DRC-2011-007323 - 0901a0688026893a

A/:
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Departmentof
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
RustyLundberg
Director
7^ ?
0 ,
September 1, 2011
VIA HAND DELIVERY
David C. Frydenlund, Vice President, Regulatory Affairs and Counsel
Denison Mines (USA) Corp. ,
1050 17'^ Street, Suite 950
Denver, CO 80265
Subject: Denison Mines (USA) Corporation (DUSA) W
PRC Inspection Results: Storm Water Best Management Practices Plan
(SWBMPP), Ground Water Module 65, October 19, 2010, Utah Ground Water
Discharge Permit No. UGW370004: DRC Request for Information and
Confirmatory Action Letter
Dear Mr. Frydenlund:
On October 19, 2010 Tom Rushing, Utah Division of Radiation Control (DRC) met with Mr.
David Turk, Radiation Safety Officer, for Denison Mines (USA) Corp. (DUSA) to conduct a
storm water inspection at the DUSA White Mesa Uranium Mill near Blanding, Utah. A copy of
the inspection findings (2010 DRC Groundwater Module 65) including a copy of the DRC photos
is attached for your information. Please refer to the attached Groundy/ater Module for more
specific information regarding the Request for Information md/or Confirmatory Actions listed
below.
Request for Information:
As discussed during a conference call amongst Phil Goble (DRC), Tom Rushing (DRC), Jo Ann
Tischler (DUSA) and David Turk (DUSA) on 8/31/2011 at 3:30 P.M, as well as afollow up
confirmation call between Jo Ann Tischler (DUS A) and Tom Rushing (DRC) on 8/31/2011 at
5:00 P.M., DUSA will submit a letter of response listing each of the request for information items
below and an explanation of all follow up actions taken or planned to address the items, post-.
marked, or otherwise delivered to the DRC office on or before 30 calendar days after DUSA
receipt of this letter. ,
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 - Salt Lake City, UT 84114-4850
Telephone [phone] - Fax [phone] • T.D.D. [phone]
www.deq. Utah.,(^ov
Prmtprl nn inn% recvcled Daoer
White Mesa Uranium Mill
2010 DRC Storm Water Inspection
Page 2
1. DRC requests information regarding updates to the plans/inspections to provide
inspections according to frequencies required by the Storm Water Best Management
Practices Plan (SWBMPP). For example, the SWBMPP requires a weekly inspection of
the diversion ditches; however, they are conducted monthly. Failure to provide these
inspections in conformance with the SWBMPP or modify the SWBMPP is a violation of
the Part I.D. 10 of the Groundwater Permit.
2. DRC requests information regarding the inspection procedures for reagent storage tanks
(including intermediate process tanks, e.g. Pregnant Liquors) which are installed on-grade
(on-grade refers to tank installations where the tank bottom is in contact with the ground)
to insure that the structural integrity of the tank bottom is acceptable/appropriate. Cathode
protection for on grade tanks is prescribed in Part I.D. 10(a) of the Groundwater Permit.
3. DRC requests an outline of a plant process for intemal notification and documentation of
the clean up of small quantity spills (less than reportable quantities). Per the 2010
inspection, it was observed that a fuel spill had occurred at the fuel tank area and had not
been cleaned up and there did not appear to be a process to identify, document, or clean up
such spills. Failure to provide/maintain such a process is in non-conformance with the
White Mesa Mill, June, 2008 SWBMPP, Part 4.2.1.
4. DRC requests that DUSA review the White Mesa Mill SPCC Plan (dated June,;2008) to
insure that all tanks included under the current facility Spill Prevention Countermeasure
and Control (SPCC) plan meet current requirements of current EPA rules (40 CFR 112).
Specifically, any additional tanks, including non-PCB containing tanks, should be
evaluated and included under the oil storage inventory and inspection protocols, where
required. This RFI is required in order to insure that procedures and policies at the mill are
in accordance with current requirements.
5. DRC requests that DUSA seal the interior drain(s) in the vehicle maintenance areas to
prevent interior spills from draining to outdoor, uncovered areas/catchments. This is
specified in the facility SWBMPP and is considered a "best management practice" to
minimize the quantity of contaminated material. The open drain(s) not in conformiarice
with the SWBMPP part 4.3.1, second bullet "clean up spills promptly, don 't let minor
spills spread, *'
6. DRC requests that DUSA insure that the clean water tank valve is sealed properly. Per the
2010 storm water inspection, it was noted that this valve was leaking and was creating
ponded water areas in unUned ditch/soil areas. This is not in conformance with Section
4.1.4 of the SWBMPP which states, ''Areas requiring maintenance or repair, such as
excessive vegetative growth, channel erosion or pooling of surface water runoff, will be
reportfed] 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."
White Mesa Uranium Mill ^
2010 DRC Storm Water Inspection
Page 3
Confirmatory Action:
The confirmatory action items listed below are per agreements made between DUSA and DRC
during a conference call amongst Phil Goble (DRC), Tom Rushing (DRC), Jo Ann
Tischler (DUSA) and David Turk (DUSA) on 8/31/2011 at 3:30 P.M, as well as a fQllow up
confirmation call between Jo Ann Tischler (DUSA) and Tom Rushing (DRC) on 8/31/2011 at
5:00 P.M.. Per those calls, it was agreed that the three listed items will be addressed within 45
calendar days of your receipt of this letter. Additionally, DUSA will submit a letter of response
listing each of the items below and an explanation of all follow up actions/activities taken to
address the items. The response will be post-marked, or otherwise delivered to the DRC office,
on or before expiration of the 45 calendar day period.
1. DUSA Has violated Part LD. 11 of the Groundwater Permit by failing to manage drums
containing altemate feed material (located outside of the feedstock management area) in
compliance with the required performance standards.
a. Feedstock material was not stored in water tight containers,
b. Feedstock material was not stored on a hardened engineered surface or asphalt
or concrete j
c. Feedstock material was not stored in a designed and approved storage area (by
the Co-Executive Secretary), or other approved area.
d. DRC observed open and degraded containers containing feedstock material on
soil and located outside of the feedstock management area.
2. DUSA has violated Part I.D. 10 of the Groundwater Permit by failing to replace/repair
concrete in the secondary containment of the Caustic Soda Tank.
3. DUSA has violated Part LD.IO of the Groundwater Permit by failing to repair cracks in the
secondary containment area for the soda ash tanks.
If you have questions or concems regarding this letter please contact Tom Rushing at (801) 536-
0080.
Sincerely,
UTAH WATER QUALITY BOARD
Rusty Lundberg
Co-Executive Secretary
Attachment: DRC Module 65 (Including photo pages)
RL:TR:tr
F:\DUSA\StormWaterManagement\2010SWInspection\DRC20IOSWBMPPCAL.doc
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 1 of 22
Utah Division of Radiation Control (DRC)
Ground Water Module 65
Denison Mines, White Mesa Uranium Mill
DRC Annual Storm Water Inspection
Ground Water Permit UGW370004
Inspection Year: 2010
Inspection Date: October 19, 2010
Module Reviewers Names/Initials: / /
Phil Goble, Compliance Section Manager t lc^CXP ^ /
Loren Morton, Environmental Program Manger '
Module Prepared by:
Tom Rushing, P.G., Compliance Section ^ 1^^/
DRC Staff Present; Tom Rushing, P.G., Compliance Section
Denison Mines Staff Present; David Turk, White Mesa Uranium Mill RSO
Denison Mines Staff Interviewed; David Turk, White Mesa Uranium Mill RSO
Currently Approved Storm Water Best Management Practices Plan (SWBMPP) for the White
Mesa Uranium Mill;
Date: June, 2008
Revision No.: 1.3
Violations Identified in Last (2009) Inspection: (list) None
Requests for Information Per Previous (2009) Inspection;
Two requests for information were issued to DUSA per the 2009 storm water inspection which
resulted in a DRC letter dated December 12, 2009, summarized below for ease of reference:
1. DRC noted that the SPCC Plan requires tank to soil potential measurements. It was unclear
whether this item was being undertaken. Please provide information to clarify the intent of
these measurements and whether or not the measurements are currently conducted.
Denison Response:
Upon review of the SPCC Plan Denison notes that tank to soil potential measurement^ are
referred to at Section 1.10 of the Pian within the context of a record that would be maintained
should such measurements actually become necessary. Soil to tank potential measuremenls are
utiUzied to test cathodic protection systems for underground tanks and piping. Denison does not
currently employ cathodic protection systems and, therefore, such testing is not required at this
time. However, if in the future such s5^$terns were to be utilized these records would be retained
in accordance with Section i .10 of the SPCC Plan.
