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HomeMy WebLinkAboutDRC-2010-005482 - 0901a068801cb8a0State ofUtah GARY R. HERBERT Govemor GREG BELL Lieutenanl Governor Department of Environmental Quality Amanda Sniith Execulive Direcior DIVISION OF RADIATION CONTROL Rust Lundberg Director DRC-2010-005482 September 29, 2010 David Frydenlund, Vice President Regulatory Affairs and Counsel ' Denison Mines (USA) Corp. 1050 17'*'Street, Suite 950 Denver, Colorado 80265 RE: Radioactive Material License (RML) Number UTI 900479: Health Physics Inspection RADMOD-RWP-02 Dear Mr. Frydenlund: On September 21, 2010, an inspection was conducted at your facility by Ryan Johnson, a- representative of the Division of Radiation Control of the Utah Department of Environmental Quality. Observations from the inspection were discussed with Rich Bartlet and Ronnie Nieves at the closeout meeting. The inspection was an examination of the activities conducted in your , facility as they relate to compliance with the Utah Radiation Control Rules, the conditions ofthe Mills RML and Federal Regulations. The inspection consisted of an examination of representative records, interviews of personnel, and observations by the inspector. During the closeout meeting the DRC inspector made recommendations regarding items for improvement. These recommendations can be found at the end of the inspection report under recommendations. Enclosed is the inspection report regarding this inspection for your review. The DRC would like to thank the Mill staff for their cooperation regarding this inspection. If you have any questions conceming this letter contact Mr. Ryan Johnson (801) 536-4250. UTAH RADIATION CONTROL BOARD Rusty Lundberg, Executive Secretary RL/RJ:r) Cc; David Turk, Site Radiation Officer Enclosures 195 Nonh 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114^850 Telephone (801)536-4250 • Fax (801-533-4097 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper INSPECTION REPORT Inspection Module: RADMOD-RWP-02: Radiation Work Permits, Personal Protection Equipment and Daily, Weekly and Monthly Inspections Inspection Location: Denison Mines- White Mesa Uranium Mill, Blanding Utah. Inspection Items: Radiation Work Permits, Personnel Protection Equipment and Daily, Weekly and Monthly Inspections Inspection Dates: September 21, 2010 Inspectors: Ryan Johnson, Utah Division of Radiation Control (DRC) Personnel Contacted: Dave Turk (Radiation Safety Officer (RSO)) Ronnie Nieves (Radiation Coordinator) Ryan Palmer (Environmental Technician) Goveming Documents: • UACR313-15 • NRC Regulatory Guide 8.31 • Radioactive Materials License (RML) UTI900479 RML UTI 900479 License Renewal Application (2/28/07) Opening Meetine Denison Mines: Dave Turk (RSO) Ronnie Nieves (Radiation Coordinator) Ryan Palmer (Environmental Technician) Utah DRC: Ryan Johnson (DRC Inspector) During the opening meeting, the inspector discussed the items ofthe inspection. These items included the documentation to be reviewed and the specific areas of the Mill that the inspector wanted to see during the inspection. Inspection Items: • Radiation Work Permits (RWPs) • Personal Protection Equipment (PPE) • Daily Inspections • Weekly Inspections • Monthly Reports • Follow-up Items o 1 le(2) disposal o Intermodal Release Surveys o Personnel Exit Surveys , 1 ofPage 4 U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMilI\HP Inspection modules\201 OMnspection ReportsMnspection ReportRADMOD-RWP-02 9-2i-10RJl.doc Item 1. RWPs: The inspector reviewed RWPs from the last two years, specifically looking at the information that is required by the Mills Radiation Protection Manual (Work to be done, Location of the work, Duration of the work, Personnel doing the work, PPE requirements, Monitoring requirements and the RSO signature). The inspector observed that the RWPs were filled out by members of the Radiation Safety staff and the Occupational Safety staff. The inspector also observed that most RWPs had supporting documentation attached to them (Safe Work Permits, Confined Space Permits and Bioassay Results). Also in the Mills Radiation Protection Manual RWPs are required for the receipt, handling and processing of any altemate feed material unless there is a Standard Operating Procedure (SOP) for it. Currently the Mill is processing UF4 altemate feed material and it has its own SOP. The inspector reviewed the UF4 SOP to verify that it covered the radiation safety concems for UF4 material. The inspector discussed with the Radiation Coordinator whether the radiation safety staff has sufficient time to prepare RWPs and how the radiation safety staff verifies that the RWPs are being followed. During this discussion the Radiation Coordinator indicated that the staff has sufficient time to prepare RWPs (approximately 20 minutes) and that the Radiation Safety staff verifies that RWPs are being followed during their daily inspections. There was one RWP currently approved and in progress during the inspection for removing super sacks from the alternate feed "fan steel" material so it can be processed with convendonal ore. On the day of the inspecdon no work was being done in association with that RWP and the inspector was not able to observe work being done and verify that the RWP is being followed. Deficiencies: TTie inspector observed that the estimated exposure line was not being properly filled out. Mill staff members were inconsistent on how to document this information. Some staff members were putting the calculated approximate dose, others were putting the different routes of entry and some were leaving it blank. The inspector spoke with RSO about these observations and the RSO said that a new Radiation Technician Training manual is waiting to be approved by the corporate office and these inconsistencies are addressed in that. Item 2. PPE: The inspector discussed with the RSO the PPE requirements for all of the different departments within the Mill. During the Mill tour the inspector observed that Mill employees were wearing the appropriate PPE for each department that they work in. The inspector discussed with the Radiation Coordinator: • How Mill employees receive information on what PPE they are required to use; • How Mill employees replace worn-out PPE; • How the Mill verifies employees are using the PPE that they are supposed to use; and • Where PPE is stored at the Mill. The inspector observed Decon personnel not wearing face shields while decontaminating an intermodal container. When the inspector brought up this concem, the RSO said that face shields are not required. Deficiencies: The inspector verified that face shields are not listed as required PPE for washing intermodals. However, the inspector deems the use of face shields is a practice that should be 2 ofPage 4 U:\rad\COMMON\Uraniuni millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP hispection modules\201 OMnspection ReportsMnspection ReportRADMOD-RWP-02 9-21-10RJl.doc \ \ considered as part of the ALARA philosophy for personnel working at the Decon Pad. Item 3. Daily Inspections: The inspector reviewed the Daily Inspection Reports for the past year. The inspector observed that daily inspections were being done and that the Daily Inspection Sheet was divided into different areas of the Mill for the Mill staff inspect. Deficiencies: Based on the above paper review, the inspector could not determine if the radiation safety staff was verifying that RWPs were being followed because the daily inspection report does not document that Mill employees assigned to that work were following the RWP. Item 4. Weekly Inspections: The inspector reviewed the Weekly Inspection Reports for the past year. The inspector observed that safety and radiological safety concems (i.e. yellowcake spills) were being identified and that different Mill department managers were being contacted to get ., them corrected. Deficiencies: The inspector observed that things were being identified that needed to be taken care of but there was no documentation if those identified items were being corrected. Item 5. Monthly Reports: The inspector reviewed the monthly reports from the last year. Specifically, the inspector looked for the information that is required by the Mills Radiation Protection Manual; • A summary of recent personnel exposure data, including bioassay and time -weighted calculafions; • A summary of all pertinent radiation survey records; • A discussion of any trends or deviafions from the radiation protection and ALARA programs, including and evaluafion of the adequacy of the implementafion of license condifions regarding radiafion protection and ALARA; and • A description of umesolved problems and the proposed corrective measures. Deficiencies: None Item 6. Follow-up Items: The following were items that the inspector was following-up on from previous inspecfions: • 11 e(2) disposal: The inspector observed 11 e(2) material being disposed of in Cell #3. This material was not placed in a slit trench because it was a soil not debris. • Intermodal Release Surveys: The inspector observed an unrestricted survey on an intermodal container. The inspector performed a verification survey on the same intermodal container. Both the Radiation Technician and inspector did not find any contaminafion levels above Department of Transportation limits. • Personnel Exit Surveys: The inspector observed Mill employees surveying themselves as they exit the restricted area. The Mill employees that were observed were surveying themselves appropriately. Deficiencies: None 3 ofPage 4 U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMillMIP hispection modules\2010\hispection ReportsVhispection ReportRADMOD-RWP-02 9-21-10RJl.doc Closeout Meeting Denison Mines: Utah DRC: Findings None Rich Bartlet (Mill Manager) Ronnie Nieves (Radiafion Coordinator) Ryan Johnson (Inspector) Recommendations During the close out meeting the DRC inspector made the following recommendations regarding items for improvement: 1. Train the radiafion safety staff and the occupational safety staff on the appropriate way to fill out the RWP form specifically the estimated exposure line. 2. Add face shields to the required PPE for personnel decontaminating tmcks, intermodals and equipment. 3. Add a RWP section to the Daily Inspection Report to document that acfive RWPs are being adhered to. 4. Document with the Weekly Inspecfion Report when non-compliance and safety items identified during weekly inspections have been corrected. Recommendation for Next Inspection 1. Observe ISL material being placed in slit trenches on Tailing Cell #3 2. Employee Exit Monitoring 3. Continue to do verification surveys on intermodals and ore tmcks 4. Spills (yellowcake and other materials) being cleaned up in the mill immediately Prepared By: Ryan Johnson (Print Name) x 9/29/10 (Date) 4 of Page 4 U:Vad\COMMON\Uranium millsM le(2)UT1900479 Denison Mines - White Mesa UMimHP hispection modules\201 OMnspection ReportsMnspection ReportRADMOD-RWP-02 9-21-10RJl.doc I UTAMIVISION OF RADIATION COWROL RADIATION PROTECTION INSPECTION MODULE RADMOD-RWP-02 RWPs/PPE DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UTI900479 References: Radioacfive Material License UTI900479, License Renewal Applicafion dated Febmary 28, 2007, Radiafion Protecfion Manual, Section 5, 10CFR20, NRC Regulatory Guide 8.30, NRC Regulatory Guide 8.31, Utah Administrative Code R313-15. RADIATION WORK PERMITS (Appendix E Section 5, 2007 License Renewal) Radiafion Protection Manual Secfion 5 Radiation Work Permits (RWPs) (Appendix E license renewal) 1) According to the Radiafion Protection Manual RWPs are required to contain the following informafion and copies ofthe RWPs are kept on file for five years. Review five (5) RWPs from the past 2 years (starting from the present year). Verify (Yes or No) that the forms contain all of the informafion that is required. Date RWP Number Work to be Done Location of Work Duration of Work Personnel Woridng PPE Required Monitoring Required RSO Signature ^> % % s /:.^f Y^. s •/•/ ^ Yi% 1~lo IL Ye-. 2) Were all of the RWPs that were reviewed complete? Comments: Yes No >£1 3) Was supporting documentation (i.e. Safe Work Permits and Confined Space Permits) attached to the RWPs? Comments: y ^ .i ^ y Yes No><r^ ^.^/iZ..^' r>/n U:\rad\COMMON\Uranium milisM le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\2010\hispection Modules\RADMOD-RWP-02.doc n^if RWPs lined out or marked with an 4) Were non-applicable items on^c RWPs lined out or marked with an Yes VcT No_ Comments: 7 ^ x 5) Does the RWP form adequately cover all of the informafion required? Yes No Comments: ; ^ /•'•'-. • 6) On average, how much fime does the RSO and Radiation Safety staff has to review requests for RWPs before they approve them? Comments: 7) How does the RSO/Radiation Safety staff verify the RWPs are being followed? Comments: • ^ ^ .jf // iy^^'<^ ^^^^ />5t--.?-s /e- /pc^i--^ j.^ I i V^Y/(^^ —, 8) Section 5.1 of the Mills Radiafion Protection manual says "The receipt, handling or processing of any altemate feed material, which has been determined by the RSO, not to within existing operafing procedure". What is the Altemate feed being processed in the Altemate feed Circuit? Comments: / ^ l A f'^^^ ' > ^^^^ "^Op /^^.-^.^ y^A <C S^P 9) If no SOP for the altemate feed is there a RWP? Yes No_ Comments: , A iMi. ^ 10) Observe the Altemate Feed Circuit are the employees following the SOP or RWP for the material they are processing? Yes No Comments: , ^-i U:\rad\COMMON\Uraniuni millsM le(2)UTI900479 Denison Mines - White Mesa UMill\HP Inspection iTiodules\201 OMnspection Modules\RADMOD-RWP-02.doc 11) Identify a RWP that is being worked under during the inspection and go to that work site and verify that the RWP is being followed. What are the details of the job? Comments: y 12) What precaufions are necessary to reduce exposure to Uranium and daughters Comments: ^ P aP YF.