practices have been followed for alternate feed materials High grade alternate feed materials typically with 1.0%U308 or greater are usually received at the Mill and stored in drums or other containers This is the way that CaF2 KOH Rhone Poulenc Cotter Concentrates and the Cameco KF Calcined Regen and UF4 alternate feed materials have been received and stored at the Mill Alternate feed materials that are received in bulk and that have higher risk of public or occupational exposure than Arizona Strip ores such as may result from high radioactivity and/or fine dry particles relative to Arizona Strip ores have been covered by less radioactive materials while stored on the Mills ore pad This is the way the Heritage alternate feed materials were handled on site and Alternate feed materials that are received in bulk and that have lower risk of public or occupational exposure than Arizona Strip ores have been stored in bulk on the site in the same manner as conventional ores This is the way the Ashland Ashland and Linde FUSRAP materials and the Cabot and FMRI materials have been handled on site Currently there are approximately 11000 tons of FMRI alternate feed materials and 5000 tons of Cabot alternate feed materials stored in bulk on the ore pad The average uranium content of each of those materials is estimated to be less than 0.25%U308 The quantity and radioactivity of those materials is much less than the quantity and radioactivity of Arizona Strip ores assumed OENISON9AA MINES in the MILDOS AREA modeling to be stored in bulk on the ore pad 300000 tons at grade of 0.64%U308 In addition the Cabot and FMRI alternate feed materials arrive at the site in moist state and harden into state that is if anything less dispersible by wind than conventional ores As result the same precautions to prevent windblown at the site for conventional ores periodic water sprays are considered adequate for those materials Based on the foregoing practices Denison is satisfied that all alternate feed materials are handled at the Mill in manner that ensures that exposures to the public and occupational exposures are kept within the environmental assumptions for the site and well within applicable regulatory standards and ALARA goals INTERROGATORY STA TEMENT ALTERNATE FEED Round One Interrogatory Statement 13 Provide the procedure used to determine how and when alternate feed is to be processed through the mill The Mill is currently installing an Alternate Feed Circuit to the mill with operational status to begin in June 2009 Provide Radiation Safety information for example additional PPE requirements and monitoring requirements and general overview of operation of this new circuit Denison Response 2.1 Overview of New Alternate Feed CircuitHistorically the Mill has processed alternate feed materials utilizing existing Mill equipment and facilities However In most cases the portions of the existing Mill circuit used for alternate feed processing could not simultaneously be used for conventional ore processing thereby resulting in alternate feed processing displacing conventional ore processing and Cleaning up the process circuits between different alternate feed processing runs and prior to subsequent conventional ore processing runs can be costly and time-consuming In order to eliminate these two issues the Mill constructed new alternate feed circuit the Circuit that can be run simultaneously and independently from number of the conventional ore processing circuits The solvent extraction precipitation drying and packaging stages however will normally continue to be performed as needed by the use of existing facilities The Circuit has its own drum dumping station This station was designed specifically for UF4 alternate feed material which is the first alternate feed material to be processed through the Circuit Modifications to the Circuit including the manner of introducing feed into the Circuit may be made for different alternate feed materials For example low grade bulk materials may be introduced through the existing SAG mill and pulp storage tanks and piped to the new Circuit Tailings solids are separated from solutions in the Circuit and are piped to the tailings system Any raffinates from the Circuit are piped to the tailings system Pregnant solutions are piped either to the Mills existing solvent extraction circuit or directly to precipitation in the Mills existing precipitation circuit 2.2 Overview of UF4 Processing in the Circuit OENISONA MINES The Circuit has been designed to accommodate number of different types of alternate feed materials However it has initially been set up to process the UF4 alternate feed materials which are currently being processed brief description of the UF4 processing steps is set out below Drums of UF4 material are dumped in the drum dumping station while submerged in hot sodium carbonate solution and then the mixture of UF4 material and hot sodium carbonate solution is transferred to another vessel for digestion and dissolution of the uranium and fluoride Next caustic soda is added and the uranium is precipitated from solution Diatomaceous earth is then added to aid in filtration and the uranium precipitate is filtered from the fluoride-bearing liquid The fluoride-bearing liquid is sent to tailings and the uranium-bearing solids are mixed with water and transferred to another vessel for re-dissolution in hot sulfuric acid solution Following acid re-dissolution any remaining solids are removed by second stage of filtration and the uranium-bearing solution is sent to one of the impurity removal tanks In the impurity removal tank ammonia is added to raise the pH sufficient to precipitate iron but leave the uranium in solution The iron precipitate is allowed to settle and the purified uranium-bearing solution is transferred to the normal uranium precipitation drying and packaging circuits of the Mill for final processing block flow diagram showing the UF4 processing is attached as Appendix to this letter 2.3 Radiation Safety Features 2.3.1 DACs There will likely be three derived air concentrations DACs used for the Circuit ore leach and SX These DACs will be calculated in accordance with Section 4.0 of the Mills Radiation Protection Manual However since the current Radiation Protection Manual calculates the leach DAC for the existing Mill facilities as one half of the ore DAC and one half of the precipitation DAC based on proximity of the existing leach circuit to the SAG mill and the precipitation circuit the leach DAC for the Circuit will have to be determined based on the physical configuration of the Circuit Until such time as the manner of calculating DACs for the Circuit is determined the Mills Radiation Safety Officer RSO will apply the strictest DAC for the Circuit to all activities in the Circuit 2.3.2 Area Air Particulate Monitoring Stations There currently are no permanently assigned air particulate monitoring locations in the Circuit Initially the RSO will place portable air particulate samplers in various areas of the Circuit to measure air particulate Once enough data is obtained the RSO will identify one or more locations for permanent inclusion in the routine air particulate monitoring program It is expected at this time that there will be at least one permanent air particulate monitoring location in the Circuit However there may be one permanent sampling location for each separate DAC area of the Circuit In addition the RSO currently plans to reactivate into the routine monitoring program air particulate monitoring location BA-31 which is located in the nearby vanadium oxidation circuit The number of air particulate monitoring areas their specific locations and OENISONDAA MINES whether or not BA-3 is reactivated into the routine monitoring program will depend on the analysis of data collected from the portable air particulate monitoring samplers and the final determination of DAC areas for the Circuit 2.3.3 Area Radon Monitoring Stations Radon monitoring will be conducted via Modified Kusnetz sampling and counting methods whereby samples for Working Level determination will initially be collected in the same locations specified for the portable air particulate monitoring sampling The samples will ultimately be collected at the same locations as the permanently assigned air particulate sampling locations 2.3.4 Breathing Zone Samples The RSO will also place breathing zone monitors on selected personnel at the outset to provide supplemental information on air particulate in the work areas 2.3.5 Gamma Detectors gamma ball is located in the nearby boiler room as part of the monitoring program for existing Mill operations Additional gamma balls have been placed at the following locations in the Circuit At the drum dumping station on the south side of the Circuit At the digest/precipitation tank on the south side of the Circuit and At central location on the north side of the Circuit near the product holding tank which is likely to have the most radioactive material on the north side of the Circuit In addition each worker will wear his or her personal dosimeter 2.3.6 Shielding No additional shielding has been designed into the Circuit Whether or not shielding will be required for any particular alternate feed material will be determined on case-by-case basis 2.3.7 Areas Posted as Radiation Areas No areas of the Circuit will be posted as Radiation Areas per se The RSO will monitor each area of the Circuit for each alternate feed material being processed through the Circuit and will make determination if any areas need to be posted as Radiation Areas on case-by-case basis 2.3.8 Bioassays Bioassays will be performed as required and at the frequency specified in the Radiation Protection Manual For the initial alternate feed material the UF4 material bioassays will be performed on all workers in the Circuit at the frequency required for yellowcake workers This OENISONA MINES will provide good initial data base to compare the effectiveness of the other methods of monitoring employed at the Circuit 2.4 Personal Protective Equipment Personal Protective Equipment PPE will vary from alternate feed material to alternate feed material and within each node step in the process for any particular alternate feed material The appropriate PPE is evaluated for each alternate feed material and either specified in new SOP for the alternate feed material or in Radiation Work Permit and/or Safe Work Permit for the feed material In addition the required PPE for any feed material or step in the process may change over time as determined by the Mills RSO and/or Safety Coordinator Such changes would typically be evidenced by changes to SOPs or changes to Radiation Work Permits and/or Safe Work Permits For the UF4 alternate feed material the following PPE is currently required Drum Dumping Node Rubber gloves Tyvex coveralls and hood rubber boots lead apron and full face respirator 14 UF4 Carbonate Digestion Node Rubber gloves rubber boots wet suits and respiratory protection NaOH Precipitation Node Rubber gloves rubber boots and splash gear NaOH Precipitate Filtration Node Rubber gloves rubber boots splash gear and respiratory protection Filter Cake Acid Re-Dissolution Node Rubber gloves rubber boots and splash gear Filtration After Acid Digestion of Filter Cake Node Rubber gloves rubber boots respiratory protection and splash gear Impurity Removal Node Rubber gloves rubber boots respiratory protection and splash gear OENISONOA MINES INTERROGATORY STA TEMENT ALTERNATE FEED Provide list of approved alternate feed material that Denison Mines will no longer be accepting Include an updated list of approved alternate feeds with their corresponding License Condition Denison Response Denison has concluded that it is unlikely that further shipments of the following alternate feed materials will be accepted at the Mill Cotter concentrates License condition 10.8 Ashland Formerly Utilized Sites Remedial Action Program FUSRAP materials License condition 10.10 and Ashland FUSRAP materials License condition 10.12 The following is an updated list of approved alternate feed materials with their corresponding License conditions after excluding the foregoing feed materials Alternate Feed Material Current License Condition Allied Signal CaF2 10.6 Allied Signal KOH 10.7 Cabot 10.9 Cameco UF4 Regen Materials Calcined Byproduct and KF Materials 10.11 St Louis FUSRAP materials 10.13 Linde FUSRAP materials 10.14 W.R Grace 10.15 Heritage 10.16 Molycorp 10.17 Maywood FUSRAP materials 10.18 FMRI 10.19 INTERROGATORY STATEMENT RELEASE SURVEYS Procedure End Dump Trailer Acceptance Handling and Release PBL-9 Rev No R-O that was provided in Round response The procedure does not instruct the mills radiation safety technicians on the radiation survey techniques or documentation requirements used by the mill to release ore trucks from the restricted area Provide procedure that instructs radiation safety technicians on how to peiform and document radiological surveys Denison Response Sections 5.0 and 6.0 of the End Dump Trailer Acceptance Handling Release Procedure address decontamination and release of equipment for restricted release and unrestricted release However those sections do not provide details on how the surveys are to be performed OENISONOAA MINES Denison will add new Section 6.0 to the Mills Radiation Protection Manual which will provide details on the actual survey procedures See the response to Interrogatory Statement below In order to better tie in this new Section 6.0 of the Radiation Protection Manual to the End Dump Trailer Acceptance Handling Release Procedure we will amend paragraph of each of Sections 5.0 and 6.0 of that procedure to read as follows changes marked Section 5.0 paragraph The Radiation Technician or RSO will scan the trailer truck and tires in various locations as shown on the Equipment Survey for Restricted Release copy attached and document the scan readings on the Equipment Survey for Restricted Release The contamination survey will be performed using appropriate radiological instrumentation for total activity in accordance with DOT transportation regulations and the procedures set out in Section 6.0 of the Mills Radiation Protection Manual The release standards to be met for restricted release are contained in U.S Department of Transportation DOT Part 49 CFR 173.441b and 173.443 copies attached Section 6.0 paragraph The Radiation Technician will perform radiological contamination survey of the truck and trailer in accordance with the procedures set out in Section 6.0 of the Mills Radiation Protection Manual If the Radiation Technician indicates areas that require further decontamination decontaminate those areas as necessary INTERROGATORY STATEMENT RELEASE SURVEYS Procedure Intennodal Container Acceptance Handling and Release PBL-2 Rev No R-O that was provided in Round response The procedure does not instruct the mills radiation safety technicians on the radiation survey techniques and documentation requirements used by the mill to release ore trucks from the restricted area Provide procedure that instructs radiation safety technicians on how to peiform and document radiological surveys Denison Response Sections 5.0 and 6.0 of the Intermodal Container Acceptance Handling Release Procedure address decontamination and release of equipment for restricted release and unrestricted release However those sections do not provide details on how the surveys are to be performed Denison will add new Section 6.0 to the Mills Radiation Protection Manual which provides details on the actual survey procedures See the response to Interrogatory Statement below In order to better tie in this new Section 6.0 of the Radiation Protection Manual to the Intermodal Container Acceptance Handling Release Procedure we will amend paragraph of Section 5.0 and paragraph of Section 6.0 of that procedure to read as follows changes marked OENISONOAA MINES Section 6.0 paragraph The Radiation Technician or RSO will scan the IMC chasses tires and White Mesa Mill truck in various locations as shown on the IMC Container Survey for Restricted Release attached and document the scan readings on the Container Survey for Restricted Release The contamination survey will be performed using appropriate radiological instrumentation for total activity in accordance with DOT transportation regulations and the procedures set out in Section 6.0 of the Mills Radiation Protection Manual The release standards to be met for restricted release are contained in U.S Department of Transportation DOT Part 49 CER 173 .441b and 173.443 copy of which is attached Section 5.0 paragraph The Radiation Technician will perform radiological contamination survey of the IMQ chassis and tires in accordance with the procedures set out in Section 6.0 of the Mills Radiation Protection Manual If the Radiation Technician indicates areas that require further decontamination decontaminate those areas as necessary INTERROGATORY STATEMENT RELEASE SURVEYS Round One Interrogatory Statement 16 Release Surveys for Product Drums Explain how the survey techniques the release standards used and documentation of surveys of Product Drums that contain radioactive material are sufficient to demonstrate regulatory compliance and maintain public health and safety Explain why surveying techniques such as the use of Large Area Wipes or swipes to look for removable contamination are not being used on all Product Drums being surveyed for release 49CFR 173.4431 Contamination Control requires removable contamination survey on EACH package Change product drum survey procedures to reflect the regulatory requirement Denison Response Removable contamination is currently surveyed on each product drum as required by 49 CER 173.4431 The level of non-fixed removable radioactive contamination on the external surfaces of each product drum offered for transport is determined by the same methods as for ore trucks and IMCs i.e by comparing survey for total fixed and removable alpha contamination to the standard for removable contamination alone which is an other method of equal or greater efficiency contemplated by 49 CFR 173.443 See the response to Interrogatory Statement below However the wording in Section 2.7 of the Mills Radiation Protection Manual for uranium product shipments and in the Mills procedure Release and Shipping of Vanadium Blackflake No PBL.-15 Book 10 the Vanadium Release SOP for vanadium product shipments does not make this clear Denison proposes to amend those procedures to more accurately describe the actual procedures OENISOJA MINES 10 Section 2.7 of the Radiation Protection Manual will be amended to read as follows changes over the current version are marked 2.7.5 Uranium Concentrate Shipments The procedures for exclusive use uranium concentrate shipments are Inspect each product barrel that makes up the consigned shipment for leaks holes in the barrels cleanliness etc Barrels requiring repair shall be repaired prior to the radiation survey Perform fixedtotal i.e fixed and removable alpha survey of each barrel using the procedures and equipment specified in Section 6.0 The release limits for fixedtotal fixed and removable alpha radiation contamination is an average of 5000 dpm/100 cm2 and maximum of 15000 dpmJlOO cm2 Any barrel that exceeds 1000 dpm/100 cm2 fixed alpha radiation contamination requires removable alpha smear/wipe test to be performed Perform removable alpha survey of each barrel exceeding 1000 dpm/100 cm2 fixedtotal alpha contamination The release limit for removable alpha radiation contamination is 1000 dpm/100 cm2 Perform smear/wipe test and analyze filters for removable alpha on 25%of the barrels at minimum and perform smear/wipe test and analyze the filters for removable alpha on any barrels that exceed 1000 dpmllOO cm2 total alpha contamination Similarly Section 5.5.1 of the Vanadium Release SOP will be amended to read as follows changes over the current version are marked 5.5.1 Alpha Surveys Perform total i.e fixed and removable fixed alpha survey of each drum using the procedures and equipment specified in Section 6.0 of the Mills Radiation Protection Manual The release limits for total fixed and removable alpha radiation contamination is an average of 5000 dpm/100 cm2 and maximum of 15000 dpm/100 cm2 Any drum that exceeds 1000 dpm/lOOcm2 fixedg alpha radiation contamination requires removable alpha smear/wipe test to be performed Perform removable alpha survey on any barrel exceeding 1000 dpm/100 cm2 fixed4 alpha contamination The release limit for removable alpha contamination is 1000 dpm/100 cm2 Perform smear/wipe test and analyze filters for removable alpha on 25%of the barrels at minimum and perform smear/wipe test and analyze the filters for removable alpha on any barrels that exceed 1000 dpm/100 cm2 fixedtotal contamination DENISOJAA MINES 11 Record the results of the foregoing alpha surveys on the attached Source Material Assay and Radiological Survey of Vanadium Form and Any drums with visible contamination are to be cleaned prior to release INTERROGATORY STATEMENT --RELEASE SURVEYS Provide procedure that instructs radiation safety technicians on how to perform and document radiological surveys for releasing equipment from the Mills restricted area Denison Response The Mill is currently preparing written procedure for performing and documenting radiological surveys for releasing trucks intermodal containers other equipment and product drums from the Mills restricted area which will be new Section 6.0 of the Mills Radiation Protection Manual Denison will submit the new Section 6.0 for Executive Secretary review within 30 days after the date of this letter INTERROGATORY STATEMENT RELEASE SURVEYS Round One Interrogatory statements 14-17 Explain how the survey techniques the release standards used and documentation of surveys of Equipment are sufficient to demonstrate regulatory compliance and maintain public health and safety Explain why surveying techniques such as the use of Large Area Wipes and swipes to look for removable contamination are not being used on all items being surveyed for release In response to the method outlined in 49 CFR 173.4431a Denison Mines states Using portable alpha detection equipment that measures the combined fixed and removable contamination is therefore another method contemplated by paragraph which is 49CFR 73.4431b above of equal or greater efficiency because the Mill applies the removable contamination standard to combined reading offixed and removable contamination Provide efficiency calculations to determine the efficiency of this method Include the survey procedure used the efficiency of the meters and probes used in relation to U-238 Show that the meters and probes that are/will be used has the appropriate sensitivity to provide small enough reading to measure the required release limits Denison Response 8.1 Method of Scanning Denison scans ore trucks intermodal containers product drums and other equipment using the following techniques and equipment Restricted Release Ore trucks intermodal containers chassis and other equipment that are exclusive use and are dedicated to particular project i.e will be returning to the Mill or another licensee for final decontamination prior to free release are released from the Mills restricted area in accordance DENISONOAA MINES 12 with the release standards set out in 49 CFR 173.443 That standard is 22 dpm/cm2 or 2200 dpm/lOOcm2 for non-fixed radioactive contamination Mill radiation safety staff determines compliance with this standard by performing scan for total contamination both fixed and removable using Ludlum Model counter with attached alpha/beta pancake probe or the equivalent The probe has 15 cm2 detection face The survey results for total fixed and removable contamination are then compared to the standard for removable alpha contamination if the scan shows 2200 dpm/lOOcm2 or more the piece of equipment is sent back for secondary decontamination and then resurveyed In fact Mill practice is to send piece of equipment back for secondary decontamination if the instrument reads anything above non-detect The Ludlum Model counter also measures beta/gamma activity on separate scale simultaneously with the total measurements thereby allowing Mill radiation safety staff to determine compliance with applicable beta/gamma release standards at the same time Unrestricted Release Ore trucks chassis intermodal containers reagent delivery trucks and all other equipment as well as product drums that are released from the Mills restricted area on an unrestricted basis are released in accordance with the standards set out in NRCs Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Tennination of Licenses for Byproduct Source or Special Nuclear Material Division of Fuel Cycle and Material Safety USNRC Washington DC 20555 That standard is 1000 dpm/lOOcm2 for non-fixed alpha contamination Mill radiation safety staff determines compliance with this standard by performing scan for total alpha contamination both fixed and removable using Ludlum Model 177 counter with 43-1 alpha detection probe or the equivalent The probe has 75 cm2 detection face The survey results for total fixed and removable alpha contamination are then compared to the standard for removable alpha contamination if the scan shows 1000 dpm/lOOcm2 or more the piece of equipment or drum is sent back for secondary decontamination and then resurveyed In addition to scanning for total alpha contamination with the Ludlum Model 177 counter Mill radiation safety staff also performs second scan of the equipment or drums with handheld gamma meter in order to determine compliance with applicable beta/gamma release standards 8.2 MDA Assessment The minimum detectable activity MDA is defined as the smallest concentration of radioactivity in sample that can be detected with 5%probability of erroneously detecting radioactivity when in fact none was present Type error and also 5%probability of not detecting radioactivity when in fact it is present Type II error IIDA is often used interchangeably with Minimum Detectable Concentration since the difference between the two terms is only one of units conversion MDA equations for survey instruments and counters are specified in NRCs NUREG 1507 Minimum Detectable Concentrations With Typical Radiation Survey Instruments for Various Contaminants and Field Conditions In order to assess Denisons equipment OENISONAA MINES 13 Equation 3-10 described below was applied to data provided by Mill radiation safety staff on August 2009 Equation 3-10 MDC 4.65VTh KT Where CB is the background count for paired observations of the sample and blank is the proportionality constant which includes adjustments for detection efficiency and probe geometry As mentioned above for surveys relating to restricted exclusive use containers Denison uses the Ludlum Model counter with attached alpha/beta pancake probe The August 2009 data for this instrument include the following Probe Size 15 cm2 15%of the Detection Area of Concern Probe Sensitivity when compared to calibration source 26% Detection Area to be considered 100 cm2 Background Count 180 cpm Background Count Time minute Given these data the Model with pancake probe MDA calculation is 4.65VTh 4.65 13.42 1677 dpmIlOO cm2 10.260.15 0.039 Given that the Model with pancake probe is only used for exclusive use restricted containers where Denison has adopted release standard of 2200 dpm/100 cm2 the instrument is sufficiently sensitive to find contaminants at that level of radioactivity As mentioned above for surveys relating to unrestricted free release for general transport and other equipment which is being release for unrestricted use Denison uses Ludlum Model 177 counter with 43-1 alpha detection probe The August 2009 data for this instrument include the following Probe Size 75 cm2 75%of the Detection Area of Concern Probe Sensitivity when compared to calibration source 24% Detection Area to be considered 100 cm2 Background Count 20 cpm Background Count Time minute Given these data the Model with pancake probe MDA calculation is 4.65V 34.65 x4.47 132 dpm/100 cm2 10.240.75 0.18 DENISONOAA MINES 14 Given that the Model 177 with 43-1 probe is used for unrestricted free release where Denison has adopted release standard of 1000 dpmIlOO cm2 the instrument is sufficiently sensitive to find contaminants at that level of radioactivity In conclusion the instruments used by Denison for releasing equipment and product drums from the Mill site have the appropriate sensitivity to provide small enough reading to measure the required release limits It should also be kept in mind that there is an added level of conservatism in Denison approach in that the instruments are reading total alpha and beta fixed and removable in the case of restricted release surveys and total fixed and removable alpha contamination in the case of unrestricted release surveys yet in both cases the survey results are compared to the standard for removable alpha contamination only INTERROGATORY STATEMENT ALARA Round One Interrogatory Statement 18 Designated Eating Areas within the Restricted Area Explain the just jfication of having designated eating areas and the number of eating areas within the restricted area and Statement 19 Designated Eating Area within the Restricted Area Define the criteria used for determining designated eating areas within the Restricted Area Define what controls each Designated Eating Area must have i.e frisking requirements wash facilities Entry Procedures etc to be suitable Designated Eating Area Denison Reponse The Mill has amended its ALARA Program relating to designated eating areas within the Mills restricted area after taking into account previous comments and recommendations made by the State of Utah Division of Radiation Control DRC and suggestions made by the Mills ALARA Committee The ALARA Program now spells out in more detail the criteria that must be applied by the Mills RSO in designating an eating area Specifically each designated eating area must now meet all of the following criteria located in an area where work with uranium is not performed and there is little likelihood of contamination wash facilities are located close by to allow workers to wash their hands etc prior to entering the designated eating area scanning machines are placed at each entry into the designated eating area and each worker entering designated eating area must perform and record personal alpha scan in the same manner as if the worker were leaving the Mills restricted area and must be free of contamination prior to entering the designated eating area copy of page of the Mills ALARA Program marked to show these changes and clean copy of that page are included as Appendix to this letter Based on these new criteria the RSO has now reduced the number of designated eating areas in the Mill to two areas within the restricted area based on the foot traffic in the areas the relationship to operations both mechanical and process access to wash stations and the ability to control access to the areas with personnel alpha monitors DENISONDI MINES 15 The first designated eating area is the existing Lunch Room/Training Room This area is limited to foot traffic of workers going to break or training sessions The room has access to wash facilities in the Change Rooms located directly below on the ground floor With the Change Rooms below this designated eating area the employees can change out of PPE wash and then proceed to the lunch room An additional scanner has been added at the north door scanner already exists at the south door Individuals coming from the Warehouse through the north door will now be required to scan at that location prior to entry into the room The second designated eating area is the area above the Warehouse offices There is only one entrance into this designated eating area Foot traffic in the area is low The Maintenance Superintendant and both Operation Foremen have their offices in this area In between the offices is small break room The break room is for supervisory personnel only There is wash station directly below the area personal alpha meter is located just inside the door DUSA has provided training to all of Mill workers on the changes to this program Every worker has been instructed on the proper activities regarding these designated eating areas Each worker has been instructed to enter the areas as if they are exiting the Mills restricted area That is every time someone enters designated eating area he or she must frisk no matter what the circumstance The other areas that were previously listed as designated eating areas the Warehouse Offices Maintenance Offices Instrument Shop Scalehouse Central Control Room and the offices in the Chemical and Metallurgical laboratories have now been removed as designated eating areas by memorandum issued by the RSO However these former designated eating areas will continue to be monitored on weekly basis for alpha contamination INTERROGATORY STATEMENT EMPLOYEE TRAINING 10 In the revised White Mesa Mill Radiation Safety Training Program Appendix Radiation Protection at the White Mesa Mill Section Types of Radiation There are five types of ionizing radiation Alpha Beta Gamma X-Ray and Neutron All forms of ionizing radiation should be mentioned and then be spec ffic on what types of ionizing radiation are found at the Mill Denison Response Section of Appendix to the White Mesa Mill Radiation Safety Training Program has been amended to mention all forms of ionizing radiation and to better identify the types of ionizing radiation found at the Mill copy of the revised Appendix marked to show the changes is attached as Appendix to this letter INTERROGATORY STATEMENT EMPLOYEE TRAINING 11 In the revised White Mesa Mill Radiation Safety Training Program Appendix Radiation Protection at the White Mesa Mill section 43 Gamma Radiation This section does not discuss the three 3fixed nuclear gauges that the mill uses Include discussion on the fixed gauges in this section OENISONI4A MINES 16 Denison Response Section of Appendix to the White Mesa Mill Radiation Safety Training Program has been amended to discuss the three fixed nuclear gauges that the Mill uses copy of the revised Appendix marked to show the changes is attached as Appendix to this letter INTERROGATORY STATEMENT STANDARD OPERATING PROCEDURES 12 Round One Interrogatory Statement 28 Provide complete list and copies of all operating procedures used at the MilL Explain how employees are trained on the procedures that they use Explain where procedures are kept and how employees have access to the procedures that they use Provide missing procedures There are Standard Operating Procedures that are missing from the application The following are examples but not limited to of procedures that are missing from the application The Respirator Protection Program and the ALARA Program references NRC Reg Guide 8.15 and UAC R313-.15-703 lists all of the procedures required in Respirator Protection Program The Mills Respirator Protection Program is missing some of these procedures Denison Response Denison is currently reviewing the Mills Respiratory Protection Program for compliance with the requirements of NRC Reg Guide 8.15 and UAC R313-15-703 to identify any required procedures that are not contained in that program Denison will submit revised Respiratory Protection Program to the Executive Secretary for review within 45 days after the date of this letter INTERROGATORY STATEMENT REVISIONS AND UPDATES 13 Round One Interrogatory Statement 36 Provide all revisions to procedures and programs that have been added or revised since February 2007 License renewal application was submitted Also provide all procedures and programs that were not included with the February 2007 License renewal application Provide the list below Denison Response Attached to this letter as Appendices to are the following Mill procedures and related documents PBL-3 Tailings Capacity Evaluation R-9/25/00 Appendix Section 3.1 White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT Monitoring Plan DUSA 9/01/08 Appendix RPP-1 Respiratory Protection Program DUSA-.2 12/1/08 Appendix Groundwater Monitoring Plan and Standard Operating Procedures for UDEQ Split Sampling Program Rev 27/1/99 Appendix PBL-RP-1 Radiation Monitoring-Personnel DUSA-3 8/1/08 Appendix PBL-RP-3 Equipment Calibration DUSA-2 12/1/08 Appendix UDEQ Split Sampling Groundwater QA Project Plan Rev 7/99 Appendix DENISONOAA MINES 17 GWDP Groundwater Monitoring Quality Assurance Plan QAP DUSA 6/18/08 Appendix Cell 4A BAT Monitoring Operations and Maintenance Plan DUSA 1.3 9/1/08 Appendix PBL-4 Clearance of Linde Material Intermodal Containers R-0 3/15/01 Appendix and PBL-6 Heritage Alternate Feed Management R-1 2.14.03 Appendix The Mill had generic Quality Assurance Program years ago However that program is no longer in existence It has been replaced by specific Quality Assurance provisions inserted in individual SOPs where appropriate and for groundwater sampling by the Mills Groundwater Monitoring Quality Assurance Plan SECTION ENGINEERING COMMENT INTERROGATORIES ROUND INTERROGATORY STATEMENT The Reclamation Plan I-A The currently approved latest Reclamation Plan needs to receive unique identifying number as to the version of the plan it is The DRC request that DUSA assign version number e.g 4.0 to the currently approved reclamation plan If there are iterative changes necessary to the plan as result of these License Renewal Application comments each DUSA proposed revision to the plan must be identWed by unique reference number e.g suffix to the number such as proposed Revision 4.1 4.2 etc The updates to the Reclamation Plan conveyed by DUSA letter dated July 25 2008 were not included in the License renewal Application They need to be included Denison Response Denison is in the process of preparing an updated version of the Reclamation Plan which will be assigned the number Revision 4.0 Revision 4.0 of the Reclamation Plan will consolidate all amendments to the Plan that have been made since Revision 3.0 was approved by NRC on July 24 2000 Revision 4.0 will also include the current approved versions of all drawings and figures and will make number of other corrections and updates referred to in the following interrogatory statements Denison will submit Revision 4.0 of the Reclamation Plan to the Executive Secretary as new Appendix to the 2007 License Renewal Application within 90 days after the date of this letter Future amendments to the Reclamation Plan will be numbered and dated so that they can be easily identified and tied to the then current version of the Reclamation Plan For example if section of the Reclamation Plan is revised that section will be given revision number and date such as Section 6.0 Revision 4.1 January 15 2010 Each revised page will have the revision number and date of the revision in the footer or header of the page However given the size of the Reclamation Plan and appendices figures and drawings Denison does not anticipate renumbering and re-issuing the entire Reclamation Plan every time section of the Plan is OENISONDAA MINES 18 amended sheet will be inserted at the beginning of the Reclamation Plan that will identify all amendments made to the Plan since the date of issue of Revision 4.0 of the Plan The sheet will list the Sections that have been revised the date of each revision and the revision number for that Section This will allow reader to keep track of all amendments to the Plan and will allow Denison and the Executive Secretary to determine if any particular copy of the Reclamation Plan is current INTERROGATORY STATEMENT The Reclamation Plan I-B Please update and complete Section of the License Renewal Application regarding the Reclamation Plan Please include the current approved version of the Reclamation Plan as an Appendix to the License Renewal Application Denison Response Revision 3.0 of the Reclamation Plan was incorporated by reference into the 2007 License Renewal Application as permitted by R313-22-325 and was not included as an Appendix to the application due to its size That is why it is not referred to in the Index to the Appendices in the License Renewal Application However as mentioned in the response to Interrogatory Statement I-A Denison is preparing an updated Revision 4.0 of the Reclamation Plan which Denison will submit as new Appendix to the 2007 License Renewal Application revised Index to the Appendices will be included in Revision 4.0 of the Reclamation Plan We have amended page 74 of the 2007 License Renewal Application to address the blank field We have not made any other changes to that page because the dollar amount of the financial surety was accurate at the date of filing the application Attached as Appendix is revised page 74 to the 2007 License Renewal Application marked to show changes and clean version INTERROGATORY STATEMENT The Reclamation Plan I-C Regarding the Cell Discharge Channel on Figure -2.2.4-1 Sedimentation basin Detail The potential need for or absence of rip-rap protection for the cell discharge channel entry and exit platform aprons must be explained and justified An adequate demonstration will include but is not limited to analysis according to NUREG-623 The need to join or not join the existing configuration the discharge channel to the toe of the new south dike of Cell must be explained and justjfied Drawing details are needed to show the outcome of the above analysis to describe the sections of the discharge channel its lining appurtenant entry exit apron zones dike alignment and lining Denison Response The Cell Discharge Channel is intended to divert the water accumulated from the PMP storm event from 143 acre area which includes the sedimentation basin created from the Cell area the reclaimed Mill area and the area to the north of the Cell area but south of the existing DENISONOAA MINES 19 diversion ditches The channel is created by excavation of the undisturbed ground to the west of Cell to maximum depth of approximately 17 feet The lower 10 feet of the channel is excavated in Dakota Sandstone to an elevation matching the lowest point on the west end of the Cell sedimentation basin The channel will be excavated at slope of 1%and will daylight in the Dakota Sandstone cliffs in Westwater Canyon cross section of the area to be excavated is included in Appendix to this letter The maximum discharge volume through the channel will be 1344 cubic feet per second resulting in flow velocity of 7.45 feet per second assuming bottom channel width of 120 feet The channel design proposed in the reclamation plan is actually 150 feet wide at the bottom which will further reduce the flow velocity The allowable flow velocity for bedrock channel is -10 feet per second therefore no riprap is required in the channel bottom The entrance to the channel will match the bottom elevation of the sedimentation basin so no riprap will be necessary at that point The channel discharge will be on to the cliffs of Westwater Canyon therefore no riprap will be necessary at that point The discharge calculations are included in Attachment to the Reclamation Plan and also included in Appendix to this letter We do not believe that the discharge channel should be joined with the toe of the new fill area on the north slope of the Cell dike The flows off the dike slope will be very small and the rip rap toe will easily protect the slope and the reclamation cover The flow velocities at the entrance to the discharge channel could possibly impact the rip rap toe or require additional rip rap and should therefore be avoided Water potentially backing up from the entrance to the discharge channel would be very low velocity in the area near the toe of the Cell north slope and would not impact the stability of the slope INTERROGATORY STATEMENT The Reclamation Plan I-D This interrogatory is being provided for USA information only This item will be pursued concurrent with DRC review of the Infiltration and Contaminant Transport Modeling Report White Mesa Mill Site Blanding Utah ICTM prepared by DUSA Last correspondence on the report was furnished by DUSA on April 30 2009 Is installation of rock apron at the base of all the final covered tailings cell outslope intended for the entire perimeter of the final covered tailings cell system If so please clarify by specifying on the drawings that such is required If not please demonstrate that the absence of such will be adequate for the 1000-year design period or at minimum 200-year period Denison Response The questions raised in Interrogatory Statement I-D will be addressed in the re-design of the tailings cover system in accordance with the approved ICTM OENISONOAA MINES 20 INTERROGATORY STATEMENT The Reclamation Plan I-E Please demonstrate that for final reclamation of the tailings cells filter blanket is necessary or unnecessary to be installed below the riprap cover for the top side slopes and rock aprons of the tailings cells Denison Response It is not clear why filter blanket was not included in the original cover design As noted by DRC Denison is proposing revised cover design as part of the Infiltration Analysis which will eliminate the rip rap on the top surface of the reclaimed tailings The need for filter blanket on the side slope and toe areas will be evaluated at that time INTERROGATORY STATEMENT The Reclamation Plan I-F Reclamation Plan Fig 3.2.3-1 Site Map Showing Locations of Buildings and Tankage needs to be updated to current conditions Denison Response An updated version of Reclamation Plan Fig 3.2.3-1 Site Map Showing Locations of Buildings and Tankage updated to current conditions will be included in Revision 4.0 of the Reclamation Plan See the response to Interrogatory Statement I-A for more detailed discussion of Revision 4.0 of the Reclamation Plan INTERROGATORY STA TEMENT The Reclamation Plan I-G In the DRC copy of the Reclamation Plan Appendix Attachment Rainfall-Duration Curve for One-hour PMP at White Mesa Mill is illegible Please provide readable copy of the graph Denison Response readable copy of Reclamation Plan Appendix Attachment Rainfall-Duration Curve for One-hour PMP at White Mesa Mill is attached as Appendix to this letter INTERROGATORY STATEMENT The Reclamation Plan I-H Numerous references to the NRC in the Reclamation Plan must be changed to the Utah Division ofRadiation Control DRC general overriding amendment to the Reclamation Plan may best satisfy this need E.g according to the last sentence on B-2 The report will be submitted to the NRC Regulatory Commission Paragraph 1.4 1.2 on B-3 and paragraph 1.5 on B-6 also refer to the NRC OENISOJAA MINES 21 Denison Response All references to NRC in the Reclamation Plan will be changed to be references to DRC the State of Utah Department of Environmental Quality or the Executive Secretary as appropriate in Revision 4.0 to the Reclamation Plan See the response to Interrogatory Statement 1-A for more detailed discussion of Revision 4.0 of the Reclamation Plan INTERROGATORY STATEMENT The Reclamation Plan I-I In the Reclamation Plan on pp B-2 and B-16 the Final Construction Report is referred to This report is important to independently document the completion of the reclamation and decommissioning work In that regard please revise the Reclamation Plan to include the following Please remove any reference to NRC/DRC field presence in the Reclamation Plan The report must be submitted to the DRC within 180 calendar days after the apparent completion of Construction for Executive Secretary review and approval Denison Response The requested changes will be included in Revision 4.0 of the Reclamation Plan See the response to Interrogatory Statement I-A for more detailed discussion of Revision 4.0 of the Reclamation Plan INTERROGATORY STA TEMENT The Reclamation Plan LI It appears the current Table of Contents TOC in the Reclamation Plan Revision 3.0 is taken directly from Revision 2.0 which is now outdated The actual content and page numbers of the plan were revised in Revision 3.0 Additional content changes to the plan as result of review of the current license renewal application are expected Adjustments to the current TOC in the Reclamation Plan are needed to bring the table up to date final adjustment will need to be done at the end of the review iterations for the license renewal application Denison Response The Table of Contents of the Reclamation Plan will be updated in Revision 4.0 of the Reclamation Plan See the response to Interrogatory Statement I-A for more detailed discussion of Revision 4.0 of the Reclamation Plan INTERROGATORY STA TEMENT The Reclamation Plan I-K The Reclamation Plan refers to work in Tailings Cells 123 and sometimes Cell 4A However the plans and specifications for the reclamation of Cell 4A are not always included in the Reclamation Plan written text and drawings OENISON9A MINES 22 Additions to the Reclamation Plan are needed to include provisions for the reclamation of Cell 4A into the plans and specifications Provisions for Cell 4A need to be incorporated into the Reclamation Plan Table of Contents TOC as well as the plans and specifications Denison Response Revision 4.0 of the Reclamation Plan will include additions relating to the reclamation of Cell 4A into the written text plans and specifications The Table of Contents of the Reclamation Plan will be updated accordingly See the response to Interrogatory Statement I-A for more detailed discussion of Revision 4.0 of the Reclamation Plan INTERROGATORY STATEMENT The Reclamation Plan I-L The tailings cell cover design found in the Reclamation Plan provided with the February 28 2007 License Renewal Application is not the same as that provided in the November 21 2007 Infiltration and Contaminant Transport Modeling Report White Mesa Site Blanding Utah prepared by MWHAmericas Inc It will be DUSAs responsibility to amend the License Renewal Application and the Reclamation Plan to ensure that the tailings cells cover design plans specifications and construction ultimately authorized conforms to the approved ICTM Denison Response The Reclamation Plan and to the extent applicable the 2007 License Renewal Application will be amended to ensure that the tailings cell cover design plans specifications and construction ultimately authorized conform to the approved ICTM Denison expects that the resulting changes to the Reclamation Plan may be significant and may justify the creation of Revision 5.0 of the Reclamation Plan in order to properly incorporate the changes into the Plan INTERROGATORY STATEMENT The Reclamation Plan H-A The application states that license violations identified during NRC or State of Utah site inspections are listed However not all violations are listed Please include listing of all violations of your Ground Water Quality Protection Permit Denison Response Denison disagrees with the foregoing statement All violations including violations under the Mills State of Utah Groundwater Discharge Permit Air Approval Order and Radioactive Materials License as of February 28 2007 the date of submittal of the 2007 License Renewal Application are listed in Table 9.2-1 of Volume of the Application These violations are also discussed in Sections 9.2.1 9.2.2 and 9.2.3 of Volume of the Application Specifically Section 9.2.3 entitled Water Quality Notices of Violation addresses the 11 violations issued on or before February 28 2007 under the Mills Groundwater Discharge Permit There have been number of violations under the Mills Radioactive Materials License Groundwater Discharge Permit and Air Approval Order since February 28 2007 However OENISONOA MINES 23 since the disclosure in the 2007 License Renewal Application is as of February 28 2007 these have not been addressed here INTERROGATORY STATEMENT Correction of Modelinjj Inferences H-B There is no paragraph 3.13.1.6 in the Environmental Report ER This reference must be corrected License Renewal Application Paragraph 6.5.8 should clearly state that the statement is based on modeling predictions License Renewal Application Paragraph 6.5.9 should clearly state that the statement in the paragraph is based on modeling predictions Denison Response The requested changes have been made to page 65 of the 2007 License Renewal Application revised page 65 marked to indicate the changes and clean copy are attached as Appendix to this letter INTERROGATORY STATEMENT Correct Version of Documents H-C The SWBMPP provided as tab in Appendix of the License Renewal Application is not the approved version Please replace with the June 2008 edition that was approved by the DRC on July 2008 Denison Response Attached as Appendix is the June 2008 edition of the Storm Water Best Management Practices Plan that was approved by the DRC on July 2008 INTERROGATORY STATEMENT Correct Version of Documents II-D The edition of the White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT Monitoring Plan DMT Plan provided as tab 3.1 of Appendix of the February 28 2007 License Renewal Application is not the approved version Please replace it with the approved 09/08 Revision Denison-6 version of the plan and attachments Denison Response Attached as Appendix is the approved 09/08 Revision Denison-6 version of the White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT Monitoring Plan INTERROGATORY STATEMENT Omission of Document H-E The License Renewal Application appears to not contain the Cell 4A BAT Monitoring Operations and Maintenance Plan OM Plan Please include the latest approved edition in the application OENISONOAA MINES 24 Denison Response Attached as Appendix is version 09/08 Revision Denison 1.3 of the Cell 4A BAT Monitoring Operations and Maintenance Plan which is the latest approved edition of that plan An electronic version of this letter and Appendices will be transmitted under separate cover If you should have any questions or require additional information please contact the undersigned Yours very truly DENISON MINES USA CORP By David denlund Vice President Regulatory Affairs and Counsel cc Ron Hochstein Harold Roberts Steven Landau David Turk OENISONOs4A MINES 25 Circuit for Processing UF4 To Be Operated at theWhite Mesa Mill White Mesa Mill 2/07 Revision DUSA- Book 12 ALARA Program Page of 20 The RSO may have other safety related duties such as responsibility for programs of industrial hygiene and fire and safety but will have no direct production-related responsibility 1.1 Operating Procedures 1.1.1 Standard Operating Procedures Established The Mill is required to maintain written standard operating procedures or Radiation Work Permits RWPs for all activities that involve handling processing or storing radioactive materials as well as health physics monitoring sampling analysis and instrument calibration All such procedures include consideration of pertinent radiation safety practices to the extent not covered in the Radiation Protection Manual Respiratory Protection Manual or Environmental Protection Manual 1.1.2 Policy-for Eating Restricted Area Smoking is pprrnitted anywhere within the Mills Restricted Area Eating lunches or snacks or chewing tobacco is not allowed within the Restricted Area of the Mill except for those areas so designated by the RSO Such noted activity as observed results in supervisory review of employee actions documentation of the incident and retraining by the Radiation Safety Staff Repeated occurrences shall be cause for dismissal This policy is in effect to ensure that radiation and uranium ingestion exposures to Mill workers are maintained ALARA .hZ hiflhl The areas of the administrative office building except for the metallurgical laboratory and sample processing sections is located outside of the Mills Restricted Area are designated as an eating MeaT areas The Restricted Area designated eating areas are as designated by the RSO from time to time and may include Each designated eating area must satisfy the following criteria Scalehouse Warehouse Office Maintenance Office Change Room .-. Mill Office Lunchroom Chief Chemist Office Met Lab Office Training Room located in an area where work with uranium is not performed and there is little likelihood of contamination This page was revised on August 14 2009 White Mesa Mill 2/07 Revision DUSA Book 12 ALARA Program Page of 20 wash facilities are located close by to allow workers to wash their hands etc prior to entering the designated eating area scanning achines are placed at each entry into the designated eating area and each worker entering designated eating area must perform and record personal alpha scan iii the same manner as if the worker were leaving the Mills Restricted Area and musf be free of contamination prior to entering the designated eating area The designated eating areas are routinely monitored for alpha and beta-gamma contamination as provided in the Radiation Protection Manual This page was revised on August 14 2009 White Mesa Mill 2/07 Revision DUSA- Book 12 ALARA Program Page of 20 The RSO may have other safety related duties such as responsibility for programs of industrial hygiene and fire and safety but will have no direct production-related responsibility 1.1 Operating Procedures 1.1.1 Standard Operating Procedures Established The Mill is required to maintain written standard operating procedures or Radiation Work Permits RWPs for all activities that involve handling processing or storing radioactive materials as well as health physics monitoring sampling analysis and instrument calibration All such procedures include consideration of pertinent radiation safety practices to the extent not covered in the Radiation Protection Manual Respiratory Protection Manual or Environmental Protection Manual 1.1.2 Policy-for Eating Restricted Area Smoking is not permitted anywhere within the Mills Restricted Area Eating lunches or snacks or chewing tobacco is not allowed within the Restricted Area of the Mill except for those areas so designated by the RSO Such noted activity as observed results in supervisory review of employee actions documentation of the incident and retraining by the Radiation Safety Staff Repeated occurrences shall be cause for dismissal This policy is in effect to ensure that radiation and uranium ingestion exposures to Mill workers are maintained ALARA The areas of the administrative office building located outside of the Mills Restricted Area are designated as eating areas The Restricted Area designated eating areas are as designated by the RSO from time to time Each designated eating area must satisfy the following criteria located in an area where work with uranium is not performed and there is little likelihood of contamination wash facilities are located close by to allow workers to wash theft hands etc prior to entering the designated eating area scanning machines are placed at each entry into the designated eating area and each worker entering designated eating area must perform and record personal alpha scan in the same manner as if the worker were leaving the Mills Restricted Area and must be free of contamination prior to entering the designated eating area The designated eating areas are routinely monitored for alpha and beta-gamma contamination as provided in the Radiation Protection Manual This page was revised on August 14 2009 RADIATION PROTECTION AT THE WHITE MESA MILL Radiation High levels of radiation are harmful to us The amount of radiation person is exposed to is referred to as his or her dose and is typically measured in millirems mrems per year We are exposed to radiation from natural sources such as the sun the soils and rocks around us as well as the air we breathe We are also exposed to radiation from other sources such as x-rays performed in connection with medical and dental examinations In the landing area each member of the general population is exposed to about 400 mrem per year from these natural sources not counting things such as x-rays Exposure Limits In order to protect workers from excessive exposure to radiation the Nuclear Regulatory Commission NRC has set maximum doses that workers can receive each year from working at facilities such as the White Mesa Mill Under these standards the maximum total dose from all sources at the Mill over and above background radiation from natural sources is 5000 mrem per year In addition the NRC requires that each facility make efforts to keep exposures to workers As Low as is Reasonably Achievable ALARA below the 5000 mremlyr limit In accordance with this requirement the Mill has set an ALARA goal at 1250 mremlyr for each worker over and above natural background This goal is 25%of the regulatory standard of 5000 mremlyr Exposures to Mill workers are typically well below this ALARA goal being usually in the 80 mremlyr to 400 mremlyr range above background How do we Keep Exposures to Radiation to Minimum One of our prime objectives is to keep radiation exposures to Mill workers to minimum This not only requires the efforts of Denison It also requires the efforts of each Mill worker to keep his or her exposures to minimum In order for workers to be able to do this proper understanding of radiation how you can be exposed to it and what precautions you can take are extremely important These topics are summarized below Types of radiation There are three types of ionizing radiation alpha beta and gamma radiation being the prevalent sources of exposure at the Mill as well as x-ray and neutron radiation which are of lesser concern at uranium milling facilities 4.1 Alpha Radiation Here at the White Mesa Mill we work with uranium one of those elements that is naturally radioactive Uranium is an alpha emitter Alpha radiation doesnt travel very far even in air The range in air for alpha radiation is about 1.25 inches single sheet of paper can block alpha radiation Even the skin layer on our bodies stops alpha radiation So outside of our body alpha radiation is really no problem What about inside the body Breathing uranium dust or swallowing uranium dust is the problem Uranium in the human body tends to seek the bones and kidneys i.e to collect there where it can cause damage In addition radon gas which comes primarily from uranium ores and tailings emits alpha radiation and is in the air we breathe at the Mill There is no smell or taste to radon gas and you cant see it Breathing high levels of radon in the air is also harmful to us 4.2 Beta Radiation Beta radiation does not travel very far in air but it can penetrate the body so merely being close to source of beta radiation will result in exposure to radiation It is not necessary to breathe in or swallow beta emitting particles although that would also be another way that beta radiation could enter your body However because most of the radiation associated with the uranium process is alpha radiation beta radiation is not much of problem at the Mill While exposures to the body merely from being close to beta radiation are minimal at the Mill internal exposure to beta radiation that enters the body through inhalation or ingestion of radioactive dust is concern For example as uranium decays some beta radiation is emitted especially where aged yellowcake is concerned so personal hygiene in the yellowcake processing portion of the Mill is important 4.3 Gamma Radiation Gamma rays are constantly being emitted from the raw ore Like beta radiation gamma radiation can penetrate the body so being close to source of gamma radiation will result in exposure to radiation However gamma radiation is stronger can travel further in air and can penetrate the body more readily than beta radiation As with beta radiation it is not necessary to breathe in or swallow gamma emitting particles although that would also be another way that gamma radiation could enter your body Gamma radiation at the Mill is mainly associated with raw ores tailings solids and some alternate feed materials So the people working in the ore piles bucking room tailings or close to certain alternate feed materials should have the highest exposure to gamma radiation here at the Mill site In addition to these sources of gamma radiation there are nuclear density gauges in the Mill complex i.e one west of the CCD area on the exterior of the tails box and two in the SAG Mill area one of which is located east of the Derrick Screens on the level of the SAG facility and another on the first level of the SAG facility on the feed line to the east pre leach tank These gauges contain the gamma emitter Cs-137 The Cs-137 is retained in container which is in-turn housed within shielded containment referred to as the pig in order to provide protection to workers from the unshielded source These devices are labeled with the tn-foil radiation symbol and in-plant gamma surveys are conducted in the immediate area of these sources to assure that gamma radiation levels are maintained ALARA These sources of Cs-137 must remain in their shielded containment They must also be tested periodically However they may only be removed from their shielding tested serviced or removed from installation by specifically licensed outside contractor 4.4 X-Rays There are no direct sources of x-radiation at the Mill thus exposure to x-rays is minimal and only related to minor emissions of x-radiation associated with the uranium decay chain radiation is similar to gamma radiation in that it is penetrating and considered to be an external source of exposure to the body Because the Mills radiation safety staff measures gamma radiation and any x-rays will be an element of those readings the protections provided for gamma radiation also protect from the minor influence of x-rays at the facility For these reasons x-rays require no additional consideration at the Mill 4.5 Neutrons There are no sources of neutron radiation associated with the uranium milling process However when earthen construction projects are underway at the Mill such as tailings cell construction construction contract personnel may use neutron gauges to measure soil moisture and density conditions for construction purposes These devices are not owned or operated by Denison and any licensing of the gauges is the responsibility of such contractors As result Denison employee exposure to these sources is negligible and could only occur near the gauge when in operation 4.6 Radioactive Dust is the Main Concern at the Mill Site 4r4 As can he seen from the discussion above radiation that enters the body through the inhalation or ingestion of dust is the main concern at the Mill site Keeping dust to minimum and providing protections to workers to minimize their exposure to radioactive dust is therefore primary objective Radon is usually not problem unless in confined spaces Exposures from being close to beta/gamma radiation is also not usually as big concern at the Mill site due to the relatively low levels of those types of radiation found at the Mill X-rays and neutron radiation are of minor concern at the Mill Exposure Pathways and Precautions to be Taken Radiation can enter the body in three different ways 5.1 Being Close to Source of Gamma Radiation Being close to ore tailings or certain alternate feed materials will expose the worker to gamma and beta radiation The stronger the source the closer you are and the longer you spend close to the source will increase your exposure Shielding such as lead can be used in some circumstances to reduce exposures to gamma and beta radiation although shielding is not commonly used at the Mill due to the generally low beta/gamma radiation experienced at the Mill Each worker is required to wear an OSL badge that records his or her exposure to beta and gamma radiation The OSL badge must be worn on the torso and must not be shielded by clothing Areas where beta/gamma radiation is high i.e over mradfhr must be posted as Radiation Areas The precautions we take at the Mill to keep exposure to beta/gamma radiation to minimum are Keeping workers away from areas with high beta/gamma radiation When you see an area posted as Radiation Area do not go near that area unless required to do so for specific task Minimizing the time each worker is required to work in areas with elevated beta/gamma radiation This also involves rotating workers so that the time each worker spends in the Radiation Area is kept to minimum Using shielding in some cases and Engineered controls in our process to reduce exposures faced by workers 5.2 Breathing in Radioactive Dust or Radon Any dust at the Mill can be radioactive Ore dust is radioactive Dust from the ore pad is radioactive Dust from around the facility buildings can be radioactive Yellowcake dust is radioactive and tailings dusts are radioactive In addition radon gas is radioactive and can be found in all areas of the Mill facility and property Radon gas is particularly dangerous in closed areas where it can accumulate The Mill monitors various areas of the Mill facilities and Mill properties for radioactive dust and radon gas Each worker is required to keep track of the time he or she spends in each area of the Mill each day and record these times on his or her Exposure Time Sheet This allows Mill Radiation Safety Staff to calculate how much exposure to radiation the worker has had each day by determining how much time each worker spends in each area and by calculating the exposure for the time spent in each area based on the monitoring results for that area This is why it is important for each worker to carefully and accurately fill out his or her Exposure Time Sheet each day The precautions we take to keep exposures to radioactive dust and radon to minimum are the following Good housekeeping is important in order to keep dust to minimum within facility buildings Water is sprayed on the ore pad and other areas of the Mill property in order to keep dust to minimum Posting and restricting access to areas where there is potential for higher exposures to radioactive dust Respiratory protection is required in areas where there is potential for higher exposures to radioactive dust and/or radon such as in the yellowcake packaging area where uranium concentrate is being handled Showers are available to all workers and yellowcake workers are required to shower at the end of their work shift Non-routine projects that may result in radiation exposure are controlled by Radiation Work Permit where personal protective equipment PPE and additional monitoring such as breathing zone sampling requirements can apply and Work clothing remains at the Mill and all workers entering the restricted area are required to survey for alpha contamination prior to leaving the facility 5.3 Ingesting Radioactive Particles Ingestion of radioactive materials at the Mill is minimal but can occur directly by swallowing dust that has entered your mouth or indirectly from contamination of food or other items person might put into his or her mouth For these reasons S-smoking eating chewing gum or tobacco etc are not allowcdpermitted in working areas of the Mill Eating is restricted to only designated eating areas You may smoke only in designated area outside of the Mills restricted area This exposure pathway is best controlled by personal hygiene principles such as cleaning your hands before eating Monitoring and Calculation of Total Dose Received by the Worker In order to ensure that worker exposure is maintained within the regulatory limits and the Mills ALARA goal various monitoring methods are used to assess the workers exposure Air samples are collected throughout the plant to assess concentrations of radioactive dust and radon in the air and the amount of time spent by workers in the various plant areas is recorded to determine the inhalation exposure of each worker given his/her particular job assignment In addition gamma and beta exposure is monitored by means of personal exposure badges OSL to assess individual exposure to external sources The amount of exposure worker receives from radioactive dust radon and beta/gamma radiation to the body are added up to determine the total dose referred to as the workers Total Effective Dose Equivalent or TEDE received by the worker for the year The workers TEDE is then compared to the regulatory limits and the Mills ALARA goal Urine samples are also collected from workers to ensure that internal uptake of uranium is not damaging kidneys and in some instances to determine uptake due to unusual circumstances In addition and as mentioned above workers are required to scan for alpha contamination as they exit the restricted area to protect against offsite contamination and exposure Leaving the Mill Each Day As can be seen from the information provided above contamination control is important as means of minimizing exposure to radiation at the Mill One of the more important places where this control is necessary is when worker leaves the Mill Taking shower leaving work clothes at the work place and scanning out to ensure that you are not taking contaminants home on your person are good practices to protect you and your family from offsite exposure All workers must scan before leaving the Mills restricted area All yellowcake workers must also shower before leaving the restricted area Reporting In order to determine that employee exposures are being maintained within the regulatory limits and company goals annual exposure calculations for each worker are completed by the Radiation Safety Department These reports are utilized to demonstrate compliance with the standards assess any trends in exposure and to provide record to the individual worker Each worker receives an exposure report annually from the Radiation Safety Department Conclusion Uranium is naturally occurring radioactive element which can have harmful effects if not properly monitored and controlled At the Mill we can be exposed primarily to alpha beta and gamma radiation and our exposures to those forms of radiation are limited by regulation and company policy Because uranium is primarily an alpha emitter alpha radiation is the principle type of radiation exposure at the Mill This means that minimizing the inhalation or swallowing of radioactive dust at the Mill is primary objective The radiation you may be exposed to at the Mill is monitored by sampling the air you breathe and measuring the external radiation received by your personnel exposure badge The results of this monitoring are evaluated and reported to you annually so that you are made aware of your exposure While the company provides engineering controls to protect you from sources of radiation each employee must remain aware of conditions at the Mill Avoiding high radiation areas wearing respirators where/when required cleaning your hands before eating avoiding dusty situations and using contamination control procedures when you leave the property are individual protections you can use to minimize your exposure to radiation at the Mill No PBL-3 INTERNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date September 25 Title Tailings Capacity Evaluation 2000 1.0 Purpose The Nuclear Regulatory Commission NRC license for the White Mesa uranium mill Mill is Performance-Based License PBL The PBL allows International Uranium USA Corporation IUSA to evaluate and implement certain changes in the licensed operation without applying for and receiving formal amendment to the NRC license The following procedure outlines the steps to follow when accepting additional conventional ore or alternate feed materials to ensure that the currently permitted capacity of the Tailings Management System is not exceeded This Standard Operating Procedure SOP is as per the Mills NRC License 2.0 Tailings Capacity Determination Procedure Whenever the Mill is considering receiving conventional ore le2 material or an alternate feed the capacity of the Mill Tailings System will have to be determined to ensure that sufficient volume is available to store the projected incremental volumes of tailings material as well as the projected volumes of waste material from final reclamation of the Mill facility based on the approved Reclamation Plan This evaluation will be performed by the Mill Manager or his designee and approved by the President of IUSA or his designee The procedure for determining whether there is sufficient capacity is described as follows and documented on the attached Tailings Capacity Form 2.1 For the first evaluation the base volume BY available will be based on the capacity stated in the Tailings Capacity Evaluation report submitted to the NRC May 15 2000 copy of which is attached For each subsequent evaluation the previous evaluation will produce remaining tailings capacity value which will become the BY 2.2 Mill Management will maintain Tailings Capacity Evaluation Record TCER book in which all evaluation forms and supporting calculations will be maintained Refer to the TECR to obtain the BY value to be used in each subsequent evaluation 2.3 The volume of tailings discharged to the active tailings cells between the date of the BY and the evaluation date will be estimated based on the Mills production reports \Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-3 Tailings Capacity SOP Rev 25 00.docPtdmin4aster SOPsBook 10_PBL SopsPBL 3_Tailings Capacity SOP Seied 9.25.00 Rev 0.doc No PBL-3 INTERNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date September 25 Title Tailings Capacity Evaluation 2000 2.4 The amount of Mill site trash disposed of in the tailings system will be determined The number of loads of trash hauled between the date of the BY and the evaluation date will be taken from the Garbage Log 2.5 The amount of 11 e.2 in-situ waste material deposited into the tailings system between the date of the BY and the evaluation date will be summarized The quantities of material will be listed by supplier and will be based on the Scale House Weigh Tickets from each shipment 2.6 The BY minus the quantities in items 2.3 2.4 and 2.5 above will become the current tailings capacity This number will be used as the BY item 2.1 above for the subsequent evaluation 2.7 The amount of alternate feed material or conventional ore committed to be processed and deposited into the tailings system will be summarized The maximum projected quantities of material will be listed by supplier and stated in dry tons i.e less the estimated moisture content 2.8 The sum of the quantities estimated in item 2.7 above will be subtracted from the current tailings capacity calculated in item 2.6 above to determine the remaining capacity available \Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6PBL-3_Tailings Capacity SOP Rev 25 00.docPtdmin4aster SOPsWook 10_PBL SopsWBL 3_Tailings Capacity SOP Seied onc fl Day 0.doc White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM AND DISCHARGE MINIMIZATION TECHNOLOGY DMT MONITORING PLAN INTRODUCTION This Tailings Management System and Discharge Minimization Technology Monitoring Plan the Plan for the White Mesa Mill the Mill provides procedures for monitoring of the tailings cell system as required under State of Utah Radioactive Materials License No UT1900479 the Radioactive Materials License as well as procedures for operating and maintenance of monitoring equipment and reporting procedures that are adequate to demonstrate DMT compliance under State of Utah Ground Water Discharge Permit No 370004 for the Mill the GWDP This Plan is designed as systematic program for constant surveillance and documentation of the integrity of the tailings impoundment system including dike stability liner integrity and transport systems as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the Mill The Plan requires daily weekly quarterly monthly and annual inspections and evaluations and monthly reporting to Mill management DAILY TAILINGS INSPECTIONS The following daily tailings inspections shall be performed 2.1 Daily Comprehensive Tailings Inspection On daily basis including weekends all areas connected with the four tailings cells will be inspected Observations will be made of the current condition of each cell noting any corrective action that needs to be taken The Environmental or Radiation Technician is responsible for performing the daily tailings inspections except on weekends when the Shift Foreman will perform the weekend tailings inspections The Radiation Safety Officer may designate other individuals with training as described in Section 2.4 below to perform the daily tailings inspection Observations made by the inspector will be recorded on the Daily Inspection Data form copy of which is attached in Appendix The Daily Inspection Data form contains an inspection checklist White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 which includes tailings cells map and spaces to record observations especially those of immediate concern and those requiring corrective action The inspector will place check by all inspection items that appear to be operating properly Those items where conditions of potential concern are observed should be marked with an note should accompany the specifying what the concern is and what corrective measures will resolve the problem This observation of concern should be noted on the form until the problem has been remedied The date that corrective action was taken should be noted as well Areas to be inspected include the following Cell and 4A Dikes 4A-S and 4A-W wind movement of tailings effectiveness of dust minimization methods spray evaporation Cell spillway Cell spillway Cell and 4A liquid pools and associated liquid return equipment cell leak detection systems and the wildlife ponds Operational features of the tailings area are checked for conditions of potential concern The following items require visual inspection during the daily tailings inspection Tailings slurry and SX raffinate transport systems from the Mill to the active disposal cells and pool return pipeline and pumps Daily inspections of the tailings lines are required to be performed when the Mill is operating The lines to be inspected include the tailings slurry lines from CCD to the active tailings cell SX raffinate lines that can discharge into Cell Cell or Cell 4A the pond return line from the tailings area to the Mill and lines transporting pond solutions from one cell to another Cell Cell Cell Cell 4A Dike structures including dikes 4A-S and 4A-W The Cell spillway Cell spillway Cell and Cell 4A liquid pools and associated liquid return equipment Presence of wildlife and/or domesticated animals in the tailings area including waterfowl and burrowing animal habitations Spray evaporation pumps and lines White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 Wind movement of tailings and dust minimization Wind movement of tailings will be evaluated for conditions which may require initiation of preventative dust minimization measures for cells containing tailings sand During tailings inspection general surface conditions will be evaluated for the following areas of tailings subject to blowing and/or wind movement liquid pool size areas not subject to blowing and/or wind movement expressed as percentage of the total cell area The evaluations will he reviewed on weekly basis or more frequently if warranted and will be used to direct dust minimization activities Observation of flow and operational status of the dust control/spray evaporation systems Observations of any abnormal variations in tailings pond elevations in Cells 13 and4A Locations of slurry and SX discharge within the active cells Slurry and SX discharge points need to be indicated on the tailings cells map included in the Daily Inspection Data form An estimate of flow for active tailings slurry and SX lines An estimate of flow in the solution return lines Daily measurements in the leak detection system LDS sumps of the tailings cells will be made when warranted by changes in the solution level of the respective leak detection system The trigger for further action when evaluating the measurements in the Cell and Cell leak detection systems is gain of more than 12 inches in 24 hours The solution level in Cell 4A leak detection is not allowed to be more than 1.0 foot above the lowest point on the bottom flexible membrane liner elevation 5556.14 feet amsl If any of these observation are made the Mill Manager should be notified immediately and the leak detection system pump started White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 Whenever the leak detection system pump is operating and the flow meter total izer is recording notation of the date and the time will be recorded on the Daily Inspection Data form This data will be used in accordance with License Condition 1.3.B through 1.3.E of the Mills Radioactive Materials License to determine whether or not the flow rate into the leak detection system is in excess of the License Conditions An estimate of the percentage of the tailings beach surface area and solution pool area is made including estimates of solutions cover areas and tailings sands for Cells and 4A Items and are to be done only when the Mill is operating When the Mill is down these items cannot be performed 2.2 Daily Operations Inspection During Mill operation the Shift Foreman or other person with the training specified in Section 2.4 below designated by the Radiation Safety Officer will perform an inspection of the tailings line and tailings area at least once per shift paying close attention for potential leaks and to the discharges from the pipelines Observations by the Inspector will be recorded on the appropriate line on the Operating Foremans Daily Inspection form 2.3 Daily Operations Patrol In addition to the inspections described in Sections 2.1 and 2.2 above Mill employee will patrol the tailings area at least twice per shift during Mill operations to ensure that there are no obvious safety or operational issues such as leaking pipes or unusual wildlife activity or incidences No record of these patrols need be made but the inspectors will notify the Radiation Safety Officer and/or Mill management in the event that during their inspection they discover that an abnormal condition or tailings emergency has occurred 2.4 Training All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings Management System training as set out in the Tailings Inspection Training procedure which is attached as Appendix This training will include training pack explaining the procedure for performing the inspection and addressing inspection items to be observed In addition each individual after reviewing the training pack will sign certification form indicating that training has been received relative to his/her duties as an inspector White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 2.5 Tailings Emergencies Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if during their inspection they discover that an abnormal condition exists or an event has occurred that could cause tailings emergency Until relieved by the Environmental or Radiation Technician or Radiation Safety Officer inspectors will have the authority to direct resources during tailings emergencies Any major catastrophic events or conditions pertaining to the tailings area should be reported immediately to the Mill Manager or the Radiation Safety Officer one of whom will notify Corporate Management If dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSFIA 303-231-5465 and the State of Utah Division of Dam Safety 801-538-7200 WEEKLY TAILINGS AND DMT INSPECTION 3.1 Weekly Tailings Inspections Weekly tailings inspections are to be conducted by the Radiation Safety Department and include the following Leak Detection Systems Each tailings cells leak detection system shall be checked weekly to determine whether it is wet or dry If marked wet the liquid levels need to be measured and reported In Cell and Cell the leak detection system is measured by use of pipe that is removed from the system which will indicate the presence of solutions in the LDS system The Cell 4A leak detection system is monitored on continuous basis by use of pressure transducer that feeds water level information to an electronic data collector The pressure transducer is calibrated for fluid with specific gravity of 1.0 The water levels are measured every hour and the information is stored for later retrieval The water levels are measured to the nearest 0.10 inch The data collector is currently programmedto store days of water level information The number of days of stored data can be increased beyond days if needed The water level data is downloaded to laptop computer on weekly basis and incorporated into the Mills environmental monitoring data base and into the files for weekly inspection reports of the tailings cell leak detection systems White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 If sufficient fluid is present in the leak detection system of any cell the fluid shall be pumped from the LDS to the extent reasonably possible and record the volume of fluid recovered Any fluid pumped from an LDA shall be returned to disposal cell If fluid is pumped from an LDS the flow rate shall be calculated by dividing the recorded volume of fluid recovered by the elapsed time since fluid was last pumped or increases in the LDS fluid levels were recorded whichever is the more recent This calculation shall be documented as part of the weekly inspection Upon the initial pumping of fluid from an LDS fluid sample shall be collected and analyzed in accordance with paragraph 11.3 of the Radioactive Materials License For Cell 4A under no circumstance shall fluid head in the leak detection system sump exceed 1-foot level above the lowest point in the lower flexible membrane liner To determine the Maximum Allowable Daily LDS Flow Rates in the Cell 4A leak detection system the total volume of all fluids pumped from the LDS on weekly basis shall be recovered from the data collector and that information will be used to calculate an average volume pumped per day Under no circumstances shall the daily LDS flow volume exceed 24160 gallons/day The maximum daily LDS flow volume will be compared against the measured cell solution levels detailed on Table in Appendix to determine the maximum daily allowable LDS flow volume for varying head conditions in Cell 4A Slimes Drain Water Level Monitoring Cell is an active tailings cell while Cell is partially reclaimed with approximately 90%of the surface covered by platform fill Each cell has slimes drain system which aids in dewatering the slimes and sands placed in the cell ii Cell has pump placed inside of the slimes drain access pipe at the bottom of the slimes drain As taken from actual measurements the bottom of the slimes drain is 38 feet below water level measuring point at the centerline of the slimes drain access pipe at the ground surface level This means that the bottom of the slimes drain pool and the location of the pump are one foot above the lowest point of the FML in Cell which based on construction reports is at depth of 39 feet below the water level measuring point on the slimes drain access pipe for Cell White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 iiiThe slimes drain pump in Cell is on timed system under which it pumps for 15 minutes each hour thereby allowing the slimes wastewater to recharge for 45 minutes before being pumped again Based on measurements taken in August 2006 the water level in the Cell slimes drain recharges to depth of about 28.50 feet before each pumping and is pumped to depth of 38 feet after each pumping in each case measured below the water level measuring point on the slimes drain access pipe The average wastewater head in the Cell slimes drain is therefore about feet The depth to water of about 28.50 feet after recharge is below the phreatic surface of tailings Cell which is at depth of about 20 feet below the water level measuring point on the slimes drain access pipe As result there is continuous flow of wastewater from Cell into the slimes drain collection system Mill management considers that the average allowable wastewater head in the Cell slimes drain resulting from pumping at these intervals is satisfactory and is as low as reasonably achievable Based on past experience cycling the pump morethan 15 minutes every hour can result in more replacement costs for pumps and more resulting system downtime ivThe Cell slimes drain pump is checked weekly to observe that it is operating and that the timer is set properly which is noted on the Weekly Tailings Inspection Form If at any time the pump is observed to be not working properly it will be fixed or replaced within 15 days Depth to wastewater in the Cell slimes drain access pipe shall be monitored and recorded weekly to determine maximum and minimum fluid head before and after pumping cycle respectively All head measurements must be made from the same measuring point the notch at the north side of the access pipe and made to the nearest 0.01 foot The results will be recorded as depth-in-pipe measurements on the Weekly Tailings Inspection Form viOn monthly basis the slimes drain pump will be turned off and the wastewater in the slimes drain access pipe will be allowed to stabilize for at least 90 hours Once the water level has stabilized based on no change in water level for three successive readings taken no less than one hour apart the water level of the wastewater will be measured and recorded as depth-in-pipe measurement on the Monthly Inspection Data form by measuring the depth to water below the water level measuring point on the slimes drain access pipe vii No process liquids shall be allowed to be discharged into Cell viii If at any time the most recent average annual head in the Cell slimes drain is found to have increased above the average head for the previous calendar year the Licensee will comply with the requirements of Part I.G.3 of the GWDP including the requirement to provide notification to the Executive Secretary orally within 24 hours followed by written notification ixBecause Cell and Cell 4A are currently active no pumping from the Cell or Cell 4A slimes drain is authorized Prior to initiation of tailings dewatering operations for Cell or Cell 4A similar procedure will be developed for ensuring that average White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 head elevations in the Cell and Cell 4A slimes drains are kept as low as reasonably achievable and that the Cell and Cell 4A slimes drains are inspected and the results reported in accordance with the requirements of the permit Wind Movement of Tailings An evaluation of wind movement of tailings or dusting and control measures shall be taken if needed Tailings Wastewater Pool Elevation Monitoring Solution elevation measurements in Cells and 4A and Roberts Pond are to be taken by survey on weekly basis as follows The survey will be performed by the Mills Radiation Safety Officer or designee the Surveyor with the assistance of another Mill worker the Assistant ii The survey will be performed using survey instrument the Survey Instrument accurate to 0.01 feet such as Sokkai No B21 or equivalent together with survey rod the Survey Rod having visible scale in 0.01 foot increments iiiThe reference Points the Reference Points for Cells and 4A and Roberts Pond are known points established by professional survey For Cell and Roberts Pond the Reference Point is wooden stake with metal disk on it located on the southeast corner of Cell The elevation of the metal disk the Reference Point Elevation for Cell and Roberts Pond is at 5623.14 feet above mean sea level FMSL For Cell and cell 4A the Reference Point is piece of metal rebar located on the south dike of Cell The elevation at the top of this piece of rebar the Reference Point Elevation for Cell and cell 4A is at 5607.83 FMSL iv The Surveyor will set up the Survey Instrument in location where both the applicable Reference Point and pond surface are visible For Cell and Roberts Pond this is typically on the road on the Cell south dike between Cell and Roberts Pond approximately 100 feet east of the Cell 1/Roberts Pond Reference Point For Cell and Cell 4A this is typically on the road on the Cell dike approximately 100 feet east of the Cell Reference Point Once in location the Surveyor will ensure that the Survey Instrument is level by centering the bubble in the level gauge on the Survey Instrument viThe Assistant will place the Survey Rod vertically on the Reference Point on the metal disk on the Cell 1/Roberts Pond Reference Point and on the top of the rebar on the Cell and cell 4A Reference Point The Assistant will ensure that the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established level reading vii The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the Survey Rod and record the number the Reference Point Reading which White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page of 36 represents the number of feet the Survey Instrument is reading above the Reference Point viii The Assistant will then move to designated location where the Survey Rod can be placed on the surface of the main solution pond in the Cell or Roberts Pond as the case may be These designated locations and the methods to be used by the Assistant to consistently use the same locations are as follows Cell stake has been place in the central area of the south dike of Cell The Assistant will walk perpendicular to the dike from the stake to the nearest point on the liquid surface of Cell and place the Survey Rod at that location Ce114A The Assistant will walk down the slope in the northeast corner of Cell 4A and place the Survey Rod at the liquid level Cell mark has been painted on the north side of the ramp going to the pump platform in Cell The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface and Roberts Pond mark has been painted on the railing of the pump stand in Roberts Pond The Assistant will place the Survey Rod against that mark and hold the rod vertically with one end just touching the liquid surface Based on the foregoing methods the approximate coordinate locations for the measuring points for Roberts Pond and the Cells are Northing Easting Roberts Pond 323041 2579697 Cell 322196 2579277 Cell 320508 2577760 Cell 4A 320300 2579360 