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65 (
Storm Water Management
Page 2 of 22 :
2. Please clarify the protocols to determine whether used oil generated at the White Mesa
facility is determined contaminated (i.e. 1 le.(2) byproduct material) and disposed of in the
tailings cell, or detennined uncontaminated (or not 1 le.(2) byproduct material) and sent
offsite for recycling. ^
Denison Response;
Used oil at the WTiiie Mesa Mill that has the potentiarfor having been^^^
radioactive material (such as that which may be generated by cleaning of machinei^ in the shop /
and received by the floor drain and conveyed to the used oil tank) is disposed onsite in the Mill
tailings impDundment. Oils that are intemal to plant machinery (such as vehicle engines) are not
subject to contamination potential and can be drained for offsile recycling. Currently, the oil that
is retained in the ased oil tank has received floor drain materials frorn the shop and
disposed in the tailings impoundment as 11 e.(2) byproduct mate^^^
An additional RFI will be included per DRC review of the response conceming cathodic protection
(item 1) as detailed per the 2010 inspection findings and per the RFI issues outlined in the conclusion
at the end of this memo. Specifically, DRC is concerned that although no underground tanks are
emplaced at the White Mesa Mill, there are on-grade tank installation where the bottom of the tank is
in intimate contact with soil.
Sunnnarv of Recommendations Made to DUSA Regarding Previous (2009) Inspection Findings
(December 12, 2009 PRC Letter);
October 2009 Recommendations:
Recommended Actions:
Recommendations related to Storm Water Documentation at the Mill
• Part 4.1.4of the Storm Water Best Management Practices Plan requires a weekly inspec
of diversion ditches, drainage channels and surface water control structures in and around the
mill area, Per DRC findings the White Mesa Standard Operating Procedures, Book 11,
Environmental Protection Manual, Section 3.1 includes forms for Daily Inspections, Weekly
tailings Inspections, and Monthly Inspections. DRC noted that the diversion Ditches and
Berms are included on the Monthly inspection form (not weekly as included as Part 4.1.4. of
the SWBMPP). DRC recommends that Denison insure that all documented inspections
match the frequencies specified in the SWBMPP (including appendices).
• Similar to die recommendation above, DRC noted tiiat the SPCC Plan Part 1.10 refers to a
Quarterly Tailings Inspection. DRC noted that the Tailings Inspections are likely done on a
shorter time schedule (daily inspections) and that a Quarterly Inspection Data form did not
appear to exist. DRC again recon^nends that all documented inspe^^^
frequencies specified in the SWBMPP.
• SPCC Plan Part 1.9.2 - It was reported onsite that no "reportable quantity" spills had
occurred at the facility over the period of records reviewed (RQ's from 40CFR117). DRC
noted that there was not a process to document smaller spills, less than reportable quantities.
DRC recommends that a process be developed for employee reporting and documentation of
smaller quantity spills and clean up actions to be included in the SWBMPP/SPGC and that a
log or other documentation is generated to clarify clean-up actions. Section 4.2.1 of the
SWBMPP refers generally to this requirement; the Ground Water Perniit (Part I.D. 10) also
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 3 of 22
requires the control of contaminant spills and immediate clean-up upon discovery (regardless
. of quantity). DRC is only recommending this measure at this time.
• SPCC Plan 1.10 - It was noted that the daily, weekly and monthly inspection data reports do
not include a field for follow up actions. DRC recommends that follow up actions, and dates
of completion, relating to any problems noted during the inspection be logged on the same
inspection data form.
Site Walkthrough Recommendations (Previoiis 2009 Inspection)
• During the site walkthrough of the shop area, DRC noted that a floor drain is located inside of
the vehicle maintenance area which drains to an outdoor storage tank (See photo log, photo
4). It was reported by Denison that any oil contaminated water in these tanks is pumped to
the used oil tank and that uncontaminated water is pumped to Roberts pond. DRC noted that
the current process creates a larger quantity of contaminated water (commingling of process
water and storm water) and recommends that the indoor drain be blocked and that any indoor
spills be cleaned up at the spill location.
• DRC noted that the SX building roof is curiently routed into the concrete containment vault
inside of the building. DRC recommends that the roof drains be inspected, and the results
documented, during a storm event to insure that the mnoff is effectively drained to that point
and is not contributing to any ponding of stormwater in the area of processing
• DRC noted that the secondary containment for the caustic soda tank was highly deteriorated.
DRC recommends that the secondary containment floor for the caustic soda tank be repaired
or replaced. (See photo log, photos 27, 28 and 30)
• DRC noted that the secondary containment for the soda ash tanks showed cracldrig on ^t^^
floor (See photo log, photos 33 and 34). DRC reconmiends that the cracks be
sealed/repaired.
Altemate Feed staging is curirentiy conducted on the south side of the processing area on the
soil without berms or coniddnmQnt. (note that Denison made no comment regarding this issue
and provided no action to resolve the recommended actions by DRC) DRC noted that one of
the drums which had been removed from its overpack was badly corroded and that altemate
feed material (black flake) was visible through a hole in the top of the barrel (see photos).
DRC also noted that a trace amount of the black flake was visible on the ground at the base
of the dmm. Although the storage during staging is not currentiy a violation of the ground
water permit, please be advised that Part I.D. 11 of the revised perrpit will include BAT
requirements for feedstock material storage. It is recommended that the barrels be kept in the
overpack until ready to be loaded onto the altemate feed rack within the containrrient area or
other altemative method at the discretion of Denison.
became a ground water permit violation per a 1/10/2010permit modification.of Part l.D.ll. This is
discussed in more detail in comments/observations related to the alternate feed circuit below)
• DRC noted that when water from the decontamination pad tanks is transferred to the concrete
vault (flushed from the recycle tanks) it is allowed to discharge across open ground. DRC
( recommends that piping from the decontamination tanks be extended to the concrete vault to
avoid potential erosion impacts and/or infiltration concems (see photos).
October, 2010 Inspection (Current), DRG Staff Finding^:
Section I " Document Review
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65 '
Storm Water Management
Page4of 22
SWBMPP (Documentation Requirements):
Part 4.1.4.—Diversion ditches, drainage channels and surface water control structures in and
around the Mill area will be inspected at least weekly. Areas requiring maintenance or repair,
such as excessive vegetative growth channel erosion or pooling of surface water runoff, will be
reported to appropriate departments and all follow up actions are to be documented.
Findings:
Diversion Ditch 1 showed excessive vegetation growth as wellas evidence of rilling and erosion on
the side banks (See Attached Photos 42, 43, 44). DRC communicated these issues during the
inspection and onsite personnel reported that they woiild provide remediation of the banks
immediately. • . • . • . •
In response to this issue DRC received an e-mail from DUSA (from Dave Turk) on 10/19/2010 (same
day of the inspection) which notifies DRC that the diversion ditches were cleaned of vegetation (via
grading) and provides 3 photos (below):
3 Photos - Attached to DUSA e-mail to DRC dated 10/19/2010 showing Diversion Ditch
Maintenance
Diversion Ditch 2 was in reasonable conditions (Attached Photo 45). DRC noted minor
amounts of vegetation in the ditch.
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page5of 22
Per DRC review of the DUSA Inspection Forms, it was noted that the Diversion Ditches and
Berms are inspected monthly (note that Part 4.1.4 of the SWBMPP requires that these
inspections be done at least weekly). Per review of the forms, DRC did not find any
observations by DUSA regarding the excessive vegetation in Diversion Ditch 1 (contrary to
DRC observations during the October 19, 2010 inspection). The DRC staff recommend that
these issus be included in a Confirmatory Action letter to DUSA, citing violations of the
Permit Part LD. 10(a) and the SWBMPP Part 4.1.4 for:
1. Failing to provide inspections of the diversion ditches weekly, and, v
2. Failing to clean the diversion ditches of excess vegataion which is a failure to
provide active operation measures.
As per above discussion above, DRC comments during the 2009 inspection (December 12,
2009 Recommendations) it was noted in a letter as a recommended action that the inspection
of diversion ditches be conducted and documented weekly as required by the SWBMPP.
However, this item was not responded to or addressed and it appears that the monthly reports
were made without a physical examination of the ditches (inspection findings were
documented but no inspection was completed).
Spill Prevention, Control, and Countermeasures Plan (SPCC) (Docunientation
Requirements):
1.6.1. - Daily monitoring of propane tanks required.
Findings:
Per DRC review of the forms it was noted that the inspection of the propane tanks is included
on the daily foreman's inspection forms, however this is only a checklist and does not require
specific items to be checked or specifically include the petroleum tanks, or their individual
condition. The same comment was made per the 2009 inspection, See the; ''December 10, ,
2009, Groundwater Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo, page T as well as iht^'December 12, 2009
DRC Findings Letter, page 2/'
"DRC noted that the fuel area is included on the "Operating Foreman's Daily Inspection"
form, however the form does not specifically refer to the petroleum tanks within the confines
of the facility, or indicate how thorough of an inspection is conducted."
During the October, 2010 inspection, DRC staff also noted that there was a small volume
diesel spill on the refueling pad during the inspection (Attached Photo 5). No evidence was
found during the inspection that DUSA cleaned this spill up.,
1.9.1. - External Notification of "reportable quantity" spills.