^ ff^M}^^ Yy/p^ ^ ^ Pl/^.^ ; 4'^ ^.y>P6 . pP< 13) What are the monitoring requirements for the RWP? Comments: . . Y-r^-^:^^ AY/CY.^^ /^r-jyiM'- 14) Are the following being done for the RWP being observed? Yes No Monitoring requirements being done? Mill personnel wearing the appropriate PPE? Other ALARA pracfices being done? Was there specialized training documented? Comments" ^— y; APPh P/P P'j^ /P.^ ... l-n .^ P-— 15) Are RWP jobs being documented on the daily and weekly inspecfions? Comments: 16) Any non-compliance issues observed? Comments: U:\rad\COMMON\Uranium millsM le(2)UTI 900479 Denison Mines - White Mesa UMill\HP hispection modules\201 OMnspection ModulesMlADMOD-RWP-02.doc 17) If yes, was it corrected and ho^Pl-as it corrected? Comments: , MP- Daily, Weekly and Monthlv Inspections 18) Review the Daily inspections for the last year. Were any non-compliance issues identified? Comments: i ^ —dPl^ X^b./n .- ^^-^^Z..,,,, C4>_ y<,C'.. .z,3: }yi,^ , PP^P 19) How was the non-compliance issue resolved? Comments: 20) Were there any re-occurrences? Comments: J /PJh- 21) Review the Weekly inspecfions for the last year. Were any non-compliance issues identified? Comments: ^ ^ 'r>^ /-u..^ 7^ .Up'Y Ai-j^.'P 4 ^^.y r P/^-^j^ '^^^P.- 22) How was the non-compliance issue resolved? Comments: / ^ ' PP 23) Were there any re-occurrences? Comments: , 7^ U:\rad\C0MM0N\Uranium millsM le(2)UTI900479 Denison Mines - While Mesa UMill\HP Inspeclion modulesVZO I OMnspection Modules\RADMOD-RWP-02.doc 24) Review the monthly Reports Mm.he following being documented? Yes No A summary ofthe recent personnel exposure data, including bioassay and time-weighted calculations A summary ofall pertinent radiation survey records A discussion ofany trends or deviations from the radiation protecfion and ALARA programs, including an evaluation of the adequacy ofthe implementafion of license conditions regarding radiation protecfion and ALARA A descripfion of unresolved problems and the proposed correcfive measures Comments: 25) Review the Monthly reports for the last year. Were any non-compliance issues identified? Comments: Aht-t 'i^P^, '!7/P^. 26) How was the non-compliance issue resolved? Comments: 27) Were there any re-occurrences? Comments: 28) Were any non-compliance issues need to be reported to the State? Comments: 29) Were all issues reported? Comments:^^^ U:\rad\COMMON\Uranium millsM I e(2)UTl 900479 Denison Mines - While Mesa UMill\HP hispection modules\201 OMnspection Modules\RADMOD-RWP-02.doc enl^( 30) Determine the PPE requirememPfor each Department/Mill Location frOTPihe RSO. Then during mill tour, Department/Location PPE Requiremen ts (check applicable) Laboratory PPE Observed Y/N Hard Hats Tyvek Disp. Gloves •^yeiP Laboratory PPE Observed Y/N Safety Glasses '^llearing Face Shields Laboratory PPE Observed Y/N Safety Boots !/ ^Respirators y "^Rubber Suits Laboratory PPE Observed Y/N Rubber Boots Lab Coats y Other Laboratory PPE Observed Y/N Coveralls Gloves AlYi/A t7 Mill PPE Observed Y/N Hard Hats 1/ ^yvek i/ '^Disp. Gloves Mill PPE Observed Y/N Safety Glasses 'Hearing 1/ '^Face Shields Mill PPE Observed Y/N Safety Boots V ' Respirators y -Rubber Suits Mill PPE Observed Y/N Rubber Boots / Lab Coats Other Mill PPE Observed Y/N Coveralls A. ''Gloves Alternate Feed Circuit PPE Observed Y/N Hard Hats V Tyvek y 'Disp. Gloves Alternate Feed Circuit PPE Observed Y/N Safety Glasses. / Hearing y '^Face Shields y Alternate Feed Circuit PPE Observed Y/N Safety Boots iy ''Respirators "Rubber Suits Alternate Feed Circuit PPE Observed Y/N Rubber Boots i/ '^Lab Coats Other Alternate Feed Circuit PPE Observed Y/N Coveralls ^Gloves Maintenance PPE Observed Y/N Hard Hats Y Tyvek Disp. Gloves Maintenance PPE Observed Y/N Safety Glasses '^Hearing Face Shields Maintenance PPE Observed Y/N Safety Boots '^Respirators Rubber Suits Maintenance PPE Observed Y/N Rubber Boots Lab Coats Other Maintenance PPE Observed Y/N Coveralls Gloves Office PPE Observed Y/N Hard Hats Tyvek Disp. Gloves Office PPE Observed Y/N Safety Glasses y 'Hearing Face Shields Office PPE Observed Y/N Safety Boots '^Respirators Rubber Suits Office PPE Observed Y/N Rubber Boots Lab Coats Other Office PPE Observed Y/N Coveralls Gloves Ore Receiving PPE Observed Y/N Hard Hats U '^yvek Disp. Gloves Ore Receiving PPE Observed Y/N Safety Glasses ^Hearing Face Shields Ore Receiving PPE Observed Y/N Safety Boots >/ "Respirators Rubber Suits Ore Receiving PPE Observed Y/N Rubber Boots Lab Coats Other Ore Receiving PPE Observed Y/N Coveralls Gloves Warehouse PPE Observed Y/N Hard Hats y '^yvek Disp. Gloves Warehouse PPE Observed Y/N Safety Glasses •Rearing Face Shields Warehouse PPE Observed Y/N Safety Boots y 'iRespirators Rubber Suits Warehouse PPE Observed Y/N Rubber Boots Lab Coats Other Warehouse PPE Observed Y/N Coveralls Gloves Utility Crew PPE Observed Y/N Hard Hats y Ifyvek Disp. Gloves Utility Crew PPE Observed Y/N Safety Glasses 'Tjearing Face Shields Utility Crew PPE Observed Y/N Safety Boots y Respirators Rubber Suits-* Utility Crew PPE Observed Y/N Rubber Boots Lab Coats Other Utility Crew PPE Observed Y/N Coveralls ^Gloves Decon Crew PPE Observed Y/N Hard Hats Y Jyvek Disp. Gloves Decon Crew PPE Observed Y/N Safety Glasses y llearing Face Shields Decon Crew PPE Observed Y/N Safety Boots y "^Respirators Rubber Suits Decon Crew PPE Observed Y/N Rubber Boots Lab Coats Other Decon Crew PPE Observed Y/N Coveralls Gloves U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMil|\HP Inspeclion modules\201 OMnspection Modules\RADMOD-RWP-02.doc PERSONAL PROTECTIVE E^PMENT (PPE) 31) Were there any areas in the mill that were observed that did not have an appropriate type or amount of PPE required? Yes j><^ No Comments P^y, :-^..y^ JJ ,y^.'jf P.yt^J^jAOL 5-;^-v/^ .^..P P -^^X^^ " y ^ Y,, y^ 7^ : > y. y .y " / Ps r^f^f Pr-^y7j. f^._:r^ \ /..-^ y'^yiP 32) Where do the mill personnel find out what PPE requirements there are for the department or area that they are working in? Comments ^^ . ' ./ , , 33) How does the Mill verify that the mill personnel are wearing their PPE? Comments: / 34) How is PPE stored and distributed to employee? Comments: ^ / / <' / A / yP-^^P c-yyx^'P-A- I- yPcPJ iy(y^y^/i^.<^y^^.^y 35) When PPE needs to be replaced what is the Mills policy? Comments: / FOLLOWUP ITEMS 36) Do a verification Survey on any Intermodal Containers that may be onsite Comments: , ^ p^ U:\rad\C0MM0N\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\2010\hispeclion Modules\RADMOD-RWP-02.doc Dor,o 7 of 0 37) Observe 1 le(2) material bein^Rposed of in the tailing cells Comments: PPP.'^'y:> ^•/j'^,..<;. JS^^P P ^ Xi^^ fe? ysP yyP^ P..-'^*^ PP^l j'y[ :^',^^P -7&,,fi' yP^L^ r .•• ^x. ^-J!--, ^ 'iT? /'T^''-^ ^ P y.rY. Ay, ^ c/ / ^^.^ " 38) Observe employees exifing the Restricted Area are the properly surveying themselves? Comments: /yJ-^y/y^ ^JhwyPiL .^c.-^/T^ 'P A'S^pcPP ^(Py, — .