These coordinate locations may vary somewhat depending on solution elevations in the Pond and Cells White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 10 of 36 ixThe Assistant will hold the Survey Rod vertically with one end of the Survey Rod just touching the pond surface The Assistant will ensure that the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established level reading The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the Survey Rod and record the number the Pond Surface Reading which represents the number of feet the Survey Instrument is reading above the pond surface level The Surveyor will calculate the elevation of the pond surface as FSML by adding the Reference Point Reading for the Cell or Roberts Pond as the case may be to the Reference Point Elevation for the Cell or Roberts Pond and subtracting the Pond Surface Reading for the Cell or Roberts Pond and will record the number accurate to 0.01 feet Summary In addition the weekly inspection should summarize all activities concerning the tailings area for that particular week Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMT Inspection form An example of the Weekly Tailings and DMT Inspection form is provided in Appendix 3.2 Weekly Inspection of Solution Levels in Roberts Pond On weekly basis solution elevations are taken on Roberts Pond in accordance with the procedures set out in Section 3.1 above The Weekly solution level in Roberts Pond is recorded on the Weekly Tailings and DMTlnspection form Based on historical observations the FML at the Pond Surface Reading area for Roberts Pond is approximately six inches above the lowest point on the pond sFML If the pond solution elevation at the Pond Surface Reading area is at or below the Fls/IL for that area the pond will be recorded as being dry 3.3 Weekly Feedstock Storage Area Inspections Weekly feedstock storage area inspections will be performed by the Radiation Safety Department to confirm that the bulk feedstock materials are stored and maintained within the defined area described in the GWDP as indicated on the map attached hereto as Appendix and all alternate feedstock located outside the defined Feedstock Area are maintained within water tight containers White Mesa Mill Standard Operating Procedures 9/08 Revision Denison6 Book 11 Environmental Protection Manual Section 3.1 Page 11 of 36 The results of this inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection Report copy of which is contained in Appendix Any variance in stored materials from this requirement or observed leaking alternate feedstock drums or other containers will be brought to the attention of Mill Management and rectified within 15 days MONTHLY TAILINGS INSPECTION Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from the Radiation Safety Department and recorded on the Monthly Inspection Data form an example of which is contained in Appendix Monthly inspections are to be performed no sooner than 14 days since the last monthly tailings inspection and can be conducted concurrently with the quarterly tailings inspection when applicable The following items are to be inspected Tailings Slurry Pipeline When the Mill is operating the slurry pipeline will be inspected at key locations to determine pipe wear Pipe thickness will be measured using an ultrasonic device by either the radiation safety staff or other trained designees The critical points of the pipe include bends slope changes valves and junctions which are critical to dike stability These locations to be monitored will be determined by the Radiation Safety Officer or his designee from the Radiation Safety Department during the Mill run Diversion Ditches Diversion ditches and shall be monitored monthly for sloughing erosion undesirable vegetation and obstruction of flow Diversion berm should be checked for stability and signs of distress Sedimentation Pond Activities around the Mill and facilities area sedimentation pond shall be summarized for the month Overspray Dust Minimization The inspection shall include an evaluation of overspray minimization if applicable This entails ensuring that the overspray system is functioning properly In the event that overspray is carried more than 50 feet from the cell the overspray system should be immediately shut-off White Mesa Mill Standard Operating Procedures 9/08 Revision Denison Book 11 Environmental Protection Manual Section 3.1 Page 12 of 36 Remarks section is included on the Monthly Inspection Data form for remarks in which recommendations can be made or observations of concern can be documented Summary ofDaily Weekly and Quarterly Inspections The monthly inspection will also summarize the daily weekly and if applicable quarterly tailings inspections for the specific month In addition settlement monitors are typically surveyed monthly and the results reported on the Monthly Inspection Data form QUARTERLY TAILINGS INSPECTION The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from the Radiation Safety Department having the training specified in Section 2.4 above once per calendar quarter quarterly inspection should be performed no sooner than 45 days since the previous quarterly inspection was performed Each quarterly inspection shall include an Embankment Inspection an Operations/Maintenance Review Construction Review and Summary as follows Embankment Inspection The Embankment inspection involves visual inspection of the crest slope and toe of each dike for movement seepage severe erosion subsidence shrinkage cracks and exposed liner Operations/Maintenance Review The Operations/Maintenance Review consists of reviewing Operations and Maintenance activities pertaining to the tailings area on quarterly basis Construction Review The Construction Review consists of reviewing any construction changes or modifications made to the tailings area on quarterly basis White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 13 of 36 Summary The summary will include all major activities or observations noted around the tailings area on quarterly basis If any of these conditions are noted the conditions and corrective measures taken should be documented in the Quarterly Inspection Data form An example of the Quarterly Inspection Data form is provided in Appendix ANNUAL EVALUATIONS The following annual evaluations shall be performed 6.1 Annual Technical Evaluation An annual technical evaluation of the tailings management system is performed by registered professional engineer PE who has experience and training in the area of geotechnical aspects of retention structures The technical evaluation includes an on-site inspection of the tailings management system and thorough review of all tailings records for the past year The Technical Evaluation also includes review and summary of the annual movement monitor survey see Section 5.2 below All tailings cells and corresponding dikes will be inspected for signs of erosion subsidence shrinkage and seepage The drainage ditches will be inspected to evaluate surface water control structures In the event tailings capacity evaluations as per SOP PBL-3 were performed for the receipt of alternate feed material during the year the capacity evaluation forms and associated calculation sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate The amount of tailings added to the system since the last evaluation will also be calculated to determine the estimated capacity at the time of the evaluation Tailings inspection records will consist of daily weekly monthly and quarterly tailings inspections These inspection records will be evaluated to determine if any freeboard limits are being approached Records will also be reviewed to summarize observations of potential concern The evaluation also involves discussion with the Environmental and/or Radiation Technician and the Radiation Safety Officer regarding activities around the tailings area for the past year During the annual inspection photographs of the tailings area will be taken The training of individuals will be reviewed as part of the Annual Technical Evaluation White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 14 of 36 The registered engineer will obtain copies of selected tailings inspections along with the monthly and quarterly summaries of observations of concern and the corrective actions taken These copies will then be included in the Annual Technical Evaluation Report The Annual Technical Evaluation Report must be submitted by September 1st of every year to Directing Dam Safety Engineer State of Utah Natural Resources 1636 West North Temple Suite 220 Salt Lake City Utah 84116-3156 6.2 Movement Monitors movement monitor survey is to be conducted by licensed surveyor annually during the second quarter of each year The movement monitor survey consists of surveying monitors along dikes 3-S 4A-W and 4A-S to detect any possible settlement or movement of the dikes The data generated from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the tailings management system 6.3 Freeboard Limits Tailings Cells and 4A The freeboard limits are as per January 10 1990 Drainage Report for Cells and 4A and are stated below liquid maximum elevation of 5615.4 feet mean sea level in Cell ii liquid maximum elevation of 5596.4 feet mean sea level in Cell 4A Tailings Cell The freeboard limit for Cell is determined annually using the following procedure From survey of Cell the pool surface will be determined ii An estimate of the maximum tons of dry tailings to be generated during the next 12 months will be made This estimate is multiplied by 1.5 factor of safety to yield the Maximum Mill Production iii The Maximum Mill Production is divided by the number of tons required White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 15 of 36 to reduce the pooi size by one acre and then subtracted from the pool surface determined in Step yielding the Reduced Pool Area iv The PMP Flood Volume Requirement as per the January 10 1990 Drainage Report is 123.4 acre feet The PMP Flood Volume Requirement is divided by the Reduced Pool Area to determine the PMP Freeboard Level The Wave Run Up of 0.78 feet as specified in the January 10 1990 Drainage Report is added to the PMP Freeboard Level to determine the Total Required Freeboard The calculation of the Total Required Freeboard for Cell will be calculated annually and the calculation sheet filed in the Mill Central File Tailings Cell 4A The freeboard limit for Cell 4A is determined annually using the following procedure The Cell 4A design includes concrete spillway between Cell and Cell 4A with the invert elevation feet below the top of the Cell dike at an elevation of 5604.5 feet amsl Should Cell receive the full PMP volume of 123.4 acre feet of water approximately 62 acre feet of that volume would flow through the spillway into Cell 4A The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water 40 acres plus the adjacent drainage area of 3.25 acres times the PMP of 10 inches This would result in total flood volume of 98 acre-feet including the 62 acre-feet of solution from Cell The freeboard depth required for Cell 4A from the PMP event would be 2.44 feet plus wave run-up depth of 0.77 feet from the 1990 Drainage Report for total freeboard requirement of 3.2 feet This calculation is illustrated on Attachment The Groundwater Quality Discharge Permit No UGW370004 for the White Mesa Mill requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell construction but based on the above calculation the freeboard would be set 3.2 feet below the top of liner The freeboard for Cell 4A would therefore be 5595.3 amsl top of liner 5598.5 3.2 feet The calculation of the Total Required Freeboard for Cell 4A will be calculated annually and the calculation sheet filed in the Mill Central File White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 16 of 36 Roberts Pond The freeboard limit for Roberts Pond is liquid maximum elevation of 5624.0 feet above mean sea level as specified in the GWDP 6.4 Annual Leak Detection Fluid Samples In the event solution has been detected in leak detection system sample will be collected on an annual basis This sample will be analyzed according to the conditions set forth in License Condition 11.3 .C The results of the analysis will be reviewed to determine the origin of the solution OTHER INSPECTIONS All daily weekly monthly quarterly and annual inspections and evaluations should be performed as specified in Sections and above However additional inspections should be conducted after any significant storm or significant natural or man-made event occurs REPORTING REQUIREMENTS In addition to the Daily Inspection Data Weekly Tailings Inspection Monthly Inspection Data and Quarterly Inspection Data forms included as Appendix and described in Sections and respectively and the Operating Foremans Daily Inspection and Weekly Mill Inspection forms described in Sections and respectively the following additional reports shall also be prepared 8.1 Monthly Tailings Reports Monthly tailings reports are prepared every month and summarize the previous months activities around the tailings area If not prepared by the Radiation Safety Officer the report shall be submitted to the Radiation Safety Officer for review The Mill Manager will review the report as well before the report is filed in the Mill Central File The report will contain summary of observations of concern noted on the daily and weekly tailings inspections Corrective measures taken during the month will be documented along with the observations where appropriate All daily and weekly tailings inspection forms will be attached to the report monthly inspection form will also be attached Quarterly inspection forms will accompany the report when applicable The report will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill Manager White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 17 of 36 8.2 DMT Reports Quarterly reports of DMT monitoring activities of all required information required by Part .F.2 of the GWDP relating to the inspections described in Section 3.1b limes Drain Water Level Monitoring 3.1d Tailings Wastewater Pool Elevation Monitoring 3.2 Weekly Inspection of Solution Levels in Roberts Pond and 3.3 Weekly Feedstock Storage Area Inspections will be provided to the Executive Secretary on the schedule provided in Table of the GWDP An annual summary and graph for each calendar year of the depth to wastewater in the Cell slimes drain must be included in the fourth quarter report After the first year and beginning in 2008 quarterly reports shall include both the current year monthly values and graphic comparison to the previous year White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 18 of 36 APPENDIX FORMS Wh i t e Me s a Mi l l St a n d a r d Op e r a t i n g Pr o c e d u r e s Bo o k 11 En v i r o n m e n t a l Pr o t e c t i o n Ma n u a l Se c t i o n 3. 1 9/ 0 8 Re v i s i o n De n i s o n - 6 Pa g e 19 of 36 AP P E N D I X CO N T DA I L Y I N S P E C T I O N DA T A An y It e m no t OK mu s t be do c u m e n t e d ch e c k ma r k OK Ac t i o n Re q u i r e d In s p e c t o r Da t e Ac c o m p a n i e d by Ti m e TA I L I N G S SL U R R Y T R A N S P O R T S Y S T E M In s p e c t i o n It e m s Co n d i t i o n s of Po t e n t i a l Co n c e r n Ce l l C e l l C e l l C e l l 4A Sl u r r y Pi p e l i n e Le a k s Da m a g e Bl o c k a g e Sh a r p Be n d s Pi p e l i n e Jo i n t s Le a k s Lo o s e C o n n e c t i o n s Pi p e l i n e Su p p o r t s Da m a g e Lo s s of Su p p o r t Va l v e s Le a k s Bl o c k e d Cl o s e d Po i n t s of Di s c h a r g e I m p r o p e r Lo c a t i o n or O r i e n t a t i o n II OP E R A T I O N A L SY S T E M S In s o e c t i o n It e m s rn n 1 - 1 of P o t e n t i a l Co n c e r n Ce l l C e l l C e l l C e l l 4A Wa t e r Le v e l Gr e a t e r Th a n Op e r a t i n g Le v e l La r g e Ch a n g e Si n c e Pr e v i o u s In p c t i o n Be a c h Li n e r an d Co v e r Cr a c k s Se v e r e Er o s i o n Su b s i d e n c e Er o s i o n of co v e r E x p o s u r e of L i n e r Wh i t e Me s a Mi l l St a n d a r d Op e r a t i n g Pr o c e d u r e s Bo o k 11 En v i r o n m e n t a l Pr o t e c t i o n Ma n u a l Se c t i o n 3. 1 9/ 0 8 Re v i s i o n De n i s o n - 6 Pa g e 20 of 36 II I DI K E S AN D EM B A N K M E N T S In s p e c t i o n It e m s Co n d i t i o n s of Po t e n t i a l Co n c e r n Di k e El Di k e 1- IA Di k e D i k e D i k e 4A - Di k e 4A - Sl o p e s Cr e s t Sl o u g h s or Sl i d i n g Cr a c k s Bu l g e s Su b s i d e n c e Se v e r e Er o s i o n Mo i s t Ar e a s Ar e a s of Se e p a g e Ou t b r e a k Cr a c k s Su b s i d e n c e Se v e r e Er o s i o n IV FL O W RA T E S Sl u r r y Li n e s Po n d Re t u r n S- X Ta i l s Sp r a y S y s t e m GP M PH Y S I C A L I N S P E C T I O N OF SL U R R Y LI N E S S Wa l k e d to Di s c h a r g e Po i n t Ob s e r v e d En t i r e Di s c h a r g e Lin e Ye s Ye s No No VI DU S T CO N T R O L Ce l l Ce l l Ce l l 4A Du s t i n g Wi n d Mo v e m e n t of Ta i l i n g s Pr e c i p i t a t i o n in c h e s li q u i d Ge n e r a l Me t e o r o l o g i c a l co n d i t i o n s _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Wh i t e Me s a Mi l l St a n d a r d Op e r a t i n g Pr o c e d u r e s 9/ 0 8 Re v i s i o n De n i s o n - 6 Bo o k 11 En v i r o n m e n t a l Pr o t e c t i o n Ma n u a l Se c t i o n 3. 1 Pa g e 21 of 36 VI I DA I L Y LE A K DE T E C T I O N CH E C K Ce l l Ce l l Ce l l Ce l l 4A Le a k De t e c t i o n Sy s t e m Ch e c k e d Dr y In i t i a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Fi n a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Ga l pu m p e d Dr y In i t i a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Fi n a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Ga l pu m p e d Dr y In i t i a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Fi n a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Ga l pu m p e d Dr y In i t i a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Fi n a l le v e l _ _ _ _ _ _ _ _ _ _ _ _ Ga l pu m p e d VI I I OB S E R V A T I O N S O F P O T E N T I A L CO N C E R N Ac t i o n Re q u i r e d Wh i t e Me s a Mi l l St a n d a r d Op e r a t i n g Pr o c e d u r e s 9/ 0 8 Re v i s i o n De n i s o n - 6 Bo o k 11 En v i r o m n e n t a l Pr o t e c t i o n Ma n u a l Se c t i o n 3. 1 Pa g e 22 of 36 OF TA I I J N G S AR E A White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 23 of 36 APPENDIX CONT DENISON MINES USA CORP WEEKLY TAILINGS INSPECTION Date____________________Inspectors Pond elevations mslft Cell Pond Solution Elevation _________________ FML Bottom Elevation 5597 Depth of Water above FML a-b ________________ Cell aPond Solution Elevation _________________ bFML Bottom Elevation 5570 cDepth of Water above FML a-b ________________ Cell 4A aPond Solution Elevation _______________ bFML Bottom Elevation ______5564 cDepth of Water above FML a-b_______________ Roberts Pond aPond Solution Elevation _______________ bFML Bottom Elevation 5612.34 cDepth of Water above FML a-b ________________ Slimes Drain Liquid Levels Cell Pump functioning properly Pump Timer set at 15mm on 45 mm off Depth to Liquid pre-pump Depth to Liquid Post-pump all measurements are depth-in-pipe Pre-pump head is 38-Depth to Liquid Pre-pump Post-pump head is 38 Depth to Liquid Post- pump _____ White Mesa Mill Standard Operating Procedures Book 11 Enviromnental Protection Manual Section 3.1 Leak Detection Systems 9/08 Revision Denison-6 Page 24 of 36 Cell Cell Cell Ce1I4A Observation Is LDS wet or dry wet__dry wet__dry wet__dry wet__dry If wet Record liquid level to Liquid to Liquid to Liquid to Liquid If sufficient fluid is present record volume of fluid pumped and flow rate Volume Flow Rate_______ Volume Flow Rate_______ Volume Flow Rate_______ Volume Flow Rate______ Was fluid sample collected Tailings Area Inspection Note dispersal of blowing tailings Control Methods Implemented Remarks Contaminated Waste Dump Does Level exceed 12 inches above the lowest point on the bottom flexible membrane liner elevation 5556.14 amsl _____no _____yes If Cell 4A leak detection system level exceeds 12 inches above the lowest point on the bottom flexible membrane liner elevation 5556.14 amsl notify supervisor or Mill manager immediately White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 25 of 36 APPENDIX CONT MONTHLY INSPECTION DATA Inspector Date ___________________________________ Slurry Pipeline Pipe Thickness To be measured only during periods when the Mill is operating Diversion Ditches and Diversion Berm Observation Diversion Ditch Diversion Ditch Diversion Ditch Diversion Berm Diversion Ditches Sloughing yes no _____yes no _____yes no Erosion _____yes no _____yes no _____yes no Undesirable _____yes no _____yes no _____yes no Vegetation Obstruction of Flow _____yes no _____yes no _____yes no Diversion Berm Stability Issues _____yes no Signs of Distress _____yes no Comments Summary of Activities Around Sedimentation Pond _________________________________ White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 26 of 36 Overspray Dust Minimization Overspray system functioning properly yes no Overspray carried more than 50 feet from the cell _____yes no If yes was system immediately shut off ______yes no Comments Remarks Settlement Monitors Cell Wi _____________Cell 2W3-S _____________Cell 3-iN ______________ Cell W2 _____________Cell 2Ei-N _____________Cell 3-iC ______________ Cell W3 _____________Cell 2Ei-iS _____________Cell 3-iS ______________ Cell W4 ____________Cell 2Ei-2S _____________Cell 3-2N ______________ Cell 2W7-C _____________Cell East _____________Cell 2W5-N ____________ Cell W7N ____________Cell W7S ____________Cell W6N ___________ Cell W6C ____________Cell W65 ____________Cell W4N ___________ Cell 4A-Toe ___________Cell W4S ____________Cell W5C ___________ Cell 3-2C Cell 3-2S Summary of Daily Weekly and Quarterly Inspections Monthly Silmes Drain Static Head Measurement for Cell Depth-in-Pipe Water Level Reading ___________________ White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 27 of 36 APPENDIX CONT WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM QUARTERLY INSPECTION DATA Inspector Date __________________________ Embankment Inspection Operations/Maintenance Review Construction Activites Summary White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 28 of 36 APPENDIX CONT ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT Week of _________through _________Date of Inspection Inspector Weather conditions for the week Blowing dust conditions for the week Corrective actions needed or taken for the week Are all bulk feedstock materials stored in the area indicated on the attached diagram yes no________ comments Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained within water-tight containers yes_______no_______ comments e.g conditions of containers_________________________________________ Conditions of storage areas for materials Other comments White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 29 of 36 APPENDIX TAILINGS INSPECTOR TRAINING This document provides the training necessary for qualifying management-designated individuals for conducting daily tailings inspections Training information is presented by the Radiation Safety Officer or designee from the Environmental Department Daily tailings inspections are conducted in accordance with the White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT Monitoring Plan The Radiation Safety Officer or designee from the Radiation Safety Department is responsible for performing monthly and quarterly tailings inspections Tailings inspection forms will be included in the monthly tailings inspection reports which summarize the conditions activities and areas of concern regarding the tailings areas Notifications The inspector is required to record whether all inspection items are normal satisfactory requiring no action or that conditions of potential concern exist requiring action check mark indicates no action required if conditions of potential concern exist the inspector should mark an in the area the condition pertains to note the condition and specify the corrective action to be taken if an observable concern is made it should be noted on the tailings report until the corrective action is taken and the concern is remedied The dates of all corrective actions should be noted on the reports as well Any major catastrophic events or conditions pertaining to the tailings area should be reported immediately to the Mill Manager or the Radiation Safety Officer one of whom will notify Corporate Management if dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSHA 303-231-5465 and the State of Utah Division of Dam Safety 801-538-7200 Inspections All areas of the tailings disposal system are routinely patrolled and visible observations are to be noted on daily tailings inspection form Refer to Appendix for an example of the daily tailings inspection form The inspection form consists of three pages and is summarized as follows Tailings Slurry Transport System The slurry pipeline is to be inspected for leaks damage and sharp bends The pipelinejoints are to be monitored for leaks and loose connections The pipeline supports are to be White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 30 of 36 inspected for damage and loss of support Valves are also to be inspected particularly for leaks blocked valves and closed valves Points of discharge need to be inspected for improper location and orientation Operational Systems Operating systems including water levels beach liners and covered areas are items to be inspected and noted on the daily inspection forms Sudden changes in water levels previously observed or water levels exceeding the operating level of pond are potential areas of concern and should be noted Beach areas that are observed as having cracks severe erosion or cavities are also items that require investigation and notation on daily forms Exposed liner or absence of cover from erosion are potential items of concern for ponds and covered areas These should also be noted on the daily inspection form Cells and 4A solution levels are to be monitored closely for conditions nearing maximum operating level and for large changes in the water level since the last inspection All pumping activities affecting the water level will be documented In Cells and the PVC liner needs to be monitored closely for exposed liner especially after storm events It is important to cover exposed liner immediately as exposure to sunlight will cause degradation of the PVC liner Small areas of exposed liner should be covered by hand Large sections of exposed liner will require the use of heavy equipment These conditions are considered serious and require immediate action After these conditions have been noted to the Radiation Safety Officer work order will be written by the Radiation Safety Officer and turned into the Maintenance Department All such repairs should be noted in the report and should contain the start and finish date of the repairs Dikes and Embankments Inspection items include the slopes and the crests of each dike For slopes areas of concern are sloughs or sliding cracks bulges subsidence severe erosion moist areas and areas of seepage outbreak For crests areas of concern are cracks subsidence and severe erosion When any of these conditions are noted an mark should be placed in the section marked for that dike In addition the dikes in particular dikes 4A-S and 4A-W should be inspected closely for mice holes and more importantly for prairie dog holes as the prairie dogs are likely to burrow in deep possibly to the liner If any of these conditions exist the inspection report should be marked accordingly Flow Rates White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 31 of 36 Presence of all flows in and out of the cells should be noted Flow rates are to be estimated in gallons per minute GPM Rates need to be determined for slurry lines pond return SX tails and the spray system During non-operational modes the flow rate column should be marked as The same holds true when the spray system is not utilized Physical Inspection of Slurry Lines physical inspection of all slurry lines has to be made every hours during operation of the mill If possible the inspection should include observation of the entire discharge line and discharge spill point into the cell If fill to elevation flags are in place the tailings and build-up is to be monitored and controlled so as to not cover the flags Dust Control Dusting and wind movement of tailings should be noted for Cells and 4A Other observations to be noted include brief description of present weather conditions and record of any precipitation received Any dusting or wind movement of tailings should be documented In addition an estimate should be made for wind speed at the time of the observed dusting or wind movement of tailings The Radiation Safety Department measures precipitation on daily basis Daily measurements should be made as near to 800 a.m as possible every day Weekend measurements will be taken by the Shifter as close to 800 a.m as possible All snow or ice should be melted before reading is taken Observations of Potential Concern All observations of concern during the inspection should be noted in this section Corrective action should follow each area of concern noted All work orders issued contacts or notifications made should be noted in this section as well It is important to document all these items in order to assure that the tailings management system records are complete and accurate Map of Tailings Cells The last section of the inspection involves drawing as accurately as possible the following items where applicable Cover area Beach/tailing sands area Solution as it exists Pump lines White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 32 of 36 Activities around tailings cell i.e hauling trash to the dump liner repairs etc Slurry discharge when operating Over spray system when operating Safety Rules All safety rules applicable to the mill are applicable when in the tailings area These rules meet the required MSI-IA regulations for the tailings area Please pay particular notice to the following rules The posted speed limit for the tailings area is 15 mph and should not be exceeded No food or drink is permitted in the area All personnel entering the tailings area must have access to two-way radio Horseplay is not permitted at any time Only those specifically authorized may operate motor vehicles in the restricted area When road conditions are muddy or slick four-wheel drive vehicle is required in the area Any work performed in which there is danger of falling or slipping in the cell will require the use of safety belt or harness with attended life line and an approved life jacket portable eyewash must be present on site as well Anytime the boat is used to perform any work an approved lifejacket and goggles must be worn at all times There must also be an approved safety watch with two-way hand- held radio on shore portable eyewash must be present on site as well 10 Preservation of Wildlife Every effort should be made to prevent wildlife and domesticated animals from entering the tailings area All wildlife observed should be reported on the Wildlife Report Worksheet during each shift Waterfowl seen near the tailings cells should be discouraged from landing by the use of noisemakers 11 Certification Following the review of this document and on-site instruction on the tailings system inspection program designated individuals will be certified to perform daily tailings inspections The Radiation Safety Officer authorizes certification Refer to the Certification Form Appendix This form should be signed and dated only after thorough review of the tailings information previously presented The form will then be signed by the Radiation Safety Officer and filed White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Enviromnental Protection Manual Section 3.1 Page 33 of 36 APPENDIX CERTIFICATION FORM Date _____________________________ Name ______________________________ have read the document titled Tailings Management System White Mesa Mill Tailings Inspector Training and have received on-site instruction at the tailings system This instruction included documentation of daily tailings inspections analysis of potential problems dike failures unusual flows notification procedures and safety Signature certify that the above-named person is qualified to perform the daily inspection of the tailings system at the White Mesa Mill Radiation Safety Personnel Tailings System Supervisor White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 34 of 36 APPENDIX FEEDSTOCK STORAGE AREA 5\BM\US Projocts\Chloroform\dwg\Whito F4cx 2004 Ore Pad.dwg fed ag ir GOal Ip 00103/2U0o PM Xerox 03545 P5.pc3 Loiter International Uranium USA Corporation Project WHITE MESA MILL REVISIONS 2S2L County Sate Utah 1cflon Feedstock Storage Area Map Scale N/A Oate 08/03/2006 Iwh_m_200Core_po Author unknown WreSted By brn White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 35 of 36 APPENDIX TABLES White Mesa Mill Standard Operating Procedures 9/08 Revision Denison-6 Book 11 Environmental Protection Manual Section 3.1 Page 36 of 36 Table Calculated Action leakage Rates for Various head Conditions Cell 4A White mesa Mill landing Utah Head above Liner System feet Calculated Action leakage Rate gallons acre day 222.04 10 314.01 15 384.58 20 444.08 25 496.50 30 543.88 35 587.46 37 604.01 White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page of 21 RESPIRATORY PROTECTION PROGRAM Table of Contents 1.0 APPLICABILITY 1.1 Respiratory Protection Policy 1.2 Responsibilities 1.2.1 Mill Manager 1.2.2 Radiation Safety Officer 1.3 Policy Regarding Facial Hair 1.4 Physiological or Psychological Limitations to Respirator Use 2.0 PROCEDURES FOR RESPIRATOR USE 2.1 Supervision of the Program Including Program Audits 2.2 Training and Minimum Qualifications of Respiratory Program Supervisors and Implementing Personnel 2.3 Training of Respirator Users 2.4 Fit Testing 2.5 Selecting Respirators 2.6 Maintaining Breathing Air Quality 2.7 Inventory and Control of Respiratory Protection Equipment 2.8 Storage and Issuance of Respiratory Protection Equipment 2.9 Maintenance Repair Testing and Quality Assurance of Respiratory Protection Equipment 2.10 Record keeping 2.11 Limitations on Periods of Respirator Use and Relief from Respirator Use 2.12 Monitoring Including Air Sampling and Bioassays 3.0 PROCEDURES FOR MEDICAL EVALUATIONS AND AUDITS 3.1 Performing and documenting the Required Medical Evaluation 3.2 Maintaining TEDE ALARA and Performing ALARA Evaluations of Respiratory Protection 4.0 PROCEDURES FOR RESPIRATOR APPLICATONS 4.1 Routine Respirator Use 4.2 Nonroutine Respirator Use 4.3 Emergency Respirator Use White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page2of2l RESPIRATORY PROTECTION PROGRAM 1.0 APPLICABILITY The Respiratory Protection Program coordinates the Air sampling sufficient to identify the potential hazard select the proper equipment and estimate exposures Surveys and bioassays as appropriate to evaluate actual intakes Testing of respirators for operability prior to each use Written procedures regarding selection fitting issuance maintenance and testing of respirators including testing for operability immediately prior to each use supervision and training of personnel monitoring including air sampling and bioassays and record keeping and Detennination by physician prior to the initial fitting of respirators and either every 12 months thereafter or at greater frequency determined by physician that the individual user is medically fit to use the respiratory protection equipment over the age of 45 or every five years for individuals under 45 years of age 1.1 Respiratory Protection Policy The Respiratory Protection Program is established for this facility as policy of Denison Mines USA Corp DUSA to protect its employees from occupational exposure to harmful concentrations of radioactive and/or toxic materials in the air The following is DUSA policy with respect to respiratory protection Process or other engineering controls will be used whenever feasible to reduce the need for use of respirators For work in areas in which respirators must be routinely used to reduce exposures SOPs will detail use of respiratory protection Non-routine use of respirators will be performed under Safe Work Permits Self Contained Breathing Apparatus SCBA respirators will only be used for evacuation and emergency response situations Due to the added physical stress of working while using respirator work periods will be alternated with rest periods Respirators will not be issued to employees unless they are to be used 1.2 Responsibilities As noted in NRC Regulatory Guide 8.15 it is widely recognized among safety professionals that the use of respiratory protection devices in the workplace can impose physiological and psychological stresses on workers obstruct their vision hinder their movements and make effective communications difficult These factors increase the risk White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page of 21 of physical injury to respirator wearers that in many cases far exceeds any potential risk associated with the inhalation of small quantity of airborne radioactive material Therefore the NRC recommends that process or engineering controls be used to the extent practical to control the concentration of radioactive material in air and that the use of respiratory protection devices be contemplated only after other measures to limit intake have been considered In general the Mill Manager is responsible for providing the equipment and resources necessary for the successful implementation of the Respiratory Protection Program and for facilitating the application of engineering controls to reduce the need for the use of respiratory protection devices The Radiation Safety Officer RSO has primary responsibility for implementation and oversight of all aspects of the respiratory protection program The Mill Manager and the RSO will coordinate efforts to use to the extent practical procedures and engineering controls based on sound protection principles to achieve ALARA 1.2.1 Mill Manager The Mill Manager is responsible for ensuring that respiratory protection program meeting or exceeding that specified by regulation is established and maintained for the employees under his or her jurisdiction 1.2.2 Radiation Safety Officer The RSO is responsible for the implementation and direct control of the respiratory protection program The RSO is charged with the following responsibilities Supervision of respirator selection procedures Establishment of training sessions about respiratory equipment for employees Establishment of continuing program of cleaning and inspecting the equipment Designation of proper storage areas for respiratory equipment Establishment of issuance and accounting procedures for uses of respiratory equipment Establishment of medical screening programs and procedures for employees assigned to wear respiratory equipment Establishment of periodic inspection schedule of those work places/conditions requiring respiratory equipment to determine exposure and/or changing situations White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-l Book 14 Page4of2l continuing evaluation of the above aspects to assure their continued functions and effectiveness 1.2.3 Employees Respirators are provided to employees for their personal protection and the proper use of respirators in areas in which such protection is required is condition of their employment Violating the established rules for respirator use may result in disciplinary action up to and including dismissal 1.3 Policy Regarding Facial Hair The proper fitting of respiratory device is necessary to ensure that it will function adequately Facial hair beards mustaches and long sideburns will not allow an airtight seal to be formed between the face and mask as contaminated air will enter into the wearers breathing zone if the proper seal is not achieved Leakage of air into the mask will nullify the purpose of the respiratory device The policy of DUSA concerning facial hair is As condition of employment those employees who may at any time be required to wear respirator as part of their employment will not have any facial hair that will restrict the proper fitting of respiratory device 1.4 Physiological or Psychological Limitations to Respirator Use This section describes physiological and psychological including emotional factors which may limit an individuals ability to wear or work in respirator Any questions or problems concerning respirators or their use such as the types described in this section should be addressed to the RSO 1.4 Physiological Limitations As described below in Section 3.1 medical qualification will be required of each employee that might be using respirator in their normal work duties This is necessary to evaluate the individuals limitations to wearing respirator devices licensed physician to determine that the individual user is medically fit to use the respiratory protection equipment will perform the medical evaluation The physician will report on any physiological factors that may limit an individuals ability to wear respirator 1.4.2 Psychological Limitations Mental factors must also be taken into consideration when employees are required to wear respirators Some individuals become claustrophobic when wearing respirator These individuals should not be required to wear respirators if the condition is severe enough to cause panic White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page of 21 1.4.3 Other Factors Other factors which may cause problems in respirator sealing must be considered when performing fit testing These may include such factors as facial structure scars skin creases or dentures 2.0 PROCEDURES FOR RESPIRATOR USE 2.1 Supervision of the Program Including Program Audits The Respiratory Protection Program is administered by the RSO Quarterly ALARA Reports from the RSO are sent to members of the ALARA Committee The effectiveness of the Respiratory Protection Program is reviewed and exposure data evaluated during annual ALARA audits 2.2 Training and Minimum Qualifications of Supervisors supervisor that is person who has the responsibility of overseeing the work activities of one or more persons who must wear respirators shall be given adequate training to ensure the proper use of respirators Supervisor training shall include but shall not necessarily be limited to the following subjects Basic respiratory protection practices Nature and extent of respiratory hazards to which persons under his/her supervision may be exposed Principles and criteria of selecting respirators Training of respirator wearers Issuance of respirators Inspection of respirators Use of respirators including monitoring their use Maintenance and storage of respirators Regulations concerning respirator use 2.3 Training of Respirator Users Each employee who may wear respirator will be required to receive training for the proper use of the device The following outline will be followed during the training process Need for Respiratory Protection Equipment Mechanics of Breathing White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-l Book 14 Page6of2l Types of Respiratory Particles Dust Fumes Mists DUSAs Respiratory Company Respiratory Protection Policy Statement Respiratory Hazards Airborne uranium and effect Radon daughters and effect Chlorine and effect Ammonia and effect Airborne vanadium and effect Acid gases and effect Other effects Engineering Controls De-mister Ventilation Ventilating systems for the yellowcake dryer and packaging rooms Respirator Selection Type of respirators their function limitations Full-face with combination cartridges Powered Air Purifying Respirators PAPR with radiological dust cartridges Self-contained breathing apparatus NIOSH and MSHA approved respirators only Identification of Hazards 02 content Routine hazards Non-routine hazards Instructions on Field Inspection of the Respirator Valves Body of mask Straps Lens Air hoses White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page7of2l Fitting Donning and Wearing Instructions and Training Wearing instructions and training including practice demonstrations shall be given to each respirator wearer and shall cover the following items Donning including seal check wearing and removing the respirator Adjusting the respirator so that its respiratory-inlet covering is properly fitted on the wearer and so that the respirator causes minimum of discomfort to the wearer Allow the respirator wearer to wear the respirator in safe atmosphere for an adequate period of time to ensure that the wearer is familiar with the operational characteristics of the respirator Respirator Sealing Problems Respirators shall not be worn when conditions prevent seal of the respirator to the wearers face For example person who has hair beard stubble mustache sideburns beard low hairlines or bangs that passes between the face and the sealing surface of the face piece of the respirator shall not be permitted to wear such respirator person who has facial hair mustache or beard which interferes with the function of respirator valves shall not be permitted to wear such respirator Glasses which have temple bars or straps which passes between the sealing surface of respirators full-face piece and the wearers face shall not be used head covering which passes between the sealing surface or respirator face piece and the wearers face shall not be used The wearing of glasses or goggles face shield welding helmet or other eye and face protective device which interferes with the seal of respirator to the wearer shall not be allowed If scars hollow temples excessively protruding cheekbones deep creases in facial skin the absence of teeth or dentures or unusual facial configurations prevent the seal of respirator face piece to wearers face the person shall not be permitted to wear the respirator If missing teeth or dentures prevent the seal of respirator mouthpiece in persons mouth the person shall not be allowed to wear respirator equipped with mouthpiece If person has nose of shape or size that prevents the closing of the nose by the nose clamp of mouthpiece/nose White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page of 21 clamp type of respirator the person shall not be permitted to wear this type of respirator Maintenance Storage and Respirator Exchange Procedures Cleaning sanitizing and maintenance techniques for all types of respirators The frequency of respirator exchange clean exchanged for used Heavy use Occasional use The steps that are to be taken to exchange respirators When how and why SCBA are used Leaving Hazardous Area respirator wearer shall be permitted to leave the hazardous area for any respirator-related cause Reasons which may cause respirator wearer to leave hazardous area included but are not limited to the following Failure of the respirator to provide adequate protection Malfunction of the respirator Detection of leakage of air contaminant into the respirator Increase resistance to breathing Severe discomfort in wearing the respirator Illness of the wearer including sensation of dizziness nausea weakness fatigue breathing difficulty coughing sneezing vomiting fever or chills Claustrophobia anxiety or other psychological factors that may affect the wearer Emergency respirator use SCBA self-contained breathing apparatus Emergency respirator issuance Regulations for respirator use lOCFRPart2OSubpartH 2.4 Fit Testing Frequency annually for every employee who is required to wear respiratory protective device White Mesa Mill Standard Operating Procedures Date 2/08 Revision DUSA-2 RPP-1 Book 14 Page9of2l Quantitative fit testing will be performed using the FitTester 3000 or equivalent Quantitative fit testing measurements will be performed as follows on the FitTester 3000 or equivalent Input the employees name style of respirator and size Select perform fit test the computer will walk you through series of five tests During the testing program the computer will evaluate the employee If there is failure during any test the employee will adjust the respirator and try again If after several attempts to pass test and the employee still fails try different size respirator Once the employee passes each of the five tests document will be printed certifying the successful completion of the examination The document will then be signed by both the employee and the facilitator of the examination The document will then be filed with the employees other Safety documents in the Radiation Safety Department Qualitative fit testing measurements will be performed using an MSA ventilation smoke tube Part No 5645 or equivalent aspirator bulb Steps for respirator issuance fit testing are as follows Respirators equipped with high-efficiency filters will be used for this test red/green filters Both ends are broken on an MSA ventilation smoke tube One end is inserted into the tube connected to the positive pressure of two-way aspirator bulb and the other end covered by inch length of tygon surgical or rubber tubing The test aerosol is generated by squeezing the aspirator bulb The test subject will don the respirator and visual inspection of the facepiece to face seal made by the tester An obvious leak in the facepiece to face seal shall be reason to abort the test and record the mask as unsatisfactory Expression of discomfort created by the mask shall also be reason to abort the test The smoke will be generated in all areas surrounding the mask The smoke is not harmful however it is sufficiently irritating that if there is leak in the seal of the mask it will be discovered immediately Any indication of detection of the smoke by the test subject during fitting indicates failure of that respirator If leakage is detected the facepiece to face seal shall be visually inspected for obvious leakage If any doubt about the condition of the respirator or the filter exists another like respirator shall be tested to assure the leakage was due to the facepiece to face seal White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page lOof2l 2.5 Selecting Respirators Respirator selection will be determined by the type of environment in which the employee will be working The concentration of oxygen and the type and concentration of hazardous contaminants in the work area atmosphere must be considered during the selection process Prior to selecting specific type of respirator the work environment must be thoroughly evaluated for respiratory hazards The following questions must then be answered What are the hazards the employee will be exposed to What are the contaminants and their concentration Are there any contaminants in the workplace environment that may damage or irritate the eyes nose or skin Yes full-face style is recommended Is the oxygen concentration in the workplace atmosphere between 19.5% to 23% Yes combination cartridges will be used if the concentration of the contaminant is within the acceptable limits for the cartridge No The workplace or area may only be entered if the 02 concentration is between 19.5 and 23%The workplace environment will be remediated i.e ventilated by safety engineering controls such that the oxygen concentration falls between these limits before it may be entered Do the contaminant concentrations in the work environment exceed the limits listed for the combination cartridge being used Yes Modify the air contaminant concentration by safety engineering measures No combination cartridges may be used if oxygen concentration is between 19.5% and 23% 2.5.1 Air Purifying Respirators Only MSHA and NIOSH approved and accepted respirators will be used The inventory will consist of full face and PAPR units and SCBAs There is only one type of air purifying respirator cartridge used for air contaminants for the full-face respirators This is red/green GME-H universal cartridge which is normally effective for removing all air contaminants and atmospheric hazards and is approved by NIOSH for use under the following conditions Organic Vapors less than 1000 ppm Pesticides Mists of Paints Lacquers and Enamels White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 11 of 21 Dustless than 0.5 mg/m3 Fumes less than 0.5 mg/m3 Mists less than 0.5 mg/m3 The PAPR units are not designed for areas that may come in contact with chemical mists or high humidity The PAPR units use an Optifilter XL Filter Assembly HE that is only good for dusty environments These units are ideal for the packaging enclosure Yellowcake Dryers Ore Storage and Tails The PAPRs must have the battery fully charged prior to usage The battery charge on each unit will last approximately eight continuous working hours All maintenance and cleaning techniques utilized with the full-face respirators will be used for the PAPR units White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 12 of 21 2.5.2 Supplied Air Apparatus SCBA versus supplied air respirators Self-contained breathing apparatus will only be used for evacuation or emergency purposes Supplied air respirators will be the apparatus of choice when The length of the work exceeds 20 minutes There is adequate time to hook up hoses and filter boards If at any time the atmosphere contains materials that might be corrosive to the employee or respiratory device the area will be evacuated The area must be ventilated until the corrosive materials fall to safe level before work may resume 2.6 Maintaining Breathing Air Quality The quality of air delivered to all supplied-air respirators shall meet the requirements for Grade air for breathing air systems as defined in CGA G-7 1-1997 as cited in Regulatory Guide 8.15 under 6.5.2 Air Quality Requirements The ANSIJCGA G.7-1 1989 specifies the contents of Grade breathing air as oxygen volume/volume of 19.5 to 23.5%hydrocarbon condensed of mg/m3 of air or less carbon monoxide of 10 ppm or less carbon dioxide of 1000 ppm or less and the lack of noticeable odor 2.7 Inventory and Control of Respiratory Protection Equipment Storage cabinets that will be used for routine respirator issuance will be located in the respirator cleaning facility Only persons authorized to use respirators are to access the storage cabinets When an employee needs clean respirator he or she will obtain one from the storage location where clean respirators are packaged and kept After obtaining clean respirator the employee will enter the pertinent information on the log sheet that is kept in the cabinet with the clean respirators When used respirator is exchanged for clean unit the dirty respirator will be placed in the receptacle provided for such use Employees who routinely wear respirator for more than four hours each day or work in areas of higher exposure potential i.e yellowcake packaging or precipitation will be required to exchange respirators daily Employees that need to be issued PAPR unit will need to see the RSO or his designee to be checked out on the proper usage of the unit All PAPRs are inventoried and only key operators or RWP individuals will be issued one of these units White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 13 of 21 Those employees who do not use respirators routinely will exchange them as they become ineffective in eliminating the hazardous contaminant This determination is made by the employee by physical inspection of the respirator by impaired breathing i.e by plugging of cartridge or by the detection of irritant smoke or other conditions which may indicate defective device 2.8 Storage of Respiratory Protection Equipment Respirators shall be stored in manner sufficient to protect the device against dust sunlight extreme cold excessive moisture or damaging chemicals The cleaned respirators will be stored in cabinets in the respirator cleaning facility outside the safety department The respirators will be stored in single layers with the facepieces and exhalation valves in more or less normal position to prevent the rubber or plastic from cracking When respirators are not being used they must be stored in the plastic bags in which they were issued Dirty respirators will be placed in receptacles located in the mill central control room and at the maintenance shop They will be gathered from these locations for cleaning and repairs The frequency that dirty respirator must be exchanged for clean one will be determined by the amount of time it is used If the employees use is greater than four hours per day the exchange will be made daily Occasional use will require weekly exchange Infrequent use will require monthly exchanges The cabinets containing emergency respirators will be located in areas that are readily accessible and in areas in which hazard may arise Emergency cabinets are located on the north side of the mill building outside of the SAG Mill doors outside the SX on the north wall on the south end of SX on the fire cabinet and at the fire hose station at the front gate All employees should be made aware of these locations The cabinets will not be locked but they will have seals attached to the hasps The seals will prevent employees from using the respirators for routine use but will allow emergency access During emergencies the seal will be broken and respirator may be selected in matter of seconds 2.9 Maintenance Repair Testing and Quality Assurance of Respiratory Protection Equipment Respirators and component parts shall be maintained and repaired only by persons specifically trained to perform this work Repairs and maintenance shall be performed in accordance with the procedures detailed below 2.9.1 Maintenance Cleaning Repair and Testing Each used respirator must be disassembled before cleaning the cartridges must be removed and discarded and any hoses or regulators must be removed and washed White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 14of21 separately Some of the units have elastic head straps these should also be removed and washed separately The respirators will be cleaned and rinsed in commercially available dishwasher The radiation and safety staff will perform cleaning and washing of respirators The respirators will be washed and then aired dried Each reassembled respirator must be inspected for radiation contamination before it is used An instrument survey or swipe test may be conducted to determine if any item is contaminated The equipment check must indicate levels of less than 100 dpmIlOO cm2 of alpha radiation or 1000 dpmllOO cm2 of beta-gamma radiation to be serviceable If repeated washings do not decrease contamination to acceptable levels that item must be disposed of Respirators shall be inspected in accordance with NRC Regulatory Guide 8.15 Revision October 1999 The following conditions should be checked during any type of inspection Air Purifying Respirators Routinely used air purifying respirators should be checked as follows before and after each use Examine the facepiece for Excessive dirt Cracks tears holes or distortion from improper storage Inflexibility stretch and massage to restore flexibility Cracked or badly scratched lenses in full facepieces Incorrectly mounted full facepiece lens or broken or missing mounting clips Cracked or broken air purifying element holders badly worked threads or missing gaskets if required Examine the head straps or head harness for Breaks Loss of elasticity Broken or malfunctioning buckles and attachments Full facepieces only excessively worn serrations on the head harness which might permit slippage Examine the exhalation valve for the following after removing its cover Foreign material such as detergent residue dust particles or human hair under the valve seat Cracks tears or distortion in the valve material Improper insertion of the valve body in the facepiece White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 15 of 21 Cracks breaks or chips in the valve body particularly in the sealing surface Missing or defective valve cover Improper installation of the valve in the valve body Examine the air purifying elements for Incorrect installation loose connections missing or warn gaskets or cross-threading in holder Cracks or dents in outside case of filter cartridge or canister If the device has corrugated breathing tube examine it for Broken or missing end connectors Missing or loose hose clamps Deterioration determined by stretching the tube and looking for cracks Examine the harness of front or back mounted gas mask for Damage or wear to the canister holder which may prevent its being held securely in place Broken harness straps or fastenings Blower mechanism on the PAPR units only Damage to the outer casing of the blower unit will result in the replacement of the blower Missing or broken pins that connect the blower to the battery pack will result in replacing of damaged pieces Supplied Air Respirators The following shall be checked If the device has tight fitting facepiece use the procedures outlined above for air purifying respirators Examine the air supply for Integrity and good condition of air supply lines and hoses including attachments and end fittings Correct operation and condition of all regulators valves or other air flow regulators White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 16 of2l 2.9.2 Quality Assurance To prevent the use of faulty or defective respiratory equipment the following steps will be taken New Equipment All new equipment will be thoroughly inspected before it is put into service Only MSHAINIOSH approved equipment will be used Parts used for repairs will be purchased only from the manufacturer of the unit being repaired or theft agents Cleaning and Repairs All respiratory devices will be inspected before and after cleaning and before and after repairs are made The inspection procedures that are to be used are listed above under Section 2.9.1 Any replacement items that will be used for repairs will be inspected prior to assembly Periodic Checks of Items in Storage At lease once during each quarter all of the respirators that are in storage will be checked for serviceability and to make sure that they will be ready for immediate use 2.10 Recordkeeping Inspections of all respiratory devices will be conducted in accordance with the provisions contained in NRC Reg Guide 8.15 and section 2.9.1 above and under no circumstances shall device that is known to be defective be used Freshly cleaned and inspected respirators will be placed in plastic bags and sealed The individual who serviced the respirator shall write the date on each bag and initial it to indicate the work has been done properly Respirators used for emergency use are inspected and the inspection recorded once per month 2.11 Limitations on Periods of Respirator Use and Relief from Respirator Use As noted above under Section 1.2 the NRC has noted that the use of respiratory protection devices in the workplace can impose physiological and psychological stresses on workers obstruct their vision hinder their movements and make effective communications difficult In consideration of this respirator wearer shall be permitted White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 17 of2l to leave the work area for any respirator-related cause Reasons which may cause respirator wearer to leave work area include but are not limited to the following Failure of the respirator to provide adequate protection Malfunction of the respirator Detection of leakage of air contaminant into the respirator Increased resistance to breathing Severe discomfort in wearing the respirator Illness of the wearer including sensation of dizziness nausea weakness fatigue breathing difficulty coughing sneezing vomiting fever or chills Claustrophia anxiety or other psychological factors that may affect the wearer 2.12 Monitoring Including Air Sampling and Bioassays 2.12.1 Evaluation of Respiratory Hazards Before respiratory protective device is used the work area must be evaluated as to the type of hazards that may be encountered The type of respiratory protection may be selected only after the hazard has been classified Most areas of the mill have been evaluated for hazards during routine work assignments Signs will be posted in the different areas that will indicate the type of respiratory device to be used under normal conditions Equipment needed Oxygen and Combustible Gas Detector MSA Orion or equivalent MSA Samplair Pump Kit or similar with the following detector tubes Carbon Dioxide Carbon Monoxide Sulfur Dioxide Ammonia Hydrogen Sulfide Nitrous Oxide Halogen Gases Chlorine Acid fumes and mists Organic vapors White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 18 of2l Many environmental designs were incorporated into the mills construction to keep exposures to most hazards at minimum This environmental equipment is checked frequently to ensure that it is functioning properly To ensure the reliability of these controls monthly gross alpha and radon daughters samples will be collected at numerous locations throughout the mill Routine samples will also be collected in the vanadium precipitation and packaging areas and analyzed for airborne vanadium The routine samples have already identified some areas that require respirator use at all times during normal working conditions These areas are inside the yellowcake dryer and packaging enclosures and the vanadium dryer area and the packaging area Other areas that may require respirator use may include but would not be limited to the sample bucking room and the SAG mill Respirators need not be worn routinely during normal working conditions in other areas of the mill At these locations usage will be determined by the hazard level or at the employees request Occasionally condition may exist that the environmental controls cannot handle At that time the appropriate respirator must be used until the workplace atmosphere is returned to normal Infrequently maintenance work will have to be performed in areas that are not normally sampled or areas that may have questionable air quality Prior to anyone entering one of these areas the environment must be evaluated to determine what hazards exist Safe Work Permit is issued for all work tasks that are anticipated to present unidentified or unusual hazardous environmental conditions Radiation Work Permit is issued for work in unassessed areas or for nonrecurring tasks for which engineering controls are not in place or practical The safety department will be responsible for the evaluation of the areas before work begins When the oxygen concentration is listed as potentially hazardous portable detector will be used to determine the exact oxygen-air mixture NIOSH defines that air which contains less than 19.5% 02 is an oxygen-deficient atmosphere and attempting to breathe such air is considered to present hazard that would be immediately dangerous to life and health Any area having less than 19.5%02 will not be entered until or unless the 02 concentration returns to and is maintained at level above 19.5%If an area is identified as having an oxygen-deficient atmosphere the oxygen levels must be remedied by engineering controls prior to entry by personnel The use of SCBA will only be for emergency escape or emergency response purposes Other atmospheric hazards will be identified and quantified by using air sampling equipment such as the MSA Samplair Pump or similar device with detector tubes for the specific contaminant in question The instructions must be carefully read for every test as each type of detector tube is handled differently After exposure to the atmosphere the tubes will indicate the presence and concentration of the chemical for which that tube is designed Chemical cartridges are good only in White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 19 of 21 atmospheres in which the chemical concentration is less than the limit set by the manufacturer and the oxygen concentration is equal to or greater than 19.5%As noted above the company policy is not to enter an area in which the 02 level is below 19.5% but to enter such areas only in emergency situations such as to retrieve an injured worker and then with the use of SCBA There are many other hazards that are very obvious but are often overlooked The following are examples dust concentrations have an adverse affect on breathing and/or the comfort of the individual some substances may cause irritation to the eyes nose throat etc but may not be chemically toxic These and other such conditions should always be considered in evaluating respiratory hazards If there is any doubt about the conditions within the work area respiratory device should be used Always be conservative 2.11.2 Breathing Zone Air Samples Breathing zone samples are collected to determine the air contamination concentration an individual may be exposed to during the execution of his job The respiratory protection factor is used to calculate the individuals exposure during the work task duration The application of respiratory protection factor assigned to the particular respiratory device is used to reduce an individuals exposure to an air contaminant concentration as determined by breathing zone sampling Routine breathing zone samples are collected by the use of small belt-mounted pump attached to hose that is in turn attached to the persons clothing close to the head or breathing zone The sample is collected for period of time that would be representative of one eight hour workday They are collected in such manner that the material collected will be representative of that being inhaled by the individual wearing the sampler 2.11.3 Bioassay Program Evaluation of the effectiveness of the respiratory protection program will be accomplished by air sampling described above in 2.12.1 and by the Mill Bioassay Program Those employees who are working in areas that require the use of respirators will submit urine specimen for analysis on biweekly basis Employees who use respirators during maintenance may also be required to submit specimens after maintenance ceases The samples will be collected from individuals who have performed maintenance tasks in atmospheres that are significantly elevated in contaminant concentration or they are working in such an area for an extended period of time The specimens will be analyzed for uranium content White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 20 of 21 3.0 PROCEDURES FOR MEDICAL EVALUATIONS AND AUDITS 3.1 Performing and Documenting the Required Medical Evaluation Medical qualification will be required of each employee that might be using respirator in their normal work duties This is necessary to evaluate the individuals limitations to wearing respirator devices The medical evaluation will be performed by licensed physician to determine that the individual user is medically fit to use the respiratory protection equipment Medical evaluation will be performed prior to the initial fitting of respirator use and either every 12 months thereafter or periodically at frequency to be determined by the physician The medical screening process will include medical history and will be sufficient in the opinion of the physician to identify any person who should not use respiratory devices for medical reasons or who should be limited to the use of specific types of respirators The physician will report any medical restrictions the employee has that would limit an individuals ability to use respirator Based on the physicians recommendations any employee may be subject to additional or more frequent medical evaluation as deemed necessary by the physician 3.2 Maintaining TEDE ALARA and Performing ALARA Evaluations of Respiratory Protection As stated in the Policy Statement in 1.0 DUSA shall use to the extent practical procedures and engineering controls based on sound protection principles to achieve ALARA and shall limit intakes by means of engineering controls or procedures along with the use of respirators consistent with maintaining the TEDE ALARA When specific ALARA evaluation is performed to justify the use or nonuse of respirators the evaluation shall consider the elements detailed in Section 2.1 of Regulatory Guide 8.15 4.0 PROCEDURES FOR RESPIRATOR APPLICATIONS 4.1 Routine Respirator Use As noted above under 2.8 the cabinets for routine use respirators will be located in the respirator cleaning facility outside the safety department Respirators will not be issued to employees unless they are to be used Only employees having current authorization to use respirators are to access the storage cabinets and obtain respirators When respirators are not being used they must be stored in the plastic bags in which they were issued Dirty respirators will be placed in receptacles located in the mill central control room and at the maintenance shop They will be gathered from these locations for cleaning and repairs White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 RPP-1 Book 14 Page 21 of 21 Donning the respirator must be performed in accordance with the training provided At least one type of user seal check must be performed immediately prior to exposure to ensure that the respirator is properly seated on the face The frequency that dirty respirator must be exchanged for clean one will be determined by the amount of time it is used If the employees use is greater than four hours per day the exchange will be made daily Occasional use will require weekly exchange Infrequent use will require monthly exchanges 4.2 Nonroutine Respirator Use Nonroutine Respirator Use shall be defined as use of respirators in unassessed areas or for nonrecurring tasks for which engineering controls are not in place of practical 4.3 Emergency Respirator Use Emergency Respirator Use shall be used for recovery of an injured person from an area where air concentrations of radioactive material may be high the breathing quality of the ambient air has not been assessed or the area may become immediately dangerous to life or health IDLH because of the presence of nonradiological hazards Respirators designed for emergency use will be stored in areas that are readily accessible to all employees Emergency cabinets are located on the north side of the mill building outside of the SAG Mill doors outside the SX on the north wall on the south end of SX on the fire cabinet and at the fire hose station at the front gate White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 GROUNDWAThR MONITORING PLAN AND STANDARD OPERATING PROCEDURES FOR UDEQ SPLIT SAMPLING PROGRAM International Uranium USA Corporation P.O Box 809 BlandingUT 84511 CDocuments and Settings\dfrydenlund\Local Settmgs\Temporary Internet Files\Content.Outlocjk\l 5CXRH6ZUDEQ Groundwater Split Sampling Procedures.docPtdminJ4aster SOPBook 18 UDEQ Procedure Plan\UDEQ Groundwater Split Sampling Procedure3doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 TABLE OF CONTENTS SECTION PAGE GROUNDWATER MONITORING PLAN AND STANDARD OPERATING PROCEDURES PART GROUNDWATER MONITORING PLAN 1.0 GROUNDWATER MONITORING 2.0 QUALITY ASSURANCE PART II-GROUNDWATER STANDARD OPERATING PROCEDURES STANDARD OPERATING PROCEDURE NO 1.0-GROUNDWATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS 1.0 EQUIPMENT 1.1 SAMPLING EQUIPMENT 1.2 MEASUREMENT OF PHREATIC ELEVATIONS 2.0 MONITORING METHODOLOGY 2.1 PHREATIC ELEVATIONS QUARTERLY 2.2 GROUNDWATER QUALITY 2.3 FIELD SAMPLE PROCEDURE FOR MONITORING WELLS 2.4 FIELD SAMPLING PROCEDURE FOR CULINARY WELLS 2.5 FIELDDATA 2.6 SAMPLE TRANSPORTATION 10 3.0 CALIBRATION 10 3.1 PIIREATIC MEASUREMENTS 10 3.2 WATER QUALITY 10 4.0 RECORD KEEPING 10 5.0 MONITORING LOCATIONS AND FREQUENCY 10 6.0 ANALYSIS PROCEDURE 10 7.0 QUALITY ASSURANCE METHODOLOGY 11 7.1 WELL CONTAMINATION 11 7.2 PHREATIC ELEVATIONS 11 7.3 WATER QUALITY 11 STANDARD OPERATING PROCEDURE NO 2.0 SAMPLE HANDLING DOCUMENTATION AND ANALYSIS 12 1.0 SAMPLELABELING 12 2.0 SAMPLE HANDLING AND SHIPPING 12 3.0 SAMPLE DOCUMENTATION AND TRACKING 12 4.0 SAMPLE CHAIN-OF-CUSTODY 13 5.0 RECORD KEEPING 13 6.0 PVC WELL CASING LIMITATIONS 13 C\Documents and Settinas\dfrvdenlund\Local Settings\Temporarv internet Fiies\Content.Outiook\I 5CXRH6Z\UDEO Groundwater Split Sampling Procedures.docPAciminMaster SOP\Bonk 8_UDEQ Procedures Plans\UDEQ Groundwater Split Sampling Proceduresdoc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 TABLE OF CONTENTS SECTION PAGE STANDARD OPERATING PROCEDURE NO 3.0 DATA VALIDATION 15 1.0 DATAVALIDATIONANDREVIEW 15 1.1 DATAQUALIFIERS 15 1.2 REQUIRED CONTENTS OF LABORATORY ANALYTICAL DATA PACKAGES 15 2.0 DATA VALIDATION PROCEDURE 15 3.0 CORRECTIVE ACTION 15 TABLE 1-GROUNDWATER MONITORING PROGRAM 16 TABLE 2-SAMPLE PRESERVATION 17 TABLE 3-DETECTION LIMITS 18 ATTACHMENT 1-FIELD WATER ANALYSIS OF GROUNDWATE 19 ATTACHMENT 2-CALCULATION OF CASING VOLUME FROM DEPTH OF WATER IN WELL2O C\Documents and Settings\dfrydenlund\Local Senings\Temporary Internet Files\Content.Outlook\SCXRFI6Z\UDEQ Groundwater Split Sampling Procedures.doePAdminMaateT SOPs\Book IS_UDEQ Procedures PIanAUDEQ Groundwater Split Sampling Procedurendoc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 GROUNDWATER MONITORING PLAN AND STANDARD OPERATING PROCEDURES PART GROUNDWATER MONITORING PLAN 1.0 GROUNDWATER MONITORING Groundwater is sampled on quarterly basis for water surface elevations and analysis of radionuclides and chemical parameters The active monitoring wells are MW-5 MW-il MW-i2 MW-i4 MW-iS and MW-i7 Quarterly groundwater samples are tested for the following parameters U-Nat nickel potassium and chloride UDEQ has requested an additional sampling program the split sampling program involving additional wells and parameters This Groundwater Monitoring Plan and SOP applies only to the groundwater split sampling events requested by UDEQ Quarterly POC sampling of monitoring wells for compliance with the NRC license requirements will continue to be conducted in accordance with the most current revision of the Groundwater Monitoring Plan and Standard Operation Procedures for quarterly POC Monitoring To implement the DEQ split-sampling program monitoring wells MW-i MW-2 MW-3 MW-4 MW-i8 MW-i9 and culinary wells and will be sampled in addition to the six POC wells named above The sampling parameters for the DEQ split-sampling program will include VOCs SVOCs radiologics major ions dissolved metals pesticides herbicides and nutrients for all wells If split sampling for UDEQ occurs on the same dates as the quarterly POC monitoring separate samples will be collected for the split sampling and quarterly POC sampling The separate quarterly POC samples will be analyzed and results reported in accordance with the Groundwater Monitoring Plan and Standard Operation Procedures for Quarterly POC Monitoring and the current NRC license conditions 2.0 QUALITY ASSURANCE Quality assurance for groundwater monitoring consists of QC samples submitted with each set of samples The QC samples for split sampling consist of duplicate spike equipment rinsate and blank During split sampling one QAIQC trip blank for VOCs will also be sent with each cooler list of sample containers and the preservatives to be used for split sampling is shown in Table Cf\Documents and Seuinas\dfrydenlund\Local Settngs\Teniporary Internet Files\Content.Outlook\5CXRHGZ\UDEQ Groundwater Split Sampling Piocedures.docp\Admin\Master SOP\Book 18 UDEQ Procedures PIanAUDEQ Groundwater Split Sampling Procedurc3.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 PART II GROUNDWATER STANDARD OPERATING PROCEDURES STANDARD OPERATING PROCEDURE NO 1.0 GROUNDWATER SAMPLING PROCEDURE AND MEASUREMENT OF FIELD PARAMETERS 1.0 EQUIPMENT Groundwater monitor wells consist of narrow diameter PVC cased wells Equipment used for groundwater sampling program is as follows 1.1 Sampling Equipment 1.8 inch O.D air-driven sampling pump 150 psi air compressor and ancillary equipment pH meter and probe Temperature level and conductivity meter with probe 0.45 micron filters Field preservation chemicals H2S04 HNO3 HC1 Five gallon sample bucket Sample containers and labels see Table Rubber gloves 10 Distilled water 11 Teflon bailer and rope 12 Cooler and ice 1.2 Measurement of Phreatic Elevations Measurement of phreatic elevations is accomplished by using the following water level equipment YSI Model 3000 temperature level and conductivity meter with probe or equivalent C\Documents and Settings\dfrydenlund\Local Seuings\Temporarv Internet Files\Content.Outlook\I 5CXRHZ\UDEO Groundwater Split Sampling Procedures.docPVtdmin\Maater SOP\Book 8_UDEQ Procedures PIans\UDEQ Groundwater Split Sampling Procedurec.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 2.0 MONITORING METHODOLOGY 2.1 Phreatic Elevations Quarterly Phreatic elevations are determined in each monitoring well prior to sampling by using water level indicator meter Field log books are maintained listing depth to water from top of casings Readings are taken by lowering the sensor into the casing until the electrical sensor contact shows that conductive liquid has been reached The distance from the point of contact to known one-foot interval marker on the wire is determined using tape measure in inches or the scale provided on the back of the T-L-C meter in tenths of foot Data is recorded as Depth to Water This information is maintained on computer files There are no action levels associated with monitor well phreatic elevation 2.2 Groundwater Quality The perched zone monitoring wells at the White Mesa Mill are located in low-yield formation During any sampling event some or all of the perched zone wells may be incapable of yielding two casing volumes of purge water The sampler will attempt to evacuate two casing volumes If the well yields two casing volumes the individual performing the sampling should immediately test for pH temperature and specific conductance and collect the samples at once in order of the parameters volatilization sensitivity If the well cannot yield two casing volumes the individual performing sampling should evacuate the well to dryness once Approximately 24 hours later the first sample should be tested for pH temperature and specific conductance Samples should then be collected and containerized in the order of the parameters volatilization sensitivity The well should be retested for pH temperature and specific conductance after sampling as measure of purge efficiency and as check on the stability of the water samples over time The wells will be sampled for the following parameters in the order listed Volatile Organic Compounds VOC 120 ml samples Semi-volatile Organic Compounds SVOC liter samples POC parameters filtered liter sample Dissolved Metals 250 ml samples Pesticides liter samples Herbicides liter samples Nutrients 2500 ml samples Major ions 1/2 gallon samples C\Documents and Settinas\dfrydenlund\Local Settings\Ternporary Internet Files\content.outlook\l SCXRH6Z\UDEC Groundwater Split Sampling Procedures.docPAdminMarter SOPsBook ISUDEQ Procedures Plans\UDEQ Groundwater Split Sampling Proceduresdoc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 Radiologics 1/2 gallon samples All UDEQ split samples will be unfiltered except for the samples collected for POC parameters dissolved metals and radiologics 2.3 Field Sampling Procedure for Monitoring Wells After two casing volumes have been evacuated or 24 hours after low yield well has been evacuated teflon bailer will be lowered to collect sample for VOCs and SVOCs Sample collection equipment should be rinsed with water from the source before containers are filled Care should be taken to not agitate the water in the well during the repeated lowering of the bailer The VOC and SVOC sample should be slowly decanted into the sample container filling the container completely The sample should then be rapidly capped excluding any headspace inverted to check for air bubbles and put into sample cooler as soon as possible The remaining samples POC parameters metals pesticides herbicides nutrients major ions and radiologics will be collected using the field pump Remove casing cap and check water level in well by lowering the electrical water level probe until conductance reading is measured Record water level in Monitoring Well logbook Record the water level casing volume and other data required in Attachment This may be recorded in the well logbook Determine the casing volume Volumegaj O.653h for casing volume and Volumegai .367h for casing or see Attachment Lower field pump into well making sure to keep pump at least five feet from the bottom of the well Evacuate two casing volumes if possible If well cannot yield two casing volumes evacuate well to dryness and wait 24 hours before performing step Remove pump from well and replace the casing cap on well if necessary Rinse pump with distilled water before sampling next well CDocuments and Setttnas\dfrvdeiilund\Local Seuings\Ternporan Internet Files\Content.Outlook\l 5CXRHOZ\UDEQ Groundwater Split Sampling Procedures.dpcPAdmin\Maiter SOPs\Bonk 18 UDEQ Procedures Plane\UDEQ Grnundwater Split Sampling Procedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 U7DEQ Split Sampling Groundwater Monitoring Plan Page of 21 Lower teflon bailer into well to collect VOC and SVOC sample 10 The first sample collected with the teflon bailer should be tested for p11 temperature and specific conductance 11 Add preservative to sample container if required 12 Slowly pour the sample from the teflon bailer into the sample containers for VOCs and SVOCs taking care not to agitate the sample 13 When filling the sample containers for VOCs allow the groundwater to fonn meniscus in the sample container and quickly cap the sample excluding any headspace 14 Invert the sample bottle to check for air bubbles 15 After samples have been collected for VOCs and SVOCs lower field pump into well 16 If filtered sample is required rinse filter with water from the sample source and place 0.45 micron filter on sample tubing Be careful not to contaminate filters by handling them with dirty fingers or gloves 17 Pump sample through filtration unit if required and into sample container after letting the first 100 ml be used to rinse the sample container and be wasted 18 Add preservative to sample container if required 19 Rinse lid of sample container when container is filled with filtered or uiifiltered water depending on the type of sample to be collected and tighten lid onto container C\Documents and Settinas\dfrydenlund\Local Settings\Ternpora Internet Files\Content.Outlook\l 5CXRH6Z\UDEC Groundwater Split Sampling Procedures.docPAdmin\Mater SOPs\Book S_UDEQ Procedures PIans\UDFQ Groundwater Split Sampling Procedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page of 21 20 Identify and label the sample container with Project/facility Date and time of sample Any preservation method utilized Samplers initials Filtered or unfiltered Ii Sample location 21 Place sample in cooler Upon returning to the office the samples are stored in refrigerator at until transferred to the analytical laboratory 22 Before leaving the sampling location thoroughly document the sampling event in the field logbook by recording the items required in SOP 2.0 Step and any other significant features or conditions during the sampling event 2.4 Field Sampling Procedure for Culinary Wells The sampling procedure for the culinary wells will be the same as the procedure for the monitoring wells except that all samples will be obtained from the pump located in the culinary well and the well will not be purged before the samples are collected The groundwater will be tested for pH conductance and temperature until three successive samples show stabilized readings on pH to 0.50 temperature to 2C and conductivity to 500 umhos When the well water has reached equilibrium the samples will be collected 2.5 Field Data Field data is retained on file or on computer for review This information is compared to the analytical results of sampling for Quality Assurance and correctness The sampler or observer will record the same types of information in the well logbook as described in Section 2.3 above CDocuments and Sethnas\dfrydenlund\caI SettmgsVLemporary Internet Files\Content.Outlook\I 5CXRHZ\UDEQ Groundwater Split Sampling Procedures.docR\Admin\Master SOPs\Book 8_UDEQ Procedures Plm\UDEQ Groundwater Split Sampling Proceduremdoc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 10 of 21 2.6 Sample Transportation Samples are catalogued at the White Mesa Mill office and sent to the Analytical Laboratory with the appropriate Chain of Custody sheets attached Samples are transported via sealed containers by postal or contract services Laboratory chain of custody procedures will be followed 3.0 CALIBRATION 3.1 Phreatic Measurements Equipment used in phreatic measurements is checked for calibration quarterly 3.2 Water Quality Probe and meter function including temperature p11 and conductivity are calibrated prior to each use by using known pH solutions and conductivity standards Temperature is checked comparatively by using thermometer 4.0 RECORD KEEPING Field data are logged onto field file worksheets see Attachment and into the field logbook Once all the data for the quarter all wells is completed the data from the worksheets is typed into computer file Certificates of analysis and computer worksheets are maintained as backup file for this information Data includes well I.D sample date well phreatic elevations field analytical data and all analytical data 5.0 MONITORING LOCATIONS AND FREQUENCY Monitor wells are monitored quarterly for phreatic elevation radionuclide and chemical analyte constituents For UDEQ split sampling water samples are collected from monitor wells 11 12 14 15 17 18 and 19 and culinary wells and 6.0 ANALYSIS PROCEDURE Analytical procedures utilized by the contract laboratory are in accordance with their respective established quality assurance and quality control programs The analyses to be performed on each well sample collected for the split sampling program as follows VOCs SVOCs POC parameters dissolved metals C\Documents and Settinas\dfrydenlund\Local Settings\Teniporary Internet Files\Content.Outlook\I 5CXRHZ\UDEO Groundwater Split Sampline Procedures.docP\Admin\Master SOP\Book IS UDEQ Procedures Planc\UDEQ Groundwater Split Sampling Procedurec.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 11 of 21 pesticides herbicides nutrients major ions radiologics Detailed information on sample size preservation techniques holding times analytical procedure numbers and required limits of detection for each parameter are provided in Tables and 7.0 QUALITY ASSURANCE METHODOLOGY 7.1 Well Contamination Well contamination from external surface factors is controlled by installation of cap over the surface casing and cementing the surface section of the drill hole Wells have surface covers of mild steel with lockable cap cover Environmental staff have access to the key series locking the wells Subsurface well stagnation for pumped wells is reduced by purging the monitoring wells and pumping the culinary wells until the temperature pH and conductivity levels of water samples become consistent This verifies that the aquifer zone water is being drawn into the well and is representative sample 7.2 Phreatic Elevations Monitoring of phreatic elevations is controlled by comparing historical field log data to actual measurement depth This serves as check of the field measurements 7.3 Water Quality Quality assurance of water sample collection sample handling and preservation is maintained by following procedures established in the White Mesa Mill groundwater quality assurance plan Observation of technician performance is monitored on periodic basis to ensure compliance with this procedure Blind duplicates of at least one well per quarter are submitted to the analytical laboratory to monitor field and laboratory quality assurance performance Deviations exceeding ten percent 10%result in analytical and field procedure review C\Documents and Settings\dfrydenlund\Local Settings\Ternporary Internet Files\Content.Ontlook\l SCXRHZ\UDEQ Groundwater Split Sampling Procedures.docPAdmin\Ma3ter SOPsook SUDEQ Procedures Plans\UDEQ Groundwater Split Sampling Proceduresdoc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UIDEQ Split Sampling Groundwater Monitoring Plan Page 12 of 21 STANDARD OPERATING PROCEDURE NO 2.0 SAMPLE HANDLING DOCUMENTATION AND ANALYSIS 2.1 1.0 SAMPLE LABELING All sample labels must be filled out in ink and numbered The date time samplers initials and the sample location will be identified on each sample The following information will be contained on the label projectifacility date and time of sample collection samplers initials filtered or unfiltered preservatives and sample location 2.0 SAMPLE HANDLING AND SIUPPING Sample containers will be placed and packaged in large plastic coolers Samples will be stored at four degrees Centigrade Samples will then be transported in these sealed containers by postal contract services to the contract analytical laboratory Chain-of-Custody reports will be placed inside resealable bag and taped to the inside lid Seals will be placed on outside of packaging 3.0 SAMPLE DOCUMENTATION AND TRACKING Documentation of observations and data from sampling provide important information about the sampling process and provide permanent record for sampling activities All observations and sampling data will be recorded in waterproof ink in bound field logbook with consecutively numbered pages The field logbook will contain the following information project name sample location samplers names and signatures date and time of sample collection sample depth description of sample type description of QA/QC samples sample handling including filtration and preservation when warranted field observations such as weather conditions 10 results of in- field measurements and 11 names of personnel present observing the sampling The field logbook will also contain detailed notes describing any other significant factors during the sampling event including as applicable mechanical equipment and vehicles operating nearby condition of the well cap and lock water appearance color odor clarity presence of debris or solids placement of sample containers and coolers relative to the sample pump exhaust difficulties in sample handling container filling or preservation any variances from the sampling plan and procedures and any other relevant feature or condition 4.0 SAMPLE CHAIN-OF-CUSTODY C\Documents and Settings\dfrydenlund\Local Settings\Ternporary internet Files\Content.Outlook\I SCXRH6Z\UDEO Groundwater Split Samplina Procedures.docPAdmin\Maater SOPs\Book IS UDEQ ocedure Plans\UDEQ Groundwater Split Sampling Procedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 13 of 21 Chain-of-Custody form accompanies the sample being shipped to the laboratory Standard Chain-of-Custody protocol is initiated for each sample set COC form is to be completed for each set of samples collected in container and is to include the following samplers name company name date and time of collection sample location and analyses requested The person shipping the samples to the laboratory will sign the COC form document shipment method and send the original and the second copy of the COC form with the samples Upon receipt of the samples the person receiving the samples will sign the COC form and return the second copy to the Environmental Coordinator Copies of the COC forms and other relevant documentation will be retained at this facility 5.0 RECORD KEEPING All groundwater data are kept in the files and when analytical results are available the results are entered into computer file Laboratory analytical data are stored in the groundwater files after the data has been entered on computer file Records will be maintained at this facility for the appropriate period of time 6.0 Pvc WELL CASING LIMITATIONS Numerous evaluations have been conducted of what impact PVC well casings may have on groundwater sampling results for VOCs These studies have often resulted in significantly different conclusions However the vast majority have concluded that PVC is capable of sorbing and leaching organic constituents These varying conclusions reflect different interpretations of what constitutes significant parameter interference In some cases PVC interference may be insignificant while in others it may seriously bias the analytical results Regardless EPA continues to advise against the use of PVC well casings where dilute organic concentrations are expected or are of interest If high concentrations are encountered greater than mgfL it is unlikely that leaching from the PVC-cased wells at the Mill would present any significant bias However should analytical results indicate low level detection of organic compounds in number of the wells the detected parameters should be compared to the list of those known to leach from PVC or glued joints Given that the limit of detection of EPA Method 8260 is ug/L analytical results for parameters known to leach from PVC or glued joints near the detection level could realistically be produced by PVC interference and should be attributed to that source C\Docurnents and Seuinas\dfrydenlund\Local Settings\Ternporai-y Internet Files\Content.Outlook\I 5CXRHZ\UDEQ Groundwater Stlit Sarnoling Procedures.clocP\Admin\Master SOP1Bonk 18 UDEQ Procedures Plans\UDEQ Groundwater Split Sarnpling Procedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UIDEQ Split Sampling Groundwater Monitoring Plan Page 14 of 21 STANDARD OPERATING PROCEDURE NO 3.0 DATA VALIDATION 1.0 DATA VALIDATION AND REVIEW 1.1 Data Qualifiers Laboratory analyses will be reviewed by the Environmental Coordinator and/or staff Quality control samples provide comparative basis for analysis fundamental to this review process Rejected data will not be usable for any purpose 1.2 Required Contents of Laboratory Analytical Data Packages The contract laboratory will prepare and retain all analytical and QC documentation The laboratory will provide hard copy information in each data package submitted in accordance with QA objectives for the Surface Water QA Project Plan COC forms cover sheets with comments narrative samples analyzed reporting limits and LLD values for analytes and analytical results of QC samples The data reduction and laboratory review will be documented signed and dated by the analyst 2.0 DATA VALIDATION PROCEDURE Ten percent of the data will be subjected to complete data validation using appropriate scientific methods and guidance from NRC Regulatory Guides 4.14 and 4.15 minimum of reported results of one or more analytes for ten percent of the samples will be recalculated from the raw data and checked for transcription order The laboratorys data validation specialist will be responsible in part for validating the analytical data 3.0 CORRECTIVE ACTION Corrective action will be taken for any noted deficiency in laboratory data QA/QC problems will be brought to the immediate attention of the environmental coordinator and or staff Appropriate response measures will be taken with regard to these problems Appropriate attachments and forms are maintained by the Environmental Department in accordance with record keeping policies of the White Mesa Mill C\Documents and Settins\dryden1und\Loca1 Settrngs\Ternporary Internet Files\Content.Outlook\I CXRH6Z\UDEO Groundwater Split Sampling Procedures.docPAdmin\Master SOPs\Boolc S_UDEQ Procedures Plans\UDEQ Groundwater Split Sampling Proccdures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 15 of 21 TABLE GROUNDWATER MONITORING PROGRAM MONITOR SITES Monitor Wells No 11 12 14 15 17 18 19 Culinary Wells and QA/QC samples FIELD REQUIREMENTS Depth of well in feet to nearest tenth inch Temperature in degrees Celsius pH to two decimal places Specific conductance in umhos at temperature Detailed description of field sampling conditions in well logbook LAB REQUIREMENTS POC Quarterly Samples UDEQ Split Samples filtered unfiltered except metals Chlorides VOCs Nickel mg/l SYOCs Potassium mgIl Dissolved Metals U-nat uCiIml Pesticides U-nat LLD uCilml Herbicides Nutrients Major ions Radiologics C\Documents and Settinas\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\l 5CXRH6Z\UDEQ Groundwater Split Sampling Procedures.dncpt\dmin\Ma9ter SOP\Book 8_UDEQ ocedures Plane\UDEQ Groundter Split Sampling Procedurez.