Findings: During the October, 2010 inspection, the facility representative stated that there
have been no reportable quantity spills (as per the Community Right to Know Act, EPCRA)
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 6 of 22
at the facility. DRC confirmed that over the period since the last inspection no reportable
quantity spills (> 100 kg) were documented. Further, DRC review of DUSA records found
no spills of any size were recorded on any of the self-inspection documents.
1.9.2. Internal Notification of incidents, spills, and significant spiU^^^
Performance Standards (list):
Findings: Per the 2009 observation conceming the reporting of smaller quantity spills, the
following observation was made (December 12,2009 DRC letter, page 2): "DRC noted that
there is not a process to report small quantity spills at the site. DRC recommended that a
process be instituted to insure that employees know who to contact regarding small quantity
spill and follow through with a process of clean-up."
DRC notes that the Groundwater Discharge Permit Part LD.lO(c) requires DUSA to
''Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery"' and that the Permit part LD. 10(d) requires DUSA to "report reagent spills or
other releases at the mill site to the Executive Secretary in Accordance with Utah
Administrative Code (UAC) 19-5'114:'' UAC 19-5-114 states that "Anyperson who spills or
discharges any oil or other substance which may cause the pollution of the waters of the state
shall immediately notify the Executive Secretary ofthe spill or discharge, any containment
procedures undertaken, and a proposed procedure for cleanup and disposal, in accordance
with rules of the board '' While DRC agrees that small quantity spill would likely not pose a
threat to waters of the State if cleaned up appropriately, the Administrative Code and Permit
requirements do not state a minimum quantity of substance spilled requiring notification
from the company. Per the 2009 recommendation, DRC is allowing the reporting for small
quantity spills (Less than the quantity required to be reported under iht Emergency Planning
Community Right to Know Act Reporting Requirements(Clean Water Act Section 311 and
Code of Federal Regulations Title 40 Part 117) to be an inhouse process of documentation
which can be reviewed by the Executive Secretary during the annual storm water inspection.
Per these findings, the 2009 module included a "recommendation" to institute a process*^for
employee reporting and documentation of small quantity and clean up actions (Deceniber 12,
2009 DRC letter, page 2).
Per the 2010 inspection it was noted that the 2009 reconmiendation was not addressed by
DUSA, and per interview with the onsite representatives it appeared that creating such a
process was not being considered. Failure to institute the spill reporting process is in
violation of the groundwater permit parts LD 10(c) and (d) as well as UAC 19-5-114. It is
therefore recommended that this item be included for follow up as a reqiiest for information
item to insure that information regarding process needs and a schedule of implementation for
reporting and documentation of clean up of oil and reagent spills. Failure to provide such a
process is not in conformance with the SWBMPP Part 4.2.1.
Form updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page7 of 22
1.10 Records and Reports.
Period of Records Examined During Inspection:
^ Begin/Ending: 4/1/2010/4/30/2010 and daily 9/23/2010
No. of On-site Records Required: Daily, Weekly and Monthly Forms
No. of On-site Records Found: All Records/Reports Onsite
No of Records Examined: 10% (Percent of Total)
How Selected: DRC Inspected a full month of daily, weekly and monthly forms as
well as the daily (9/23/10) form which included a visual inspection
of the SX building roof runoff. /
Daily Tailings Inspection Data:
Findings: Daily inspection of tailings slurry transport system, operational systems (water
level, beach, liner and cover), dikes and embankments, physical inspection of the slurry tines,
dust control and leak detection was implemented and documented on an inspection form.
See attachment 1 (Daily Inspection Form). DRC reviewed all ofthe fomis for the month of
April (April 1, 2010 through April 30, 2010). This month was picked at random. DRC also
reviewed the daily inspection form for 9/23/2010, this report was chosen since includes an
addendum with observations, post rain event, of the SX building roof drainage. DRC noted
that each quarter of reports was organized in a separate hard copy file. All of the reports
(daily, weekly, monthly) were on file for the reviewed month (April, 2CI10). DRC did note
that there was no quarterly report and it was reported by DUSA staff that ins^^
required quarterly were included on reports at a higher frequency. The DUS A onsite
representative (David Turk) indicated that the higher frequency would be more protective of
the environment and should be allowed as an improvement to the inspection process. DRC
advised DUSA that a more frequent inspection was hkely more protective, but that the storm
water best management practices plan needed to be updated to reflect the current inspection
process and frequencies in order to avoid confusion.
Per the 2009 storm water inspection, DRC noted that follow up actions (resolution of noted
problems) were not documented on the actual daily form (December 12, 2009 DRC letter).
DRC recommended that the follow up be documented on the daily form. The issue of
follow-up actions and date of completion of follow up being documented on the same
inspection form (as the one where the problem was identified) was disciissed with David
Turk during the October, 2010 inspection. He agreed that this process could be improved
and agreed to modify the inspection fomi to include a section for follow up actions needed
and dates of completion.
Per follow up of this item during the 2010 inspection it was found that the inspection forms
have not been modified to include date/time of follow up actions on the same form, therefore,
it is still necessary to look at additional forms (following forms) to determine if follow up
actions were taken.
DRC will include the issue of follow up actions for daily inspections as well as updating the
SWBMPP to accurately reflect the inspection frequencies as a "Request for Information"
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page 8 of 22
item since these issues are not specific violations of Rule, Permit or Plan. DRC recognizes
that the company has different options in terms of how to better track deficiencies noted
during an inspection. The issue may be addressed on the current inspection forms, or DUSA
may opt to initiate a separated tracking system (e.g. a monthly non-compliance report) to
document inspection deficiencies and follow-up actions.
Weekly Tailings Inspections and Sur^vey:
Findings: The weekly tailings inspection was done and documented on a weekly tailings
inspection form. The forrn includes sections to document pond elevations (solution
elevation, FML bottom elevation, and depth of water above FML) for cell 1, 3, 4A and
Roberts Pond, as well as shmes drain hquid levels in cell 2. The form also includes
information regarding the leak detection systems for cells 1, 2, and 3 and 4A as well as
potential blowing of tailings. The form, as part of the Standard Operating Procedures, also
includes sections for reporting pararneters about the Leak Detection Systems (part of the
DMT plan requirements, not storm water related). Per the 2009 inspection, DRC had no
comments regarding the weekly tailings inspection (see December 12, 2009 DRC letter). Per
this 2010 inspection, the weekly form still meets the required frequency, and appears to
include required infonnation. However, per in-house discussions amongst DRC staff, it was
noted that in order to avoid confusion it may be preferable to organize inspection protocols
for storm water requirements separate form engineering related topics. This topic will be
reviewed again during the 2011 storm water inspection, and options regarding the forms will
be discussed with onsite DUSA representatives.
Monthly Tailings Inspection, Pipeline Thickness:
Findings: The monthly inspection report includes a summary of the slurry pipeline condition
and measurement of pipe thickness during 2010. Per the 2009 inspection (^December 10,
2009, Ground Water Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo, page 4), it was noted that the March 21, 2009
monthly report did not include a measurement of pipe thickness due to the mill being in non-
operational status.
The monthly report additionally contains inspection protocols and observations related to the
diversion ditches and berms, sedimentation pond, dust control, settiement monitors and
slimes drain static head measurements for cell 2. Per above (weekly form comments) DRC
will require that follow up actions regarding, any findings or maintenance needs be included
on the same inspection form or per an altemative method such as the use of an intemal non-
comphance report which cotild by developed by DUSA. Per above, this issue will be
included as a "Request for Information" item.
Quarterly Tailings Inspection:
Findings: During the October, 2010 inspection, DRC staff noted that there is not a Quarterly
inspection form. It appears that all inspections required on a quarterly inspection frequency
are conducted at other (shorter) frequencies and are recorded on altemate forms. Per
Form Updated December 14, 2010
White Mesa Mill
Ground Water Module 65
Storm Water Management
Page9of22 '
discussion above in the daily inspection RFI section, these are not specific violations of Rule
or the Groundwater permit, however, the DUSA facility SWBMPP does need to be kept
current, thus, this item will be included in an RFI letter to the facihty.
Tank to soil potential measurements:
Findings: This item was iiicluded as a request for information to the facility on the 2009
Findings and RFI Letter, the response from DUSA is below:
DenisQii Respoiigte;
Upon review of the SPGC Flan Denison notes that tank to soil potential measurements are
referred to at Section L lO of the Plan widiin the context of a mcord that would be maintained
should such measurements actually become necessary. Soil to tank potential measurements are
utilized to test cathodic protection systems for underground tanks and piping, Denison does not
currently employ cathodic protection systems and, therefore
time« However Jf in the future such systenis were to be utiliz^^
in accordance with Sec^oa LIO ofthe SPCC Plan.
