The URL can be used to link to this page

Home My WebLink AboutDRC-2011-007446 - 0901a068802787f4State ofUtah GARY R. HERBERT Govemor GREG BELL Lieutenant Governor Department of Enviromnental Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rust Lundberg Director G-201 September 26, 2011 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 UTl 900479: Health Physics Inspection RADMOD-AFIL-01 Dear Mr. Frydenlund: On September 20 and 21, 2011, an inspection was conducted at your facility by Ryan Johnson, a representative of the Division of Radiation Control (DRC) of the Utah Department of Environmental Quality. Observations from the inspection were discussed with David Turk and/ Ronnie Nieves at the closeout meeting. The inspection was an examination ofthe activities conducted in your facility as they relate to compliance with the Utah Radiation Control Rules, the license conditions ofthe RML UTl 900479 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 DRG inspector made recommendations regarding items for improvement. These recommendations can be found at the end ofthe inspection report under recommendations. Enclosed is the inspection report regarding this inspection for your review. The DRC considers this inspection closed. 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 Lundbe^, Executive Secretary RL/RJ:rj Cc: David Turk, Site Radiation Officer Enclosures 195 North 1950 West • Salt Lake City, UT IVIailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801-533-4097 • T.D.D. (801) 536^414 www.deq.utah.gov Printed on 100% recycled paper INSPECTION REPORT I Inspection Module: RADMOD-AFIL-01: Altemate Feed and Insitu-Leach Inspection Location: Denison Mines- White Mesa Uranium Mill, [Blanding Utah. Inspection Items: Inspection Dates: Inspectors: Altemate Feed Acceptance and Circuit and Insitu Leach Recovery (ISL) (a.k.a. 1 le(2)) Material Acceptance and Dis}50sal ! September 20 and 21, 2011 | I Ryan Johnson, Utah Division of Radiation Control (DRC) Personnel Contacted: Dave Turk (Radiation Safety Officer (RSO)) Coordinator) , Ronnie Nieves (Radiological Goveming Documents: • UACR313-15 I • Radioactive Materials License (RML) UTl 900479 Opening Meetmg Denison Mines: Dave Turk (Radiation Safety Officer) Ronnie Nieves (Radiological Coordinator) | Utah DRC: Ryan Johnson (Inspector) Kevin Camey (Inspector) During the opening meeting, the inspector discussed the inspection items and documentation to be reviewed during the inspection. Only the Altemate Feed Circuit of the Mill was in operation during this inspection the remainder of the Mill was in annual shut down and maintenance. The Mill staff reminded the inspector of the safety requirements for the Mill. lof Page 4 U:\rad\COMMON\Uranium mills\lle(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 IMnspection ReportsUnspection ReportRADMOD-AfIL-019-22-IlRJ.doc j • The generators shipping papers. Deficiencies: ISL documentation is incomplete it does not completely document disposal activities and steps taken to minimize void spaces. In discussing this observation with the Mills RSO, the Inspector was provided a new form that will be filled out for ISL (1 le(2)) material disposal. This form is Attachment 2 lie.(2) Byproduct Material Disposal Docuinentation Form and it part of SOP PBL-10 R-3 lie. (2) Byproduct ^ Disposal This revision of the procedure is currently be reviewed by the DRC and won't be implemented until the DRC approves the procedure. Closeout Meeting Denison Mines: Dave Turk (RSO) Ronnie Nieves (Radiological Coordinator) Utah DRC: Ryan Johnson (Inspector) Kevin Camey (Inspector) During the closeout meeting the inspector discussed with RSO the number of air particulate monitoring stations around the Mill. The inspector questioned, due to the size, of the Mill property, if there were enough BHV stations around the Mill to properly document the effluents from the Mill's ore pad, stacks and tailings cells. Findings The following findings were observed during this inspection: ' 1. Large cracks were observed in the concrete floor of the Altemate Feed Circuit area; 2. Drums being staged to be put into the Altemate Feed Circuit were being placed on soil; and 3. Incomplete documentation of the 1 le.