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 16 of 21 TABLE SAMPLE PRESERVATION AND ANALYSES Analysis Sample Bottle Preservative Max Holding Time Volatile Organics 8260A 40 ml glass vials with teflon lids HCI 2-3 drops days Semi-Volatile Organics 8270 liter amber glass none days POC Parameters filtered liter plastic HNO3 28 days Dissolved Metals filtered Type ifi aluminum antimony arsenic barium beryllium cadmium chromium copper iron lead manganese mercury molybdenum nickel selenium silver thallium vanadium zinc 250 ml plastic HNO3 28 days Pesticides unfiltered 8081 liter glass with teflon cap none days Herbicides unfiltered 8151 liter glass with teflon cap none days UDEQ Chemistry sample unfiltered Type II bicarbonate calcium carbonate chloride fluoride hydroxide magnesium potassium sodium sulfate total suspended solids CO2 total alkalinity total hardness conductivity pH total dissolved solids CO3 solids turbidity gallon plastic none days Nutrients unfiltered NO2 NH3 Total P04 500 ml plastic H2S04 28 days Radiologic filtered Gross and f3 Radium-226 Radium-228 Unat gallon plastic HNO3 months C\Documents and Settins\dtrydenlund\lca1 SetnngsVIenworary Internet Files\Content.Outlook\l 5CXRH6ZUDEO Groundwater Split Sampling Procedures.docPAdminMa3ter SOP\Book S_UDEQ ocedures Planc\UDEQ Groundwater Split Sampling Procedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 17 of 21 TABLE DETECTION LIMITS TO BE USED FOR UDEQ SPLIT SAMPLING Parameter Detection Limit Parameter Detection Limit VOC UDEQ Chemistry Bottle Parameters Bicarbonate SVOC Calcium mg/l Carbonate POC Parameters Chloride mg/I Chlorides mg/i Fluoride 0.05 mg/I Nickel 0.05 mg/l Hydroxide Potassium mg/i Magnesium mg/l U-nat 0.0003 mg/i Potassium mg/i Sodium mg/l Dissolved Metals Sulfate 10 mg/I Aluminum 30 ug/l Total Alkalinity mg/I Antimony ug/l Total Hardness Arsenic ug/l Turbidity 0.05 NTU Barium ug/l CO2 Beryllium ug/l Conductivity Cadmium ug/l pH Chromium ug/l Total Dissolved Solids mg/i Copper 12 ug/l CO3 Solids Iron 20 ug/l Total Suspended Solids mg/i Lead ug/l Manganese ug/i Nutrients Mercury 0.2 ug/l N02 0.02 mg/i Molybdenum ug/l NFl3 0.05 mg/i Nickel 10 ug/l Total P04 0.02 mg/l Selenium ug/l Silver ugh Radiologic Parameters Thallium ug/l Gross Alpha pCi/i Vanadium 30 ug/l Gross Beta 10 pCi/i Zinc 30 ug/l Radium-226 0.5 pCi/i Radium-228 pCi/l Pesticides Total pCi/I Herbicides Detection Limit is per EPA Standard Method SW-846 ATTACHMENT C\Documents and Settinas\dfrydenlund\Local Seltings\Teniporary Internet Files\Content.Outlook\1 SCXRH6Z\UDEQ Groundwater Split Sampline Procedures.docPdmin\Mater SOPs\Book 18 UDEQ oeedures PIanc\UDEQ Groundwater Split Sampling Precedures.doc White Mesa Mill Standard Operating Procedures Date 7/99 Revision Book 18 UDEQ Split Sampling Groundwater Monitoring Plan Page 18 of 21 FIELD WATER ANALYSIS OF GROUNDWATER Location___________________________Date/Sampler pH Buffer 7.0 pH Buffer 4.0 Specific Conductance uMHOS Well Depth Depth to Water ______________________Casing Volume .653h1.367h Conductivity avg pH of Water avg Temperature avg Conductivity________________Conductivity pH______________________pH Temperature Temperature Conductivity________________Conductivity________________ pH______________________pH Temperature Temperature Conductivity________________Conductivity pH________________pH________________ Temperature Temperature Conductivity________________Conductivity pH________________pH________________ Temperature Temperature Comments C\Documents and Settinas\dtrydenlund\Local Seftings\Tempora Internet Files\Content.Outlook\1 5CXRHOZ\UVEp Groundwater Split Sampling Procedures.docPVtdmin\Master SOPt\Bonk 8_UDEQ Procedurec Plana\UDEQ Groundwater Split Sampling Procedurcs.dpc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page of 19 1.0 RADIATION MONITORING PERSONNEL This section contains the following procedures for personnel radiation monitoring including airborne particulates alpha surveys beta/gamma surveys and urinalysis surveys 1.1 AIRBORNE PARTICULATES Sampling for personnel exposure to airborne particulate radionuclides other than for radon progeny will be done utilizing two distinct sampling protocols personnel breathing zone samplers and ambient air high volume samplers Specific standard operating procedures for these two collection methods are described in Section 1.1.2 and 1.1.3 below 1.1.1 Frequency For work where there is the potential to cause airborne radiation doses to site personnel the frequency and type of air sampling to be conducted is determined from measured air concentrations 0.01 DAC 0.1 DAC Quarterly or monthly area air sampling and/or bioassay measurements 0.1 DAC Continuous sampling is appropriate if concentrations are likely to exceed 0.10 DAC averaged over 40 hours or longer The RSO will determine the exact frequency of area air sampling breathing zone sampling and/or bioassay measurements and determine how many workers in group of workers performing similar jobs are to be equipped with breathing zone air samplers Higher airborne concentrations warrant more frequent use of area air samplers bioassay measurements and breathing zone air samplers Area air samplers may be used where documentation exists showing the sample is equivalent to breathing zone sample Breathing zone samples taken within one foot of the workers head are considered representative without further documentation Breathing zone air samplers are preferred under work conditions of higher airborne concentrations Table 1.1.1-1 below from Regulatory Guide 8.25 provides additional guidance for the RSO in designing and implementing air sampling programs for specific jobs C\Documents and Settings\dfrydenlundtLocal Settings\Temporary Internet Fi1esContent.Out1ook\I5CXRH6z\Sect1 AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures SOP PBL-RP-l Book Radiation Protection Manual Section Table 1.1.1-1 Air Sampling Recommendations Based on Estimated Intakes and Airborne Concentrations CADocuments and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\Sectl AppD RPM WMMSOP R-3 08 .doc Date 8/08 Revision DUSA-3 Page of 19 Workers Estimated Annual Intake as Fraction of ALl Estimated Airborne Concentrations as Fraction of DAC Air Sampling Recommendations 0.1 0.01 0.01 Air sampling is generally not necessary However monthly or quarterly grab samples or some other measurement may be appropriate to confirm that airborne levels are indeed low Some air sampling is appropriate Intermittent or grab samples are appropriate near the lower end of the range Continuous sampling is appropriate if concentrations are likely to exceed 0.1 DAC averaged over 40 hours or longer 0.1 0.3 0.3 Monitoring of intake by air sampling or bioassay is required by 10 CFR 20.1502b demonstration that the air samples are representative of the breathing zone is appropriate if intakes of record will be based on air sampling and concentrations are likely to exceed 0.3 DAC averaged over 40 hours i.e intake more than 12 DAC-hours in week Any annual intake Air samples should be analyzed before work resumes the next day when potential intakes may exceed 40 DAC-hours in week When work is done in shifts results should be available before the next shift ends Credit may be taken for protection factors if respiratory protection program is in place Continuous air monitoring should be provided if there is potential for intakes to exceed 40 DAC hours in day Credit may be taken for protection factors if respiratory protection program is in place White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL.-RP-1 Book Radiation Protection Manual Section Page of 19 1.1.2 Breathing Zone Sampling 1.1.2.1 General Breathing zone samplers SKC pumps and accessory kits or equivalent are used to determine airborne exposure to uranium while individuals are performing specific jobs The units consist of portable low volume pump that attaches to the individuals belt tygon tubing and filter holder that is attached to the individuals lapel or shirt collar The unit monitors airborne uranium in persons breathing zone Pumps must be recharged after to hours of use 1.1.2.2 Applicability Breathing zone samples are required for all calciner maintenance activities at least quarterly during routine operating and maintenance tasks on representative individuals performing these tasks when radiation work permits are issued in which airborne concentrations may exceed 25%of 1OCFR2O limits weekly for yellowcake operations or at the discretion of the RSO 1.1.2.3 Procedure The procedure for collecting breathing zone sample is as follows Secure the breathing zone sampler which has been charged and loaded with filter paper from the radiation department Secure the pump to the workers belt and the filter holder to the shirt collar or lapel Try to secure pump tubing to minimize restriction of motion Turn pump on record the time pump was turned on and continue monitoring until the work being monitored is completed and the worker no longer is in the exposure area Record the time at which the job is complete Return the pump and accessories to the RSO who will remove the filter paper for analysis Be sure to indicate accurately the total time taken by the work being monitored Analysis of filter samples will be performed using sensitive alpha detector The procedure is as follows count background sample for ten minutes divide the C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6z\sectl AppD RPM WMM5OP R-3 05.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page of 19 background count by ten to obtain the background count rate in cpm Place the breathing zone sample in the instrument and count the sample again for ten minutes divide the sample count by ten to obtain the count rate in cpm subtract the background count rate from the sample count rate and record all data on the Breathing Zone sampling analysis form copy of which is attached Record the total hours of exposure that are being assigned to the employee on the Employee Exposure form which is maintained in personnel folders Be sure to consider protection factors permitted by respirator use if the employee was also wearing respiratory protection during the job The number of DAC hours assigned is calculated using the following formula DAC hours Measured air concentration Total hours of exposure of exposure DACPF where DAC Derived Air Concentration for uranium 10 CFR Part 20 Appendix PF protection factor for respirator use If no respiratory protection was used PF The measured air concentration must be in uCilcc 1.1.2.4 Calibration Prior to use calibration of the breathing zone samplers will be done using the Bubble Tube Calibration method described in Section 3.2.1 1.1.2.5 Equipment Breathing Zone Sampler The equipment used for breathing zone samples consists of Personal sampling pumps Gelman 37 mm Delrin filter holders or equivalent Gelman 37 mm type A/F glass fiber filters or equivalent Kurz Model 543 air mass flow meter or equivalent 1.1.2.6 Data Record Data maintained on file includes Time on and off for each sample pump Sampling locations CDocuments and Scttings\dfryden1undLoca1 Settings\Temporary Internet Fi1es\content.OutIook\I5CXRH6Zsect1 AppD RPM WMMSOP R-3 08 .doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section PageS of 19 Individuals name identification number etc Date and sample number Sample count rate 1.1.2.7 Calculations The airborne concentration in uCi/cc is equal to the sample count rate minus the background count rate in cpm divided by the instrument alpha efficiency the sample flow rate in cc/minute the sample time in minutes and conversion factor converting dpm to uCi The calculation is Equation Number Airborne concentration Count Rate TimeeffTjconiersion factorFlow Rate i.e cpm-Bkg uCi 1_ cc eff2.22x lO6dpmcc/minmin where eff cpm/dpm for counting instruments cpm counts/mm dpm disintegrations/min conversion factor uci 2.22x 106 dpm Flow Rate cc/min Collection time mm Once the airborne concentration has been calculated it is possible to calculate personnel exposure in microcuries uCi Personnel exposure is determined for an individual who is working in an area at known air concentration uCi/cc for given amount of time hours breathing the area air at an assumed rate The breathing rate for standard person Handbook of Radiological Health is 1.20 cubic meters per hour m3/hr The calculation for personnel exposure is Equation Number Exposure uCi uCilcc1.20m3/hrhours of exposureconversion rate where uCilcc air concentration from Equation 1.20 m3/hr breathing rate for standard man ICRP CADocuments and Settings\dfrydenlund\Locaf Settings\Temporary Internet FiIes\Content.Outlook\15CXRHZ\Sectl AppD RPM WMMSOP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page of 19 hours of exposure hours conversion factor lO6cc/m3 It is also possible to determine the percent or fraction of the Derived Air Concentration DAC for particular radionuclide using the information obtained from the exposure calculation and dividing this value by the regulatory limit DAC listed in 10 CFR Part 20 DAC Exposure in uCiluCi limit 10 CFR Part 20 For the natural uranium U-Nat the DAC limits from 10 CFR Part 20 for insoluble Class compounds are as follows Weekly 1.0 i03 uCi/week Quarterly 1.25 102 uCi/Qt Yearly 5.0 102 uCi/yr 1.1.2.8 ALA RA/Quality Con trol The RSO reviews each monitored result and initiates action if levels exceed 25%of 10 CFR 20 limits At minimum ten percent 10%of the air samples collected in given quarter will be recounted using the same instrument or using different instrument and these results will be compared to the original sample results Deviations exceeding 30% of the original sample results will be reviewed by the RSO and the samples will be recounted again until the sample results are determined to be consistent Additional QA samples consisting of spiked air samples duplicate samples and blank samples will be submitted to the radiation department for counting This will be based on ten percent 10%of the number of samples collected during quarter The sample results will be compared to the spiked values duplicate values or blank background values of the prepared sample Deviations exceeding 30%of the determined spiked duplicate or blank value will be recounted If no resolution of the deviation exceeding 30%is made the QA samples preparation will be repeated Periodic reviews by the RSO and the ALARA audit committee will be made and documented to ensure quality maintenance and ALARA control 1.1.3 Airborne Uranium High Volume Sampling Grab air sampling involves passing representative sample of air through filter paper disc via an air pump for the purpose of determining the concentration of uranium in breathing air at that location Although the process is only measuring airborne concentrations at specific place and at specific time the results can often be used to represent average concentration in general area high volume sample pump will be used for this purpose Samples will be analyzed as per standard gross alpha analysis procedures using sensitive alpha detector C\Documents and 5ettings\dfryden1undLoca1 Settings\Temporary Internet Files\Content.Outlook\15CXRH6z\sectl AppD RPM WMM5OP R-3 05.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page of 19 1.1.3.1 Frequency and Locations The following principles used for the collection of area grab samples must be considered when collecting sample in order to obtain representative air concentration that workers may be exposed to during their assigned work tasks The locations selected for sampling should be representative of exposures to employees working in the area For special air sampling the sampling period should represent the conditions during the entire period of exposure This may involve sampling during the entire exposure period For routine sampling the sampling period must be sufficient to ensure minimum flow rate of 40 liters per minute for at least 60 minutes Sample filters will be analyzed for gross alpha using sensitive alpha detector Grab sampling procedures may be supplemented by use of Breathing Zone Samples for special jobs or non-routine situations 1.1.3.2 Sampling Equipment Monitoring equipment will be capable of obtaining an air sample flow rate of at least 40 liters per minute for one hour or longer Equipment utilized will be and Eberline RAS-1 or Scientific Industries Model H25004 or equivalent Filter media will have maximum of 0.8 micron pore diameter Equipment is calibrated prior to each usage as per Section 3.6 of this manual 1.1.3.3 Sampling Procedure Steps for collection of area airborne grab samples are as follows high volume pump will be used for sample collection Check sample pump calibration Locate sampler at designated site Insert clean filter using tweezers into the filter holder on the sampler Do not contaminate the filter Log start time and Mill operating conditions at the site Collect sample for minimum of 60 minutes at flow rate of 40 liters per minute CADocuments and Settings\dfrydenlund\Local settings\Temporary Internet Fi1es\Content.Out1ook15CXRH6Z\5ect1 AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page of 19 After sampling is completed carefully remove the filter using tweezers from the filter holder and place it in clean glassine envelope or in the plastic casing furnished with the filter Log all sample data on the log sheet Sample location and number also on the envelope Time on time off and date Mill operating conditions at the site Samplers initials Analyze for gross alpha 1.1.3.4 Calculations Perform calculations as described in Section 1.1.2.7 1.1.3.5 Records Logs of all samples taken are filed in the RSO files Data are used to calculate radiation exposures as described in Section 4.0 Whenever grab sampling results indicate that concentrations in work locations exceed 25%of the applicable value in 10 CFR Part 20 Appendix time weighted exposures of employees who have worked at these locations shall be computed Calculations will reveal an individuals exposure in DAC hours This value shall be assigned to the worker and logged onto the workers Employee Exposure to Airborne Radionuclides form This form is in Section Whenever special air sampling programs as required for cleanup maintenance decontamination incidents etc reveal that an employee has been exposed to airborne radioactive material the calculated value shall also be entered on the individuals exposure form 1.1.3.6 Quality Assurance Calibration checks on each air sampler prior to field use ensure accurate airflow volumes Use of tweezers and new filter storage containers minimizes contamination potential Field logging of data during sampling and logging of identifying data on sampled filter containers minimizes sample transposition Quality control samples will be analyzed as described in Section 1.1.2.8 Review of data by the RSO and by the ALARA Audit committee further assures quality maintenance C\Documents and settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6z\sectl AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page of 19 1.2 ALPHA SURVEYS 1.2.1 Restricted Area The Restricted Area is defined as The property area within the chain link fence surrounding the mill property and the area enclosed to the north and east of the facility by the posted Restricted Area fence The active tailings and liquid waste disposal areas All personnel who enter the Restricted Area will monitor themselves each time they leave the Restricted Area and at the end of their shift The Radiation Safety Department will review the monitoring information All personnel exiting the Restricted Area must initial record of their monitoring activity 1.2.2 Instrumentation The instrumentation utilized for personnel alpha scanning is listed in Appendix at the end of this manual Personnel alpha survey instruments are located at the exits from the Restricted Area 1.2.3 Monitoring Procedures The monitoring procedure includes the following steps The alarm rate meter is adjusted within the range of 500 to 750 dpm/100 cm2 to ensure margin of 250 dpm/100 cm2 due to the low efficiency of this instrumentation An individual monitors himself by slowly passing the detector over their hands clothing and shoes including the shoe bottoms at distance from the surface of approximately inch An area that is suspected of possessing any contamination i.e hands boots visible spotting/stain on clothing etc should be carefully monitored by placing the detector directly on the surface and note the measurement Should an alarm be set off indicating the presence of contamination the individual should Resurvey themselves to verify the contamination If contamination is present the individual must wash the affected area and again resurvey themselves to ensure the contamination has been removed CADocuments and Settingsdfryden1unthLocaI Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\sectl AppD RPM WMM5OP R-3 08 .doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 10 of 19 if the decontamination efforts by the individual are not successful then the Radiation Safety personnel will be contacted to assess the situation Further decontamination may be required II an individuals clothing cannot be successfully decontaminated they must obtain clothing from the warehouse to use and must launder the personal clothing in the laundry room Individual surveys are to be logged and initialed Access to and from the Mills Restricted Area by all Mill workers contractors and delivery personnel other than Radiation Safety and Environmental Staff Senior Laboratory personnel Mill Management and Mill Supervisory personnel and others as may be designated by the RSO will be limited to one or more access points as may be designated by the RSO from time to time Radiation Technician will be positioned at each access point designated by the RSO under paragraph above during peak transition times such as during breaks and at the ends of shifts to observe that each worker contractor or delivery person is performing proper scan This paragraph will cease to apply to any such access point if and when one or more automated full body scanners portals or the equivalent are situated at the access point which would require workers exiting at that location to scan themselves by exiting through the portal and the procedures in this Manual are amended to incorporate the use and maintenance of such portal or portals 1.2.4 Training All employees will be trained on the proper scanning procedures and techniques 1.2.5 Records Log sheets will be collected daily and filed by the Radiation staff Records will be retained at the Mill Contamination incidents will result in written record which is maintained on file 1.2.6 Limits/ALARA Contamination limits for personnel scans are set at 1000 dpm/100 square centimeters Records will be reviewed by the RSO to maintain levels noted as low as reasonable achievable 1.2.7 Quality Assurance C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRHZ\5ectl AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 11 of 19 random check of an individuals scanning technique provides quality assurance of the monitoring procedures Daily function checks using calibrated sources assures instrumentation performance Periodic review by the RSO and the ALARA audit committee document and ensure quality control and ALARA maintenance 1.3 BETA-GAM1VEA SURVEYS Site employees working within the Restricted Area will be required to wear personal monitoring device such as TLD LUXEL badge or other NVLAP approved device which has been approved by the RSO and the SERP during their work period The personal monitoring devices are normally issued to each employee quarterly however during pregnancy or if the radiological potential for exposure to an individual is anticipated to be elevated and requires quick assessment the badges may be issued monthly 1.3.1 Monitoring Procedures The monitoring procedures consist of Personnel issued personal monitoring devices will wear the device on the trunk torso of the body or visibly on the exterior of their hard hat The personal monitoring device records beta/gamma radiation as well as other forms of penetrating radiation such as x-rays personal monitoring device is an exposure record of an individuals personal exposure to radiation while on the job Therefore personal monitoring devices are to remain at the Mill in the personal possession of each individual in locker or other secure area All exposure records obtained by personal monitoring device which are not consistent with the exposure rates of work tasks or work location measurements made throughout the Mill will be evaluated by the RSO This evaluation will result in an investigation by the RSO and written explanation of the findings These written records will be maintained at the Mill Personal monitoring devices will be issued at minimum quarterly and will be exchanged by the Radiation Safety Department Missing or lost badges will be reported to management Female employees that become pregnant and continue to work during the course of their pregnancy will be placed on monthly personal monitoring device exchange during this period NRC Regulation Guide 8.13 provides guidelines to be followed during pregnancy and is made part of this procedure 1.3.2 Records C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\Sectl AppD RPM WMMSOP R-3 05.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 12 of 19 The Radiation Safety Department will maintain all occupational exposure records in the departmental files Occupational exposure records are part of an individuals health record and as such will be considered private information An individual may examine his/her exposure record upon request An employee terminating his/her employment with Denison Mines USA Corp may request copy of his/her occupational exposure records The Radiation Safety Department on the signature of the employee will request prior occupational exposure records Occupational exposure records will be made available to authorized company or regulatory personnel 1.3.3 Quality Assurance Periodic reviews by the RSO and the ALARA audit committee document and ensure quality control and maintenance of conditions ALARA 1.4 URINALYSIS SURVEYS 1.4.1 Frequency Urinalyses will be performed on those employees that are exposed to airborne yellowcake or involved in maintenance tasks during which yellowcake dust may be produced or routinely exposed to airbome uranium ore dust Baseline urmnalyses will be performed prior to initial work assignments Urine samples are collected on routine basis from mill employees as required in Regulatory Guide 8.22 Urine samples will be collected from employees who have worked in yellowcake packaging yellowcake precipitation grind area SAG mill ore feed sample plant scale house and the sample preparation room every two weeks during production periods Samples will be collected from all other employees monthly during production periods During non-production periods bi-weekly samples will be collected if individual exposures are expected to exceed 25%of the DAC value otherwise samples will be collected from all employees quarterly Non-routine urinalyses will usually be performed on employees who have been working on assignments that require Radiation Work Permit and always on any individual that may have been exposed to airborne uranium or ore dust concentrations that exceed the 25%of the DAC level c\Documents and settings\dfiydenlund\Local 5ettings\Temporary Internet Fi1esContent.OutIcok\15cXRH6Z\sect1 AppD RPM WMMSOP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page 13 of 19 1.4.2 Specimen Collection Clean disposable sample cups with lids will be provided to each employee that will be required to submit urine specimen The containers will be picked up at the administration building before the individual enters the Restricted Area The container filled with specimen will be returned to the bioassay laboratory prior to reporting to work The name of the employee and the date of collection will be indicated on the specimen cup valid sample must be collected at least 40 hours but not more than 96 hours after the most recent occupancy of the employees work area after two days but not more than four days off The specimen should be collected prior to reporting to the individuals work location To prevent contamination the hands should be carefully washed prior to voiding Under unusual circumstances where specimens cannot be collected in this manner the worker will shower immediately prior to voiding 1.4.3 Sample Preparation Equipment required 15 ml disposable centrifuge tubes with lids 10 ml pipette ul pipette lOulpipette Disposable tips for the above pipettes Spiking solution 0.03 or 0.02 gIl of uranium in de-ionized water After the specimens are received they will be stored in refrigerator until they are prepared for analysis Sample preparation will be done in an area decontaminated to less than 25 dpm alpha removable per 100 cm2 prior to preparation of samples All of the equipment that is used in sample preparation will be clean and maintained in such condition log will be prepared and the following information will be kept for each urinalysis performed Sample identification number Name of employee submitting the specimen C\Documents and Settings\dfiydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\sectl AppD RPM WMM5OP R-3 08.doe White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page 14 of 19 Date of sample collection Date the sample was sent to the laboratory Date the results were received Results of the urinalysis in ugh Indication of any spike used in ugh The centrifuge tubes will be marked with sample identification number 10 milliliters of urine will then be pipetted into the centrifuge tube using the pipette device To prevent contamination new tip must be used for each specimen After each step of the procedure the proper entry must be made in the logbook The samples that are to be spiked for quality assurance purposes will then be prepared The spikes will be introduced into the sample with ul or 10 ul pipettes new tip must be used with each spike With the standard spike solution 0.03 gIl of ul spike will result in 15 ug/l concentration for the 10 ml sample the 10 ul spike will give 30 ug/l The proper entry must be made in the logbook for each sample spiked After preparation has been completed the QA samples are securely packaged as soon as practicable and sent to the contract laboratory for analysis The samples that are to be analyzed in-house will be placed in the chemistry laboratorys refrigerator until the analysis can be completed copy of the in-house analytical procedure is described in Section 1.4.7.6 1.4.4 Quality Assurance To assure reliability and reproducibility of results at least 25%of the samples that are submitted for analysis will be used for quality assurance purposes These samples will consist of spikes duplicates and blanks samples collected from individuals known to have no lung or systemic uranium burden Spiked samples will be prepared as stated under sample preparation of this procedure Duplicates will be identical samples of the same specimen and/or spikes of identical concentrations To assure reliability of the in-house analytical procedure 10%of the samples will be sent to contractor laboratory for analysis These samples will contain quality assurance items designed to provide intra-laboratory comparisons 1.4.5 Analysis C\Documents and Settings\dfiydenlund\Local SettingsTemporary Internet Files\Content.Outlook\15CXRH6Z\Sectl AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 15 of 19 After the samples are collected as outlined in Guide 8.22 they are identified to the lab by collection date and number Urinalysis results must be completed and reported to the Radiation Safety Department within seven days of the sample collection 1.4.5.1 Equipment List Specimen collection cups with disposable lids VWR No 15708-711 or equivalent Screw cap disposable graduated 15 ml centrifuge tubes Coming No 25310 or equivalent Micro-pipettes each each 10 microliters Oxford Model 7000 or equivalent 20 ml Scintillation Vials Disposable micro-pipette tips for micro-pipettes Oxford No 910A or equivalent Lab Oven Hot Plate Fume Hood Ultrasonic Cleaner 10 ICP-MS 11 Forceps with curved tips 1.4.5.2 Reagent List 1%to 2%Nitric Acid Concentrated Nitric Acid Perchloric Acid Concentrated 70% Wetting Agent 1000 ug/ml Uranium Stock Solution certified vendor prepared Dilutions of the above stock solution replaced bi-annually Used for QA/QC Appropriate Cleaning Solution for Ultrasonic Cleaner Ensure that all reagents used are within their expiration dates listed on each reagent package if applicable 1.4.5.3 Premise portion of urine is digested in the presence of strong oxidizer and the sample is heated at 550 degrees Celsius for hour to destroy all organics and insure proper oxidation state of any uranium present to allow the uranium to solubilize in dilute matrix mix 1.4.5.4 Safety Precautions Follow laboratory guidelines when working with acids C\Documents and Settings\dfrydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\15CXRH6Z\sectl AppD RPM WMM5OP R-3 O8.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 16 of 19 Utilize all appropriate PPE All digestions must be done under working fume hood Working with perchloric acid in the presence of organic material can be hazardous Do not overheat to dryness Excess nitric acid is required to insure all organic material is destroyed prior to perchloric phase of digestion 1.4.5.5 Sample Preparation Procedure Compare sample numbering with bioassay result sheet to insure order and eliminate discrepancies To 20 ml scintillation vials add mls instrument grade concentrated nitric acid and ml concentrated perchloric acid Maintaining sample order of left to right front to back lowest sample number to highest sample number in the set add ml to 10 ml of sample to the scintillation vial Swirl the vial and place on hot plate again maintaining the above stated sample order Hot plate should be set to allow sample to cook down for approximately hours prior to perchloric phase of digestion Cook samples down to perchloric salts If there is any brown color left in the sample repeat digestion It is important that wet ashing of sample is complete to insure oxidation of the uranium Place the samples in oven at 550C for at least hour Remove samples from the oven allow to cool and add 10 ml of 1%or 2%nitric acid that has 0.2%wetting agent to the samples Heat the samples to digest salts Analyze using procedure on the ICP-MS described in section 1.4.7.6 1.4.5.6 ICP-MS Procedures Special considerations Because of the high salt content of the samples it is necessary to clean the skimmer and sampler cones after each use Turn the argon on at the tank and set the delivery pressure at 80 pounds per square inch psi C\Documents and 5ettings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\5ectl AppD RPM WMM5OP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page 17 of 19 The ICP-MS is in continuous standby mode because it is necessary to maintain vacuum on the detector To move from the standby mode to the operating mode press the ON button There are two turbo vacuum pumps that need to come up to speed prior to operating the ICP-MS While waiting for the pumps purge the interface area with argon by pressing the and buttons The argon light will come on while the argon is purging It is good idea to purge at least times Turn on the exhaust fan and the water supply to the ICP-MS The water supply has to have delivery pressure of 70 psi It may be necessary to change the filters on the water supply in order to achieve sufficient water supply pressure The ICP-MS will not operate below this pressure Turn on the computer and enter the Spectro program Press the START button to start the ignition sequence The ignition step is 60 seconds At 10 seconds the vacuum pump for the interface starts If the exhaust fan is not on the plasma will shut off few seconds after ignition After the plasma ignites the electronics go through check loop Avoid any input to the computer during this time Under the instrument window in the generator parameters turn the pump on and set the nebulizer flow to the appropriate amount determined from previous set up operations Under Utilities select the Scan Manager window From this window select the time scan that has previously been set up for your operation 10 Using the instrnment settings adjust or verify that the Rh line is about io5 counts Close and exit Scan Manager 11 Under Measure select Quantitative and then Bioanalysis 12 After entering this window under Function select Standardize Method and follow prompts After verifying standardization values are close to previous operation begin sample analysis 13 Because of the nature of the sample it is necessary to aspirate blank in between each sample After to samples the blank needs to be aspirated for sufficient time to clean the salt build up C\Documents and Settings\dfiyden1undLoca1 Settings\Temporary Internet FiIes\Content.OutIook15CXRH6Z\5ect1 AppD RPM WMM5OP R-3 08 .doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP- Book Radiation Protection Manual Section Page 18 of 19 14 To begin sample analysis press F2 or click the Start button at the bottom left side of the window Record the value and move to the next sample 15 After the last sample exit window and aspirate the blank long enough to clean the lines and chambers 16 Allow the pump to run long enough without aqueous uptake to void all lines and chambers 17 Turn the pump off and relax lines off of pump 18 Push the STOP button to go back to the standby mode 19 After to 10 minutes turn off the water supply exhaust fan and argon All bioassay samples need to be analyzed three working days from receipt in the laboratory Samples are extremely susceptible to contamination Precautions should be taken to minimize traffic and fugitive dust while samples are digesting Volume additions are made with an auto-pipette for which the calibration has been checked 1.4.6 Reporting and Corrective Actions As soon as the analytical results are received they are entered in the logbook and the entries are checked for correctness and completeness The lab report is returned to the Radiation Safety Department with results reported as micrograms/liter of uranium The information must be placed in the individual employees exposure file and maintained as directed by the DRC The Radiation Safety Department is notified immediately of any sample with concentration greater than 35 micrograms/liter of uranium Corrective actions will be taken when the urinary uranium concentration falls within the limits listed in Table attached The Radiation Safety Department should compute the error on the control spiked samples and advise the lab if the results are more than 30%of the known values If any of the results obtained for the quality assurance control samples are in error by 30%the analysis must be repeated 1.5 IN-VIVO MONITORiNG CDocuments and Settings\dfrydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\Sectl AppD RPM WMMSOP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 8/08 Revision DUSA-3 SOP PBL-RP-1 Book Radiation Protection Manual Section Page 19 of 19 In-vivo body counting for lung burdens of U-natural and U-235 will not be routinely conducted Monitoring will be conducted at the discretion of the RSO in consultation with DUSA management should potential exposure to an individual warrant c\Documents and Settings\dfiydenlund\Local Settings\Temporary Internet Files\content.Outlook\I5cXRHoZ\sectl AppD RPM WMMSOP R-3 08.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 3.0 EOUIPMENT/CALIBRATION All radiation detection instruments used at the Mill are sent to qualified independent laboratory for calibration every six months If necessary Radiation Safety Staff can use the procedures outlined below to verify calibration 3.1 Counters/Detectors 3.1.1 General All radiation detectors require determination of detector optimal voltage performance or plateau operating point The graph of voltage applied to detector versus detector response is referred to as plateau curve The plateau curve typically has two rapidly sloping sections and stable flat region The optimal operating point is typically located at the beginning of the flat or flatter section of the graph The plateau curve is specific for particular detector and its accompanying readout or measuring meter and may vary over time depending upon electronic component condition The equipment used to determine detector plateau curves includes Appropriate radiation sources Electrostatic voltmeter Radiation detecting instrument Graph paper Manufacturers technical manual The procedure is Ensure instrument batteries are fresh or fully charged if applicable Turn the instrument on Adjust the instrument voltage control starting at voltage of 600 using electrostatic voltmeter to monitor voltage setting Expose detector to radiation source applicable to the type of detector and in the appropriate setting Record voltage and instrument response for each adjustment of voltage applied increments of 50 volts are adequate C\Documents and Settings\dfzydenlund\Local Settings\Temporary Internet Files\Content.Out1ook15cXRH6Z\sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL--RP-3 Book Radiation Protection Manual Section Page of 15 Repeat steps and until instrument response rapidly increases versus voltage level At this point the detector is approaching potential differentials across the electrode that may damage the detector Graph instrument response versus voltage applied Set equipment high voltage control to the optimum operating point Record on graph voltage selected Retain graph with calibration records 3.1.2 Function Checks Calibration function checks are required prior to use of radiation detection instruments used at the Mill for the purpose of verifying that the instruments are operating at the same efficiency as when they were calibrated by the calibration laboratory i.e within 1-10% Function checks are also used for verifying repeatability reliability and comparability of an instruments measurements from one period to another By performing function checks for extended time periods or on larger sample size these goals are met Function checks involve two basic elements calibration laboratory efficiency is compared to the instruments efficiency on the date of the function check and the function check is verified with check source having similar isotopic composition as the one that was used by the calibration laboratory to calibrate the instrument Function checks are made for all types of radiation survey instruments The basic principle in performing function check is measuring the radiation field using survey instrument against known amount of radiation from calibrated source These measurements are made for the specific type of radiation occurring For example when performing beta/gamma survey the instrument function check is performed using beta/gamma check source such as SrY-90 When performing an alpha survey use an alpha check source such as Th-230 or Pu-239 for performing the function check Function checks are documented on the Calibration Check Forms see Attachment for copies of forms to be used for each specific instrument They will be maintained in the instruments calibration and maintenance file number of radiation detection instruments are used at the Mill An Instrument Users Manual for each instrument is maintained in the calibration files together with calibration documentation The Users Manuals are to be considered the primary reference for c\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet FiIes\content.Out1ook15cXRH6Z\sect3 AppD RPM WMMSOP R-12 05 a.doe White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 operating particular instrument This Standard Operating Procedure SOP is not intended to replace the Users Manual but rather to supplement the Manual by providing steps to be performed for function checks Before operating an instrument personnel should read the Users Manual and become familiar with the instruments operation capabilities and special features Personnel will also receive on the job training on each instrument 3.1.3 Alpha Monitors Alpha particles travel very short distances in the air due to their high ionization ability typically 1/4 to inch Due to this limitation alpha monitoring must be done at distance of inch or less between the detector face and the source Alpha monitoring to be consistent requires ensuring consistent distance be utilized between the detector face and the source Alpha detectors read out in counts per minute cpm correlation relationship known as the efficiency factor between the meter response and the actual disintegration rate of the source is used to determine actual calibration of the meter Radioactivity is measured in curies Ci which by definition is 3.7 1010 disintegrations per second dps or 2.2 1012 disintegrations per minute dpm Mother measurement unit is the Becquerel or one dps Alpha radiation is usually monitored as dpm per surface area measured Radiation survey equipment used at the Mill for alpha surveys are listed in Appendices and 3.1.3.1 Calibration and Function Check Frequency The frequency of calibration is specified in individual instrument user manuals and manufacturers specifications During production periods the following frequencies are observed for calibration and function checks of radiation detection instruments Calibration Function Type Frequency Checks Employee scans month days/week Radon progeny month each use Respirator checks month each use Area fixed scans month Daily or each use Area wipe scans month Daily or each use During non-production periods the following frequencies are observed cDocuments and Settings\dfiydenlund\.Local settings\Temporary Internet Files\content.outlook\I5CXRHoZ\sect3 AppD RPM WMM5OP R-12 05 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 Calibration Function Type Frequency Checks Employee scans month bi-monthly Radon progeny month each use Respirator checks month each use Area fixed scans month Daily or each use Area wipe scans month Daily or each use 3.1.3.2 Function Check Procedures Alpha Counters and Scaler Instruments The following steps will be used for function checks for alpha counters and alpha scaler instruments Turn the instrument on and place calibrated alpha check source in the detector holder on or the face of the detector Count the source for minute and record this value in cpm Repeat step four more times Average the five readings and divide the average in cpm by the know activity on the alpha source This is the efficiency of the instrument and detector Compare this efficiency with the efficiency obtained from the calibration lab if the efficiency comparison is within 10%deviation the instrument needs is calibrated if not the instrument needs to be recalibrated if this efficiency comparison is within 10%deviation the instrument is in calibration Proceed with monitoring activities 3.1.3.3 Function Check Procedures ESP-1 There are special performance considerations when using the Eberline Smart Portable ESP-1 instrument with an Eberline AC-alpha detector because the ESP-1 contains microcomputer to perform its internal calculations Once the user has adjusted the calibration constant CC which is special feature of the ESP-the value obtained during measurement event will be converted to 100%and displayed as such Adjusting the CC of the ESP-1 in no way changes the laboratory calibration performed on the instruments The calibration constant is set to value of one at the laboratory and calibration proceeds as detailed by the manufacturer specifications c\Documents and Settings\dfiydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5cXRH6Z\Sect3 AppD RPM WMMSOP R-12 05 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 The following steps will be used for function checks for the ESP- Turn the instrument on and set the calibration constant CC to 1.00 This is the setting the calibration laboratory uses for performing calibration of the instruments Place calibrated alpha check source on the face of the detector and count the source for one minute and record this value in cpm Repeat step four more times Average the five readings in cpm and divide by the known activity of the alpha check source Note use an alpha check source which is the same radioisotope i.e Th-230 or Pu-239 or one of equivalent energy emission for this procedure The instrument efficiency is now established Compare the efficiency to the value obtained from the calibration lab If the efficiency comparison is within 10%deviation the instrument is calibrated if not the instrument requires recalibration Set the calibration constant CC to the efficiency value obtained in step For instance if the efficiency value is 20%from step change the CC from 1.00 to 0.20 This setting changes the calibration constant to the efficiency of the detector by introducing multiplier into the microprocessor Then individual measurements are obtained at 100%level Place calibrated alpha check source on the detector and take five readings Average the five readings and divide this value by the known activity of the check source This value should be 100%5%of the known activity of the check source If it is not within this range 100%5%readjust the CC fine tune slightly and count the source five times and average Compare the average value to the check source keeping in mind you want to be within 100 5.0%of the total activity of the check source Continue this step until that objective is achieved The instrument is not only in calibration as observed by step it is now functionally capable of measuring at 100% efficiency Proceed with use 3.1.3.4 Calibration Procedures All radiation detection instruments used at the Mill are sent to qualified offsite laboratory every six months for calibration However if additional onsite calibration is required the calibration procedures are Set the detector high voltage at the prior determined operating point using an electrostatic voltmeter C\Documents and Settings\dfrydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\15CXRH6Z\5ect3 AppD RPM WMMSOP R-12 05 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 For counter/scalers radon progeny/wipes close the detector without source present obtain reading for set time This is background reading Place calibrated source for the type of radiation being measured in the source holder and obtain reading Observe the counts per minute for both the background and the source Subtract the cpm value of background from the cpm value of the source to obtain the net cpm Divide the net cpm value by the known dpm of the source This is the percentage efficiency of the instrument system for this energy source By dividing 100 by this efficiency an efficiency factor is obtained Dpm equals the cpm divided by the efficiency of the instrument detector system Note curie 2.22 12 dpm microcurie 2.22 dpm picocurie 2.22 dpin 3.1.4 Beta-gamma Monitors Equipment utilized for beta-gamma monitoring is listed in Appendices and 3.1.4.1 Function Check Procedure The following steps will be used for function checks on beta/gamma instruments Turn the instrument on and place the calibrated beta/gamma SR-Y-90 check source on the face of the detector Let the reading stabilize to constant value Record this value in cpm Divide this value by the known activity on the check source This is the efficiency of the instrument and detector C\Documents and Settings\dfrydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\15CXRH6Z\Sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 Compare this efficiency to the efficiency obtained from the calibration laboratory If the efficiency comparison is within 10%deviation the instrument needs is calibrated if not the instrument needs to be recalibrated If this efficiency comparison is within 10%deviation the instrument is in calibration Proceed with monitoring activities 3.1.4.2 Calibration All beta-gamma survey instruments are sent out every six months for calibration Additional calibration if necessary may be performed on site using techniques described in Reg Guide 8.30 Appendix Beta Calibration of Survey Instruments for calibration performed by qualified calibration laboratory using the indicated source as listed in Appendix 3.1.5 GammaMonitors Instruments for gamma measurements are listed in Appendix 3.1.5.1 Calibration Independent calibration service laboratories perform calibration every six months Meters are calibrated to Cesium-137 or other radioisotopes as suggested by the calibration laboratory or manufacturer Most calibration service laboratories calibrate Beta/Gamma instruments electronically in accordance with their standard calibration procedures However electronic calibration basically consists of the steps described below Connect survey instrument to be calibrated to the model 500 Turn both instruments on Record high voltage reading on model 500 Set cpm and the range multiplier on the model 500 to the desired meter deflection The model 500 frequency controls consist of the three-digit readout range selector coarse tuning know and the fine tuning knob The three-digit readout is in cpm times the frequency multiplier CDocuments and Settings\dfrydenlund\Local Settings\Temporary Internet FiIesContent.OutIook\15CXRFI6Z\Sect3 AppD RPM WMMSOP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 Calibrating survey instruments in cpm Set model 500 frequency to value that will provide meter deflection on the survey instruments highest count scale Set pulse height/amplitude to twice instrument input sensitivity Adjust the range calibration potentiometer on the survey meter to provide correct reading record De-code model 500 frequency to next lower value then do the same for the survey instrument Adjust the range calibration potentiometer for correct reading on survey instrument Record readings Repeat process until all ranges have been calibrated at meter deflection Record readings Return to highest count scale on survey meter Set model 500 for 1/4 scale deflection readings Survey instrument should read within 10%of model 500 frequency Record readings If readings are outside of the tolerance re-calibrate for meter deflection Tap instrument meter lightly to check for sticky meter Meter tolerance is 3%from the initial readings to the final reading Decode 500 to next lower scale Check survey instruments for 14 scale reading Record Record input sensitivity Select the most sensitive amplitude range 0-5 my on the model 500 Observe meter on survey instrument Increase pulse amplitude switching to next higher range if necessary until the rate meter indicates stable reading i.e further increase of pulse amplitude does not cause an increase in meter reading Now decrease pulse height until the cDocuments and Seuings\dfrydenlundthocal Settings\Temporary Internet Files\Content.Ouflook\1SCXRH6Z\sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page of 15 survey instrument meter reading drops 15 5%Record this pulse height as the instrument sensitivity If your instrument has gain or threshold control to set instrument sensitivity set pulse height on the model 500 to desired sensitivity level Now adjust your instrument threshold or gain control until the rate meter reading is within 85 5% of its stable reading value see step Record the pulse height as instrument sensitivity Calibrating survey instrument to cps Set frequency in model 500 Divide model 500 readings by 60 to convert to counts per second Repeat calibration steps as in item above 3.1.5.2 Frequency of Calibration If electronic calibration is performed using the above method by the Radiation Safety Department the model 500 pulse generator will be sent out for calibration on an annual basis 3.2 PERSONNEL AIR SAMPLERS The calibration procedure for personnel air samplers involves primary and secondary calibration procedures Samplers will be calibrated prior to each use by either of two methodologies bubble tube or mass flow determinations Air samplers may be calibrated to standard air conditions 3.2.1 Bubble Tube Calibration Method The Bubble Tube Calibration Method is primary calibration method and does not require corrections to or from standard conditions for temperature and pressure Personal air samplers are calibrated for the flow rate for the sampling being performed typically 2- liters per minute The equipment utilized is as follows Burette 1000 ml capacity 10 ml divisions Support iron rectangular base with rod Burette clamps2 Soap solution dish Tubing Gelman filter holder filter media 0.8 micron glass fiber Gelman type AlE C\Documents and Settings\dfrydenlund\Local settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\5ect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page 10 of 15 Stopwatch Small screwdriver Sample pump The procedures utilized are Assemble filter train place filter in an in-line filter Attach two lengths of tubing to each connector of the in-line filter holder Make sure the Burette is clean Clamp the 1000 ml Burette upside down on the ring stand with the Burette clamps Attach the pump to be calibrated to one end of the filter train connect the other end of the filter train to the small end of the 1000 ml Burette as per Figure Check all tubing connections for air tightness Pour approximately inch 12 mm of soap solution into the dish Start the pump Raise the dish up under the Burette opening and then immediately lower the dish This should cause film of soap to form over the Burette opening i.e bubble Repeat this procedure until the film bubble will travel up the inverted Burette the length of the graduation marks on the Burette without breaking When the film bubble has wetted the Burette inside and will travel the entire length of the graduated area of the Burette proceed with the actual calibration run Quickly form three bubbles and start the stopwatch when the middle bubble is at the bottom graduation line actually the 1000 ml mark but for purposes here it will be called the zero line 10 Time the travel of the bubble from the zero line to the top line of the graduated distance ml Since the capacity of the Burette is 1000 ml 1.0 liter then the volume of air that is displaced above the bubble i.e needed to raise the bubble is 1.0 liter Stopping the stopwatch at the top mark is the time elapsed for the pump to accomplish this The rate of rise of the bubble through the apparatus is the flow rate of air being pulled by the pump 11 Increase or decrease the pump collection rate by adjusting the appropriate screw or knob designed for this purpose C\Documents and 5ettings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRHZ\Sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP.-3 Book Radiation Protection Manual Section Page 11 of 15 12 Set the pump flow collection rate to the desired valued usually between and liters per minute for low volume collection pumps and between 30 and 80 liters per minute for high volume collection pumps 3.2.2 Mass Flow Method Mass flow meters are manufactured equipment designed to measure air collection flow rates for variety of purposes Mass flow meters may be subject to temperature and pressure corrections of air movement depending on whether they are calibrated/manufactured for standard conditions Utilizing an air mass flow meter traceable to NBS the airflow rate of pumps can be quickly adjusted to correct standard flow rate conditions However the mass flow meter must be calibrated annually using primary calibration method The equipment consists of the following Kurz air mass flow model 543 or equivalent Suitable filter head adapter connections Filter heads with filter media Pump to be calibrated Note The meter is calibrated directly in standard air conditions 25 29.82 Hg The procedures utilized are Ensure pump batteries are fully charged Ensure flow meter batteries are fully charged Assemble filter train Connect with suitable adapter the Kurz probe onto the filter train Ensure an airtight seal with tape if necessary Set the meter function switch to the highest range 40 std liters per minute Turn the pump on Select appropriate range on the meter Do not allow meter needle to be forcibly pegged C\Documents and Settings\dftydenlund\Local Settings\Temporai-y Internet Files\content.Outlook\1ScXRI6Z\sect3 AppD RPM WMMSOP R-12 05 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page 12 of 15 Adjust the pump flow rate as necessary to desired flow rate Allow the meter to stabilize before adjustment of the pump Meter reads directly in standard air conditions correcting for temperature and barometric pressure Pump is now calibrated Low volume pumps are set at to 1pm 3.2.3 Electronic Calibration Method The electronic primary gas flow calibration is the primary calibration method and does not require corrections to or from standards conditions for temperature and pressure Personal air samplers are calibrated for the flow rate for the sampling being performed typically liters per minute The equipment utilized is as follows UltraFlo Primary Gas Flow Calibrator or equivalent Soap solution Tubing Small screwdriver Sample pump The procedure proceeds as follows Remove the two nipples on the back of the UltraFlo Primary Gas Flow Calibrator Attach the connection tubing from the top nipple to the sample pump Turn calibrator on Turn sample pump on Press the plunger style button on top of the soap dispensing portion of the device Write down the digital reading from the calibrator device Repeat steps and three times Take an average of the three readings If the sample pump requires adjustment take the screwdriver and adjust the set screw on the face of the sample pump and then repeat steps through 10 After the sample pump is calibrated document the calibration on the Breathing Zone/Radon Calibration Sheet in the Radiation department 11 Replace nipple caps on the back of the calibrator 3.3 AREA AIR SAMPLERS C\Documents and Settings\dfryden1undLoca1 Settings\Temporary Internet Files\Content.Outlook\15CXRFI6Z\Sect3 AppD RPM WMMSOP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page 13 of 15 The calibration procedure for area air samplers involves one of the following procedures Kurz Mass Flow Wet Test Gas Meter or Bubble Tube Method 3.3.1 Kurz Mass Flow Method Repeat procedures discussed in 3.2.2 except airflow rate is adjusted to 40 slpm and samplers utilized are Eberline RAS-1 Scientific Industries Model H25004 Equivalent 3.3.2 Wet Test Gas Meter Method The wet test gas meter method utilizes Precision Scientific wet test meter rated at one cubic foot per revolution of the main dial This method is used to calibrate the Kurz air mass flow meter in addition to direct calibration of the area air samplers The procedures are Attached coupling to sampler filter assembly secure it with tape Connect wet test meter hose to coupling Check water level of wet test meter The needle should be on slightly above the water level Check the thermometer temperature of the wet test meter Record this on the calibration sheet Assume that the wet and dry bulb temperatures are the same Turn on the sampler Check the west test meters manometer reading This reading is obtained by adding the left and right column values typical reading might be .3 Log these values for each ball height on the Static pressure ..H20 column For the following sampler approximate settings pull one cubic foot of air through the wet test meter and record the time in seconds for each 20 30 40 and 50 1pm Sampler Calibration Procedures Calculations and Equations To convert the static pressure of the manometer attached to the wet test meter from inches of water to inches of mercury divide the number of inches to water by 13.6 Example 0.4/13.6-0.02941176 Hg c\Documents and Settings\dfiydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\15CXRH6Z\sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page 14 of 15 To compute the actual flow rate rate act 1pm first divide the number of cubic feet by the number of seconds Example ft.3/90 sec .01111 ft.3lawx Convert the cubic feet to liters The conversion factor is 28.317 Example .01111 ft.3lsec 28.3 17 ft.3 .3 146 Llsec Multiply this by 60 to convert from seconds to minutes Example .3 146 L/sec 60 sec 1888 L/m or 18.88 1pm Using the Vapor Pressures of Water chart find the vapor pressure inside the wet test meter by matching the wet bulb temperature with the corresponding vapor pressure This number is the vapor pressure at the standard wet bulb Pvpstw Find the vapor pressure at dewpoint using this formula Pv dewpoint Pvpstw 0.00036 13 td-tw Bp Where dry bulb temp tw wet bulb temp bp barometric pressure in inches of mercury Assume that the dry bulb temperature and the wet bulb temperature are the same so the difference between them will always be zero Thus Pv dewpoint will equal Pvpstw Determine the actual air density act with this formula Dact 1.327 td 459.67 0.378 Pv dewpointJ Where td dry bulb temp in degrees Bp barometric pressure in inches of mercury Sp static pressure of wet test meter in inches of mercury CADocuments and 5ettings\dfrydenlund\Local 5ettings\Temporary Internet Files\Content.Outlook\1SCXRHZ\5ect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 12/08 Revision DUSA-2 SOP-PBL-RP-3 Book Radiation Protection Manual Section Page 15 of 15 Example Dact 1.327 70.5 459.67 0.02941 176-0.378 .875 1.327 530.17 24773688 0.33075 0.00250297 24.44293 Dact 0.06117996 Log this in Air Density lbs/ft3 colunm of log sheet Find the flow rate of the sampler at standard conditions std using this formula Qstd Qact Dact std Where std .075 lbs/ft3 0.061 17996 i.e std 18.88 0.075 18.88 0.8157328 15.40 std 15.40 write this down for each position in the 0.075 column 3.3.3 Bubble Tube Method Refer to Section 3.2.1 to perform this method C\Documents and Settings\dftydenlund\Local SettingsTemporary Internet Fi1esContent.Out1ook\15CXRH6Z\Sect3 AppD RPM WMM5OP R-12 08 a.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 GROUNDWATER QUALITY ASSURANCE PROJECT PLAN FOR UDEQ SPLIT SAMPLING International Uranium USA Corporation P.O Box 809 BlandingUT 84511 C\Documents and Settings\dfryden1und.Local Settings\Temporaxy Internet Files\Content.Outlook\I5CXRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 TABLE OF CONTENTS SECTION PAGE white mesa mills groundwater quality assessment project plan 1.0 INTRODUCTION 2.0 DESCRIPTION AND OVERALL DATA QUALITY OBJECTIVES 2.1 INTRODUCTION 2.2 ANALYTICAL OBJECTIVES 2.3 DATA MANAGEMENT OBJECTIVES 2.4 PROJECT SCHEDULE 3.0 PROJECT ORGANIZATION AND RESPONSIBILITIES 3.1 PROJECT ORGANIZATION 3.2 RESPONSIBILITIES OFIUC PERSONNEL 3.3 RESPONSIBILITIES OF CONTRACT LABORATORY 4.0 QUALITY ASSURANCE PARAMETERS 4.1 QUALITY ASSURANCE PARAMETERS 4.1.1 PRECISION 4.1.2 ACCURACY 4.1.3 REPRESENTATIVENESS 4.1.4 COMPLETENESS 4.1.5 COMPARABILITY 4.2 FIELD ANDLABORATORY QUALITY CONTROL 4.2.1 FIELD QC CHECKS 4.2.2 FIELD QC CHECK PROCEDURES 10 4.3 LABORATORY QC CHECKS 11 4.3.1 MATRIXSPIKE 11 4.3.2 LABORATORY DUPLICATES 11 4.3.3 LABORATORY AND PREPARATION BLANKS 12 4.4 MEASUREMENT GOALS 12 4.5 FIELD MEASUREMENTS 12 5.0 SAMPLING PROCEDURES 12 6.0 SAMPLEANDDOCUMENTCUSTODYPROCEDURES 12 7.0 CALIBRATION AND FREQUENCY PROCEDURES 12 8.0 ANALYTICAL PROCEDURES 13 8.1 LABORATORY PROCEDURES 13 8.2 PHYSICAL TESTS AND FIELD PROCEDURES 13 9.0 DATA REDUCTION VALIDATION AND REPORTING 13 10.0 INTERNAL LABORATORY CHECKS 14 11.0 SYSTEM AND PERFORMANCE AUDITS 15 11.1 AUDITPROCEDURE 15 11.2 FOLLOW-UP ACTIONS 15 113 AUDITRECORDS 15 12.0 PREVENTIVE MAINTENANCE 16 13.0 DATA ASSESSMENT PROCEDURES 16 14.0 CORRECTIVE ACTION 17 15.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT 17 16.0 REFERENCES 19 TABLE 1.0 ORGANIZATIONAL STRUCTURE 20 ATTACHMENT INTERPRETATION OF GROUNDWATER VOC RESULTS FROM PVC WELLS.21 ATTAChMENT ESTABLISHMENT OF BACKGROUND AND INTERPRETATION OFRESULT.22 CADocuments and Settings\dfiydenlund\Local SettingsTemporary Internet Files\Content.Outook\15CXRHZ\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 WHITE MESA MILLS GROUNDWATER QUALITY ASSURANCE PROJECT PLAN 1.0 INTRODUCTION This quality assurance program is based on EPA Guideline SW-846 NRC Regulatory Guide 4.14 and 4.15 and is designed to provide specific guidance and quality assurance requirements for White Mesa Mills environmental sampling activities This specific Quality Assurance QA Project Plan is applicable to the UDEQ groundwater split sampling program It presents the purpose organization and Standard Operating Procedures SOPs pertinent to conducting split sampling in manner consistent with specific quality assurance goals Quarterly sampling of POC monitoring parameters for compliance with NRC license conditions will be conducted in accordance with the Groundwater Monitoring Plan and Standard Operating Procedures for Quarterly POC Monitoring and the Groundwater Quality Assurance Project Plan for Quarterly POC Monitoring The quality assurance goals in this Project Plan focus on precision accuracy completeness representativeness and comparability The QA program addresses data quality objectives DQOs quality assurance objectives sample and document custody procedures quality control procedures data evaluation procedures and analytical procedures 2.0 DESCRIPTION AND OVERALL DATA QUALITY OBJECTIVES 2.1 INTRODUCTION This document governs environmental sampling activities undertaken in cooperation with UDEQs request for expanded sampling of groundwater at the White Mesa Mill 2.2 ANALYTICAL OBJECTIVES The data quality objective process described in EPA Guideline SW- 846 is used as basis for development of the analytical objectives For analysis of the groundwater samples analytical objectives have been developed and are described in detail in Sections 4.0 and 8.0 Analytical objectives include criteria for precision accuracy representativeness completeness and comparability of the groundwater c\nocuments and Settings\dfiydenluud\Lucal 5ettings\Temporuy Internet Files\Coritent.OutIuok15CXRH6Z\UDEQ Groundwater QA Plan.doe White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 data Analytical methods used vary according to the analyses required and according to the methods used by the laboratory Procedures regarding review of data and data validation are included 2.3 DATA MANAGEMENT OBJECTIVES Procedures are given to document sample quality Procedures include all SOPs for groundwater monitoring well sampling activities Field logbooks will be kept as described in Appendix Part II SOP No 1.0 Sample analyses from the in- house laboratory and from the contract laboratory will be retained in the monitoring wells file Analytical results from the additional wells and expanded parameter list of the UDEQ split sampling program will not be incorporated into the quarterly POC report to NRC The quarterly POC report will contain only those parameters which are required by the NRC license conditions and which have been sampled and analyzed in accordance with the Groundwater Monitoring Plan and Standard Operating Procedures for Quarterly POC Monitoring and the Groundwater Quality Assurance Project Plan for Quarterly POC Monitoring Analytical results and summaries from the additional wells and expanded parameter list will be provided to IIJC management 2.4 PROJECT SCHEDULE The groundwater project schedule is discussed in Section 1.0 of Appendix Part Groundwater Monitoring Plan for UDEQ Split Sampling 3.0 PROJECT ORGANIZATION AND RESPONSIBILITIES 3.1 PROJECT ORGANIZATION Project organization consists of the Environmental Coordinator reporting to the Department Head of EA/HS The Department Head of EAIHS has the overall responsibility for assuring that the QA program is being followed and that QC measures are adequate The Environmental Technician reports to the Environmental Coordinator on the progress of groundwater sampling activities and any problems incurred In addition both the in-house Chemist and the Laboratory Project Chemist send all groundwater analyses to the Environmental Coordinator for review An Organizational Chart is included in Table 1.0 3.2 RESPONSIBILITIES OF IUC PERSONNEL C\Documerits and Settings\dfrydenlund\Local SettingsTemporary Internet Files\Content.Outlook\15CXRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 The Environmental Technician is responsible for sample collection sample storage sample management and equipment calibration The Technician is required to follow all SOPs relating to groundwater sampling activities The in-house Chemist is responsible for performing groundwater analyses for chemical analytes specified by EA/HS department head The Chemist is also responsible for following U.S EPA analytical methods in Guideline SW-846 In addition White Mesa Mills Environmental Coordinator is responsible for directing and coordinating all environmental sampling activities The Department Head of EAJHS will supervise all QA/QC measures to assure proper adherence to the QA program and will determine corrective measures to be taken when deviations from the program occur 3.3 RESPONSIBILITIES OF CONTRACT LABORATORY The contract laboratory is responsible for providing sample analyses for groundwater monitoring and for reviewing all analytical data to assure that data are valid and of sufficient quality The laboratory is also responsible for data validation in which 10%of the data is checked in reference to data quality objectives In addition the laboratory must adhere to the specified guidelines IUC is requiring the laboratory to meet The guidelines the contract laboratory is expected to follow are EPA Guideline SW-846 and NRC Regulatory Guide 4.14 and 4.15 The contract laboratory will be chosen based on the following criteria experience in analyzing environmental samples with detail for precision and accuracy experience with similarmatrix analyses operation of stringent internal quality assurance program meeting IUs specifications ability to satisfy radionuclide requirements as stipulated in NRC Regulatory Guide 4.14 and audit and approval of the laboratory by IUC Details of quality assurance quality control QAIQC requirements for laboratory performance are addressed in sections 6.0 and 15.0 respectively 4.0 QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA The primary QA objective for all White Mesa Mills groundwater sampling activities is to identify and implement procedures for field sampling laboratory analyses data management and reporting that will provide data of sufficient quality to meet groundwater monitoring objectives C\Documents and settings\dfrydenlund\Local Settings\Temporary Internet Fi1es\Content.OutIook\15CXRH6ZUDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 Project objectives are previously discussed in section 2.0 The quality assurance objectives are to document data quality in terms of precision accuracy representativeness completeness and comparability 4.1 QUALITY ASSURANCE PARAMETERS 4.1.1 PRECISION Precision is defined as the measure of variability that exists between individual sample measurements of the same property under identical conditions Precision is measured through the use of sample splits taken at specified regular intervals Split samples are prepared during laboratory analysis and must contain identical concentrations of the parameters of concern Analysis of sample splits generates an estimate of overall precision in sampling and analysis Laboratory split analyses express precision as relative percent difference %RPD Field and laboratory split analyses are evaluated during data validation as discussed in Section 9.0 4.1.2 ACCURACY Accuracy is defined as measure of bias in system or as the degree of agreement between measured value and an accepted or measured value The accuracy of laboratory analyses is evaluated based on analyzing standards of known concentration both before and during analysis Accuracy is also measured by spiking samples with known concentration of reagent and measuring the actual versus expected recovery in analysis Blank analysis also notes bias that may have occurred due to cross contamination Analytical QC samples which will be used to control analytical accuracy are discussed in Section 4.3 Accuracy is moreover measured and evaluated through the Standard Operating Procedures SOPs Accuracy is evaluated through the use of blanks Blanks may be field blanks or equipment rinsate blanks which may demonstrate the bias resulting from contamination Such contamination may be due to sampling equipment sample containers or sample handling Section 4.2 addresses quality control samples collected in the field to be used to evaluate the accuracy of sampling activities The impact of bias cKDumenu and Settings\dfiydenlund\Local Seuings\Temporary Internet Files\content.outlook\lScRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 encountered during sampling will be evaluated during data validation as discussed in Section 9.0 4.1.3 REPRESENTATIVENESS Representativeness is defined as the degree to which set of data accurately represents the characteristics of population parameter conditions at sampling point or an environmental condition Representativeness is controlled by collecting QC samples and performing all sampling in compliance with the applicable procedures Detailed sampling procedures are provided QC samples collected in the field to control data representativeness are discussed in Section 4.2 4.1.4 COMPLETENESS Completeness refers to the amount of valid data obtained from measurement system in reference to the amount that could be obtained under ideal conditions Laboratory completeness is measure of the number of samples submitted for analysis compared to the number of analyses found acceptable after review of the analytical data 4.1.5 COMPARABILITY Comparability refers to the confidence with which one set of data can be compared to another measuring the same property Data can be prepared based on accuracy precision and representativeness Data are comparable if sampling conditions collection techniques measurement procedures methods and reporting units are consistent for all samples within sample set Data subject to quality assurance quality control QA/QC measures are deemed more reliable than data without any QA/QC measures Quality control samples which help evaluate comparability are discussed in Section 4.3 4.2 FIELD AND LABORATORY QUALITY CONTROL 4.2.1 FIELD QC CHECKS Field QC checks consist of field duplicates and rinsate blanks collected and submitted to the analytical laboratory in order to assess the quality of data resulting from the field sampling C\Documents and Settings\dfrydenlund\Local 5enings\Temporary Internet FiIes\Content.Outlook\ISCXRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 program Field duplicates will be analyzed to determine the reproducibility of sampling and laboratory results Equipment rinsate blanks will serve as check for cross- contamination that may have occurred during the sampling process The Standard Operating Procedures address the topics of equipment decontamination and sampling procedures to be followed Equipment rinsate blanks provide check for cross- contamination by sampling equipment The frequency for collection of equipment rinsate blanks is described in Part Appendix Groundwater Monitoring Plan Field Blanks will be analyzed to evaluate data accuracy through presentation of possible bias Trip blanks consist of distilled water samples shipped from the laboratory carried into the field and returned to the laboratory in the same cooler or other package as field samples Trip blanks will be analyzed to determine whether transport field or shipping conditions have introduced bias or variability into field samples For the UDEQ split sampling program one trip blank per sampling date or one trip blank per sample shipping container cooler will be analyzed for VOCs 4.2.2 FIELD QC CHECK PROCEDURES Field Duplicates will be used as an additional check on the precision of laboratory analyses At least one field duplicate will be collected during each sample event and submitted blind to the analytical laboratory that is the sample will be numbered as if it were another sample For the UDEQ split sampling program one field duplicate will be collected from any one of the perched zone monitoring wells if well recovery rates and water yields permit Field QC check procedures will include peer review and approval of field procedures by the Department Head of EA/HS All procedures must be signed off by the Department Head of EAIHS in order to be properly implemented and documented For field QC check procedures instrument calibration of all field instruments involved in the sampling process will be made prior to each day of sampling Procedures for instrument calibration are contained in the standard operating procedure 4.3 LABORATORY QC CHECKS C\Documents and Settings\dfrydenlund\Local 5ettings\Temporary Internet Fi1esContent.OutIook15CXRH6ZAUDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page of 22 The QC checks for the in-house and contract analytical laboratory will meet or exceed the quality control measures set forth in the analytical methods used by the laboratory Laboratory QC samples will assess the accuracy and precision of the environmental analyses The following describes the type of QC samples which will be used to assess the quality of the data 4.3.1 MATRIX SPIKE matrix spike is an environmental sample to which known concentrations have been added The spike is taken through the entire analytical procedure and the recovery of the analytes is calculated Results are expressed as percent recovery of the known amount spiked The matrix spike serves as check evaluating the effect of the sample matrix on the accuracy of analysis Matrix spike analyses will be documented in the field logbook and the Chain-of-Custody form by the environmental technician using sample identification number Extra sample volume may be collected as needed minimum of in 20 samples shall be designated for spike analysis The same minimum will hold true for the in-house laboratory as well as the contract laboratory The amount of spiked reagent to add to sample can be determined from the following formula Ni Vi N2 V2 where Ni is the concentration of sample water and where N2 is the concentration of the spike reagent Vi is the volume of the sample water V2 is the volume of reagent that needs to be added When solving the equation V2 can be determined 4.3.2 LABORATORY DUPLICATES laboratory duplicate is taken as split from an environmental sample duplicate is prepared and analyzed by identical methods to the original sample Duplicates serve to check precision of the analysis Results are expressed as relative percent difference RPD between analytical results for the split and the original sample Both the in-house and the contract lab will analyze duplicates C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet FilesContent.Out1ook\15CXRH6ZAUDEQ Groundwater QAPIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 10 of 22 4.3.3 LABORATORY AND PREPARATION BLANKS laboratory blank is prepared and analyzed in an identical manner to the environmental sample preparation blank consists of analyte-free deionized water analyzed in manner identical to the environmental sample Contamination detected in analysis of laboratory or preparation blanks will be used to evaluate any laboratory contamination of groundwater samples which may have occurred 4.4 MEASUREMENT GOALS The objective of quality assurance is to assess the accuracy and precision of sampling activities and laboratory methodology and to provide quantifiable data with known accuracy and precision limits Field activity QC objectives will be fulfilled by the approved sampling and sample handling procedures described in the Groundwater Monitoring Plan and the Groundwater SOPs The accuracy and precision of laboratory analyses will be determined by analysis of laboratory spiked samples laboratory duplicates and sample blanks collected and analyzed with frequency as described below Accuracy is measured as the percent recovery as the percent recovery of known standard or spiked amount for method-specific calibration standards and spiked field samples Precision is measured as relative percent difference RPD for field duplicates The frequency of the duplicates is for every 20 samples submitted The frequency for blanks is for every 20 samples submitted Equipment rinsate blanks will be collected each day groundwater sampling is conducted and submitted with the quarterly samples Furthermore spike should be performed for every 20 samples submitted QA measurement of the representativeness of data is achieved through analysis of field duplicates assuming that comparable sampling and analysis procedures have been followed QA measurement of data comparability is also achieved through analytical methods and laboratory quality assurance programs Laboratory quality assurance provides means for establishing consistency in the performance of analytical procedures and assuring adherence to analytical methods utilized Laboratory quality control programs include C\Documents and Settings\dfrydenlund\Local 5ettingsTemporary Internet Files\Content.Outlook\15CXRHoZ\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page Il of 22 traceability of measurements to independent reference materials and internal controls QA measurement of completeness will be evaluated during data validation as discussed in Section 9.0 Completeness goals for groundwater are addressed in Section 4.14 4.5 FIELD MEASUREMENTS Measurement data will be generated for all groundwater sampling activities and will include description of weather conditions during the time of sample collection QA objectives for the data will be achieved by recording field instrument calibrations and by following preventative maintenance procedures 5.0 SAMPLING PROCEDURES Sampling procedures for split sampling are specified in the Groundwater Standard Operating Procedures for UDEQ Split Sampling These procedures include procedures for preparation of sampling equipment sample designation sample preservation and decontamination 6.0 SAMPLE AND DOCUMENT CUSTODY PROCEDURES Sample and document custody procedures have previously been addressed in other sections Procedures will include sample handling labeling shipping Chain-of-Custody documents field documentation and project documentation Verifiable sample custody will be an integral part of all field and laboratory operations related to groundwater monitoring Traceable steps will be taken in the field and laboratory to document that all samples have been properly acquired preserved and identified 7.0 CALIBRATION AND FREQUENCY PROCEDURES Calibration and frequency procedures have been previously addressed Procedures include calibration of field and laboratory equipment and frequency of calibration fundamental requirement for collection of valid data is the proper calibration of all analytical instruments Calibration documents that analytical equipment is operating properly and that data produced are within defined calibration ranges 8.0 ANALYTICAL PROCEDURES 8.1 LABORATORY PROCEDURES C\Documents and 5ettingsdfiyden1und\Loca1 5ettings\Temporary Internet FiIes\Content.Out1ook15CXRH6Z\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 12 of 22 The analytical procedures to be used by the in-house laboratory and contract laboratory will depend on the analysis being done Methods will vary depending on the laboratory contracted All compliance analyses will be performed at the contract laboratory However both labs are to meet the specifications as outlined by IUC These specifications required both the in-house and contract laboratory to follow NRC Regulatory Guide 4.14 and EPA Guideline SW- 846 The groundwater limits for radionuclides are given in NRC Regulatory Guide 4.14 and the contract laboratory is expected to meet these limits Analytical procedures are discussed in section 11.0 8.2 PHYSICAL TESTS AND FIELD PROCEDURES Parameters such as pH and specific conductance will be measured upon sample collection with appropriate instruments in accordance with the procedures The contract lab will be required to meet the guidelines specified for LLD values for radionuclides in groundwater and may deviate from the LLD values provided that the standard error is not greater than 10%of the estimated value of the sample 9.0 DATA REDUCTION VALIDATION AND REPORTING The analytical data generated by the contract laboratory will be evaluated for the precision completeness accuracy and representativeness using specific data validation procedures All groundwater data will go through two levels of data review and validation The first level of review will be by the contract laboratory data validation specialist will validate all analyses for the contract lab Full validation will include recalculation of raw data for minimum of one or more analytes for ten percent of the samples analyzed The remaining 90%of all data will undergo QC review which will include validating holding times and QC samples Overall data assessment will be part of the validation process as well The laboratory reviewer will evaluate the quality of the data based on NRC guide 4.14 and on analytical methods used The reviewer will check the following sample preparation information is correct and complete analysis information is correct and complete appropriate laboratory SOPs are being followed analytical results are correct and complete QC samples are within established control limits blanks are within QC limits special C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 13 of 22 sample preparation and analytical requirements have been met and documentation is complete The laboratory will prepare and retain full QC and analytical documentation The laboratory will report the data as group of 20 or less along with the QA/QC data The contract laboratory will provide the following information cover sheet listing samples included in report with narrative results of compounds identified and quantified dilution factors and reporting limits for all analytes Also to be included are the QA/QC analytical results The second level of review will be the responsibility of the Environmental Coordinator The review will be objective and independent since the Environmental Coordinator is not directly involved in the analysis of the groundwater samples Additional chemical analyses for groundwater samples will be provided by the in-house laboratory Other areas of interest for validation purposes will include the review of sampling procedures rinsate blanks laboratory blanks laboratory duplicates and spikes Laboratory analyses will also be checked for completeness upon receipt from the contract laboratory Re-runs will be required for samples not meeting reporting limits of LLD values In addition the holding time for groundwater samples varies according to the analyte being analyzed As part of the data validation process the holding time will be compared to the date of the laboratory sample analyses and the date of sample collection to assure validity of the analyses 10.0 INTERNAL LABORATORY CHECKS Laboratory QA procedures will be followed to ensure proper handling and tracking of analytical accuracy and precision Accuracy will be evaluated using spikes blanks and duplicates All out-of-compliance results will be logged by the laboratory QA officer with corrective actions described as well as the results of the corrective actions taken All raw and reduced data will be stored according to the laboratorys record keeping procedures and QA program All records will be available for on-site inspection at any time during the course of investigation The contract laboratory will follow specific SOPs and analytical methods used by the laboratory SOPs will be available for on-site review by non-laboratory personnel during the course of investigation If re-runs occur with increasing frequency the QA officer and the project chemist will be consulted to establish more appropriate analytical approaches to problem samples 11.0 SYSTEM AND PERFORMANCE AUDITS C\Documents and 5euingsdfrydenlund\Loca1 Settings\Temporary Internet FiIes\Content.Out1ook\15CXRH6ZUDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 14 of 22 System audits are conducted to verify documentation and implementation of the QA program The audits also evaluate the effectiveness of the established QA program and identify any weakness within the program needing improvement Audits identify deviations from the QA program and verify correction of such deviations The Department Head of EAJHS will be responsible for initiating and overseeing system audits Performance audits are used to assess the accuracy of measurement data through the use of laboratory performance evaluation and blind check samples Blind performance evaluation samples will be submitted to the contract laboratory for analysis 11.1 AUDIT PROCEDURE The system audits will be conducted by IIJC staff or by other qualified and approved persons System audits will review field and laboratory operations including sampling equipment laboratory equipment sampling procedures and equipment calibrations to evaluate the effectiveness of the QA program and to identify any weakness that may exist 11.2 FOLLOW-UP ACTIONS Response to the system audits is required when deviations are found and corrective action is required The Department Head of EAIHS in coordination with the Environmental Coordinator will respond to each Audit Finding Report by completing the Corrective action Reply section on each form The response is to be completed within 20 days of receipt and is to state the corrective measures taken for each finding The response will include the corrective action the date of implementation and include corrective action to prevent recurrence 113 AUDIT RECORDS Audit records for all audits conducted to date will be retained in Central Files These records will contain audit reports written replies records of completion for corrective actions and any other documents associated with the audits supporting audit findings or corrective actions 12.0 PREVENTIVE MAINTENANCE Preventive maintenance concerns the proper maintenance and care of field and laboratory instruments Preventive maintenance helps ensure that groundwater data generated will be of sufficient quality to meet QA objectives Both field and c\Duments and Settirigs\dfrydenlund\Local settings\Temporary Internet FiIes\Content.Out1ookI5CXRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 15 of 22 laboratory instruments have set maintenance schedule to ensure proper functioning of the instruments Both field and laboratory instruments will be maintained as per the manufacturers specifications and established sampling practice Field instruments will be checked and calibrated prior to use Batteries will be charged and checked daily or as needed All equipment out of service will be immediately replaced Field instruments will be protected from adverse weather conditions during sampling activities Instruments will be stored properly at the end of each working day Calibration and maintenance problems encountered will be recorded in the field logbook Calibration and maintenance procedures have been specified Both the in-house and the contract laboratory are responsible for the maintenance of their instruments Preventive maintenance will be performed on scheduled basis to minimize downtime and the potential interruption of analytical work 13.0 DATA ASSESSMENT PROCEDURES Data assessment and review will be accomplished by the Project Chemist in conjunction with data validation and QC review summary of this assessment of chemical data quality will be reviewed by the Environmental Coordinator Any problems regarding sample collection shipping handling or analysis will be taken into consideration when evaluating the quality of the data Both precision and accuracy of the data will be evaluated to assess the quality of the data Assessment of data with respect to the quality assurance objectives will be accomplished through the joint efforts of the Project Chemist Environmental Coordinator and the Department Head of BAtHS The assessment will evaluate sample collection sample handling field data validated blank values and any other data flags or qualifiers Data assessment for the UDBQ split sampling program will also consider the impact of PVC wells on the accuracy of VOC and SVOC analytical results as described in Attachment to this QAPP 14.0 CORRECTIVE ACTION 15.0 Both the field Technician and Project Chemist are responsible for following procedures in accordance with the protocols established in the Quality Assurance Project Plan Corrective action should be taken for any procedure deficiencies or deviations noted in the groundwater monitoring program All deviations from field sampling procedures will be noted in the field logbook Any QA/QC problems that arise will be brought to the immediate attention of the CDocuments and 5ettings\dfrydenlund\Local 5ettingsTemporary Internet Fi1esContent.OutIook\15CXRH6Z\UDEQ Groundwater QA Plan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 16 of 22 Environmental Coordinator Laboratory deviations will be recorded by the QA officer in logbook as well Corrective actions will be made and documented when procedures are not strictly in compliance with the established protocol Data associated with these deviations is considered suspect Additional samples or measurements will be taken in the field to replace data considered suspect Upon implementation of corrective action memorandum documenting the field corrective action will be placed in the monitoring well files and in Central Files Corrective action for laboratory deviations will be the responsibility of both the Environmental Coordinator and Laboratory Supervisor Any deviation apparent during analysis will be addressed and corrective action will be taken when deemed necessary All corrective measures will be documented and filed 15.