DRC notes that although DUSA states that no underground storage tanks are currentiy
emplaced at the White Mesa Mill, there are several tanks which are sitting on the ground and
can not be visually inspected (On Grade Tanks). DRC will therefore request additional
information from DUSA regarding their current inspection protocols for on-grade tanks.
Cathodic protection is needed for DUSA to comply with Part I.D. 10(a) of the groundwater
permit (to insure integrity of the bottoms of tanks which are installed on-grade).
Annual bulk oil and fuel tank visual inspections:
Findings: Per the DRC 2009 inspection review comments (December 10, 2009, Ground
Water Module 65 Inspection^ Storm Water Best Management Practices Plan (SWBMPP)
Inspection, DRC Review Memo): tank condition is not specifically checked by the mill. DRC
did note that a general inspection of the tank area is conducted (hsted as fuel area) and
documented on the operating foreman's daily inspection log, however, this does not
comprehensively address the conditions of each tank at the facility. DRC also noted that :
daily volume measurements are recorded for the fuel tanks, but, again, the tank condition is
not taken into account. These omissions on DUSA inspection reports were noted to be the
same per the 2010 inspection. Per DRC review of the facility Groundwater Permit and
SWBMP it was noted that there is not requirement fpr DUSA to inspect and document the
condition of these tanks. It is recommended that inspections to visually inspect the integrity
of each of these tanks be included in the permit at atleast an annual frequency (Item to be
included in a Ground Water Permit Modification).
DRC noted that the diesel storage tanks located on the north side of the mill building (2
tanks, 250 gallons each) do not have secondary containment systems. The unleaded gasoline
tank does include a 3,000 gallon secondary containment structure which is the same volume
as the tank. Diesel tanks at the pump station include secondary containment for the volume
of 1 tank (2 tanks located inside of the containment). DRC will insure that potential issues
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regarding these tanks are addressed with the SPCC review "Request for Information" as
described below.
Tank and pipeline thickness tests:
Findings: Per^DRC review the only thickness test noted was the slurry pipeline thickness and
this is only taken during times when the Mill is operating. No issues were noted during the
inspection regarding this requirement.
Quarterly and annual PCB transformer inspections (curriently PCB only):
Findings: Per the 2009 inspection, the facility reported that there are currently no PCB
transformers at the site. DRC discussed that the SPCC mle, 40CER112 has been updated to
include non-PCB oil types. Denison agreed to review the new language and update the
SPCC plan as appropriate. Per the 2010 follow up, it does not appear that the SPCC plan has
been re-evaluated per the 2009 recommendation (December 12, 2009 DRC Letter). DRC
will include this issue as a request for information item, to ensure that all inspections are
consistent with the current SPCC regulations. Also, DRC will request information regarding
the current inventory of petroleum stored at the mill to insure that all oil types and tank
quantities, secondary containment (tank descriptions) included on the mill inventory list are
consistent with current SPCC requirements.
Tank supports and foundation inspections:
Findings: The operating foremans daily inspection provides a general inspection of the Fuel
Area, but does not provide a specific inspection of tank suppori^s and foundation. This item is
also covered in the tank condition inspection section above. DRC noted that the inspection
frequency is not noted, it was interpreted that this inspection relates to a visual inspection of
the integrity of tank supports only and is likely conducted with the tanks condition repprt.
DRC will follow up with this item during the 2011 stomi water inspection. Specifically,
DRC will insure that tank supports and foundations are inspected and documented with the
tank coifidition reports.
Spill Incident Reports:
Findings:; No spill reports/incident reports were filled out on any of the DUSA inspection
forms examined during the October, 2010 inspection. Denison representative reported that
there have been no spills. Per comments above, DRC will include a "Request for
Information" to insure that small volume (smaller than reportable quantity spills) and follow
up (clean up) and documentation protocols associated with the spills is implemented.
Latest revision of SPCC plan (onsite and available?):
Findings: The cuirent SPCC plan (dated June, 2008) was onsite and available during the
inspection.
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1.11 Personnel training and Spill Prevention Procedures (records of training required
to be maintained in the general safety training files):
DRC reviewed the log of people who have been trained to conduct the daily inspections at
the White Mesa facility as below
Period of Records Examined:
Begin: October 23, 2009 \
Ending: October 19, 2010
No. of Records Found: 13
No of Records Examined: 13 (100 Percent of Total)
How Selected: Comprehensive Review of this Training
Findings: DRC found that specific to 2010, 4 people had been trained including those
conducting current daily inspections at the site. The Radiation Safety Personnel also signed
the forms certifying the trainee as qualified to conduct the daily inspections.
Regulatory Requirements (Ground Water PermitUGW370004^ Utah Administrative Code
(UAC) and Utah Code Annotated (UCA)
This section quotes the White Mesa Ground Water Quality Permit and SWBMPP to clarify
issues of non-compliance and/or nonconformance with the requirements.
In the Ground Water Permit:
The ground water permit Part LD.IO requires provisions in the facility SWMPP to: 1. Protect
groundwater quality or other waters by design, construction, and/or active operational
measures that meet the requirements of Ground Water Quality Protection Regulations (UAC
R317-6-6.3(G) and R317-6-6.4(C), 2. Prevent, control and contain spills of reagents and
chemicals, 3. Clean up spills of reagents or chemicals immediately upon discovery.
UAC R317-6-6.3(G) .states "Information which shows that the discharge can be controlled
and will not migrate into or adversely affect the quality of any other waters ofthe state,
including the applicable surface water quality standards, that the discharge is compatible
with the receiving groundwater, and that the discharge will comply with the applicable class
TDS limits, ground water quality standards, class protection levels or an alternate
concentration limit proposed by the facility."
R317-6-6.4(C) states "The Executive Secretary may issue a ground water discharge permit
for an existing facility provided:
1. the applicant demonstrates that the applicable class TDS limits, ground water quality
standards and protection levels will be met;
2. the monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
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3. the applicant utilizes treatment and discharge minimization technology commensurate
with plant process design capability and similar or equivalent to that utilized by facilities
that produce similar products or services with similar production process technology; and,
4. there is no current or anticipated impairment of present and future beneficial uses ofthe
groundwater."
C/AC/?3i 7-(5-6.5(G)an<i/?5/7-6-6.4 refer to requirements for ground water p^
applications and require that any discharges will be consistent with ground water class limits,
appropriate discharge minimization technology is in place etc.
(UCA) 19-5-114 requires that a person who spills any substance which may cause pollution
of waters of the State (includes groundwaters) is required to "immediately notity the
executive secretary of the spill or discharge, any containment procedures undertaken, and a
proposed procedure for cleanup and disposal, in accordance with mles of the" water quality
board.
The following quotations are from the White Mesa Stormwater Best Management Practices
Plan (pp. 4 - 7). These quotation refer specifically to best management practices that have
been approved by the Co-Executive Secretary to be followed by DUSA.
Best Management Practices Plan (June 2008), List of General Best Management Practices
(Performance Standards) applicable to all areas and specific areas of the site (Section 4.0 of
the SWBMPP) as listed below
All Areas:
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 thexontainers covered when not in use.
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)
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. 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
Permit No. UGW370004 and Byproduct Materials License #UT19^
Areas requiring maintenance or repair, such as excessive vegetative growth,
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channel erosion or pooling of surface waterrunoff, will be reported to the site
management and maintenance departments for necessary action to repair
damage or perform reconstmction 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
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
Process and Laboratory Areas:
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
• 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 niinimum amount of water needed for
effective cleanup
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 dmms 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.
3 Water Management '
• Whenpossible, 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 Materials Management
• Purchaseandinventory the smallest amount of laboratory reagent necessary
• Do not stock more of a reagent than will be used up before its expiration date
• All new constmction 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.
Maintenance Activities:
\ Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly
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• Designate specific areas indoors for parts cleaning, and use cleaners and solvents
only in those areas
Clean up spills promptly
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 to capture leakage and contain spills
Manage Vehicle Fluids
Drain fluids from leaking or wrecked/damaged vehicles and equipnient as soon
as possible
Promptiy 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
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 a disposal location in the tailings area authorized to accept waste
materials from maintenance or construction activities
Use Controls During Paint Application and Cleanup
Mix and use the right amount of paint for the job. Use up one container before
opening a second one
Recycle or reuse leftover paint whenever possible
Never clean bmshes 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 •
Ore Pad, Tailings area^ and Heavy Equipment ^
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 tmck wash station, make sure the water collection and recycling system is
working before tuming on water sprays
2 Manage stockpiles to prevent windbome contamination
• Water spray the ore pad and impaved areas at appropriate frequency in
accordance with Mill SOP's
• Water spray stockpiles as required by opacity standards or weather conditions
• Don't over-water. Keep surfaces moist bllt niinindze runoff water
3 Keep earthmoving activities from becoming pollutant sources
• Schedule excavation, grading and other earthmoving activities when extreme
dryness and high winds will not be a factor
• Remove existing vegetation only when absolutely necessary
• Seed or plan temporary vegetation for erosion control on slopes
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Section II— Site Walk Through Inspection
Areas and Observations:
Ore Storage:
Observations (attach extra sheets if needed): Ore is currently being stockpiled at the facility
until a large enough quantity is stored for an ore run. DRC noted that a runoff drain (piped to
the tailings cells) was constructed at the southwest comer of the ore storage area per past
DRC comments and that the drain appeared to be clean and that the overflow pipe was
visible above accumulations of sediment. Although accumulations of silt/clay were within
the drain it did not appear that the integrity of the drain was iinpacted and that it was likely
free draining. Also, the berm on the eastem side of the tailings storage area' had been re-
graded and heightened and appeared improved over what was observed during 2009. (Photos
1 and 2) DRC had no additional recommendations conceming this area.