>,P PP /\y-ye^ -r 39) During the Mill Tour look for yellowcake and see if it is being cleanup. Comments: 7)J A/P ^ ^a/P/^.. ,/^P.>. -P /^/// y, ipJpo^s^yL yy^yT PiL U^j^y^:^P^ ^ <^ytZ^/{ U;\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP hspeclion modules\201 OMnspection Modules\RADMOD.-RWP-02.doc Dnnn e of e A. ^ ^ ,.s/yp3^ ^-^^^ RADIATION WORK PERMIT RWP# 3Pk^ Requestor -^ .-d^ R,.,.4.U-VV Job Location <?r^ fi^..,,.> Job Description Radiological Monitoring and Sampling At Start ty^ Intermitte Continuous ^L^Dust (B) Radon Daughters (C) Beta-Gamma" ((5><^ross Alpha (E) Removable Alpha Breathing Zon^_^ ____ Minutes Ran Bioassay (^^-^ No At End pCi Personnel leaving Protective Equipment Rubber Gloves Coveralls /TI., ,^VS Respirator Fit Testing Rubber boots Hoods Rubber suits Local Ventilation Name Type1/^S) Irritant Smoke Size Proper Fit Worn Fitted by (Initials) fol.\ fa^ie^ y >^ y .y , /La ALARA Considerations Estimated Job Duration: Standby Workers NA Cleanup ... \\ ,^\,^ Estimated exposure RPWI.-.. i ,.; .k.. APPROVEDBY: iJ4^il?,4L»,L ^.Tv^r^U.Li Number of Workers_ Showers Required — Time Limitations _ Date Name In Out In Out In Out In Out Total Time •rci/v ^^^^ fiyy- (iu U '<^-t b .-9.'J/7 '3'/(7 Job Status: Completed_ Permit Terminated Reviewed By Changed Date Cancelled Time Date .By '1 No.: PBL-21 • DENISON MINES (USA) CORP.^ STANDARD OPERATING PROCEDlMs Rev. No.: R-l • DENISON MINES (USA) CORP.^ STANDARD OPERATING PROCEDlMs Page 1 of Date: June 24, 2009 Title: UF4 Processing 25 STANDARD OPERATING PROCEDURES FOR UF4 PROCESSING Overview The following standard operating procedures ("SOP") are for the processing of the UF4 altemate feed material. These operating procedures are summarized by nodes with the hazards, PPE, cautionary statements and operating instructions for each node. A node is a phase of recovery in the overall process and is indicated by graphic presentation of the process flow. A block flow diagram of the overall process is set out on the following page. There are general considerations that are applicable to all process nodes. They are: • Lines and Pumps All lines, pumps and valves must be used according to specific operating instructions that will be issued as required during process evaluations and recovery. • Specific Operatmg Instructions Specific operating instmctions apply to each process node based upon the metallurgical requirements necessary for recovery of an on-specification product. These instmctions will change periodically after operating process and parameters have been determined. • Hazard Assessment Worksheet Each hazard assessment worksheet identifies hazardous parameters for each node, such as operating temperature, pressure and radioactive content of each stream. The overall hazard rating is based on quantity of chemical, phase of the chemical (gas, solid, and liquid) and the MSDS health rating for each chemical. The overall health rating is the sum of the three ratings. • Persoimel Protective Equipment ("PPE") PPE is identified on each node and is accompanied by cautionary statements of each important hazardous chemical. This information will be presented to all operations personnel, and any questions regarding this mformation will be answered. This SOP may be modified as necessary by a Radiation Work Permit ("RWP") which would establish new procedures and requirements during the processing of the UF4 altemate feed material. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP. _ STAKT)ARD OPERATING PROCEDURES Page 2 of Title: UF4 Processing 25 Block Flow Diagram of Overall Process BartBh Solids To Tailings 1 To Nomnal Yellowcake Precipitation Product Holding Tank No.:PBL-21 # DENISON MINES (USA) CORP^ STANDARD OPERATING PROCEDlWs Rev. No.: R-l # DENISON MINES (USA) CORP^ STANDARD OPERATING PROCEDlWs Page 3 of Date: June 24, 2009 Title: UF4 Processing 25 NODE #1 - UF4 DRUM DUMPING Hazard Assessment Worksheet Equipment Component UF4 Drum Dumping Node Individual Equipment No. Parameter Process Material in Component Process Flow Diagram Uranium Tetra- fluoride Sodium Carbonate Hydrogen Peroxide Quantity in Equipment (lb) 1600 8,300 250 Concentration (%) 70-90 10 50 Flashpoint, °F — — TLV-TWA mg/m' STEL mg/m' — Radioactivity, pCi/g 484,263 — Temperature, °C 25-80 25-80 Pressure, psig — ~ Health Rating 1 1 2 Hazard Rating Rad 0 Oxy Assessment Description: The UF4 material is a dry solid and can become airbome easily. Also, the UF4 material contains fluorides which can become highly corrosive if allowed to come in contact with acids. The material should be left undisturbed as much as possible once the drums are opened until the drums are loaded in the drum dumper. The UF4 material is also radioactive and you must follow established health physics controls. If any UF4 gets on your clothing or skin, wash it off with generoiis amounts of soap and water. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDUR: Title: IJF4 Piocessing ORES Page 4 of 25 Steam -i H,0 NajCOs OO NajCOj Make- up Tank Steam H,0 Submerged Drum Dumping Station Digestion / Precipitation Tank Operating Instructions The UF4 drums must be kept sealed or covered as much as possible until all process components are ready for dumping the drums. • Make sure you are familiar with the MSDS sheets for the UF4 material and the sodium carbonate, copies of which are attached to this procedure. • Make a safety inspection of all lines and equipment. o Inspect lines for leaks or seeps. o Inspect safety showers and eyewash fountains. This processing of UF4 consumes significant volumes of sodium carbonate (soda ash) solution. A batch of the sodium carbonate (soda ash) solution is made up as follows: • Add a volume ofi water to the sodium carbonate make-up tank as instructed by your supervisor. • Tura on agitation in the tank and add steam as needed to raise the water temperature as instructed by your supervisor (normally about 80°C). • Raise a supersack of soda ash into position and gradually add soda ash to the stirred water in the tank. Repeat with additional supersacks of soda ash until you have added the amount of soda ash as instructed by your supervisor. i) No.: PBL-21 • DENISON MINES (USA) CORPj^ STANDARD OPERATING PROCEDlMs Rev. No.: R-l • DENISON MINES (USA) CORPj^ STANDARD OPERATING PROCEDlMs Page 5 of Date: June 24, 2009 Title: UF4 Processing 25 • Continue stirring and heating the contents of the tank as instructed by your supervisor until all of the soda ash has dissolved. • Transfer a volume of sodium carbonate (soda ash) solution from the make up tank to the drum dumping station as instmcted by your supervisor. • Add a volume of hydrogen peroxide solution to the drum dumping station as instmcted by your supervisor. The procedure for dumping the UF4 drums is as follows: • Put on die PPE specified in the applicable RWP-or as otherwise specified by die Radiation Safety Officer. . • Tum on the drum dumping station and the weigh scale. • Place a UF4 dmm in position for handling. • Weigh the drum and record the drum