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT The Environmental Technician will report to the Environmental Coordinator regularly regarding progress of the groundwater sampling program The technician will also brief the coordinator on any QA/QC issues associated with groundwater sampling activities The in-house and contract laboratories maintain detailed procedures for laboratory record keeping Each data set report submitted to the Environmental Coordinator will contain the laboratorys certification of the analytical methods performed and identify all QC/QC measures not within the established control limits Any QA/QC problems will be brought to the Environmental Coordinators attention as soon as possible After sampling has been completed and final analyses are completed and reviewed brief data evaluation summary report will be prepared The report will summarize the data validation efforts and provide an evaluation of the data quality in regard to precision accuracy and completeness The final summary will be prepared by the Project Chemist for the contract lab and by the staff Chemist at the in-house lab The final summary will be reviewed by the Environmental Coordinator If UDEQ split sampling and quarterly POC sampling are conducted on the same dates analytical results from the additional wells and expanded parameter list of the UDEQ split sampling program will not be incorporated into the quarterly POC report The quarterly POC report will contain only those parameters which are required by the NRC license conditions and which have been sampled and analyzed in accordance with the Groundwater Monitoring Plan and Standard Operating Procedures for Quarterly POC Monitoring and the Groundwater Quality Assurance Project Plan for Quarterly POC Monitoring c\Dumrns and Settings\dfrydenlund\Local SettingsTemporary Internet Files\Content.Outlook\IScXRH6z\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 17 of 22 16.0 REFERENCES Environmental Protection Agency EPA 1986 Test Methods for Evaluating Solid Waste SW-846 Third Edition November Environmental Protection Agency EPA 1987 Data Quality Objectives for Remedial Response Activities Development Process EPA/540/g-87/003 and Data Quality Objectives for Remedial Response Activities Example Scenario RIJFS Activities at Site with Contaminated Soils and Groundwater EPA/540/G-87/004 Environmental Protection Agency EPA 1988a Laboratory Validation Functional Guidelines for Evaluating Organic Analyses February Environmental Protection Agency EPA 1988b Laboratory Data Evaluation Functional Guidelines for Evaluating Inorganic Analysis July Environmental Protection Agency EPA 1990 National Functional Guidelines for Organic Data Review Revised June Nuclear Regulatory Commission NRC 1980 Radiological Effluent and Environmental Monitoring at Uranium Mills Regulatory Guide 4.14 April Nuclear Regulatory Commission NRC 1979 Quality Assurance for Radiological Monitoring Programs Effluent Streams and the Environment Regulatory Guide 4.15 February Umetco White Mesa Mill 1990 White Mesa Procedures Manual for Groundwater Hydrology CADocuments and Settings\dfrydenhmd\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Book 18 UDEQ Split Sampling Quality Assurance Plan TABLE 1.0 ORGANIZATIONAL STRUCTURE Date 07/99 Revision Page 18 of 22 DEPARTMENT HEAD OF EA/HS ENVIRONMENTAL COORDINATOR ENVIRONMENTAL TECHNICIAN IN-HOUSE CHEMIST LABORATORY PROJECT CHEMIST CDocuments and Seuings\dfrydenlund\Local SeuingsTemporaiy Internet Files\Content.Outlook\15CXRH6Z\UDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 19 of 22 ATTACHMENT Interpretation of Groundwater VOC Results from PVC Wells As has been noted in correspondence between IIJSA and UDEQ EPA and others have conducted numerous evaluations of what impact PVC well casings may have on groundwater sampling results for VOCs These studies have often resulted in significantly different conclusions However the vast majority have concluded that PVC is capable of sorb ing and leaching organic constituents These varying conclusions reflect different interpretations of what constitutes significant parameter interference In some cases PVC interference may be insignificant while in others it may seriously bias the analytical results Regardless EPA continues to advise against the use of PVC well casing where dilute organic concentrations are expected or are of interest With this in mind it should be possible to collect worthwhile groundwater samples from the existing PVC-Ocased wells at the Mill as long as the results are analyzed with PVC interference in mind If high concentrations were to be encountered greater than mgfL it is unlikely that leaching from PVC casing would present any significant bias However should analytical results indicate low level detection of organic compounds in number of the wells the detected parameters should be compared to the list of those known to leach from PVC or glued joints Given that the limit of detection of EPA method 8260 is ugIL analytical results for parameters known to leach from PVC or glued joints near the detection level could realistically be produced by PVC interference and should be attributed to that source c\Documents and 5ettings\dfrydenlund\Local settings\Temporary Internet Files\Content.Outlook\I5cXRH6rUDEQ Groundwater QA Plan.doe White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 20 of 22 ATTACHMENT Establishment of Background and Interpretation of Results from UDEQ Split Sampling 2.1 Wells to be Sampled for UDEQ Split Sampling Program The UDEQ split sampling program involves sampling of the following IUSA wells Culinary Wells Energy Fuels Wells and Monitoring Wells MW-i MW-2 MW-3 MW-4 MW-5 MW-li MW-12 MW-14 MW-iS MW-17 MW-18 and MW-19 These wells can be separated into two categories with respect to status of background values Wells that have been monitored as part of the ongoing NRC quarterly monitoring and for which intra-well background has been established for the POC monitoring parameters Specifically wells MW-5 -ii -12 -14 -15 and -17 have been monitored and intra-well background established for chloride nickel potassium and U-Nat Wells for which background has not been established for some or all of the extended list of parameters Background has not been established for MW-5 ii -12 -14 -15 and -17 for components of the extended list of parameters that are not POC monitoring parameters that is any parameters other than the four identified above For the remaining wells proposed by UDEQ including the culinary wells and the Ute wells IUC has not established background for any of the parameters in the extended list 2.2 Background for Wells in the Perched Zone Due to the temporal and spatial variations in water quality in the perched zone UDEQ has agreed with JUSA that an intra-well comparison is the most appropriate method for evaluation of White Mesa Mill groundwater data IUSA currently utilizes the Shewhart CUSUM control chart method described in Section 3.0 of the White Mesa Mill Points of Compliance POC Report Titan Environmental September 1994 for establishment of background and evaluation of ongoing analytical results for the POC parameters reported quarterly for wells MW-S -11 -12 -14 -15 and -17 EPA recommends this method in their c\uments and Settings\dfrydenIundLocaI Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\UDEQ Groundwater QA Plandoc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 21 of 22 guidance document Statistical Evaluation of Groundwater at RCRA Facilities USEPA April 1989 I1JSA will also utilize the Shewhart-CUSUM method for Establishing background for additional parameters to be analyzed during the split sampling program for POC wells MW-5 -11 -12 -14 -15 and 17 Evaluating ongoing analytical results for both POC parameters and additional parameters to be analyzed during the split sampling program for POC wells MW 5-il -12 -14 -15 and 17 Establishing background for all parameters to be analyzed during the split sampling program for additional wells MW -1 MW-2 MW-3 MW-4 MW-18 andMW-19 Evaluating ongoing analytical results for all parameters to be analyzed during the split sampling program for additional wells MW -1 MW-2 MW-3 MW-4 MW- 18 and MW-19 2.3 Background for Entrada/Navajo Wells IIJSA will also utilize the Shewhart-CUSUM method for Establishing background for all parameters to be analyzed during the split sampling program for culinary wells and Evaluating ongoing analytical results for all parameters to be analyzed during the split sampling program for culinary wells and 2.4 Consideration of Historic Information in the Evaluation of New Groundwater Data In evaluating analytical results from both the perched zone wells in the Dakota Sandstone and the culinary wells in the Navajo Sandstone consideration will be given to the fact that previous data not included in the eight periods of data used to establish background under the Shewhart-CUSUM method indicate that certain analytes were already elevated in natural background Attachment Table identifies the parameters that have been shown to be elevated due to natural geochemical phenomena in both formations C\Documents and Settings\dfryderilund\Local 5ettings\Temporaiy Internet Files\Content.Outlook\15CXRHZAUDEQ Groundwater QA PIan.doc White Mesa Mill Standard Operating Procedures Date 07/99 Revision Book 18 UDEQ Split Sampling Quality Assurance Plan Page 22 of 22 Attachment Table Summary of Water Quality Results Prior to White Mesa Mill Startup Background Well or Source Metals Elevated Ions Elevated Sample Formation Above Acceptable Above Acceptable Levels Levels G2R Navajo Sandstone iron Cottonwood Creek 01 Dakota Sandstone arsenic2 sulfate2 iron2 selenium2 Cottonwood Creek 03 Dakota Sandstone arsenic2 sulfate2 iron2 selenium2 Cottonwood Creek G4 Dakota Sandstone arsenic2 sulfate2 iron2 selenium2 Cottonwood Creek 05 Dakota Sandstone arsenic2 sulfate2 iron2 selenium2 Stock Well G6R Dakota Sandstone arsenic sulfate iron1 lead1 Stock Well G7R Dakota Sandstone arsenic sulfate iron1 lead Culinary Well Navajo Sandstone iron3 sulfate3 Culinary Well Navajo Sandstone sulfate3 Culinary Well Navajo Sandstone sulfate3 Culinary well Navajo Sandstone sulfate3 Notes Environmental Report Dames Moore 1978 Includes results confinned by Utah State Division of Health Laboratory Environmental Statement USNRC 1979 Includes results confirmed by Utah State Division of Health Laboratory Pre-Startup Data Review DAppolonia 1981 Includes results confirmed by Utah State Division of Health Laboratory C\Documents and settings\dliydenlund\.Local Settings\Temporary Internet FiIesContent.Outlook\15CXRH6Z\UDEQ Groundwater QA Plan.doc Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 WHITE MESA URANIUM MILL GROUND WATER MONITORING QUALITY ASSURANCE PLAN QAP STATE OF UTAH GROUNDWATER DISCHARGE PERMIT No UGW370004 Denison Mines USA Corp P.O Box 809 landing UT 84511 Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 TABLE OF CONTENTS Page INTRODUCTION ORGANIZATION AND RESPONSIBILITIES 2.1 Functional Groups 2.2 Overall Responsibility For the AQ/QC Program 2.3 Data Requestors/Users 2.4 Data Generators 2.4.1 Sampling and QC Monitors 2.4.2 Analysis Monitor 2.4.3 Data Reviewers/Approvers 2.5 Responsibilities of Analytical Laboratory QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OF DATA 3.1 Precision 3.2 Accuracy 10 3.3 Representativeness 10 3.4 Completeness 10 3.5 Comparability 11 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 11 4.1 Controlling Well Contamination 11 4.2 Controlling Depth to Groundwater Measurements 11 Mill Groundwater Discharge Permit Date6-18-08 Revision Groundwater Monitoring Quality Assurance Plan QAP Page of 43 4.3 Water Quality QC Samples 11 4.3.1 VOCTripBlanks 11 4.3.2 Equipment Rinsate Samples 12 4.3.3 Field Duplicates 12 4.3.4 Definition of Batch 12 CALIBRATION 12 5.1 Depth to Groundwater Measurements 13 5.2 Water Quality 13 GROUND WATER SAMPLING AND MEASUREMENT OF FIELD 13 PARAMETERS 6.1 Groundwater Head Monitoring 13 6.1.1 Location and Frequency of Groundwater Head Monitoring 13 6.1.2 Equipment Used For Groundwater Head Monitoring 14 6.1.3 Field Sampling Procedure for Groundwater Head Monitoring 14 6.2 Ground Water Compliance Monitoring 14 6.2.1 Location and Frequency of Groundwater Compliance Monitoring 14 6.2.2 Quarterly and Semi-Annual Sampling Required Paragraphs I.E.1.a orl.E.1.b of the 15 GWDP 6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G or I.G.2 of the 15 GWDP 6.2.4 Sampling Equipment for Groundwater Compliance Monitoring 15 6.2.5 Decontamination Procedure 16 6.2.6 Pre Purging/Sampling 17 Activities 6.2.7 Well Purging/Measurement of Field Parameters 17 6.2.8 Samples to be Taken and Order of Taking Samples 20 6.2.9 Field Duplicate 20 Samples 6.2.10 VOCs and Nutrient Sampling 21 6.2.11 Heavy Metals All Other Non-Radiologics and Gross Alpha Sampling 21 6.2.12 Procedures to Follow After Sampling 24 SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 25 7.1 Field Data Worksheets 25 7.2 Chain-Of-Custody and Analytical Request Record 26 7.3 Record Keeping 26 Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 ANALYTICAL PROCEDURES AND QA/QC 27 8.1 Analytical Quality Control 27 8.1.2 Spikes Blanks and Duplicates 27 8.2 Analytical Laboratory Procedures 28 INTERNAL QUALITY CONTROL CHECKS 31 9.1 Field QC Check Procedures 31 9.1.1 Review of Compliance With the Procedures Contained in this Plan 31 9.1.2 Analyte Completeness Review 31 9.1.3 Blank Comparisons 31 9.1.4 Duplicate Sample Comparisons 31 9.2 Analytical Laboratory QA Reviews 32 9.3 QA Manager Review of Analytical Laboratory Results and Procedures 33 9.4 Analytical Data 34 10 CORRECTIVE ACTION 34 10.1 When Corrective Action is Required 34 10.2 Procedure for Corrective Action 35 11 REPORTING 35 12 SYSTEM AND PERFORMANCE AUDITS 36 12.1 QA Manager to Perform System Audits and Performance Audits 36 12.2 System Audits 36 12.3 Performance Audits 37 12.4 Follow-Up Actions 37 12.5 Audit Records 37 13 PREVENTIVE MAINTENANCE 37 14 QUALITY ASSURANCE REPORTS TO MANAGEMENT 38 Mill Groundwater Discharge Pefmit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 14.1 Ongoing QAIQC Reporting 38 14.2 Periodic Reporting to Management 38 15 AMENDMENT 39 16 REFERENCES 39 Appendices Appendix A-Chloroform Investigation Monitoring Quality Assurance Program Li 11 ii Mill Groundwater Discharge Permit Date6-18-08 Revision_3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 INTRODUCTION This Groundwater Monitoring Quality Assurance Plan the Plan details and describes all sampling equipment field methods laboratory methods qualifications of environmental analytical laboratories data validation and sampling and other corrective actions necessary to comply with UAC R3 17-6-6.3I and at the White Mesa Uranium Mill the Mill as required under paragraph I.H.6 of State of Utah Groundwater Discharge Permit No UGW370004 the GWDP for the Mill This Procedure incorporates the applicable provisions of the United States Environmental Protection Agency EPA RCRA Groundwater Monitoring Technical Enforcement Guidance Document OSWER-9950 September 1986 as updated by EPAs RCRA Ground-Water Monitoring Draft Technical Guidance November 1992 Activities in an integrated program to generate quality data can be classified as management i.e quality assurance or QA and as functional i.e quality control or QC The objective of this Plan is to ensure that monitoring data are generated at the Mill that meet the requirements for precision accuracy completeness representativeness and comparability required for management purposes and to comply with the reporting requirements established by applicable permits and regulations ORGANIZATION AND RESPONSIBILITIES 2.1 Functional Groups This Plan specifies roles for QA Manager as well as representatives of three different functional groups the data users the data generators and the data reviewers/approvers The roles and responsibilities of these representatives are described below 2.2 Overall Responsibility For the QAJQC Program The overall responsibility for ensuring that the QAIQC measures are properly employed is the responsibility of the QA Manager The QA Manager is typically not directly involved in the data generation i.e sampling or analysis activities At the Mill the QA Manager is the Mills Radiation Safety Officer RSO or other qualified person designated by Denison Mines USA Corp DUSA corporate management 2.3 Data Requestors/Users The generation of data that meets the objectives of this Plan is necessary for management to make informed decisions relating to the operation of the Mill facility and to comply with the reporting requirements set out in the GWDP and other permits and applicable regulations Accordingly the data requesters/users the Data Users are therefore DUSAs corporate management and regulatory authorities through the implementation of such permits and regulations The data quality objectives DQOs required for any groundwater sampling event such as acceptable minimum detection limits are specified in this Plan Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 2.4 Data Generators The individuals who carry out the sampling and analysis activities at the request of the Data Users are the data generators For Mill activities this involves sample collection record keeping and QA/QC activities conducted by one or more sampling and quality control/data monitors each Sampling and QC Monitor The Sampling and QC Monitors are radiation and environmental technicians or other qualified Mill personnel as designated by the QA Manager The Sampling and QC Monitors perform all field sampling activities collect all field QC samples and perform all data recording and chain of custody activities in accordance with this Plan Data generation at the contract analytical laboratory the Analytical Laboratory utilized by the Mill to analyze the environmental samples is performed by or under an employee or agent the Analysis Monitor of the Analytical Laboratory in accordance with specific requirements of the Analytical Laboratorys own QA/QC program The responsibilities of the data generators are as follows 2.4.1 Sampling and QC Monitors The Sampling and QC Monitors are responsible for field activities These include Ensuring that samples are collected preserved and transported as specified in Plan Checking that all sample documentation labels field data worksheets chain-of- custody records packing lists is correct and transmitting that information along with the samples to the Analytical Laboratory in accordance with this Plan Maintaining records of all samples tracking those samples through subsequent processing and analysis and ultimately where applicable appropriately disposing of those samples at the conclusion of the program Preparing quality control samples for field sample collection during the sampling event Preparing QC and sample data for review by the QA Manager and Preparing QC and sample data for reporting and entry into computer data base where appropriate 2.4.2 Analysis Monitor The Analysis Monitor is responsible for QA/QC activities at the Analytical Laboratory These include Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page of 43 Training and qualifying personnel in specified Analytical Laboratory QC and analytical procedures prior to receiving samples Receiving samples from the field and verifying that incoming samples correspond to the packing list or chain-of-custody sheet and Verifying that Analytical Laboratory QC and analytical procedures are being followed as specified in this Plan by the Analytical Laboratorys QA/QC program and in accordance with the requirements for maintaining National Environmental Laboratory Accreditation Program NELAP and/or National Voluntary Laboratory Accreditation Program NAVLAP certification 2.4.3 Data Reviewers/Approvers The QA Manager has broad authority to approve or disapprove project plans specific analyses and final reports In general the QA Manager is responsible for reviewing and advising on all aspects of QA/QC including Ensuring that the data produced by the data generators meet the specifications set out in this Plan Making on-site evaluations and submitting audit samples to assist in reviewing QA/QC procedures Determining with the Sampling and QC Monitor and Analysis Monitor appropriate sampling equipment and sample containers in accordance with this Plan to minimize contamination and Supervising all QA/QC measures to assure proper adherence to this Plan and determining corrective measures to be taken when deviations from this Plan occur The QA Manager may delegate certain of these responsibilities to one or more Sampling and QC Monitors or to other qualified Mill personnel 2.5 Responsibilities Of Analytical Laboratory Unless otherwise specified by DUSA corporate management all environmental analysis of groundwater sampling required by the GWDP or by other applicable permits will be performed by contract Analytical Laboratory Mill Groundwater Discharge Permit Date6-18-08 Revision Groundwater Monitoring Quality Assurance Plan QAP Page of 43 The Analytical Laboratory is responsible for providing sample analyses for groundwater monitoring and for reviewing all analytical data to assure that data are valid and of sufficient quality The Analytical Laboratory is also responsible for data validation in accordance with the requirements for maintaining NELAP and/or NAVLAP certification In addition to the extent not otherwise required to maintain NELAP and or NAYLAP certification the Analytical Laboratory must adhere to EPA Guideline SW-846 and to the extent consistent with NELAP and EPA practices the applicable portions of NRC Regulatory Guide 4.14 The Analytical Laboratory will be chosen by DUSA and must satisfy the following criteria experience in analyzing environmental samples with detail for precision and accuracy experience with similar matrix analyses operation of stringent internal quality assurance program meeting NELAP and/or NAYLAP certification requirements and that satisfies the criteria set out in Section below ability to satisfy radionuclide requirements as stipulated in the applicable portions of NRC Regulatory Guide 4.14 and certified by the State of Utah for and capable of performing the analytical methods set out in Table The analytical procedures used by the Analytical Laboratory will be in accordance with Utah Administrative Code R3 17-6-6.3L QUALITY ASSURANCE OBJECTIVES FOR MEASUREMENT OFDATA The objective of this Plan is to ensure that monitoring data are generated at the Mill that meet the requirements for precision accuracy representativeness completeness and comparability required for management purposes and to comply with the reporting requirements established by applicable permits and regulations the Field and Analytical QC samples described in Sections 4.3 and 8.1 below are designed to ensure that these criteria are satisfied Data subject to QA/QC measures are deemed more reliable than data without any QAIQC measures 3.1 Precision Precision is defined as the measure of variability that exists between individual sample measurements of the same property under identical conditions Precision is measured through the analysis of samples containing identical concentrations of the parameters of concern For duplicate measurements precision is expressed as the relative percent difference RPD of data pair and will be calculated by the following equation RPD /2 100 Where original and duplicate are the reported concentration for field duplicate samples analyses or in the case of analyses performed by the Analytical Laboratory the percent recoveries for matrix spike and matrix spike duplicate samples EPA SW-846 Chapter Section 5.0 page 28 Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 10 of 43 3.2 Accuracy Accuracy is defined as measure of bias in system or as the degree of agreement between measured value and an accepted or measured value The accuracy of laboratory analyses is evaluated based on analyzing standards of known concentration both before and during analysis Accuracy will be evaluated by the following equation EPA SW-846 Chapter Section 5.0 page 24 Recovery A-B I/C 100 Where the concentration of analyte in sample the concentration of analyte in an unspiked sample the concentration of spike added 3.3 Representativeness Representativeness is defined as the degree to which set of data accurately represents the characteristics of population parameter conditions at sampling point or an environmental condition Representativeness is controlled by performing all sampling in compliance with this Plan 3.4 Completeness Completeness refers to the amount of valid data obtained from measurement system in reference to the amount that could be obtained under ideal conditions Laboratory completeness is measure of the number of samples submitted for analysis compared to the number of analyses found acceptable after review of the analytical data Completeness will be calculated by the following equation Completeness Number of valid data points/total number of measurements 100 Where the number of valid data points is the total number of valid analytical measurements based on the precision accuracy and holding time evaluation Completeness is determined at the conclusion of the data validation Executive Secretary approval will be required for any completeness less than 100 percent 3.5 Comparability Comparability refers to the confidence with which one set of data can be compared to another measuring the same property Data are comparable if sampling conditions collection techniques measurement procedures methods and reporting units are consistent for all samples within sample set Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 11 of 43 FIELD SAMPLING QUALITY ASSURANCE METHODOLOGY 4.1 Controlling Well Contamination Well contamination from external surface factors is controlled by installation of cap over the surface casing and cementing the surface section of the drill hole Wells have surface covers of mild steel with lockable cap cover Radiation Safety staff has access to the keys locking the wells Subsurface well stagnation for pumped wells is reduced by pumping two well casing volumes of water from the wells to the extent practicable This ensures to the extent practicable that the aquifer zone water is being drawn into the well and is representative sample 4.2 Controlling Depth to Groundwater Measurements Monitoring of depth to groundwater is controlled by comparing historical field log data to actual measurement depth This serves as check of the field measurements 4.3 Water Quality QC Samples Quality assurance for ground water monitoring consists of the following QC samples 4.3.1 VOC Trip Blanks Trip blanks will be used to assess contamination introduced into the sample containers by volatile organic compounds VOCs through diffusion during sample transport and storage At minimum at least one trip blank will be in each shipping container containing samples to be analyzed for VOCs Trip blanks will be prepared by the Analytical Laboratory transported to the sampling site and then returned to the Analytical Laboratory for analysis along with the samples collected during the sampling event The trip blank will be unopened throughout the transportation and storage processes and will accompany the technician while sampling in the field DTG Field and Laboratory Quality Assurance/Quality control 7.8 pages 7-30 7-3 43.2 Equipment Rinsate Samples Where portable non-dedicated pump is used rinsate sample will be collected prior to using and after decontaminating the sampling equipment at the beginning of each sampling event and at the beginning of each day of the sampling event TEGD Field QA/QC Program page 119 Where non-dedicated bailer is used rinsate sample will be collected prior to any well sampling or purging and after decontamination at the beginning of each sampling event and at the beginning of each day of the sampling event In the case of equipment rinsate blank samples for pump the sample will be prepared by pumping de-ionized water Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 12 of 43 into the sample containers In the case of equipment rinsate blank samples for non- disposable or non-dedicated bailer the sample will be prepared by pouring de-ionized water over and through the bailer and into the sample containers During quarterly/semi-annual monitoring events equipment rinsate blanks will need to be analyzed only for the contaminants required during the accelerated monitoring event 4.3.3 Field Duplicates One Duplicate set of samples submitted with each Batch defined in Section 4.3.4 of samples DTG Field and Laboratory Quality Assurance/Quality Control 7.8 taken from one of the wells being sampled and will be submitted to the Analytical Laboratory and analyzed for all contaminants listed in Table of the GWDP EPA SW-846 Chapter Section 3.4.1 4.3.4 Definition of Batch For the purposes of this Plan Batch is defined as 20 or fewer samples PA SW-846 Chapter Section 5.0 page 23 CALIBRATION fundamental requirement for collection of valid data is the proper calibration of all sample collection and analytical instruments Sampling equipment shall be calibrated in accordance with manufacturers recommendations and Analytical Laboratory equipment shall be calibrated in accordance with Analytical Laboratory procedures Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 13 of 43 5.1 Depth to Groundwater Measurements Equipment used in depth to groundwater measurements will be checked prior to each use to ensure that the Water Sounding Device is functional 5.2 Water Quality The Field Parameter Meter will be calibrated prior to each sampling event and at the beginning of each day of the sampling event according to manufacturers specifications for example by using two known pH solutions and one specific conductance standard Temperature will be checked comparatively by using thermometer Calibration results will be recorded on the Field Data Worksheet GROUND WATER SAMPLING AND MEASUREMENT OF FIELD PARAMETERS 6.1 Groundwater Head Monitoring 6.1.1 Location and Frequency of Groundwater Head Monitoring Depth to groundwater shall be measured quarterly in the following wells and piezometers All Point of Compliance wells listed in paragraphs 6.2.1 and below Monitoring wells MW-20 and MW-22 All piezometers P-l P-2 P-3 P-4 and P-5 All chloroform contaminant investigation wells required to be monitored during the quarter under State of Utah Notice of Violation and Groundwater Corrective Action Order UDEQ Docket No UGQ-20-O1 not already included in paragraph On November 17 2006 such chloroform contaminant investigation wells were the following MW-4 TW4-10 TW4-1 TW4-11 TW4-2 TW4-12 TW4-3 TW4-13 TW4-4 TW4-14 TW4-5 TW4-16 TW4-6 TW4-18 TW4-7 TW4-19 TW4-8 TW4-20 TW4-9 TW4-21 TW4-22 Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 14 of 43 In any other wells or piezometers required by the Executive Secretary of the Utah Radiation Control Board as indicated by the Mills RSO 6.1.2 Equipment Used For Groundwater Head Monitoring Measurement of depth to groundwater is accomplished by using Solinist IT 300 or equivalent device the Water Sounding Device 6.1.3 Field Sampling Procedure for Groundwater Head Monitoring In the case of any well that is being sampled for groundwater quality depth to groundwater is measured prior to sampling Depth to groundwater is measured from the top of the inner well casing or for the piezometers from the top of the casing and is recorded on the Field Data Worksheet for Groundwater described in Section 7.1 the Field Data Worksheet Readings are taken by lowering the Water Sounding Device into the casing until the Device alarms indicating that the water surface has been reached The depth to groundwater is then determined by reference to the distance markings on the line attached to the Device Data is recorded on the Field Data Worksheet as Depth to Water to the nearest 0.01 of foot 6.2 Ground Water Compliance Monitoring 6.2.1 Location and Frequency of Groundwater Compliance Monitoring Groundwater quality shall be measured in the following wells at the following frequencies Semi-annually in the following Point of Compliance wells MW-i MW-2 MW- MW-5 MW-i2 MW-i5 MW-i7 MW-i8 and MW-19 Quarterly in the following Point of Compliance wells MW-il MW-i4 MW-20 MW-22 MW-26 and MW-32 and Quarterly in the following new Point of Compliance wells until quarters of background data are obtained MW-23 MW-24 MW-25 MW-27 MW-28 MW-29 MW-30 and MW-3 Thereafter these wells will be sampled on quarterly or semi-annual basis as required by the GWDP Chloroform Investigation sampling will collected from the locations and at the frequencies listed at Item in the Chloroform Investigation Monitoring Quality Assurance Program Appendix to this document Mill Groundwater Discharge Permit Date6-18 08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 15 of 43 In addition quarterly or monthly sampling may be required for certain parameters in certain wells for which accelerated monitoring is required under paragraph I.G.1 or I.G.2 of the GWDP It is important to confirm with the Mills RSO prior to conducting any monitoring well sampling whether or not any parameters in any wells are subject to this accelerated monitoring 6.2.2 Quarterly and Semi-Annual Sampling Required Under Paragraphs I.E.1.a or I.E.1.b of the GWDP All quarterly and semi-annual samples collected under paragraphs 6.2.1 and above paragraphs I.E .a or T.E .h of the GWDP shall be analyzed for the following parameters Field parameters depth to groundwater pH temperature specific conductance redox potential Eh and turbidity in the manner specified in paragraph 6.2.7 and Laboratory Parameters All parameters specified in Table of the GWDP and ii General inorganics chloride sulfate carbonate bicarbonate sodium potassium magnesium calcium and total anions and cations 6.2.3 Quarterly or Monthly Sampling Required Under Paragraphs I.G.1 or I.G.2 of the GWDP Any quarterly or monthly sampling required under paragraphs I.G or I.G.2 of the GWDP shall be in the wells and for the specific parameters required by those paragraphs of the GWDP as specified by the Mills RSO 6.2.4 Sampling Equipment for Groundwater Compliance Monitoring All equipment used for purging and sampling of groundwater which enters the well or may otherwise contact sampled groundwater shall be made of inert materials For the purposes of this QAP the following equipment definitions shall apply Dedicated Bailer bailer that is dedicated to be used at one specific well for the use of purging or sampling Said bailer well remain with and in side the well casing suspended and secured Non Dedicated Bailer bailer that is used for purging and sampling at one or more well Dedicated Pump pump that is dedicated to one specific well for the use of purging or sampling Said pump well remain with and in side the well Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 16 of 43 casing suspended and secured Non Dedicated Pump pump that is used for purging and sampling at one or more wells Groundwater compliance monitoring is accomplished by using the equipment or the equivalent listed below Bailer made of inert materials for purging DTG 7.3 page 7-10 If dedicated pump is installed in the well use the dedicated pump otherwise use 1.8 inch outside diameter air-driven sampling pump or equivalent 150 psi air compressor and ancillary equipment or equivalent Field parameters shall be measured using YSI-556 with Flow Cell Multi- Parameter Meter system or equivalent that allows continuous stream of water from the pump to the meter that enables measurements to be taken on real-time basis without exposing the water stream to the atmosphere The Field Parameter Meter measures the following parameters Water temperature ii Specific conductivity iiiTotal Dissolved Solids TDS iv Standard pH Redox potential Eh Field parameters are measured by using flow cell system that enables the measurements to be taken on real-time basis without exposing the water stream to the atmosphere Turbidity measuring instrument capable of determining if turbidity is NTU 0.45 micron high capacity disposable inline filters Field preservation chemicals as provided by the Analytical Laboratory Five gallon calibrated sample bucket Stopwatch Sealed sterile Polyethylene sample containers as provided by the Analytical Laboratory De-ionized water Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 17 of 43 One new unused clean disposable single check valve bailer or the equivalent for each well to be sampled for VOCs and If any portable non-dedicated pumps are used the following equipment supplies and solutions or the equivalent necessary for decontamination procedures 15 gallons of de-ionized water ii gallons of de-ionized water/nonphosphate detergent such as Liqui-Nox iii5 gallons of de-ionized water/11N03 solution mixture of approximately and 1/2 gallons of de-ionized water and gallon of HNO3 ivRubber gloves and Sterile sample containers from the Mill laboratory 6.2.5 Decontamination Procedure If portable non-dedicated pump is to be used prior to each sampling event at the beginning of each day during the sampling event and between each sampling location well decontaminate the portable non-dedicated sampling pump prior to its use for purging or sampling using the following procedure wash the pump probe probe sheath and other pump equipment that may come in contact with the sampling well inner casing or well water the Sampling Equipment with nonphosphate detergent rinse the Sampling Equipment with de-ionized water rinse the Sampling Equipment with dilute .1N hydrochloric or nitric acid and rinse the Sampling Equipment with de-ionized water The probe should then be placed in the decontaminated probe sheath or otherwise protected from contamination until used for purging or sampling All water produced during decontamination will be containerized Containerized water will be disposed of in Tailings Cell All sampling and purging equipment that has been decontaminated as per the foregoing procedure shall be covered with plastic sheet to shield such equipment from dust or other materials that may contaminate the equipment when traveling to and between purging/sampling locations 6.2.6 Pre -Purging Sampling Activities Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 18 of 43 If portable non-dedicated pump is to be used prior to commencing the events sampling activities check the pumping equipment to ensure that no air is leaking into the discharge line in order to prevent aeration of the sample If portable non-dedicated pump is to be used prior to each sampling event and at the beginning of each day during the sampling event decontaminate the sampling pump using the procedure set forth in Section 6.2.5 If portable non-dedicated pump is to be used after completion of decontamination and prior to the beginning of each day of each sampling event prepare one Equipment Rinsate Sample by following the procedure set forth in Section 4.3.2 and Prior to leaving the Mill office place the Trip Blanks into cooler that will preserve the VOC samples The Trip Blanks will accompany the groundwater samplers throughout the monitoring event 62.7 Well Purging/Measurement of Field Parameters Remove the well casing cap and measure and record depth to groundwater by following the procedures set out in paragraph 6.1.3 above Determine the casing volume in gallons where is colunm height of the water in the well calculated by subtracting the depth to groundwater in the well from the total depth of the well O.653h for casing volume and .367h for casing volume Record the casing volume on the Field Data Worksheet If the RSO has advised the field technician that immiscible contaminants i.e LNAPLs or DNAPLs are known to occur or could potentially occur in the subsurface at the location of the well follow the additional procedures to be provided by the RSO prior to well purging Purging Where Use of Pump is Effective See paragraph 6.2.7 below where bailer is required If portable non-dedicated pump is used ensure that it has been decontaminated in accordance with Section 6.2.5 since its last use in different well lower the pump into the well making sure to keep the pump at least five feet from the bottom of the well Be sure never to drop the pump into the well as this will cause degassing of the water upon impact Once the pump is lowered into the well or if the well has dedicated pump perform the following steps Commence pumping ii Determine pump flow rate by using stopwatch and calibrated bucket by measuring the number of seconds required to fill to the one-gallon mark Record this in the pumping rate section of the Field Data Worksheet Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 19 of 43 iiiCalculate the amount of time to evacuate two casing volumes ivEvacuate two casing volumes if possible by pumping for the length of time determined in paragraph iii Take measurements of field parameters pH specific conductance temperature redox potential and turbidity during well purging using the Field Parameter Meter and turbidity measuring instrument These measurements will be recorded on the Field Data Worksheet Purging is completed after two casing volumes have been removed and the field parameters pH temperature specific conductance redox potential Eh and turbidity have stabilized to within 10%over at least two consecutive measurements The groundwater in the well should recover to within at least 90%of the measured groundwater static surface before sampling In addition turbidity measurement in the water should be NTU prior to sampling DTG Well Development 6.7 page 6-48 unless the well is characterized by water that has higher turbidity flow-cell needs to be used for field parameters If the well is purged to dryness or is purged such that full recovery exceeds two hours the well should be sampled as soon as sufficient volume of groundwater is available to fill sample containers DTG Well Purging 7.2.4 page 7-9 vi If the well yields two casing volumes the individual performing the sampling should immediately proceed to Section 6.2.8 vii If the well cannot yield two casing volumes Evacuate the well to dryness and record the number of gallons evacuated on the Field Data Worksheet and Prior to sampling measure and record depth to groundwater on the Field Data Worksheet following the procedures set out in paragraph 6.1.3 above Purging Where Use of Pump is Not Effective For wells where pump is not effective for purging and/or sampling wells with shallow water columns i.e where the water colunm is less than five feet above the bottom of the well casing or the well takes over two days to recover from purging disposable bailer made of inert materials may be used If bailer is used the following procedure will be followed Use the sound level instrument to determine the water column and figure the amount of water that must be evacuated Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 20 of 43 ii Attach disposable bailer to rope and reel iiiLower the bailer into the well and listen for contact with the solution Once contact is made allow the bailer to gradually sink in the well being careful not to allow the bailer to come in contact with the bottom sediment iv After the bailer is full retrieve the bailer and discharge the water from the bailer into gallon buckets By doing this one can record the number of gallons purged vAfter the bailer is emptied lower the bailer back into the well and gain another sample as before This process will continue until the two casing volumes have been collected or until no more water can be retrieved When the process is finished for the well the bailer will be disposed of and viTake field measurements referred to in paragraph 6.2.7 above from the water in the buckets Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 21 of 43 6.2.8 Samples to be taken and order of taking samples For each sampling event unless sampling for specific parameter under the accelerated monitoring requirements of paragraphs I.G or I.G.2 of the GWDP as specified by the RSO the following separate samples shall be taken in the following order from each monitoring well VOCs sample containers 40 ml each bailer is used Nutrients ammonia nitrate and nitrite sample container 100 ml bailer is used Heavy metals sample container 250 ml filtered All other non-radiologics fluoride general inorganics TDS total cations and anions sample container 250 ml filtered and Gross alpha sample container 1000 ml filtered The sample collection containers and sample volumes for chloroform sampling are specified at Item of the Chloroform Investigation Monitoring Quality Assurance Program Appendix to this document The number of sample containers and the quantities taken shall be as set out above unless otherwise dictated by the Analytical Laboratory as specified by the RSO 6.2.9 Field Duplicate Samples One duplicate set of samples is required for each Batch of samples see Section 4.3.4 for definition of Batch EPA SW-846 Chapter Section 3.4.1 Field duplicate samples will be analyzed for the contaminants listed in Table of the GWDP The duplicate samples should be as near to split samples as reasonably practicable rather than merely taking second set of samples from the same well after the field samples have been taken from that well This can be accomplished by alternately partially filling the field sample containers and duplicate containers until both sets of containers are full Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 22 of 43 6.2.10 VOCs and Nutrient Sampling When sampling for VOCs and Nutrients the following procedure shall be followed Obtain specifically identified sample containers for the type of sample to be taken as provided by the Analytical Laboratory Add the quantity of specified preservative provided by the Analytical Laboratory to each sample container Sample the well using an unused clean disposable single check valve bailer or the equivalent Sample water should be transferred to sample containers in controlled manner that will minimize sample agitation and aeration In the case of VOC samples be sure that the sample containers are filled as full as possible with no airspace in the containers After each sample container is filled rinse the lid of the container with water and tighten lid onto container and Discard the bailer 6.2.11 Heavy Metals All Other Non-Radiologics and Gross Alpha Sampling When sampling for heavy metals all other non-radiologics and for gross alpha the following procedure shall be followed Obtain the specifically identified sample container for the type of sample to be taken as provided by the Analytical Laboratory Add the quantity of specified preservative provided by the Analytical Laboratory to each sample container When using pump to sample wells without shallow water columns i.e where the water column is more than five feet above the bottom of the well casing or the well takes less than two days to recover from purging Place new 0.45 micron filter on the sample tubing ii Pump the sample through the filtration unit and into the sample container at the same rate or lesser pumping rate than was used to purge the well Mill Groundwater Discharge Permit Date6-18-08 Revision Groundwater Monitoring Quality Assurance Plan QAP Page 23 of 43 iiiThe pump should be operated in continuous manner so that it does not produce samples that are aerated in the return tube or upon discharge ivRemove pump from the well and If using portable non-dedicated pump decontaminate pump as per Section 6.2.5 Do not place decontaminated pump on the ground or on other contaminated surfaces When using bailer to sample wells with shallow water columns i.e where the water column is less than five feet above the bottom of the well casing or the well takes over two days to recover from purging then one of the following two procedures will be used Filtering Water Samples at the Well Head The sample water is collected by use of inch Teflon bailer or the equivalent that is capable of being attached to hand-operated pressure pump or the equivalent Only disposable parts of the pressure pump may come into contact with the sample water Attach the pump to the disposable bailer and activate the pump in accordance with manufacturers instructions such that the sample water in the bailer is forced through clean un-used disposable 0.45 micron filter into clean previously unused sample container in maimer such that only disposable parts of the pump mechanism come into contact with the sample water Sample water should be transferred to sample containers in controlled manner that will minimize sample agitation and aeration Rinse lid of sample container with any remaining filtered water after container is filled with filtered water and tighten lid onto container Unless dedicated to particular well dispose of the bailer filter and any parts of the pump mechanism that come into contact with the sample water and No rinsate sample is needed because everything that comes into contact with the sample water is clean and unused prior to sampling and disposed of after sampling the well ii Filtering Water Samples at the Mill Laboratory new clean gallon raw sample container must be used to capture waters needed to be filtered The sample water is collected by use of inch Teflon bailer or the equivalent and then discharged into the gallon container After all the samples have been collected for the well and placed in the field sample container which contains blue ice to keep the samples at Mill Groundwater Discharge Permit Date6 18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 24 of 43 the required temperature the sampler will then proceed directly back to the Mill laboratory and perform the filtration on the sample Unless the bailer is dedicated to particular well it will be disposed of after completion of sampling in the well Upon arrival at the administration building all other samples from the well that do not require filtration will be placed in the sample holding refrigerator in the locked sample storage room The sampler will then carry the sample that requires filtration in the cooler to the laboratory and set up the equipment to be used for filtration of the sample The equipment needed for this process consists of 2000 ml glass filter flask 250 ml bell and glass frit for micro-filtration 0.45 micron filter setup 0.45 micron filter paper The glass filter flask and micro-filtration equipment will go through cleaning and rinsate process The processing will included the following Rinsing of the equipment using DI water Rinsing the equipment with mixture of DI water and HNO3 Rinsing the equipment with mixture of DI water and Liqui Nox soap Rinsing the equipment with DI water Finally the collection of the final process rinsate solutions are placed in the sample collection cooler and labeled as filtration equipment rinsate sample The flask is attached to the vacuum system in the laboratory using Tygon Vacuum Tubing or the equivalent The micro-filtrationsystem is then inserted into the filter flask 0.45 micron filter paper is then placed between the bell and the glass frit and clamped in place to prevent solution leaking out The water sample is then slowly added into the bell and the vacuum is turned on As the vacuum draws the water through the filter paper additional solutions are added until the flask is full When the flask is full the vacuum is turned off and the bell is unclamped from the fit The Tygon tubing is then removed from the flask The glass frit is then pulled out of the flask The filtered solutions are then poured into the various remaining sample collection bottles Sample water should be transferred to sample containers in controlled manner that will minimize sample agitation and aeration Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 25 of 43 Rinse lid of sample container with any remaining filtered water after container is filled with filtered water and tighten lid onto container If additional filtered water is required to complete the sample requirements the sample bottles will be placed in the field cooler along with the raw sample and housed there while the filtration system is being hooked back up and the procedures set out in paragraphs Ito above are repeated until sufficient sample water has been filtered to fill up the required number of sample bottles After all samples from the well that require filtration have been filtered in accordance with the foregoing procedure and placed in the proper sample bottles the remainder of the raw sample is then discharged into the laboratory sink which runs to tails and The filtered samples are then transported to the locked sample storage room and placed in the sample holding refrigerator The time lapse between the actual sampling times to the completion of the filtration process is approximately hour Samples are always in the field sample container except for when the raw sample is pulled from the cooler and poured in the bell on the filter flask 6.2.12 Procedures to Follow After Sampling In each case once sample is taken identify and label the sample container with Sample locationlfacility Date and time of sample Any preservation method utilized Samplers initials Filtered or unfiltered Parameters requested to be analyzed Place each sample in an ice-packed cooler immediately upon taking the sample and labeling the sample container Replace the casing cap on the well Lock the well Before leaving the sampling location thoroughly document the sampling event on the Field Data Worksheet by recording the items required in paragraph 7.1 and Upon returning to the office the samples must be stored in refrigerator at at no more than These samples shall be received by the Analytical Laboratory at no more than Samples will then be re-packed in the plastic ice-packed Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 26 of 43 cooler and transported via these sealed plastic containers by postal contract services to the Analytical Laboratory SAMPLE DOCUMENTATION TRACKING AND RECORD KEEPING 7.1 Field Data Worksheets Documentation of observations and data from sampling provide important information about the sampling process and provide permanent record for sampling activities All observations and field sampling data will be recorded in waterproof ink on the Field Data Worksheets which will be maintained on file at the Mill The Field Data Worksheets will contain the following information Name of the site/facility description of sampling event location of sample well name samplers names and signatures dates and times of well purging and sample collection type of well purging equipment used pump or bailer previous well sampled during the sampling event well depth depth to groundwater before purging and sampling results of in-field measurements pH specific conductance water temperature redox potential Eh measurements turbidity measurements calculated well casing volume volume of water purged before sampling volume of water purged when field parameters are measured type and condition of well pump description of samples taken sample handling including filtration and preservation volume of water collected for analysis types of sample containers and preservatives weather conditions and external air temperature name of certified Analytical Laboratory The Field Data Worksheets will also contain detailed notes describing any other significant factors during the sampling event including as applicable condition of the well cap and lock water appearance color odor clarity presence of debris or solids any variances from this Procedure and any other relevant feature or condition An example of form of Field Data Worksheet that incorporates this information is attached as Attachment Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 27 of 43 7.2 Chain-Of-Custody and Analytical Request Record Chain-of-Custody and Analytical Request Record form the COC Form provided by the Analytical Laboratory will accompany the samples being shipped to the Analytical Laboratory An example of the Analytical Laboratorys Chain of Custody Form is attached as Attachment If the Chain of Custody Form changes at any time the Company shall provide copy of the new or revised Chain of Custody Form to the Executive Secretary and substitute the new form for the old form in Attachment Standard Chain-of-Custody protocol is initiated for each sample set COC Form is to be completed for each set of samples collected in shipping container cooler and is to include the following samplers name company name date and time of collection sample type e.g water sample location number of sample containers in the shipping container analyses requested signatures of persons involved in the chain of possession internal temperatures of the shipping container when opened at the laboratory remarks section to identify potential hazards or to relay other information to the Analytical Laboratory Chain-of-Custody reports will be placed inside re-sealable bag and taped to the inside lid Custody seals will be placed on the outside of each cooler The person shipping the samples to the Analytical Laboratory will sign the COC Form document shipment method and send the original and the second copy of the COC Form with the samples Upon receipt of the samples the person receiving the samples will sign the COC Form and return the second copy to the Mills RSO Copies of the COC Forms and other relevant documentation will be retained at the Mill Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 28 of 43 7.3 Record Keeping The Field Data Worksheets are retained at the Mill Original Certificates of Analysis from the Analytical Laboratory showing the laboratory analytical results for the water samples are maintained at the Mill Once all the data for the quarter all wells sampled during the quarter is completed key data from the Field Data Worksheets and from the Certificates of Analysis are typed into computer file Key data entered into the computer file will include well I.D sample date depth to groundwater average field data and all laboratory analytical data These computer files are maintained at the Mill ANALYTICAL PROCEDURES AND QA/QC Analytical Laboratory QA provides means for establishing consistency in the performance of analytical procedures and assuring adherence to analytical methods utilized Analytical Laboratory QC programs include traceability of measurements to independent reference materials and internal controls 8.1 Analytical Quality Control Analytical QA/QC will be governed by the QA/QC program of the Analytical Laboratory In choosing and retaining the Analytical Laboratory DUSA shall ensure that the Analytical Laboratory is certified by the State of Utah and by NELAP and/or NAVLAP is capable of performing the analytical procedures specified in Section 8.2 and that the QA/QC program of the Analytical Laboratory includes the spikes blanks and duplicates described in Section 8.1.2 1.2 Spikes Blanks and Duplicates Analytical Laboratory QC samples will assess the accuracy and precision of the analyses The following describes the type of QC samples that will be used by the Analytical Laboratory to assess the quality of the data The following procedures shall be performed at least once with each Batch of samples Duplicate Spike Matrix Spike split/spiked field sample shall be analyzed with every analytical batch Analytes stipulated by the analytical method by applicable regulations or by other specific requirements must be spiked into the sample Selection of the sample to be spiked and/or split depends on the information required and the variety of conditions within typical matrix The duplicate spike matrix spike sample serves as check evaluating the effect of the sample matrix on the accuracy of analysis Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 29 of 43 Blanks Each batch shall be accompanied by reagent blank The reagent blank shall be carried through the entire analytical procedure Contamination detected in analysis of reagent blanks will be used to evaluate any Analytical Laboratory contamination of environmental samples which may have occurred Field Samples/Surrogate Compounds Every blank standard and environmental sample including matrix spike/matrix duplicate samples shall be spiked with surrogate compounds prior to purging or extraction Surrogates are organic compounds which are similar to analytes of interest in chemical composition extraction and chromatography but which are not normally found in environmental samples Surrogates shall be spiked into samples according to the appropriate organic analytical methods Check Sample Each analytical batch shall contain number of check samples For each method the Analytical Laboratory will normally analyze the following check samples or their equivalents method blank laboratory control spike matrix spike and matrix spike duplicate or the equivalent with relative percent difference reported 8.2 Analytical Laboratory Procedures The analytical procedures to be used by the Analytical Laboratory will be as specified in Table or as otherwise authorized by the Executive Secretary With respect to Chloroform Investigation sampling the analytical procedures for parameters monitored under that program are specified at Item of the Chloroform Investigation Monitoring Quality Assurance Program Appendix to this document Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 30 of 43 Table Contaminant Analytical Methods to be Used Reporting Limit1 Maximum Holding Times Sample Preservation Requirements Sample Temperature Requirements Nutrients Ammonia as A4500- NH3 0.05 mg/L 28 days H2S04 to pH2 4C Nitrate Nitrite as E353.2 0.1 mg/L 28 days H2S04 to pH2 4C Heavy Metals Arsenic E200.8 jig/L months HNO3 to pHc2 None Beryllium E200.8 0.50 tgfL months HNO3 to p112 None Cadmium E200.8 0.50 g/L months HNO3 to pH2 None Chromium E200.8 25 pg/L months 11N03 to p112 None Cobalt E200.8 10 j.ig/L months HNO3 to p112 None Copper E200.8 10 g/L months HNO3 to pH2 None Iron E200.7 30 jigIL months 11N03 to pH2 None Lead E200.8 1.0 pg/L months 11N03 to pH2 None Manganese E200.8 10 jiglL months HNO3 to pH2 None Mercury E200.8 0.50 jtgfL 28 days HNO3 to p112 None Molybdenum E200.8 10 jig/L months FINO3 to p112 None Nickel E200.8 20 pg/L months 11N03 to pH2 None Selenium E200.8 ig/L months 11N03 to p112 None Silver E200.8 10 g/L months HNO3 to pH2 None Thallium E200.8 0.50 igIL months HNO3 to pH2 None Tin E200.8 100 pg/L months 11N03 to pH2 None Uranium E200.8 0.30 pgIL months HNO3 to pH2 None Vanadium E200.8 15 pg/L months 11N03 to p112 None Zinc E200.8 10 jig/L months 11N03 to pH2 None Radiologics Gross Alpha E900.1 1.0 pCifL months HNO3 to pH2 None Volatile Organic Compounds Acetone 5W8260B 20 pg/L 14 days HC1 to pH2 4C Benzene 5W8260B 1.0 pgIL 14 days 11Cl to pH2 4C 2-Butanone MEK 5W8260B 20 pg/L 14 days HCl to pH2 4C Mill Groundwater Discharge Permit Groundwater Monitoring Quality Assurance Plan QAP Date6-18-08 Revision-3 Page 31 of 43 Others Field pH S.U Fluoride TDS A45 00-H A4500-F A2540 0.01 s.u Immediate None None Contaminant Analytical Methods to be Used Reporting Limit1 Maximum Holding Times Sample Preservation Requirements Sample Temperature Requirements Carbon Tetrachioride SW8260B 1.0 g/L 14 days HC1 to pH2 4C Chloroform SW8260B 1.0 jig/L 14 days HC1 to pHc2 4C Chioromethane SW8260B 1.0 pg/L 14 days HC1 to pFR2 4C Dichioromethane Methylene Chloride SW8260B 1.0 pgfL 14 days HC1 to pH2 4C Naphthalene SW8260B 1.0 g/L 14 days HC1 to pH2 4C Tetrahydrofuran SW8260B 1.0 pg/L 14 days HC1 to pH2 4C Toluene SW8260B 1.0 pgIL 14 days HC1 to pHc2 4C Xylenes total SW8260B 1.0 ig/L 14 days HC1 to pHc2 4C General Inorganics Chloride A4500-Cl mgIL 28 days None None Sulfate A4500- 504E mgIL 28 days None 4C Carbonate as C03 A2320 mg/L 14 days None 4C Bicarbonate as HCO3 A2320 mgIL 14 days None 4C Sodium E200.7 0.5 mg/L months 11N03 to pHc2 None Potassium E200.7 0.5 mgfL months HNO3 to pHc2 None Magnesium E200.7 0.5 mg/L months HNO3 to pH2 None Calcium E200.7 0.5 mg/L months HNO3 to pH2 None The Analytical Laboratory will be required to meet the reporting limits RLs in the foregoing Table unless the RI must be increased due to sample matrix interference Le-due to dilution gain in which case the increased EL will be used or unless otherwise approved by the Executive Secretary 0.1 mg/L lOmg/L 28 days days None None None 4C INTERNAL QUALITY CONTROL CHECKS Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 32 of 43 Internal quality control checks are inherent in this Plan The QA Manager will monitor the performance of the Sample and QC Monitors and to the extent practicable the Analysis Monitor to ensure that they are following this Plan In addition either the QA Manager or Sampling and QC Monitor will review and validate the analytical data generated by the Analytical Laboratory to ensure that it meets the DQOs established by this Plant Finally periodic system and performance audits will be performed as detailed in Section 12 below 9.1 Field QC Cheek Procedures The QA Manager will perform the following QAJQC analysis of field procedures 9.1.1 Review of Compliance With the Procedures Contained in this Plan Observation of technician performance is monitored by the QA Manager on periodic basis to ensure compliance with this Plan 9.1.2 Analyte Completeness Review The QA Manager will review all Analytical Results to confirm that the analytical results are complete i.e there is an analytical result for each required constituent in each well The QA Manager shall also identify and report all instances of non-compliance and non conformance see Part I.E .a of the Permit Executive Secretary approval will be required for any completeness prior to QA/QC analysis less than 100 percent Non-conformance will be defined as failure to provide field parameter results and analytical results for each parameter and for each well required in Sections 6.2.2 and 6.2.3 for the sampling event without prior written Executive Secretary approval 9.1.3 Blank Comparisons Trip blanks and equipment rinsate samples will be compared with original sample results Non-conformance conditions will exist when contaminant levels in the blanks/sampless are within an order of magnitude of the original sample result TEGD Field QA/QC Program page 119 9.1.4 Duplicate Sample Comparisons The following analyses will be performed on duplicate field samples Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 33 of 43 Relative Percent Difference RPDs will be calculated in comparisons of duplicate and original field sample results Non-conformance will exist when the RPD 20%unless the measured activities are less than times the required detection limit Standard Methods 1998 EPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review February 1994 9240.1-05-0 25 Radiologics Counting Error Term All gross alpha analyses shall be reported with an error term All gross alpha analysis reported with an activity equal to or greater than the GWCL shall have counting variance that is equal to or less that 20%of trhe reported activity concentration An error term may be greater than 20%of the reported activity concentration when the sum of the activity concentration and error term is less than or equal to the GWCL Radiologics Duplicate Samples Comparability of results between the original and duplicate radiologic samples will be evaluated by determining compliance with the following formula A-B /sa2sb22 Where the first duplicate measurement the second duplicate measurement sa2 the uncertainty of the first measurement squared sb2 the uncertainty of the second measurement squared Non-conformance exists when the foregoing equation is EPA Manual for the Certification of Laboratories Analyzing Drinking Water Criteria and Procedures Quality Assurance January 2005 EPA 815-R-05-004 VI-9 If the QA Managers review finds any situations of non-conformance see Section 10 9.2 Analytical Laboratory QA Reviews Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 34 of 43 Full validation will include recalculation of raw data for minimum of one or more analytes for ten percent of the samples analyzed The remaining 90%of all data will undergo QC review which will include validating holding times and QC samples Overall data assessment will be part of the validation process as well The Analysis Monitor or data validation specialist will evaluate the quality of the data based on SW-846 the applicable portions of NRC guide 4.14 and on analytical methods used The reviewer will check the following sample preparation information is correct and complete analysis information is correct and complete appropriate Analytical Laboratory procedures are followed analytical results are correct and complete QC samples are within established control limits blanks are within QC limits special sample preparation and analytical requirements have been met and documentation is complete The Analytical Laboratory will prepare and retain full QC and analytical documentation The Analytical Laboratory will report the data as group of one batch or less along with the QA/QC data The Analytical Laboratory will provide the following information cover sheet listing samples included in report with narrative results of compounds identified and quantified and reporting limits for all analytes Also to be included are the QA/QC analytical results 9.3 QA Manager Review of Analytical Laboratory Results and Procedures The QA Manager shall perform the following QA reviews relating to Analytical Laboratory procedures Reporting Limit RL Comparisons The QA Manager shall confirm that all reporting limits used by the Analytical Laboratory are in conformance with the reporting limits set out on Table Non-conformance shall be defined as reporting limit that violates these provisions unless the reporting limit must be increased due to sample matrix interference i.e due to dilution gain or reporting limit that exceeds the respective GWQS listed in Table of the GWDP Laboratory Methods Review The QA Manager shall confirm that the analytical methods used by the Analytical Laboratory are those specified in Table unless otherwise approved by the Executive Secretary Non-conformance shall be defined when the Analytical Laboratory uses analytical methods not listed in Table and not otherwise approved by the Executive Secretary Holding Time Examination Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 35 of 43 The QA Manager will review the analytical reports to verify that the holding time for each contaminant was not exceeded Non-conformance shall be defined when the holding time is exceeded Sample Temperature Examination The QA Manager shall review the analytical reports to verify that the samples were received by the Analytical Laboratory at temperature no greater than the approved temperature listed in Table Non-conformance shall be defined when the sample temperature is exceeded 9.4 Analytical Data All QA/QC data and records required by the Analytical Laboratorys QA/QC program shall be retained by the Analytical Laboratory and shall be made available to DUSA as requested Analytical data submitted by the Analytical Laboratory should contain the date/time the sample was collected the date/time the sample was received by the Analytical Laboratory the date/time the sample was extracted if applicable and the date/time the sample was analyzed All out-of-compliance results will be logged by the Analysis Monitor with corrective actions described as well as the results of the corrective actions taken All raw and reduced data will be stored according to the Analytical Laboratorys record keeping procedures and QA program All Analytical Laboratory procedures and records will be available for on-site inspection at any time during the course of investigation If re-runs occur with increasing frequency the Analysis Monitor and the Mills QA Manager will be consulted to establish more appropriate analytical approaches for problem samples 10 CORRECTIVE ACTION 10.1 When Corrective Action is Required The Sampling and QC Monitors and Analytical Laboratory are responsible for following procedures in accordance with this Plan Corrective action should be taken for any procedure deficiencies or deviations noted in this Plan All deviations from field sampling procedures will be noted on the Field Data Worksheets or other applicable records Any QA/QC problems that arise will be brought to the immediate attention of the QA Manager Analytical Laboratory deviations will be recorded by the Analysis Monitor in logbook as well When non-conformance is identified DUSA shall Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 36 of 43 When non-conformance occurs as specified in Sections 9.1.3 9.1.4 or 9.3 the data shall be qualified to denote the problem In addition DUSA shall determine the root cause and provide specific steps to resolve problemss in accordance with the procedure set forth in Section 10.2 Any non-conformance with QAP requirements in given quarterly ground water monitoring period will be corrected and reported to the Executive Secretary on or before submittal of the next quarterly ground water monitoring report When sample is lost sample container broken or the sample or analyte was omitted resample within 10 days of discovery and analyze again in compliance with all requirements of this Plan The results for this samples should be included in the same quarterly monitoring report with other samples collected for the same sampling event and For any other material deviation from this Plan the procedure set forth in Section 10.2 shall be followed 10.2 Procedure for Corrective Action The need for corrective action for non-conformance with the requirements of this Plan may be identified by system or performance audits or by standard QA/QC procedures The procedures to be followed if the need for corrective action is identified are as follows Identification and definition of the problem Assignment of responsibility for investigating the problem Investigation and determination of the cause of the problem Determination of corrective action to eliminate the problem Assigning and accepting responsibility for implementing the corrective action Implementing the corrective action and evaluating its effectiveness and Verifying that the corrective action has eliminated the problem The QA Manager shall ensure that these steps are taken and that the problem which led to the corrective action has been resolved memorandum explaining the steps outlined above will be placed in the applicable monitoring files and the Mill Central Files and the corrective action will be documented in Report prepared in accordance with Section 11 11 REPORTING As required under paragraph I.F of the GWDP the Mill will send groundwater monitoring report to the Executive Secretary on quarterly basis Both the Routine Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 37 of 43 Groundwater Monitoring Reports pertinent to Part I.F of the Permit and Chloroform Investigation Reports shall be submitted according to the following schedule Quarter Period Due Date First January March June Second April June September Third July September December Fourth October December March The Routine Groundwater Monitoring Reports pertinent to Part I.F of the Permit will include the following information Description of monitor wells sampled Description of sampling methodology equipment an decontamination procedures to the extent they differ from those described in this Plan summary data table of historic groundwater levels for each monitor well and piezometer summary data table showing the results of the sampling event listing all wells and the analytical results for all constituents and identifying any constituents that are subject to accelerated monitoring in any particular wells pursuant to Part I.G of the GWDP or are out of compliance in any particular wells pursuant to Part I.G.2 of the GWDP Copies of Field Data Worksheets Copies of Analytical Laboratory results Copies of Chain of Custody Forms Water Table Contour Map showing groundwater elevation data for the quarter will be contemporaneous for all wells on site not to exceed maximum time difference of five calendar days Evaluation of groundwater levels gradients and flow directions Quality assurance evaluation and data validation description see Section for further details All non-conformance with this Plan and all corrective actions taken Recommendations and Conclusions With respect to the chloroform investigation reporting requirements these are specified at Item of the Chloroform Investigation Monitoring Quality Assurance Program Appendix to this document In addition an electronic copy of all analytical results will be transmitted to the Executive Secretary in comma separated values CSV format or as otherwise advised by the Executive Secretary Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 38 of 43 Further reporting may be required as result of accelerated monitoring under paragraphs I.G and LG.2 of the GWDP The frequency and content of these reports will he defined by DUSA corporate management working with the Executive Secretary 12 SYSTEM AND PERFORMANCE AUDITS 12.1 QA Manager to Perform System Audits and Performance Audits DUSA shall perform such system audits and performance audits as it considers necessary in order to ensure that data of known and defensible quality are produced during sampling program The frequency and timing of system and performance audits shall be as determined by DUSA 12.2 System Audits System audits are qualitative evaluations of all components of field and Analytical Laboratory QC measurement systems They determine if the measurement systems are being used appropriately System audits will review field and Analytical Laboratory operations including sampling equipment laboratory equipment sampling procedures and equipment calibrations to evaluate the effectiveness of the QA program and to identify any weakness that may exist The audits may be carried out before all systems are operational during the program or after the completion of the program Such audits typically involve comparison of the activities required under this Plan with those actually scheduled or performed special type of systems audit is the data management audit This audit addresses only data collection and management activities 12.3 Performance Audits The performance audit is quantitative evaluation of the measurement systems of program It requires testing the measurement systems with samples of known composition or behavior to evaluate precision and accuracy With respect to performance audits of the analytical process either blind performance evaluation samples will be submitted to the Analytical Laboratory for analysis or the auditor will request that it provide results of the blind studies that the Analytical Laboratory must provide to its NELAP and/or NAVLAP accreditation agency on an annual basis The performance audit is carried out without the knowledge of the analysts to the extent practicable Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Ground water Monitoring Quality Assurance Plan QAP Page 39 of 43 12.4 Follow-Up Actions Response to the system audits and performance audits is required when deviations are found and corrective action is required Where corrective action is required the steps set out in Section 10.2 will be followed 12.5 Audit Records Audit records for all audits conducted will be retained in Mill Central Files These records will contain audit reports written records of completion for corrective actions and any other documents associated with the audits supporting audit findings or corrective actions 13 PREVENTIVE MAINTENANCE Preventive maintenance concerns the proper maintenance and care of field and laboratory instruments Preventive maintenance helps ensure that monitoring data generated will be of sufficient quality to meet QA objectives Both field and laboratory instruments have set maintenance schedule to ensure proper functioning of the instruments Field instruments will be maintained as per the manufacturers specifications and established sampling practice Field instruments will be checked and calibrated prior to use in accordance with Section Batteries will be charged and checked daily when these instruments are in use All equipment out of service will be immediately replaced Field instruments will be protected from adverse weather conditions during sampling activities Instruments will be stored properly at the end of each working day Calibration and maintenance problems encountered will be recorded in the Field Data Worksheets or logbook The Analytical Laboratory is responsible for the maintenance and calibration of its instruments in accordance with Analytical Laboratory procedures and as required in order to maintain its NELAP and/or NAVLAP certifications Preventive maintenance will be performed on scheduled basis to minimize downtime and the potential interruption of analytical work 14 QUALITY ASSURANCE REPORTS TO MANAGEMENT 14.1 Ongoing QA/QC Reporting The following reporting activities shall be undertaken on regular basis The Sample and QC Monitors shall report to the QA Manager regularly regarding progress of the applicable sampling program The Sample and QC Monitors will also brief the QA Manager on any QA/QC issues associated with such sampling activities Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 40 of 43 The Analytical Laboratory shall maintain detailed procedures for laboratory record keeping Each data set report submitted to the Mills QA Manager or his staff will identify the analytical methods performed and all QA/QC measures not within the established control limits Any QA/QC problems will be brought to the QA Managers attention as soon as possible and After sampling has been completed and final analyses are completed and reviewed brief data evaluation summary report will be prepared by the Analytical Laboratory for review by the QA Manager by Sampling and QC Monitor or by such other qualified person as may be designated by the QA Manager The report will be prepared in accordance with NELAP and/or NAVLAP requirements and will summarize the data validation efforts and provide an evaluation of the data quality 14.2 Periodic Reporting to Management The QA Manager shall present report to DUSAs ALARA Committee at least once per calendar year on the performance of the measurement system and the data quality These reports shall include Periodic assessment of measurement quality indicators i.e data accuracy precision and completeness Results of any performance audits including any corrective actions Results of any system audits including any corrective actions and Significant QA problems and recommended solutions 15 AMENDMENT This Plan may be amended from time to time by DUSA only with the approval of the Executive Secretary Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 41 of 43 16 REFERENCES 16.1 United States Environmental Protection Agency November 2004 Test Methods for Evaluating Solid Waste EPA SW-846 16.2 United States Environmental Protection Agency September 1986 RCRA Ground Water Monitoring Technical Enforcement Guidance Document TEGD Office of Solid Waste and Emergency Response OSWER-9950.1 16.3 United States Environmental Protection Agency November 1992 RCRA Ground water Monitoring Draft Technical Guidance DTG Office of Solid Waste 16.4 Standard Methods for the Examination of Water and Wastewater 20th Edition 1998 American Public Health Association American Water Works Association Water Environment Federation Washington D.C 1-7 Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 42 of 43 ATTACHMENT WHITE MESA URANIUM MILL FIELD DATA WORKSHEET FOR GROUND WATER Description of Sampling Event______________________________________________________ Sampler Location well name_______________________Name and initials__________________________ Date and Time for Purging _______________and Sampling if different_____________________ Well Purging Equip Used pump or _bailer Well Pump if other than Bennet___________ Sampling Event________________________Prey Well Sampled in Sampling Event_______ pH Buffer 7.0 pH Buffer 4.0 Specific Conductance _________uMHOS/cm Well Depth Depth to Water Before Purging Casing Volume Well .653h Well .367h Conductance avg pH of Water avg________________________ Well Water Temp avg Redox Potential Eh Turbidity Weather Cond.