(2) material disposal process. The Inspector also observed that the White Mesa Mill was in the process of correcting all ofthe findings observed at the time of the inspection. Therefore, no enforcement actions will be taken and these findings will be followed up by the DRC during the next inspection. Recommendations ' The following are DRC recommendations regarding items for improvement: 1 1. The DRC recommends that the 11 e.(2) Byproduct Material Disposal Documentation Form in Attachment 2 of SOP PBL-10 R-3 11 e.(2) Byproduct Disposal is used inunediately and not to wait for DRC approval ofthe SOP. 2. The DRC recommends that the concrete for the Dmm Dumping Node is completed. 3. The DRC recommends that the cracks in the concrete floor of the Altemate Feed Circuit are repaired. i 3 ofPage4 U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 IMnspection ReportsMnspection ReportRADMOD-APIU019-22-llRJ.doc i UTAH DIVISION OF RADIATION CONTROL Inspection Module RADMOD-AFIL WHITE MESA MILL RML LICENSE UTl 900479 OPENING MEETING INSPECTOR(S) DATE f- U MEETING MEMBERS NAME COMPANY CONTACT INFORMATION ^ UTAH DIVISION OF RADIATION CONTROL , DISCUSSION SITE STAFF COMMENTS /^ST ^/ /^H( y-yJ^-ti^ ft] , UTAIPOIVISION OF RADIATION COWTROL RADIATION PROTECTION INSPECTION MODULE RADMOD-AFIL-01 ALTERNATE FEED/INSITU LEACH FACILITY MATERIALS DENISON MINES - WHITE MESA URANIUM MILL RADIOACTIVE MATERIAL LICENSE UTl900479 References: Radioactive Material License UTl 900479, License Renewal Application dated Febmary 28, 2007, Radiation Protection Manual, Section 5,10CFR20, Utah Administrative Code R313-15. Alternate Feed Material (License Conditions 10.1.10.6 through 10.19) 1) Review the altemate feed manifests from the last two years. (License Condition 10.6 through 10.19) Date Generator Name Amount Receiyed Storage Location/Processed (I /OO rA^. / COM ITI 0nnd.7Q n»»nicr.n \;i;not! _ WViifo Moco I IMinXUP Incnof'tir.r, mnHiiUcN^n 1 1 \Incr^fv-ti'rin Mr>Hii1p>c\R A P^lVir 6. U:\rad\COMMON\Uranium mills\lIe(2)UTl 900479 Denison Mines - White Mesa UMillMlP Inspection modules\201 IMnspection ModulesMlADMOD-AFIL-01.doc Dnoo 1 Q 2^ Have any altemate feeds been Comments: epted that were not approved through" !icense Amendment? Yes NoXy'. How much tailings cell disposal capacity does the mill have left at the time of the inspection? How much altemate feed/ore/ISL material does the mill have onsite? 3) Does the amount of altemate feed/ore/ ISL material exceed the tailing cell capacity? Yes_ No Is the current surety amount adequate for the amount of altemate feed/ore/ ISL material currently stored at the mill? (License Condition 10.1) Yes No^ Comments: Observe the new Alternate Feed Circuit being used. 4) Which Altemate Feed is being processed?(Name and Associated License Condition) Comments: 5) What PPE is being used? Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N PPE Requirements (check applicable) ^ Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N Hard Hats i Tyvek Disp. Gloves Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N Safety Glasses f Hearing Face Shields Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N Rubber Boots Lab Coats Other Alternate Feed Circuit Drum Dumping Node PPE Observed Y/N Coveralls Gloves Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N PPE Requiremen ts (check applicable) Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N Hard Hats f Tyvek Disp. Gloves Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N Safety Glasses f Hearing Face Shields Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N Rubber Boots Lab Coats Other Alternate Feed Circuit UF4 Carbonate Digestion Node PPE Observed Y/N Coveralls p Gloves Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N PPE Requiremem ts (check applicable) Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N Hard Hats P Tyvek Disp. Gloves Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N