weight. • Undo the dmm lid carefully and report any unusual conditions to your supervisor. • Examine the contents of the drum. If the contents of the dmm have solidified to the extent that the material cannot be easily removed from the dmm, then refasten the lid and set the dmm aside for special handling at a later date. For all other dmms, proceed with the following steps. • Place the dmm in die drum dumper. Make sure the dmm is properly secured and make sure all personnel are clear of the dmm dumper mechanisms. Then actuate the dmm dumper and dump its contents into the bath portion of the dumping station while the dmm is submerged in the bath. • Set the valves in the appropriate positions to re-circulate the contents of the badi and start the discharge pump. e Operate water jets and other features of the dumping station until the dnmi has been completely emptied. Then actuate the dumping mechanism to remove the empty dmm from the bath. • Inspect the dmm to assure it is empty and then remove the empty dmm from the process area as instmcted by your supervisor. If the drum is not empty, repeat No.: PBL-21 ^ DENISON MINES (USA) CORP. ^ Rev. No.: R-l STANDARD OPERATING PROCEDURES Page 8 of Date: June 24, 2009 Title: IJF4 Processing 25 Steam CO H,0, CO Na2C03 Digestion / Make-Up Precipitation Tank Tank Operating Instructions This node deals witli digesting the UF4 material in sodium carbonate (soda ash) solution at 80°C for about 4 hours. • Make a safety inspection of all lines and equipment. o Inspect lines for leaks or seeps. o Inspect safety showers and eyewash fountains • As the digestion tank is being filled from the drum dumping station, once the level of slurry in the digestion tank is appropriate for starting agitation without causing splashing or spillage - then start agitation. Continue receiving slurry from the dmm dumping station until a full batch has been received. • Add the required volume of hydrogen peroxide solution to the digestion tank as instmcted by your supervisor. Wear appropriate PPE for handling hydrogen peroxide, as specified below. • Add steam to the contents of the tank until the contents reach 80°C. Continue adding steam as needed to maintain this temperature. • Continue agitation of the tank contents at 80°C for 4 hours to complete the necessary digestion. • At the end of the digestion time, measure the volume of final digestion solution in the tank and take a sample of the contents of the tank and No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORR^JT STANDARD OPERATING PROCEDL^Ss Tide: UF4 Piocessing Page 9 of 25 place the sample in an appropriately marked container. Make sure this sample container is marked clearly witii the batch number, the sample identification and the date. Make sure this sample is collected by laboratory technicians and transported to the laboratory. Whenever working in, around or on this process you must avoid splashing and any contact with the skin and you must wear PPE which includes at a mininium, hard hat, coveralls, mbber boots and gloves, safety glasses witii side shields, and .may include respiratory protection, a face shield or safety^ goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety, Officer. 1 No.: PBL-21 ^ DENISON MINES (USA) CORP. ^ Rev. No.: R-1 STANDARD OPERATING PROCEDURES Page 10 of Date: June 24, 2009 Tide: UF4 Processing 25 NODE #3 - NaOH PRECIPITATION NODE Hazard Assessment Worksheet Equipment Component Individual Equipment No. NaOH Precipitation Node Parameter per Tank Process Material in Component Process Flow Diagram Uranium Sodium NaOH Diatomaceous Process Flow Diagram Carbonate Earth Filter Aid Quantity in Equipment (lb) 1200 8,300 6,800 3,000 Concentration (%) 1.4 10 50 3 Flashpoint, °F — — — TLV-TWA mg/m' — — - STEL mg/m' — — — Radioactivity, pCi/g 484,242 — — — Temperature, °C 70 70 Amb Amb Pressure, psig — — — — Health Rafing 1 1 3 0 Health Hazard Rad 0 Cor 0 Assessment Description: A uranium-rich precipitate is formed by NaOH addition to the solution from the carbonate digestion of the UF4 material in this processing step. The liquid in the tank is strongly basic. Any splashing or contact with the skin should be avoided. These materials can cause skin and eye burns. The solution and the precipitate that is formed are also radioactive and you must follow established health physics controls. If any of the solution or precipitate gets on you, wash it off with generous amounts of soap and water. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 I ll I II III I I lil II III I II II idH STANDARD OPERATING PR0CEDIJKE5 Title: UF4 Processing Page 11 of 25 Digestion/ Precipitation Tank 1 Operating Instructions This node deals with formation of a uranium-rich precipitate by addition of NaOH to the final solution from the carbonate digestion of the UF4 material. • This precipitation processing step will be done in the same tank in which the carbonate digestion was performed. • Make a safety inspection of all lines and equipment. 6 Inspect lines for leaks or seeps. o Inspect safety showers and eyewash fountains • Continue agitation of the final solution from carbonate digestion of the UF4 material. Add steam, if necessary, to maintain the contents of the digestion/precipitation tank at least at 70°C (158°F). • Make'sure you are wearing all appropriate PPE for handling 50% NaOH (caustic) solution, as specified below. • To the agitated contents of the digestion/precipitation tank carefully add 50% NaOH (caustic) solution until the pH of the contents of the tank reaches at least 13.0 as instmcted by your supervisor. Measure the pH of the tank contents with pH paper obtained from the lab. Do not measure the pH using an ordinary pH meter and probe - these may not give correct pH readings in this solution. • After the contents of the tank reach the target pH, continue for 4 hours to agitate the tank contents at the target temperature and continue to No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP. STANDARD OPERATING PROCED Tide: UF4 Piocessing Page 12 of 25 carefully add small volumes of the 50% NaOH solution to the tanic as necessary to maintain the target pH. After four hours the precipitation reaction should be complete. At this point add to the sluiry in the digestion/precipitation tank the amount of filter aid (diatomaceous earth) as instmcted by your supervisor. Make sure you are wearing the appropriate respirator protection as determined by the RSO whenever handling or working in the vicinity of filter aid in its dry condition. Then adjust the necessary valves, tuiTi on the pump, and transfer the contents of the digestion/precipitation tank to the filter feed tank. After the batch of material has been transferred as completely as practical from the digestion/precipitation tank to the filter feed tank then make sure the digestion/precipitation tank agitator is tumed off and that all valves, pumps, etc. have been retumed to the proper settings for starting handling of the next