___________________Ext Amb Temp.prior to sampling event__________ Time__________Gal Purged___________Time__________Gal Purged Conductance_________________________Conductance____________________________ pH pH__________________________________ Temperature Temperature Redox Potential Eh__________________Redox Potential Eh_____________________ Turbidity___________________________Turbidity______________________________ Time__________Gal Purged___________Time___________Gal Purged Conductance_________________________Conductance____________________________ pH_______________________________pH__________________________________ Temperature Temperature Redox Potential Eh___________________Redox Potential Eh______________________ Turbidity___________________________Turbidity______________________________ Mill Groundwater Discharge Permit Date6-18-08 Revision-3 Groundwater Monitoring Quality Assurance Plan QAP Page 43 of 43 Volume of Water Purged When Field Parameters are Measured____________________________ Pumping Rate Calculation Flow Rate in gpm Time to evacuate two casing volumes 2V 5/60 _________________T2V/Q _____________________ Number of casing volumes evacuated if other than two___________________________________ If well evacuated to dryness number of gallons evacuated________________________________ Name of Certified Analytical Laboratory if Other Than Energy Labs_________________________ Type of Sample Sample Taken circle Sample Volume indicate if other than as specified below Filtered circle Preservative Added circle VOCs 3x40m1 HCL Nutrients 100 ml H2S04 Heavy Metals 250 ml HNO3 All Other Non- Radiologics 250 ml No Preservative Added Gross Alpha 1000 ml H2S04 Other specify Sample volume If preservative is used Specify Type and Quantity of Preservative Comments 09/08 Revision Denison 1.3 Cell 4A BAT Monitoring Operations and Maintenance Plan Introduction Construction of Cell 4A was authorized by the Utah Department of Environmental Quality Division of Radiation Control DRC on June 25 2007 The construction authorization provided that Cell 4A shall not be in operation until after BAT Monitoring Operations and Maintenance Plan is submitted for Executive Secretary review and approval The Plan shall include requirements in Part F.3 of the Groundwater Discharge Permit No UGW370004 GWDP and full fill the requirements of Parts I.D.6 I.E.8 and I.F.8 of the GWDP Cell Desi2n Tailings Cell 4A consists of the following major elements Dikes consisting of earthen embankments of compacted soil constructed between 1989-1990 and composed of four dikes each including 15-foot wide road at the top minimum On the north east and south margins these dikes have slopes of 3H to lv The west dike has interior slope of 2H to lv Width of these dikes varies each has minimum crest width of at least 15 feet to support an access road Base width also varies from 89-feet on the east dike with no exterior embankment to 211-feet at the west dike Foundation including subgrade soils over bedrock materials Foundation preparation included excavation and removal of contaminated soils compaction of imported soils to maximum dry density of 90%Floor of Cell 4A has an average slope of 1%that grades from the northeast to the southwest corners Tailings Capacity the floor and inside slopes of Cell 4A encompass about 40 acres and have maximum capacity of about 1.6 million cubic yards of tailings material storage as measured below the required 3-foot freeboard Liner and Leak Detection Systems including the following layers in descending order Primary Flexible Membrane Liner FML consisting of impermeable 60 mil high density polyethylene HDPE membrane that extends across both the entire cell floor and the inside side-slopes and is anchored in trench at the top of the dikes on all four sides The primary FML will be in direct physical contact with the tailings material over most of the Cell 4A floor area In other locations the primary FML will be in contact with the slimes drain collection system discussed below Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 Leak Detection System includes permeable HDPE geonet fabric that extends across the entire area under the primary FML in Cell 4A and drains to leak detection sump in the southwest corner Access to the leak detection sump is via an 18-inch inside diameter ID PVC pipe placed down the inside slope located between the primary and secondary FML liners At its base this pipe will be surrounded with gravel filter set in the leak detection sump having dimensions of 10 feet by 10 feet by feet deep In turn the gravel filter layer will be enclosed in an envelope of geotextile fabric The purpose of both the gravel and geotextile fabric is to serve as filter Secondary FML consisting of an impermeable 60-mil HDPE membrane found immediately below the leak detection geonet Said FML also extends across the entire Cell 4A floor up the inside side-slopes and is also anchored in trench at the top of all four dikes Geosynthetic Clay Liner consisting of manufactured geosynthetic clay liner GCL composed of 0.2-inch of low permeability bentonite clay centered and stitched between two layers of geotextile Prior to disposal of any wastewater in Cell 4A the Permittee shall demonstrate that the GCL has achieved moisture content of at least 50%by weight This item is revised requirement per DRC letter to DUSA dated September 28 2007 Slimes Drain Collection System including two-part system of strip drains and perforated collection pipes both installed immediately above the primary FML as follows Horizontal Strip Drain System is installed in herringbone pattern across the floor of Cell 4A that drain to backbone of perforated collection pipes These strip drains are made of prefabricated two-part geo-composite drain material solid polymer drainage strip core surrounded by an envelope of non-woven geotextile filter fabric The strip drains are placed immediately over the primary FML on 50-foot centers where they conduct fluids downgradient in southwesterly direction to physical and hydraulic connection to the perforated slimes drain collection pipe series of continuous sand bags filled with filter sand cover the strip drains The sand bags are composed of woven polyester fabric filled with well graded filter sand to protect the drainage system from plugging Horizontal Slimes Drain Collection Pipe System includes backbone piping system of 4-inch ID Schedule 40 perforated PVC slimes drain collection SDC pipe found at the downgradient end of the strip drain lines This pipe is in turn overlain by berm of gravel that runs the entire diagonal length of the cell surrounded by geotextile fabric cushion in immediate contact with the primary FML In turn the gravel is overlain Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 by layer of non-woven geotextile to serve as an additional filter material This perforated collection pipe serves as the backbone to the slimes drain system and runs from the far northeast corner downhill to the far southwest corner of Cell 4A where it joins the slimes drain access pipe Slimes Drain Access Pipe consisting of an 18-inch ID Schedule 40 PVC pipe placed down the inside slope of Cell 4A at the southwest corner above the primary FML Said pipe then merges with another horizontal pipe of equivalent diameter and material where it is enveloped by gravel and woven geotextile that serves as cushion to protect the primary FML reducer connects the horizontal 18-inch pipe with the 4-inch SDC pipe At some fliture time pump will be set in this 18-inch pipe and used to remove tailings wastewaters for purposes of de-watering the tailings cell Dike Splash Pads minimum of eight 10-foot wide splash pads are installed on the interior dike slopes to protect the primary FML from abrasion and scouring by tailings sluny These pads will consist of an extra layer of 60 mil HDPE membrane that will be placed down the inside slope of Cell 4A from the top of the dike and down the inside slope The pads on the north side of the Cell will extend to point 5-feet beyond the toe of the slope to protect the liner bottom during initial startup of the Cell The exact location of the splash pads is detailed on the As-Built Plans and Specifications Emergency Spillway concrete lined spillway constructed near the western corner of the north dike to allow emergency runoff from Cell into Cell 4A This spillway will be limited to 6-inch reinforced concrete slab set directly over the primary FML in 4-foot deep trapezoidal channel No other spillway or overflow strncture will be constructed at Cell 4A All stormwater runoff and tailings wastewaters not retained in Cells and will be managed and contained in Cell 4A including the Probable Maximum Precipitation and flood event Cell Operation Solution Discharge Cell 4A will initially be used for storage and evaporation of process solutions from the Mill operations These process solutions will be from the uraniumlvanadium solvent extraction circuit or transferred from Cell evaporation pond or the free water surface from Cell The solution will be pumped to Cell 4A through inch or inch diameter HDPE pipelines The initial solution discharge will be in the southwest corner of the Cell The discharge pipe will be routed down the Splash Pad provided in the corner of the Cell to protect the pipeline running from the solution reclaim barge The solution will be discharged in the bottom of the Cell away from any sand bags or other installation on the top of the FML Building the solution pool from the low end of Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 the Cell will allow the solution pool to gradually rise around the slimes drain strips eliminating any damage to the strip drains or the sand bag cover due to solution flowing past the drainage strips The solution will eventually be discharged along the dike between Cell and Cell 4A utilizing the Splash Pads described above The subsequent discharge of process solutions will be near the floor of the pond through discharge header designed to discharge through multiple points thereby reducing the potential to damage the Splash Pads or the Slimes Drain system At no time will the solution be discharged into less than feet of solution As the cell begin to fill with solution the discharge point will be pull back up the Splash Pad and allowed to continue discharging at or near the solution level Initial Solids Discharge Once Cell 4A is needed for storage for tailings solids the slurry discharge from No CCD thickener will be pumped to the cell through inch or inch diameter HDPE pipelines The pipelines will be routed along the dike between Cell and Cell 4A with discharge valves and drop pipes extending down the Splash Pads to the solution level One or all of the discharge points can be used depending on operational considerations Solids will settle into cone or mound of material under the solution level with the courser fraction sealing out closer to the discharge point The initial discharge locations are shown on Figure Figure illustrates the general location of the solution and slurry discharge pipelines and control valve locations The valves are or stainless steel knife-gate valves The initial discharge of slurry will be at or near the toe of the Cell slope and then gradually moved up the slope continuing to discharge at or near the water surface This is illustrated in Section A-A on Figure Because of the depth of Cell 4A each of the discharge points will be utilized for an extended period of time before the cone of material is above the maximum level of the solution The discharge location will then moved further to the interior of the cell allowing for additional volume of solids to be placed under the solution level The solution level in the cell will vary depending on the operating schedule of the Mill and the seasonal evaporation rates The tailings slurry will not be allowed to discharge directly on to the Splash Pads in order to further protect the FML The tailings slurry will discharge directly in to the solution contained in the Cell onto an additional protective sheet or on to previously deposited tailings sand Equipment Access Access will be restricted to the interior portion of the cell due to the potential to damage the flexible membrane liner Only rubber tired all terrain vehicles or foot traffic will be allowed on the flexible membrane liner Personnel are also cautioned on the potential damage to the flexible membrane liner through the use and handling of hand tools and maintenance materials Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 Reclaim Water System pump barge and solution recovery system will be installed in the southwest corner of the cell to pump solution from the cell for water balance purposes or for re-use in the Mill process Figure illustrates the routing of the solution return pipeline and the location of the pump barge The pump barge will be constructed and maintained to ensure that the flexible membrane liner is not damaged during the initial filling of the cell or subsequent operation and maintenance activities The condition of the pump barge and access walkway will be noted during the weekly Cell inspections Interim Solids Discharge Figure illustrates the progression of the slurry discharge points around the east side of Cell 4A Once the tailings solids have been deposited along the north and east sides of the Cell the discharges points will subsequently be moved to the sand beaches which will eliminate any potential for damage to the liner system Liner Maintenance and QAQC Any construction defects or operational damage discovered during observation of the flexible membrane liner will be repaired tested and documented according to the procedures detailed in the approved Revised construction Quality Assurance Plan for the Construction of the Cell 4A Lining System May 2007 by GeoSyntec Consultants BAT Performance Standards for Tailings Cell 4A DUSA will operate and maintain Tailings Cell 4A so as to prevent release of wastewater to groundwater and the environment in accordance with this BAT Monitoring Operations and Maintenance Plan pursuant to Part I.H 19 of the GWDP These performance standards shall include Leak Detection System Pumping and Monitoring Equipment the leak detection system pumping and monitoring equipment includes submersible pump pump controller water level indicator head monitoring and flow meter with volume totalizer The pump controller is set to maintain the maximum level in the leak detection system at no more than foot above the lowest level of the secondary flexible menbrane second leak detection pump with pressure transducer flow meter and manufacturer recommended spare parts for the pump controller and water level data collector is maintained in the Mill warehouse to ensure that the pump and controller can be replaced and operational within 24 hours of detection of failure of the pumping system The root cause Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 of the equipment failure will be documented in report to Mill management with recommendations for prevention of re-occurrence Maximum Allowable Head the Permittee shall measure the fluid head above the lowest point on the secondary flexible membrane by the use of procedures and equipment specified in the White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT monitoring Plan 3/07 Revision Denison-3 or the currently approved DMT Plan Under no circumstance shall fluid head in the leak detection system sump exceed 1-foot level above the lowest point in the lower flexible membrane liner Maximum Allowable Daily LDS Flow Rates the Permittee shall measure the volume of all fluids pumped from the LDS on weekly basis and use that information to calculate an average volume pumped per day Under no circumstances shall the daily LDS flow volume exceed 24160 gallons/day The maximum daily LDS flow volume will be compared against the measured cell solution levels detailed on the attached Table to determine the maximum daily allowable LDS flow volume for varying head conditions in the cell. 3-foot Minimum Vertical Freeboard Criteria the Permittee shall operate and maintain wastewater levels to provide 3-foot Minimum of vertical freeboard in Tailings Cell 4A Said measurements shall be made to the nearest 0.1 foot Slimes Drain Recovery Head Monitoring immediately after the Permittee initiates pumping conditions in the Tailings Cell 4A slimes drain system monthly recovery head tests and fluid level measurements will be made in accordance with plan approved by the DRC Executive Secretary The slimes drain system will pumping and monitoring equipment includes submersible pump pump controller water level indicator head monitoring and flow meter with volume totalizer Routine Maintenance and Monitoring Trained personnel inspect the White Mesa tailings system on once per day basis Any abnormal occurrences or changes in the system will be immediately reported to Mill management and maintenance personnel The inspectors are trained to look for events involving the routine placement of tailings material as well as events that could affect the integrity of the tailings cell dikes or lining systems The daily inspection reports are summarized on monthly basis and reviewed and signed by the Mill Manager Solution Elevation Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 Measurements in Cell 4A are to be taken by survey on weekly basis as follows The survey will be performed by the Mills Radiation Safety Officer or designee the Surveyor with the assistance of another Mill worker the Assistant ii The survey will be performed using survey instrument the Survey Instrument accurate to 0.01 feet such as Sokkai No B2 or equivalent together with survey rod the Survey Rod having visible scale in 0.01 foot increments iiiThe reference Points the Reference Points for Cells 4A are known points established by Registered Land Surveyor For Cell 4A the Reference Point is piece of metal rebar located on the dike between Cell and Cell 4A The elevation at the top of this piece of rebar the Reference Point Elevation for Cell 4A is at 5607.83 feet above mean sea level amsl iv The Surveyor will set up the Survey Instrument in location where both the applicable Reference Point and pond surface are visible For Cell 4A this is typically on the road between Cell and Cell4A approximately 100 feet east of the Cell 4A Reference Point Once in location the Surveyor will ensure that the Survey Instrument is level by centering the bubble in the level gauge on the Survey Instrument viThe Assistant will place the Survey Rod vertically on the Cell 4A Reference Point The Assistant will ensure that the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established level reading vii The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the Survey Rod and record the number the Reference Point Reading which represents the number of feet the Survey Instrument is reading above the Reference Point The Assistant will then move to designated location where the Survey Rod can be placed on the surface of the main solution pond in Cell 4A The designated location for Cell 4A is in the northeast corner of the Cell where the side slope allows for safe access to the solution surface The approximate coordinate locations for the measuring points for Cell 4A is 2579360 east and 320300 north These coordinate locations may vary somewhat depending on solution elevations in the Cell The Assistant will hold the Survey Rod vertically with one end of the Survey Rod just touching the pond surface The Assistant will ensure that the Survey Rod is vertical by gently rocking the rod back and forth until the Surveyor has established level reading viii The Surveyor will focus the cross hairs of the Survey Instrument on the scale on the Survey Rod and record the number the Pond Surface Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 Reading which represents the number of feet the Survey Instrument is reading above the pond surface level The Surveyor will calculate the elevation of the pond surface in feet amsl by adding the Reference Point Reading for the Cell and subtracting the Pond Surface Reading for the Cell and will record the number accurate to 0.01 feet Leak Detection System The Leak detection system is monitored on continuous basis by use of pressure transducer that feeds water level information to an electronic data collector The water levels are measured every hour and the infonnation is stored for later retrieval The water levels are measured to the nearest 0.10 inch The data collector is currently programmed to store days of water level information The number of days of stored data can be increased beyond days if needed The water level data is downloaded to laptop computer on weekly basis and incorporated into the Mills environmental monitoring data base and into the files for weekly inspection reports of the tailings cell leak detection systems Within 24 hours after collection of the weekly water level data the information will be evaluated to ensure that the water level in the leak detection sump did not exceed the allowable level 5556.14 feet amsl and the average daily flow rate from the LDS did not exceed the maximum daily allowable flow rate at any time during the reporting period For Cell 4A under no circumstance shall fluid head in the leak detection system sump exceed 1-foot level above the lowest point in the lower flexible membrane liner To determine the Maximum Allowable Daily LDS Flow Rates in the Cell 4A leak detection system the total volume of all fluids pumped from the LDS on weekly basis shall be recovered from the data collector and that information will be used to calculate an average volume pumped per day Under no circumstances shall the daily LDS flow volume exceed 24160 gallons/day The maximum daily LDS flow volume will be compared against the measured cell solution levels detailed on the attached Table to determine the maximum daily allowable LDS flow volume for varying head conditions in Cell 4A Any abnormal or out of compliance water levels must be immediately reported to Mill management The data collector is also equipped with an audible alarm that sounds if the water level in the leak detection sump exceeds the allowable level 5556.14 feet amsl The current water level is displayed at all times on the data collector and available for recording on the daily inspection form The leak detection system is also equipped with leak detection pump EPS Model 25S05-3 stainless steel or equal The pump is capable of pumping in excess of 25 gallons per minute at total dynamic head of 50 Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 feet The pump has 1.5 inch diameter discharge and operates on 460 volt phase power The pump is equipped with pressure sensing transducer to start the pump once the level of solution in the leak detection sump is approximately 2.25 feet elevation 5555.89 above the lowest level of the leak detection sump inches above the lowest point on the lower flexible membrane liner to ensure the allowable 1.0 foot 5556.14 feet amsl above the lowest point on the lower flexible membrane liner is not exceeded The attached Figure Leak Detection Sump Operating Elevations illustrates the relationship between the sump elevation the lowest point on the lower flexible membrane liner and the pump-on solution elevation for the leak detection pump The pump also has manual start and stop controls The pump will operate until the solution is drawn down to the lowest level possible expected to be approximately inches above the lowest level of the sump approximate elevation 5554.0 The pump discharge is equipped with 1.5 inch flow meter EPS Paddle Wheel Flowsensor or equal that reads the pump discharge in gallons per minute and records total gallons pumped The flow rate and total gallons is recorded by the Inspector on the weekly inspection form The leak detection pump is installed in the horizontal section of the 18 inch horizontal perforated section of the PVC collection pipe The distance from the top flange face at the collection pipe invert to the centerline of the 22.5 degree elbow is 133.4 feet and the vertical height is approximately 45 feet The pump is installed at least feet beyond the centerline of the elbow The bottom of the pump will be installed in the leak detection sump at least 135.4 feet or more from the top of the flange invert pressure transducer installed with the pump continuously measures the solution head and is programmed to start and stop the pump within the ranges specified above The attached Figure illustrates the general configuration of the pump installation second leak detection pump with pressure transducer flow meter and manufacturer recommended spare parts for the pump controller and water level data collector will be maintained in the Mill warehouse to ensure that the pump and controller can be replaced and operational within 24 hours of detection of failure of the pumping system The root cause of the equipment failure will be documented in report to Mill management with recommendations for prevention of re-occurrence Slimes Drain System pump Tsurumi Model KTZ23.7-62 stainless steel or equal will be placed inside of the slimes drain access riser pipe and near as possible to the bottom of the slimes drain sump The bottom of the slimes drain sump is 38 feet below water level measuring point at the centerline of the Page Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 slimes drain access pipe near the ground surface level The pump discharge will be equipped with inch flow meter EM Model 33 or equal that reads the pump discharge in gallons per minute and records total gallons pumped The flow rate and total gallons will be recorded by the Inspector on the weekly inspection form ii The slimes drain pump will be on adjustable probes that allows the pump to be set to start and stop on intervals determined by Mill management iiiThe Cell 4A slimes drain pump will be checked weekly to observe that it is operating and that the level probes are set properly which is noted on the Weekly Tailings Inspection Form If at any time the pump is observed to be not working properly it will be repaired or replaced within 15 days ivDepth to wastewater in the Cell 4A slimes drain access riser pipe shall be monitored and recorded weekly to determine maximum and minimum fluid head before and after pumping cycle respectively All head measurements must be made from the same measuring point to the nearest 0.01 foot The results will be recorded as depth-in-pipe measurements on the Weekly Tailings Inspection Form On monthly basis the slimes drain pump will be turned off and the wastewater in the slimes drain access pipe will be allowed to stabilize for at least 90 hours Once the water level has stabilized based on no change in water level for three successive readings taken no less than one hour apart the water level of the wastewater will be measured and recorded as depth-in-pipe measurement on the Monthly Inspection Data form by measuring the depth to water below the water level measuring point on the slimes drain access pipe The slimes drain pump will not be operated until Mill management has determined that no additional process solutions will be discharged to Cell 4A and the Cell has been partially covered with the first phase of the reclamation cap The long term effectiveness and performance of the slimes drain dewatering will be evaluated on the same basis as the currently operating slimes drain system for Cell Tailintzs Emcr2encies Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if during their inspection they discover that an abnormal condition exists or an event has occurred that could cause tailings emergency Until relieved by the Environmental or Radiation Technician or Radiation Safety Officer inspectors will have the authority to direct resources during tailings emergencies Any major catastrophic events or conditions pertaining to the tailings area should be reported immediately to the Mill Manager or the Radiation Safety Officer one of whom Page 10 Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 will notify Corporate Management If dam failure occurs notify your supervisor and the Mill Manager immediately The Mill Manager will then notify Corporate Management MSHA 303-231-5465 and the State of Utah Division of Dam Safety 801-538-7200 Cell 4A Solution Freeboard Calculation The maximum tailings cell pond wastewater levels in Cells 1-I Cell Cell and Cell 4A are regulated by condition 10.3 of the White Mesa Mill le.2 Materials License Condition 10.3 states that Freeboard limits for Cells 1-1 and shall be set periodically in accordance with the procedures set out in Section 3.0 to Appendix of the previously approved NRC license application including the October 13 1999 revisions made to the January 10 1990 Drainage Report The freeboard limit for Cell shall be recalculated annually in accordance with the procedures set in the October 13 1999 revision to the Drainage Report The 1990 Drainage Report uses the Local 6-hour Probable Maximum Precipitation PMP event for calculating the freeboard requirements for each of the tailings cells The PMP for the White Mesa site is 10 inches Based on the PMP storm event the freeboard requirement for Cell is maximum operating water level of 5615.4 feet above mean sea level amsl The Cell freeboard limit is not affected by operations or conditions in Cells or 4A Cell has no freeboard limit because the Cell is 99%frill of tailings solids and all precipitation falling on Cell and the adjacent drainage area must be contained in Cell The flood volume from the PMP event over the Cell and Cell pond areas plus the adjacent drainage areas is 123.4 acre-feet of water According to the freeboard calculation procedures this volume currently must be contained in the existing 24-acre pool area in Cell This results in maximum operating water level in Cell of 5601.6 feet amsl The Cell 4A design includes concrete spillway between Cell and Cell 4A with the invert elevation feet below the top of the Cell dike at an elevation of 5604.5 feet amsl Once Cell 4A is placed in operation the cell would be available for emergency overflows from Cell but as long as the freeboard limit in Cell is maintained at 5601.6 it is extremely unlikely that Cell 4A would see any overflow water from Cell unless the full PMP event were to occur Should Cell receive the full PMP volume of 123.4 acre feet of water approximately 62 acre feet of that volume would flow through the spillway into Cell 4A The flood volume from the PMP event over the Cell 4A area is 36 acre-feet of water 40 acres plus the adjacent drainage area of 3.25 acres times the PMP of 10 inches This would result in total flood volume of 98 acre-feet including the 62 acre-feet of solution from Cell The freeboard depth required for Cell 4A from the PMP event would be 2.44 feet plus wave mn-up depth of 0.77 feet from the 1990 Drainage Report for Page 11 Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 total freeboard requirement of 3.2 feet This calculation is illustrated on Attachment The Groundwater Quality Discharge Permit No UGW370004 for the White Mesa Mill requires that the minimum freeboard be no less than 3.0 feet for any of the existing Cell construction but based on the above calculation the freeboard would be set 3.2 feet below the top of liner The freeboard for Cell 4A would therefore be 5595.3 amsl top of liner 5598.5 3.2 feet Figure Hydraulic Profile Schematic shows the relationship between the Cells and the relative elevations of the solution pools and the spillway elevations If Cell 4A were required to store the entire PMP event for Cell Cell and Cell 4A the required storage volume would be approximately 160 acre-feet of solution This would increase the necessary freeboard to 4.77 feet The required freeboard for Cell 4A will be recalculated annually along with the re calculation of the Cell freeboard requirement calculation of the current freeboard calculation for both Cells is attached to this Plan Page 12 Cell 4A BAT Monitoring Operations and Maintenance Plan 09/08 Revision Denison 1.3 Attachments Figure Initial Filling Plan GeoSyntec Consultants Figure Initial Filling Plan Details and Sections GeoSyntec Consultants Figure Initial Filling Plan Solution and Slurry Pipeline Routes GeoSyntec Consultants Figure Interim Filling Plan GeoSyntec Consultants Figure Leak Detection System Sump GeoSyntec Consultants Figure Leak Detection Sump Operating Elevations Figure Hydraulic Profile Schematic Cell and Cell 4A Freeboard Calculation Table Calculated Action leakage Rates for Various Head Conditions Cell 4A White Mesa Mill Blanding Utah GeoSyntec Consultants 10 White Mesa Mill Tailings Management System and Discharge Minimization Technology DMT Monitoring Plan 3/07 Revision DUSA-2 32 pages or currently approved version of the DMT Page 13 2/ /1 l\ _/ / 40 0 SC A L E IN FE E T HD F E PIP E L I N E SL U R R Y O R S O L U T I O N SC A L E IN FE E T IN I T I A L FIL L I N G PL A N CE L L 4A BL A N D I N O UT A H 00 2q 0 Ge o s y n t e c C _ D A T E co n s u l E a n t s PR O J E C T N O JU N 20 0 8 FIO I J R E SC O 3 4 Y_ IL J i- -L -J Solution Elevation 5556.14 fe Leak Detection Sump Elevation 5553.64 feet amsl Denison Mines USA Corp LENISOJAA MINES Project White Mesa Mill REVISIONS County Son Juan County State Location White Mesa Mill Figure Leak Detection Sump Operating Levels Scale N/A Oate 09/2008 figure 6.dwg Author HRR Drafted Sy GM PM P Vo l u m e 36 ac - f t plu s 61 . 6 ac - f t fr o m Ce l l 2 an d Ce l l Ce l l 4A Fr e e b o a r d Li m i t 55 9 5 . 3 ms l Hy d r a u l i c Pr o f i l e Sc h e m a t i c PM P Vo l u m e 12 3 . 4 ac - f t 61 . 6 ac - f t ov e r f l o w s to Ce l l 4A 3S p i 1 1 E I e v . 5 6 . 5 Ce l l Fr e e b o a r d Li m i t 56 0 1 . 9 ms l Ce l l Clo s e d Fi g u r e No t to Sc a l e Ce l l C e l l 4A Fr e e b o a r d Ca l c u l a t i o n Ra d i o a c t i v e Ma t e r i a l s Li c e n s e UT 1 90 0 4 7 9 Li c e n s e Co n d i t i o n 10 3 An n u a l Re c a l c u l a t i o n An n u a l Ca l c u l a t i o n V a r i a b l e s Ce l l PS Ce l l Po o l Su r f a c e fro m mo s t re c e n t su r v e y 24 3 or a e r i a l ph o t o g r a p h ac r e s Au g u s t 24 20 0 3 MD T Es t i m a t e d Ma x i m u m dr y to n s of Ta i l i n g s 70 0 0 0 to be ge n e r a t e d d u r i n g ne x t 12 mo n t h s Oc t o b e r 2 0 0 6 S e p t e m b e r 30 2 0 0 7 De f i n i t i o n s Co n s t a n t Fa c t o r s an d Ca l c u l a t i o n s Ce l l PM P P M P Flo o d Vo l u m e Re q u i r e m e n t ac r e - f e e t 12 3 . 4 AR F Ar e a Re d u c t i o n F a c t o r f r o m Ja n u a r y 10 1 9 9 0 Dr a i n a g e Re p o n dr y to n s pe r ac r e 39 1 4 8 WR U Wa v e Ru n Up fa c t o r fro m Ja n u a r y 10 19 9 0 Dr a i n a g e R e p o r t fe e t 0.7 8 DC To p of Un e r Dik e Cr e a f Ce l l fe e f ab o v e me a n as s le v e l 56 0 8 . 5 SW E Sp i l l w a y In v e r t Ele v a t i o n fe e t ab o v e me a n se a le v e l 56 0 4 . 5 MM P Ma x i m u m Mil l Pr o d u c t i o n dr y t o n s 1S MO T 1.5 70 0 0 0 10 5 0 0 0 dr y to n s RP A Re d u c e d Po o l Ar e a ac r e s PS MM P AR F 24 . 0 10 5 0 0 0 3 9 1 4 6 21 . 3 ac r e s PM P F L P M P Fr e e b o a r d Le v e l fe e t PM P R P A 12 3 . 4 21 . 3 5.8 fe e t TR F To t a l Re q u i r e d Fr e e b o a r d fe e t PM P F L WR U 5.8 0.7 8 6.6 fe e t FL 3 Fr e e b o a r d U m i f fe e t ab o v e me a n se a le v e l DC TR F 56 0 8 . 5 6.6 56 0 1 . 9 fe e t ma t AS 3 Av a i l a b l e Sto r a g e Ce l l ac r e - f e e t PM P SW E -F L 3 PS 12 3 . 4 56 0 4 . 5 56 0 1 . 9 24 . 0 61 . 8 ac r e - f e e t OF V 3 Ov e r f l o w Vo l u m e to C e l l 4A ac r e - f e e t PM P AS 3 12 3 . 4 61 . 8 61 . 6 Ma x i m u m Fr e e b o a r d Lim i t fro m GW D P is 56 0 5 . 6 fe e t ma l Ma x i m u m Fr e e b o a r d Lim i f fro m ru n o f f c a l c u l a t i o n is 56 0 3 . 0 fe e t ma t If th e c a l c u l a t e d FL is gr e a t e r th a n 5 6 0 3 . 0 fe e t ma t th e n th e FL is 56 0 3 . 0 m a t rn rC L. . .L 1 L ... . . . . . L s .. . . a Li J _ i _ J L. a . . L. . .1 . 1 1 An n u a l Ca l c u l a t i o n V a r i a b l e s Ce l l 4A PS 4 Ce l l 4A Po o l Su r f a c e fro m mo s t re c e n t su r v e y or a e r i a l ph o t o g r a p h ac r e s MD T 4 Es t i m a t e d Ma x i m u m dr y to n s of T a i l i n g s to be de p o s i t e d in Ce l l 4A du r i n g ne x t 12 mo n t h s Ju l y l 2 0 0 8 Ju n e S O 2 0 0 g AT S 4 Ar e a of Ta i l i n g s So l i d s ab o v e ele v a t i o n 55 9 3 ac r e s Ce l l C e l l 4A Fr e e b o a r d Ca l c u l a t i o n Ra d i o a c t i v e Ma t e r i a l s Li c e n s e IJ T 1 90 0 4 7 9 Li c e n s e Co n d i t i o n 10 . 3 An n u a l Re c a l c u l a t i o n 40 . 0 70 0 0 0 0.0 PM P 4 PM P Flo o d Vo l u m e Re q u i r e m e n t ac r e - f e e t AR F Ar e a Re d u c t i o n F a c t o r f r o m Ja n u a r y 10 19 9 0 Dr a i n a g e R e p o r t dr y to n s pe r ac r e WR U 4 Wa v e Ru n Up fa c t o r fro m Ja n u a r y 10 19 9 0 Dr a i n a g e R e p o r t fe e t DC 4 To p of Lin e r Dik e Cr e s t Ce l l 4A fe e t ab o v e me a n se a le v e l RP A 4 Re d u c e d Po o l Ar e a ac r e s PM P F L 4 PM P Fre e b o a r d L e v e l fe e t TR F To t a l Re q u i r e d Fr e e b o a r d fe e t FL 4 Fr e e b o a r d Lim i t fe e t ab o v e me a n se a le v e l P8 4 A T S 4 40 . 0 PM P 4 OF V 3 RP A 4 36 . 0 PM P F L 4 WR U 4 DC 4 TR F 4 61 . 6 40 . 0 2.4 4 0.7 7 ss g a . s 3.2 40 . 0 a c r e s 2.4 4 fe e t 3.2 fe e t 55 9 5 . 3 fe e t me l Ma x i m u m Fr e e b o a r d U m i t fro m GW D P 55 9 5 5 fe a t me l Ma x i m u m Fr e e b o a r d Lim i t fro m ru n o f f c a l c u t a t i o n is 55 9 5 . 3 fe e t ma t If th e c a l c u l a t e d FL 4 is gr e a t e r th a n 55 9 5 . 5 fe a t me l th e n t h e FL 4 is 55 9 5 . 3 m a t De f i n i t i o n s Co n s t a n t Fa c t o r s an d Ca l c u l a t i o n s Ce l l 4A 36 . 0 39 1 4 6 0.7 7 55 9 8 . 5 Table Calculated Action Leakage Rates GeoSyntec Consultants for Various Head Conditions Cell 4A White Mesa Mill Blanding Utah Head Above Liner System feet Calculated Action Leakage Rate gallons/acrelday 222.04 10 314.01 15 384.58 20 444.08 25 496.50 30 543.88 35 587.46 37 604.01 No PBL-4 INTERNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date March 15 2001 Title Clearance of Linde Material Intermodal Containers Purpose The purpose of this Procedure is to document the steps to be followed to ensure that prior to receipt of Linde materials at the White Mesa Mill the Mill the materials have been properly sampled and analyzed in accordance with the IT Corporation Sampling and Analysis Plan the IT SAP and the IT Contained-Tn Sampling Work Plan and have satisfied other applicable requirements This procedure may be amended subject to approval by IUSAs Safety and Environmental Review Panel SERP from time to time as appropriate Clearance Procedure for Linde Materials The following steps must be followed before any Linde materials may be received at the Mill for processing 2.1 IT will conduct sampling of the Linde materials at the Linde site in accordance with the IT SAP and IT Contained-In Sampling Work Plan for total VOCs and total SVOCs IT will forward the sample results immediately upon receipt to IUSA or JUSAs independent RCRA consultant 1JSAs RCRA consultant and the New York State Department of Environmental Conservation NYSDEC IT will transmit sample results to TUSA under cover letter which states that chemical data in each package has been reviewed by IT all results are consistent with the current Radioactive Material Profile Record RMPR The date of the referred RMPR should be noted all results are below NYSDECs TAGM 3028 contained out action levels as referenced in the Linde Site Contained-Tn Sampling Work Plan and the sample locations are within the geographical areas that are included within the contained-in area IT has been instructed to have the sampling results transmitted to IUSA prior to the IMCs associated with the sampling results arriving at the Mill 2.2 IUSAs RCRA consultant will review the sample results and if available confirmation letter from NYSDEC to confirm that the results are consistent with the referenced RMPR none of the sample results indicate the existence of chemical components not listed in IUSAs Lists of Acceptable Contaminants attached hereto as Attachment the sample locations are within the geographical areas that are included within the contained-in area and all results for VOCs and SVOCs other than PAils are below NYSDECs TAGM 3028 contained out action levels as referenced in Attachment If JUSAs RCRA Consultant identifies that the IT cover letter is inconsistent with any of the four conditions listed above or is lacking any information referred to in 2.1 IUSAs RCRA C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-4_Linde Material Clearance SOP 03 05 01.doc No PBL-4 INTERNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date March 15 2001 Title Clearance of Linde Material Intermodal Containers Consultant will advise either the Vice President Regulatory Affairs or his designee who will determine whether or not the letter is acceptable 2.3 If the analysis of the sample results indicates that all four conditions detailed in Section 2.2 are satisfied then no further actions are required under this Section 2.3 If IUSAs RCRA consultant identifies some chemical components other than any chemical components that have been determined to be due solely to Lab influence that could possibly be listed hazardous wastes and are identified in Attachment then the following steps will be taken IUSA will advise IT that further technical review is required to determine whether the new constituents is not from RCRA listed source from RCRA listed source but can be contained-out under TAGM or from RCRA listed source and cannot be contained-out under TAGM ii IT will perform RCRA analysis to determine if the new compound is RCRA listed waste IUSA will assist IT in this analysis as appropriate iii IUSAs RCRA consultant will prepare technical memorandum for review by IUSAs SERP Committee addressing whether or not the new compound is listed hazardous waste and whether or not the new compound may pose any material handling safety or environmental impacts at the Mill IT the generator after performing its own RCRA analysis will make the final determination and advise IUSA in writing of the determination results before IMCs containing material associated with the sample results undergoing listed waste determination reach the Mill iv meeting of IUSAs SERP will be scheduled to review ITs analysis and recommendations IUSAs RCRA consultants analysis and any other pertinent information to determine whether or not the new chemical components are listed hazardous wastes or whether they are not listed hazardous wastes If the SERP concludes that the compound is not RCRA listed waste then it will be added to the list of acceptable compounds for the Mill found in Attachment IT will provide IUSA an updated revision with date of the Preliminary Material Characterization Report C\Documents and Settings\dfiydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5cXRH6z\PBL-4 Linde Material cleance sop 0308 01.doc No PBL-4 INTERNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date March 15 2001 Title Clearance of Linde Material Intermodal Containers PMCR as soon as possible No change to the RMPR will be required for this situation If the contaminant is determined to be subject to the TAGM by IT and NYSDEC IT will provide IUSA written confirmation of this determination together with an updated revision with date of the PMCR as soon as possible JUSAs SERP will review the determination and if agreed to Attachment will be updated IT will also be required to submit an updated RMPR to IUSA addressing this determination If the SERP concludes that the compound resulted from RCRA listed source but it is not added to the TAGM list by NYSDEC then any materials that based on IT confirmatory excavation results contain such compound will not be shipped to the Mill or if received at the Mill will be returned to IT If IUSAs RCRA Consultant is unable to confirm that all of the conditions set out in Section 2.2 and have been satisfied IUSAs RCRA Consultant will advise the Vice President Regulatory Affairs or his designee of this fact and the Vice President Regulatory Affairs or his designee will make determination as to what additional steps if any are required in order to clear the material that is characterized by the sample results for receipt at the Mill 2.4 Periodically IUSA will arrange to send to the Utah Department of Environmental QualityUDEQcopyofallsampleresultsfromITthathave been received and technically reviewed If any SERP actions are required to have been taken with respect to any of that data copies of the applicable SERP reports will also be sent to the UDEQ 2.5 UDEQ has advised IUSA that they will contact IUSA if they have any concerns with any of the data or SERP reports that have been sent to them They have agreed that it is not necessary for IUSA to contact UDEQ regarding any of the sampling data or accompanying analysis subject to Section 2.6 below 2.6 If any of the sample data indicates the presence of an anomaly i.e an unusual new chemical component that does not fit within the general rationale that has been applied to date for other chemical components then IUSA will contact UDEQ to confirm that UDEQ is satisfied with IUSA technical review and that the anomaly is not listed hazardous waste At the time of sending in such sample data IUSA will contact Don Verbica or equivalent at UDEQ to arrange for discussion of the sample results and JUSA will receive verbal or written confirmation from Don Verbica or equivalent that UDEQ is satisfied that the anomaly is not listed hazardous waste C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15cXRH6Z\PBL-4 Linde Material clearance so 03 08 0l.doc No PBL-4 INTE RNATIONAL URANIUM USA CORPORATION Rev No R-0 STANDARD OPERATING PROCEDURES Page of Date March 15 2001 Title Clearance of Linde Material Intermodal Containers 2.7 Simultaneously with the steps set out in Sections 2.3 to 2.5 above IUSAs RCRA Consultant or other person designated by the Vice President Regulatory Affairs will correlate sample results from IT to IMC Shipper numbers sent to the Mill in accordance with the following procedure For each IMC find the Shipper Number Linde-It on IT Linde Site to JUG Ship Log the Ship Log sheet Find the Sample It corresponding to each IMC on the Ship Log Fill in the Sample It column in for each IMC on the IT Data Checklist form When JUSAs RCRA Consultant or designee has determined that set of sampling results are acceptable via the process in either Section 2.2 or 2.3 above IUs RCRA Consultant or designee will indicate that the IMCs associated with those results should receive interim clearance for entrance to the Mill by filling in dates in the columns VOC OK and SVOC OK in the IT Data Checklist form and the column IMCs Interim Cleared in the Linde Lot Control database 2.8 As soon as IUSAs RCRA Consultant and Vice President Regulatory Affairs or his designee have determined that one or more IMCs has satisfied all of the following criteria By following the procedure contained in Section 2.7 above IUSAs RCRA Consultant or designee has determined that the IT sample results have been received with respect to all materials contained in that batch of IMCs and No new chemical components other than chemical components that have been determined to be due to Lab influence have been identified in any of the sample results relating to that batch of IMCs or if any new chemical components have been identified the procedures set out in Section 2.3 above have been followed I1Js RCRA Consultant together with either IUSA Vice President Regulatory Affairs or his designee will prepare memorandum advising IUSA President or his designee of that fact including the identification numbers of the IMCs 2.9 Upon receipt of the memorandum referred to in Section 2.8 IUSAs President or his designee will advise the Plant Manager in writing of the IMCs acceptable for receipt at the Mill 2.10 Upon receipt of the memorandum the Mill staff will follow the receipt procedures as detailed in SOP PBL-2 Intermodal Container Acceptance Handling and Release for receipt of the IMCs at the Mill C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-4_Linde Material Clearance 50P 03 05 0l.doc ATTACHMENT LISTS OF ACCEPTABLE CONTAMINANTS C\Documents and Setfings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRFI6Z\PBL-4 Linde Material Clearance SOP 03 08 01.doc Attachment Table List of Contaminants in Linde Uranium Material RCRA FOOl Acceptable When Contained Out Subject to NYSDEC TAGM 3028 Volatile Organic Chemical VOC Contaminant TAGM Action Level_ug/kg Carbon tetrachioride 4900 Chlorobenzene 1800000 12-Dichioroethene total cis and trans isomers cis and trans 12 DCE cis-780000 trans-1600000 trans-12-Dichloroethene trans 12 DCE 1600000 12 Dichloroethane 12 DCA 7000 Methylene chloride 85000 Tetrachioroethene PCE 12000 111 -Trichioroethane 111 TCA 7000000 Trichlorethene TCE 58000 Attachment Table List of Contaminants in Linde Uranium Material Other Acceptable Contaminants Volatile Organic Chemical VOC Contaminant TAGM Action Level_uglkg Acetone 7800000 Butanone 47000000 Benzene 22000 Bromoform 81000 Carbon disulfide 7800000 Chloroform 100000 Chioromethane 49000 11 -Dichioroethene 1100 Ethylbenzene 7800 Hexachioroethane 46000 Pentachlorophenol 3000 11 22-Tetrachloroethane 3200 Toluene 18000000 Trichiorofluoromethane 23000000 Vinyl chloride 340 Xylene total 160000000 NYSDEC requires that contaminants from both RCRA-listed and non-listed waste sources must not exceed TAGM 3028 action levels Attachment Table continued List of Contaminants in Linde Uranium Material Other Acceptable Contaminants Semi-Volatile Organic Chemical SVOC Contaminant TAGM Action Level ug/kg Acenaphthene 4700000 Acenaphthylene Anthracene 23000000 Benzo anthracene 900000 Benzo pyrene 90 Benzo fluoranthene 900 Benzo ghi perylene --- Benzo fluoranthene 9000 Bis 2-ethyihexyl phthalate 46000 Chrysene 88000 Dibenz ah anthracene 90 Dibenzofuran --- Di-n-butyl phthalate 7800000 Fluoranthene 3100000 Fluorene 3100000 2-Methylnaphtahalene --- Methyiphenol --- Naphthalene 310000 N-nitrosodiphenylamine 130000 Phenanthrene --- Pyrene 2300000 Polychiorinated biphenyls PCBs Arochiors 1248 1254 1260 50000 TAGM action levels have not been established for some contaminants No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management 1.0 Purpose The following procedure applies to acceptance of alternate feed materials from Heritage Minerals Inc HMI which International Uranium USA Corporation IUSA determines to potentially contain levels of thorium that require that special procedures be followed which are over and above those required for conventional ores or other alternate feed materials This procedure may be amended subject to approval by I1JSAs Safety and Environmental Review Panel SERP from time to time as appropriate to incorporate information and results obtained from the evaluation of health physics surveys monitoring and controls implemented pursuant to keeping radiological exposures to employees the public and the environment As Low As Reasonably Achievable ALARA The methods set forth in this Standard Operating Procedure SOP are based on the assumption that the HMI materials will be delivered to the White Mesa Mill in 20-ton intermodal containers IMCs Should the delivery method be modified IUSA will revise this SOP to address the selected mode of delivery 2.0 Ore Receiving For material receiving procedures see Section 2.0 of White Mesa Mill SOP PBL-2 Intennodal Container Acceptance Handling and Release 3.0 Ore Dumping After the IMC has been dropped off in the Restricted Area connect the Bartlett tipper to the chassis with loaded IMC and transport across the truck scales After weighing the IMC move the tipper and chassis onto the ore storage pad Enter the loaded weight of the IMC on the IMC SWT Remove the tarp on the back of the IMC and open the tailgate Dump the material in the IMC onto the ore storage pad After all material has been removed from the IMC transport the empty IMC back across the scales for an empty weight Record the empty weight on the appropriate IMC SWT At the end of each day turn in outbound SWT to Mill Records Manager The Mill Records Manager will fill out Daily Materials Receipts form to obtain the net weight of the material in each IMC C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-6 Heritage Alternate Feed Management_rev 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management After weighing the IMC the Bartlett tipper will deposit the IMC in designated area within the Restricted Area for decontamination 10 Use front-end loader or similar equipment to push material into the designated ore lot pile 11 The HMI material will be stored in one stockpile to enhance dust control and minimize exposure risks The stockpile size not including the cover material will not exceed height of 10 feet 12 Dust suppression measures will include the following The stockpile will be wet down at least once per day until such time that it is covered The completed stockpile will be covered with Ashland material or another suitable material to provide cover of the stockpile to reduce the potential of dusting and provide temporary radiation cover All stockpiles will be inspected at least once per day to ensure the integrity of the covering In the event of wind speeds in excess of 20 MPH all dumping activities will cease immediately 4.0 Radiation Monitoring during Ore Receipt Due to the potential for higher concentrations of thoron and other potential radiological hazards during HMI material receipt and handling Radiation Work Permit RWP will be issued during the initial receipt of HivIl material The RWP will list the health physics controls required personal protective equipment dust control monitoring and survey requirements necessary to assess the radiological exposure potential to employees operating under the RWP As soon as the results of the monitoring activity conducted in accordance with the conditions indicated by the RWP have been evaluated the added radiological surveys applicable to the particular HMI material will be established communicated to the Radiation Safety Technicians RSTs conducted and documented Irrespective of the added surveys selected the following radiological surveys will be performed routinely for the duration of the receipt of HMI material Based upon results of monitoring and dose calculations recognizing that there may be potential for higher than normal radiological exposures the Mill Radiation Safety Officer RSO may recommend that personnel be rotated from area to area periodically in order to reduce potential exposure C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\1SCXRH6Z\PBL-6_Heritage Alternate Feed Management_revi 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Pa ge 30 Date Feb 14 2003 Title Heritage Alternate Feed Management 4.1 Area Airborne Sampling Weekly area airborne sampling will be conducted in the areas of the Mill listed below twenty-four hour air sample will be collected at flow rate of 40 liters per minute or greater After sufficient data has been collected and reviewed by the RSO and ALARA Committee area airborne sampling frequency may be reduced to once every two weeks during the receiving of HMI mill feed HMI Stockpile area Scalehouse area The above samples will be analyzed for gross alpha 4.2 DAC Determination composite feed sample of HMI material was analyzed for radioisotropic composition The data were used by the RSO to establish derived air concentration DAC The DAC for the HMI material that was established based upon data gathered under RWP370 and which will be applied during processing of the HMI material is 1.24ff2 pCi/cc based on thorium If air sample results indicate an airborne radioactive dust concentration of 25%of the thorium DAC in any of the areas sampled during processing then the air sample frequency will be increased to daily in those areas until mitigative measures have reduced concentrations below 25%of the thorium DAC for two consecutive days 4.3 Breathing Zone Samplipg Breathing zone air samples will be collected once per week on select individuals who perform routine work tasks associated with receiving operations After sufficient data has been collected and reviewed by the RSO and ALARA Committee breathing zone sampling frequency may be reduced to once every two weeks or greater during the receiving of HMI materials Breathing zone air samples will be collected from individuals who perform work tasks under an RWP In addition to the above sampling under and further breathing zone samples may be collected from individuals at the discretion of the RSO C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6ZkPBL-6_Heritage Alternate Feed Management_revi 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-l STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management 4.4 Surveys For External Radiation All employees working with HMI material will wear personal radiation monitoring device The devices will be collected quarterly and the results entered on individual exposure forms Beta/gamma dose rate measurements will be performed weekly in all areas of the Mill operations These data will be used to perform monthly dose rate calculations Individuals who perform work tasks that are anticipated to exhibit the highest potential dose rate exposures may be directed by the RSO at his discretion to wear monthly personal radiation monitoring devices 4.5 Surveys for Radon-222 Radon-220 and Their Daughters Weekly measurements of radon daughter concentrations for both Ra-222 and Ra 220 will be conducted in those areas of the Mill listed above in Section 4.1 of this SOP If radon daughter concentrations from either the uranium or thorium parent are less than 25%of the limit 0.08 working level for Ra-222 or 0.25 working level for Ra-220 the sampling frequency will be decreased to monthly 5.0 Radiation Monitoring during Ore Processing Radiation Work Permit RWP will be issued during the initial processing of HMI material The RWP will list the health physics controls required personal protective equipment dust control monitoring and survey requirements necessary to assess the radiological exposure potential to employees operating under the RWP As soon as the results of the monitoring activity conducted in accordance with the conditions indicated by the RWP have been evaluated any added radiological surveys applicable to the HMI material will be established communicated to the Radiation Safety Technicians RSTs conducted and documented frrespective of the added surveys selected the following radiological surveys will be performed routinely for the duration of the processing of HMI material that is from the time the material is fed to process to tailings disposition Based upon results of monitoring and dose calculations the RSO may recommend that personnel be rotated from area to area periodically in order to reduce potential exposure 5.1 Area Airborne Sampling Initial area airborne sampling will be conducted during HMI material feeding at locations where it is known that the potential for dust normally exists during material feed operations specifically alongside the portable and the stationery grizzly and at the belt drop chute into the trommel Samples will also be taken during initial ore feeding operations in any other areas which show evidence of dusting At minimum initial area air samples will be collected for at least two C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\1 5CXRH6Z\PBL-6_Heritage Alternate Feed Management_rev 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATiNG PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management hours at collection flow rate of 40 liters per minute or greater These samples will be analyzed for gross alpha using standard laboratory methods described in Mill Radiation Protection SOPs but applying the modified DAC limits for HMI material that were established with RWP 370 detailed in Section 4.2 above As processing progresses additional area air samples will be collected and analyzed using the same air sampling procedures described above in areas such as the Leach area or any other process areas in which the RSO determines it would be useful to quantify the potential for air emissions 5.2 DAC Determination As noted above in Section 4.2 composite feed sample of HivIl material was analyzed for radioisotropic composition The data were used by the RSO to establish derived air concentration DAC 1.24W2 RCi/cc based on thorium If air sample results indicate an airborne radioactive dust concentration of 25%of the thorium DAC in any of the areas sampled during processing then the air sample frequency will be increased to daily in those areas until mitigative measures have reduced concentrations below 25%of the thorium DAC for two consecutive days 5.3 Breathing Zone Sampling Breathing zone air samples will be collected for at least four hours at collection flow rate of four liters per minute during initial HMI material processing for select individuals performing material feed operations namely the loader and tromrnel operators Breathing zone air samples will he collected from individuals who perform work tasks under an RWP In addition to the above sampling under and further breathing zone samples may be collected from individuals at the discretion of the RSO 5.4 Tailings Management Tailings resulting from processing HMI material will be deposited in an area of the tailings system that will ensure that the material is fully submerged beneath pond liquid and/or tailings slurry from non-HMI alternate feed materials until such time as the first layer of interim cover or random fill is placed on the tailings system This will minimize the potential for thoron gas to escape to the atmosphere Mill Management and the RSO will coordinate efforts to ensure that operations personnel are provided direction regarding placement of HMI tailings In addition the weekly tailings inspections reports will document the placement of HMI tailings during the preceding week C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\PBL-6Heritage Alternate Feed Management_revl 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management 5.5 Surveys For External Radiation All employees working with HMI material will wear personal radiation monitoring device The devices will be collected quarterly and the results entered on individual exposure forms Beta/gamma dose rate measurements will be performed weekly in all areas of the Mill operations These data will be used to perform monthly dose rate calculations Individuals who perform work tasks that are anticipated to exhibit the highest potential dose rate exposures will wear monthly personal radiation monitoring devices 5.6 Surveys for Radon-222 Radon-220 and Their Daughters Monthly measurements of radon daughter concentrations for both Ra-222 and Ra-220 will be conducted in those areas of the Mill listed above in Section 5.1 of this SOP If radon daughter concentrations from either the uranium or thorium parent is greater than 25%of the limit 0.08 working level for Ra-222 or 0.25 working level for Ra-220 the sampling frequency will be increased to weekly in areas where these levels are routinely encountered The radiation safety staff will check all ventilation systems in the Mill daily 6.0 Decontamination and Release of IMCs For intermodal release procedures see White Mesa Mill Standard Operating Procedure PBL-2 Intennodal Container Acceptance Handling and Release 7.0 Hazard Identification and Safety In addition to the usual safety procedures required for work at the Mill the following safety procedures are to be followed for projects involving HMI materials 7.1 Required Personnel Protective Equipment PPE In all areas of the Mill covered by this procedure hard hats safety glasses and steel-toed shoes are required as minimum These must be worn in all areas of the Mill with the exception of the Administration Building The following are required while handling HMI material Coveralls Leather or rubber gloves C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-6_Heritage Alternate Feed Management_revi 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management Rubber Boots or Booties Respiratory protection as directed by the RSO or specified in an RWP Respiratory protection will be used during initial receipt and handling of HMI feed materials and until material-specific DAC values are set In addition all individuals who work in areas where there is likelihood that the airborne concentration DAC limits for either uranium radon thoron or thorium will exceed 25%of the DAC will be required to wear respiratory protection as directed by the RSO See section 8.1.2 below 7.2 Industrial Hazards and Safety Use caution when chassis are backing onto the Ore Pad Ensure that all personnel within 50 feet of the area where the IMC is hooked up to the Bartlett tipper are aware that dumping is about to commence Bartlett tipper operators must use caution during the dumping process Move at least 25 feet away from the rear of the IMC during the initial dumping operation Do not place any part of your body inside the IMC when the chassis is being tipped and the tailgate is open The IIvIC could be lowered or accidentally fall at any time which would cause the tailgate to close rapidly and result in injury Only work under the tailgate after it has been properly blocked open Be aware of high-pressure wash water When the crane is in operation make sure all personnel except the persons in charge of the tag lines are 50 feet away from the IMC being moved The persons in charge of the tag lines should never be underneath the IMC that is being moved Be aware of slippery conditions on the ore pad during periods of inclement weather Be aware of the potential for ice build-up on and around the decontamination pad during periods of cold weather Use caution when entering or exiting equipment Be sure to use the ladders and hand rails Do not jump off of the equipment C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\PBL-6_Heritage Alternate Feed Management_revi 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management 8.0 Radiological and Environmental Concerns Environmental radiation monitoring is routinely performed at the White Mesa Mill at sufficient frequency quarterly and semiannually that any potential impact to the public and or the environment would be identified 8.1 Airborne Radiation Protection The areas of the ore storage pad used for HMI material will only be posted as either Radiation Area and/or Airborne Radioactivity Area in accordance with 10 CFR 20.1902 All personnel involved with material handling will be required to wear full face respirator until such time that review of the air samples by the RSO and ALARA committee indicate that this level of protection is not needed Employees will be notified of any changes to the respiratory protection requirements by memorandum Subsequent to approvals by the RSO and ALARA Committee for reduced posting if based on air sampling an area exhibits 25%of the DAC limits for either uranium or thorium it will be posted Respiratory Protection Required All individuals who work in areas where there is likelihood that the airborne concentration DAC limits for either uranium radon thoron or thorium will exceed 25%of the DAC will be required to wear respiratory protection As directed by written memorandum from the RSO one of the following respirators will be selected Full Face Respirator ii Powered Air Purifying Respirator iii Self Contained Breathing Apparatus SCBA Personal air monitoring will be conducted as per Section of the White Mesa Mill Radiation Protection Manual and Sections 4.2 and 5.2 above 8.2 Urinalysis All personnel involved with the dumping and stockpiling of HMI material and RSTs involved in monitoring described in this SOP will submit urine sample every two weeks at minimum or at greater frequency if so directed by the provisions of an RWP Personnel involved in processing of HMI material will submit urine samples at the usual frequency prescribed in Mill Radiation Protection SOPs These samples will be analyzed for uranium content C\.Documents and Settings\dfrydenlund\.Local Settings\Temporary Internet Files\Content.Outlook\15CXRH6Z\PBL-6_Heritage Alternate Feed Management_rev 02 14 03.doc No PBL-6 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 STANDARD OPERATING PROCEDURES Page of Date Feb 14 2003 Title Heritage Alternate Feed Management Evaluation and corrective actions will be conducted pursuant to guideline provisions contained in Regulatory Guide 8.22 Bioassay at Uranium Mills In vivo lung counting may be implemented if circumstances suggest an overexposure or uptake of either uranium or thorium has occurred In vivo counting will be conducted at the discretion of the RSO and ALARA Committee 8.3 Personal Hygiene All personnel involved with the dumping stockpiling or processing of HMI material will be required to wear coveralls All personnel will survey their hands boots and clothing for surface contamination prior to eating or leaving the restricted area C\Documents and Settings\dfrydenlund\Local Settings\Temporary Internet Files\Content.Outlook\I5CXRH6Z\PBL-6_Heritage Alternate Feed Management_revi 02 14 03.doc RECLAMATION PLAN The Reclamation Plan White Mesa Mill Blanding Utah Source Material License No SUA 1358 Docket No 40-8681 Revision 3.0 JuLy 2000 the Reclamation Plan copy of which has been provided was transmitted to the Executive Secretary1 by letter dated and is hereby incorporated by reference The financial surety including the amount for the long term care fund currently required under Mill License condition 9.5 is $11893975 This amount is reviewed annually by Denison and the Executive Secretary as required by Mill License condition 9.5 Part I.D of the GWDP provides that upon commencement of decommissioning Denison shall reclaim the Mill site and all related facilities stabilize the tailings cells and construct cover system over the tailings cells in compliance with all engineering design and specifications in the Mills Reclamation Plan In that respect Part I.D.6 of the GWDP provides that before reclamation and closure of any tailings disposal cell the Mill shall ensure that the final design construction and operation of the cover system at each tailings cell will comply with all requirements of the approved Reclamation Plan and will for period of not less than 200 years meet the following minimum performance requirements Minimize infiltration of precipitation or other surface water into the tailings including but not limited to the radon barrier Prevent the accumulation of leachate head within the tailings waste layer that could rise above or over-top the maximum FML liner elevation internal to any disposal cell i.e create bathtub effect and Ensure that groundwater quality at the compliance monitoring wells does not exceed the Groundwater Quality Standards or Groundwater Compliance Limits specified in the GWDP Part I.D.7 also provides that the Co-Executive Secretary reserves the right to require modifications to the Reclamation Plan for purposes of compliance with the Utah Groundwater Quality Protection Regulations including but not limited to containment and control of contaminants or discharges or potential discharges to Waters of the State hi order to ensure that the Reclamation Plan meets the requirements of the Utah Groundwater Quality Protection Regulations Part I.H 11 of the GWDP requires that Denison submit for Co Executive Secretary approval an infiltration and contaminant transport modeling report that demonstrates the long-term ability of the tailings cells cover system to adequately contain and control tailings contaminants and protect nearby groundwater quality of the uppermost aquifer Such Report shall demonstrate how the tailings cell engineering design and specifications will comply with the minimum performance requirements of Part I.D.6 of the GWDP Denison submitted work plan for such modeling report for Co-Executive Secretary approval on 74 This page was revised on August 14 2009 September 2005 as required and is currently in the process of completing such report Ti 74 This page was revised on August 14 2009 RECLAMATION PLAN The Reclamation Plan White Mesa Mi14 Blanding Utah Source Material License No SUA 1358 Docket No 40-8681 Revision 3.0 July 2000 the Reclamation Plan copy of which has been provided to the Executive Secretary is hereby incorporated by reference The financial surety including the amount for the long term care fund currently required under Mill License condition 9.5 is $11893975 This amount is reviewed annually by Denison and the Executive Secretary as required by Mill License condition 9.5 Part I.D of the GWDP provides that upon commencement of decommissioning Denison shall reclaim the Mill site and all related facilities stabilize the tailings cells and construct cover system over the tailings cells in compliance with all engineering design and specifications in the Mills Reclamation Plan In that respect Part I.D.6 of the GWDP provides that before reclamation and closure of any tailings disposal cell the Mill shall ensure that the final design construction and operation of the cover system at each tailings cell will comply with all requirements of the approved Reclamation Plan and will for period of not less than 200 years meet the following minimum performance requirements Minimize infiltration of precipitation or other surface water into the tailings including but not limited to the radon barrier Prevent the accumulation of leachate head within the tailings waste layer that could rise above or over-top the maximum FML liner elevation internal to any disposal cell i.e create bathtub effect and Ensure that groundwater quality at the compliance monitoring wells does not exceed the Groundwater Quality Standards or Groundwater Compliance Limits specified in the GWDP Part I.D.7 also provides that the Co-Executive Secretary reserves the right to require modifications to the Reclamation Plan for purposes of compliance with the Utah Groundwater Quality Protection Regulations including but not limited to containment and control of contaminants or discharges or potential discharges to Waters of the State In order to ensure that the Reclamation Plan meets the requirements of the Utah Groundwater Quality Protection Regulations Part I.H 11 of the GWDP requires that Denison submit for Co Executive Secretary approval an infiltration and contaminant transport modeling report that demonstrates the long-term ability of the tailings cells cover system to adequately contain and control tailings contaminants and protect nearby groundwater quality of the uppermost aquifer Such Report shall demonstrate how the tailings cell engineering design and specifications will comply with the minimum performance requirements of Part I.D.6 of the GWDP Denison submitted work plan for such modeling report for Co-Executive Secretary approval on September 2005 as required and is currently in the process of completing such report 74 This page was revised on August 14 2009 1$%fl %flflk nnnim 0ng nr COST ESTIMATE L4ac.j jÆ/cne c.acMTal4c/S 7b Th n/c pnc rcnc i/.t..vor flC.4 CS Cetc-WS eta en 31 3zg rcrscr 774 ri/a 7p eoic Vc/vnetr 7y J.tc .Ovcr 4tlcc 02577o3.J2x.S4 E.47j%C1 4Sb05c-1 U-SE 5crair 3ZUw.e 61ooc Cj ss .L LLtt tr Vaiwne Cacv-wa-4stL 44Vb MC reQ ISo .4 vfl tC.14 4.s.-t s...r.//.4L/41 Rn ec4-t roQ in Ca aJ 2/Isg/o aarwwecai /Cq.rnt c.c 6/S s-gz 7b.sc_rflcacivc.ev 4if At a.i.i SL .evite .dhc n171/4.A61 4cchrore ia MJ SW MIxxx eatflea I-f- I-trda INTERNATIONAI URANIUM USA CORP COST ESTIMATE S4ttrirs 4-4 nt /olwne Gi..r ____________Wt- 23.c4ya i_.A_ J-2i_ -1 cy/4 CfldStJfl$t$ .i c--4LSiz .c7 h.o.8oc Sot ---C%1S1S3_ItCflImJJ1.L ------- -- vi//aN ie $a2c ad 3S EyeflWCt OW aar2itscflpd 8ªryor.aS 4-snme Pe .2 4Cc 7714e2.eJ .L Scrrynot Wce ch4wtvet ctflcMJ i1tt sTsfr Sock Ccr 4v 2$ .1 .-trn-t INTERNATIONAL URANIUM USA CORP COST ESTIMATE Ccn.tc n.j Soec 2S..5 /9c Saea c-r 4cs SO hr/iivn it 3/0Cy/h ______Zra.ccics IL1- 17c7/Ie ttnllLtij jO4 nt se-c /IetMsf .J tintj. 1t7 L._._- 56 __ _ di r . _ c 3 27 4 f\ \ k- 56 r\ \ / CE L L 61 6 A Bo t t o m El e v a t i o n of Ce l l 1- I 56 0 4 MS L -1 - 1 cM Ch a n n e l In l e t el e v a t i o n 56 0 4 MS L 1a o .a c e % t t // AR E A OF CE L L TO BE BR E A C H E D s% V To p of Be d r o c k sa n d s t o n e 56 1 5 MS L __ _ _ _ _ _ _ _ _ _ _ ti 3t fr o m dr i l l ho l e 95 an d Co n s t r u c t i o n Re p o r t -/ be Ch a n n e l Ou t l e t el e v a t i o n 55 9 6 MS L 4J To p s o i l St o c k p i l e re m o v e d an d us e d fo r re c l a m a t i o n of wi n d b l o w n 4J 7 J 5 7 t 5 f l J \ ff r J5 6 1 I y4 E _X \ cl e a n u p ar e a s aw l Mi l l ar e a fi n a l re c l a m a t i o n 91 C\ 5 6 1 . 5 15 6 1 0. 8 Ce l l 1- I Ou t l e t Ch a n n e l ATTACHMENT CHANNEL AND TOE APRON DESIGN CALCULATIONS OF WHITE MESA FACILITIES BLANDING UTAH PREPARED BY INTERNATIONAL URANIUM USA CORP INDEPENDENCE PLAZA 1050 17TH STREET SUITE 950 DENVER CO 80265 ATTACHMENT 7-RESPONSE TO NRC COMMENTS 7/17/98 TABLE OF SIX-HOUR LOCAL PMP RAINFALL DEPTH VS DURATION FOR WHITE MESA MIL 6-Hour Storm Rainfall is 10 inches ref Hydrologic Design Report for White Mesa Mill 1990 6/1 Hr Ratio for WHITE MESA is 1.22 Figure 4.7 and Table 4.4 HMR 49 ONE-HOUR PMP IS 8.20 inches at 5000 ft elevation 97.0%or 7.95 inches at 5600 ft elevation Plot of data is adaptation of Figure 12.10 HMR 55A to site rainfall Average elevation of site in vicinity of base of cell 4Aeach tanks TIME DISTRIBUTION OF FIRST ONE HOUR OR THE ONE-HOUR PMP after Table 2.1 NUREG CR 4620 DURATION OF RAINFALL DEPTH IN INCHES AT AVERAGE ELEVATION OF HOURS 1-HR PMP based on Table 6.3A HMR 49 0.25 0.5 0.75 74 89 95 100 111 116 119 121 122 5000 ft 0.00 6.07 7.30 7.79 8.20 9.10 9.51 9.75 9.92 10.00 5600 0.00 5.88 7.08 7.55 7.95 8.83 9.22 9.46 9.62 9.70 RAINFALL RAINFALL OF RAINFALL DEPTH IN DURATION DURATION ONE-HOUR AT ELEVATION MINUTES HOURS PMP 2.5 10 15 20 30 45 60 0.04 0.08 0.17 0.25 0.33 0.50 0.75 1.00 27.5 45 62 74 82 89 95 100 5000 ft 2.25 3.69 5.08 6.07 6.72 7.30 7.79 8.20 5600 2.19 3.58 4.93 5.88 6.52 7.08 7.55 7.95 Cl -J -J .L _ J ._ LJ DE P T H VS DU R A T I O N F O R 6- H R PM P WH I T E ME S A MI L L UT A H AT T A C H M E N T R E S P O N S E T O N R C C O M M E N T S 7/ 1 7 / 9 8 12 . 0 0 10 . 0 0 8. 0 0 6. 0 0 4. 0 0 2. 0 0 0. 0 0 DU R A T I O N HO U R S -J -J 9. 0 0 8. 0 0 7. 0 0 00 5. 0 0 4. 0 0 3. 0 0 2. 0 0 1. 0 0 RA I N F A L L - D U R A T I O N CU R V E FO R O N E - H O U R P M P AT WH I T E ME S A MI L L AT T A C H M E N T R E S P O N S E TO N R C CO M M E N T S 7/ 1 7 / 9 8 20 DU R A T I O N HO U R S ATTACHMENT 11 RESPONSES TO NRC COMMENTS 7117198 RATIONAL METHOD CALCULATION OF PMF PEAK DISCHARGE VELOCITY AND DEPTH THROUGH CELL DISCHARGE CHANNEL FLOW PATH ELEMENT ELEMENT LENGTH MAX ELEV MIN GRADIENT ELEV SLOPE ANGLE degrees tc hours RAINFALL WiTHIN to in/hr SURFACE AREA acres PEAK DISCHARGE cfs LONGEST 4800 5655 5610 0.0094 0.54 0.54 7.20 13.43 143 1344 FLOW PARAMETERS IN CELL DISCHARGE CHANNEL AT PEAK PMF DISCHARGE Bedrock Channel Channel Bottom Width ft Channel Side Slopes Channel Gradient fl/ft Manning Coeff On/i .49s.S Flow Depth ft Crosa Section Area of Flow ar2 Hydraulic Radius Rft aRA.S7 Velocity Allowable Peak Velocity fps COE 1970 100 31 0.0100 0.025 226 1.62 169.9 1.54 226.95 7.96 8-10 Bedrock Channel 120 31 0.0100 0.025 226 1.45 180.3 1.40 225.46 7.45 8-10 -J -J RA I N F A L L - D U R A T I O N CU R V E F O R ON E - H O U R P M P AT WH I T E ME S A MI L L AT T A C H M E N T 9- RE S P O N S E TO NR C C O M M E N T S 7/ 1 7 / 9 8 1. 2 0 DU R A T I O N H O U R S 6.5.8 MILDOS AREA Modeling For purposes of this Application the MILDOS AREA modeling for the Mill was updated assuming the Mill was processing high grade Arizona Strip ores at full capacity Section 3.13.42.6 of the Environmental Report discusses this modeling in detail and concludes that1 based on modeling predictions even miming at full capacity in high-grade Arizona Strip ores the maximum potential doses to the public are well within applicable regulatory standards and ALARA goals 6.5.9 Summary of Effectiveness of Environmental Controls and Monitoring As is evident from the various historic environmental monitoring results discussed in this Section the Mill has operated in compliance with all applicable regulatory standards and ALARA goals and in maimer that has not resulted in any significant impacts to public health safety or the environment The MILDOS AREA modeling confirms that based on modeling predictions the current design and operation controls at the Mill are sufficient to result in operations at full capacity processing high-grade ores that are within the regulatory standards and applicable ALARA goals As result of these historic monitoring results and updated modeling it is evident that the Mills equipment facilities and procedures are adequate to minimize danger to public health or the environment and that renewal of the Mills License will not be inimical to the health and safety of the public 65 This page was revised on August 14 2009 6.5.8 MILDOS AREA Modeling For purposes of this Application the MILDOS AREA modeling for the Mill was updated assuming the Mill was processing high grade Arizona Strip ores at full capacity Section 3.13.2.6 of the Environmental Report discusses this modeling in detail and concludes that based on modeling predictions even running at full capacity in high-grade Arizona Strip ores the maximum potential doses to the public are well within applicable regulatory standards and ALARA goals 6.5.9 Summary of Effectiveness of Environmental Controls and Monitoring As is evident from the various historic environmental monitoring results discussed in this Section the Mill has operated in compliance with all applicable regulatory standards and ALARA goals and in manner that has not resulted in any significant impacts to public health safety or the environment The MILDOS AREA modeling confirms that based on modeling predictions the current design and operation controls at the Mill are sufficient to result in operations at full capacity processing high-grade ores that are within the regulatory standards and applicable ALARA goals As result of these historic monitoring results and updated modeling it is evident that the Mills equipment facilities and procedures are adequate to minimize danger to public health or the environment and that renewal of the Mills License will not be inimical to the health and safety of the public 65 This page was revised on August 14 2009 Letter of August 14 2009 to the Executive Secretary of the Utah Radiation Control Board APPENDIX STORM WATER BEST MANGEMENT PRACTICES PLAN for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Blanding Utah June 2008 Prepared by Denison Mines USA Corp 1050 17th Street Suite 950 Denver CO 80265 TABLE OF CONTENTS 1.0 Purpose 2.0 Scope 3.0 Responsibility 4.0 Best Management Practices 4.1 General Management Practices Applicable to All Areas 4.2 Management Practices for Process and Laboratory Areas 4.3 Management Practices for Maintenance Activities 4.4 Management Practices for Ore Pad Tailings Area and heavy Equipment Operations Figures Figure White Mesa Mill Site Map Figure Mill Site Drainage Basins Figure IUSA Mill Management Organization Chart Figure JUSA Corporate Management Organization Chart Tables Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Appendices Appendix White Mesa Mill Spill Prevention Control and Countermeasures Plan Appendix White Mesa Mill Emergency Response Plan Best Management Practices Plan Revision 1.3 June 12 2008 1.0 INTRODUCTION/PURPOSE Denison Mines USA Corp DUSA operates the White Mesa Uranium Mill the Mill in Blanding Utah The Mill is net water consumer and is zero-discharge facility with respect to water effluents That is no water leaves the Mill site because the Mill has no outfalls to public stormwater systems no surface runoff to public stormwater systems no discharges to publicly owned treatment works POTW5 and no discharges to surface water bodies The State of Utah issued Groundwater Discharge Permit No UGW3 70004 to DUSA on March 2005 As part of compliance with the Permit DUSA is required to submit Stormwater Best Management Practices Plan BMPP to the Executive Secretary of the Division of Radiation Control Utah Department of Environmental Quality This BMPP presents operational and management practices to minimize or prevent spills of chemicals or hazardous materials which could result in contaminated surface water effluents potentially impacting surface waters or ground waters through runoff or discharge connections to stormwater or surface water drainage routes Although the Mill by design cannot directly impact stormwater surface water or groundwater the Mill implements these practices in good faith effort to minimize all sources of pollution at the site Page Best Management Practices Plan Revision 1.3 June 12 2008 2.0 SCOPE This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in process operations laboratory operations and maintenance activities and minimize spread of particulates from stockpiles and tailings management areas at the Mill Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this BMPP The Mill site was constructed with an overall grade and diversion ditch system designed to channel all surface runoff including precipitation equivalent to Probable Maximum PrecipitationlProbable Maximum Flood PMP/PMF storm event to the tailings management system In addition Mill tailings all other process effluents all solid waste and debris except used oil and recyclable materials and spilled materials that cannot be recovered for reuse are transferred to one or more of the tailings cells in accordance with the Mills NRC license conditions All of the process and laboratory building sinks sumps and floor drains are tied to the transfer lines to the tailings impoundments site map of the Mill is provided in Figure sketch of the site drainage basins is provided in Figure As result unlike other industrial facilities whose spill management programs focus on minimizing the introduction of chemical and solid waste and wastewater into the process sewers and storm drains the Mill is permitted by NRC license to manage some spills via draining or washdown to the process sewers and ultimately the tailings system However as good environmental management practice the Mill attempts to minimize the number and size of material spills and the amount of unrecovered spilled material and washwater that enters the process sewers after spill cleanup Section 4.0 itemizes the practices in place at the Mill to meet these objectives Requirements and methods for management recordkeeping and documentation of hazardous material spills are addressed in the DUSA White Mesa Mill Spill Prevention Control and Countermeasures SPCCPlan Revised February 2007 the Emergency Response Plan ERP also revised in February 2007 and the housekeeping procedures incorporated in the White Mesa Mill Standard Operating Procedures SOPs The SPCC plan and the ERP are provided in their entirety in Appendices and respectively Page Best Management Practices Plan Revision 1.3 June 12 2008 3.0 RESPONSIBILITY All Mill personnel are responsible for implementation of the practices in this BMPP DUSA White Mesa Mill management is responsible for providing the facilities or equipment necessary to implement the practices in this BMPP The Mill Management Organization is presented in Figure The DUSA Corporate Management Organization is presented in Figure An updated spill prevention and control notification list is provided in Table Page Best Management Practices Plan Revision 1.3 June 12 2008 4.0 BEST MANAGEMENT PRACTICES summary list and inventory of all liquid and solid materials managed at the Mill is provided in Tables through 4.1 General Management Practices Applicable to All Areas 4.1.1 Keep Potential Pollutants from Contact with Soil and Surface Water Store hazardous materials and other potential pollutants in appropriate containers Label the containers Keep the containers covered when not in use 4.1.2 Keep Potential Pollutants from Contact with Precipitation Store bulk materials in covered tanks or drums Store jars bottle or similar small containers in buildings or under covered areas Replace or repair broken dumpsters and bins Keep dumpster lids and large container covers closed when not in use to keep precipitation out 4.1.3 Keep Paved Areas from Becoming Pollutant Sources Sweep paved areas regularly and dispose of debris in the solid waste dumpsters or tailings area as appropriate 4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and Reagent Storage Area Diversion ditches drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly in accordance with the regularly scheduled inspections required by Groundwater Discharge Permit No UGW370004 and Byproduct Materials License UT1 900479 Areas requiring maintenance or repair such as excessive vegetative growth channel erosion or pooling of surface water runoff will be report to site management and maintenance departments for necessary action to repair damage or perform reconstruction in order for the control feature to perform as intended Status of maintenance or repairs will be documented during follow up inspections and additional action taken if necessary 4.1.5 Recycle Fluids Whenever Possible When possible select automotive fluids solvents and cleaners that can be recycled or reclaimed When possible select consumable materials from suppliers who will reclaim empty containers Keep spent fluids in properly labeled covered containers until they are picked up for recycle or transferred to the tailings area for disposal Page Best Management Practices Plan Revision 1.3 June 12 2008 4.2 Management Practices for Process and Laboratory Areas 4.2.1 Clean Up Spills Properly Clean up spills with dry cleanup methods absorbents sweeping collection drums instead of water whenever possible Clean spills of stored reagents or other chemicals immediately after discovery Groundwater Discharge Permit No UGW370004 Section I.D.8.c Recover and re-use spilled material whenever possible Keep supplies of rags sorbent materials such as cat litter spill collection drums and personnel protective equipment PPE near the areas where they may be needed for spill response If spills must be washed down use the minimum amount of water needed for effective cleanup 4.2.2 Protect Materials Stored Outdoors If drummed feeds or products must be stored outdoors store them in covered or diked areas when possible If drummed chemicals must be stored outdoors store them in covered or diked areas when possible Make sure drums and containers stored outdoors are in good condition and secured against wind or leakage Place any damaged containers into an overpack drum or second container 4.2.3 Water Management When possible recycle and reuse water from flushing and pressure testing equipment When possible wipe down the outsides of containers instead of rinsing them off in the sink When possible wipe down counters and work surfaces instead of hosing or rinsing them off to sinks and drains 4.2.4 Materials Management Purchase and inventory the smallest amount of laboratory reagent necessary Do not stock more of reagent than will be used up before its expiration date All new construction of reagent storage facilities will include secondary containment which shall control and prevent any contact of spilled reagents or otherwise released reagent or product with the ground surface Groundwater Discharge Permit No UGW370004 Section I.D.3.e Page Best Management Practices Plan Revision 1.3 June 12 2008 4.3 Management Practices for Maintenance Activities 4.3.1 Keep Clean Dry Shop Sweep or vacuum shop floors regularly Designate specific areas indoors for parts cleaning and use cleaners and solvents only in those areas Clean up spills promptly Dont let minor spills spread Keep supplies of rags collection containers and sorbent material near each work area where they are needed Store bulk fluids waste fluids and batteries in an area with secondary containment double drum drip pan to capture leakage and contain spills 4.3.2 Manage Vehicle Fluids Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible Use drip pans or plastic tarps to prevent spillage and spread of fluids Promptly contain and transfer drained fluids to appropriate storage area for reuse recycle or disposal Recycle automotive fluids if possible when their usefhl life is finished 4.3.3 Use Controls During Paint Removal Use drop cloths and sheeting to prevent windborne contamination from paint chips and sandblasting dust Collect contain and transfer as soon as possible accumulated dusts and paint chips to disposal location in the tailings area authorized to accept waste materials from maintenance or construction activities 4.3.4 Use Controls During Paint Application and Cleanup Mix and use the right amount of paint for the job Use up one container before opening second one Recycle or reuse leftover paint whenever possible Never clean brushes or rinse or drain paint containers on the ground paved or unpaved Clean brushes and containers only at sinks and stations that drain to the process sewer to the tailings system Paint out brushes to the extent possible before water washing water-based paint or solvent rinsing oil-based paint Filter and reuse thinners and solvent whenever possible Contain solids and unusable excess liquids for transfer to the tailings area Page Best Management Practices Plan Revision 1.3 June 12 2008 4.4 Management Practices for Ore Pad Tailings Area and Heavy Equipment Detailed instructions for ore unloading dust suppression and tailings management are provided in the Mill SOPs 4.4.1 Wash Down Vehicles and Equipment in Proper Areas Wash down trucks trailers and other heavy equipment only in areas designated for this purpose such as washdown pad areas and the truck wash station At the truck wash station make sure the water collection and recycling system is working before turning on water sprays 4.4.2 Manage Stockpiles to Prevent Windborne Contamination Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill SOPs Water spray stockpiles as required by opacity standards or weather conditions Dont over-water Keep surfaces moist but minimize runoff water 4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources Schedule excavation grading and other eartbmoving activities when extreme dryness and high winds will not be factor to prevent the need for excessive dust suppression Remove existing vegetation only when absolutely necessary Seed or plant temporary vegetation for erosion control on slopes Page TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Home Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.166 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Home Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE REAGENT YARD LIST REAGENtt2J JAN1TVYLBS NUMBEROFT cApACrry STGMGETANKS .GALLdN ADOGEN 2382 6120 ADVANTAGE 1O1M 2475 AMERSJTE2 AMINE 2384 19440 AMMONIUM SULFATE BULK 54000 AMMONIUM SULFATE BAGS 4300 ANHYDROUS AMMONIA 107920 31409 CHEMFAC 100 12800 CLARIFLOC N-1O1P 3000 DECYLALCOHOL 45430 DIESEL FUEL 250 6000 FLOCCULENT M1O11N 30550 FLOCCULENT M1302C 3550 GRINDING BALLS 48290 ISODECANOL 45430 KEROSENE 1344 10152 MACKANATE 3150 MILLSPERSE 802 1410 NALCO 2458 NALCO 8815 PERCOL 351 1500 PERCOL 406 13950 PERCOL 745 POLOX 10360 POLYHALL YCF PROPANE 30000 SALT BAGS 39280 SALT BULK SODA ASH BAGS 39280 SODA ASH BULK 84100 16921 8530 SODIUM CHLORATE 101128 17700 10500 SODIUM HYDROXIDE 19904 SULFURIC ACID 4801440 1600000 269160 UNLEADED GASOLINE 3000 USED OIL 5000 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 Chemical in Lab RQ2 Quantity In Stock Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 68 kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg Chemical in Volatiles and RQ2 Quantity In Stock Flammables Lockers ABC Chloroform 4.54 kg Formaldehyde 45.4 kg IL of 37%solution Nitrobenzene 454 kg 12L Toluene 454 kg 12 Chemical in Acid Shed RQ2 Quantity In Stock Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Pad 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 .___________0T14INV STORAG ttMPOUNa Acetic Acid Glacial 1000 lbs gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 lbs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs kg 11 lbs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 REAGENT RQ2 QUANTITY IN REAGENT YARD Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfioc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 PRODUCT QUANTITY IN WAREHOUSE Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout 00 0 0 100 200 SC$ I E 0 1 F a S T In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Pr . j . c WH I T E M E S A MIL L ir Cot M y Son .Iu o n Ott o t Ut a h 0j Fi g u r e MIL L S I T E LA Y O U T 0O S I O i l . . 