Reagent Yard:
Observations: (attach extra sheets if needed): A new, enclosed, reagent building is has been
constmcted for dry chemical storage (Photo 39).
Per DRC inspection of the reagent yard it appeared that dram storage was appropriate. No
degraded or tapped drums were noted in those areas. (Note that altemate feed/intermediate
product dram storage are logged in other sections below)
ShopA^ehicle Maintenance Area:
Observations: Per the 2009 walkthrough comments it was nottd ihdl {December 10, 2009,
Ground Water Module 65 Inspection, Storm Water Best Management Practices Plan
(SWBMPP) Inspection, DRC Review Memo):
"DRC noted that a floor drain was located inside of the building which drains to an outdoor
storage tank (below ground concrete vaults). It was reported that any oil contaminated water
in these tanks was pumped to the used oil tank. DRC noted that this creates a large quantify
of contaminated storm water and recommended that the indoor drain be blocked and that
indoor oil spills be cleaned prior to contamination of storm water. If the water in the vault is
determined to be uncontaminated then it is transferred to Roberts Pond."
Per the October, 2010 inspection, DRC noted that the interior floor drain was still open and
operating (Photo 7) and that no reconfiguration or process changes had occurred in response
to the DRC findings. Since these issues are in conflict with the best management practices
quoted above, specifically since the interior drain and containment area produce a larger
volume of contaminated fluid (mixes with storm water), this item will be included as a
request for information forfollow-up.
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Mill Processing Areas:
Two specific areas of observation comments were noted during the 2010 site walk through as
below.
Observations 1: SX Building Roof Drainage Runoff- The 2009 DRC inspection
recommendations included this as an item and recommended that the SX roof drainage be
evaluated (per an onsite personnel inspection) to evaluate whether the current system was
adequate to avoid roof drainage downgradient into the altemate feed circuit. It was noted
that this onsite inspection was conducted on 9/23/2010 by David Turk and that the comments
were included as ari addendum to the daily log. Per the 9/23/10 DUS A inspection onsite
personel observed that the current drainage system is "not adequate." In follow up the
9/23/10 inspection states that "the drainage system needs to be addressed by the engineer and
have the situation corrected." DRC will include a request for information to determine what
findings have been made and if any corrective actions were conducted.
Observation 2: Vanadium intermediate product stored in open drums (Photo 17). DRC
noted that approx 20 open drams, containing product, were located onsite directly
downgradient from the existing decontamination pad. If was noted that these drams are
located within the "Feedstock Storage Area" as defined by coordinates listed in the
Groundwater Permit Part I.D.3.F. Therefore no additional follow up will be done regarding
the observation.
Alternate Feed Circuit South of SX Building:
Observations: During the October, 2010 inspection, DRC observed the new altemate feed
processing area. It was noted that drainage within the containment area was pumped into
overhead tanks. During the inspection jit was reported by David Turk that a Denison
employee was posted at the altemate feed location 24 hours a day, 7 days a week, see Photos
33 through 35. DRC noted that drums jof black flake were still being staged on soil areas
adjacent to the altemate feed circuit. Per the 2009 recommendations, DRC stated (December
12, 2009 DRC Findings Letter, p. 3):
• Alternate Feed staging is currentijj conducted on the south side of the processing area on the
soil without berms or containment. DRC noted that one of the drums which had been
removed from its overpack was badly corroded and that altemate feed material (black flake)
was visible through a hole in the top of the barrel (see photos). DRC also noted that a trace
amount of the black flake was visi|ble on the ground at the base of the dram. Although the
storage during staging is not currehtly a violation of the ground water permit, please be
advised that Part I D. 11 of the revised permit will include BAT requirements for feedstock
material storage. It is recommended that the barrels be kept in the overpack until ready to be
loaded onto the altemate feed rack within the containment area or other altemative method at
the discretion of Denison. !
• •. • •. : " I •' ..• . ' • ^ ••: „:.:•
Per the 2010 inspection findings it was| noted that the same issue was present onsite. Several
barrels of altemate feed material (black flake) were found stored (staged) on soil on the south
side of the processing area, west of the SX building, without overpacks in badly deteriorated
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drums which had been perforated on the side and without cover (see photos 36, 37, 38). -
Therefore, Denison Mines ignored the recommendations of the 2009 inspection
correspondence.
The Denison Mines Groundwater Permit, Part LD. 11 (BAT Requirements for Feedstock
Material Stored Outside the Feedstock Storage Area was modified on January 20, 2010 and -
states:
"BAT Requirements for Feedstock Material Stored Outside the Feedstock Storage Area -
the Permittee shall store and manage feedstock materials outside the ore storage pad
in accordance with the following minimum performance requirements:
a) Feedstock materials will be stored at all times in water-tight containers, and
b) Aisle ways will be provided at all times to allow visual inspection of each and
every feedstock container, or
c) Each and every feedstock container will be placed inside a water-tight overpack
prior to storage, or
d) Feedstock containers shall be stored on a hardened surface to prevent spillage
onto subsurface soils, and that conforms with the following minimum physical
requirements:
1) A storage area composed of a hardened engineered surface of asphalt or
concrete, and
2) A storage area designed, constructed, and operated in accordance with
engineering plans and specifications approved in advance by the Executive
Secretary. All such engineering plans or specifications submitted shall
demonstrate compliance with Part I.D.4, and
3) A storage area that provides containment berms to control stormwater^ run-on
and run-off, and
4) Stormwater drainage works approved in advance by the Executive Secretary,
or ^ • _ , '
Other storage facilities and means approved in advance by the Executive Secretary "
Therefore, the storage practices observed in October, 2010 are a violation of the
Groundwater Permit Part LD.11, for the following reasons:
1. Feedstock Staging and Management - staging of feedstock in preparation of
its entry into the altemate feed circuit is part of feedstock management, and
subject to the requirements of Part I.D. 11 of the Permit
2. Observed Feedstock- during the October, 2010 inspection DRC observed:
a. Feedstock material was not stored in water tight containers,
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b. Feedstock material was not stored on a hardened engineered surface
or asphalt or concrete,
c. Feedstock material was not stored in a designed and approved
storage area (by the Co-Executive Secretary), or other approved area,
d. Feedstock material was stored in open and degraded containers
containing placed on soil and located outside of the feedstock
management area.
As a result, DRC staff recommend that the feedstock management violation be included on
the confirmatory action letter..
Old Decontamination Pad:
Observations: Wash water is recycled until too dirty to be used effectively for vehicle
washing, the water is then discharged to a below grade tank thence to the process water pond.
DRC noted that the concrete collection vault for overflow from the pad (thence discharging
to Roberts Pond) was repaired per the inspection findings listed in the 2009 DRC review
memo and Findings Letter. Specifically it was noted that the discharge from the
decontamination pad holding tank was piped completely to the wash-out tank. It was noted
that the wash-out tank was full of sedimeht and required clean-out. Note that this
decontamination pad is seldoin used since commencement of operation of the new facility.
DRC has observed the pad during visits to the facility subsequent to the inspection and
verified that the old pad is defunct. No further action will be conducted related to the
findings at the old decontamination pad.
New Scale House Decontamination Pad:
Observations: The new decontamination pad (facility) was not in operation at the time of the
storm water inspection. The baffle water containment^treatment tanks had been drained of all
water and a black sealer was apphed on all interior seams (See Photo 3 and 4). Onsite DUSA
representatives stated that the containment system was being preparedfor a hydrostatic test
to prove tank integrity. Note that the tank improvements were being coiiducted during no-
operation period ofthe new decontamination pad. No further action will be conducted per
observations at the scale house decontamination pad.
Reagent Tanks:
Sodium Chloride Tanks - DRC noted that the containment area was earthen. It was
reported that this was allowable due to the age of the tanks. Per discussion between TR and
LM it was noted that LM had a past discussion with Harold Roberts regarding the secondary
containment. An agreement was forged that all reagent tanks that pre-existed the Ground
Water Permit (3/05) would be acceptable as is - and that as upgrades or replacements were
installed, DUSA would work to meet BAT requirements. More detail regarding this
agreement is in the December 2004 Statement of Basis, and in Part I.D.3(g).; See Photo 15.