batch of UF4 slurry from the drum dumping station. Whenever working in, around or on this process you must avoid splashing and any contact with the skin and YOU MUST wear PPE which includes at a minimum, hard hat, coveralls, rubber boots and gloves, safety glasses with side shields, and may include respiratory protection, a face shield or safety goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety Officer. ) No.: PBL-21 DENISON MINES (USA) CORP« STANDARD OPERATING PRGCEDUIES Rev. No.: R-l DENISON MINES (USA) CORP« STANDARD OPERATING PRGCEDUIES Page 13 of Date: June 24, 2009 Title: UF4 Processing 25 NODE #4 - NaOH PRECIPITATE FILTRATION NODE Hazard Assessment Worksheet Equipment Component NaOH Precipitate Filtration Node Individual Equipment No. Parameter per Tank Process Material in Component Process Flow Diagram Uranium Sodium Carbonate NaOH Diatomaceous Earth Filter Aid Quantity in Equipment (lb) 1200 8,300 6,800 3,000 Concentration (%) 1.4 10 8 3 Flashpoint, °F — — — TLV-TWA mg/m' — — — STEL mg/m' — — Radioactivity, pCi/g 484,242 — — — Temperature, °C 70 70 70 Amb. Pressure, psig — — .r-~ Health Rating 1 1 3 0 Health Hazard Rad 0 Cor 0 Assessment Description: The uranium-rich precipitate formed by NaOH addition to the solution from the carbonate digestion of the UF4 material is separated from the solution by pressure filtration. Make sure all pressurized lines, connections and fittings are in good condition and not leaking. The liquid in the tank is strongly basic. Any splashing or contact with the skin should be avoided. The chemicals in the liquid can cause skin and eye burns. The solution ahd the precipitate are also radioactive and you must follow established health physics controls. If any of the solution or precipitate gets on you, wash it off with generous amounts of soap and water. The filter aid material is dusty in the dry condition and you must avoid breathing the dust. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MIMES (USA) CORP. STANDARD OPERATING PROCEDURES Title: UF4 Processing To Tails - Cell 1 Filter Cake Filter Cake Filter Aid Addition Tank Re-Pulp Tank 1 Filter Aid Addition Tank Page 14 of 25 Y c o CO Filter Cake Acid Re- Dissolution Tank 1 Operating Instructions This node deals with the pressure filtration processing step to recover the uranium-rich precipitate formed by NaOH addition to the solution from tiie carbonate digestion of the UF4 material. • Make a safety inspection of all lines and equipment. o Inspect lines for leaks or seeps. o Inspect safety showers and eyewash fountains o Inspect the filter to make sure it has been fully dumped, cleaned, and prepared to receive fresh feed material. • If body feed filter aid has already been added in the digestion/precipitation tank, omit the first two steps of this SOP Node. Otherwise, open or close the necessary valves and turn on the necessary pumps to circulate the slurry from the filter feed tank through the filter aid addition tank and back to the filter feed tank. Tum on agitation in the filter aid addition tank. Add and mix into the contents of the filter aid addition tank the amount and type of body feed filter aid as instructed by your supervisor. Make sure you are wearing the appropriate respirator as determined by the Radiation Safety Officer whenever handling or working in the vicinity of filter aid in its dry condition. ) .) No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORPf _ STANDARD OPERATING PROCEDURES Tide: UF4 Processing Page 15 of 25 • When all body feed filter aid has been added, turn off appropriate pumps and adjust the appropriate valves to shut off flow from tiie filter feed tank to the filter aid addition tank. Complete transfer of all slurry from the filter aid addition tank to the filter feed tank, using a small volume of water as necessary to rinse out the tank. Then tmn off the pump and adjust the valves to shut off flow from the filter aid addition tank to the filter feed tank. • Add water to the filter aid addition tank for pre-coating the pressure filter according to instructions from your supervisor. Start agitation of the tank and then add pre-coat filter aid to the tank according to instructions from your supervisor. Mix the contents of the tank thoroughly. Make sure you are wearing the appropriate respirator as determined by the Radiation Safety Officer whenever handling or working in the vicinity of filter aid in its dry condition. • Adjust all necessary valves and tum on the pump to transfer pre-coat filter aid slurry from the filter aid addition tank to the filter press. Pump the entire contents of the filter aid addition tank through the filter press. Then turii off tiie pump and adjust all necessary valves to leave the pre-coated filter press filled with water under some pressure. • Adjust all necessary valves and tum on the pump from the filter feed tank to the filter press. Recycle filtrate back to the filter feed tank until the solution clears and then adjust the appropriate valves to send all barren filtrate to the filtrate and wash surge tank. Pump the contents of the filter feed tank through the filter press until the tank is empty or tiie pressuris or flow rate indicates the filter press chambers are full of filter cake. • Tum off the pump from the filter feed tank, adjust the necessary valves, and run wash water through the filter press according to instmctions from your supervisor. Send the filter discharge to the filtrate and wash surge tank. • Shut off the wash water, adjust the appropriate valves, and mn compressed air through the filter press according to instmctions from your supervisor. Send the filter discharge liquid to the filtrate and wash surge tank. • When the filter cake has been adequately dried by the compressed air, shut off the air flow and depressurize the filter press. No.: PBL-21 ^ DENISON MINES (USA) CORP.^ Rev. No.: R-l STANDARD OPERATING PROCEDURES Page 16 of Date: June 24, 2009 Title: UF4 Processing 25 Tum on the screw conveyor system under the filter press, open the filter, and dump and transfer all filter cake to the filter cake re-pulp tank 1. Add water to the filter cake re-pulp tank 1 as instructed by your supervisor and agitate the contents of the tank until tiie filter cake is fully re-pulped. Adjust appropriate valves and tum on the pump to transfer the re-pulped filter cake slurry to the filter cake acid re- dissolution tank according to instmctions from your supervisor. Clean the filter press, close it up, and prepare it for its next filtration cycle. Repeat pre-coating the filter, filtering the contents of the filter feed tank, and dumping and re-pulping the filter cake and transferring it to the filter cake acid re-dissolution tank until the filter feed tank is empty. Make sure the volume in the filtrate and wash surge tank is measured and recorded and make sure a sample of the contents of the tank is placed in an appropriately marked sample container for analysis by the lab. Then send