2 0 o tt 4 o v 04 2 0 0 2 tro f l l o p o t to r o n t o By .w o d d C n d ooto i o w n Figure White Mesa Mill Mill Site Drainage Basins Figure White Mesa Mill Mill Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Wh i t e Me s a Mi l l Or g a n i z a t i o n a l St r u c t u r e Fi g u r e Figure Corporate Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Or g a n i z a t i o n a l St r u c t u r e Fi g u r e APPENDICES APPENDIX WRITE MESA MIELL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Bland ing Utah 84511 February 2007 Prepared by Denison Mines USA Corp 1050 7th Street Suite 950 Denver Colorado 80265 TABLE OF CONTENTS SECTION PAGE 1.1 Objective .2 Responsibilities 1.3 Drainage Basins Pathways and Diversions 1.4 Description of Basins 1.4.1 Basin Al 1.4.2 Basin A2 1.4.3 Basin Bl 1.4.4 Basin B2 1.4.5 Basin B3 1.4.6 Basin 1.4.7 Basin 1.4.8 Basin 1.5 Potential Chemical Spill Sources And Spill Containment 1.5.1 ReagentTanks 1.5.2 Ammonia 1.5.3 Ammonium Meta Vanadate 1.5.4 Caustic Storage Sodium Hydroxide 1.5.5 Sodium Carbonate 1.5.6 Sodium Chlorate 1.5.7 Sulfuric Acid 1.5.8 Vanadium Pentoxide 1.5.9 Kerosene Organic 1.6.0 Used/Waste Oil SECTION PAGE 1.6.1 Propane 1.7 Potential Petroleum Sources And Containment 1.7.1 Petroleum Storage Tanks 1.7.1.1 Diesel 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.2 Unleaded Gasoline 1.7.2.3 Pump Station 1.7.2.4 Truck Unloading 1.8 Spill Discovery And Remedial Action 1.9 Spill Incident Notifications 1.9.1 External Notification 1.9.2 Internal Notification 11 1.10 Records And Reports 12 1.11 Personnel Training And Spill Prevention Procedures 12 1.11.1 Training Records 12 1.11.2 Monitoring Reports 13 1.12 Revision 13 1.13 Summary 13 1.14 Mill Manager Approval 14 1.15 Certification by Registered Professional Engineer 14 LIST OF TABLES Table 1.0 Mill Organization Chart Table 2.0 Reagent Tank List Table 3.0 Laboratory Chemical Inventory List Table 4.0 Reagent Yard/Small Quantity Chemicals List Table 5.0 Reagent Yard/Bulk Chemicals List Table 6.0 Petroleum Products and Solvents List LIST OF FIGURES Figure Mill Site Layout Figure Mill Site Drainage Basins WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS 1.1 OBJECTIVE The objective of the Spill Prevention Control and Countermeasures SPCC Plan is to serve as site-specific guideline for the prevention of and response to chemical and petroleum spills and as guidance document for compliance with Groundwater Discharge Permit No UGW370004 The plan outlines spill potentials containment areas and drainage characteristics of the White Mesa Mill site The plan addresses chemical spill prevention spill potentials spill discovery and spill notification procedures The Oil Pollution Prevention Sections of the Clean Water Act 40 CFR 112 to 117 also referred to as the Spill Prevention Control and Countermeasures SPCCrules establish requirements that apply to facilities which could reasonably be expected to discharge oil in quantities that may be harmful as described in that Act into or upon the navigable waters of the United States or that may affect natural resources of the United States Section 112 states that the Act is not applicable to facilities that are not subject to the authority of the Environmental Protection Agency EPA for one of the following reasons Due to its location the facility could not reasonably be expected to discharge oil into navigable waters of or impact natural resources of the U.S or The facility is subject to authority of the Department of Transportation as defined in Memorandum of Understanding MOU between the Secretary of Transportation and the EPA Administrator or The facility does not exceed either the underground or the above ground storage capacity 42000 gallons and 1320 gallons respectively prescribed in the rules The Mill could not reasonably be expected as described in the SPCC regulation to discharge oil into the navigable waters or impact natural resources of the U.S The Mill site was constructed with an overall grade and diversion ditch system designed to channel the non-recovered portion of any material spill to the tailings management system Hence it is not reasonable to expect that surface spills will ever reach navigable waters or natural resources of the U.S or Utah Therefore the SPCC reporting requirements in the Clean Water Act are not applicable to the Mill However as good environmental management practice the Mill has implemented the spill management program described in this document which is consistent with the intent of the Clean Water Act to the extent practicable Although the Mill by design cannot directly impact navigable waters of the U.S and as result spills that may occur but are retained within the site would not be reportable the Mill implements these practices in good faith effort to minimize all potential sources of pollution at the site Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this SPCC Ammonia is the only chemical that has the potential to leave the site and would do so as vapor Figure Site Layout Map shows map of the mill site including the locations of the chemical tanks on-site Figure shows the basins and drainage ditch areas for the mill site Table 1.0 is an organization chart for Mill operations Table 2.0 lists the reagent tanks and their respective capacities Table 3.0 lists the laboratory chemicals their amounts and their reportable quantities Table 4.0 lists the operations chemicals Table 5.0 lists the chemicals in the reagent yard their amounts and their reportable quantities Table 6.0 lists the petroleum products and solvents on site 1.2 RESPONSIBILITIES Person in charge of facility responsible for spill prevention Mr Richard Bartlett Interim Mill Manager 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 459-2495 home Person in charge of follow-up spill record keeping and/or reporting Mr David Turk Department Head Health Safety and Environmental 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 678-7802 home Refer to Section 1.9 Spill Incident Notification for list of company personnel to be notified in case of spill In addition an organizational chart is provided in Table 1.0 1.3 DRAINAGE BASINS PATHWAYS AND DIVERSIONS The main drainage pathways are illustrated in Figure The map shows drainage basin boundaries flow paths constructed diversion ditches tailings cells the spillway between Cell and dikes berms and other relevant features The White Mesa Mill is zero discharge facility for process liquid wastes The mill area has been designed to ensure that all spills or leaks from tanks will drain toward the lined tailings cells The tailings cells in turn are operated with sufficient freeboard minimum of three feet to withstand 100%of the PMP Probable Maximum Precipitation This allows for maximum of 10 inches of rain at any given time 1.4 DESCRIPTION OF BASINS Precipitation and unexpected spills on the mill property are contained within their respective drainage basins Runoff would ultimately drain into one of the three lined tailings cells 1.4.1 Basin Al Basin Al is north of Cell 1-I and Diversion Ditch No The basin contains 23 acres all of which drain into Westwater Creek This area is not affected by mill operations 14.2 Basin A2 Basin A2 contains all of Cell 1-I including an area south of the Diversion Ditch No The basin covers 84 acres Any runoff from this basin would be contained within Cell 1-I 1.4.3 Basin BI Basin Bl is north of the mill property and is not affected by mill operations The basin contains 45.4 tributary acres Runoff from this basin drains into flood retention area by flowing through Diversion Ditch No Diversion Ditch No drains into Westwater Creek 1.4.4 Basin B2 Basin B2 is northeast of the mill and contains only 2.6 acres Runoff from this basin would drain into Diversion Ditch No Diversion Ditch No ultimately drains into Diversion Ditch No This basin is not affected by mill operations 1.4.5 Basin B3 Basin B3 contains most of the mill area buildings ore stockpiles process storage tanks retention ponds spill containment structures pipelines and roadways The normal direction of flow in this basin is from the northwest to the southwest Any runoff from this basin would drain into Cell 1-I The basin contains 64 acres This basin has sufficient freeboard to withstand 100%of the PMP Probable Maximum Precipitation This allows 10 inches of rain for any given storm event 1.4.6 Basin Basin contains all of Cell The basin consists of 80.7 acres This basin contains earth stockpiles and the heavy equipment shop The direction of flow in this basin is to the southwest All runoff in this basin would be channeled along the southern edge of the basin Runoff would then flow into Cell via the spillway from Cell to Cell 1.4.7 Basin Basin contains all of Cell This basin consists of 78.3 acres including portion of the slopes of the topsoil stockpile and random stockpile The basin contains all flows including those caused by the PMF 1.4.8 Basin Basin contains Cell 4A and consists of 43.3 acres All anticipated flows including those caused by the PMF will be contained within the basin and will flow directly into Cell 4A 1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT This section details potential sources of chemical spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.5.1 Reagent Tanks Tank list included in Table 2.0 1.5.2 Ammonia The ammonia storage tanks consist of two tanks with capacity of 31409 gallons each The tanks are located southeast of the Mill building Daily monitoring of the tanks for leaks and routine integrity inspections will be conducted to minimize the hazard associated with ammonia The reportable quantity for an ammonia spill is gallons Ammonia spills should be treated as gaseous Ammonia vapors will be monitored closely to minimize the hazard associated with inhalation If vapors are detected efforts will be made to stop or repair the leak expeditiously Ammonia is the only chemical as vapor that has the potential to leave the site 1.5.3 Ammonia Meta Vanadate Ammonia meta vanadate is present in the SX building as the process solutions move through the circuit to produce the vanadium end product But the primary focus will be on the transportation of this chemical The reportable quantity for an ammonia meta vanadate spill is 1000 pounds 1.5.4 Caustic Storage Sodium Hydroxide The caustic storage tank is located on splash pad on the northwest corner of the SX building The tank has capacity of 19904 gallons The tank supports are mounted on concrete curbed catchment pad that directs spills into the sand filter sump in the northwest corner of the SX building The reportable quantity for sodium hydroxide spill is 85 gallons 1.5.5 Sodium Carbonate Soda Ash The soda ash solution tank has capacity of 16921 gallons and is located in the northeast corner of the SX building The smaller soda ash shift tank has capacity of 8530 gallons and is located in the SX building Spills will be diverted into the boiler area and would ultimately drain into Cell 1-I There is no reportable quantity associated with sodium carbonate spill 1.5.6 Sodium Chlorate Sodium chlorate tanks consist of two fiberglass tanks located within dike east of the SX building The larger tank is used for dilution purposes and has maximum capacity of 17700 gallons The smaller tank serves as storage tank and has capacity of 10500 gallons Daily monitoring of the tanks for leaks and integrity inspections will be conducted to minimize the hazard associated with sodium chlorate Sodium chlorate that has dried and solidified becomes even more of safety hazard due to its extremely flammable nature The reportable quantity for sodium chlorate spill is 400 gallons 1.5.7 Sulfuric Acid The sulfuric acid storage tanks consist of one large tank with the capacity of 16000000 gallons and two smaller tanks with capacities of 269160 gallons each The large tank is located in the northwest corner of mill area basin B3 and is primarily used for acid storage and unloading The tank support for the large tank is on mound above depression which would contain significant spill All flows resulting would be channeled to Cell 1-I The tank is equipped with high level audible alarm which sounds prior to tank overflows concrete spill catchment with sump in the back provides added containment around the base of the tank However the catchment basin would not be able to handle major tank failure such as tank rupture The resulting overflow would flow towards Cell 1-I The two smaller storage tanks are located within an equal volume spill containment dike east of the mill building The tanks are not presently in use but are equipped with high level audible alarms The reportable quantity for sulfuric acid spill is 65 gallons 1000 pounds 1.5.8 Vanadium Pentoxide Vanadium pentoxide is produced when vanadium is processed through the drying and fusing circuits and is not present in the vanadium circuit until after the deammoniator Efforts will be made to minimize leaks or line breaks that may occur in processes in the circuit that contain vanadium pentoxide Special care will be taken in the transportation of this chemical The reportable quantity for vanadium pentoxide spill is 1000 pounds 1.5.9 Kerosene Organic The kerosene storage area is located in the central mill yard and has combined capacity of 10152 gallons in three tanks Any overflow from these three tanks would flow around the south side of the SX building and then into Cell 1-I These tanks have drain valves which remain locked unless personnel are supervising draining operations The reportable quantity for kerosene spill is 100 gallons 1.6.0 Used Waste Oil Used Waste oil for parts washing is located north of the maintenance shop in tank and has capacity of 5000 gallons The tank is contained within concrete containment system Ultimate disposal of the used oil is to an EPA permitted oil recycler Any oil escaping the concrete containment system will be cleaned up Soil contaminated with used oil will be excavated and disposed of in Cell 1.6.1 Propane The propane tank is located in the northwest corner of the mill yard and has capacity of 30000 gallons Daily monitoring of the tank for leaks and integrity inspections will be conducted to minimize potential hazards associated with propane leaks Propane leaks will be reported immediately There is no reportable quantity associated with propane spill 1.7 POTENTIAL PETROLEUM SPILL SOURCES AND CONTAINMENT This section details potential sources of petroleum spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.7.1 Petroleum Tanks 1.7.1.1 Diesel Two diesel storage tanks are located north of the mill building The tanks have capacities of 250 gallons each One of the diesel tanks is for the emergency generator The other tank is located in the pumphouse on an elevated stand Spillage from either tank would ultimately flow into Cell 1-I The reportable quantity for diesel spill is 100 gallons 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.1 Diesel The diesel tank is located on the east boundary of Basin B3 and has capacity of 6000 gallons The tank is contained within concrete catchment pad The reportable quantity for diesel spill is 100 gallons 1.7.2.2 Unleaded Gasoline The unleaded gasoline tank is located next to the diesel tank The unleaded gasoline tank has capacity of 3000 gallons and is contained within the same containment system as the diesel tank The reportable quantity for an unleaded gasoline spill is 100 gallons 1.7.2.3 Pump Station Both the diesel and the unleaded gasoline tanks will be used for refueling company vehicles used around the mill site The pump station is equipped with an emergency shut-off device in case of overflow during fueling In addition the station is also equipped with piston leak detector and emergency vent Check valves are present along with tank monitor console with leak detection system The catchment is able to handle complete failure of one tank However if both tanks failed the concrete catchment pad would not be able to contain the spill In this case temporary berm would need to be constructed Absorbent diapers or floor sweep would be used in an effort to limit and contain the spill The soil would be cleaned up and placed in the authorized disposal area in Cell 1.7 2.4 Truck Unloading In the event of truck accident resulting in an overturned vehicle in the mill area proper reporting and containment procedures will be followed when warranted such as when oil or diesel fuel is spilled Proper clean-up procedures will be followed to minimize or limit the spill The spill may be temporarily bermed or localized with absorbent compounds Any soils contaminated with diesel fuel or oil will be cleaned up and placed in the authorized disposal area in Cell 1.8 SPILL DISCOVERY AND REMEDIAL ACTION Once chemical or petroleum spill has been detected it is important to take measures to limit additional spillage and contain the spill that has already occurred Chemical or petroleum spills will be handled as follows The Shift Foreman will direct efforts to shut down systems if possible to limit further release The Shift Foreman will also secure help if operators are requiring additional assistance to contain the spill The Shift Foreman is also obligated to initiate reporting procedures Once control measures have begun and personal danger is minimized the Shift Foreman will notify the Production Superintendent Maintenance Superintendent or Mill Manager The Production or Maintenance Superintendent will notify the Mill Manager who in turn will notify the Environmental Health and Safety Manager The Mill Manager will assess the spill and related damage and direct remedial actions The corrective actions may include repairs clean up disposal and company notifications Government notifications may be necessary in some cases If major spill continues uncontrolled these alternatives will be considered Construct soil dikes or pit using heavy equipment Construct diversion channel into an existing pond Start pumping the spill into an existing tank or pond Plan further clean-up and decontamination measures 1.9 SPILL INCIDENT NOTIFICATION 1.9.1 External Notification As stated in Section 1.1 spills are not expected to reach navigable waters of the United States If spill of reportable quantity occurs then mill and corporate management must be notified and they will evaluate whether or not the following agencies must be notified EPA National Response Center 1-800-424-8802 State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah 801/538-7200 Water Quality Division 801/538-6146 In case of tailings dam failure contact the following agencies State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah Natural Resources 801/538-7200 1.9.2 Internal Notification Internal reporting requirements for incidents spills and significant spills are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions and accidents Government investigations information requests or enforcement actions Private actions or claims corporate or employee Deviations from corporate policies or government requirements by management Which have or could result in the following Death serious injury or adverse health effects Property damage exceeding $1000000 10 Government investigation or enforcement action which limits operations or assesses penalties of $100000 or more Publicity resulted or anticipated Substantial media coverage Report At The Beginning Of The Next Day Event Criteria Was reported to government agency as required by law Worker employee or contractor recordable injury or illness associated with release Community impact-reported or awareness Publicity resulted or anticipated Release exceeding the reportable quantities listed in Section 1.5 for each specific process material waste or by-product In the event of spill of reportable quantity the Mill Manager is required to call the Corporate Environmental Manager or the President and Chief Executive Officer The individual first discovering the spill will report it to the Shift Foreman Production Superintendent or Maintenance Superintendent who will in turn ensure that the Mill Manager is notified The Environmental Health and Safety Manager will also be contacted by the Mill Manager Name Title Home Phone Mill Personnel Richard Bartlett Interim Mill Manager 435 678-2495 Wade Hancock Maintenance Foreman 435 678-2753 David Turk Environmental Health and Safety Manager 435 678-7802 N/A Production Superintendent N/A Maintenance Foreman Scot Christensen Mill Shift Foreman 435 678-2015 Corporate Personnel Ronald Hochstein President and Chief Operating Officer 604 377-1167 David Frydenlund Vice President and General Counsel 303 221-0098 In the event the next person in the chain-of-command cannot be reached then proceed up the chain-of-command to the next level Table 1.0 shows the organizational chart for the mill site 11 1.10 RECORDS AND REPORTS The following reports and records are to be maintained in Central Files by the Environmental Health and Safety Manager for inspection and review for minimum of three years Record of site monitoring inspections Daily Tailings Inspection Data Weekly Tailings Inspection and Survey Monthly Tailings Inspection Pipeline thickness Quarterly Tailings Inspection Tank to soil potential measurements Annual bulk oil and fuel tank visual inspections Tank and pipeline thickness tests Quarterly and annual PCB transformer inspections if transformer contains PCBs Tank supports and foundation inspections Spill Incident Reports Latest revision of SPCC plan 1.11 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES All new employees are instructed on spills at the time they are employed and trained They are briefed on chemical and petroleum spill prevention and control They are informed that leaks in piping valves and sudden discharges from tanks should be reported immediately Abnormal flows from ditches or impoundments are of immediate concern In addition safety meeting is presented annually by the Environmental Health and Safety Manager to review the SPCC plan 1.11.1 Training Records Employee training records on chemical and petroleum spill prevention are maintained in the general safety training files 1.11.2 Monitoring Reports Shift logs shall provide checklist for inspection items 12 1.12 REVISION This procedure is to be reviewed by the mill staff and registered professional engineer at least onc eve ry th ree years and updated when circumstances warrant revision 1.13 Summary Below is table listing the specific reportable quantities associated with the major chemical and petroleum products on-site CHEMICAL REPORTABLE QUANTITY RQ AMMONIA 100 POUNDS AMV 1000 POUNDS SODIUM HYDROXIDE 1000 POUNDS SODA ASH No Reportable Quantity SODIUM CHLORATE 400 GALLONS SULFURIC ACID 1000 POUNDS VANADIUM PENTOXIDE 1000 POUNDS KEROSENE 100 GALLONS OIL No Reportable Quantity PROPANE No Reportable Quantity DIESEL UNLEADED FUEL 100 GALLONS 13 1.14 MILL MANAGER APPROVAL hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with the Standard Operating Procedures currently in effect 4/Car Richard Bartlett Interim Mill Manager 1.15 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with good engineering practices Harold Roberts Registered Professional Engineer State of Utah No 165838 14 TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Home Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.166 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Home Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE 2.0 REAGENT TANK LIST QUANTITY REAGENT CAPACITY GAL DIESEL 250 KEROSENE 10152 USED/WASTE OIL 5000 DIESEL 6000 UNLEADED 3000 PROPANE 30000 AMMONIA 31409 SODIUM HYDROXIDE 19904 SODA ASH SOLUTION 16921 SODA ASH SHIFT 8530 SODIUM CHLORATE 17700 SODIUM CHLORATE 10500 SULFURIC ACID 1600000 SULFURIC ACID 269160 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 Jj Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 6.8 kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg tIfethia11nVlatiIØiandi QUntiW1nSbŁkT FlammablestockerstBCL -- -- -t r-c- Chloroform 4.54 kg Formaldeh1e 45.4 kg IL of 37%solution Nitrobenzene 454 kg 12L Toluene 454 kg 12L RyH QUahtitWitStokH Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 tHEMICAtI ItJJIT fiQZIt QIJANTIfiN STCRAE -T7-6OMROUND Acetic Acid Glacial 1000 lbs gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 Ibs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs 5kg IlIbs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal 5kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act Sulfuric Acid Floc 301 TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 Hype nbc 102 Ammonia East Tank Ammonia West Tank Kerosene Salt Bags Ammonium Hydrogendifluonide Soda Ash Dense Bag Phosphoric Acid Polyox illsperse Nalco TX760 Nalco 7200 Tributyl phosphate Distillates Diesel Gasoline Alamine 336 drums Fboc 109 Floc 208 Floc 904 Hyperfloc 624 Salt Bulk solids Salt Bulk solutions Caustic Soda Ammonium Sulfate Sodium Chlorate Alamine 335 Bulk Alamine 310 Bulk lsodecanol Vanadium Pentoxide3 Yellowcake3 Ammonia Meta Vanadate This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard REAGENT RQ2 QUANTITYIN REAGENTXARD 0b0 lbs None None 100 lbs 100 lbs 100 gal None None None 5000 lbs None None None None None None 100 gal 100 gal None None None None None None None 1000 lbs None None None None None 1000 lbs None 1000 lbs 9000000 lbs 1200 lbs 1500 lbs lbs 105000 lbs 500 gal 2000 lbs 20450 lbs lbs 6300 lbs 490 lbs 1410 lbs barrels 1590 lbs 9450 lbs 100 gal Approx 3300 gal Approx 6000 gal lbs lbs lbs lbs lbs lbs lbs lbs lbs 20000 lbs lbs lbs lbs 30000 lbs 100000 lbs lbs TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distfllates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT -.QUANTIfl4N WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout GR I Z Z L Y DE c O N T A M I N A T I O N PA D DIE S E L SA M P L E PL A N TLi rt _ 2r se n t pi vs e t Figure White Mesa Mill Mill Site Drainage Basins APPENDIX WRITE MESA MILL EMERGENCY RESPONSE PLAN EMERGENCY RESPONSE PLAN REVISION 1.1 Denison Mines USA Corp nn..4.aa--iaiiVVIIIICIVICScLIVEIlI Blanding Utah April14 1986 REVISED February 16 2007 Distribution List Ron Hochstein Rich Bartlett David Turk Michael Spillman Mill Shift Foremen Blanding Fire Department San Juan County EMS Coordinator State of Utah Department of Radiation Control Revision Date January 16 2006 TABLE OF CONTENTS Page Number 1.0 Introduction .1 2.0 White Mesa Mill Background .1 3.0 Plan Objectives 4.0 Description of Facilities 4.1 Fire Water Supply and Alarm Systems 4.2 Office Building and Laboratory 4.3 Solvent Extraction Building 4.4 Mill Building 4.5 Maintenance Shop/Warehouse/Change Room Building 4.6 Reagent and Fuel Storage 4.7 Boiler House 4.8 Sample Plant 5.0 Organization and Responsibilities 5.1 Mill Manager/Incident Commander 5.2 Operations Superintendent 5.3 Radiation Safety Officer/Fire Chief 5.4 Maintenance Supervisor 5.5 Laboratory Supervisor 5.6 Shift Foremen 5.7 Scale House Personnel 5.8 Emergency Response Teams 6.0 Specific Emergencies 10 6.1 Fire 10 6.2 Chemical or Gas Release 10 6.3 Earthquake 10 6.4 Terrorist/Bomb Threat 10 6.5 Tailings Dam Break and Major Floods 10 7.0 Evacuation Procedure 11 7.1 Notification 11 7.2 Assembly 11 7.3 Specific Procedures for Operations Personnel 11 8.0 Off-Site Emergency Equipment/Personnel Release 11 9.0 Emergency Equipment 12 9.1 Fire Hose 12 9.2 Self Contained Breathing Apparatus 12 9.3 Spill Clean-up Equipment 12 9.4 Fire Fighting PPE 12 10.0 Emergency Transportation 13 11.0 Emergency Evacuation Drills 13 EXHIBITS Emergency Notification List E- Internal Notifications E-2 Site Layout Map E-3 Main Shut-off Valves E-4 APPENDICES Emergency Procedure Response to Fire A-I Emergency Procedure Response to Chemical or Gas Release A-2 Emergency Evacuation Procedure A-3 FIGURES Fire System Schematic F-I i-i INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WRITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 INTRODUCTION This Emergency Response Plan is written not only to comply with Federal State and local regulations but even more importantly to reduce the risk to our employees and that of the community in regards to Health Safety and Environmental Emergencies This plan includes the following evaluation of the potential risks for fire explosions gas releases chemical spills and floods including tailings dam failure specific emergency programs for each potential event definition of administrative response actions and definition of the emergency response contacts both internal and external The White Mesa Mill the Mill operates under the following regulatory agencies Utah State Department of Environmental Quality Division of Radiation Control Mine Safety and Health Administration Environmental Protection Agency Utah State Department of Environmental Quality Division of Air Quality and Utah State Division of Natural Resources Bureau of Dam Safety WIIITE MESA MILL OVERVIEW The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and vanadium In addition to the processing of conventional ores the Mill also processes alternate feed materials using similar process steps and chemicals The conventional ore is stored on the Ore Pad shown in Exhibit Alternate feed materials are also stored on the Ore Pad and may be stored in bulk form lined burrito bags liners or drums The descriptions of each alternate feed material are maintained by the Mills Radiation Safety Officer The Mill utilizes semi-autogenous grind circuit followed by hot sulfuric acid leach and solvent extraction process to extract uranium and vanadium from ores using large amounts of sulfuric acid sodium chlorate kerosene amines ammonia and caustic soda in the process The reagent storage tank locations are described in further detail in Section 4.6 Emissions from the Mill process are in the form of air emissions from exhaust stacks and solid/liquid tailings which are stored in the Mills tailings cells located west/southwest of the main Mill building The major exhaust stack parameters are shown in the following table Description Height ft from surface Diameter inches Estimated Flow Rate cfln Leach Exhaust l00 36 13700 Yellow Cake Drying stacks --85 18 4000 per stack Vanadium Roasting Fusion 85 38 4100 P\Admin\Master 5OPs\Book 16 Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 There are also smaller exhaust stacks associated with the Laboratory in the Mill Administration building and the boiler exhaust stack The Mills tailings cells are comprised of four below grade engineered cells Cell 1-I and 4A Liquids are stored in Cell 1-I and Cell the active tailings cell The liquid in the tailings cells is very acidic In addition to the tailings cells there is also an emergency lined catchment basin west of the Mill building Solutions in this basin or the tailings cells should not be used to fight fires in the Mill facility The products of the Mill include ammonium metavanadate AMV vanadium pregnant liquor VPL vanadium pentoxide V205 and yellowcake or uranium concentrate U3O8 The V205 and U308 products are packaged in steel drums for shipment The AMY is packaged in either steel drums or super-saks while the VPL is sold in liquid form in bulk Master files containing Material Safety Data Sheets for all materials in use at the Mill are maintained at the Safety Office Mill Maintenance Office Mill Laboratory and Mill Central Control Room Copies are also on file at the Blanding Clinic Doctors Offices Blanding Fire House and Office of the San Juan County Emergency Medical Coordinator The nearest residence to the Mill is approximately one mile to the north of the Mill the next is residence approximately two miles north of the Mill followed by the community of White Mesa about 3.5 miles to the south The City of Blanding is located approximately miles to the northeast The Mill site is near Utah State Highway 191 and can be accessed by paved access road from the highway to the Mill facilities PLAN OBJECTIVES The primary objectives of this plan are To save lives prevent injuries prevent panic and minimize property/environmental damage to the lowest possible level To evacuate and account for all people in the area including visitors truck drivers contractors etc To provide assembly areas that are as safe as possible and which can be reached without traveling through hazardous area Assembly areas will be properly manned to deal with sick or injured persons and provisions will be made to evacuate those persons to proper shelter To make adequately trained personnel available to cope with rescue and recovery operations as directed by the Incident Commander DESCRIPTION OF FACILITIES The Mill facilities are shown on the Site Layout Map included as Exhibit P\Admin\Master SOPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No It-I Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.1 Fire Water Supply and Alarm Systems 4.1.1 Fire Water Supply The fire water supply facilities include 400000 gallon Storage Tank of which 250000 gallons are reserved for fire emergencies Centrifugal diesel driven pump rated at 2000 gpm at 100 psi This pump starts automatically when the pressure in the fire main drops below 100 psi See Figure Fire System Schematic When more water is needed for an emergency an additional source is the Recapture Reservoir supply pipeline which can be utilized in emergencies at rate of about 1200 gpm 4.1.2 Alarm System The alarm systems include the following public address system hand held radios siren 4.2 Office Building and Laboratory 4.2.1 Office Building The office building approximately 10000 square feet contains the administration offices radiation health and safety offices and the Mill laboratory The central file vault and the main computer system are also in this building The ambulance is kept on the west side of the office building near the safety office entrance 4.2.2 Laboratory The laboratory facilities contain the following three flammable cabinets keys required chemical storage room south of main lab six fume hoods hoods 12 and are in the center of the laboratory and hoods and are along the west wall Hoods and are no longer in service Hoods and are on the west side and are on the east side of the center cluster of hoods with being in front Only hoods and may be used for perchloric acid outside laboratory chemical storage north of office building key required perchloric acid storage vault located underground west of office building key required wide variety of chemicals in small quantities are located in the laboratory These chemicals range from acids to bases along with flammable metal compounds and peroxide forming compounds Oxidizers and organic chemicals which have strong potential of producing harmful vapors if the containers are damaged to the point that the chemicals are exposed are stored in storage room in the laboratory There are no acids stored in this storage room The acids including but not limited to sulfuric nitric acetic perchloric phosphoric and hydrochloric acids are stored in the main laboratory area in 2.5 liter or 500-mi bottles MSDS books for all P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 chemicals in the laboratory are located in the Laboratory Safety Department Mill Maintenance office and Mill Central Control room 4.2.3 Electrical Electrical transfonners and electrical switches are located in the laboratory at the east end of the chemical storage room 4.2.4 Fire Protection System The fire protection systems in the office building and laboratory include fire hose station located on the east end of the office building The station includes two sets of turnout gear two SCBA units and Incident Commander materials automatic wet sprinlder system which is actuated at 212 portable dry chemical extinguishers strategically located throughout the building 4.3 Solvent Extraction Building The solvent extraction SX building approximately 21000 square feet houses the uranium and vanadium solvent extraction circuits and the ELUEX circuit The SX circuits may contain up to 200000 gallons kerosene 757000 liters which has flash point of 185 Associated equipment in the SX building includes temporary boiler located at the southwest end of the SX building which maintains the temperature for the fire system Chemicals which may be encountered in the SX building include Kerosene Caustic Soda Anhydrous Ammonia Sulthric Acid Salt Brine Soda Ash Ammonium Sulfate Amines Alcohol Sodium Chlorate Sodium Vanadate Propane The VPL product is stored in the SX building 4.3.1 Electrical All electrical switches are located outside in the MCC room north of the SX building The main control panel for all of the equipment is located in the Central Control Room in the main Mill building 4.3.2 Fire Protection System The SX building fire protection systems include P\Admin\Master 5OPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc iNTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 wet AFFF foam sprinider system with heat actuated sprinkler heads that release at 12F portable dry chemical extinguishers strategically located throughout the building For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic included as Figure in this Plan 4.4 MIII Building The mill building approximately 22000 square feet contains process equipment related to grind leach counter current decantation precipitation drying and packaging of uranium and vanadium products Chemicals which may be encountered in the mill building include Caustic Soda Anhydrous Ammonia Sulfuric Acid Soda Ash Ammonium Sulfate Sodium Chlorate Sodium Vanadate Propane The finished products which are contained in the mill building include AMY V7O5 and U3O3 or yellowcake 4.4.1 Electrical The main electrical switch gear is located west of the SAG mill on the ground floor in the north west corner of the mill building Circuit control panels are located in the SAG mill control room the central control room the vanadium roaster control room and the AMY area 4.4.2 Fire Protection System The main mill building fire protection systems include portable dry chemical extinguishers strategically located throughout the building water hoses throughout the building For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System Schematic included as Figure of this Plan 4.5 Maintenance Shop/Warehouse/Change Room Building This building approximately 20000 square feet contains the main maintenance shop area located on the north end of the building the main warehouse located on the south end of the building and the personnel change rooms and lunchltraining room located on the extreme south end of the building on the ground and second floors Within the maintenance shop area are the following work area and specialty shops P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 the main maintenance shop area contains welding and cuffing equipment lathes presses and drill presses carpenter shop which contains various saws and planes Fiberglass work is also done within this shop area and it is located at the northwest end of the maintenance shop area an electrical shop which is located south of the carpenter shop heavy equipment maintenance shop area is located at the north end of the maintenance shop in the center of the building rubber room for rubber lining of equipment is located east of the equipment shop area the maintenance shop office instrument shop and tool room are located at the south end of the maintenance shop area The warehouse area contains primarily dry good storage for repair parts and consumables for the operation of the Mill There is an electrical water heater for the change room which is located in the warehouse area at the south end Within the warehouse and maintenance shops there are some oils and chemicals stored in the following locations smail quantities of flammable material such as starting fluid and spray paint are kept in the warehouse drums of new oil and anti-freeze are stored along the east wall of the equipment maintenance area and on the east side of the warehouse on oil storage racks used oil is stored in tank located northeast of the equipment shop The tank has capacity of approximately 5800 gailons in the main maintenance shop area and the rubber room there are flammable storage cabinets and east of the warehouse there is trailer which is used to store flammable items such as rubber cements paints and fiberglass resins compressed gas cylinder storage both empty and full is located outside east of the maintenance shop 4.5.1 Electrical The main electrical circuit breaker for the maintenance shop and warehouse building is located on the east wail inside the Maintenance shop Auxiliary electrical panels for the change room and warehouse are located in the southwest corner of the warehouse area 4.5.2 Fire Protection System The fire protection system within the maintenance shop/warehouse/change room building includes wet automatic sprinkler system that releases at 212 portable dry chemical extinguishers strategically located throughout the maintenance area warehouse area and the change room and lunch room For fire hydrant and hose cabinet locations refer to the Fire System Schematic Figure 4.6 Reagent and Fuel Storage The following lists the reagents and fuel stored at the Mill site P\Admin\Master SOPs\Book 16_Emergency Response PJan\Emergency Response Plan Rev 09.29.05.doc IIJTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 sulfuric acid tank located northwest of the mill building which has capacity of approximately 1.4 million gallons storage tank for propane is located on the north edge of the mill site northwest of the mill building It has storage capacity of 30000 gallons four sodium chlorate tanks located east of SX building north of the office building and east of the pulp storage tanks The two tanks east of the SX building are for sodium chlorate storage and the other two tanks are for dilution of the sodium chlorate two anhydrous ammonia tanks located east of the SX building with capacity of 31409 gallons each three kerosene tanks located east of the SX building with capacity of 10152 gallons each one caustic soda tank north of the SX building with capacity of 19904 gallons three soda ash tanks which are located east of the SX building One tank is the dry soda ash tank with capacity of 70256 gallons Two of the tanks are soda ash dilution tanks with capacities of 16921 gallons each diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad The gasoline storage capacity is 3200 gallons while diesel storage capacity is 8000 gallons Other reagents are stored in steel barrels or super sacs in reagent yard located east of the office building Typical reagents which are stored in this yard include polymers and flocculants boiler feed water chemicals methanol tributyl phosphate dirty soda ash and ammonium sulfate SX ainines and emulsion breakers decyl alcohol minimal amounts of acid in barrels used oil in drums and overpacks 4.7 Boiler Facilities The main building approximately 12400 square feet is located on the west side of the Mill site and contains air compressors and water treatment facilities To the north of the main building is building which houses propane-fired boiler The vanadium oxidation tank oxidation thickener and pH adjustment tank are located south of the boiler house facilities 4.7.1 Electrical The main electrical panel for the boiler house is located outside of the building on the south wall 4.7.2 Fire Protection System The fire protection system for the boiler facilities is comprised of strategically located portable dry chemical extinguishers P\Admin\Master 5OPs\Boolc 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc iNTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.8 Sample Plant The sample plant building approximately 8000 square feet is located on the ore pad east of the maintenance shop/warehouse building The sampling plant equipment has been removed from the building and it is currently used as storage area for maintenance 4.8.1 Electrical The electrical panel for this building is located on the east wall upstairs 4.8.2 Fire Protection System There are no extinguishers or sprinkler systems in the sample plant ORGANIZATION AND RESPONSIBILITIES The organizational chart for an emergency situation is illustrated in Figure 5.1 Mill Manager/Incident Commander The Incident Commander has the responsibility for preparing an Emergency Plan communicating the Plan directing activities during emergencies and reporting to local State and Federal authorities The Incident Commander will stop routine radio usage upon learning of an emergency and set up the base station in safe location for directing activities Radio usage will be limited to the emergency The Incident Commander has the responsibility to contact all outside services The Incident Commander has the responsibility to account for all employees at the Mill using the assistance of supervisors and/or any International Uranium USA Corporation IUSA personnel The Incident Commander has the responsibility for the news media and reports directly to the President of IUSA 5.2 Mill General Superintendent The Mill General Superintendent has the responsibility of directing outside emergency personnel and has the responsibility for plant security and will report directly to the Incident Commander The Mill General Superintendent will act as Incident Commander in the absence of the Mill Manager 5.3 Radiation Safety Officer/Fire Chief The Radiation Safety Officer will direct rescue operations and provide the necessary emergency medical personnel and facilities to cope with the emergency Adequately trained fire crews and operable emergency equipment will be maintained at all times P\Admin\Master 5OPs\Book 16 Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MThL EMERGENCY RESPONSE PLAN Page of 13 As Fire Chief the Radiation Safety Officer has the responsibility to maintain trained fire crews and operable equipment mobilize and direct the fire crews and equipment in fire emergency or one containing the threat of fire and to assist in evacuation and rescue or recovery operations In the absence of the Radiation Safety Officer the Mill Safety Coordinator will assume these duties 5.4 Maintenance Supervisor The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with the emergency including isolation of utilities and providing technical advice as needed The Maintenance Supervisor will be assisted by the Mill Safety Coordinator 5.5 Laboratory Supervisor The Laboratory Supervisor has the responsibility to direct and account for all office personnel including IUSA personnel and office visitors in evacuation and in activities to cope with the emergency In case of mill tour the Supervisor accompanying the tour will be responsible for evacuation of visitors 5.6 Shift Foremen Shift Foremen are in charge until the Incident Commander arrives and are responsible for all functions listed above Shift Foremen have the responsibility to account for all of their people in addition to any visitors contractors etc in their areas and report to the Incident Commander or in the absence of the Incident Commander to administer all of the above duties 5.7 Scale House Personnel Scale house person on shift will be responsible to account for ore truck drivers and reagent truck drivers 5.8 Emergency Response Teams The response crew for each operating shift will normally consist of the following operators under the direction of the shift foreman This organization may be changed for individual shifts subject to the approval of the Fire Chief 5.8.1 Operational Mode Leach Operator CCD Operator Solvent Extraction Operator Mill Trainee 5.8.2 Non-Operational Mode Shift Foreman Operations Personnel Maintenance Personnel P\Admin\Master SOPs\Book 16_Emergency Response PJan\Emergency Response Plan Rev 09.29.O5.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 10 of 13 Figure Emergency Response Organizational Structure Incident Commander Mitt Manager Director of Security Operations Superintendent Fire Chief Radiation Safety Officer Shift Foremen Emeipency Response Teams Lab Supervisor Operatidnal Mode Non-Operational Mode Leach Operator CCD Operator Shift Foreman Operations Personnel SX Operator Mill Trainee Maintenance Person net SPECIFIC EMERGENCIES The following details procedures to be followed during specific emergencies but are not limited to the following 6.1 Fire Should fire occur the procedure outlined in Appendix for reporting and responding to fires will be followed Particular areas of concern include Solvent Extraction Building Propane Tanks Lab or Lab Storage Area 6.2 Chemical or Gas Release The procedures for response to chemical or gas release are outlined as Appendix 6.3 Earthquake Although this is highly unlikely an earthquake could occur at the Mill severe earthquake could cause buildings and other structures to collapse chemical and/or gas releases major fires as well as general panic In the event of maj or earthquake the evacuation procedures outlined in Appendix will be followed P\Admin\Master SOPs\Book 16_Emergency Response PJan\Emergency Response Plan Rev 09.29.05.doc 10 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 11 of 13 6.4 Terrorist/Bomb Threat In the event that any person should receive threat of bomb the following evacuation procedure should be followed Notify any person of authority i.e Superintendent Foreman Radiation Safety Officer who will immediately notify law enforcement authorities and evacuate the threatened area Evacuate all persons from the affected area and stop all radio transmissions 6.5 Tailings Dam Break and Major Floods Flood water breaching tailings embanlcments presents one of the greatest dangers for the sudden release of tailings solids and impounded water The tailings cells are designed with sufficient freeboard three feet to withstand back-to-back 100-year storm events or 40%of the probable maximum flood PMF followed by the 100-year storm event The flood design is equivalent to 15 inches of rainfall In addition the tailings dikes were designed in accordance with U.S NRC regulations and allow sufficient margin of safety even in the event of an earthquake The possibility of floods resulting from Westwater Creek Cottonwood Creek and Corral Creek causing dam failure is extremely remote The tailings cells and dikes are inspected on both daily and shift basis Discharges from dike failure would extend three miles before leaving JUSAs property In the event of dam failure large operating equipment will be mobilized to construct temporary earthen dikes or bemis downgradient to the failed dike In addition the State of Utah Department of Radiation Control Executive Secretary the Executive Secretary MSHA and State of Utah Department of Natural Resources Division of Dam Safety shall be notified In the event of seismic rupture of tailings slurry pipelines the released sluny will be contained in the tailings cells regardless of the quantity released EVACUATION PROCEDURE See Appendix 7.1 Notification Employees will be notified to evacuate the area by dialing 184 on any area telephone and announcing that the Mill should be evacuated This announcement will be repeated twice When the paging system cycles through the evacuation siren continuous frequency will automatically sound for approximately forty-five seconds and then automatically shut off allowing communications by radio from that point If the 184 number is dialed accidentally the evacuation alarm may be canceled by disconnecting the phone until the page cycle ends then re dial 184 See Exhibits and 7.2 Assembly When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all personnel will assemble at The parking lot south of the office P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERITATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WIIITE MESA MILL EMERGENCY RESPONSE PLAN Page 12 of 13 The scalehouse North side of Tailings Cell or North of the Mill Assembly site will depend upon conditions i.e nature of the emergency wind conditions etc The Fire Chief or Shift Foreman will specify the appropriate assembly site 7.3 Specific Procedure for Operations Personnel See specific emergency shutdown procedure for Operations by area under the relevant Operating Procedure for your area All employees not mentioned under Operating Procedures are to immediately report to the assembly area and congregate by crew so that all persons can be accounted for As employees leave their work areas they must pass the word to evacuate to any persons who may not be aware of the emergency After the Mill has been determined to be safe for re-entry employees will be verbally notified to return to their work stations Off-Site Emergency Equipment/Personnel Release Any emergency response equipment or personnel that enter the Restricted Area in response to an incident will be scanned and decontaminated prior to leaving the site according to the procedures included in PBL-9 End Dump Trailer Acceptance Handling and Release Any equipment will be decontaminated according to the requirements found in Table of the Nuclear Regulatory Commissions NRCs Policy and Guidance Directive FC-85-23 Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct Source or Special Nuclear Material issued May 1987 Injured personnel should be evaluated for radiation contamination if there was potential for contamination at the earliest convenience Should it be necessary contaminated articles will be gathered by the radiological staff after medical treatment has been rendered If the personnel cannot be decontaminated notify the clinic/hospital personnel in advance EMERGENCY EQUIPMENT Emergency equipment for the Mill is provided as follows 9.1 Fire Hose Fire hose cabinets are located at the following sites with minimum of 300 feet of 2-1/2 hose two spanner wrenches spray nozzles and one hydrant wrench South of SX West of CCD North of Mill Building East of pulp storage tanks Northwest of Maintenance Shop West of Warehouse P\Admin\Master 5OPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 12 INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 13 of 13 East of office building 9.2 Self Contained Breathing Apparatus Two Self-Contained Breathing Apparatus are located at each of the following locations Hose station east of office building Hose Station South of SX North End SX Outside Wall North end of Mill building outside wall 9.3 Spill Clean-up Equipment Barrels of soda ash are located throughout the Mill to be used in case of chemical spill Soda ash is also stored in bulk if needed There are also few drums of absorbent stored near the laboratory The laboratory also contains acid spill kits and absorbent materials to be used in case of spill 9.4 Fire Fighting PPE Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in the Fire Hose Station located on the east side of the office building 9.5 Maintenance of Emergency Equipment Fire extinguishers are inspected on an annual basis as well as the fire pump system The Mill Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure that all of the equipment is in place 10 EMERGENCY TRANSPORTATION One fully-equipped First Responder Unit Ambulance located west of the office building Other motor pool vhicles on the property will be utilized as needed in emergency situations with support as needed from the local Emergency Medical Services 11 EMERGENCY DRILLS AND TRAINING Quarterly drills as required by MSHA are prepared by the Safety and Radiation Departments to monitor performance of personnel responding to emergency situations Each drill will be enacted upon one or more of the potential scenarios by this plan The drill and evacuation activities are documented by the Mills Safety Coordinator and maintained within plant files Management will review all drills at quarterly ALARA Committee Meetings P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc EXIIIBIT EMERGENCY NOTIFICATION LIST ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR Give artificial respiration if necessary Control bleeding Treat for shock Immobilize fractures and stabilize for transportation Scan the injured for excessive alpha prior to transporting if time allows If alpha is excessive or there is no time to scan notify the clinic/hospital personnel and the Radiation Safety Office THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED Blanding Clinic 678-2254 or 678-3434 930 400 San Juan Hospital Monticello ...678-2830 or 587-2116 364 1st EMT and CPR TRAINED The following personnel should be contacted if they are on-site in the event of an emergency to aid in the event of any injuries to personnel David Turk EMT and CPR trained Mike Spillman CPR trained AMBULANCE SERVICE Blanding Dial 911 If the Company Ambulance is used an attendant must ride with the injured in addition to the driver except where the injured could normally be transported in car or pickup OTHER EMERGENCY NUMBERS Fire Department Dial 911 or 678-2313 County Sheriff Dial 911 or 587-2237 Highway Patrol Dial 911 or 587-2000 Blanding Police Dial 911 678-2916 or 678-2334 MANAGERS The Supervisor will notify one of the following of all incidents R.E Bartlett 435-678-2495 Turk 435-678-7802 or 435-459-1068 Spillman 435-678-2761 MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING AGENCIES AS REQUIRED FOR EACH INCIDENT State of Utah Department of Radiation Control 801-536-4250 MSHA Field Off.--80l-524-3450 Dist Off 303-231-5465 MSHA Arlington 800-746-1553 State Emergency Response Comm 801-538-3400 State of Utah Natural Resources Dam Safety 801-538-7200 National Response Center 800-424-8802 Utah Poison Control Center 800-456-7707 Notification of surrounding communities and or residences will be handled by the appropriate agencies as required by EPCRA Emergency Planning and Community Right to Know Act Revision Date January 16 2006 E-1 EXHIBIT INTERNAL NOTIFICATIONS Internal reporting requirements for Incidents Spills and Significant Events are as follows Report Immediatejy Event Criteria Release of toxic or hazardous substances Fire explosions or other accidents Government investigations information requests or enforcement actions Private actions or claims corporations or employees Deviations from Corporate policies or government requirements by Management Other significant events which have resulted or could result in Death serious injury or adverse health effect employees or public Property damage exceeding $1000000 Government investigation or enforcement action limiting operation or penalties of $100000 or more Significant criminal actions Substantial media coverage Unscheduled down time of more than 24 hours Report at the Beginning of the Next Business Day Tncident Criteria Was reported to government agency as required by law Worker IUSA or contractor recordable injury or illness associated with release Community impact reported or awareness Publicity resulted or is anticipated Release of process material waste or product in excess of the Reportable Quantities listed in Section 1.5 of the Spill Prevention Control and Countermeasures Plan The local manager in charge is to call Ron Hochstein or Dave Frydenlund Name Title Office Phone Home Phone Ron Hochstein President and COO 303-628-7798 office 604-931-6334 home 604-377-1167 cell David Frydenlund V.P and General Counsel 303-389-4130 office 303-221-0098 home 303-808-6648 cell Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 02.14.07 E-2 EXHIBIT SITE LAYOUT MAP P\Admin\Master SOPs\Book 16_Emergency Response PJan\Emergency Response Plan Rev 09.29.05.doc E-3 et Ca Ci LI -I Cl Cl Ci EXHIBIT MAIN SHUT-OFF VALVES During an emergency this list should be used along with Site Layout Map Exhibit to locate tanks and valves associated with these tanks REAGENT SHUT-OFF VALVE LOCATIONS Sulfuric Acid Main located south side of acid tank East acid pump discharge valve West acid pump discharge valve Main leach area located 25 feet west of Derrick screens next to walkway 1-1/2 Main SX area located south of Central Control room Ammonia Main east tank located on end at bottom Main west tank located on end at bottom Valve located on top of tank east tank Valve located on top of tank west tank Kerosene Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Pump discharge valve Soda Ash Main valve located at bottom of tank dry storage Main valve located at bottom of tank on 30%dilution tank Main valve locate at bottom of tank on dilution tank Salt Main valve located at bottom of tank Caustic Soda Main valve located at bottom of tank east and west between supports P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc E-4 EXHJBIT MAIN SHUT-OFF VALVES Sodium Chlorate 31 Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Propane Main located 15 feet east of tank Main located on pipe off top of tank Main located at bottom of tank also fill pipe PLANT UTILITY SHUT-OFF VALVE LOCATIONS Process Water Main valve located on west side of water storage tank Discharge valve off service water pump east Discharge valve off service water pump west Mill process water main located east wall by SAG mill Fire Water Main valve located west side of water storage tank Emergency fire pump discharge valve to fire system Emergency fire pump discharge valve to header west side of pump house Main valve located south of Central Control room for SX and boilers Potable Water Main suction from potable water storage tank Main discharge from potable water storage tank Main located at east wall by SAG mill Main located south of Central Control room for SX Maintenance shop and offices Steam Main discharge valve for Superior boiler located at top of boiler Main steam valve located south side of boiler house PfsAdmin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 EXHIBIT MAIN SHUT-OFF VALVES Plant Air Main valve located at receiver tank in compressor room at boiler house Main valve to mill building located south of Central Control room PROCESS SHUT-OFF VALVE LOCATIONS Pulp Storage No valve located on west side of tank No valve located on west side of tank Preleach old No pulp storage valve located on west side of tank Preleach Thickener Main valve located underneath at center cone Clarifier Main valve located underneath at center cone Main valve located underneath at center cone CO Thickeners Main valve located underneath at center cone of each thickener PAdmin\Master 5OPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 0929.05 doe E-4 APPENDIX EMERGENCY PROCEDURE RESPONSE TO FIRE The fire will be reported by dialing 185 on any telephone in the area and announcing the location of the fire over the paging system This announcement will be repeated twice for total of three announcements When the paging system cycles through the fire siren alternating frequency will automatically sound for approximately forty-five seconds then automatically shut off allowing radio communications to resume Mobilize the fire crew Evacuate all personnel Rescue any victims of the fire do this only with properly trained and equipped personnel Isolate utility lines affected by the fire Extinguish the fire and post fire watch for flare-ups Report the fire to proper local State Corporate and Federal agencies In cases where the fire is not extinguished within thirty minutes of discovery the area ....t...k.....cc ...a..4......t._...i-....a...a .1 _..i-...-.a 1...it sf011 iliUnt uc Owl icaucu on aitcl cAungwnn1g atlu icit iutui ucu unui cica5cu oy ivionn and JUSA management Emergency off-site centers Blanding Fire House and Sheriffs office Blanding Fire 350 West 200 South Blanding Phone number is 911 Sheriffs Office 50 West 100 South Blanding Phone number is 911 or 435 587-2237 P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-I APPENDIX EMERGENCY PROCEDURE RESPONSE TO CHEMICAL OR GAS RELEASE chemical or gas release would most likely occur very suddenly The person who would first witness chemical or gas release should immediately contact his supervisor who would initiate the procedures outlined below Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped by the release Provide first aid and emergency medical care for any ill or injured persons Initiate necessary steps to contain and/or neutralize the release such as spraying with water fog turning off valves etc Guard against possible fires by shutting off electrical circuits isolating gas lines and aIrn0tnn onnrroc fr rn ha .ff00A 0mb .Jtj1.LALLttL1S5 1bAL1LaJZJ OJ%4fl..O J1%JI1S LII Afl..3 LU.tL P\Admin\Master SOPs\Book 16_Emergency Response Plan \Emergency Response Plan Rev 09.29 05.doc A-I APPENDIX EMERGENCY EVACUATION PROCEDURE Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Personnel are to assemble in one of the following areas The parking lot south of the office building The scalehouse The north side of Tailings Cell or North of the Mill Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped Provide first aid and emergency medical care for any ill or injured persons Guard against possible fires by shutting off electrical circuits isolating gas lines and eliminating ignition sources from the affected area P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-i FIGURE FIRE SYSTEM SCHEMATIC DRAWING P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-i .0 % LS M O - e ot I Sb i f l c tn 4 14 oo o 4c S l L ew q n f l 4h t h L .0 % IS w- t q . t St% Q 1 % r $ t c5 1t 1 0 .r v . s A is to g 0t j %w 9 oo o o .- q P i tO % L n $ fl V r 00 0 0 0 1 - STORM WATER BEST MANGEMENT PRACTICES PLAN for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Blanding Utah June 2008 Prepared by Denison Mines USA Corp 1050 17th Street Suite 950 Denver CO 80265 TABLE OF CONTENTS 1.0 Purpose 2.0 Scope 3.0 Responsibility 4.0 Best Management Practices 4.1 General Management Practices Applicable to All Areas 4.2 Management Practices for Process and Laboratory Areas 4.3 Management Practices for Maintenance Activities 4.4 Management Practices for Ore Pad Tailings Area and heavy Equipment Operations Figures Figure White Mesa Mill Site Map Figure Mill Site Drainage Basins Figure IIUSA Mill Management Organization Chart Figure 1JSA Corporate Management Organization Chart Tables Table White Mesa Mill Management Personnel Responsible for Jmplementing This BMPP Appendices Appendix White Mesa Mill Spill Prevention Control and Countermeasures Plan Appendix White Mesa Mill Emergency Response Plan Best Management Practices Plan Revision 1.3 June 12 2008 1.0 INTRODUCTION/PURPOSE Denison Mines USA Corp DUSA operates the White Mesa Uranium Mill the Mill in Blanding Utah The Mill is net water consumer and is zero-discharge facility with respect to water effluents That is no water leaves the Mill site because the Mill has no outfalls to public stormwater systems no surface runoff to public stormwater systems no discharges to publicly owned treatment works POTW5 and no discharges to surface water bodies The State of Utah issued Groundwater Discharge Permit No UGW3 70004 to DUSA on March 2005 As part of compliance with the Permit DUSA is required to submit Stormwater Best Management Practices Plan BMPP to the Executive Secretary of the Division of Radiation Control Utah Department of Environmental Quality This BMPP presents operational and management practices to minimize or prevent spills of chemicals or hazardous materials which could result in contaminated surface water effluents potentially impacting surface waters or ground waters through runoff or discharge connections to stormwater or surface water drainage routes Although the Mill by design cannot directly impact stormwater surface water or groundwater the Mill implements these practices in good faith effort to minimize all sources of pollution at the site Page Best Management Practices Plan Revision 1.3 June 12 2008 2.0 SCOPE This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in process operations laboratory operations and maintenance activities and minimize spread of particulates from stockpiles and tailings management areas at the Mill Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this BMPP The Mill site was constructed with an overall grade and diversion ditch system designed to channel all surface runoff including precipitation equivalent to Probable Maximum Precipitation/Probable Maximum Flood PMP/PMF storm event to the tailings management system In addition Mill tailings all other process effluents all solid waste and debris except used oil and recyclable materials and spilled materials that cannot be recovered for reuse are transferred to one or more of the tailings cells in accordance with the Mills NRC license conditions All of the process and laboratory building sinks sumps and floor drains are tied to the transfer lines to the tailings impoundments site map of the Mill is provided in Figure sketch of the site drainage basins is provided in Figure As result unlike other industrial facilities whose spill management programs focus on minimizing the introduction of chemical and solid waste and wastewater into the process sewers and storm drains the Mill is permitted by NRC license to manage some spills via draining or washdown to the process sewers and ultimately the tailings system However as good environmental management practice the Mill attempts to minimize the number and size of material spills and the amount of unrecovered spilled material and washwater that enters the process sewers after spill cleanup Section 4.0 itemizes the practices in place at the Mill to meet these objectives Requirements and methods for management recordkeeping and documentation of hazardous material spills are addressed in the DUSA White Mesa Mill Spill Prevention Control and Countermeasures SPCCPlan Revised February 2007 the Emergency Response Plan ERP also revised in February 2007 and the housekeeping procedures incorporated in the White Mesa Mill Standard Operating Procedures SOPs The SPCC plan and the ERP are provided in their entirety in Appendices and respectively Page Best Management Practices Plan Revision 1.3 June 12 2008 3.0 RESPONSIBILITY All Mill personnel are responsible for implementation of the practices in this BMPP DUSA White Mesa Mill management is responsible for providing the facilities or equipment necessary to implement the practices in this BMPP The Mill Management Organization is presented in Figure The DUSA Corporate Management Organization is presented in Figure An updated spill prevention and control notification list is provided in Table Page Best Management Practices Plan Revision 1.3 June 12 2008 4.0 BEST MANAGEMENT PRACTICES summary list and inventory of all liquid and solid materials managed at the Mill is provided in Tables through 4.1 General Management Practices Applicable to All Areas 4.1.1 Keep Potential Pollutants from Contact with Soil and Surface Water Store hazardous materials and other potential pollutants in appropriate containers Label the containers Keep the containers covered when not in use 4.1.2 Keep Potential Pollutants from Contact with Precipitation Store bulk materials in covered tanks or drums Store jars bottle or similar small containers in buildings or under covered areas Replace or repair broken dumpsters and bins Keep dumpster lids and large container covers closed when not in use to keep precipitation out 4.1.3 Keep Paved Areas from Becoming Pollutant Sources Sweep paved areas regularly and dispose of debris in the solid waste dumpsters or tailings area as appropriate 4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and Reagent Storage Area Diversion ditches drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly in accordance with the regularly scheduled inspections required by Groundwater Discharge Permit No UGW370004 and Byproduct Materials License UT1900479 Areas requiring maintenance or repair such as excessive vegetative growth channel erosion or pooling of surface water runoff will be report to site management and maintenance departments for necessary action to repair damage or perform reconstruction in order for the control feature to perform as intended Status of maintenance or repairs will be documented during follow up inspections and additional action taken if necessary 4.1.5 Recycle Fluids Whenever Possible When possible select automotive fluids solvents and cleaners that can be recycled or reclaimed When possible select consumable materials from suppliers who will reclaim empty containers Keep spent fluids in properly labeled covered containers until they are picked up for recycle or transfened to the tailings area for disposal Page Best Management Practices Plan Revision 1.3 June 12 2008 4.2 Management Practices for Process and Laboratory Areas 4.2.1 Clean Up Spills Properly Clean up spills with dry cleanup methods absorbents sweeping collection drums instead of water whenever possible Clean spills of stored reagents or other chemicals immediately after discovery Groundwater Discharge Permit No UGW370004 Section I.D.8.c Recover and re-use spilled material whenever possible Keep supplies of rags sorbent materials such as cat litter spill collection drums and personnel protective equipment PPE near the areas where they may be needed for spill response If spills must be washed down use the minimum amount of water needed for effective cleanup 4.2.2 Protect Materials Stored Outdoors If drummed feeds or products must be stored outdoors store them in covered or diked areas when possible If drummed chemicals must be stored outdoors store them in covered or diked areas when possible Make sure drums and containers stored outdoors are in good condition and secured against wind or leakage Place any damaged containers into an overpack drum or second container 4.2.3 Water Management When possible recycle and reuse water from flushing and pressure testing equipment When possible wipe down the outsides of containers instead of rinsing them off in the sink When possible wipe down counters and work surfaces instead of hosing or rinsing them off to sinks and drains 4.2.4 Materials Management Purchase and inventory the smallest amount of laboratory reagent necessary Do not stock more of reagent than will be used up before its expiration date All new construction of reagent storage facilities will include secondary containment which shall control and prevent any contact of spilled reagents or otherwise released reagent or product with the ground surface Groundwater Discharge Permit No UGW370004 Section I.D.3.e Page Best Management Practices Plan Revision 1.3 June 12 2008 4.3 Management Practices for Maintenance Activities 4.3.1 Keep Clean Dry Shop Sweep or vacuum shop floors regularly Designate specific areas indoors for parts cleaning and use cleaners and solvents only in those areas Clean up spills promptly Dont let minor spills spread Keep supplies of rags collection containers and sorbent material near each work area where they are needed Store bulk fluids waste fluids and batteries in an area with secondary containment double drum drip pan to capture leakage and contain spills 4.3.2 Manage Vehicle Fluids Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible Use drip pans or plastic tarps to prevent spillage and spread of fluids Promptly contain and transfer drained fluids to appropriate storage area for reuse recycle or disposal Recycle automotive fluids if possible when their useful life is finished 4.3.3 Use Controls During Paint Removal Use drop cloths and sheeting to prevent windbome contamination from paint chips and sandblasting dust Collect contain and transfer as soon as possible accumulated dusts and paint chips to disposal location in the tailings area authorized to accept waste materials from maintenance or construction activities 4.3.4 Use Controls During Paint Application and Cleanup Mix and use the right amount of paint for the job Use up one container before opening second one Recycle or reuse leftover paint whenever possible Never clean brushes or rinse or drain paint containers on the ground paved or unpaved Clean brushes and containers only at sinks and stations that drain to the process sewer to the tailings system Paint out brushes to the extent possible before water washing water-based paint or solvent rinsing oil-based paint Filter and reuse thinners and solvent whenever possible Contain solids and unusable excess liquids for transfer to the tailings area Page Best Management Practices Plan Revision 1.3 June 12 2008 4.4 Management Practices for Ore Pad Tailings Area and Heavy Equipment Detailed instructions for ore unloading dust suppression and tailings management are provided in the Mill SOPs 4.4.1 Wash Down Vehicles and Equipment in Proper Areas Wash down trucks trailers and other heavy equipment only in areas designated for this purpose such as washdown pad areas and the truck wash station At the truck wash station make sure the water collection and recycling system is working before turning on water sprays 4.4.2 Manage Stockpiles to Prevent Windborne Contamination Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill SOPs Water spray stockpiles as required by opacity standards or weather conditions Dont over-water Keep surfaces moist but minimize runoff water 4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources Schedule excavation grading and other earthmoving activities when extreme dryness and high winds will not be factor to prevent the need for excessive dust suppression Remove existing vegetation only when absolutely necessary Seed or plant temporary vegetation for erosion control on slopes Page7 TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Home Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.l66 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Rome Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE REAGENT YARD LIST REAGEN1Hi .QUAN1rnLBS eNUMBEROF APACfl11 STORAGE-TANKS CAtiONS ADOGEN 2382 6120 ADVANTAGE 1O1M 2475 AMERSITE AMINE 2384 19440 AMMONIUM SULFATE BULK 54000 AMMONIUM SULFATE BAGS 4300 ANHYDROUS AMMONIA 107920 31409 CHEMFAC 100 12800 CLARIFLOC N-1O1P 3000 DECYLALCOHOL 45430 DIESEL FUEL 250 6000 FLOCCULENT M1O11N 30550 FLOCCULENT M1302C 3550 GRINDING BALLS 48290 ISODECANOL 45430 KEROSENE 1344 10152 MACKANATE 3150 MILLSPERSE 802 1410 NALCO 2458 NALCO 8815 PERCOL 351 1500 PERCOL 406 13950 PERCOL 745 POLOX 10360 POLYHALL YCF PROPANE 30000 SALT BAGS 39280 SALT BULK SODA ASH BAGS 39280 SODA ASH BULK 84100 16921 8530 SODIUM CHLORATE 101128 17700 10500 SODIUM HYDROXIDE 19904 SULFURIC ACID 4801440 1600000 269160 UNLEADED GASOLINE 3000 USED OIL 5000 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 Chemical in Lab RQ2 Quantity In Stock Aluminum nitrate 2270 kg 1.8 kg Ammonium bifluoride 45.4 kg 2.27 kg Ammonium chloride 2270 kg 2.27 kg Ammonium oxalate 2270 kg 6.8 kg Ammonium thiocyanate 2270 kg 7.8 kg Antimony potassium tartrate 45.4 kg 0.454 kg n-Butyl acetate 2270 kg Carbon tetrachloride 4.54 kg 1.0 Cyclohexane 454 kg 24 Ferric chloride 454 kg 6.810 kg Ferrous ammonium sulfate 454 kg 0.57 kg Potassium chromate 4.54 kg 0.114 kg Sodium nitrite 45.4 kg 2.5 kg Sodium phosphate tribasic 2270 kg 1.4 kg Zinc acetate 454 kg 0.91 kg Chemical in Volatiles and RQ2 Quantity In Stock Flammables Lockers ABC Chloroform 4.54 kg Formaldehyde 45.4 kg of 37%solution Nitrobenzene 454 kg 12 Toluene 454 kg 12L Chemical in Acid Shed RQ2 Quantity In Stock Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 fftRQ7 QJA1.JN Acetic Acid Glacial 1000 lbs gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 lbs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs kg 11 Ibs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal 5kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARDIBULK CHEMICALS LIST1 REAGENT RQ QUANTITY IN REAGENT YARD Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfloc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous substances Designated Pursuant to section 311 of the Clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT QUANTITY IN WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout 1q 0 6 p 190 290 SC. L E 04 F E E T In t e r n a t i o n a l Ur a n i u m LI S A Co r p o r a t i o n tro j a f l WH T E ME S A MIL L Ca u n f y San .tti a a Stf l I Uta h La c t i l a r a Fi g u r e MIL L SL i t LA Y O U T tt l 2 0 0 14 2 0 0 2 tra F f i c p a t an o n ara r a a a ay sm d n r s d Figure White Mesa Mill Mill Site Drainage Basins Figure White Mesa Mill Mill Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Wh i t e Me s a Mi l l Or g a n i z a t i o n a l St r u c t u r e Fi g u r e Figure Corporate Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Or g a n i z a t i o n a l St r u c t u r e Fi g u r e APPENDICES APPENDIX WHITE MESA MTLL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS for White Mesa Uranium Mill 6425 South Highway 191 Box 809 Blanding Utah 84511 February 2007 Prepared by Denison Mines USA Corp 1050 7th Street Suite 950 Denver Colorado 80265 TABLE OF CONTENTS SECTION PAGE 1.1 Objective 1.2 Responsibilities 1.3 Drainage Basins Pathways and Diversions 1.4 Description of Basins 1.4.1 Basin Al .4.2 Basin A2 1.4.3 Basin BI 1.4.4 Basin B2 1.4.5 Basin B3 1.4.6 Basin 1.4.7 Basin 1.4.8 Basin 1.5 Potential Chemical Spill Sources And Spill Containment 1.5.1 Reagent Tanks 1.5.2 Ammonia 1.5.3 Ammonium Meta Vanadate 1.5.4 Caustic Storage Sodium Hydroxide 1.5.5 Sodium Carbonate 1.5.6 Sodium Chlorate 1.5.7 Sulfuric Acid 1.5.8 Vanadium Pentoxide 1.5.9 Kerosene Organic 1.6.0 Used/Waste Oil SECTION PAGE 1.6.1 Propane 1.7 Potential Petroleum Sources And Containment 1.7.1 Petroleum Storage Tanks 1.7.1.1 Diesel 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.2 Unleaded Gasoline 1.7.2.3 Pump Station 1.7.2.4 Truck Unloading 1.8 Spill Discovery And Remedial Action 1.9 Spill Incident Notifications 1.9.1 External Notification 1.9.2 Internal Notification 11 1.10 Records And Reports 12 1.11 Personnel Training And Spill Prevention Procedures 12 1.11.1 Training Records 12 1.11.2 Monitoring Reports 13 1.12 Revision 13 1.13 Summary 13 1.14 Mill Manager Approval 14 1.15 Certification by Registered Professional Engineer 14 LIST OF TABLES Table 1.0 Mill Organization Chart Table 2.0 Reagent Tank List Table 3.0 Laboratory Chemical Inventory List Table 4.0 Reagent Yard/Small Quantity Chemicals List Table 5.0 Reagent Yard/Bulk Chemicals List Table 6.0 Petroleum Products and Solvents List LIST OF FIGURES Figure Mill Site Layout Figure Mill Site Drainage Basins WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS 1.1 OBJECTIVE The objective of the Spill Prevention Control and Countermeasures SPCC Plan is to serve as site-specific guideline for the prevention of and response to chemical and petroleum spills and as guidance document for compliance with Groundwater Discharge Permit No UGW370004 The plan outlines spill potentials containment areas and drainage characteristics of the White Mesa Mill site The plan addresses chemical spill prevention spill potentials spill discovery and spill notification procedures The Oil Pollution Prevention Sections of the Clean Water Act 40 CFR 112 to 117 also referred to as the Spill Prevention Control and Countermeasures SPCC rules establish requirements that apply to facilities which could reasonably be expected to discharge oil in quantities that may be harmful as described in that Act into or upon the navigable waters of the United States or that may affect natural resources of the United States Section 112 states that the Act is not applicable to facilities that are not subject to the authority of the Environmental Protection Agency EPA for one of the following reasons Due to its location the facility could not reasonably be expected to discharge oil into navigable waters of or impact natural resources of the U.S or The facility is subject to authority of the Department of Transportation as defined in Memorandum of Understanding MOU between the Secretary of Transportation and the EPA Administrator or The facility does not exceed either the underground or the above ground storage capacity 42000 gallons and 1320 gallons respectively prescribed in the rules The Mill could not reasonably be expected as described in the SPCC regulation to discharge oil into the navigable waters or impact natural resources of the U.S The Mill site was constructed with an overall grade and diversion ditch system designed to channel the non-recovered portion of any material spill to the tailings management system Hence it is not reasonable to expect that surface spills will ever reach navigable waters or natural resources of the U.S or Utah Therefore the SPCC reporting requirements in the Clean Water Act are not applicable to the Mill However as good environmental management practice the Mill has implemented the spill management program described in this document which is consistent with the intent of the Clean Water Act to the extent practicable Although the Mill by design cannot directly impact navigable waters of the U.S and as result spills that may occur but are retained within the site would not be reportable the Mill implements these practices in good faith effort to minimize all potential sources of pollution at the site Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this SPCC Ammonia is the only chemical that has the potential to leave the site and would do so as vapor Figure Site Layout Map shows map of the mill site including the locations of the chemical tanks on-site Figure shows the basins and drainage ditch areas for the mill site Table 1.0 is an organization chart for Mill operations Table 2.0 lists the reagent tanks and their respective capacities Table 3.0 lists the laboratory chemicals their amounts and their reportable quantities Table 4.0 lists the operations chemicals Table 5.0 lists the chemicals in the reagent yard their amounts and their reportable quantities Table 6.0 lists the petroleum products and solvents on site 1.2 RESPONSIBILITIES Person in charge of facility responsible for spill prevention Mr Richard Bartlett Interim Mill Manager 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 459-2495 home Person in charge of follow-up spill record keeping and/or reporting Mr David Turk Department Head Health Safety and Environmental 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 678-7802 home Refer to Section 1.9 Spill Incident Notification for list of company personnel to be notified in case of spill In addition an organizational chart is provided in Table 1.0 1.3 DRAINAGE BASINS PATHWAYS AND DIVERSIONS The main drainage pathways are illustrated in Figure The map shows drainage basin boundaries flow paths constructed diversion ditches tailings cells the spillway between Cell and dikes berms and other relevant features The White Mesa Mill is zero discharge facility for process liquid wastes The mill area has been designed to ensure that all spills or leaks from tanks will drain toward the lined tailings cells The tailings cells in turn are operated with sufficient freeboard minimum of three feet to withstand 100%of the PMP Probable Maximum Precipitation This allows for maximum of 10 inches of rain at any given time 1.4 DESCRIPTION OF BASINS Precipitation and unexpected spills on the mill property are contained within their respective drainage basins Runoff would ultimately drain into one of the three lined tailings cells 1.4.1 Basin Al Basin Al is north of Cell 1-I and Diversion Ditch No The basin contains 23 acres all of which drain into Westwater Creek This area is not affected by mill operations 1.4.2 Basin A2 Basin A2 contains all of Cell 1-I including an area south of the Diversion Ditch No The basin covers 84 acres Any runoff from this basin would be contained within Cell 1-I 1.4.3 Basin BI Basin Bl is north of the mill property and is not affected by mill operations The basin contains 45.4 tributary acres Runoff from this basin drains into flood retention area by flowing through Diversion Ditch No Diversion Ditch No drains into Westwater Creek 1.4.4 Basin B2 Basin B2 is northeast of the mill and contains only 2.6 acres Runoff from this basin would drain into Diversion Ditch No Diversion Ditch No ultimately drains into Diversion Ditch No This basin is not affected by mill operations 1.4.5 Basin B3 Basin B3 contains most of the mill area buildings ore stockpiles process storage tanks retention ponds spill containment structures pipelines and roadways The normal direction of flow in this basin is from the northwest to the southwest Any runoff from this basin would drain into Cell 1-I The basin contains 64 acres This basin has sufficient freeboard to withstand 100%of the PMP Probable Maximum Precipitation This allows 10 inches of rain for any given storm event 1.4.6 Basin Basin contains all of Cell The basin consists of 80.7 acres This basin contains earth stockpiles and the heavy equipment shop The direction of flow in this basin is to the southwest All runoff in this basin would be channeled along the southern edge of the basin Runoff would then flow into Cell via the spillway from Cell to Cell 1.4.7 Basin Basin contains all of Cell This basin consists of 78.3 acres including portion of the slopes of the topsoil stockpile and random stockpile The basin contains all flows including those caused by the PMF 1.4.8 Basin Basin contains Cell 4A and consists of 43.3 acres All anticipated flows including those caused by the PMF will be contained within the basin and will flow directly into Cell 4A 1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT This section details potential sources of chemical spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.5.1 Reagent Tanks Tank list included in Table 2.0 1.5.2 Ammonia The ammonia storage tanks consist of two tanks with capacity of 31409 gallons each The tanks are located southeast of the Mill building Daily monitoring of the tanks for leaks and routine integrity inspections will be conducted to minimize the hazard associated with ammonia The reportable quantity for an ammonia spill is gallons Ammonia spills should be treated as gaseous Ammonia vapors will be monitored closely to minimize the hazard associated with inhalation If vapors are detected efforts will be made to stop or repair the leak expeditiously Ammonia is the only chemical as vapor that has the potential to leave the site 1.5.3 Ammonia Meta Vanadate Ammonia meta vanadate is present in the SX building as the process solutions move through the circuit to produce the vanadium end product But the primary focus will be on the transportation of this chemical The reportable quantity for an ammonia meta vanadate spill is 1000 pounds 1.5.4 Caustic Storage Sodium Hydroxide The caustic storage tank is located on splash pad on the northwest corner of the SX building The tank has capacity of 19904 gallons The tank supports are mounted on concrete curbed catchment pad that directs spills into the sand filter sump in the northwest corner of the SX building The reportable quantity for sodium hydroxide spill is 85 gallons 1.5.5 Sodium Carbonate Soda Ash The soda ash solution tank has capacity of 16921 gallons and is located in the northeast corner of the SX building The smaller soda ash shift tank has capacity of 8530 gallons and is located in the SX building Spills will be diverted into the boiler area and would ultimately drain into Cell I-I There is no reportable quantity associated with sodium carbonate spill 1.5.6 Sodium Chlorate Sodium chlorate tanks consist of two fiberglass tanks located within dike east of the SX building The larger tank is used for dilution purposes and has maximum capacity of 17700 gallons The smaller tank serves as storage tank and has capacity of 10500 gallons Daily monitoring of the tanks for leaks and integrity inspections will be conducted to minimize the hazard associated with sodium chlorate Sodium chlorate that has dried and solidified becomes even more of safety hazard due to its extremely flammable nature The reportable quantity for sodium chlorate spill is 400 gallons 1.5.7 Sulfuric Acid The sulfuric acid storage tanks consist of one large tank with the capacity of 16000000 gallons and two smaller tanks with capacities of 269160 gallons each The large tank is located in the northwest corner of mill area basin B3 and is primarily used for acid storage and unloading The tank support for the large tank is on mound above depression which would contain significant spill All flows resulting would be channeled to Cell 1-I The tank is equipped with high level audible alarm which sounds prior to tank overflows concrete spill catchment with sump in the back provides added containment around the base of the tank However the catchment basin would not be able to handle major tank failure such as tank rupture The resulting overflow would flow towards Cell 1-I The two smaller storage tanks are located within an equal volume spill containment dike east of the mill building The tanks are not presently in use but are equipped with high level audible alarms The reportable quantity for sulfuric acid spill is 65 gallons 1000 pounds 1.5.8 Vanadium Pentoxide Vanadium pentoxide is produced when vanadium is processed through the drying and fusing circuits and is not present in the vanadium circuit until after the deammoniator Efforts will be made to minimize leaks or line breaks that may occur in processes in the circuit that contain vanadium pentoxide Special care will be taken in the transportation of this chemical The reportable quantity for vanadium pentoxide spill is 1000 pounds 1.5.9 Kerosene Organic The kerosene storage area is located in the central mill yard and has combined capacity of 10152 gallons in three tanks Any overflow from these three tanks would flow around the south side of the SX building and then into Cell 1-I These tanks have drain valves which remain locked unless personnel are supervising draining operations The reportable quantity for kerosene spill is 100 gallons 1.6.0 Used Waste Oil Used Waste oil for parts washing is located north of the maintenance shop in tank and has capacity of 5000 gallons The tank is contained within concrete containment system Ultimate disposal of the used oil is to an EPA permitted oil recycler Any oil escaping the concrete containment system will be cleaned up Soil contaminated with used oil will be excavated and disposed of in Cell 1.6.1 Propane The propane tank is located in the northwest corner of the mill yard and has capacity of 30000 gallons Daily monitoring of the tank for leaks and integrity inspections will be conducted to minimize potential hazards associated with propane leaks Propane leaks will be reported immediately There is no reportable quantity associated with propane spill 1.7 POTENTIAL PETROLEUM SPILL SOURCES AND CONTAINMENT This section details potential sources of petroleum spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.7.1 Petroleum Tanks 1.7.1.1 Diesel Two diesel storage tanks are located north of the mill building The tanks have capacities of 250 gallons each One of the diesel tanks is for the emergency generator The other tank is located in the pumphouse on an elevated stand Spillage from either tank would ultimately flow into Cell 1-I The reportable quantity for diesel spill is 100 gallons 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.1 Diesel The diesel tank is located on the east boundary of Basin B3 and has capacity of 6000 gallons The tank is contained within concrete catchment pad The reportable quantity for diesel spill is 100 gallons 1.7.2.2 Unleaded Gasoline The unleaded gasoline tank is located next to the diesel tank The unleaded gasoline tank has capacity of 3000 gallons and is contained within the same containment system as the diesel tank The reportable quantity for an unleaded gasoline spill is 100 gallons 1.7.2.3 Pump Station Both the diesel and the unleaded gasoline tanks will be used for refueling company vehicles used around the mill site The pump station is equipped with an emergency shut-off device in case of overflow during fueling In addition the station is also equipped with piston leak detector and emergency vent Check valves are present along with tank monitor console with leak detection system The catchment is able to handle complete failure of one tank However if both tanks failed the concrete catchment pad would not be able to contain the spill In this case temporary berm would need to be constructed Absorbent diapers or floor sweep would be used in an effort to limit and contain the spill The soil would be cleaned up and placed in the authorized disposal area in Cell 1.7 2.4 Truck Unloading In the event of truck accident resulting in an overturned vehicle in the mill area proper reporting and containment procedures will be followed when warranted such as when oil or diesel fuel is spilled Proper clean-up procedures will be followed to minimize or limit the spill The spill may be temporarily bermed or localized with absorbent compounds Any soils contaminated with diesel fuel or oil will be cleaned up and placed in the authorized disposal area in Cell 1.8 SPILL DISCOVERY AND REMEDIAL ACTION Once chemical or petroleum spill has been detected it is important to take measures to limit additional spillage and contain the spill that has already occurred Chemical or petroleum spills will be handled as follows The Shift Foreman will direct efforts to shut down systems if possible to limit further release The Shift Foreman will also secure help if operators are requiring additional assistance to contain the spill The Shift Foreman is also obligated to initiate reporting procedures Once control measures have begun and personal danger is minimized the Shift Foreman will notify the Production Superintendent Maintenance Superintendent or Mill Manager The Production or Maintenance Superintendent will notify the Mill Manager who in turn will notify the Environmental Health and Safety Manager The Mill Manager will assess the spill and related damage and direct remedial actions The corrective actions may include repairs clean up disposal and company notifications Government notifications may be necessary in some cases If major spill continues uncontrolled these alternatives will be considered Construct soil dikes or pit using heavy equipment Construct diversion channel into an existing pond Start pumping the spill into an existing tank or pond Plan further clean-up and decontamination measures 1.9 SPILL INCIDENT NOTIFICATION 1.9.1 External Notification As stated in Section 1.1 spills are not expected to reach navigable waters of the United States If spill of reportable quantity occurs then mill and corporate management must be notified and they will evaluate whether or not the following agencies must be notified EPA National Response Center 1-800-424-8802 State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah 801/538-7200 Water Quality Division 801/538-6146 In case of tailings dam failure contact the following agencies State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah Natural Resources 801/538-7200 1.9.2 Internal Notification Internal reporting requirements for incidents spills and significant spills are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions and accidents Government investigations information requests or enforcement actions Private actions or claims corporate or employee Deviations from corporate policies or government requirements by management Which have or could result in the following Death serious injury or adverse health effects Property damage exceeding $1000000 10 Government investigation or enforcement action which limits operations or assesses penalties of $100000 or more Publicity resulted or anticipated Substantial media coverage Report At The Beginning Of The Next Day Event Criteria Was reported to government agency as required by law Worker employee or contractor recordable injury or illness associated with release Community impact-reported or awareness Publicity resulted or anticipated Release exceeding the reportable quantities listed in Section 1.5 for each specific process material waste or by-product In the event of spill of reportable quantity the Mill Manager is required to call the Corporate Environmental Manager or the President and Chief Executive Officer The individual first discovering the spill will report it to the Shift Foreman Production Superintendent or Maintenance Superintendent who will in turn ensure that the Mill Manager is notified The Environmental Health and Safety Manager will also be contacted by the Mill Manager Name Title Home Phone Mill Personnel Richard Bartlett Interim Mill Manager 435 678-2495 Wade Hancock Maintenance Foreman 435 678-2753 David Turk Environmental Health and Safety Manager 435 678-7802 N/A Production Superintendent N/A Maintenance Foreman Scot Christensen Mill Shift Foreman 435 678-2015 Corporate Personnel Ronald Hochstein President and Chief Operating Officer 604 377-1167 David Frydenlund Vice President and General Counsel 303 221-0098 In the event the next person in the chain-of-command cannot be reached then proceed up the chain-of-command to the next level Table 1.0 shows the organizational chart for the mill site 11 1.10 RECORDS AND REPORTS The following reports and records are to be maintained in Central Files by the Environmental Health and Safety Manager for inspection and review for minimum of three years Record of site monitoring inspections Daily Tailings Inspection Data Weekly Tailings Inspection and Survey Monthly Tailings Inspection Pipeline thickness Quarterly Tailings Inspection Tank to soil potential measurements Annual bulk oil and fuel tank visual inspections Tank and pipeline thickness tests Quarterly and annual PCB transformer inspections if transformer contains PCBs Tank supports and foundation inspections Spill Incident Reports Latest revision of SPCC plan 1.11 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES All new employees are instructed on spills at the time they are employed and trained They are briefed on chemical and petroleum spill prevention and control They are informed that leaks in piping valves and sudden discharges from tanks should be reported immediately Abnormal flows from ditches or impoundments are of immediate concern In addition safety meeting is presented annually by the Environmental Health and Safety Manager to review the SPCC plan 1.11.1 Training Records Employee training records on chemical and petroleum spill prevention are maintained in the general safety training files 1.11.2 Monitoring Reports Shift logs shall provide checklist for inspection items 12 1.12 REVISION This procedure is to be reviewed by the mill staff and registered professional engineer at least once very th ree years and updated when circumstances warrant revision 1.13 Summary Below is table listing the specific reportable quantities associated with the major chemical and petroleum products on-site CHEMICAL REPORTABLE QUANTITY RQ AMMONIA 100 POUNDS AMV 1000 POUNDS SODIUM HYDROXIDE 1000 POUNDS SODA ASH No Reportable Quantity SODIUM CHLORATE 400 GALLONS SULFURIC ACID 1000 POUNDS VANADIUM PENTOXI DE 1000 POUNDS KEROSENE 100 GALLONS OIL No Reportable Quantity PROPANE No Reportable Quantity DIESEL UNLEADED FUEL 100 GALLONS 13 1.14 MILL MANAGER APPROVAL hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with the Standard Operating Procedures currently in effect Richard Bartlett Interim Mill Manager 1.15 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with good engineering practices Harold Roberts Registered Professional Engineer State of Utah No 165838 14 TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Rome Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.166 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Rome Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE 2.0 REAGENT TANK LIST QUANTITY REAGENT CAPACITY GAL DIESEL 250 KEROSENE 10152 USED/WASTE OIL 5000 DIESEL 6000 UNLEADED 3000 PROPANE 30000 AMMONIA 31409 SODIUM HYDROXIDE 19904 SODA ASH SOLUTION 16921 SODA ASH SHIFT 8530 SODIUM CHLORATE 17700 SODIUM CHLORATE 10500 SULFURIC ACID 1600000 SULFURIC ACID 269160 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 bTtr\t_- Aluminum nitrate 2270 kg 1.6 kg Ammonium bifluoride 45.4 kg 2.27 kg Ammonium chloride 2270 kg 2.27 kg Ammonium oxalate 2270 kg 6.8 kg Ammonium thiocyanate 2270 kg 7.8 kg Antimony potassium tartrate 45.4 kg 0.454 kg n-Butyl acetate 2270 kg Carbon tetrachloride 4.54 kg 1.0 Cyclohexane 454 kg 24 Ferric chloride 454 kg 6.810 kg Ferrous ammonium sulfate 454 kg 0.57 kg Potassium chromate 4.54 kg 0.114 kg Sodium nitrite 45.4 kg 2.5 kg Sodium phosphate tribasic 2270 kg 1.4 kg Zinc acetate 454 kg 0.91 kg ChethiŁa11oIatiIei4and/1 RQLCi cct Cr Chloroform 4.54 kg Formaldehyde 45.4 kg IL of 37%solution Nitrobenzene 454 kg 12 Toluene 454 kg 12 -j 1ttti .c-tt 7Uaflfl$SStc1c Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 CHEMICAU C941y4--C1z _________ Acetic Acid Glacial 1000 lbs COMPOUND gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 Ibs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs 5kg IlIbs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 REAGENT QUANTITYIN REAGENT YARD Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfloc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT -.-QUANTITYINI WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout GR I Z Z L Y DE C O N T A M I N A 1 I O N PA D DIE S E L SA M P L E PL A N T I_ _ It _ s o 10 sc g L E I N T I E T Figure White Mesa Mill Mill Site Drainage Basins APPENDIX WHITE MESA MILL EMERGENCY RESPONSE PLAN EMERGENCY RESPONSE PLAN REVISION 1.1 Denison Mthes USA Corp t1TL--aa...r aimYVILLICIVICScLIVIIII landing Utah April14 1986 REVISED February 16 2007 Distribution List Ron Hochstein Rich Bartlett David Turk Michael Spillman Mill Shift Foremen Blanding Fire Department San Juan County EMS Coordinator State of Utah Department of Radiation Control Revision Date Januaiy 162006 TABLE OF CONTENTS Page Number 1.0 Introduction 2.0 White Mesa Mill Background 3.0 Plan Objectives 4.0 Description of Facilities 4.1 Fire Water Supply and Alarm Systems 4.2 Office Building and Laboratory 4.3 Solvent Extraction Building 4.4 Mill Building 4.5 Maintenance Shop/Warehouse/Change Room Building 4.6 Reagent and Fuel Storage 4.7 Boiler House 4.8 Sample Plant 5.0 Organization and Responsibilities 5.1 Mill Manager/Incident Commander 5.2 Operations Superintendent 5.3 Radiation Safety Officer/Fire Chief 5.4 Maintenance Supervisor 5.5 Laboratory Supervisor 5.6 Shift Foremen 5.7 Scale House Personnel 5.8 Emergency Response Teams 6.0 Specific Emergencies 10 6.1 Fire 10 6.2 Chemical or Gas Release 10 6.3 Earthquake 10 6.4 Terrorist/Bomb Threat 10 6.5 Tailings Dam Break and Major Floods 10 7.0 Evacuation Procedure 11 7.1 Notification II 7.2 Assembly 11 7.3 Specific Procedures for Operations Personnel II 8.0 Off-Site Emergency Equipment/Personnel Release 11 9.0 Emergency Equipment 12 9.1 Fire Hose 12 9.2 Self Contained Breathing Apparatus 12 9.3 Spill Clean-up Equipment 12 9.4 Fire Fighting PPE 12 10.0 Emergency Transportation 13 11.0 Emergency Evacuation Drills 13 EXHIBITS Emergency Notification List E- Internal Notifications E-2 Site Layout Map E-3 Main Shut-off Valves E-4 APPENDICES Emergency Procedure Response to Fire A-I Emergency Procedure Response to Chemical or Gas Release A-2 Emergency Evacuation Procedure A-3 FIGURES Fire System Schematic F-I ii INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 INTRODUCTION This Emergency Response Plan is written not only to comply with Federal State and local regulations but even more importantly to reduce the risk to our employees and that of the community in regards to Health Safety and Environmental Emergencies This plan includes the following evaluation of the potential risks for fire explosions gas releases chemical spills and floods including tailings dam failure specific emergency programs for each potential event definition of administrative response actions and definition of the emergency response contacts both internal and external The White Mesa Mill the Mill operates under the following regulatory agencies Utah State Department of Environmental Quality Division of Radiation Control Mine Safety and Health Administration Environmental Protection Agency Utah State Department of Environmental Quality Division of Air Quality and Utah State Division of Natural Resources Bureau of Dam Safety WIIITE MESA MILL OVERVIEW The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and vanadium In addition to the processing of conventional ores the Mill also processes alternate feed materials using similar process steps and chemicals The conventional ore is stored on the Ore Pad shown in Exhibit Alternate feed materials are also stored on the Ore Pad and may be stored in bulk form lined burrito bags liners or drums The descriptions of each alternate feed material are maintained by the Mills Radiation Safety Officer The Mill utilizes semi-autogenous grind circuit followed by hot sulfuric acid leach and solvent extraction process to extract uranium and vanadium from ores using large amounts of sulfuric acid sodium chlorate kerosene amines ammonia and caustic soda in the process The reagent storage tank locations are described in further detail in Section 4.6 Emissions from the Mill process are in the form of air emissions from exhaust stacks and solid/liquid tailings which are stored in the Mills tailings cells located west/southwest of the main Mill building The major exhaust stack parameters are shown in the following table Description Height ft from surface Diameter inches Estimated Flow Rate cfm Leach Exhaust -400 36 13700 Yellow Cake Drying stacks 85 18 4000 per stack Vanadium Roasting Fusion 85 38 4100 P\Admin\Master SOPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 There are also smaller exhaust stacks associated with the Laboratory in the Mill Administration building and the boiler exhaust stack The Mills tailings cells are comprised of four below grade engineered cells Cell 1-I and 4A Liquids are stored in Cell 1-I and Cell the active tailings cell The liquid in the tailings cells is very acidic In addition to the tailings cells there is also an emergency lined catchment basin west of the Mill building Solutions in this basin or the tailings cells should not be used to fight fires in the Mill facility The products of the Mill include ammonium metavanadate AIvIV vanadium pregnant liquor VPL vanadium pentoxide 1205 and yellowcake or uranium concentrate U308 The V2O5 and U308 products are packaged in steel drums for shipment The AMY is packaged in either steel drums or super-saks while the VPL is sold in liquid form in bulk Master files containing Material Safety Data Sheets for all materials in use at the Mill are maintained at the Safety Office Mill Maintenance Office Mill Laboratory and Mill Central Control Room Copies are also on file at the Blanding Clinic Doctors Offices Blanding Fire House and Office of the San Juan County Emergency Medical Coordinator The nearest residence to the Mill is approximately one mile to the north of the Mill the next is residence approximately two miles north of the Mill followed by the community of White Mesa about 3.5 miles to the south The City of Blanding is located approximately miles to the northeast The Mill site is near Utah State Highway 191 and can be accessed by paved access road from the highway to the Mill facilities PLAN OBJECTIVES The primary objectives of this plan are To save lives prevent injuries prevent panic and minimize property/environmental damage to the lowest possible level To evacuate and account for all people in the area including visitors truck drivers contractors etc To provide assembly areas that are as safe as possible and which can be reached without traveling through hazardous area Assembly areas will be properly manned to deal with sick or injured persons and provisions will be made to evacuate those persons to proper shelter To make adequately trained personnel available to cope with rescue and recovery operations as directed by the Incident Commander DESCRIPTION OF FACILITIES The Mill facilities are shown on the Site Layout Map included as Exhibit P\Admin\Master SOPs\Boolc 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc II4TERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.1 Fire Water Supply and Alarm Systems 4.1.1 Fire Water Supply The fire water supply facilities include 400000 gallon Storage Tank of which 250000 gallons are reserved for fire emergencies Centrifugal diesel driven pump rated at 2000 gpm at 100 psi This pump starts automatically when the pressure in the fire main drops below 100 psi See Figure Fire System Schematic When more water is needed for an emergency an additional source is the Recapture Reservoir supply pipeline which can be utilized in emergencies at rate of about 1200 gpm 4.1.2 Alarm System The alarm systems include the following public address system hand held radios siren 4.2 Office Building and Laboratory 4.2.1 Office Building The office building approximately 10000 square feet contains the administration offices radiation health and safety offices and the Mill laboratory The central file vault and the main computer system are also in this building The ambulance is kept on the west side of the office building near the safety office entrance 4.2.2 Laboratory The laboratory facilities contain the following three flammable cabinets keys required chemical storage room south of main lab six fume hoods hoods 12 and are in the center of the laboratory and hoods and are along the west wall Hoods and are no longer in service Hoods and are on the west side and are on the east side of the center cluster of hoods with being in front Only hoods and may be used for perchloric acid outside laboratory chemical storage north of office building key required perchloric acid storage vault located underground west of office building key required wide variety of chemicals in small quantities are located in the laboratory These chemicals range from acids to bases along with flammable metal compounds and peroxide forming compounds Oxidizers and organic chemicals which have strong potential of producing harmful vapors if the containers are damaged to the point that the chemicals are exposed are stored in storage room in the laboratory There are no acids stored in this storage room The acids including but not limited to sulfuric nitric acetic perchloric phosphoric and hydrochloric acids are stored in the main laboratory area in 2.5 liter or 500-mi bottles MSDS books for all P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 chemicals in the laboratory are located in the Laboratory Safety Department Mill Maintenance office and Mill Central Control room 4.2.3 Electrical Electrical transformers and electrical switches are located in the laboratory at the east end of the chemical storage room 4.2.4 Fire Protection System The fire protection systems in the office building and laboratory include fire hose station located on the east end of the office building The station includes two sets of turnout gear two SCBA units and Incident Commander materials automatic wet sprinkler system which is actuated at 212 portable dry chemical extinguishers strategically located throughout the building 4.3 Solvent Extraction Building The solvent extraction SX building approximately 21000 square feet houses the uranium and vanadium solvent extraction circuits and the ELUEX circuit The SX circuits may contain up to 200000 gallons kerosene 757000 liters which has flash point of 185 Associated equipment in the SX building includes temporary boiler located at the southwest end of the SX building which maintains the temperature for the fire system Chemicals which may be encountered in the SX building include Kerosene Caustic Soda Anhydrous Ammonia Sulfuric Acid Salt Brine Soda Ash Ammonium Sulfate Amines Alcohol Sodium Chlorate Sodium Vanadate Propane The VPL product is stored in the SX building 4.3.1 Electrical All electrical switches are located outside in the MCC room north of the SX building The main control panel for all of the equipment is located in the Central Control Room in the main Mill building 4.3.2 Fire Protection System The SX building fire protection systems include P\Admin\Master SOPsBook 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-I Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 wet AFFF foam sprinkler system with heat actuated sprinkler heads that release at 12F portable dry chemical extinguishers strategically located throughout the building For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic included as Figure in this Plan 4.4 Mill Building The mill building approximately 22000 square feet contains process equipment related to grind leach counter current decantation precipitation drying and packaging of uranium and vanadium products Chemicals which may be encountered in the mill building include Caustic Soda Aithydrous Ammonia Sulfuric Acid Soda Ash Ammonium Sulfate Sodium Chlorate Sodium Vanadate Propane The finished products which are contained in the mill building include AMY V205 and U308 or yellowcake 4.4.1 Electrical The main electrical switch gear is located west of the SAG mill on the ground floor in the north west corner of the mill building Circuit control panels are located in the SAG mill control room the central control room the vanadium roaster control room and the AMY area 4.4.2 Fire Protection System The main mill building fire protection systems include portable dry chemical extinguishers strategically located throughout the building water hoses throughout the building For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System Schematic included as Figure of this Plan 4.5 Maintenance Shop/Warehouse/Change Room Building This building approximately 20000 square feet contains the main maintenance shop area located on the north end of the building the main warehouse located on the south end of the building and the personnel change rooms and lunch/training room located on the extreme south end of the building on the ground and second floors Within the maintenance shop area are the following work area and specialty shops P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 the main maintenance shop area contains welding and cuffing equipment lathes presses and drill presses carpenter shop which contains various saws and planes Fiberglass work is also done within this shop area and it is located at the northwest end of the maintenance shop area an electrical shop which is located south of the carpenter shop heavy equipment maintenance shop area is located at the north end of the maintenance shop in the center of the building rubber room for rubber lining of equipment is located east of the equipment shop area the maintenance shop office instrument shop and tool room are located at the south end of the maintenance shop area The warehouse area contains primarily dry good storage for repair parts and consumables for the operation of the Mill There is an electrical water heater for the change room which is located in the warehouse area at the south end Within the warehouse and maintenance shops there are some oils and chemicals stored in the following locations small quantities of flammable material such as starting fluid and spray paint are kept in the warehouse drums of new oil and anti-freeze are stored along the east wall of the equipment maintenance area and on the east side of the warehouse on oil storage racks used oil is stored in tank located northeast of the equipment shop The tank has capacity of approximately 5800 gallons in the main maintenance shop area and the rubber room there are flammable storage cabinets and east of the warehouse there is trailer which is used to store flammable items such as rubber cements paints and fiberglass resins compressed gas cylinder storage both empty and full is located outside east of the maintenance shop 4.5.1 Electrical The main electrical circuit breaker for the maintenance shop and warehouse building is located on the east wall inside the Maintenance shop Auxiliary electrical panels for the change room and warehouse are located in the southwest corner of the warehouse area 4.5.2 Fire Protection System The fire protection system within the maintenance shop/warehouse/change room building includes wet automatic sprinider system that releases at 212 portable dry chemical extinguishers strategically located throughout the maintenance area warehouse area and the change room and lunch room For fire hydrant and hose cabinet locations refer to the Fire System Schematic Figure 4.6 Reagent and Fuel Storage The following lists the reagents and fuel stored at the Mill site P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 sulfuric acid tank located northwest of the mill building which has capacity of approximately 1.4 million gallons storage tank for propane is located on the north edge of the mill site northwest of the mill building It has storage capacity of 30000 gallons four sodium chlorate tanks located east of SX building north of the office building and east of the pulp storage tanks The two tanks east of the SX building are for sodium chlorate storage and the other two tanks are for dilution of the sodium chlorate two anhydrous ammonia tanks located east of the SX building with capacity of 31409 gallons each three kerosene tanks located east of the SX building with capacity of 10152 gallons each one caustic soda tank north of the SX building with capacity of 19904 gallons three soda ash tanks which are located east of the SX building One tank is the dry soda ash tank with capacity of 70256 gallons Two of the tanks are soda ash dilution tanks with capacities of 16921 gallons each diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad The gasoline storage capacity is 3200 gallons while diesel storage capacity is 8000 gallons Other reagents are stored in steel barrels or super sacs in reagent yard located east of the office building Typical reagents which are stored in this yard include polymers and flocculants boiler feed water chemicals methanol tributyl phosphate dirty soda ash and ammonium sulfate SX amines and emulsion breakers decyl alcohol minimal amounts of acid in barrels used oil in drums and overpacks 4.7 Boiler Facilities The main building approximately 12400 square feet is located on the west side of the Mill site and contains air compressors and water treatment facilities To the north of the main building is building which houses propane-fired boiler The vanadium oxidation tank oxidation thickener and pH adjustment tank are located south of the boiler house facilities 4.7.1 Electrical The main electrical panel for the boiler house is located outside of the building on the south wall 4.7.2 Fire Protection System The fire protection system for the boiler facilities is comprised of strategically located portable dry chemical extinguishers P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.8 Sample Plant The sample plant building approximately 8000 square feet is located on the ore pad east of the maintenance shop/warehouse building The sampling plant equipment has been removed from the building and it is cunently used as storage area for maintenance 4.8.1 Electrical The electrical panel for this building is located on the east wall upstairs 4.8.2 Fire Protection System There are no extinguishers or sprinider systems in the sample plant ORGANIZATION AND RESPONSIBILITIES The organizational chart for an emergency situation is illustrated in Figure 5.1 Mill Manager/Incident Commander The Incident Conunander has the responsibility for preparing an Emergency Plan communicating the Plan directing activities during emergencies and reporting to local State and Federal authorities The Incident Commander will stop routine radio usage upon learning of an emergency and set up the base station in safe location for directing activities Radio usage will be limited to the emergency The Incident Commander has the responsibility to contact all outside services The Incident Commander has the responsibility to account for all employees at the Mill using the assistance of supervisors and/or any International Uranium USA Corporation IUSA personnel The Incident Commander has the responsibility for the news media and reports directly to the President of IUSA 5.2 Mill General Superintendent The Mill General Superintendent has the responsibility of directing outside emergency personnel and has the responsibility for plant security and will report directly to the Incident Commander The Mill General Superintendent will act as Incident Commander in the absence of the Mill Manager 5.3 Radiation Safety Officer/Fire Chief The Radiation Safety Officer will direct rescue operations and provide the necessary emergency medical personnel and facilities to cope with the emergency Adequately trained fire crews and operable emergency equipment will be maintained at all times P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 As Fire Chief the Radiation Safety Officer has the responsibility to maintain trained fire crews and operable equipment mobilize and direct the fire crews and equipment in fire emergency or one containing the threat of fire and to assist in evacuation and rescue or recovery operations In the absence of the Radiation Safety Officer the Mill Safety Coordinator will assume these duties 5.4 Maintenance Supervisor The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with the emergency including isolation of utilities and providing technical advice as needed The Maintenance Supervisor will be assisted by the Mill Safety Coordinator 5.5 Laboratory Supervisor The Laboratory Supervisor has the responsibility to direct and account for all office personnel including IUSA personnel and office visitors in evacuation and in activities to cope with the emergency In case of mill tour the Supervisor accompanying the tour will be responsible for evacuation of visitors 5.6 Shift Foremen Shift Foremen are in charge until the Incident Commander arrives and are responsible for all functions listed above Shift Foremen have the responsibility to account for all of their people in addition to any visitors contractors etc in their areas and report to the Incident Commander or in the absence of the Incident Commander to administer all of the above duties 5.7 Scale House Personnel Scale house person on shift will be responsible to account for ore truck drivers and reagent truck drivers 5.8 Emergency Response Teams The response crew for each operating shift will normally consist of the following operators under the direction of the shift foreman This organization may be changed for individual shifts subject to the approval of the Fire Chief 5.8.1 Operational Mode Leach Operator CCD Operator Solvent Extraction Operator Mill Trainee 5.8.2 Non-Operational Mode Shift Foreman Operations Personnel Maintenance Personnel P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 10 of 13 Figure Emergency Response Organizational Structure Incident Commander Mitt Manager Director of Security Operations Supedntendent Fire Chief Radiation Safety Officer Shift Foremen Emergency Response Teams Lab Supervisor Operational Mode Non-Operational Mode Leach Operator CCD Operator Shift Foreman Operations Personnel SX Operator Mill Trainee Maintenance Personnel SPECIFIC EMERGENCIES The following details procedures to be followed during specific emergencies but are not limited to the following 6.1 Fire Should fire occur the procedure outlined in Appendix for reporting and responding to fires will be followed Particular areas of concern include Solvent Extraction Building Propane Tanks Lab or Lab Storage Area 6.2 Chemical or Gas Release The procedures for response to chemical or gas release are outlined as Appendix 6.3 Earthquake Although this is highly unlikely an earthquake could occur at the Mill severe earthquake could cause buildings and other structures to collapse chemical and/or gas releases major fires as well as general panic In the event of major earthquake the evacuation procedures outlined in Appendix will be followed P\Admin\Master 5OPs\Book 16_Emergency Response PlanWmergency Response Plan Rev 09.29.05.doc 10 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 11 of 13 6.4 Terrorist/Bomb Threat In the event that any person should receive threat of bomb the following evacuation procedure should be followed Notify any person of authority i.e Superintendent Foreman Radiation Safety Officer who will immediately notify law enforcement authorities and evacuate the threatened area Evacuate all persons from the affected area and stop all radio transmissions 6.5 Tailings Dam Break and Major Floods Flood water breaching tailings embankments presents one of the greatest dangers for the sudden release of tailings solids and impounded water The tailings cells are designed with sufficient freeboard three feet to withstand back-to-back 100-year storm events or 40%of the probable maximum flood PMF followed by the 100-year storm event The flood design is equivalent to 15 inches of rainfall In addition the tailings dikes were designed in accordance with U.S NRC regulations and allow sufficient margin of safety even in the event of an earthquake The possibility of floods resulting from Westwater Creek Cottonwood Creek and Corral Creek causing dam failure is extremely remote The tailings cells and dikes are inspected on both daily and shift basis Discharges from dike failure would extend three miles before leaving IUSAs property In the event of dam failure large operating equipment will be mobilized to construct temporary earthen dikes or berms downgradient to the failed dike In addition the State of Utah Department of Radiation Control Executive Secretary the Executive Secretary MSIIA and State of Utah Department of Natural Resources Division of Dam Safety shall be notified In the event of seismic rupture of tailings slurry pipelines the released slurry will be contained in the tailings cells regardless of the quantity released EVACUATION PROCEDURE See Appendix 7.1 Notification Employees will be notified to evacuate the area by dialing 184 on any area telephone and announcing that the Mill should be evacuated This announcement will be repeated twice When the paging system cycles through the evacuation siren continuous frequency will automatically sound for approximately forty-five seconds and then automatically shut off allowing communications by radio from that point If the 184 number is dialed accidentally the evacuation alarm may be canceled by disconnecting the phone until the page cycle ends then re dial 184 See Exhibits and 7.2 Assembly When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all personnel will assemble at The parking lot south of the office PAdmin\Master SOPs\Book 16_Emergency Response Plan \Ernergency Response Plan Rev 09.29.05.doc 11 INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 12 of 13 The scalehouse North side of Tailings Cell or North of the Mill Assembly site will depend upon conditions i.e nature of the emergency wind conditions etc The Fire Chief or Shift Foreman will specify the appropriate assembly site 7.3 Specific Procedure for Operations Personnel See specific emergency shutdown procedure for Operations by area under the relevant Operating Procedure for your area All employees not mentioned under Operating Procedures are to immediately report to the assembly area and congregate by crew so that all persons can be accounted for As employees leave their work areas they must pass the word to evacuate to any persons who may not be aware of the emergency After the Mill has been detennined to be safe for re-entry employees will be verbally notified to return to their work stations Off-Site Emergency Equipment/Personnel Release Any emergency response equipment or personnel that enter the Restricted Area in response to an incident will be scanned and decontaminated prior to leaving the site according to the procedures included in PBL-9 End Dump Trailer Acceptance ilandling and Release Any equipment will be decontaminated according to the requirements found in Table of the Nuclear Regulatory Commissions NRCs Policy and Guidance Directive FC-85-23 Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct Source or Special Nuclear Material issued May 1987 Injured personnel should be evaluated for radiation contamination if there was potential for contamination at the earliest convenience Should it be necessary contaminated articles will be gathered by the radiological staff after medical treatment has been rendered If the personnel cannot be decontaminated notify the clinic/hospital personnel in advance EMERGENCY EQUIPMENT Emergency equipment for the Mill is provided as follows 9.1 Fire Hose Fire hose cabinets are located at the following sites with minimum of 300 feet of 2-1/2 hose two spanner wrenches spray nozzles and one hydrant wrench South of SX West of CCD North of Mill Building East of pulp storage tanks Northwest of Maintenance Shop West of Warehouse P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 12 INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 13 of 13 East of office building 9.2 Self Contained Breathing Apparatus Two Self-Contained Breathing Apparatus are located at each of the following locations Hose station east of office building Hose Station South of SX North End SX Outside Wall North end of Mill building outside wall 9.3 Spill Clean-up Equipment Barrels of soda ash are located throughout the Mill to be used in case of chemical spill Soda ash is also stored in bulk if needed There are also few drums of absorbent stored near the laboratory The laboratory also contains acid spill kits and absorbent materials to be used in case of spill 9.4 Fire Fighting PPE Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in the Fire Hose Station located on the east side of the office building 9.5 Maintenance of Emergency Equipment Fire extinguishers are inspected on an annual basis as well as the fire pump system The Mill Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure that all of the equipment is in place 10 EMERGENCY TRANSPORTATION One filly-equipped First Responder Unit Ambulance located west of the office building Other motor pool vehicles on the property will be utilized as needed in emergency situations with support as needed from the local Emergency Medical Services 11 EMERGENCY DRILLS AND TRAINING Quarterly drills as required by MSHA are prepared by the Safety and Radiation Departments to monitor performance of personnel responding to emergency situations Each drill will be enacted upon one or more of the potential scenarios by this plan The drill and evacuation activities are documented by the Mills Safety Coordinator and maintained within plant files Management will review all drills at quarterly ALARA Committee Meetings P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 13 EXHIBIT EMERGENCY NOTIFICATION LIST ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR Give artificial respiration if necessary Control bleeding Treat for shock Immobilize fractures and stabilize for transportation Scan the injured for excessive alpha prior to transporting if time allows If alpha is excessive or there is no time to scan notify the clinic/hospital personnel and the Radiation Safety Office THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED Blanding Clinic 678-2254 or 678-3434 930 400 San Juan Hospital Monticello ...678-2830 or 587-2116 364 1st EMT and CPR TRAINED The following personnel should be contacted if they are on-site in the event of an emergency to aid in the event of any injuries to personnel David Turk EMT and CPR trained Mike Spillman CPR trained AMBULANCE SERVICE Blanding Dial 911 If the Company Ambulance is used an attendant must ride with the injured in addition to the driver except where the injured could normally be transported in car or pickup OTHER EMERGENCY NUMBERS Fire Department Dial 911 or 678-2313 County Sheriff Dial 911 or 587-2237 Highway Patrol Dial 911 or 587-2000 Blanding Police Dial 911 678-2916 or 678-2334 MANAGERS The Supervisor will notify one of the following of all incidents R.E Bartlett 435-678-2495 Turk 435-678-7802 or 435-459-1068 Spillman 435-678-2761 MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING AGENCIES AS REQUIRED FOR EACH INCIDENT State of Utah Department of Radiation Control 801-536-4250 MSHA Field Off.--801-524-3450 Dist Off 303-231-5465 MSHA Arlington 800-746-1553 State Emergency Response Comm 801-538-3400 State of Utah Natural Resources Dam Safety 801-538-7200 National Response Center 800-424-8802 Utah Poison Control Center 800-456-7707 Notification of surrounding communities and or residences will be handled by the appropriate agencies as required by EPCRA Emergency Planning and Community Right to Know Act Revision Date January 16 2006 Ed EXHIBIT INTERNAL NOTIFICATIONS Internal reporting requirements for Incidents Spills and Significant Events are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions or other accidents Government investigations information requests or enforcement actions Private actions or claims corporations or employees Deviations from Corporate policies or government requirements by Management Other significant events which have resulted or could result in Death serious injury or adverse health effect employees or public Property damage exceeding $1000000 Government investigation or enforcement action limiting operation or penalties of $100000 or more Significant criminal actions Substantial media coverage Unscheduled down time of more than 24 hours Report at the Beginning of the Next Business Day Incident Criteria Was reported to government agency as required by law Worker IIJSA or contractor recordable injury or illness associated with release Community impact reported or awareness Publicity resulted or is anticipated Release of process material waste or product in excess of the Reportable Quantities listed in Section 1.5 of the Spill Prevention Control and Countermeasures Plan The local manager in charge is to call Ron Hochstein or Dave Frydenlund Name Title Office Phone Home Phone Ron Hochstein President and COO 303-628-7798 office 604-931-6334 home 604-377-1167 cell David Frydenlund V.P and General Counsel 303-389-4130 office 303-221-0098 home 303-808-6648 cell Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 02.14.07 E-2 EXHIBIT SITE LAYOUT MAP P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-3 ID i l i n t e th 1Z4 -4 Co to EXIIIBIT MAIN SHUT-OFF VALVES During an emergency this list should be used along with Site Layout Map Exhibit to locate tanks and valves associated with these tanks REAGENT SHUT-OFF VALVE LOCATIONS Sulfuric Acid Main located south side of acid tank East acid pump discharge valve West acid pump discharge valve Main leach area located 25 feet west of Denick screens next to walkway 1-1/2 Main SX area located south of Central Control room Ammonia Main east tank located on end at bottom Main west tank located on end at bottom Valve located on top of tank east tank Valve located on top of tank west tank Kerosene Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Pump discharge valve Soda Ash Main valve located at bottom of tank dry storage Main valve located at bottom of tank on 30%dilution tank Main valve locate at bottom of tank on dilution tank Salt Main valve located at bottom of tank Caustic Soda Main valve located at bottom of tank east and west between supports PAAdmin\Master SOPs\Book 16_Emergency Response PlarAEmergency Response Plan Rev 09.29.05.doc E-4 EXHIBIT MAIN SHUT-OFF VALVES Sodium Chlorate Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Propane Main located 15 feet east of tank Main located on pipe off top of tank Main located at bottom of tank also fill pipe PLANT UTILITY SHUT-OFF VALVE LOCATIONS Process Water Main valve located on west side of water storage tank Discharge valve off service water pump east Discharge valve off service water pump west Mill process water main located east wall by SAG mill Fire Water Main valve located west side of water storage tank Emergency fire pump discharge valve to fire system Emergency fire pump discharge valve to header west side of pump house Main valve located south of Central Control room for SX and boilers Potable Water Main suction from potable water storage tank Main discharge from potable water storage tank Main located at east wall by SAG mill Main located south of Central Control room for SX Maintenance shop and offices Steam Main discharge valve for Superior boiler located at top of boiler Main steam valve located south side of boiler house P\AcImin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 EXHIBIT MAIN SHUT-OFF VALVES Plant Air Main valve located at receiver tank in compressor room at boiler house Main valve to mill building located south of Central Control room PROCESS SHUT-OFF VALVE LOCATIONS Pulp Storage No valve located on west side of tank No valve located on west side of tank Preleach old No pulp storage valve located on west side of tank Preleach Thickener Main valve located underneath at center cone Clarifier Main valve located underneath at center cone Main valve located underneath at center cone CO Thickeners Main valve located underneath at center cone of each thickener PAdminMaster 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 APPENDIX EMERGENCY PROCEDURE RESPONSE TO FIRE The fire will be reported by dialing 185 on any telephone in the area and announcing the location of the fife over the paging system This announcement will be repeated twice for total of three announcements When the paging system cycles through the fire siren alternating frequency will automatically sound for approximately forty-five seconds then automatically shut off allowing radio communications to resume Mobilize the fire crew Evacuate all personnel Rescue any victims of the fire do this only with properly trained and equipped personnel Isolate utility lines affected by the fire Extinguish the fire and post fife watch for flare-ups Report the fire to proper local State Corporate and Federal agencies In cases where the fire is not extinguished within thirty minutes of discovery the area must be barricaded off after extinguishing and left undisturbed until released by MSHA and IUSA management Emergency off-site centers Blanding Fire House and Sheriffs office landing Fire 350 West 200 South Blanding Phone number is 911 Sheriffs Office 50 West 100 South Blanding Phone number is 911 or 435 587-2237 P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-I APPENDIX EMERGENCY PROCEDURE RESPONSE TO CHEMICAL OR GAS RELEASE chemical or gas release would most likely occur very suddenly The person who would first witness chemical or gas release should immediately contact his supervisor who would initiate the procedures outlined below Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped by the release Provide first aid and emergency medical care for any ill or injured persons Initiate necessary steps to contain and/or neutralize the release such as spraying with water fog turning off valves etc Guard against possible fires by shutting off electrical circuits isolating gas lines and nfl c.tfl rnnn 4rnn 10 .-Pf000A orao X.tJAZ14SLtI.JJ15 15AL1L1J1S OJt41.O .LZ%JZA2 L1fl %1j%..IA.tt tu.t. P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29 05.doc A-I APPENDIX EMERGENCY EVACUATION PROCEDURE Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Personnel are to assemble in one of the following areas The parking lot south of the office building The scalehouse The north side of Tailings Cell or North of the Mill Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped Provide first aid and emergency medical care for any ill or injured persons Guard against possible fires by shutting off electrical circuits isolating gas lines and eliminating ignition sources from the affected area P\Admin\Master 5OPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc A-i FIGURE FIRE SYSTEM SCHEMATIC DRAWING P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc A-I 44 t l L MI I V S S 4% Si oil fl t l % f l % -5 ci a tf l r q r aa o n ks P \ Pi o% J s l O C I So o n sm lf l % f l ws a r q sf l i r rt ro i Y1 o s dI . O a- .6 l- .L r e - e lS 04 dV i f l j ef l f l 4 Oo o fl 3 I tO fl t 2 S j .1 OO o O % t .M P r c L tl O I L n N 1v r oo o o e f r STORM WATER BEST MANGEMENT PRACTICES PLAN for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Blanding Utah June 2008 Prepared by Denison Mines USA Corp 1050 17th Street Suite 950 Denver CO 80265 TABLE OF CONTENTS 1.0 Purpose 2.0 Scope 3.0 Responsibility 4.0 Best Management Practices 4.1 General Management Practices Applicable to All Areas 4.2 Management Practices for Process and Laboratory Areas 4.3 Management Practices for Maintenance Activities 4.4 Management Practices for Ore Pad Tailings Area and heavy Equipment Operations Figures Figure White Mesa Mill Site Map Figure Mill Site Drainage Basins Figure JUSA Mill Management Organization Chart Figure IUSA Corporate Management Organization Chart Tables Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Appendices Appendix White Mesa Mill Spill Prevention Control and Countermeasures Plan Appendix White Mesa Mill Emergency Response Plan Best Management Practices Plan Revision 1.3 June 12 2008 1.0 INTRODUCTION/PURPOSE Denison Mines USA Corp DUSA operates the White Mesa Uranium Mill the Mill in Blanding Utah The Mill is net water consumer and is zero-discharge facility with respect to water effluents That is no water leaves the Mill site because the Mill has no outfalls to public stormwater systems no surface runoff to public stormwater systems no discharges to publicly owned treatment works POTWs and no discharges to surface water bodies The State of Utah issued Groundwater Discharge Permit No UGW3 70004 to DUSA on March 2005 As part of compliance with the Permit DUSA is required to submit Stormwater Best Management Practices Plan BMPP to the Executive Secretary of the Division of Radiation Control Utah Department of Environmental Quality This BMPP presents operational and management practices to minimize or prevent spills of chemicals or hazardous materials which could result in contaminated surface water effluents potentially impacting surface waters or ground waters through runoff or discharge connections to stormwater or surface water drainage routes Although the Mill by design cannot directly impact stormwater surface water or groundwater the Mill implements these practices in good faith effort to minimize all sources of pollution at the site Page Best Management Practices Plan Revision 1.3 June 12 2008 2.0 SCOPE This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in process operations laboratory operations and maintenance activities and minimize spread of particulates from stockpiles and tailings management areas at the Mill Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this BMPP The Mill site was constructed with an overall grade and diversion ditch system designed to channel all surface runoff including precipitation equivalent to Probable Maximum Precipitation/Probable Maximum Flood PMP/PMF storm event to the tailings management system In addition Mill tailings all other process effluents all solid waste and debris except used oil and recyclable materials and spilled materials that cannot be recovered for reuse are transferred to one or more of the tailings cells in accordance with the Mills NRC license conditions All of the process and laboratory building sinks sumps and floor drains are tied to the transfer lines to the tailings impoundments site map of the Mill is provided in Figure sketch of the site drainage basins is provided in Figure As result unlike other industrial facilities whose spill management programs focus on minimizing the introduction of chemical and solid waste and wastewater into the process sewers and storm drains the Mill is permitted by NRC license to manage some spills via draining or washdown to the process sewers and ultimately the tailings system However as good environmental management practice the Mill attempts to minimize the number and size of material spills and the amount of unrecovered spilled material and washwater that enters the process sewers after spill cleanup Section 4.0 itemizes the practices in place at the Mill to meet these objectives Requirements and methods for management recordkeeping and documentation of hazardous material spills are addressed in the DUSA White Mesa Mill Spill Prevention Control and Countermeasures SPCCPlan Revised February 2007 the Emergency Response Plan ERP also revised in February 2007 and the housekeeping procedures incorporated in the White Mesa Mill Standard Operating Procedures SOPs The SPCC plan and the ERP are provided in their entirety in Appendices and respectively Page Best Management Practices Plan Revision 1.3 June 12 2008 3.0 RESPONSIBILITY All Mill personnel are responsible for implementation of the practices in this BMPP DUSA White Mesa Mill management is responsible for providing the facilities or equipment necessary to implement the practices in this BMPP The Mill Management Organization is presented in Figure The DUSA Corporate Management Organization is presented in Figure An updated spill prevention and control notification list is provided in Table Page Best Management Practices Plan Revision 1.3 June 12 2008 4.0 BEST MANAGEMENT PRACTICES summary list and inventory of all liquid and solid materials managed at the Mill is provided in Tables through 4.1 General Management Practices Applicable to All Areas 4.1.1 Keep Potential Pollutants from Contact with Soil and Surface Water Store hazardous materials and other potential pollutants in appropriate containers Label the containers Keep the containers covered when not in use 4.1.2 Keep Potential Pollutants from Contact with Precipitation Store bulk materials in covered tanks or drums Store jars bottle or similar small containers in buildings or under covered areas Replace or repair broken dumpsters and bins Keep dumpster lids and large container covers closed when not in use to keep precipitation out 4.1.3 Keep Paved Areas from Becoming Pollutant Sources Sweep paved areas regularly and dispose of debris in the solid waste dumpsters or tailings area as appropriate 4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and Reagent Storage Area Diversion ditches drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly in accordance with the regularly scheduled inspections required by Groundwater Discharge Permit No UGW370004 and Byproduct Materials License UT1900479 Areas requiring maintenance or repair such as excessive vegetative growth channel erosion or pooling of surface water runoff will be report to site management and maintenance departments for necessary action to repair damage or perform reconstruction in order for the control feature to perform as intended Status of maintenance or repairs will be documented during follow up inspections and additional action taken if necessary 4.1.5 Recycle Fluids Whenever Possible When possible select automotive fluids solvents and cleaners that can be recycled or reclaimed When possible select consumable materials from suppliers who will reclaim empty containers Keep spent fluids in properly labeled covered containers until they are picked up for recycle or transferred to the tailings area for disposal Page Best Management Practices Plan Revision 1.3 June 12 2008 4.2 Management Practices for Process and Laboratory Areas 4.2.1 Clean Up Spills Properly Clean up spills with dry cleanup methods absorbents sweeping collection drums instead of water whenever possible Clean spills of stored reagents or other chemicals immediately after discovery Groundwater Discharge Permit No UGW370004 Section I.D.8.c Recover and re-use spilled material whenever possible Keep supplies of rags sorbent materials such as cat litter spill collection drums and personnel protective equipment PPE near the areas where they may be needed for spill response If spills must be washed down use the minimum amount of water needed for effective cleanup 4.2.2 Protect Materials Stored Outdoors If drummed feeds or products must be stored outdoors store them in covered or diked areas when possible If drummed chemicals must be stored outdoors store them in covered or diked areas when possible Make sure drums and containers stored outdoors are in good condition and secured against wind or leakage Place any damaged containers into an overpack drum or second container 4.2.3 Water Management When possible recycle and reuse water from flushing and pressure testing equipment When possible wipe down the outsides of containers instead of rinsing them off in the sink When possible wipe down counters and work surfaces instead of hosing or rinsing them off to sinks and drains 4.2.4 Materials Management Purchase and inventory the smallest amount of laboratory reagent necessary Do not stock more of reagent than will be used up before its expiration date All new construction of reagent storage facilities will include secondary containment which shall control and prevent any contact of spilled reagents or otherwise released reagent or product with the ground surface Groundwater Discharge Permit No UGW370004 Section I.D.3.e Page Best Management Practices Plan Revision 1.3 June 12 2008 4.3 Management Practices for Maintenance Activities 4.3.1 Keep Clean Dry Shop Sweep or vacuum shop floors regularly Designate specific areas indoors for parts cleaning and use cleaners and solvents only in those areas Clean up spills promptly Dont let minor spills spread Keep supplies of rags collection containers and sorbent material near each work area where they are needed Store bulk fluids waste fluids and batteries in an area with secondary containment double drum drip pan to capture leakage and contain spills 4.3.2 Manage Vehicle Fluids Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible Use drip pans or plastic tarps to prevent spillage and spread of fluids Promptly contain and transfer drained fluids to appropriate storage area for reuse recycle or disposal Recycle automotive fluids if possible when their useful life is finished 4.3.3 Use Controls During Paint Removal Use drop cloths and sheeting to prevent windborne contamination from paint chips and sandblasting dust Collect contain and transfer as soon as possible accumulated dusts and paint chips to disposal location in the tailings area authorized to accept waste materials from maintenance or construction activities 4.3.4 Use Controls During Paint Application and Cleanup Mix and use the right amount of paint for the job Use up one container before opening second one Recycle or reuse leftover paint whenever possible Never clean brushes or rinse or drain paint containers on the ground paved or unpaved Clean brushes and containers only at sinks and stations that drain to the process sewer to the tailings system Paint out brushes to the extent possible before water washing water-based paint or solvent rinsing oil-based paint Filter and reuse thinners and solvent whenever possible Contain solids and unusable excess liquids for transfer to the tailings area Page Best Management Practices Plan Revision 1.3 June 12 2008 4.4 Management Practices for Ore Pad Tailings Area and Heavy Equipment Detailed instructions for ore unloading dust suppression and tailings management are provided in the Mill SOPs 4.4.1 Wash Down Vehicles and Equipment in Proper Areas Wash down trucks trailers and other heavy equipment only in areas designated for this purpose such as washdown pad areas and the truck wash station At the truck wash station make sure the water collection and recycling system is working before turning on water sprays 4.4.2 Manage Stockpiles to Prevent Windborne Contamination Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill SOPs Water spray stockpiles as required by opacity standards or weather conditions Dont over-water Keep surfaces moist but minimize runoff water 4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources Schedule excavation grading and other earthrnoving activities when extreme dryness and high winds will not be factor to prevent the need for excessive dust suppression Remove existing vegetation only when absolutely necessary Seed or plant temporary vegetation for erosion control on slopes Page TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Rome Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.l66 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Home Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Fryderihmd Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE REAGENT YARD LIST ADOGEN 2382 ADVANTAGE 1O1M AMERS1TE AMINE 2384 AMMONIUM SULFATE BULK AMMONIUM SULFATE BAGS ANHYDROUS AMMONIA CHEMFAC 100 CLARIFLOC N-1O1P DECYLALCOHOL DIESEL FUEL FLOCCULENT M1O11N FLOCCULENT M1302C GRINDING BALLS ISODECANOL KEROSENE MACKANATE MILLSPERSE 802 NALCO 2458 NALCO 8815 PERCOL 351 PERCOL 406 PERCOL 745 POLOX POLYHALL YCF PROPANE SALT BAGS SALT BULK SODA ASH BAGS SODA ASH BULK SODIUM CHLORATE SODIUM HYDROXIDE SULFURIC ACID UNLEADED GASOLINE USED OIL 6120 2475 19440 54000 4300 107920 12800 3000 45430 30550 3550 48290 45430 1344 3150 1410 1500 13950 10360 39280 39280 84100 101128 4801440 16921 8530 17700 10500 19904 1600000 269160 3000 5000 REAGENT ..2Hy QUANTT\ttBSY NUMBEROFcTh STORAGE TANKS pAc1T. cAaoNs 31409 250 6000 10152 30000 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 Chemical in Lab RQ2 Quantity In Stock Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 6.8 kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg Chemical in Volatiles and RQ2 Quantity In Stock Flammables Lockers ABC Chloroform 4.54 kg Formaldehyde 45.4 kg cl of 37%solution Nitrobenzene 454 kg 12 Toluene 454kg 12L Chemical in Acid Shed RQ2 Quantity In Stock Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 IcHEMItAt tYQ tQijAN7jTht1NN CiRAtE 1kStP Acetic Acid Glacial 1000 lbs toMpooNæ gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 Ibs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs kg 11 Ibs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal 5kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 REAGENT RQ2 QUANTITY IN REAGENT YARD Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfloc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous substances Designated Pursuant to section 311 of the clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT RQ QUANTITY IN WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout 050 0 0 000 200 OC $ L E 0 1 F 0 0 1 In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Pr t J . t WH E r E M E S A MIL L ttv t c t c o t c to t o i t y fl .tooio uta h Ot t Lo o t t a Fi g u r e MIL L S I T E LA Y O U T i_ 2 IO t t i o v tra f f i c - p o t I- Sle d d C o d 000 o i o w n Figure White Mesa Mill Mill Site Drainage Basins Figure White Mesa Mill Mill Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Wh i t e Me s a Mi l l Or g a n i z a t i o n a l St r u c t u r e Fi g u r e Figure Corporate Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Or g a n i z a t i o n a l St r u c t u r e Fi g u r e APPENDICES APPENDIX WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS for White Mesa Uranium Mill 6425 South Highway 191 P.O Box809 Bland ing Utah 84511 February 2007 Prepared by Denison Mines USA Corp 1050 Street Suite 950 Denver Colorado 80265 TABLE OF CONTENTS SECTION PAGE 1.1 Objective 1.2 Responsibilities 1.3 Drainage Basins Pathways and Diversions 1.4 Description of Basins 1.4.1 Basin Al .4.2 Basin A2 1.4.3 Basin Bl 1.4.4 Basin B2 1.4.5 Basin B3 1.4.6 Basin 1.4.7 Basin 1.4.8 Basin 1.5 Potential Chemical Spill Sources And Spill Containment 1.5.1 ReagentTanks 1.5.2 Ammonia 1.5.3 Ammonium Meta Vanadate 1.5.4 Caustic Storage Sodium Hydroxide 1.5.5 Sodium Carbonate 1.5.6 Sodium Chlorate 1.5.7 Sulfuric Acid 1.5.8 Vanadium Pentoxide 1.5.9 Kerosene Organic 1.6.0 Used/Waste Oil SECTION PAGE 1.6.1 Propane 1.7 Potential Petroleum Sources And Containment 1.7.1 Petroleum Storage Tanks 1.7.1.1 Diesel 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.2 Unleaded Gasoline 1.7.2.3 Pump Station 1.7.2.4 Truck Unloading 1.8 Spill Discovery And Remedial Action 1.9 Spill Incident Notifications 1.9.1 External Notification 1.9.2 Internal Notification 11 1.10 Records And Reports 12 1.11 Personnel Training And Spill Prevention Procedures 12 1.11.1 Training Records 12 1.11.2 Monitoring Reports 13 1.12 Revision 13 1.13 Summary 13 1.14 Mill Manager Approval 14 1.15 Certification by Registered Professional Engineer 14 LIST OF TABLES Table 1.0 Mill Organization Chart Table 2.0 Reagent Tank List Table 3.0 Laboratory Chemical Inventory List Table 4.0 Reagent Yard/Small Quantity Chemicals List Table 5.0 Reagent Yard/Bulk Chemicals List Table 6.0 Petroleum Products and Solvents List LIST OF FIGURES Figure Mill Site Layout Figure Mill Site Drainage Basins WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS 1.1 OBJECTIVE The objective of the Spill Prevention Control and Countermeasures SPCC Plan is to serve as site-specific guideline for the prevention of and response to chemical and petroleum spills and as guidance document for compliance with Groundwater Discharge Permit No UGW370004 The plan outlines spill potentials containment areas and drainage characteristics of the White Mesa Mill site The plan addresses chemical spill prevention spill potentials spill discovery and spill notification procedures The Oil Pollution Prevention Sections of the Clean Water Act 40 CFR 112 to 117 also referred to as the Spill Prevention Control and Countermeasures SPCC rules establish requirements that apply to facilities which could reasonably be expected to discharge oil in quantities that may be harmful as described in that Act into or upon the navigable waters of the United States or that may affect natural resources of the United States Section 112 states that the Act is not applicable to facilities that are not subject to the authority of the Environmental Protection Agency EPA for one of the following reasons Due to its location the facility could not reasonably be expected to discharge oil into navigable waters of or impact natural resources of the U.S or The facility is subject to authority of the Department of Transportation as defined in Memorandum of Understanding MOU between the Secretary of Transportation and the EPA Administrator or The facility does not exceed either the underground or the above ground storage capacity 42000 gallons and 1320 gallons respectively prescribed in the rules The Mill could not reasonably be expected as described in the SPCC regulation to discharge oil into the navigable waters or impact natural resources of the U.S The Mill site was constructed with an overall grade and diversion ditch system designed to channel the non-recovered portion of any material spill to the tailings management system Hence it is not reasonable to expect that surface spills will ever reach navigable waters or natural resources of the U.S or Utah Therefore the SPCC reporting requirements in the Clean Water Act are not applicable to the Mill However as good environmental management practice the Mill has implemented the spill management program described in this document which is consistent with the intent of the Clean Water Act to the extent practicable Although the Mill by design cannot directly impact navigable waters of the U.S and as result spills that may occur but are retained within the site would not be reportable the Mill implements these practices in good faith effort to minimize all potential sources of pollution at the site Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this SPCC Ammonia is the only chemical that has the potential to leave the site and would do so as vapor Figure Site Layout Map shows map of the mill site including the locations of the chemical tanks on-site Figure shows the basins and drainage ditch areas for the mill site Table 1.0 is an organization chart for Mill operations Table 2.0 lists the reagent tanks and their respective capacities Table 3.0 lists the laboratory chemicals their amounts and their reportable quantities Table 4.0 lists the operations chemicals Table 5.0 lists the chemicals in the reagent yard their amounts and their reportable quantities Table 6.0 lists the petroleum products and solvents on site 1.2 RESPONSIBILITIES Person in charge of facility responsible for spill prevention Mr Richard Bartlett Interim Mill Manager 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 459-2495 home Person in charge of follow-up spill record keeping and/or reporting Mr David Turk Department Head Health Safety and Environmental 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 678-7802 home Refer to Section 1.9 Spill Incident Notification for list of company personnel to be notified in case of spill In addition an organizational chart is provided in Table 1.0 1.3 DRAINAGE BASINS PATHWAYS AND DIVERSIONS The main drainage pathways are illustrated in Figure The map shows drainage basin boundaries flow paths constructed diversion ditches tailings cells the spillway between Cell and dikes berms and other relevant features The White Mesa Mill is zero discharge facility for process liquid wastes The mill area has been designed to ensure that all spills or leaks from tanks will drain toward the lined tailings cells The tailings cells in turn are operated with sufficient freeboard minimum of three feet to withstand 100%of the PMP Probable Maximum Precipitation This allows for maximum of 10 inches of rain at any given time 1.4 DESCRIPTION OF BASINS Precipitation and unexpected spills on the mill property are contained within their respective drainage basins Runoff would ultimately drain into one of the three lined tailings cells 1.4.1 Basin Al Basin Al is north of Cell I-I and Diversion Ditch No The basin contains 23 acres all of which drain into Westwater Creek This area is not affected by mill operations 1.4.2 BasinA2 Basin A2 contains all of Cell 1-I including an area south of the Diversion Ditch No The basin covers 84 acres Any runoff from this basin would be contained within Cell 1-I 1.4.3 Basin BI Basin B1 is north of the mill property and is not affected by mill operations The basin contains 45.4 tributary acres Runoff from this basin drains into flood retention area by flowing through Diversion Ditch No Diversion Ditch No drains into Westwater Creek 1.4.4 Basin B2 Basin B2 is northeast of the mill and contains only 2.6 acres Runoff from this basin would drain into Diversion Ditch No Diversion Ditch No ultimately drains into Diversion Ditch No This basin is not affected by mill operations 1.4.5 Basin B3 Basin B3 contains most of the mill area buildings ore stockpiles process storage tanks retention ponds spill containment structures pipelines and roadways The normal direction of flow in this basin is from the northwest to the southwest Any runoff from this basin would drain into Cell 1-I The basin contains 64 acres This basin has sufficient freeboard to withstand 100%of the PMP Probable Maximum Precipitation This allows 10 inches of rain for any given storm event 1.4.6 Basin Basin contains all of Cell The basin consists of 80.7 acres This basin contains earth stockpiles and the heavy equipment shop The direction of flow in this basin is to the southwest All runoff in this basin would be channeled along the southern edge of the basin Runoff would then flow into Cell via the spillway from Cell to Cell 1.4.7 Basin Basin contains all of Cell This basin consists of 78.3 acres including portion of the slopes of the topsoil stockpile and random stockpile The basin contains all flows including those caused by the PMF 1.4.8 Basin Basin contains Cell 4A and consists of 43.3 acres All anticipated flows including those caused by the PMF will be contained within the basin and will flow directly into Cell 4A 1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT This section details potential sources of chemical spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.5.1 Reagent Tanks Tank list included in Table 2.0 1.5.2 Ammonia The ammonia storage tanks consist of two tanks with capacity of 31409 gallons each The tanks are located southeast of the Mill building Daily monitoring of the tanks for leaks and routine integrity inspections will be conducted to minimize the hazard associated with ammonia The reportable quantity for an ammonia spill is gallons Ammonia spills should be treated as gaseous Ammonia vapors will be monitored closely to minimize the hazard associated with inhalation If vapors are detected efforts will be made to stop or repair the leak expeditiously Ammonia is the only chemical as vapor that has the potential to leave the site 1.5.3 Ammonia Meta Vanadate Ammonia meta vanadate is present in the SX building as the process solutions move through the circuit to produce the vanadium end product But the primary focus will be on the transportation of this chemical The reportable quantity for an ammonia meta vanadate spill is 1000 pounds 1.5.4 Caustic Storage Sodium Hydroxide The caustic storage tank is located on splash pad on the northwest corner of the SX building The tank has capacity of 19904 gallons The tank supports are mounted on concrete curbed catchment pad that directs spills into the sand filter sump in the northwest corner of the SX building The reportable quantity for sodium hydroxide spill is 85 gallons 1.5.5 Sodium Carbonate Soda Ash The soda ash solution tank has capacity of 16921 gallons and is located in the northeast corner of the SX building The smaller soda ash shift tank has capacity of 8530 gallons and is located in the SX building Spills will be diverted into the boiler area and would ultimately drain into Cell 1-I There is no reportable quantity associated with sodium carbonate spill 1.5.6 Sodium Chlorate Sodium chlorate tanks consist of two fiberglass tanks located within dike east of the SX building The larger tank is used for dilution purposes and has maximum capacity of 17700 gallons The smaller tank serves as storage tank and has capacity of 10500 gallons Daily monitoring of the tanks for leaks and integrity inspections will be conducted to minimize the hazard associated with sodium chlorate Sodium chlorate that has dried and solidified becomes even more of safety hazard due to its extremely flammable nature The reportable quantity for sodium chlorate spill is 400 gallons 1.5.7 Sulfuric Acid The sulfuric acid storage tanks consist of one large tank with the capacity of 16000000 gallons and two smaller tanks with capacities of 269160 gallons each The large tank is located in the northwest corner of mill area basin B3 and is primarily used for acid storage and unloading The tank support for the large tank is on mound above depression which would contain significant spill All flows resulting would be channeled to Cell 1-I The tank is equipped with high level audible alarm which sounds prior to tank overflows concrete spill catchment with sump in the back provides added containment around the base of the tank However the catchment basin would not be able to handle major tank failure such as tank rupture The resulting overflow would flow towards Cell 1-I The two smaller storage tanks are located within an equal volume spill containment dike east of the mill building The tanks are not presently in use but are equipped with high level audible alarms The reportable quantity for sulfuric acid spill is 65 gallons 1000 pounds 1.5.8 Vanadium Pentoxide Vanadium pentoxide is produced when vanadium is processed through the drying and fusing circuits and is not present in the vanadium circuit until after the deammoniator Efforts will be made to minimize leaks or line breaks that may occur in processes in the circuit that contain vanadium pentoxide Special care will be taken in the transportation of this chemical The reportable quantity for vanadium pentoxide spill is 1000 pounds 1.5.9 Kerosene Organic The kerosene storage area is located in the central mill yard and has combined capacity of 10152 gallons in three tanks Any overflow from these three tanks would flow around the south side of the SX building and then into Cell 1-I These tanks have drain valves which remain locked unless personnel are supervising draining operations The reportable quantity for kerosene spill is 100 gallons 1.6.0 Used Waste Oil Used Waste oil for parts washing is located north of the maintenance shop in tank and has capacity of 5000 gallons The tank is contained within concrete containment system Ultimate disposal of the used oil is to an EPA permitted oil recycler Any oil escaping the concrete containment system will be cleaned up Soil contaminated with used oil will be excavated and disposed of in Cell 1.6.1 Propane The propane tank is located in the northwest corner of the mill yard and has capacity of 30000 gallons Daily monitoring of the tank for leaks and integrity inspections will be conducted to minimize potential hazards associated with propane leaks Propane leaks will be reported immediately There is no reportable quantity associated with propane spill 1.7 POTENTIAL PETROLEUM SPILL SOURCES AND CONTAINMENT This section details potential sources of petroleum spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.7.1 Petroleum Tanks 1.7.1.1 Diesel Two diesel storage tanks are located north of the mill building The tanks have capacities of 250 gallons each One of the diesel tanks is for the emergency generator The other tank is located in the pumphouse on an elevated stand Spillage from either tank would ultimately flow into Cell 1-I The reportable quantity for diesel spill is 100 gallons 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.1 Diesel The diesel tank is located on the east boundary of Basin B3 and has capacity of 6000 gallons The tank is contained within concrete catchment pad The reportable quantity for diesel spill is 100 gallons 1.7.2.2 Unleaded Gasoline The unleaded gasoline tank is located next to the diesel tank The unleaded gasoline tank has capacity of 3000 gallons and is contained within the same containment system as the diesel tank The reportable quantity for an unleaded gasoline spill is 100 gallons 1.7.2.3 Pump Station Both the diesel and the unleaded gasoline tanks will be used for refueling company vehicles used around the mill site The pump station is equipped with an emergency shut-off device in case of overflow during fueling In addition the station is also equipped with piston leak detector and emergency vent Check valves are present along with tank monitor console with leak detection system The catchment is able to handle complete failure of one tank However if both tanks failed the concrete catchment pad would not be able to contain the spill In this case temporary berm would need to be constructed Absorbent diapers or floor sweep would be used in an effort to limit and contain the spill The soil would be cleaned up and placed in the authorized disposal area in Cell 1.7 2.4 Truck Unloading In the event of truck accident resulting in an overturned vehicle in the mill area proper reporting and containment procedures will be followed when warranted such as when oil or diesel fuel is spilled Proper clean-up procedures will be followed to minimize or limit the spill The spill may be temporarily bermed or localized with absorbent compounds Any soils contaminated with diesel fuel or oil will be cleaned up and placed in the authorized disposal area in Cell 1.8 SPILL DISCOVERY AND REMEDIAL ACTION Once chemical or petroleum spill has been detected it is important to take measures to limit additional spillage and contain the spill that has already occurred Chemical or petroleum spills will be handled as follows The Shift Foreman will direct efforts to shut down systems if possible to limit further release The Shift Foreman will also secure help if operators are requiring additional assistance to contain the spill The Shift Foreman is also obligated to initiate reporting procedures Once control measures have begun and personal danger is minimized the Shift Foreman will notify the Production Superintendent Maintenance Superintendent or Mill Manager The Production or Maintenance Superintendent will notify the Mill Manager who in turn will notify the Environmental Health and Safety Manager The Mill Manager will assess the spill and related damage and direct remedial actions The corrective actions may include repairs clean up disposal and company notifications Government notifications may be necessary in some cases If major spill continues uncontrolled these alternatives will be considered Construct soil dikes or pit using heavy equipment Construct diversion channel into an existing pond Start pumping the spill into an existing tank or pond Plan further clean-up and decontamination measures 1.9 SPILL INCIDENT NOTIFICATION 1.9.1 External Notification As stated in Section 1.1 spills are not expected to reach navigable waters of the United States If spill of reportable quantity occurs then mill and corporate management must be notified and they will evaluate whether or not the following agencies must be notified EPA National Response Center 1-800-424-8802 State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah 801/538-7200 Water Quality Division 801/538-6146 In case of tailings dam failure contact the following agencies State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah Natural Resources 801/538-7200 1.9.2 Internal Notification Internal reporting requirements for incidents spills and significant spills are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions and accidents Government investigations information requests or enforcement actions Private actions or claims corporate or employee Deviations from corporate policies or government requirements by management Which have or could result in the following Death serious injury or adverse health effects Property damage exceeding $1000000 10 Government investigation or enforcement action which limits operations or assesses penalties of $100000 or more Publicity resulted or anticipated Substantial media coverage Report At The Beginning Of The Next Day Event Criteria Was reported to government agency as required by law Worker employee or contractor recordable injury or illness associated with release Community impact-reported or awareness Publicity resulted or anticipated Release exceeding the reportable quantities listed in Section 1.5 for each specific process material waste or by-product In the event of spill of reportable quantity the Mill Manager is required to call the Corporate Environmental Manager or the President and Chief Executive Officer The individual first discovering the spill will report it to the Shift Foreman Production Superintendent or Maintenance Superintendent who will in turn ensure that the Mill Manager is notified The Environmental Health and Safety Manager will also be contacted by the Mill Manager Name Title Home Phone Mill Personnel Richard Bartlett Interim Mill Manager 435 678-2495 Wade Hancock Maintenance Foreman 435 678-2753 David Turk Environmental Health and Safety Manager 435 678-7802 N/A Production Superintendent N/A Maintenance Foreman Scot Christensen Mill Shift Foreman 435 678-2015 Corporate Personnel Ronald Hochstein President and Chief Operating Officer 604 377-1167 David Frydenlund Vice President and General Counsel 303 221-0098 In the event the next person in the chain-of-command cannot be reached then proceed up the chain-of-command to the next level Table 1.0 shows the organizational chart for the mill site 11 1.10 RECORDS AND REPORTS The following reports and records are to be maintained in Central Files by the Environmental Health and Safety Manager for inspection and review for minimum of three years Record of site monitoring inspections Daily Tailings Inspection Data Weekly Tailings Inspection and Survey Monthly Tailings Inspection Pipeline thickness Quarterly Tailings Inspection Tank to soil potential measurements Annual bulk oil and fuel tank visual inspections Tank and pipeline thickness tests Quarterly and annual PCB transformer inspections if transformer contains PCBs Tank supports and foundation inspections Spill Incident Reports Latest revision of SPCC plan 1.11 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES All new employees are instructed on spills at the time they are employed and trained They are briefed on chemical and petroleum spill prevention and control They are informed that leaks in piping valves and sudden discharges from tanks should be reported immediately Abnormal flows from ditches or impoundments are of immediate concern In addition safety meeting is presented annually by the Environmental Health and Safety Manager to review the SPCC plan 1.11.1 Training Records Employee training records on chemical and petroleum spill prevention are maintained in the general safety training files 1.11.2 Monitoring Reports Shift logs shall provide checklist for inspection items 12 1.12 REVISION This procedure is to be reviewed by the mill staff and registered professional engineer at least onc eve ry th ree years and updated when circumstances warrant revision 1.13 Summary Below is table listing the specific reportable quantities associated with the major chemical and petroleum products on-site CHEMICAL REPORTABLE QUANTITY RQ AMMONIA 100 POUNDS AMV 1000 POUNDS SODIUM 1000 POUNDS HYDROXIDE SODA ASH No Reportable Quantity SODIUM 400 GALLONS CHLORATE SULFURIC ACID 1000 POUNDS VANADIUM 1000 POUNDS PENTOXIDE KEROSENE 100 GALLONS OIL No Reportable Quantity PROPANE No Reportable Quantity DIESEL 100 GALLONS UNLEADED FUEL 13 1.14 MILL MANAGER APPROVAL hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with the Standard Operating Procedures currently in effect %dcar Richard Bartlett Interim Mill Manager 1.15 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with good engineering practices Registered Professional Engineer State of Utah No 165838 Harold Roberts 14 TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Home Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.166 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Home Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE 2.0 REAGENT TANK LIST QUANTITY REAGENT cAPACITYGAt DIESEL 250 KEROSENE 10152 USED/WASTE OIL 5000 DIESEL 6000 UNLEADED 3000 PROPANE 30000 AMMONIA 31409 SODIUM HYDROXIDE 19904 SODA ASH SOLUTION 16921 SODA ASH SHIFT 8530 SODIUM CHLORATE 17700 SODIUM CHLORATE 10500 SULFURIC ACID 1600000 SULFURIC ACID 269160 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 _-__ fiQj --- ÆntiiIAStbk ---s-b Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 6.8 kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg GhiºatVoiMiIand FIfl3iæTib1e ScSABt t1t1 Chloroform -p1 4.54 kg Formaldehyde 45.4 kg IL of 37%solution Nitrobenzene 454 kg 12 Toluene 454 kg 12 CheiWuinAidShØd-I -- Oiiaht1tWJitStoÆk Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 cH EMiCAt .RQ eQUANTJ 1WŁ1NIZ2t Acetic Acid Glacial 4c 000 lbs tOMPOUNU gal Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 Ibs Chlorine 10 lbs lbs Ferrous Sulfate Heptahydrate 1000 lbs kg 11 Ibs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 REAGENT RQ2 QUANTITY IN REAGENT YARD Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfloc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT QUANTJTY IN WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout GR I Z Z L Y DE C O N T A M I N A T I O N PA D DIE S E L SA M P L E P L A N T Lj G 10 SC f t L t IN FT Figure White Mesa Mill Mill Site Drainage Basins APPENDIX WHITE MESA MILL EMERGENCY RESPONSE PLAN EMERGENCY RESPONSE PLAN REVISION 1.1 Denison Mines USA Corp na.i--aL--isii VYIIIIC IVlCSct 1SC landing Utah April14 1986 REVISED February 16 2007 Distribution List Ron Hochstein Rich Bartlett David Turk Michael Spillman Miii Shifi Foremen Blanding Fire Department San Juan County EMS Coordinator State of Utah Department of Radiation Control Revision Date January 16 2006 TABLE OF CONTENTS Page Number 1.0 Introduction 2.0 White Mesa Mill Background 3.0 Plan Objectives 4.0 Description of Facilities 4.1 Fire Water Supply and Alarm Systems 4.2 Office Building and Laboratory 4.3 Solvent Extraction Building 4.4 Mill Building 4.5 Maintenance Shop/Warehouse/Change Room Building 4.6 Reagent and Fuel Storage 4.7 Boiler House 4.8 Sample Plant 5.0 Organization and Responsibilities 5.1 Mill Manager/Incident Commander 5.2 Operations Superintendent 5.3 Radiation Safety Officer/F ire Chief 5.4 Maintenance Supervisor 5.5 Laboratory Supervisor 5.6 Shift Foremen 5.7 Scale House Personnel 5.8 Emergency Response Teams 6.0 Specific Emergencies 10 6.1 Fire 10 6.2 Chemical or Gas Release 10 6.3 Earthquake 10 6.4 Terrorist/Bomb Threat 10 6.5 Tailings Dam Break and Major Floods 10 7.0 Evacuation Procedure 11 7.1 Notification 11 7.2 Assembly 11 7.3 Specific Procedures for Operations Personnel 11 8.0 Off-Site Emergency Equipment/Personnel Release 11 9.0 Emergency Equipment 12 9.1 Fire Hose 12 9.2 Self Contained Breathing Apparatus 12 9.3 Spill Clean-up Equipment 12 9.4 Fire Fighting PPE 12 10.0 Emergency Transportation 13 11.0 Emergency Evacuation Drills 13 EXHIBITS Emergency Notification List E- Internal Notifications E-2 Site Layout Map E-3 Main Shut-off Valves E-4 APPENDICES Emergency Procedure Response to Fire A-I Emergency Procedure Response to Chemical or Gas Release A-2 Emergency Evacuation Procedure A-3 FIGURES Fire System Schematic F-I ii INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 INTRODUCTION This Emergency Response Plan is written not only to comply with Federal State and local regulations but even more importantly to reduce the risk to our employees and that of the community in regards to Health Safety and Environmental Emergencies This plan includes the following evaluation of the potential risks for fire explosions gas releases chemical spills and floods including tailings dam failure specific emergency programs for each potential event definition of administrative response actions and definition of the emergency response contacts both internal and external The White Mesa Mill the Mill operates under the following regulatory agencies Utah State Department of Environmental Quality Division of Radiation Control Mine Safety and Health Administration Environmental Protection Agency Utah State Department of Environmental Quality Division of Air Quality and Utah State Division of Natural Resources Bureau of Dam Safety WHITE MESA MILL OVERVIEW The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and vanadium In addition to the processing of conventional ores the Mill also processes alternate feed materials using similar process steps and chemicals The conventional ore is stored on the Ore Pad shown in Exhibit Alternate feed materials are also stored on the Ore Pad and may be stored in bulk form lined burrito bags liners or drums The descriptions of each alternate feed material are maintained by the Mills Radiation Safety Officer The Mill utilizes semi-autogenous grind circuit followed by hot sulfuric acid leach and solvent extraction process to extract uranium and vanadium from ores using large amounts of sulfuric acid sodium chlorate kerosene amines ammonia and caustic soda in the process The reagent storage tank locations are described in further detail in Section 4.6 Emissions from the Mill process are in the form of air emissions from exhaust stacks and solid/liquid tailings which are stored in the Mills tailings cells located west/southwest of the main Mill building The major exhaust stack parameters are shown in the following table Description Height ft from surface Diameter inches Estimated Flow Rate cfm Leach Exhaust -l00 36 13700 Yellow Cake Drying stacks -85 18 4000 per stack Vanadium Roasting Fusion 85 38 4100 P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergeney Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 There are also smaller exhaust stacks associated with the Laboratory in the Mill Administration building and the boiler exhaust stack The Mills tailings cells are comprised of four below grade engineered cells Cell 1-I and 4A Liquids are stored in Cell 1-I and Cell the active tailings cell The liquid in the tailings cells is very acidic In addition to the tailings cells there is also an emergency lined catchment basin west of the Mill building Solutions in this basin or the tailings cells should not be used to fight fires in the Mill facility The products of the Mill include ammonium metavanadate AMy vanadium pregnant liquor VPL vanadium pentoxide V205 and yellowcake or uranium concentrate lJO The V205 and 11308 products are packaged in steel drums for shipment The AMV is packaged in either steel drums or super-saks while the VPL is sold in liquid form in bulk Master files containing Material Safety Data Sheets for all materials in use at the Mill are maintained at the Safety Office Mill Maintenance Office Mill Laboratory and Mill Central Control Room Copies are also on file at the Blanding Clinic Doctors Offices Blanding Fire House and Office of the San Juan County Emergency Medical Coordinator The nearest residence to the Mill is approximately one mile to the north of the Mill the next is residence approximately two miles north of the Mill followed by the community of White Mesa about 3.5 miles to the south The City of Blanding is located approximately miles to the northeast The Mill site is near Utah State Highway 191 and can be accessed by paved access road from the highway to the Mill facilities PLAN OBJECTIVES The primary objectives of this plan are To save lives prevent injuries prevent panic and minimize property/environmental damage to the lowest possible level To evacuate and account for all people in the area including visitors truck drivers contractors etc To provide assembly areas that are as safe as possible and which can be reached without traveling through hazardous area Assembly areas will be properly manned to deal with sick or injured persons and provisions will be made to evacuate those persons to proper shelter To make adequately trained personnel available to cope with rescue and recovery operations as directed by the Incident Commander DESCRIPTION OF FACILITIES The Mill facilities are shown on the Site Layout Map included as Exhibit P\AdminMaster SOPsVBook 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.1 Fire Water Supply and Alarm Systems 4.1.1 Fire Water Supply The fire water supply facilities include 400000 gallon Storage Tank of which 250000 gallons are reserved for fire emergencies Centrifugal diesel driven pump rated at 2000 gpm at 100 psi This pump starts automatically when the pressure in the fire main drops below 100 psi See Figure Fire System Schematic When more water is needed for an emergency an additional source is the Recapture Reservoir supply pipeline which can be utilized in emergencies at rate of about 1200 gpm 4.1.2 Alarm System The alarm systems include the following public address system hand held radios siren 4.2 Office Building and Laboratory 4.2.1 Office Building The office building approximately 10000 square feet contains the administration offices radiation health and safety offices and the Mill laboratory The central file vault and the main computer system are also in this building The ambulance is kept on the west side of the office building near the safety office entrance 4.2.2 Laboratory The laboratory facilities contain the following three flammable cabinets keys required chemical storage room south of main lab six fume hoods hoods 12 and are in the center of the laboratory and hoods and are along the west wall Hoods and are no longer in service Hoods and are on the west side and are on the east side of the center cluster of hoods with being in front Only hoods and may be used for perchloric acid outside laboratory chemical storage north of office building key required perchloric acid storage vault located underground west of office building key required wide variety of chemicals in small quantities are located in the laboratory These chemicals range from acids to bases along with flammable metal compounds and peroxide forming compounds Oxidizers and organic chemicals which have strong potential of producing harmful vapors if the containers are damaged to the point that the chemicals are exposed are stored in storage room in the laboratory There are no acids stored in this storage room The acids including but not limited to sulfuric nitric acetic perchloric phosphoric and hydrochloric acids are stored in the main laboratory area in 2.5 liter or 500-mi bottles MSDS books for all P\AdminMaster SOPsBook 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 chemicals in the laboratory are located in the Laboratory Safety Department Mill Maintenance office and Mill Central Control room 4.2.3 Electrical Electrical transformers and electrical switches are located in the laboratory at the east end of the chemical storage room 4.2.4 Fire Protection System The fire protection systems in the office building and laboratory include fire hose station located on the east end of the office building The station includes two sets of turnout gear two SCBA units and Incident Commander materials automatic wet sprinkler system which is actuated at 212 portable dry chemical extinguishers strategically located throughout the building 4.3 Solvent Extraction Building The solvent extraction SX building approximately 21000 square feet houses the uranium and vanadium solvent extraction circuits and the ELUEX circuit The SX circuits may contain up to 200000 gallons kerosene 757000 liters which has flash point of 185 Associated equipment in the SX building includes temporary boiler located at the southwest end of the SX building which maintains the temperature for the fire system Chemicals which may be encountered in the SX building include Kerosene Caustic Soda Anhydrous Ammonia Sulthric Acid Salt Brine Soda Ash Ammonium Sulfate Amines Alcohol Sodium Chlorate Sodium Vanadate Propane The VPL product is stored in the SX building 4.3.1 Electrical All electrical switches are located outside in the MCC room north of the SX building The main control panel for all of the equipment is located in the Central Control Room in the main Mill building 4.3.2 Fire Protection System The SX building fire protection systems include P\Admin\Master 5OPsVBook 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MiLL EMERGENCY RESPONSE PLAN Page of 13 wet AFFF foam sprinkler system with heat actuated sprinider heads that release at 212F portable dry chemical extinguishers strategically located throughout the building For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic included as Figure in this Plan 4.4 Mill Building The mill building approximately 22000 square feet contains process equipment related to grind leach counter current decantation precipitation drying and packaging of uranium and vanadium products Chemicals which may be encountered in the mill building include Caustic Soda Anhydrous Ammonia Sulfuric Acid SodaAsh Ammonium Sulfate Sodium Chlorate Sodium Vanadate Propane The finished products which are contained in the mill building include AMY V2O5 and U308 or yellowcake 4.4.1 Electrical The main electrical switch gear is located west of the SAG mill on the ground floor in the north west corner of the mill building Circuit control panels are located in the SAG mill control room the central control room the vanadium roaster control room and the AMV area 4.4.2 Fire Protection System The main mill building fire protection systems include portable dry chemical extinguishers strategically located throughout the building water hoses throughout the building For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System Schematic included as Figure of this Plan 4.5 Maintenance Shop/Warehouse/Change Room Building This building approximately 20000 square feet contains the main maintenance shop area located on the north end of the building the main warehouse located on the south end of the building and the personnel change rooms and lunchltraining room located on the extreme south end of the building on the ground and second floors Within the maintenance shop area are the following work area and specialty shops P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc IIJTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 the main maintenance shop area contains welding and cutting equipment lathes presses and drill presses carpenter shop which contains various saws and planes Fiberglass work is also done within this shop area and it is located at the northwest end of the maintenance shop area an electrical shop which is located south of the carpenter shop heavy equipment maintenance shop area is located at the north end of the maintenance shop in the center of the building rubber room for rubber lining of equipment is located east of the equipment shop area the maintenance shop office instrument shop and tool room are located at the south end of the maintenance shop area The warehouse area contains primarily dry good storage for repair parts and consumables for the operation of the Mill There is an electrical water heater for the change room which is located in the warehouse area at the south end Within the warehouse and maintenance shops there are some oils and chemicals stored in the following locations small quantities of flammable material such as starting fluid and spray paint are kept in the warehouse drums of new oil and anti-freeze are stored along the east wall of the equipment maintenance area and on the east side of the warehouse on oil storage racks used oil is stored in tank located northeast of the equipment shop The tank has capacity of approximately 5800 gallons in the main maintenance shop area and the rubber room there are flammable storage cabinets and east of the warehouse there is trailer which is used to store flammable items such as rubber cements paints and fiberglass resins compressed gas cylinder storage both empty and full is located outside east of the maintenance shop 4.5.1 Electrical The main electrical circuit breaker for the maintenance shop and warehouse building is located on the east wall inside the Maintenance shop Auxiliary electrical panels for the change room and warehouse are located in the southwest corner of the warehouse area 4.5.2 Fire Protection System The fire protection system within the maintenance shop/warehouse/change room building includes wet automatic sprinkler system that releases at 212 portable dry chemical extinguishers strategically located throughout the maintenance area warehouse area and the change room and lunch room For fire hydrant and hose cabinet locations refer to the Fire System Schematic Figure 4.6 Reagent and Fuel Storage The following lists the reagents and fuel stored at the Mill site P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 sulfuric acid tank located northwest of the mill building which has capacity of approximately 1.4 million gallons storage tank for propane is located on the north edge of the mill site northwest of the mill building It has storage capacity of 30000 gallons four sodium chlorate tanks located east of SX building north of the office building and east of the pulp storage tanks The two tanks east of the SX building are for sodium chlorate storage and the other two tanks are for dilution of the sodium chlorate two anhydrous ammonia tanks located east of the SX building with capacity of 31409 gallons each three kerosene tanks located east of the SX building with capacity of 10152 gallons each one caustic soda tank north of the SX building with capacity of 19904 gallons three soda ash tanks which are located east of the SX building One tank is the dry soda ash tank with capacity of 70256 gallons Two of the tanks are soda ash dilution tanks with capacities of 16921 gallons each diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad The gasoline storage capacity is 3200 gallons while diesel storage capacity is 8000 gallons Other reagents are stored in steel barrels or super sacs in reagent yard located east of the office building Typical reagents which are stored in this yard include polymers and flocculants boiler feed water chemicals methanol tributyl phosphate dirty soda ash and ammonium sulfate SX amines and emulsion breakers decyl alcohol minimal amounts of acid in barrels used oil in drums and overpacks 4.7 Boiler Facilities The main building approximately 12400 square feet is located on the west side of the Mill site and contains air compressors and water treatment facilities To the north of the main building is building which houses propane-fired boiler The vanadium oxidation tank oxidation thickener and pH adjustment tank are located south of the boiler house facilities 4.7.1 Electrical The main electrical panel for the boiler house is located outside of the building on the south wall 4.7.2 Fire Protection System The fire protection system for the boiler facilities is comprised of strategically located portable dry chemical extinguishers P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc iNTERNATIONAL URANIUM USA CORPORATION Rev No Ri Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.8 Sample Plant The sample plant building approximately 8000 square feet is located on the ore pad east of the maintenance shop/warehouse building The sampling plant equipment has been removed from the building and it is currently used as storage area for maintenance 4.8.1 Electrical The electrical panel for this building is located on the east wall upstairs 4.8.2 Fire Protection System There are no extinguishers or sprinkler systems in the sample plant ORGANIZATION AND RESPONSIBILITIES The organizational chart for an emergency situation is illustrated in Figure 5.1 Mill Manager/Incident Commander The Incident Commander has the responsibility for preparing an Emergency Plan communicating the Plan directing activities during emergencies and reporting to local State and Federal authorities The Incident Commander will stop routine radio usage upon learning of an emergency and set up the base station in safe location for directing activities Radio usage will be limited to the emergency The Incident Commander has the responsibility to contact all outside services The Incident Commander has the responsibility to account for all employees at the Mill using the assistance of supervisors and/or any International Uranium USA Corporation IUSA personnel The Incident Commander has the responsibility for the news media and reports directly to the President of IUSA 5.2 Mill General Superintendent The Mill General Superintendent has the responsibility of directing outside emergency personnel and has the responsibility for plant security and will report directly to the Incident Commander The Mill General Superintendent will act as Incident Commander in the absence of the Mill Manager 5.3 Radiation Safety Officer/Fire Chief The Radiation Safety Officer will direct rescue operations and provide the necessary emergency medical personnel and facilities to cope with the emergency Adequately trained fire crews and operable emergency equipment will be maintained at all times P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 As Fire Chief the Radiation Safety Officer has the responsibility to maintain trained fire crews and operable equipment mobilize and direct the fire crews and equipment in fire emergency or one containing the threat of fire and to assist in evacuation and rescue or recovery operations In the absence of the Radiation Safety Officer the Mill Safety Coordinator will assume these duties 5.4 Maintenance Supervisor The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with the emergency including isolation of utilities and providing technical advice as needed The Maintenance Supervisor will be assisted by the Mill Safety Coordinator 5.5 Laboratory Supervisor The Laboratory Supervisor has the responsibility to direct and account for all office personnel including IUSA personnel and office visitors in evacuation and in activities to cope with the emergency In case of mill tour the Supervisor accompanying the tour will be responsible for evacuation of visitors 5.6 Shift Foremen Shift Foremen are in charge until the Incident Commander arrives and are responsible for all functions listed above Shift Foremen have the responsibility to account for all of their people in addition to any visitors contractors etc in their areas and report to the Incident Commander or in the absence of the Incident Commander to administer all of the above duties 5.7 Scale House Personnel Scale house person on shift will be responsible to account for ore truck drivers and reagent truck drivers 5.8 Emergency Response Teams The response crew for each operating shift will normally consist of the following operators under the direction of the shift foreman This organization may be changed for individual shifts subject to the approval of the Fire Chief 5.8.1 Operational Mode Leach Operator CCD Operator Solvent Extraction Operator Mill Trainee 5.8.2 Non-Operational Mode Shift Foreman Operations Personnel Maintenance Personnel P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 10 of 13 Figure Emergency Response Organizational Structure Incident Commander Mitt Manager Director of Secuhty Operations Supehntendent Fire Chief Radiation Safety Officer Shift Foremen Emergency Response Teams Lab Supervisor Operatidnal Mode Non-Operational Mode Leach Operator CCD Operator Shift Fomman Operations Personnel SX Operator Mill Trainee Maintenance Personnel SPECIFIC EMERGENCIES The following details procedures to be followed during specific emergencies but are not limited to the following 6.1 Fire Should fire occur the procedure outlined in Appendix for reporting and responding to fires will be followed Particular areas of concern include Solvent Extraction Building Propane Tanks Lab or Lab Storage Area 6.2 Chemical or Gas Release The procedures for response to chemical or gas release are outlined as Appendix 6.3 Earthquake Although this is highly unlikely an earthquake could occur at the Mill severe earthquake could cause buildings and other structures to collapse chemical and/or gas releases major fires as well as general panic In the event of major earthquake the evacuation procedures outlined in Appendix will be followed P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 10 INTERNATIONAL URAMUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 11 of 13 6.4 Terrorist/Bomb Threat In the event that any person should receive threat of bomb the following evacuation procedure should be followed Notify any person of authority i.e Superintendent Foreman Radiation Safety Officer who will immediately notify law enforcement authorities and evacuate the threatened area Evacuate all persons from the affected area and stop all radio transmissions 6.5 Tailings Dam Break and Major Floods Flood water breaching tailings embankments presents one of the greatest dangers for the sudden release of tailings solids and impounded water The tailings cells are designed with sufficient freeboard three feet to withstand back-to-back 00-year storm events or 40%of the probable maximum flood PMF followed by the 100-year storm event The flood design is equivalent to 15 inches of rainfall In addition the tailings dikes were designed in accordance with U.S NRC regulations and allow sufficient margin of safety even in the event of an earthquake The possibility of floods resulting from Westwater Creek Cottonwood Creek and Corral Creek causing dam failure is extremely remote The tailings cells and dikes are inspected on both daily and shift basis Discharges from dike failure would extend three miles before leaving IUSAs property In the event of dam failure large operating equipment will be mobilized to construct temporary earthen dikes or berms downgradient to the failed dike In addition the State of Utah Department of Radiation Control Executive Secretary the Executive Secretary MSHA and State of Utah Department of Natural Resources Division of Dam Safety shall be notified In the event of seismic rupture of tailings slurry pipelines the released slurry will be contained in the tailings cells regardless of the quantity released EVACUATION PROCEDURE See Appendix 7.1 Notification Employees will be notified to evacuate the area by dialing 184 on any area telephone and announcing that the Mill should be evacuated This announcement will be repeated twice When the paging system cycles through the evacuation siren continuous frequency will automatically sound for approximately forty-five seconds and then automatically shut off allowing communications by radio from that point If the 184 number is dialed accidentally the evacuation alarm may be canceled by disconnecting the phone until the page cycle ends then re dial 184 See Exhibits and 7.2 Assembly When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all personnel will assemble at The parking lot south of the office P\Aclmin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 11 INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 12 of 13 The scalehouse North side of Tailings Cell or North of the Mill Assembly site will depend upon conditions i.e nature of the emergency wind conditions etc The Fire Chief or Shift Foreman will specify the appropriate assembly site 7.3 Specific Procedure for Operations Personnel See specific emergency shutdown procedure for Operations by area under the relevant Operating Procedure for your area All employees not mentioned under Operating Procedures are to immediately report to the assembly area and congregate by crew so that all persons can be accounted for As employees leave their work areas they must pass the word to evacuate to any persons who may not be aware of the emergency After the Mill has been detennined to be safe for re-entry employees will be verbally notified to return to their work stations Off-Site Emergency Equipment/Personnel Release Any emergency response equipment or personnel that enter the Restricted Area in response to an incident will be scanned and decontaminated prior to leaving the site according to the procedures included in PBL-9 End Dump Trailer Acceptance Handling and Release Any equipment will be decontaminated according to the requirements found in Table of the Nuclear Regulatory Commissions NRCs Policy and Guidance Directive FC-85-23 Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct Source or Special Nuclear Material issued May 1987 Injured personnel should be evaluated for radiation contamination if there was potential for contamination at the earliest convenience Should it be necessary contaminated articles will be gathered by the radiological staff after medical treatment has been rendered If the personnel cannot be decontaminated notify the clinic/hospital personnel in advance EMERGENCY EQUIPMENT Emergency equipment for the Mill is provided as follows 9.1 Fire Hose Fire hose cabinets are located at the following sites with minimum of 300 feet of 2-1/2 hose two spanner wrenches spray nozzles and one hydrant wrench South of SX West of CCD North of Mill Building East of pulp storage tanks Northwest of Maintenance Shop West of Warehouse PAAdmin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 12 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 13 of 13 East of office building 9.2 Self Contained Breathing Apparatus Two Self-Contained Breathing Apparatus are located at each of the following locations Hose station east of office building Hose Station South of SX North End SX Outside Wall North end of Mill building outside wall 9.3 Spill Clean-up Equipment Barrels of soda ash are located throughout the Mill to be used in case of chemical spill Soda ash is also stored in bulk if needed There are also few drums of absorbent stored near the laboratory The laboratory also contains acid spill kits and absorbent materials to be used in case of spill 9.4 Fire Fighting PPE Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in the Fire Hose Station located on the east side of the office building 9.5 Maintenance of Emergency Equipment Fire extinguishers are inspected on an annual basis as well as the fire pump system The Mill Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure that all of the equipment is in place 10 EMERGENCY TRANSPORTATION One fully-equipped First Responder Unit Ambulance located west of the office building Other motor pool vehicles on the property will be utilized as needed in emergency situations with support as needed from the local Emergency Medical Services 11 EMERGENCY DRILLS AND TRAINING Quarterly drills as required by MSHA are prepared by the Safety and Radiation Departments to monitor performance of personnel responding to emergency situations Each drill will be enacted upon one or more of the potential scenarios by this plan The drill and evacuation activities are documented by the Mills Safety Coordinator and maintained within plant files Management will review all drills at quarterly ALARA Committee Meetings P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc 13 EXHIBIT EMERGENCY NOTIFICATION LIST ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR Give artificial respiration if necessary Control bleeding Treat for shock Immobilize fractures and stabilize for transportation Scan the injured for excessive alpha prior to transporting if time allows If alpha is excessive or there is no time to scan notify the clinic/hospital personnel and the Radiation Safety Office TIlE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED Blanding Clinic 678-2254 or 678-3434 930 400 San Juan Hospital Monticello ...678-2830 or 587-2116 364 1st EMT and CPR TRAINED The following personnel should be contacted if they are on-site in the event of an emergency to aid in the event of any injuries to personnel David Turk EMT and CPR trained Mike Spiliman CPR trained AMBULANCE SERVICE Blanding Dial 911 If the Company Ambulance is used an attendant must ride with the injured in addition to the driver except where the injured could normally be transported in car or pickup OTHER EMERGENCY NUMBERS Fire Department Dial 911 or 678-2313 County Sheriff Dial 911 or 587-2237 Highway Patrol Dial 911 or 587-2000 Blanding Police Dial 911 678-2916 or 678-2334 MANAGERS The Supervisor will notify one of the following of all incidents R.E Bartlett 435-678-2495 Turk 435-678-7802 or 435-459-1068 Spiliman 435-678-2761 MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING AGENCIES AS REQUIRED FOR EACH INCIDENT State of Utah Department of Radiation Control 801-536-4250 MSHA Field Off.