Safety Glasses Hearing Face Shields Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N Rubber Boots r' Lab Coats Other Alternate Feed Circuit NaOH Precipitation Node PPE Observed Y/N Coveralls Gloves U:\rad\COMMON\Uranium millsM le(2)UTl900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 IMnspection ModulesMlADMOD-AFIL-Ol .doc r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N PPE Ff^uiremem ts (check applicable) r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N Hard Hats P Tyvek Disp. Gloves r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N Safety Glasses P Hearing Face Shields r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N Safety Boots Respirators Rubber Suits r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N Rubber Boots P Lab Coats Other r Alternate Feed Circuit NaOH Precipitate Filtration Node PPE Observed Y/N Coveralls ? Gloves f Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N PPE Requiremem ts (check applicable) Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N Hard Hats ? Tyvek Disp. Gloves Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N Safety Glasses P Hearing Face Shields Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N Rubber Boots f Lab Coats Other Alternate Feed Circuit Filter Cake Acid Re-Dissolution Node PPE Observed Y/N Coveralls r Gloves •P Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N PPE Requirement ts (check applicable) Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N Hard Hats p Tyvek Disp. Gloves Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N Safety Glasses F Hearing Face Shields Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N Rubber Boots P Lab Coats Other Alternate Feed Circuit Filtration After Acid Digestion of Filter Cake Node PPE Observed Y/N Coveralls Gloves Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N PPE Requirement ts (check applicable) Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N Hard Hats P Tyvek Disp. Gloves Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N Safety Glasses P Hearing Face Shields Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N Safety Boots Respirators Rubber Suits Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N Rubber Boots f Lab Coats Other Alternate Feed Circuit Impurity Removal Node PPE Observed Y/N Coveralls r Gloves 1 Comments: 6) Is the New Circuit operated under an RWP or an SOP? Comments: RWP SOP V 7) Where are the air monitoring Stations located for the Altemate feed Circuit? Comments: /A U:\rad\COMMON\Uranium milIsM le(2)UTl900479 Denison Mines - White Mesa UMiIl\HP Inspection modules\201 IMnspection ModuIesMlADMOD-AFIL-0I.doc 8) What type of air Monitoring a^feey doing for the Altemate feed Circu^l^ Comments: / ^ J 9) Is the Air Monitoring in the Altemate Feed Circuit adequate? Yes No Comments: . 10) Is the Altemate feed Circuit posted? Yes No Is each area within the Altemate feed Circuit posted differently? Yes y No How is the Altemate feed Circuit area(s) posted? Comments: / / / /? 11) Does the posting(s) reflect the radiological/health concems present? Yes No Comments: imments: • ' /! 12) Are area gamma monitors in the Altemate Feed Circuit located appropriately? Yes >r^ No Comments: ^ 9^ 5^ 13) What are the types of monitoring systems being used and are they appropriate? Comments: ^ U:\rad\COMMON\Uranium mills\lle(2)UTl 900479 Denison Mines - White Mesa UMill\HP Inspection modules\201 l\hispection ModulesMlADMOD-AFIL-OLdoc ^ 14) Briefly describe the dmm han^il^g and loading into the Altemate Feed^fcuit. Comments: — . i^-^ >^j,^^ /£>.o.^ p^c^ /j/?