the contents of the filtrate and wash surge tank to tailings. Whenever working in, around or on this process you must avoid splashing and any contact with the skin and YOU MUST wear PPE which includes at a minimum, hard hat, coveralls, mbber boots and gloves, safety glasses with side shields, and may include respiratory protection,, a face shield or safety goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety Officer. Always keep your work area clean and ensure your work area is free of obstmctions. No.: PBL-21 • DENISON MINES (USA) CORP^ STANDARD OPERATING PROCEDllBs Rev. No.: R-l • DENISON MINES (USA) CORP^ STANDARD OPERATING PROCEDllBs Page 17 of Date: June 24, 2009 Title: UF4 Processing 25 NODE #5 - FILTER CAKE ACID RE-DISSOLUTION NODE Hazard Assessment Worksheet Equipment Component Filter Cake Acid Re-Dissolution Node Individual Equipment No. O Parameter per Tank Process Material in Component Process Flow Diagram Uranium Sulfuric Acid Sodium Chlorate Quantity m Equipment (lb) 1200 1250 150 Concentration (%) 1-8 93 50 Flashpoint, °F — — TLV-TWA ppm — ,— STEL ppm — — Radioactivity, pCi/g 484,242 — — — Temperature, °C 25-40 25-40 Pressure, psig — 0-100 — — Health Ratmg 1 3 1 Health Hazard Rad Cor Oxy Assessment Description: The re-pulped filter cake of basic uranium-rich precipitate and the acidic solution in which it will be digested should be handled with caution. Any splashing or contact with the skin should be avoided. The acidic chemicals in the liquid can cause skin and eye burns. The solution and the filter cake are also radioactive and you must follow established health physics controls. If any of the solution or filter cake gets on you, wash it off with generous amounts of soap and water. • ) No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORR^fc" STANDARD OPERATING PROCEDURES Title: UF4 Processing Page 18 of 25 H2SO4 Steam NaClO, Filter Cake Acid Re-Dissolution Tank Operating Instructions This node deals with the acid digestion of re-pulped uranium-rich filter cake. • Make a safety inspection of all equipment. o Inspect safety showers and eyewash fountains o Inspect valves and fittings in the acid line. • As the slurry of re-pulped filter cake is being transferred to the filter cake acid re-dissolution tank, turn on agitation in the tank as soon as the level is sufficient according to your supervisor's instmctions. • Add water to the contents of the filter cake acid re-dissolution tank according to instmctions from your supervisor and carefully add sulfuric acid to bring the pH of the slurry to 2.0 or a lower pH as instructed by your supervisor. Add a volume of sodium chlorate solution to the contents of the filter cake acid re-dissolution tank as instmcted by your supervisor. • Add steam to bring the contents of the filter cake acid re-dissolution tank to 40°C or another temperature as instmcted by your supervisor. Agitate the slurry in the tank at the target temperature and pH for a time of at least one hour as instmcted by your supervisor, adding steam and sulfuric acid as needed to maintain these conditions. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP^^ STANDARD OPERATING PROCEDlWs Titie: UF4 Processing Page 19 of 25 Whenever working in,, around or . on this process, you rnust avoid splashing and any contact with the skin and YOU MUST wear PPE which includes at a mininium, hard hat, coveralls, nibber boots and gloves, safety glasses with side shields, and respiratory protection, a face shield or safety goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety Officer. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP. STANDARD OPERATING PROCED Titie: UF4 Processing URES Page 20 of 25 NODE #6 - FILTRATION AFTER ACID DIGESTION OF FILTER CAKE NODE Hazard Assessment Worksheet Equipment Component Filtration After Acid Digestion of Filter Cake Node Individual Equipment No. Parameter Process Material in Component Process Flow Diagram Uranium Dilute H2SO4 Diatomaceous Earth Filter Aid Quantity in Equipment (lb) 1,200 50 3,000 Concentration (%) 2-4 0.1-0.2 8-10 Flashpoint, °F ~ — — TLV-TWA mg/m' — — STEL mg/m' — — Radioactivity, pCi/g — — Temperature, "C 40 40 40 Pressure, psig ~ — Healtii Rating 1 3 0 Hazard Rating Rad Cor 0 Assessment Description: This processing step involves pressure filtration of an acidic slurry. Any splashing or contact with the skin should be avoided. The acidic chemicals in the liquid can cause skin and eye burns. The solution and the filter cake are also radioactive and you must follow established health physics controls. If any of the solution or filter cake gets on you, wash it off with generous amounts of soap and water. If any of the filter cake becomes dry, respiration of the dust must be avoided. The filter press and piping leading to it will be under pressure and should be handled carefully. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) C^ORP^" STANDARD OPERATING PROCEDURES Tide: UF4 Processing Page 21 of 25 Filtrate and Wash Coinp. Air H2O Second Stage Filter Press H2O CO CO Y c 0 Filter Cake CO Impurity Impurity Removal Tank Removal Tank 1 , 2 Filter Cake Re-Pulp Tank 2 Filter Cake Acid Re-Dissolution Tank H2O Cake Washing Tank Operating Instructions In this processing step the used filter aid is separated from the dissolved uranium by pressure filtration. • Make a safety inspection of all lines and equipment. o Inspect lines for leaks or seeps. o Inspect the filter feed pump and the filter press for leaks and proper assembly. o Inspect safety showers and eyewash foimtains. • Adjust ail necessaiy valves and tum on the pump from the filter cake acid re-dissolution tank to the filter press. Recycle filtrate back to the filter cake acid re-dissolution tank untU the solution clears and then adjust the appropriate valves to send the filtrate to impurity removal tank 1 or tank 2. Pump the contents pf the filter cake acid re- dissolution tank through the filter press until the tank is empty or the pressure pr flow rate indicates the filter press chanibers are full of filter cake. • When the pressure or flow rate indicates the filter press chambers are full of filter cake, tum off the pump from the filter cake acid re- dissolution tank, adjust the necessary valves, and run wash water through the filter press according to instmctions from your supervisor. Send the filtrate from washing to the same impurity removal tank. \ ) No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MCNTES (USA) CORP STANDARD OPERATING PROCED Titie: UF4 Processing URES Page 22 of 25 • Wlien the water wash is completed, shut off the wash water, adjust appropriate valves, and mn compressed air through the filter press according to instructions from your supervisor. Send any liquid discharged from the filter press to the same impurity removal tanic. • When the filter cake has been adequately dried by tiie compressed air, shut off the air flow and depressurize the filter press. • Tum on the screw conveyor system under