--801-524-3450 Dist Off 303-231-5465 MSHA Arlington 800-746-1553 State Emergency Response Comm 801-538-3400 State of Utah Natural Resources Dam Safety 801-538-7200 National Response Center 800-424-8802 Utah Poison Control Center 800-456-7707 Notification of surrounding communities and or residences will be handled by the appropriate agencies as required by EPCRA Emergency Planning and Community Right to Know Act Revision Date Januaiy 16 2006 Ed EXHIBIT INTERNAL NOTIFICATIONS Internal reporting requirements for Incidents Spills and Significant Events are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions or other accidents Government investigations information requests or enforcement actions Private actions or claims corporations or employees Deviations from Corporate policies or government requirements by Management Other significant events which have resulted or could result in Death serious injury or adverse health effect employees or public Property damage exceeding $1000000 Government investigation or enforcement action limiting operation or penalties of $100000 or more Significant criminal actions Substantial media coverage Unscheduled down time of more than 24 hours Renort at the Beginning of the Next Business Day Incident Criteria Was reported to government agency as required by law Worker uSA or contractor recordable injury or illness associated with release Community impact reported or awareness Publicity resulted or is anticipated Release of process material waste or product in excess of the Reportable Quantities listed in Section 1.5 of the Spill Prevention Control and Countermeasures Plan The local manager in charge is to call Ron Hochstein or Dave Frydenlund Name Title Office Phone Home Phone Ron Hochstein President and COO 303-628-7798 office 604-931-6334 home 604-377-1167 cell David Frydenlund V.P and General Counsel 303-389-4130 office 303-221-0098 home 303-808-6648 cell Master SOPs\Book 16_Emergency Response PlarAEmergcncy Response Plan Rev 002.14.07 E-2 EXHIBIT SITE LAYOUT MAP P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-3 fl d _ w a n P1 gx v . s i IJ 1 D A Y 1 1 1 1 8 TiM 4a e lf l % .n 4 ra u mw s n s v s 3 a J I M no l a i o d s o a yg f l mf l p i V J f l vn o p n n p q of l tO PV S _ I4 t S T I EXHIBIT MAIN SHUT-OFF VALVES During an emergency this list should be used along with Site Layout Map Exhibit to locate tanks and valves associated with these tanks REAGENT SHUT-OFF VALVE LOCATIONS Sulfuric Acid Main located south side of acid tank East acid pump discharge valve West acid pump discharge valve Main leach area located 25 feet west of Derrick screens next to walkway 1-1/2 Main SX area located south of Central Control room Ammonia Main east tank located on end at bottom Main west tank located on end at bottom Valve located on top of tank east tank Valve located on top of tank west tank Kerosene Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Pump discharge valve Soda Ash Main valve located at bottom of tank dry storage Main valve located at bottom of tank on 30%dilution tank Main valve locate at bottom of tank on dilution tank Salt Main valve located at bottom of tank Caustic Soda Main valve located at bottom of tank east and west between supports P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 EXIIIBIT MAIN SHUT-OFF VALVES Sodium Chlorate Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Propane Main located 15 feet east of tank Main located on pipe off top of tank Main located at bottom of tank also fill pipe PLANT UTILITY SHUT-OFF VALVE LOCATIONS Process Water Main valve located on west side of water storage tank Discharge valve off service water pump east Discharge valve off service water pump west Mill process water main located east wall by SAG mill Fire Water Main valve located west side of water storage tank Emergency fire pump discharge valve to fire system Emergency fire pump discharge valve to header west side of pump house Main valve located south of Central Control room for SX and boilers Potable Water Main suction from potable water storage tank Main discharge from potable water storage tank Main located at east wall by SAG mill Main located south of Central Control room for SX Maintenance shop and offices Steam Main discharge valve for Superior boiler located at top of boiler Main steam valve located south side of boiler house P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 EXHIBIT MAIN SHUT-OFF VALVES Plant Air Main valve located at receiver tank in compressor room at boiler house Main valve to mill building located south of Central Control room PROCESS SHUT-OFF VALVE LOCATIONS Pulp Storage No valve located on west side of tank No valve located on west side of tank Preleach old No pulp storage valve located on west side of tank Preleach Thickener Main valve located underneath at center cone Clarifier Main valve located underneath at center cone Main valve located underneath at center cone CCD Thickeners Main valve located underneath at center cone of each thickener P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 APPENDIX EMERGENCY PROCEDURE RESPONSE TO FIRE The fire will be reported by dialing 185 on any telephone in the area and announcing the location of the fire over the paging system This announcement will be repeated twice for total of three announcements When the paging system cycles through the fire siren alternating frequency will automatically sound for approximately forty-five seconds then automatically shut off allowing radio communications to resume Mobilize the fire crew Evacuate all personnel Rescue any victims of the fire do this only with properly trained and equipped personnel Isolate utility lines affected by the fire Extinguish the fire and post fire watch for flare-ups Report the fire to proper local State Corporate and Federal agencies In cases where the fire is not extinguished within thirty minutes of discovery the area t...-..4 1-.-...-.a IAOTIA lflUnL tic tuuiicaucu Un aiLc1 cAwlgunrnJlg CUJU ICIL WIUILU1UCU wan icxca5cu vy nuorln and IUSA management Emergency off-site centers Blanding Fire House and Sheriffs office Blanding Fire 350 West 200 South Blanding Phone number is 911 Sheriffs Office 50 West 100 South Blanding Phone number is 911 or 435 587-2237 P\Admin\Master 5OPs\Book 6_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc A-I APPENDIX EMERGENCY PROCEDURE RESPONSE TO CHEMICAL OR GAS RELEASE chemical or gas release would most likely occur very suddenly The person who would first witness chemical or gas release should immediately contact his supervisor who would initiate the procedures outlined below Activate evacuation alarm by using the dial 184 notification system Evacuate mul account for all personnel Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped by the release Provide first aid and emergency medical care for any ill or injured persons Initiate necessary steps to contain and/or neutralize the release such as spraying with water fog turning off valves etc Guard against possible fires by shutting off electrical circuits isolating gas lines and alrnn0tn nntnn on.rna frnrn 4ha oPfansA 0mbOJt41%.IUI1 L1I%ass%.JL%.tt Wta P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.054oc A-I APPENDIX EMERGENCY EVACUATION PROCEDURE Activate evacuation alann by using the dial 184 notification system Evacuate and account for all personnel Personnel are to assemble in one of the following areas The parking lot south of the office building The scalehouse The north side of Tailings Cell or North of the Mill Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped Provide first aid and emergency medical care for any ill or injured persons Guard against possible fires by shutting off electrical circuits isolating gas lines and eliminating ignition sources frbm the affected area P\Mmin\Master 5OPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc A-I FIGURE FIRE SYSTEM SCHEMATIC DRAWING PfAdmin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-I 46 t l is n n a 4% I. .1 fl n 45 a b 9 jf l j LA rw 44 . 0 ts f l d o W d0 -n a He 2 00 0 t si nf l .. v oo a o s t .- s t i w j _ WO i n $ iv r os o o s fr tt i t Q l % f l % _k l 5 It i c Ir v . s i j j Lr . t fl 4 y s r P1 o% J . r n 1 o C do o - % sc n STORM WATER BEST MANGEMENT PRACTICES PLAN for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Blanding Utah June 2008 Prepared by Denison Mines USA Corp 1050 17th Street Suite 950 Denver CO 80265 TABLE OF CONTENTS 1.0 Purpose 2.0 Scope 3.0 Responsibility 4.0 Best Management Practices 4.1 General Management Practices Applicable to All Areas 4.2 Management Practices for Process and Laboratory Areas 4.3 Management Practices for Maintenance Activities 4.4 Management Practices for Ore Pad Tailings Area and heavy Equipment Operations Figures Figure White Mesa Mill Site Map Figure Mill Site Drainage Basins Figure JUSA Mill Management Organization Chart Figure IIJSA Corporate Management Orgathzation Chart Tables Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Appendices Appendix White Mesa Mill Spill Prevention Control and Countermeasures Plan Appendix White Mesa Mill Emergency Response Plan Best Management Practices Plan Revision 1.3 June 12 2008 1.0 INTRODUCTION/PURPOSE Denison Mines USA Corp DUSA operates the White Mesa Uranium Mill the Mill in Blanding Utah The Mill is net water consumer and is zero-discharge facility with respect to water effluents That is no water leaves the Mill site because the Mill has no outfalls to public stormwater systems no surface runoff to public stormwater systems no discharges to publicly owned treatment works POTW5 and no discharges to surface water bodies The State of Utah issued Groundwater Discharge Permit No UGW3 70004 to DUSA on March 2005 As part of compliance with the Permit DUSA is required to submit Stormwater Best Management Practices Plan BMPP to the Executive Secretary of the Division of Radiation Control Utah Department of Environmental Quality This BMPP presents operational and management practices to minimize or prevent spills of chemicals or hazardous materials which could result in contaminated surface water effluents potentially impacting surface waters or ground waters through runoff or discharge connections to stormwater or surface water drainage routes Although the Mill by design cannot directly impact stormwater surface water or groundwater the Mill implements these practices in good faith effort to minimize all sources of pollution at the site Page Best Management Practices Plan Revision 1.3 June 12 2008 2.0 SCOPE This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in process operations laboratory operations and maintenance activities and minimize spread of particulates from stockpiles and tailings management areas at the Mill Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this BMPP The Mill site was constructed with an overall grade and diversion ditch system designed to channel all surface runoff including precipitation equivalent to Probable Maximum PrecipitationlProbable Maximum Flood PMP/PMF storm event to the tailings management system In addition Mill tailings all other process effluents all solid waste and debris except used oil and recyclable materials and spilled materials that cannot be recovered for reuse are transferred to one or more of the tailings cells in accordance with the Mills NRC license conditions All of the process and laboratory building sinks sumps and floor drains are tied to the transfer lines to the tailings impoundments site map of the Mill is provided in Figure sketch of the site drainage basins is provided in Figure As result unlike other industrial facilities whose spill management programs focus on minimizing the introduction of chemical and solid waste and wastewater into the process sewers and storm drains the Mill is permitted by NRC license to manage some spills via draining or washdown to the process sewers and ultimately the tailings system However as good environmental management practice the Mill attempts to minimize the number and size of material spills and the amount of unrecovered spilled material and washwater that enters the process sewers after spill cleanup Section 4.0 itemizes the practices in place at the Mill to meet these objectives Requirements and methods for management recordkeeping and documentation of hazardous material spills are addressed in the DUSA White Mesa Mill Spill Prevention Control and Countermeasures SPCCPlan Revised February 2007 the Emergency Response Plan ERP also revised in February 2007 and the housekeeping procedures incorporated in the White Mesa Mill Standard Operating Procedures SOPs The SPCC plan and the ERP are provided in their entirety in Appendices and respectively Page Best Management Practices Plan Revision 1.3 June 12 2008 3.0 RESPONSIBILITY All Mill personnel are responsible for implementation of the practices in this BMPP DUSA White Mesa Mill management is responsible for providing the facilities or equipment necessary to implement the practices in this BMPP The Mill Management Organization is presented in Figure The DUSA Corporate Management Organization is presented in Figure An updated spill prevention and control notification list is provided in Table Page Best Management Practices Plan Revision 1.3 June 12 2008 4.0 BEST MANAGEMENT PRACTICES summary list and inventory of all liquid and solid materials managed at the Mill is provided in Tables through 4.1 General Management Practices Applicable to All Areas 4.1.1 Keep Potential Pollutants from Contact with Soil and Surface Water Store hazardous materials and other potential pollutants in appropriate containers Label the containers Keep the containers covered when not in use 4.1.2 Keep Potential Pollutants from Contact with Precipitation Store bulk materials in covered tanks or drums Store jars bottle or similar small containers in buildings or under covered areas Replace or repair broken dumpsters and bins Keep dumpster lids and large container covers closed when not in use to keep precipitation out 4.1.3 Keep Paved Areas from Becoming Pollutant Sources Sweep paved areas regulariy and dispose of debris in the solid waste dumpsters or tailings area as appropriate 4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and Reagent Storage Area Diversion ditches drainage channels and surface water control structures in and around the Mill area will be inspected at least weekly in accordance with the regularly scheduled inspections required by Groundwater Discharge Permit No UGW370004 and Byproduct Materials License UT1900479 Areas requiring maintenance or repair such as excessive vegetative growth channel erosion or pooling of surface water runoff will be report to site management and maintenance departments for necessary action to repair damage or perform reconstruction in order for the control feature to perform as intended Status of maintenance or repairs will be documented during follow up inspections and additional action taken if necessary 4.1.5 Recycle Fluids Whenever Possible When possible select automotive fluids solvents and cleaners that can be recycled or reclaimed When possible select consumable materials from suppliers who will reclaim empty containers Keep spent fluids in properly labeled covered containers until they are picked up for recycle or transferred to the tailings area for disposal Page Best Management Practices Plan Revision 1.3 June 12 2008 4.2 Management Practices for Process and Laboratory Areas 4.2.1 Clean Up Spills Properly Clean up spills with dry cleanup methods absorbents sweeping collection drums instead of water whenever possible Clean spills of stored reagents or other chemicals immediately after discovery Groundwater Discharge Permit No UGW370004 Section I.D.8.c Recover and re-use spilled material whenever possible Keep supplies of rags sorbent materials such as cat litter spill collection drums and personnel protective equipment PPE near the areas where they may be needed for spill response If spills must be washed down use the minimum amount of water needed for effective cleanup 4.2.2 Protect Materials Stored Outdoors If drummed feeds or products must be stored outdoors store them in covered or diked areas when possible If drummed chemicals must be stored outdoors store them in covered or diked areas when possible Make sure drums and containers stored outdoors are in good condition and secured against wind or leakage Place any damaged containers into an overpack drum or second container 4.2.3 Water Management When possible recycle and reuse water from flushing and pressure testing equipment When possible wipe down the outsides of containers instead of rinsing them off in the sink When possible wipe down counters and work surfaces instead of hosing or rinsing them off to sinks and drains 4.2.4 Materials Management Purchase and inventory the smallest amount of laboratory reagent necessary Do not stock more of reagent than will be used up before its expiration date All new construction of reagent storage facilities will include secondary containment which shall control and prevent any contact of spilled reagents or otherwise released reagent or product with the ground surface Groundwater Discharge Permit No UGW370004 Section I.D.3.e Page Best Management Practices Plan Revision 1.3 June 12 2008 4.3 Management Practices for Maintenance Activities 4.3.1 Keep Clean Dry Shop Sweep or vacuum shop floors regularly Designate specific areas indoors for parts cleaning and use cleaners and solvents only in those areas Clean up spills promptly Dont let minor spills spread Keep supplies of rags collection containers and sorbent material near each work area where they are needed Store bulk fluids waste fluids and batteries in an area with secondary containment double drum drip pan to capture leakage and contain spills 4.3.2 Manage Vehicle Fluids Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible Use drip pans or plastic tarps to prevent spillage and spread of fluids Promptly contain and transfer drained fluids to appropriate storage area for reuse recycle or disposal Recycle automotive fluids if possible when their useful life is finished 4.3.3 Use Controls During Paint Removal Use drop cloths and sheeting to prevent windbome contamination from paint chips and sandblasting dust Collect contain and transfer as soon as possible accumulated dusts and paint chips to disposal location in the tailings area authorized to accept waste materials from maintenance or construction activities 4.3.4 Use Controls During Paint Application and Cleanup Mix and use the right amount of paint for the job Use up one container before opening second one Recycle or reuse leftover paint whenever possible Never clean brushes or rinse or drain paint containers on the ground paved or unpaved Clean brushes and containers only at sinks and stations that drain to the process sewer to the tailings system Paint out brushes to the extent possible before water washing water-based paint or solvent rinsing oil-based paint Filter and reuse thinners and solvent whenever possible Contain solids and unusable excess liquids for transfer to the tailings area Page Best Management Practices Plan Revision 1.3 June 12 2008 4.4 Management Practices for Ore Pad Tailings Area and Heavy Equipment Detailed instructions for ore unloading dust suppression and tailings management are provided in the Mill SOPs 4.4.1 Wash Down Vehicles and Equipment in Proper Areas Wash down trucks trailers and other heavy equipment only in areas designated for this purpose such as washdown pad areas and the truck wash station At the truck wash station make sure the water collection and recycling system is working before turning on water sprays 4.4.2 Manage Stockpiles to Prevent Windborne Contamination Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill SOPs Water spray stockpiles as required by opacity standards or weather conditions Dont over-water Keep surfaces moist but minimize runoff water 4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources Schedule excavation grading and other earthmoving activities when extreme dryness and high winds will not be factor to prevent the need for excessive dust suppression Remove existing vegetation only when absolutely necessary Seed or plant temporary vegetation for erosion control on slopes Page TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Home Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.l66 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Home Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE REAGENT YARD LIST REAGEN1/L t-UAt4mitBS 2- UMBERO STORAGETANKS -PAC WL 4GALWNSV ADOGEN 2382 6120 ADVANTAGE 1O1M 2475 AMERSJTE2 AMINE 2384 19440 AMMONIUM SULFATE BULK 54000 AMMONIUM SULFATE BAGS 4300 ANHYDROUS AMMONIA 107920 31409 CHEMFAC 100 12800 CLARIFLOC N-1O1P 3000 DECYLALCOHOL 45430 DIESEL FUEL 250 6000 FLOCCULENTM1O11N 30550 FLOCCULENT M1302C 3550 GRINDING BALLS 48290 ISODECANOL 45430 KEROSENE 1344 10152 MACKANATE 3150 MILLSPERSE 802 1410 NALCO 2458 NALCO 8815 PERCOL 351 1500 PERCOL 406 13950 PERCOL 745 POLOX 10360 POLYHALL YCF PROPANE 30000 SALT BAGS 39280 SALT BULK SODA ASH BAGS 39280 SODA ASH BULK 84100 16921 8530 SODIUM CHLORATE 101128 17700 10500 SODIUM HYDROXIDE 19904 SULFURIC ACID 4801440 1600000 269160 UNLEADED GASOLINE 3000 USED OIL 5000 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 Chemical in Lab RQ2 Quantity In Stock Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 6M kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg Chemical in Volatiles and RQ2 Quantity In Stock Flammables Lockers AIBC Chloroform 4.54 kg Formaldehyde 45.4 kg of 37%solution Nitrobenzene 454 kg 12 Toluene 454 kg 12L Chemical in Acid Shed RQ2 Quantity In Stock Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARD/SMALL QUANTITY CHEMICALS LIST1 ay 1000 lbs ftM POiJtPt gal 1000 lbs 5L 100 lbs lbs 10 lbs kg 4.4 Ibs 10 lbs lbs Heptahydrate 1000 lbs kg 11 Ibs 5000 lbs 60 gal of 40% solution 1000 lbs 10 0.1 32 gal 5kg 11 Ibs 5.5%100 lbs kg 11 Ibs of 5.5%solution lb lbs 100 lb 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 5.0 REAGENT YARDIBULK CHEMICALS LIST1 Sulfuric Acid Floc 301 Hyperfloc 102 Ammonia East Tank Ammonia West Tank Kerosene Salt Bags Ammonium Hydrogendifluoride Soda Ash Dense Bag Phosphoric Acid Polyox Millsperse Nalco TX760 Nalco 7200 Tributyl phosphate Distillates Diesel Gasoline Alamine 336 drums Floc 109 Floc 208 Floc 904 Hyperfioc 624 Salt Bulk solids Salt Bulk solutions Caustic Soda Ammonium Sulfate Sodium Chlorate Alamine 335 Bulk Alamine 310 Bulk Isodecanol Vanadium Pentoxide3 Yellowcake3 Ammonia Meta Vanadate This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the clean Water Act REAGENT RQ2 QUANTITY IN REAGENT YARD 1000 lbs None None 100 lbs 100 lbs 100 gal None None None 5000 lbs None None None None None None 100 gal 100 gal None None None None None None None 1000 lbs None None None None None 1000 lbs None 1000 lbs 9000000 lbs 1200 lbs 1500 lbs lbs 105000 lbs 500 gal 2000 lbs 20450 lbs lbs 6300 lbs 490 lbs 1410 lbs barrels 1590 lbs 9450 lbs 100 gal Approx 3300 gal Approx 6000 gal lbs lbs lbs lbs lbs lbs lbs lbs lbs 20000 lbs lbs lbs lbs 30000 lbs 100000 lbs lbs Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act PRODUCT QUANTITY WAREHOUSE 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout 1D tO O SC Q E IN F O O T In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Tro j a n WH I T E M E S A MIL L cs m t y J 0 0 0 t. E E Fi g u r e MIL L S I T E LA Y O U T Do q 14 2 0 0 2 tra f f i c p o t SIe d d C a d ort l o t o w o Figure White Mesa Mill Mill Site Drainage Basins Figure White Mesa Mill Mill Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Wh i t e Me s a Mi l l Or g a n i z a t i o n a l St r u c t u r e Fi g u r e Sa f e t y Lf Ch e m i s t Figure Corporate Management Organization Chart In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n Or g a n i z a t i o n a l St r u c t u r e Fi g u r e APPENDICES APPENDIX WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS for White Mesa Uranium Mill 6425 South Highway 191 P.O Box 809 Blanding Utah 84511 February 2007 Prepared by Denison Mines USA Corp 1050 7th Street Suite 950 Denver Colorado 80265 TABLE OF CONTENTS SECTION PAGE 1.1 Objective 1.2 Responsibilities 1.3 Drainage Basins Pathways and Diversions 1.4 Description of Basins 1.4.1 Basin Al 1.42 Basin A2 1.4.3 Basin BI 1.4.4 Basin B2 1.4.5 Basin B3 1.4.6 Basin 1.4.7 Basin 1.4.8 Basin 1.5 Potential Chemical Spill Sources And Spill Containment 1.5.1 ReagentTanks 1.5.2 Ammonia 1.5.3 Ammonium Meta Vanadate 1.5.4 Caustic Storage Sodium Hydroxide 1.5.5 Sodium Carbonate 1.5.6 Sodium Chlorate 1.5.7 Sulfuric Acid 1.5.8 Vanadium Pentoxide 1.5.9 Kerosene Organic 1.6.0 Used/Waste Oil SECTION PAGE 1.6.1 Propane 1.7 Potential Petroleum Sources And Containment 1.7.1 Petroleum Storage Tanks 1.7.1.1 Diesel 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.2 Unleaded Gasoline 1.7.2.3 Pump Station 11.2.4 Truck Unloading 1.8 Spill Discovery And Remedial Action 1.9 Spill Incident Notifications 1.9.1 External Notification 1.9.2 Internal Notification 11 1.10 Records And Reports 12 1.11 Personnel Training And Spill Prevention Procedures 12 1.11.1 Training Records 12 1.11.2 Monitoring Reports 13 1.12 Revision 13 1.13 Summary 13 1.14 Mill Manager Approval 14 1.15 Certification by Registered Professional Engineer 14 LIST OF TABLES Table 1.0 Mill Organization Chart Table 2.0 Reagent Tank List Table 3.0 Laboratory Chemical Inventory List Table 4.0 Reagent Yard/Small Quantity Chemicals List Table 5.0 Reagent Yard/Bulk Chemicals List Table 6.0 Petroleum Products and Solvents List LIST OF FIGURES Figure Miii Site Layout Figure Mill Site Drainage Basins WHITE MESA MILL SPILL PREVENTION CONTROL AND COUNTERMEASURES PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS 1.1 OBJECTIVE The objective of the Spilt Prevention Control and Countermeasures SPCC Plan is to serve as site-specific guideline for the prevention of and response to chemicat and petroteum spilts and as guidance document for compliance with Groundwater Discharge Permit No UGW370004 The ptan outlines spill potentials containment areas and drainage characteristics of the White Mesa Mill site The plan addresses chemical spill prevention spitt potentials spill discovery and spilt notification procedures The Oil Pollution Prevention Sections of the Clean Water Act 40 CFR 112 to 117 atso referred to as the Spitl Prevention Control and Countermeasures SPCC rutes estabtish requirements that appty to facilities which coutd reasonabty be expected to discharge oit in quantities that may be harmful as described in that Act into or upon the navigabte waters of the United States or that may affect natural resources of the United States Section 112 states that the Act is not appticable to facilities that are not subject to the authority of the Environmental Protection Agency EPA for one of the fottowing reasons Due to its tocation the facitity coutd not reasonably be expected to discharge oit into navigabte waters of or impact naturat resources of the U.S or The facility is subject to authority of the Department of Transportation as defined in Memorandum of Understanding MOU between the Secretary of Transportation and the EPA Administrator or The facility does not exceed either the underground or the above ground storage capacity 42000 gatlons and 1320 gatlons respectively prescribed in the rutes The Milt could not reasonabty be expected as described in the SPCC regutation to discharge oil into the navigable waters or impact naturat resources of the U.S The Mitt site was constructed with an overalt grade and diversion ditch system designed to channel the non-recovered portion of any material spill to the tailings management system Hence it is not reasonabte to expect that surface spills will ever reach navigable waters or naturat resources of the U.S or Utah Therefore the SPCC reporting requirements in the Clean Water Act are not appticable to the Milt However as good environmental management practice the Mitt has implemented the spitl management program described in this document which is consistent with the intent of the Clean Water Act to the extent practicable Although the Mill by design cannot directly impact navigable waters of the U.S and as result spills that may occur but are retained within the site would not be reportable the Mill implements these practices in good faith effort to minimize all potential sources of pollution at the site Storage of ores and alternate feeds on the ore pad and containment of tailings in the Mill tailings impoundment system are not considered spills for the purposes of this SPCC Ammonia is the only chemical that has the potential to leave the site and would do so as vapor Figure Site Layout Map shows map of the mill site including the locations of the chemical tanks on-site Figure shows the basins and drainage ditch areas for the mill site Table 1.0 is an organization chart for Mill operations Table 2.0 lists the reagent tanks and their respective capacities Table 3.0 lists the laboratory chemicals their amounts and their reportable quantities Table 4.0 lists the operations chemicals Table 5.0 lists the chemicals in the reagent yard their amounts and their reportable quantities Table 6.0 lists the petroleum products and solvents on site 1.2 RESPONSIBILITIES Person in charge of facility responsible for spill prevention Mr Richard Bartlett Interim Mill Manager 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 459-2495 home Person in charge of follow-up spill record keeping and/or reporting Mr David Turk Department Head Health Safety and Environmental 6425 South Highway 191 Blanding UT 84511 435 678-2221 work 435 678-7802 home Refer to Section 1.9 Spill Incident Notification for list of company personnel to be notified in case of spill In addition an organizational chart is provided in Table 1.0 1.3 DRAINAGE BASINS PATHWAYS AND DIVERSIONS The main drainage pathways are illustrated in Figure The map shows drainage basin boundaries flow paths constructed diversion ditches tailings cells the spillway between Cell and dikes berms and other relevant features The White Mesa Mill is zero discharge facility for process liquid wastes The mill area has been designed to ensure that all spills or leaks from tanks will drain toward the lined tailings cells The tailings cells in turn are operated with sufficient freeboard minimum of three feet to withstand 100%of the PMP Probable Maximum Precipitation This allows for maximum of 10 inches of rain at any given time 1.4 DESCRIPTION OF BASINS Precipitation and unexpected spills on the mill property are contained within their respective drainage basins Runoff would ultimately drain into one of the three lined tailings cells 1.4.1 Basin Al Basin Al is north of Cell 1-I and Diversion Ditch No The basin contains 23 acres all of which drain into Westwater Creek This area is not affected by mill operations 1.4.2 Basin A2 Basin A2 contains all of Cell 1-I including an area south of the Diversion Ditch No The basin covers 84 acres Any runoff from this basin would be contained within Cell 1-I 1.4.3 Basin Bl Basin Bl is north of the mill property and is not affected by mill operations The basin contains 45.4 tributary acres Runoff from this basin drains into flood retention area by flowing through Diversion Ditch No Diversion Ditch No drains into Westwater Creek 1.4.4 Basin B2 Basin B2 is northeast of the mill and contains only 2.6 acres Runoff from this basin would drain into Diversion Ditch No Diversion Ditch No ultimately drains into Diversion Ditch No This basin is not affected by mill operations 1.4.5 Basin B3 Basin B3 contains most of the mill area buildings ore stockpiles process storage tanks retention ponds spill containment structures pipelines and roadways The normal direction of flow in this basin is from the northwest to the southwest Any runoff from this basin would drain into Cell 1-I The basin contains 64 acres This basin has sufficient freeboard to withstand 100%of the PMP Probable Maximum Precipitation This allows 10 inches of rain for any given storm event 1.4.6 Basin Basin contains all of Cell The basin consists of 80.7 acres This basin contains earth stockpiles and the heavy equipment shop The direction of flow in this basin is to the southwest All runoff in this basin would be channeled along the southern edge of the basin Runoff would then flow into Cell via the spillway from Cell to Cell 1.4.7 Basin Basin contains all of Cell This basin consists of 78.3 acres including portion of the slopes of the topsoil stockpile and random stockpile The basin contains all flows including those caused by the PMF 1.4.8 Basin Basin contains Cell 4A and consists of 43.3 acres All anticipated flows including those caused by the PMF will be contained within the basin and will flow directly into Cell 4A 1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL CONTAINMENT This section details potential sources of chemical spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States Reportable Quantities are those identified in 40 CFR Pad 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.5.1 Reagent Tanks Tank list included in Table 2.0 1.5.2 Ammonia The ammonia storage tanks consist of two tanks with capacity of 31409 gallons each The tanks are located southeast of the Mill building Daily monitoring of the tanks for leaks and routine integrity inspections will be conducted to minimize the hazard associated with ammonia The reportable quantity for an ammonia spill is gallons Ammonia spills should be treated as gaseous Ammonia vapors will be monitored closely to minimize the hazard associated with inhalation If vapors are detected efforts will be made to stop or repair the leak expeditiously Ammonia is the only chemical as vapor that has the potential to leave the site 1.5.3 Ammonia Meta Vanadate Ammonia meta vanadate is present in the SX building as the process solutions move through the circuit to produce the vanadium end product But the primary focus will be on the transportation of this chemical The reportable quantity for an ammonia meta vanadate spill is 1000 pounds 1.5.4 Caustic Storage Sodium Hydroxide The caustic storage tank is located on splash pad on the northwest corner of the SX building The tank has capacity of 19904 gallons The tank supports are mounted on concrete curbed catchment pad that directs spills into the sand filter sump in the northwest corner of the SX building The reportable quantity for sodium hydroxide spill is 85 gallons 1.5.5 Sodium Carbonate Soda Ash The soda ash solution tank has capacity of 16921 gallons and is located in the northeast corner of the SX building The smaller soda ash shift tank has capacity of 8530 gallons and is located in the SX building Spills will be diverted into the boiler area and would ultimately drain into Cell 1-I There is no reportable quantity associated with sodium carbonate spill 1.5.6 Sodium Chlorate Sodium chlorate tanks consist of two fiberglass tanks located within dike east of the SX building The larger tank is used for dilution purposes and has maximum capacity of 17700 gallons The smaller tank serves as storage tank and has capacity of 10500 gallons Daily monitoring of the tanks for leaks and integrity inspections will be conducted to minimize the hazard associated with sodium chlorate Sodium chlorate that has dried and solidified becomes even more of safety hazard due to its extremely flammable nature The reportable quantity for sodium chlorate spill is 400 gallons 1.5.7 Sulfuric Acid The sulfuric acid storage tanks consist of one large tank with the capacity of 16000000 gallons and two smaller tanks with capacities of 269160 gallons each The large tank is located in the northwest corner of mill area basin B3 and is primarily used for acid storage and unloading The tank support for the large tank is on mound above depression which would contain significant spill All flows resulting would be channeled to Cell 1-I The tank is equipped with high level audible alarm which sounds prior to tank overflows concrete spill catchment with sump in the back provides added containment around the base of the tank However the catchment basin would not be able to handle major tank failure such as tank rupture The resulting overflow would flow towards Cell 1-I The two smaller storage tanks are located within an equal volume spill containment dike east of the mill building The tanks are not presently in use but are equipped with high level audible alarms The reportable quantity for sulfuric acid spill is 65 gallons 1000 pounds 1.5.8 Vanadium Pentoxide Vanadium pentoxide is produced when vanadium is processed through the drying and fusing circuits and is not present in the vanadium circuit until after the deammoniator Efforts will be made to minimize leaks or line breaks that may occur in processes in the circuit that contain vanadium pentoxide Special care will be taken in the transportation of this chemical The reportable quantity for vanadium pentoxide spill is 1000 pounds 1.5.9 Kerosene Organic The kerosene storage area is located in the central mill yard and has combined capacity of 10152 gallons in three tanks Any overflow from these three tanks would flow around the south side of the SX building and then into Cell 1-I These tanks have drain valves which remain locked unless personnel are supervising draining operations The reportable quantity for kerosene spill is 100 gallons 1.6.0 Used Waste Oil Used/Waste oil for parts washing is located north of the maintenance shop in tank and has capacity of 5000 gallons The tank is contained within concrete containment system Ultimate disposal of the used oil is to an EPA permitted oil recycler Any oil escaping the concrete containment system will be cleaned up Soil contaminated with used oil will be excavated and disposed of in Cell 1.6.1 Propane The propane tank is located in the northwest corner of the mill yard and has capacity of 30000 gallons Daily monitoring of the tank for leaks and integrity inspections will be conducted to minimize potential hazards associated with propane leaks Propane leaks will be reported immediately There is no reportable quantity associated with propane spill 1.7 POTENTIAL PETROLEUM SPILL SOURCES AND CONTAINMENT This section details potential sources of petroleum spills and reportable quantities For purposes of this SPCC reportable quantity will be defined as quantities listed below which could be expected to reach navigable waters of the United States It is not expected that any spill would reach navigable waters of the United States However if spill of volume listed below occurs and remains on the mill site which is the more likely scenario then management is to be notified so that proper internal evaluations of the spill are made 1.7.1 Petroleum Tanks 1.7.1.1 Diesel Two diesel storage tanks are located north of the mill building The tanks have capacities of 250 gallons each One of the diesel tanks is for the emergency generator The other tank is located in the pumphouse on an elevated stand Spillage from either tank would ultimately flow into Cell 1-I The reportable quantity for diesel spill is 100 gallons 1.7.2 Aboveground Fuel Pump Tanks 1.7.2.1 Diesel The diesel tank is located on the east boundary of Basin B3 and has capacity of 6000 gallons The tank is contained within concrete catchment pad The reportable quantity for diesel spill is 100 gallons 1.7.2.2 Unleaded Gasoline The unleaded gasoline tank is located next to the diesel tank The unleaded gasoline tank has capacity of 3000 gallons and is contained within the same containment system as the diesel tank The reportable quantity for an unleaded gasoline spill is 100 gallons 1.7.2.3 Pump Station Both the diesel and the unleaded gasoline tanks will be used for refueling company vehicles used around the mill site The pump station is equipped with an emergency shut-off device in case of overflow during fueling In addition the station is also equipped with piston leak detector and emergency vent Check valves are present along with tank monitor console with leak detection system The catchment is able to handle complete failure of one tank However if both tanks failed the concrete catchment pad would not be able to contain the spill In this case temporary berm would need to be constructed Absorbent diapers or floor sweep would be used in an effort to limit and contain the spill The soil would be cleaned up and placed in the authorized disposal area in Cell 1.7 2.4 Truck Unloading In the event of truck accident resulting in an overturned vehicle in the mill area proper reporting and containment procedures will be followed when warranted such as when oil or diesel fuel is spilled Proper clean-up procedures will be followed to minimize or limit the spill The spill may be temporarily bermed or localized with absorbent compounds Any soils contaminated with diesel fuel or oil will be cleaned up and placed in the authorized disposal area in Cell 1.8 SPILL DISCOVERY AND REMEDIAL ACTION Once chemical or petroleum spill has been detected it is important to take measures to limit additional spillage and contain the spill that has already occurred Chemical or petroleum spills will be handled as follows The Shift Foreman will direct efforts to shut down systems if possible to limit further release The Shift Foreman will also secure help if operators are requiring additional assistance to contain the spill The Shift Foreman is also obligated to initiate reporting procedures Once control measures have begun and personal danger is minimized the Shift Foreman will notify the Production Superintendent Maintenance Superintendent or Mill Manager The Production or Maintenance Superintendent will notify the Mill Manager who in turn will notify the Environmental Health and Safety Manager The Mill Manager will assess the spill and related damage and direct remedial actions The corrective actions may include repairs clean up disposal and company notifications Government notifications may be necessary in some cases If major spill continues uncontrolled these alternatives will be considered Construct soil dikes or pit using heavy equipment Construct diversion channel into an existing pond Start pumping the spill into an existing tank or pond Plan further clean-up and decontamination measures 1.9 SPILL INCIDENT NOTIFICATION 1.9.1 External Notification As stated in Section 1.1 spills are not expected to reach navigable waters of the United States If spill of reportable quantity occurs then mill and corporate management must be notified and they will evaluate whether or not the following agencies must be notified EPA National Response Center 1-800-424-8802 State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah 801/538-7200 Water Quality Division 801/538-6146 In case of tailings dam failure contact the following agencies State of Utah Department of Environmental Quality Division of Radiation Control 801/536-4250 State of Utah Natural Resources 801/538-7200 1.9.2 Internal Notification Internal reporting requirements for incidents spills and significant spills are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions and accidents Government investigations information requests or enforcement actions Private actions or claims corporate or employee Deviations from corporate policies or government requirements by management Which have or could result in the following Death serious injury or adverse health effects Property damage exceeding $1000000 10 Government investigation or enforcement action which limits operations or assesses penalties of $100000 or more Publicity resulted or anticipated Substantial media coverage Report At The Beginning Of The Next Day Event Criteria Was reported to government agency as required by law Worker employee or contractor recordable injury or illness associated with release Community impact-reported or awareness Publicity resulted or anticipated Release exceeding the reportable quantities listed in Section 1.5 for each specific process material waste or by-product In the event of spill of reportable quantity the Mill Manager is required to call the Corporate Environmental Manager or the President and Chief Executive Officer The individual first discovering the spill will report it to the Shift Foreman Production Superintendent or Maintenance Superintendent who will in turn ensure that the Mill Manager is notified The Environmental Health and Safety Manager will also be contacted by the Mill Manager Name Title Home Phone Mill Personnel Richard Bartlett Interim Mill Manager 435 678-2495 Wade Hancock Maintenance Foreman 435 678-2753 David Turk Environmental Health and Safety Manager 435 678-7802 N/A Production Superintendent N/A Maintenance Foreman Scot Christensen Mill Shift Foreman 435 678-2015 Corporate Personnel Ronald Hochstein President and Chief Operating Officer 604 377-1167 David Frydenlund Vice President and General Counsel 303 221-0098 In the event the next person in the chain-of-command cannot be reached then proceed up the chain-of-command to the next level Table 1.0 shows the organizational chart for the mill site 11 1110 RECORDS AND REPORTS The following reports and records are to be maintained in Central Files by the Environmental Health and Safety Manager for inspection and review for minimum of three years Record of site monitoring inspections Daily Tailings Inspection Data Weekly Tailings Inspection and Survey Monthly Tailings Inspection Pipeline thickness Quarterly Tailings Inspection Tank to soil potential measurements Annual bulk oil and fuel tank visual inspections Tank and pipeline thickness tests Quarterly and annual PCB transformer inspections if transformer contains PCBs Tank supports and foundation inspections Spill Incident Reports Latest revision of SPCC plan 1.11 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES All new employees are instructed on spills at the time they are employed and trained They are briefed on chemical and petroleum spill prevention and control They are informed that leaks in piping valves and sudden discharges from tanks should be reported immediately Abnormal flows from ditches or impoundments are of immediate concern In addition safety meeting is presented annually by the Environmental Health and Safety Manager to review the SPCC plan 1.11.1 Training Records Employee training records on chemical and petroleum spill prevention are maintained in the general safety training files 1.11.2 Monitoring Reports Shift logs shall provide checklist for inspection items 12 1.12 REVISION This procedure is to be reviewed by the mill staff and registered professional engineer at least onc eve ry th ree years and updated when circumstances warrant revision 1.13 Summary Below is table listing the specific reportable quantities associated with the major chemical and petroleum products on-site CHEMICAL REPORTABLE QUANTITY RQ AMMONIA 100 POUNDS AMV 1000 POUNDS SODIUM HYDROXIDE 1000 POUNDS SODA ASH No Reportable Quantity SODIUM CHLORATE 400 GALLONS SULFURIC ACID 1000 POUNDS VANADIUM PENTOXIDE 1000 POUNDS KEROSENE 100 GALLONS OIL No Reportable Quantity PROPANE No Reportable Quantity DIESEL UNLEADED FUEL 100 GALLONS 13 1.14 MILL MANAGER APPROVAL hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with the Standard Operating Procedures currently in effect Richard Bartlett Interim Mill Manager 1.15 CERTIFICATION BY REGISTERED PROFESSIONAL ENGINEER hereby certify that have reviewed the foregoing chemical and petroleum product SPCC plan that am familiar with the International Uranium USA Corporation White Mesa Mill facilities and attest that this SPCC plan has been prepared in accordance with good engineering practices Harold Roberts Registered Professional Engineer State of Utah No 165838 14 TABLES Table White Mesa Mill Management Personnel Responsible for Implementing This BMPP Mill Staff Personnel Title Work Phone Rome Phone Other Contact Number Rich Bartlett Interim Mill Manager 435-678-2221 435 678-2495 Ext 105 Wade Hancock Maintenance Foreman 435-678-2221 435 678-2753 Ext.166 Scot Christensen Mill Foreman 435-678-2221 435 678-2015 David Turk Radiation Safety Officer 435-678-2221 435 678-7802 Ext 113 Corporate Management Staff Personnel Title Work Phone Rome Phone Other Contact Number Ron Hochstein President Chief Operating 604 806-3589 Cell 604 377-1167 Officer David Frydenlund Vice President and 303 389-4130 303 221-0098 General Counsel Cell 303 808-6648 TABLE 2.0 REAGENT TANK LIST QUANTITY REAGENT cAPACITY GAL DIESEL 250 KEROSENE 10152 USED/WASTE OIL 5000 DIESEL 6000 UNLEADED 3000 PROPANE 30000 AMMONIA 31409 SODIUM HYDROXIDE 19904 SODA ASH SOLUTION 16921 SODA ASH SHIFT 8530 SODIUM CHLORATE 17700 SODIUM CHLORATE 10500 SULFURIC ACID 1600000 SULFURIC ACID 269160 TABLE 3.0 LABORATORY CHEMICAL INVENTORY LIST1 SIw5K Aluminum nitrate Ammonium bifluoride Ammonium chloride Ammonium oxalate Ammonium thiocyanate Antimony potassium tartrate n-Butyl acetate Carbon tetrachloride Cyclohexane Ferric chloride Ferrous ammonium sulfate Potassium chromate Sodium nitrite Sodium phosphate tribasic Zinc acetate 2270 kg 45.4 kg 2270 kg 2270 kg 2270 kg 45.4 kg 2270 kg 4.54 kg 454 kg 454 kg 454 kg 4.54 kg 45.4 kg 2270 kg 454 kg 1.8 kg 2.27 kg 2.27 kg 6.8 kg 7.8 kg 0.454 kg 1.0 24 6.810 kg 0.57 kg 0.114 kg 2.5 kg 1.4 kg 0.91 kg hemioIuVthtiJescand -flQk Quahtitthtstocl FihthMiSiVkŁWABfl V4 Chloroform 4.54 kg Formaldehyde 45.4 kg IL of 37%solution Nitrobenzene 454 kg 12 Toluene 454 kg 12 Q4Si Chloroform 4.54 kg 55 gal Hydrochloric acid 2270 kg 58 gal Nitric acid 454 kg Phosphoric acid 2270 kg 10 Sulfuric acid 454 kg 25 Hydrofluoric Acid 45.4 kg Ammonium hydroxide 454 kg 18 This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act TABLE 4.0 REAGENT YARDISMALL QUANTITY CHEMICALS LIST1 Ammonium Hydroxide 1000 lbs 5L Carbon Disulfide 100 lbs lbs Calcium Hypochlorite 10 lbs kg 4.4 Ibs Chlorine 10 lbs Olbs Ferrous Sulfate Heptahydrate 1000 lbs kg lIbs Hydrochloric Acid 5000 lbs 60 gal of 40% solution Nitric Acid 1000 lbs 10 Potassium Permanganate 0.1 32 gal kg 11 Ibs Sodium Hypochlorite 5.5%100 lbs kg 11 Ibs of 5.5%solution Silver Nitrate lb lbs Trichloroethylene 100 lb Xylene Mixed Isomers 100 lbs lbs This list identifies chemicals which are regulated as hazardous substances under the Federal Water Pollution Control Act 40 CFR Pad 117 Materials in this list are stored in locked storage compound near the bulk storage tank area The Mill also stores small quantities of other materials that are not hazardous substances per the above regulation Reportable Quantities are those identified in 40 CFR Pad 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act Acetic Acid Glacial TABLE 5.0 REAGENT YARD/BULK CHEMICALS LIST1 REAGENT.H 11 Q2 QUANTITYIN REAGENflARO Sulfuric Acid 1000 lbs 9000000 lbs Floc 301 None 1200 lbs Hyperfloc 102 None 1500 lbs Ammonia East Tank 100 lbs lbs Ammonia West Tank 100 lbs 105000 lbs Kerosene 100 gal 500 gal Salt Bags None 2000 lbs Ammonium Hydrogendifluoride None 20450 lbs Soda Ash Dense Bag None lbs Phosphoric Acid 5000 lbs 6300 lbs Polyox None 490 lbs Millsperse None 1410 lbs Nalco TX760 None barrels Nalco 7200 None 1590 lbs Tributyl phosphate None 9450 lbs Distillates None 100 gal Diesel 100 gal Approx 3300 gal Gasoline 100 gal Approx 6000 gal Alamine 336 drums None lbs Floc 109 None lbs Floc 208 None lbs Floc 904 None lbs Hyperfloc 624 None lbs Salt Bulk solids None lbs Salt Bulk solutions None lbs Caustic Soda 1000 lbs lbs Ammonium Sulfate None lbs Sodium Chlorate None 20000 lbs Alamine 335 Bulk None lbs Alamine 310 Bulk None lbs Isodecanol None lbs Vanadium Pentoxide3 1000 lbs 30000 lbs Yellowcake3 None 100000 lbs Ammonia Meta Vanadate 1000 lbs lbs This list identifies all chemicals in the reagent yard whether or not they are regulated as hazardous substances under the Federal Water Pollution control Act 40 CFR Part 117 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous substances Designated Pursuant to Section 311 of the Clean Water Act Vanadium Pentoxide and Yellowcake the Mills products are not stored in the Reagent Yard itself but are present in closed containers in the Mill Building and/or Mill Yard TABLE 6.0 PETROLEUM PRODUCTS AND SOLVENTS LIST1 iPRODUCT QUANTJTY4NH Lubricating Oils in 55 gallon drums Transmission Oils Water Soluble Oils Xylene mixed isomers Toluene Varsol Solvent 2%trimethyl benzene in petroleum distillates This list includes all solvents and petroleum-based products in the Mill warehouse petroleum and chemical storage aisles Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3 Reportable Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean Water Act 100 gal 100 gal 100 gal 100 lbs 1000 lbs 100 gal 1540 gallons gallons 30 gallons gallons gallons gallons FIGURES Figure White Mesa Mill Mill Site Layout WIS E Dl FIE T In t e r n a t i o n a l Ur a n i u m US A Co r p o r a t i o n P.J . t t WH I T E M E S A MIL L ia v t s m t s CW b t $ b Stt t Ut a h it t Lo c a t Fi g u r e MIL L S I T E LA Y O U T Dt t % 14 2 0 0 2 fr a W c a t uti c i o w n Figure White Mesa Mill Mill Site Drainage Basins APPENDIX WHITE MESA MTLL EMERGENCY RESPONSE PLAN EMERGENCY RESPONSE PLAN REVISION 1.1 Denison Mines USA Corp 1t7t.-WiT.11 VV IIILC JVICSd IV1III landing Utah April 14 1986 REVISED February 16 2007 Distribution List Ron Hochstein RichE Bartlett David Turk Michael Spillman Mill Shift Foremen Blanding Fire Department San Juan County EMS Coordinator State of Utah Department of Radiation Control Revision Date January 16 2006 TABLE OF CONTENTS Page Number 1.0 Introduction .1 2.0 White Mesa Mill Background .1 3.0 Plan Objectives 4.0 Description of Facilities 4.1 Fire Water Supply and Alarm Systems 4.2 Office Building and Laboratory 4.3 Solvent Extraction Building 4.4 Mill Building 4.5 Maintenance Shop/Warehouse/Change Room Building 4.6 Reagent and Fuel Storage 4.7 Boiler House 4.8 Sample Plant 5.0 Organization and Responsibilities 5.1 Mill Manager/Encident Commander 5.2 Operations Superintendent 5.3 Radiation Safety Officer/Fire Chief 5.4 Maintenance Supervisor 5.5 Laboratory Supervisor 5.6 Shift Foremen 5.7 Scale House Personnel 5.8 Emergency Response Teams 6.0 Specific Emergencies 10 6.1 Fire 10 6.2 Chemical or Gas Release 10 6.3 Earthquake 10 6.4 Terrorist/Bomb Threat 10 6.5 Tailings Dam Break and Major Floods 10 7.0 Evacuation Procedure 11 7.1 Notification 11 7.2 Assembly 11 7.3 Specific Procedures for Operations Personnel 11 8.0 Off-Site Emergency Equipment/Personnel Release 11 9.0 Emergency Equipment 12 9.1 Fire Hose 12 9.2 Self Contained Breathing Apparatus 12 9.3 Spill Clean-up Equipment 12 9.4 Fire Fighting PPE 12 10.0 Emergency Transportation 13 11.0 Emergency Evacuation Drills 13 EXHIBITS Emergency Notification List E- Internal Notifications E-2 Site Layout Map E-3 Main Shut-off Valves E-4 APPENDICES Emergency Procedure Response to Fire A-I Emergency Procedure Response to Chemical or Gas Release A-2 Emergency Evacuation Procedure A-3 FIGURES Fire System Schematic F-I ii INThRNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 INTRODUCTION This Emergency Response Plan is written not only to comply with Federal State and local regulations but even more importantly to reduce the risk to our employees and that of the community in regards to Health Safety and Environmental Emergencies This plan includes the following evaluation of the potential risks for fire explosions gas releases chemical spills and floods including tailings dam failure specific emergency programs for each potential event definition of administrative response actions and definition of the emergency response contacts both internal and external The White Mesa Mill the Milloperates under the following regulatory agencies Utah State Department of Environmental Quality Division of Radiation Control Mine Safety and Health Administration Environmental Protection Agency Utah State Department of Environmental Quality Division of Air Quality and Utah State Division of Natural Resources Bureau of Dam Safety WHITE MESA MILL OVERVIEW The Mill processes conventional uranium or uranium/vanadium ores to recover uranium and vanadium In addition to the processing of conventional ores the Mill also processes alternate feed materials using similar process steps and chemicals The conventional ore is stored on the Ore Pad shown in Exhibit Alternate feed materials are also stored on the Ore Pad and may be stored in bulk form lined burrito bags liners or drums The descriptions of each alternate feed material are malntained by the Mills Radiation Safety Officer The Mill utilizes semi-autogenous grind circuit followed by hot sulfuric acid leach and solvent extraction process to extract uranium and vanadium from ores using large amounts of sulfuric acid sodium chlorate kerosene amines ammonia and caustic soda in the process The reagent storage tank locations are described in further detail in Section 4.6 Emissions from the Mill process are in the form of air emissions from exhaust stacks and solid/liquid tailings which are stored in the Mills tailings cells located west/southwest of the main Mill building The major exhaust stack parameters are shown in the following table Description Height ft from surface Diameter inches Estimated Flow Rate cfln Leach Exhaust l00 36 13700 Yellow Cake Drying stacks 85 18 4000 per stack Vanadium Roasting Fusion 85 38 4100 P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 1NTERNATIONAL URANIUM USA CORPORATION Rev No.R-l Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 There are also smaller exhaust stacks associated with the Laboratory in the Mill Administration building and the boiler exhaust stack The Mills tailings cells are comprised of four below grade engineered cells Cell I-I and 4A Liquids are stored in Cell 1-I and Cell the active tailings cell The liquid in the tailings cells is very acidic In addition to the tailings cells there is also an emergency lined catchment basin west of the Mill building Solutions in this basin or the tailings cells should not be used to fight fires in the Mill facility The products of the Mill include ammonium metavanadate AMV vanadium pregnant liquor VPL vanadium pentoxide V205 and yellowcake or uranium concentrate U3O8 The V2O5 and U3O8 products are packaged in steel drums for shipment The AM17 is packaged in either steel drums or super-saks while the VPL is sold in liquid form in bulk Master files containing Material Safety Data Sheets for all materials in use at the Mill are maintained at the Safety Office Mill Maintenance Office Mill Laboratory and Mill Central Control Room Copies are also on file at the Blanding Clinic Doctors Offices Blanding Fire House and Office of the San Juan County Emergency Medical Coordinator The nearest residence to the Mill is approximately one mile to the north of the Mill the next is residence approximately two miles north of the Mill followed by the community of White Mesa about 3.5 miles to the south The City of Blanding is located approximately miles to the northeast The Mill site is near Utah State Highway 191 and can be accessed by paved access road from the highway to the Mill facilities PLAN OBJECTIVES The primary objectives of this plan are To save lives prevent injuries prevent panic and minimize property/environmental damage to the lowest possible level To evacuate and account for all people in the area including visitors truck drivers contractors etc To provide assembly areas that are as safe as possible and which can be reached without traveling through hazardous area Assembly areas will be properly manned to deal with sick or injured persons and provisions will be made to evacuate those persons to proper shelter To make adequately trained personnel available to cope with rescue and recovery operations as directed by the Incident Commander DESCRIPTION OF FACILITIES The Mill facilities are shown on the Site Layout Map included as Exhibit P\Admin\Master sOPs\Book 16_Emergency Response Pian\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MiLL EMERGENCY RESPONSE PLAN Page of 13 4.1 Fire Water Supply and Alarm Systems 4.1.1 Fire Water Supply The fire water supply facilities include 400000 gallon Storage Tank of which 250000 gallons are reserved for fire emergencies Centrifugal diesel driven pump rated at 2000 gpm at 100 psi This pump starts automatically when the pressure in the fire main drops below 100 psi See Figure Fire System Schematic When more water is needed for an emergency an additional source is the Recapture Reservoir supply pipeline which can be utilized in emergencies at rate of about 1200 gpm 4.1.2 Alarm System The alarm systems include the following public address system hand held radios siren 4.2 Office Building and Laboratory 4.2.1 Office Building The office building approximately 10000 square feet contains the administration offices radiation health and safety offices and the Mill laboratory The central file vault and the main computer system are also in this building The ambulance is kept on the west side of the office building near the safety office entrance 4.2.2 Laboratory The laboratory facilities contain the following three flammable cabinets keys required chemical storage room south of main lab six fume hoods hoods 12 and are in the center of the laboratory and hoods and are along the west wall Hoods and are no longer in service Hoods and are on the west side and are on the east side of the center cluster of hoods with being in front Only hoods and may be used for perchloric acid outside laboratory chemical storage north of office building key required perchioric acid storage vault located underground west of office building key required wide variety of chemicals in small quantities are located in the laboratory These chemicals range from acids to bases along with flammable metal compounds and peroxide forming compounds Oxidizers and organic chemicals which have strong potential of producing harmful vapors if the containers are damaged to the point that the chemicals are exposed are stored in storage room in the laboratory There are no acids stored in this storage room The acids including but not limited to sulfuric nitric acetic perchloric phosphoric and hydrochloric acids are stored in the main laboratory area in 2.5 liter or 500-mi bottles MSDS books for all PAdmin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 chemicals in the laboratory are located in the Laboratory Safety Department Mill Maintenance office and Mill Central Control room 4.2.3 Electrical Electrical transformers and electrical switches are located in the laboratory at the east end of the chemical storage room 4.2.4 Fire Protection System The fire protection systems in the office building and laboratory include fire hose station located on the east end of the office building The station includes two sets of turnout gear two SCBA units and Incident Commander materials automatic wet sprinlder system which is actuated at 212 portable dry chemical extinguishers strategically located throughout the building 4.3 Solvent Extraction Building The solvent extraction SX building approximately 21000 square feet houses the uranium and vanadium solvent extraction circuits and the ELUEX circuit The SX circuits may contain up to 200000 gallons kerosene 757000 liters which has flash point of 185 Associated equipment in the SX building includes temporary boiler located at the southwest end of the SX building which maintains the temperature for the fire system Chemicals which may be encountered in the SX building include Kerosene Caustic Soda Anhydrous Ammonia Sulfuric Acid Salt Brine Soda Ash Ammonium Sulfate Amines Alcohol Sodium Chlorate Sodium Vanadate Propane The VPL product is stored in the SX building 4.3.1 Electrical All electrical switches are located outside in the MCC room north of the SX building The main control panel for all of the equipment is located in the Central Control Room in the main Mill building 4.3.2 Fire Protection System The SX building fire protection systems include P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WifiTE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 wet AFFF foam sprinkler system with heat actuated sprinkler heads that release at 212F portable dry chemical extinguishers strategically located throughout the building For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic included as Figure in this Plan 4.4 Mill Building The mill building approximately 22000 square feet contains process equipment related to grind leach counter current decantation precipitation drying and packaging of uranium and vanadium products Chemicals which may be encountered in the mill building include Caustic Soda Anhydrous Ammonia Sulthric Acid Soda Ash Ammonium Sulfate Sodium Chlorate Sodium Vanadate Propane The finished products which are contained in the mill building include AMV V205 and U3O8 or yellowcake 4.4.1 Electrical The main electrical switch gear is located west of the SAG mill on the ground floor in the north west comer of the mill building Circuit control panels are located in the SAG mill control room the central control room the vanadium roaster control room and the AMV area 4.4.2 Fire Protection System The main mill building fire protection systems include portable dry chemical extinguishers strategically located throughout the building water hoses throughout the building For fire hydrant and hose cabinet locations in the Mill building refer to the Fire System Schematic included as Figure of this Plan 4.5 Maintenance Shop/Warehouse/Change Room Building This building approximately 20000 square feet contains the main maintenance shop area located on the north end of the building the main warehouse located on the south end of the building and the personnel change rooms and lunch/training room located on the extreme south end of the building on the ground and second floors Within the maintenance shop area are the following work area and specialty shops P\AdminMaster 5OPsBook 16_Emergency Response PIan\.Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 the main maintenance shop area contains welding and cutting equipment lathes presses and drill presses carpenter shop which contains various saws and planes Fiberglass work is also done within this shop area and it is located at the northwest end of the maintenance shop area an electrical shop which is located south of the carpenter shop heavy equipment maintenance shop area is located at the north end of the maintenance shop in the center of the building rubber room for rubber lining of equipment is located east of the equipment shop area the maintenance shop office instrument shop and tool room are located at the south end of the maintenance shop area The warehouse area contains primarily dry good storage for repair parts and consumables for the operation of the Mill There is an electrical water heater for the change room which is located in the warehouse area at the south end Within the warehouse and maintenance shops there are some oils and chemicals stored in the following locations small quantities of flammable material such as starting fluid and spray paint are kept in the warehouse drums of new oil and anti-freeze are stored along the east wall of the equipment maintenance area and on the east side of the warehouse on oil storage racks used oil is stored in tank located northeast of the equipment shop The tank has capacity of approximately 5800 gallons in the main maintenance shop area and the rubber room there are flammable storage cabinets and east of the warehouse there is trailer which is used to store flammable items such as rubber cements paints and fiberglass resins compressed gas cylinder storage both empty and flill is located outside east of the maintenance shop 4.5.1 Electrical The main electrical circuit breaker for the maintenance shop and warehouse building is located on the east wall inside the Maintenance shop Auxiliary electrical panels for the change room and warehouse are located in the southwest corner of the warehouse area 4.5.2 Fire Protection System The fire protection system within the maintenance shop/warehouse/change room building includes wet automatic sprinkler system that releases at 212 portable dry chemical extinguishers strategically located throughout the maintenance area warehouse area and the change room and lunch room For fire hydrant and hose cabinet locations refer to the Fire System Schematic Figure 4.6 Reagent and Fuel Storage The following lists the reagents and fuel stored at the Mill site PAAdmin\Master SOPs\Book 6_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No Rd Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 sulfuric acid tank located northwest of the mill building which has capacity of approximately 1.4 million gallons storage tank for propane is located on the north edge of the mill site northwest of the mill building It has storage capacity of 30000 gallons four sodium chlorate tanks located east of SX building north of the office building and east of the pulp storage tanks The two tanks east of the SX building are for sodium chlorate storage and the other two tanks are for dilution of the sodium chlorate two anhydrous ammonia tanks located east of the SX building with capacity of 31409 gallons each three kerosene tanks located east of the SX building with capacity of 10152 gallons each one caustic soda tank north of the SX building with capacity of 19904 gallons three soda ash tanks which are located east of the SX building One tank is the dry soda ash tank with capacity of 70256 gallons Two of the tanks are soda ash dilution tanks with capacities of 16921 gallons each diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore pad The gasoline storage capacity is 3200 gallons while diesel storage capacity is 8000 gallons Other reagents are stored in steel barrels or super sacs in reagent yard located east of the office building Typical reagents which are stored in this yard include polymers and flocculants boiler feed water chemicals methanol tributyl phosphate dirty soda ash and ammonium sulfate SX amines and emulsion breakers decyl alcohol minimal amounts of acid in barrels used oil in drums and overpacks 4.7 Boiler Facilities The main building approximately 12400 square feet is located on the west side of the Mill site and contains air compressors and water treatment facilities To the north of the main building is building which houses propane-fired boiler The vanadium oxidation tank oxidation thickener and pH adjustment tank are located south of the boiler house facilities 4.7.1 Electrical The main electrical panel for the boiler house is located outside of the building on the south wall 4.7.2 Fire Protection System The fire protection system for the boiler facilities is comprised of strategically located portable dry chemical extinguishers PtAdmin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 0929 05 doe iNTERNATIONAL URANIUM USA CORPORATION Rev No R-I Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page of 13 4.8 Sample Plant The sample plant building approximately 8000 square feet is located on the ore pad east of the maintenance shop/warehouse building The sampling plant equipment has been removed from the building and it is currently used as storage area for maintenance 4.8.1 Electrical The electrical panel for this building is located on the east wall upstairs 4.8.2 Fire Protection System There are no extinguishers or sprinlder systems in the sample plant ORGANIZATION AND RESPONSIBILITIES The organizational chart for an emergency situation is illustrated in Figure 5.1 Mill Manager/Incident Commander The Incident Commander has the responsibility for preparing an Emergency Plan communicating the Plan directing activities during emergencies and reporting to local State and Federal authorities The Incident Commander will stop routine radio usage upon learning of an emergency and set up the base station in safe location for directing activities Radio usage will be limited to the emergency The Incident Commander has the responsibility to contact all outside services The Incident Commander has the responsibility to account for all employees at the Mill using the assistance of supervisors and/or any International Uranium USA Corporation IUSA personnel The Incident Commander has the responsibility for the news media and reports directly to the President of IUSA 5.2 Mill General Superintendent The Mill General Superintendent has the responsibility of directing outside emergency personnel and has the responsibility for plant security and will report directly to the Incident Commander The Mill General Superintendent will act as Incident Commander in the absence of the Mill Manager 5.3 Radiation Safety Officer/Fire Chief The Radiation Safety Officer will direct rescue operations and provide the necessary emergency medical personnel and facilities to cope with the emergency Adequately trained fire crews and operable emergency equipment will be maintained at all times P\Admin\Master SOPs\Book 16 Emergency Response Plan\Emergency Response Plan Rev 09.29.O5.doc INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MThL EMERGENCY RESPONSE PLAN Page of 13 As Fire Chief the Radiation Safety Officer has the responsibility to maintain trained fire crews and operable equipment mobilize and direct the fire crews and equipment in fire emergency or one containing the threat of fire and to assist in evacuation and rescue or recovery operations In the absence of the Radiation Safety Officer the Mill Safety Coordinator will assume these duties 5.4 Maintenance Supervisor The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with the emergency including isolation of utilities and providing technical advice as needed The Maintenance Supervisor will be assisted by the Mill Safety Coordinator 5.5 Laboratory Supervisor The Laboratory Supervisor has the responsibility to direct and account for all office personnel including IUSA personnel and office visitors in evacuation and in activities to cope with the emergency In case of mill tour the Supervisor accompanying the tour will be responsible for evacuation of visitors 5.6 Shift Foremen Shift Foremen are in charge until the Incident Commander arrives and are responsible for all functions listed above Shift Foremen have the responsibility to account for all of their people in addition to any visitors contractors etc in their areas and report to the Incident Commander or in the absence of the Incident Commander to administer all of the above duties 5.7 Scale House Personnel Scale house person on shift will be responsible to account for ore truck drivers and reagent truck drivers 5.8 Emergency Response Teams The response crew for each operating shift will normally consist of the following operators under the direction of the shift foreman This organization may be changed for individual shifts subject to the approval of the Fire Chief 5.8.1 Operational Mode Leach Operator CCD Operator Solvent Extraction Operator Mill Trainee 5.8.2 Non-Operational Mode Shift Foreman Operations Personnel Maintenance Personnel P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc INTERNATIONAL URANIUM USA CORPORATION Rev No RI Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 10 of 13 Figure Emergency Response Organizational Structure Incident Commander Mill Manager Director of Security Operations Superintendent Fire Chief Radiation Safety Officer Shift Foremen Emerpency Response Teams Lab Supervisor Operational Mode Non-Operational Mode Leach Operator CCD Operator Shift Foreman Operations Personnel SX Operator Mill Trainee Maintenance Personnel SPECIFIC EMERGENCIES The following details procedures to be followed during specific emergencies but are not limited to the following 6.1 Fire Should fire occur the procedure outlined in Appendix for reporting and responding to fires will be followed Particular areas of concern include Solvent Extraction Building Propane Tanks Lab or Lab Storage Area 6.2 Chemical or Gas Release The procedures for response to chemical or gas release are outlined as Appendix 6.3 Earthquake Although this is highly unlikely an earthquake could occur at the Mill severe earthquake could cause buildings and other structures to collapse chemical and/or gas releases major fires as well as general panic In the event of major earthquake the evacuation procedures outlined in Appendix will be followed P\Admin\Master 5OPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc 10 INTERNATIONAL URANIUM USA CORPORATION Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 11 of 13 6.4 Terrorist/Bomb Threat In the event that any person should receive threat of bomb the following evacuation procedure should be followed Notify any person of authority i.e Superintendent Foreman Radiation Safety Officer who will immediately notify law enforcement authorities and evacuate the threatened area Evacuate all persons from the affected area and stop all radio transmissions 6.5 Tailings Dam Break and Major Floods Flood water breaching tailings embankments presents one of the greatest dangers for the sudden release of tailings solids and impounded water The tailings cells are designed with sufficient freeboard three feet to withstand back-to-back 100-year storm events or 40%of the probable maximum flood PMF followed by the 100-year storm event The flood design is equivalent to 15 inches of rainfall In addition the tailings dikes were designed in accordance with U.S NRC regulations and allow sufficient margin of safety even in the event of an earthquake The possibility of floods resulting from Westwater Creek Cottonwood Creek and Corral Creek causing dam failure is extremely remote The tailings cells and dikes are inspected on both daily and shift basis Discharges from dike failure would extend three miles before leaving IUSAs property In the event of dam failure large operating equipment will be mobilized to construct temporary earthen dikes or berms downgradient to the failed dike In addition the State of Utah Department of Radiation Control Executive Secretary the Executive Secretary MSHA and State of Utah Department of Natural Resources Division of Dam Safety shall be notified In the event of seismic rupture of tailings slurry pipelines the released slurry will be contained in the tailings cells regardless of the quantity released EVACUATION PROCEDURE See Appendix 7.1 Notification Employees will be notified to evacuate the area by dialing 184 on any area telephone and announcing that the Mill should be evacuated This announcement will be repeated twice When the paging system cycles through the evacuation siren continuous frequency will automatically sound for approximately forty-five seconds and then automatically shut off allowing communications by radio from that point If the 184 number is dialed accidentally the evacuation alarm may be canceled by disconnecting the phone until the page cycle ends then re dial 184 See Exhibits and 7.2 Assembly When the evacuation alarm sounds or when personnel are verbally notified by radio or other means all personnel will assemble at The parking lot south of the office P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 11 INTERNATIONAL URANIUM USA CORPORATION Rev No R-l Date Sept 29 2005 WIIITE MESA MILL EMERGENCY RESPONSE PLAN Page 12 of 13 The scalehouse North side of Tailings Cell or North of the Mill Assembly site will depend upon conditions i.e nature of the emergency wind conditions etc The Fire Chief or Shift Foreman will specify the appropriate assembly site 7.3 Specific Procedure for Operations Personnel See specific emergency shutdown procedure for Operations by area under the relevant Operating Procedure for your area All employees not mentioned under Operating Procedures are to immediately report to the assembly area and congregate by crew so that all persons can be accounted for As employees leave their work areas they must pass the word to evacuate to any persons who may not be aware of the emergency After the Mill has been detennined to be safe for re-entry employees will be verbally notified to return to their work stations OIl-Site Emergency Equipment/Personnel Release Any emergency response equipment or personnel that enter the Restricted Area in response to an incident will be scanned and decontaminated prior to leaving the site according to the procedures included in PBL-9 End Dump Trailer Acceptance Handling and Release Any equipment will be decontaminated according to the requirements found in Table of the Nuclear Regulatory Commissions NRCs Policy and Guidance Directive FC-85-23 Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Temiination of Licenses for Byproduct Source or Special Nuclear Material issued May 1987 Injured personnel should be evaluated for radiation contamination if there was potential for contamination at the earliest convenience Should it be necessary contaminated articles will be gathered by the radiological staff after medical treatment has been rendered If the personnel cannot be decontaminated notify the clinic/hospital personnel in advance EMERGENCY EQUIPMENT Emergency equipment for the Mill is provided as follows 9.1 Fire Hose Fire hose cabinets are located at the following sites with minimum of 300 feet of 2-1/2 hose two spanner wrenches spray nozzles and one hydrant wrench South of SX West of CCD North of Mill Building East of pulp storage tanks Northwest of Maintenance Shop West of Warehouse P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 12 UINtERATIONAL URANIUM USA CORPORATiON Rev No R-1 Date Sept 29 2005 WHITE MESA MILL EMERGENCY RESPONSE PLAN Page 13 of 13 East of office building 9.2 Self Contained Breathing Apparatus Two Self-Contained Breathing Apparatus are located at each of the following locations Hose station east of office building Hose Station South of SX North End SX Outside Wall North end of Mill building outside wall 9.3 Spill Clean-up Equipment Barrels of soda ash are located throughout the Mill to be used in case of chemical spill Soda ash is also stored in bulk if needed There are also few drums of absorbent stored near the laboratory The laboratory also contains acid spill kits and absorbent materials to be used in case of spill 9.4 Fire Fighting PPE Two complete sets of turnout gear for fire fighting and/or emergency extrication are located in the Fire Hose Station located on the east side of the office building 9.5 Maintenance of Emergency Equipment Fire extinguishers are inspected on an annual basis as well as the fire pump system The Mill Safety Coordinator performs regular spot checks on the emergency equipment locations to ensure that all of the equipment is in place 10 EMERGENCY TRANSPORTATION One fully-equipped First Responder Unit Ambulance located west of the office building Other motor pool vehicles on the property will be utilized as needed in emergency situations with support as needed from the local Emergency Medical Services 11 EMERGENCY DRILLS AND TRAINING Quarterly drills as required by MSHA are prepared by the Safety and Radiation Departments to monitor performance of personnel responding to emergency situations Each drill will be enacted upon one or more of the potential scenarios by this plan The drill and evacuation activities are documented by the Mills Safety Coordinator and maintained within plant files Management will review all drills at quarterly ALARA Committee Meetings P\Admin\Master SOPsBook 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc 13 EXHIBIT EMERGENCY NOTIFICATION LIST ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR Give artificial respiration if necessary Control bleeding Treat for shock Immobilize fractures and stabilize for transportation Scan the injured for excessive alpha prior to transporting if time allows If alpha is excessive or there is no time to scan notify the clinic/hospital personnel and the Radiation Safety Office THE SUPERVISOR OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING AS NEEDED Blanding Clinic 678-2254 or 678-3434 930 400 San Juan Hospital Monticello ...678-2830 or 587-2116 364 1st EMT and CPR TRAINED The following personnel should be contacted if they are on-site in the event of an emergency to aid in the event of any injuries to personnel David Turk EMT and CPR trained Mike Spillman CPR trained AMBULANCE SERVICE Blanding Dial 911 If the Company Ambulance is used an attendant must ride with the injured in addition to the driver except where the injured could normally be transported in car or pickup OTHER EMERGENCY NUMBERS Fire Department Dial 911 or 678-2313 County Sheriff Dial 911 or 587-2237 Highway Patrol Dial 911 or 587-2000 Blanding Police Dial 911 678-2916 or 678-2334 MANAGERS The Supervisor will notify one of the following of all incidents R.E Bartlett 435-678-2495 Turk 435-678-7802 or 435-459-1068 Spillman 435-678-2761 MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING AGENCIES AS REQUIRED FOR EACH INCIDENT State of Utah Department of Radiation Control 801-536-4250 MSHA Field Off.--801-524-3450 Dist Off 303-231-5465 MSHA Arlington 800-746-1553 State Emergency Response Comm 801-538-3400 State of Utah Natural Resources Dam Safety 801-538-7200 National Response Center 800-424-8802 Utah Poison Control Center 800-456-7707 Notification of surrounding communities and or residences will be handled by the appropriate agencies as required by EPCRA Emergency Planning and Community Right to Know Act Revision Date Januaiy 16 2006 Ed EXHIBIT INTERNAL NOTIFICATIONS Internal reporting requirements for Incidents Spills and Significant Events are as follows Report Immediately Event Criteria Release of toxic or hazardous substances Fire explosions or other accidents Government investigations information requests or enforcement actions Private actions or claims corporations or employees Deviations from Corporate policies or government requirements by Management Other significant events which have resulted or could result in Death serious injury or adverse health effect employees or public Property damage exceeding $1000000 Government investigation or enforcement action limiting operation or penalties of $100000 or more Significant criminal actions Substantial media coverage Unscheduled down time of more than 24 hours Report at the Beginning of the Next Business Day Incident Criteria Was reported to government agency as required by law Worker IIJSA or contractor recordable injury or illness associated with release Community impact reported or awareness Publicity resulted or is anticipated Release of process material waste or product in excess of the Reportable Quantities listed in Section 1.5 of the Spill Prevention Control and Countermeasures Plan The local manager in charge is to call Ron Hochstein or Dave Frydenlund Name Title Office Phone Home Phone Ron Hochstein President and COO 303-628-7798 office 604-931-6334 home 604-377-1167 cell David Frydenlund V.P and General Counsel 303-389-4130 office 303-221-0098 home 303-808-6648 cell Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 002.14.07 E-2 EXHIBIT SITE LAYOUT MAP P\Admin\MaSleT SOPS\BOOk 16 Emergency Response Plan\EmergencY Response Plan Rev 09.29.05.doC E-3 WI Mt Øt f l i II to to t- EXHIBIT MAIN SHUT-OFF VALVES During an emergency this list should be used along with Site Layout Map Exhibit to locate tanks and valves associated with these tanks REAGENT SHUT-OFF VALVE LOCATIONS Sulfuric Acid Main located south side of acid tank East acid pump discharge valve West acid pump discharge valve Main leach area located 25 feet west of Derrick screens next to walkway 1/2 Main SX area located south of Central Control room Ammonia Main east tank located on end at bottom Main west tank located on end at bottom Valve located on top of tank east tank Valve located on top of tank west tank Kerosene Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Pump discharge valve Soda Ash Main valve located at bottom of tank dry storage Main valve located at bottom of tank on 30%dilution tank Main valve locate at bottom of tank on dilution tank Salt Main valve located at bottom of tank Caustic Soda Main valve located at bottom of tank east and west between supports P\Admin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.054oc E-4 EXHIBIT MAIN SHUT-OFF VALVES Sodium Chlorate Main valve located at bottom of tank east tank Main valve located at bottom of tank north tank Main valve located at bottom of tank south tank Propane Main located 15 feet east of tank Main located on pipe off top of tank Main located at bottom of tank also fill pipe PLANT UTILITY SHUT-OFF VALVE LOCATIONS Process Water Main valve located on west side of water storage tank Discharge valve off service water pump east Discharge valve off service water pump west Mill process water main located east wall by SAG mill Fire Water Main valve located west side of water storage tank Emergency fire pump discharge valve to fire system Emergency fire pump discharge valve to header west side of pump house Main valve located south of Central Control room for SX and boilers Potable Water Main suction from potable water storage tank Main discharge from potable water storage tank Main located at east wall by SAG mill Main located south of Central Control room for SX Maintenance shop and offices Steam Main discharge valve for Superior boiler located at top of boiler Main steam valve located south side of boiler house PAdmin\Master SOPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 EXHIBIT MAIN SHUT-OFF VALVES Plant Air Main valve located at receiver tank in compressor room at boiler house Main valve to mill building located south of Central Control room PROCESS SHUT-OFF VALVE LOCATIONS Pulp Storage No valve located on west side of tank No valve located on west side of tank Preleach old No pulp storage valve located on west side of tank Preleach Thickener Main valve located underneath at center cone Clarifier Main valve located underneath at center cone Main valve located underneath at center cone CCD Thickeners Main valve located underneath at center cone of each thickener P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc E-4 APPENDIX EMERGENCY PROCEDURE RESPONSE TO FIRE The fire will be reported by dialing 185 on any telephone in the area and announcing the location of the fire over the paging system This announcement will be repeated twice for total of three announcements When the paging system cycles through the fire siren alternating frequency will automatically sound for approximately forty-five seconds then automatically shut off allowing radio communications to resume Mobilize the fire crew Evacuate all personnel Rescue any victims of the fire do this only with properly trained and equipped personnel Isolate utility lines affected by the fire Extinguish the fire and post fire watch for flare-ups Report the fire to proper local State Corporate and Federal agencies In cases where the fire is not extinguished within thirty minutes of discovery the area must be barricaded off after extinguishing and left undisturbed until released by MSHA and IUSA management Emergency off-site centers Blanding Fire House and Sheriffs office Blanding Fire 350 West 200 South Blanding Phone number is 911 Sheriffs Office 50 West 100 South Blanding Phone number is 911 or 435 587-2237 P\Admin\Master SOPs\Book 16_Emergency Response PIan\Emergency Response Plan Rev 09.29.05.doc A-I FIGURE FIRE SYSTEM SCHEMATIC DRAWING P\Admin\Master SOPs\Book 16_Emergency Response PlankEmergency Response Plan Rev 09.29.05.doc A-i 4c s l L .n n o 4t I . L St i G 1 I f l t 1o Lr I vf l s o w pt n r fl o APPENDIX EMERGENCY PROCEDURE RESPONSE TO CHEMICAL OR GAS RELEASE chemical or gas release would most likely occur very suddenly The person who would first witness chemical or gas release should immediately contact his supervisor who would initiate the procedures outlined below Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped by the release Provide first aid and emergency medical care for any ill or injured persons Initiate necessary steps to contain and/or neutralize the release such as spraying with water fog turning off valves etc Guard against possible fires by shutting off electrical circuits isolating gas lines and aInnotnn cnflrnat -crn.n h0 .cr04 .tSL1ASSatIJ15 151JJflJIS OJt41a..O Sit/ALL I11 LtLZ L/tL w.a P\Admin\Master 5OPs\Book 16_Emergency Response Plan\Emergency Response Plan Rev 09.29.05.doc A-I APPENDIX EMERGENCY EVACUATION PROCEDURE Activate evacuation alarm by using the dial 184 notification system Evacuate and account for all personnel Personnel are to assemble in one of the following areas The parking lot south of the office building The scalehouse The north side of Tailings Cell or North of the Mill Mobilize trained personnel and emergency equipment such as SCBAs first aid equipment etc Initiate rescue operations for any people who may be trapped Provide first aid and emergency medical care for any ill or injured persons Guard against possible fires by shutting off electrical circuits isolating gas lines and eliminating ignition sources from the affected area P\Admin\Master 5OPs\Book 16_Emergency Response Plan\.Emergency Response Plan Rev 09.29.05doc A-i