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Kerosene Tanks — DRC noted that the containment area was earthen. It was reported that
this was allowable due to the age of the tanks as discussed in the Sodiurn Chloride Tank .
Section above. Photo 14 \
Ammonia Tanks — DRC noted that the containment area was earthen. It was reported that
this was allowable due to the age of the tanks as discussed in the Sodium Chloride Tank and
Kerosene Tank sections above. Photo 13
Used Oil Tank - Appeared to have appropriate secondary containment. No records
conceming visual inspections of tank integrity. Photo 6
Kerosene Tank - Located in the same secondary containment area as the used oil tank.
Facility reported that this was acceptable (by rale) as long as the containment was
constructed for the largest tank. This criterion is consistent with past inspections by DRC at
the site with similar findings. Photo 6
Fuel Tanks ~ Above ground tanks appeared maintained and had secondary containment.
Photo5
Uranium Liquor Tanks - Containment areas appeared to be in good condition. Photo 18
Vanadium Pregnant Liquor (VPL) Tanks - Per comments related to an Engineering
(Discharge Minimization) inspection conducted by DRC personel during 2010 it was noted
that steam condensate from the VPL tanks was being allowed to accumulate in the area of the
tanks and around the tanks. In response to these comments DUSA has agreed to provide a
concrete secondary containment and punipout system for the steam condensate (this item is
being tracked under separate cover). For additional information, see DUSA letter dated July
15, 2010 and DRC response dated September 27, 2010. DRC noted per this inspection that,
pending the constmction of the containment pad, DUSA has provided drain extensions and is
discharging the water into storm drains away from the VPL tanks (Photos 11,12). DRC will
follow up with this item as necessary to insure that condensate water or upgradient runoff
does not accumulate in the VPL tank area.
Clean Water Tank - DRC noted that the clean water tank valve was not sealed, the valve
was leaking water (exact volume/time was not measured) at approx 60 gallons/minute. Photo
19. The repair of this valve will be included as a request for information item to insure that
water is not surface ponding in the confines of the facility without adequate engineering
controls (eg liner).
Sulfuric Acid Tank - The tank appeared in good condition. DRC noted that a new berm
was recentiy constmcted around the sulfuric acid tank. Onsite DUSA representatives
reported that this was done in response to historical DRC comments regarding potential large
scale breaches of the tanks. DUSA representative also reported that if such a breach occurred
it could impact a transformer station (electric power) located approx 200 meters east of the
tank. Photos 21, 22 & 23
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Propane Tank - No issues observed. DRC noted that the valves and air quality system was
recentiy replaced. Area was clean. Photo 25 ^
Caustic Soda Tank- Secondary Containment was not in good condition. Concrete was
highly degraded and appeared to have holes extending to underlying earthen material. The
DRC 2009 recommendation was to repair or replace the secondary containment floor. This
recommendation item was not addressed and therefore will be included with the 2010
Confirmatory Action items. Failure to maintain the integrity of the secondary containment is
a violation of the Groundwater Permit Part LD.lO.b. (See photos 29, 30)
Soda Ash Tanks - Secondary containment floor showed cracks. DRC 2009
recommendation was to repair or replace the secondary containment floor. The
recommendation was not addressed and will therefore be included on the 2010 Confirmatory
Action Items. Failure to maintain the integrity of the secondary containment is a violation of
the Groundwater Permit Part LD.lO.b.
Tailings Cells Areas (Note that upland drainage was included in comments above) -
DRC toured the tailings cell areas (Cells 1,2, 3, 4A and 4B (under construction at time of
inspection) and observed the condition of the outer toe areas of the dikes to insure that
excessive erosion or damage (e.g: burrowing animal intrusion or rooting damage) was not
present. Per the DRC review the dikes appeared in good condition.
Summary of Onsite Closeout Meeting: An onsite close-out meeting took place between
Tom Rushing (DRC) and David Turk (DUSA). During this meeting DRC informed the
DUSA representative of the issues stated in the inspection above. It was especially noted that
the DRC 2009 recommended actions were for the most part not addressed and that these
items would likely be included as confirmatory action items for the 2010 correspondence.
Date/Time: 10-19-2Q10/1300
DUSA Representatives Present--David Turk, RSO
DRC Representatives Present - Tom Rushing, P.G.
Conclusions
DRC will arrange a conference call with DUSA representatives to discuss the confirmatory
action items and request for information items detailed above and summarized below. It is
anticipated that compliance schedules (deadlines) will be negotiated and finalized during the
conference call:
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The CAL items are:
1. DUSA has violated the Groundwater Permit Part I.D.I 1 by faihng to manage drums
containing altemate feed material (located outside of the feedstock management area)
in compliance with the required performance standards.
a. Feedstock material was not stored in water tight containers,
b. Feedstock material was not stored on a hardened engineered surface or
asphalt or concrete,
c. Feedstock material was not stored in a designed arid approved storage area
(by the Co-Executive Secretary), or other approved area.
d. DRC observed open and degraded containers containing feedstock
material on soil and located outside of the feedstock management area.
2. DUSA has violated the Groundwater Permit Part I.D. 10 by failing to replace/repair
concrete in the secondary containment of the Caustic Soda Tank.
3. DUSA has violated the Groundwater Permit Part I.D. 10 by faihng to repair cracks in
the secondary containment area for the soda ash tanks.
The RFI items are:
1. DRC will requiest information regarding updates to the plans/inspections to provide
inspections according to frequencies required by the Storm Water Best Management
Practices Plan (SWBMPP). For example, the SWBMPP requires a weekly inspection
ofthe diversion ditches, however, they are conducted monthly. Failure to provide
these inspections in conformance with the SWBMPP or modify the SWBMPP is a
violation of the Groundwater Permit Part LD. IO., "The Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facihty in
accordance with the currently approved Stormwater Best Management Practices
Plan."
2. DRC will request information regarding the .inspection procedures for reagent storage
tanks (including intermediate process tanks, eg Pregnant Liquors) which are installed
on-grade (on-grade refers to tank installations where the tank bottom is in contact
with the ground) to insure that the structural integrity of the tank bottom is
acceptable/appropriate. Cathodic protection for on grade tanks is prescribed for the
on-grade tanks, in order for DUSA to comply with Part I.D.lO(a) of the groundwater
permit.
3. DRC will request an outhne of a plant process for intemal notification and
dociimentation of the clean up of small quantity spills (less than reportable
quantities). Per the 2010 inspection it was noted that afuel spill had occurred at the
fuel tank area, however, had not been cleaned i^p and there did not appear to be a
process to identify, document, or clean up such spills. Failure to provide such a
process is not in conformance with the SWBMPP Part 4.2.1.
4. DRC wili request that DUSA review the facility SPCC plan to insure that all tanks
included under the current facility Spill Prevention Countermeasure and Control
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Storm Water Management
Page22of22
(SPCC) plan meet current requirements of current EPA rules (40CFR112).
Specifically, any nori-PCB containing tanks should be included under oil inventory
and be included with inspection protocols. This RFI is required in order to insure that
current procedures and policies at the mill are up to date.
5. Seal interior drains in the vehicle maintenance areas that drain to outdoor uncovered
areas. This is specified in the facihty SWBMPP and is considered a best management
practice to minimize the quantity of contaminated material. The open drain is not in
conformance with the SWBMPP part 4.3.1, second bullet "clean up spills promptiy,
don't let minor spills spread."
6. Insure that the clean water tank valve is sealing properly. Per the 2010 storm water
inspection it was noted that this valve was leaking and was creating pond areas in
unlined ditch/soil areas. This is not in conformance with Section 4.1.4 of the
SWBMPP which states, "Areas requiring maintenance or repair, such as excessive
vegetative growth, channel erosion or pooling of surface water runoff, will be
report[ed] 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."
F:\DUSA\Storm Water Management\2010 SW Inspection\2010 SW Inspection Memo - White Mesa Mill - Fnl.doc
U:\rad\COMMON\Uranium millsM Ie(2)UTl 900479 Denison Mines - White Mesa UMillXStorm Water
Management\Modu le65 MemoFormat.doc
Form Updated December 14, 2010
White Mesa Mill, 2010 DRG Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 1 - Copies of Daily, Weekly and Monthly Inspection Data Logs for April,
2010
White Mesa Mill - Standard Operating Procedures
Book 11: EHviroiimeotsil Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 17 of 25
APPENDIX A (GONT.)