the filter press, open the filter, and dump and transfer all filter cake to the filter cake re-pulp tank 2. • Add water to the filter cake re-pulp tank according to instructions from your supervisor and agitate contents of the tank until the filter cake is fully re-pulped. Transfer the re-pulped filter cake slurry to the cake washing tank according to instmctions from your supervisor. • Clean the filter press, close it up, and prepare it for its next filtration cycle. • Repeat, as needed, steps for filtering the contents of the filter cake acid re-dissolution tank and dumping and re-pulping and transferring the filter cake until the filter cake acid re-dissolution tank is empty. • Transfer the clear supernatant liquid from the cake washing tank back into the process to recover the contained uranium according to instmctions from your supervisor. Wash the filter cake solids in the cake washing tank with water as instructed by your supervisor. Once the washing of the filter cake solids is sufficient, transfer the solids from the cake washing tank to tailings according to instructions from your supervisor. • Make sure a sample is taken of the underflow solids slurry transferred from the cake washing tank to tailings. • Whenever working in, around or on this process you must avoid splashing and any contact with the skin and YOU MUST wear PPE which includes at a minimum, hard hat, coveralls, mbber boots and gloves, safety glasses with Side shields, and may include respiratory protection, a face shield or safety goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety Officer. Always keep your work area clean and ensure your work area is free of obstmctions. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CO: STANDARD OPERATING PROCED Titie: UF4 Processing R^^ Page 23 of 25 NODE #7 - IMPURITY REMOVAL NODE Hazard Assessment Worksheet Equipment Component Impurity Removal Node Individual Equipment No. Parameter Process Material in Component Process Flow Diagram Uranium H2SO4 Ammonia Quantity in Equipment (lb) 1200-2400 50-500 100-250 Concentration (%) 2-4 93 100 Flashpoint, °F — — ._ TLV-TWA mg/m' — . 25 STEL mg/m' — 35 Radioactivity, pCi/g .— — :: Temperature, °C 40 20 20 Pressure, psig Health Rating 1 3 3 Hazard Rating Rad Cor Assessment Description: In this step, impurities will be separated from the uranium by pH adjustment and precipitation, using ammonia, followed by settling and decantation. REMEMBER Ammonia vapor, fumes and mists are Toxic Atmospheres and cannot be detected by smell above approximately 100 ppm. IF you smell strong ammonia fumes you must wear a full face respirator with universal cai-tridges. At high concentrations your skin and eyes can be burned. The beginning solution and the precipitate are also radioactive and you must follow established health physics controls. If any of the solution or precipitate gets on you, wash it off with generous amounts of soap and water. No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP.' STANDARD OPERATING PROCEDURES Title: UF4 Piocessing Page 24 of 25 To Tails' Cell 1 NHsor H2SO4 Steam Steam CO CO NH3 or H2SO4 Impurity Impurity Removal Removal Tank 1 Tank 2 To Normal Yellowcake Precipitation Product Holding Tank Operating Instructions This node deals with the separation of uranium from impurities, by adjusting pH with ammonia (NH3), to form a precipitate, allowing the precipitate to settle to the bottom of the tank, and then decanting and pumping away the clear liquid. • Make a safety inspection of all lines and equipment. o Inspect lines and tanks for leaks or seeps, o Inspect safety showers and eyewash fountains • Measure contained volume and then tum on the agitator and take a sample of the tank contents for the impurity removal tank containing tiie acid digestion liquor that has most recently been clarified by filtration in the filter press. Place the sample in an appropriately labeled sample bottle for analysis by the lab. • Add steam, as necessary, to the contents of the impurity removal tank according to instmctions from your supervisor to establish and maintain the target temperature for the tank contents. Add ammonia to the contents of the impurity removal tank according to instructions from your supervisor. Continue adding ammonia until the contents of the tank reach and remain at the target pH, as instructed by your supervisor, and then continue agitation for an additional 30 minutes. • Tum off the agitator in the impurity removal tank and allow the precipitate to settle according to instmctions from your supervisor. J No.: PBL-21 Rev. No.: R-l Date: June 24, 2009 DENISON MINES (USA) CORP STANDARD OPERATING PROCEDU Titie: UF4 Processing Page 25 of 25 Depending on the impurity being removed from the uranium, the uranium may be contained in either the precipitate or in tiie supernatant liquid. Once your supervisor has determined that the precipitate in the impurity removal tank has settled sufficientiy, begin decanting the clear supernatant liquid from the tank. If tiie uranium is in the precipitate, then transfer the decanted liquid to tailings as instmcted by your supervisor. Be sure to take a sample of the decanted liquid and record and report the volume of decanted liquid. After the liquid is completely decanted as instmcted by youi" supervisor, add water to wash the precipitate as instructed by your supervisor and agitate, settle and decant again. After washing the precipitate, add water and sulfuric acid to the precipitate as instructed by your supervisor and agitate until the uranium is all re-dissolved. Then either conduct other impurity removal steps on the liquor or transfer it to the product holding tank. If the uranium is in the decanted liquid, tiien transfer the liquid to the other impurity removal tank if addition impurity removal is needed, or else transfer the liquid to the product holding tank. Once the decanting is complete, add water, agitate, settle and decant again to wash the precipitate, sending the liquid removed to the same tank as previously. If tiie washed precipitate is sufficiently low in uranium, transfer it to tailings as instructed by your supervisor. Otherwise, send the precipitate to re-processing as instructed by your supervisor. Once impurities have been sufficiently removed and the liquor has accumulated sufficiently in the product holding tank, transfer the contents of the product holding tank slowly to the normal yellowcake precipitation area of the plant. Each time a transfer from tiiis tank occurs, record and report the volume transferred and take a sample of the liquor transferred in a properly marked sample container. Whenever working in, aroimd or on this process YOU MUST wear PPE which includes at a minimum, hard hat, coveralls, mbber boots and gloves, safety glasses with side shields, and may include respiratory protection, a face shield or safety goggles, all as specified in the applicable RWP or as otherwise specified by the Radiation Safety Officer.