\z^^^, t ^^. ^ ,-,/4^ /P^^ ^ A—'l.r^c^A^ 3rill's, s Note * Tom during a previous inspection documented that dmms were being staged off of the Altemate Feed Circuit with possible staining in soils from the dmms ' U:\rad\C0MM0N\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMillVHP hispection modules\201 l\hispection Modules\RADMOD-AFIL-01 .doc ^ Alternate Feed Material (Conta^fc-ized Alternate Feedstock Material l^fcage Procedure) 15) Are all Altemate Feed materials stored on the Ore Pad? Yes No^^C If answer is no then go to questions 8 through 13. If yes skip to question 14. Comments: . ^ . / 16) Where is the Altemate Feed not on the Ore Pad being stored? Comments: /] / ; / 17) Is the Altemate Feed Material being stored on a Hardened Surface? Yes No If No, Is the Altemate feed being stored in Over Pack containers? Yes No Comments: /i // 18) Are Altemate Feed Containers stacked no more then 2 wide and 2 high? Yes No Comments: 19) Are Altemate Feed Containers being stored on planks or pallets? Yes No ^ Comments: 20) Are Altemate Feed Storage areas bermed? Yes^ Nox*^^ Comments: / ..^ ^ /? — JiJb S^^^y yA.jf^ 21) Are weekly inspections of the Altemate Feed Storage Areas being done and documented? Yes^^^No Comments: U:\rad\COMMON\Uranium millsM le(2)UTl 900479 Denison Mines - White Mesa UMillMiP hispection modules\201 Uhispection Modules\RADMOD-AFIL-01 .doc Insitu Leach Facilitv Material (HRnse Condition 10.5) 22) According to License Condition 10.5 Part D "All disposal activities shall be documented". Review the disposal records from the past two years (starting from the present year). Describe how the shipments are documented and what is documented. . Comments: . J^^<£:L^ t^-^^y^ , ^ ' f>:TD^ /^^..; y U:\rad\COMMON\Uraniummills\lle(2)UT 1900479 Denison Mines - White Mesa UMill\HP hispection modules\201 l\hispection ModulesMlADMOD-AFIL-0I.doc , 23) Have any single source of ISL^lfste material exceed the disposal limit ^^,000 cubic yards per source? Comments: (License Condition 10.5.A) Yes No 24) Was all ISL waste material disposed in Cell #3? (License Condition 10.5.C) Comments: Yesx*^ No 25) Were all disposal activities properly documented? (License Condition 10.5.D) , ^ Comments: Yes_ No y<i 26) Did the documentation show that all steps were taken to minimize void spaces? (License Condition 10.5.B) Comments: Yes No 27) Discuss with the Lead/Forman of ISL disposal on how ISL material is disposed. If possible observe also. Comments: yf'i^yyl^ '^/ii'iT ^y^C '. J_ , . r^ v % ^ /^^ ''y:.M, /P^o^^ r./o ~C/.y^..J ^^.^ ^y^^^^^.-^ gf>; U <,-Jk. y>L,.^ ..Jl -^Ji U:\rad\COMMON\Uranium millsM le(2)UT 1900479 Denison Mines - White Mesa UMiil\HP hispection modules\201 l\hispection Modules\RADMOD-AFiL-01.doc UTAH DIVISION OF RADIATION CONTROL Inspection Module RADMOD-AFIL WHITE MESA MILL RML LICENSE UTl 900479 CLOSEOUT MEETING INSPECTOR(S) ^ DATE f--^^ // MEETING MEMBERS NAME COMPANY CONTACT INFORMATION ^-h^ '^f^-^ UTAH DIVISION OF RADIATION CONTROL CLOSEOUT MEETING DISCUSSION of FINDINGS % <:%^'f /x^^ '^^.^u.^ ^'^j^-^ i^^^-y^ /fpyri'^^xy^ SITE STAFF COMMENTS No.: PBL-10 Rev. No.: R-3 Date: Sept. 12, 2011 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproducl Disposal Page 10 of 11 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: Name of employee receiving the load: Generator of the Byproduct Material: Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or No Who gave and when was the notification given? Description of byproduct material disposal area/activities: Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? Was the material segregated from any Mill material or equipment disposed of in the cell? Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's Initials Was the maximum lift thickness above tailings less than 4 feet thick? Was the maximum lift thicknessof subsequent lifts less than 2 feet thick? Has 4 foot of tailings sands been maintained under each disposal area? Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? No.: PBL-10 Rev. No.: R-3 Date: Sept. 12,2011 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 11 of 11 How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at least 4 times prior to placement of subsequent lifts? Were void spaces filled with tailings? Was the shipment properly covered? Are additional settlement monitors required to be placed for this generator? If required, where were settlement markers were placed? Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or No 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? Yes or No