DAELY INSPECTION ©ATA
Inspector: ^I'^n^.r MXy
Date; U-^lO
Accompanied by: /i/^/^f^
Time: \'\oCs
Atiy Item not "OK" must be docunienfed. A check niark = OK, X = Action Required
Inspection items Conditions of Potential Concem Cell 1 CeU2 Cells CeU
A; A I^aks, JDamage, Blpc^ Sharp Bends -IS Mm-'... l^a]!^^ y
Pi|)^jpll^pp Diamkge^^^
Valves Leaks, Blocked^ Gllo^ed y y
Ppiirt(§) Qjfl3ffe^ y
ihspidiortSteins ; i Sv Boittditibi^ CeU.l Cell 2 CeU 3 '-•xieUfcr 4A
Water Level Greater T1U|L Qp^ting Level, Large C^hange
Siiicie I^vibiis mspection V/"
Beach . • Cracl(5, jSeyQieflSiision, Subsidenee = \y Liner and Cover Erosion of cover, Exposure of Liner
DIKES AND EMBANKMENTS
Inspection Items CBSHitions of Potential Concem Dike
l-I
t)ike 1-
lA
Dike 2 Dikes Dike4A-
S
Dike
4A-W
les Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
Areas, Areas of Seepage Outbreak /4
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental ProtectioB Manual Section 3.1
2/07 Revision: DUSA-2
Page 18 of 25
Crest Cracks, Subsidence, Severe Erosion ^y
IV. FLOW RATES
Slurry Linefs) Pond Return S-XTails Spray Svstem
GPM 5G)0
V. PHYSICAL INSPECTION OF SLURRY ~1/v^vjS^r <^3 - ^PM
LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
y 'Yes
^ No
No
VL DUST CONTROL
Cell2 GeUS CeU
4A
ViiidMoyeiiie©^^
•recipitaSon: O inches liquid . / -.-w-^^'^i^
leneral Meteorblbgiciai
a DAILY LEAK DETECTION CHECK 1
Cell 1 Cell2 . • ..Cells...... Cell4A
eak DetectldirSystein: *
hecked
^-=-^^.^^^^Ghecked -eak DetectldirSystein: *
hecked
Wet ^ Drv c/Wet Drv Wet >^Dry x/ Wet Diy
eak DetectldirSystein: *
hecked
Initial level *^ Initial level 1^-3^
eak DetectldirSystein: *
hecked
Finalievel Final level -r!v- •>^4-:: -iv ,.Fi!i^.l^«iv.,-d^^.:.,;.. Finalievel
eak DetectldirSystein: *
hecked
Oai. pumped Gal. pumped —' iGfal. putnped Flow Meter CH^^O
VBB QBS]ERYA'i;iONS OFP^
White Mesa Mill - Standard Operating Procedures
Book 11: EnvironmentalProtectionManual, Sections.!
3/10 Revision: Denison-9
Page 28 of 46
Date: M-;a-lo
1. Pond and Beach
elevations (msl,ft)
APPENDIX A (CONT)
DENISON MINES (USA) CORP.
WEEKLY TAILINGS INSPECTION
Cell 1: (a) Pond Solution Elevation
(b) FML Bottom Elevation - 5597_
(c) Depth of Water above FML ((a)-(b)) i P
Cell 4A: (a)Pond Solution Elevation
(b)FML Bottom Elevation 5564
(c) Depth of Water above FML ((a)-(b)) ^\ . ^
(d) Elevation of Beach Area
with Highest elevation (monthly) . — .
Roberts
Pond: (a)Pond Solution Elevation
(b)FML Bottom Elevation
(G)Depth of Water above FML ((a)-(b))
5612.34
(MX 3
2. Slimes Drain Liquid Levels Cell 2
ssio
Pump ftmctioiiing properly
PumpTijner set at 15min on45 min off.-A^Q AAM'^'C'Ffo4
Depth to Liquid pre-pump
DT? ^4>S Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pumo head is 38'-Depth to Liquid Pre-pump =
am
Post-pump head is 38'-Depth to Liquid Post-
pump =_l£LSS
White Mesa Mill - Standaid Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3/10 Revision: Denison-9
Page 29 of 46
3. Leak Detection Systems
Observation:
Celll Cell 2 Cell 3 CelI4A
wet v^dry ^wet "^dry Is LDS wet or dry? wet dry wet dry
If wet, Record
liquid level:
- Ft to
Liquid Liquid
Ft to — Ftto
Liquid
Ftto
Liquid
If sufficient fluid is
present, record
volume of fluid
pumped and flow
rate:
Volume ^
Flow Rate -
Volume
Flow Rate.
Volume
Flow Rate ^
Volume 3J57aSO
Flow Rate
yes -/ no Was fluid sample
collected?
yes </ no yes ^ no yes y no
Observation:
New Decon Pad.
Portal 1
New Decon Pad,
Portal 2
New Decon Pad
Portal 3
Is LDS (Portal)
wet or dry?
wet y dry wet i/dry wet <^rv
If wet, Record
liquid level:
Ftto
Liquid
Ftto
Liquid
Ft to
Liquid
If wet, Report to
RSO
4. Tailings Area Inspection (Note dispersal of blowing tailings):
5. Control Methods Implemented: ^ivW^ji ^^^^ OJ[^r ^6 k.^ v4iK^{>^ cf^LL-^ ccu^^ Vmto,
\
6. Remarks: K6-L ft^ ^""^^ P'*^'^ <^ CnW 'h.^t^ C'^I^ArAlr^ Cell ^ ft^
7. Contaminated Waste Dump: >-eaUs ^aA
6
White Mesa Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
3/10 Revision: Denison-9
Page 30 of 46
8.0 Decontamination Pad Inspections
Concrete Integrity Concrete Integrity
New Decon Pad Existing Decon Pad
Checked Checked
Are there any cracks on the
wash pad surface greater
than 1/8 inch of
separation? Yes i/No
Contact the RSO if a
problem has been
observed.
Are there any cracks on the
wash pad surface greater
than 1/8 inch of
separation? Yes No
Contact the RSO if a
problem has been
observed.
Reniarks (including a description of any abnormalities relating to the New Decon Pad or Existing Decon
Pad)
* Does Level exceed 12 inches above the lovvest point on the bottom flexible membrane liner (elevation
5556.14 amsl)? \X 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 AfesaMiJI Q^. ^
2/07 Re
^ONTHLYflvsPECHONDATA
1. SlmiyKpe^g.
vision: Dus^2
Page 22 of 25
Observation: ,
fiffiSaonDitol,! r»- .
ofl?|ow
J'es.—*£_no
y^-i-k^o
LHO
-Ho
•4:.: ~
White M&sk Mill - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/07 Revisjkm; jpySA-2
Page 23 of 25
Gnimization: ^^^lO-p "S^^/s 4. Overspray Dust Minimization:
Overspray system functioning pipperl)^: / .{^ves
Commente;:
ho
no Overspray carried more than SO feet frdm ihe c^
If "yes", was system ininiedi^ly shut off? . •/ '^y^s ;;.; • . ' no
- J—- . ... •^^^:.::yi^^a^^LA.-^^ ^^^^
CeU2Ei-N:
Cell 2^1-2S:
CeU 2 East:
..• ' •' '
Book 11: ^viixmmaitdPmtectioaMamml, Secdon 3,1
2/07Pvevisioi!:DUSAr3
Page 25 of 25
AFPENPIXA(COKT.)
Oil ST01A6E/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of tf hiiid through s/yW/o Date of lnsii>^bn:/}pe; j l i^ 2oi /
Ihspeotdi-: Qj> <\ AAO (\. cot >
Weafhea: copditioti^
Blo'miig ^hiit @p^^ vireek:
Cdn-eotiVe
i^T I f|e o^uaY
i^iribl^^ area iiidieated' oh the i
area indicateid dia^i^ maintained
yes:.../^./vimky^
coinments (S.g.^ ^g>^^:
Conditions dTstt^^ iMiialie
Ofl]ierconimaatsi
Location Trans. Shot Base Applied Elevation
Cell4A 5.5 5574.5 5577 Name: Tanner Holliday; Garrin Palmer
Intitial 8 5582.5
Date: 4/30/2010
C2W1 3.1 5613.04 5619.06
C2W2 1.22 5613.04 5620.94
C2W3 4.46 5613.04 5617.7
C2W4 4.92 5613.04 5617.24
Initial 9.26 5622.16
C2E 4.8 5623.14 5623.86
2E1-1N , 1.26 5623.14 5627.4
2E1-1S 5.78 5623.14 5622.88
2E1-2S . 5,22 5623.14 5623.44
2W7-C 6.46 5623.14 5622.2
2W7-N 7.18 5623.14 5621.48
2W7-S 8.78 5623.14 5619.88
2W6-N 8.2 5623.14 5620.46
2W6-C , 10.58 5623.14 5618.08
2W6-S 12.22 5623.14 5616.44
Initiai • 5.52 5628.66
2W5-C 4.02 5613.04 5618.14
2W4-N 3.08 5613.04 5619.08
2W4-S 6.2 5613.04 5615.96
2W5-N 3.46 5613.04 5618.7
2W3-S 5.66 5613.04 5616.5
2W5-S 8.1 5613.04 5614.06
2.84 5615.88
Initial 4.9 5617.94
3-1N 1 5613.04 5616.94
3-1G 5.16 5613.04 5612.78
3-18 2.78 5613.04 5615.16
3-2N 4.78 5613.04 5613.16
3-2C 2.28 5613.04 5613.6
3-28 3.74 5613.04 5612.14
Location Trans. Shot Base Applied Elevation
Cell4A 5.S 5574.5 5574.5 Name: Tanner Holliday^ Garrin Palmer
Intitial 6 0 5574.5 r • / ^ ' Date: H.30.a.0i0
C2W1 3.1 5612.77 , 5612.77
C2W2 Liia 5612.77 5612.77
C2W3 5612.77 5612.77
C2W4 5612.77 5612.77
initial 5612.77
C2E ^.9 5623.14 5623.14
2EMN 1.26 5623.14 5623.14
2E1-1S 5.-71? 5623.14 5623.14
2E1-2S A. 11 5623.14 5623.14
2W7-C AMC 5623.14 5623.14
2W7-N 1.18 5623.14 5623.14
2W7-S 5623.14 5623.14
2W6-N 5623.14 5623.14
2W6-e 5623.14 5623.14
2W6-S 5623.14 5623.14
Initial 5.sa. 5623.14
2W5-C 5612.77 5612.77
2W4-N 5612.77 5612.77
2W4-S 5612.77 5612.77
2W5-N 5612.77 5612.77
2W3-8 5612.77 5612.77
9A
Initial M.q 5613.04
3-1N l.O 5613.04 5613.04
3-1C 5613.04 5613.04
3-18 5613.04 5613.04
3-2N 5613.04 5613.04
3-2C / 5613.04 5613.04
3-28 / 5613.04 5613.04
White Mesa Mill- Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page 17 of 25
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Inspector: ^Air/.^ ^fj./i/v<r-
Date: A-ar^'ID
Accompanied by:i{„lltAu)^
Time: \330
Any Item not "OK" must be documented. A check mark = OBC, X = Action Required
1. TAILINGS SLURRY TRANSPORT SYSTEM
Inspection Items Conditions of Potential Concem CeUl Cell2 Cell 3 Cell
4A
• • . , • • .1
Slurry Pipeline Leaks, Damage, Blockage, Sharp Bends \^
Pipeline Joints Leaks, Loose Connections vu/A y Pipeliiie Supports Damage, Loss of Support A>/A ^y< ,y
Valves Leaks, Blocked, Closed Xy 1^
Point(s) of Discharge Improper Location or Orientation Yy V/A
OPERATIONAL SYSTEMS
Inspection Items Conditions of Potential Concem Celll CeU 2 Cell 3 Cell
4A
Water Level Greater Than Operating Level, Large Change
Since previous Inspection \y \y Beach Cracks, Severe Erosion, Subsidence y Liner and Cover Erosioh of cover. Exposure of Liner
m. DIKES AND EMBANKMENTS
Inspection Items Conditions of Potential Concern Dike
l-I
Dike 1-
lA
Dike 2 Dike 3 Dike4A-Dike
4A-W
dopes Sloughs or Sliding Cracks, Bulges,
Subsidence, Severe Erosion, Moist
Areas, Areas of Seepage Outbreak
ty yy y-
White Mesa MiU - Standard Operating Procedures
Book 11: Environmental Protection Manual, Section 3.1
2/07 Revision: DUSA-2
Page .18 of 25
Crest Cracks, Subsidence, Severe Erosion
IV. FLOW RATES
Slurry Linefs) Pond Retum S-X Tails Sorav System
GPM Hf5 CT5
V. PHYSICAL INSPECTION OF SLURRY
LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
Yes
y Yes
_No
No
VI. DUST CONTROL
CeU2 Cell 3 Cell
4A
Dusting y Wind Movement of Tailings \^—
Precipitation: |.'X inches liquid
^ •••
General Meteorological conditions: f^iW-U^ C-^^^y^ytK-^f
vn. DAILY LEAK DETECTION CHECK 1 GeU 1 Cell 2 Cells Cell4A
• V ....
Leak IDetection System
[Checked
sy^ Checked Cheeked \y^ Checked Ky^ ChiBcked Leak IDetection System
[Checked
Wet v-xl5rv \y^zX Drv Wet tx^ry Wet Dry
Leak IDetection System
[Checked
' Initial level >^—" Initial level Initial level '•""""^ Initial level H
Leak IDetection System
[Checked
finalievel Finalievel "-'^ Final level Finalievel '
Leak IDetection System
[Checked
tjal. pumped '^"^ Gal pumped Qal. pumped Flow Meter^i51) tS^O
Vin OBSERVATIONS OF POTENTIAL CONCERN Actipn Required
'S SLUW 0-iSCHAR6f LOCATION
if'
1. m
4
-y
September23, 2010
After the rain event on the 22"" of September, an event in which over 1.2" of rain fell, ttwas observed
that the drainage fronn the SX building roof is not adequate. The rainfall caused pooling solutions. The
drainage system needs to be addressed by the engineer and have the situation corrected.
David Turk
Radiation Safety Officer
White Mesa Mill, 2010 DRC Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 2 - Copies of Certification for Tailings Management Systems Daily
Inspections
, ^ . r» J ^ 3/10 Revision: Denison-9
White Mesa Mill-Standard Operatmg Procedures Page 40 of 46
Book 11: Environmental Prolection Manual, Section 3.1 —
APPENDIX G
CERTIFICATION FORM
Name:
I have read the document titled "Tailings Management System. White ^^^^^^"L,^^^"^?^.^. .
Lspector Training" and have received on-site instruction at
included documentation of daUy tailirigs inspections, analysis of potential problem
failures, unusual flovvs), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Rad^afon Safety Personnel/ Tailings System"
SuiJWrisor
White Mesa Mill ~ Standard Operating Procedures
Book 11: Environmenta! Protection Manual, Section 3.1
3/10 Revision: Denison-9
Page 40 of 46
APPENDIX C
CERTIFICATION FORM
Name: ^^^^'-j-^
I have reaftlhe document tided 'Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instruction at die tailings system. This instmction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Milk
Radiation Safety Personnel/ Tailings System
Supervisor
White Mesa Mill - Sundard Operating Procedures 3/1G Revision: Denison-9
Book 11: Environmental Protection Manual, Section 3.1 Page 40 of 46
APPENDIX C
CERTIFICATION FORM
Date: 5fZ< f i-o
tMame: '~\)/ILJ* A I .^y L
I have read the document tided '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
I certify that the above-named person is qualified to perform the daily inspection of the taiUngs
system at the White Mesa Mill.
Radiatii^ Safety PersoSseSinrailings System
Supetvisor
White Mesa Mill ~ Standard Operating Procedures 3/10 Revision; Denison-9
Book 11: Enviromnental Protection Manual, Section 3.1 Page 40 of 46
APPENDIX C
CERTIFICATION FORM
Date: ^-2'\-20\0
I 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, unusua!l flows), notification procedures and safety;
MM.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at Uie White Mesa Mill.
Safety Personnel/ Tailings System
White Mesa Mill- Standard Operating Procedures ^^^'^'^Paee^^of 6
Book 11: Environmental Protection Manual, Sectipn 3.2
APPENDIXD
CERTIFICATION FORM
Date: pJ>a>^0^
Name:
I have read the document titled "Tailings Management System, mite Mesa Mill TaUings !
Klc^Stag'' andhavereceived on-site instruction at the tailings systern This .t^tmction
iS cLumeLtionof daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
1 cerdfy that the above-named person is qualified to perfonn Ae daily inspection ^o^
system at the White Mesa Mill. ^
Radiation Safety Personnel Tailings System
Supervisor
White Mesa Mill - Standard Operating Procedures 2/07 Revision: DUSA-2
Book ll: EnvironmentalProtection Manual, Section 3.2 Page6 of 6
APPENDIXD
CERTIFICATION FORM
Date:
Name: (^nft SlcrUnd^
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instmction at the tailings system. This instmction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
Signature
(
I certify that the above-named person is qualified to perform the daily insp^^^
system at the White Mesa Mill
Radiatran Safety Personnel/ Tailings System
Superasor
I.
2/07 Page 6 oto
CERT
iFlCATlONfORM
lljJrSS^ ——
failuies. unusual /- Aw
Signature
V. ,hove-named person qui
of the tailings
Radiation
Supervisor
i^Personnei
White Mesa MiU-Standard Operating Procedures 2/07 Revision: DUSA-2
Book 11: Environmental Protection Manual, Section 3.2 Page 6 of 6
APPENDIXD
CERTIFICATION FORM
Date: lol-bizco'^
Name: lX^,x~T-.yk
I have read the document titled 'Tailings Management System, White Mesa Mill Tailings
Inspector Trammg" 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.
I certify that the above-named person is qualified to perform the daily inspection ofthe tailings
system at the White Mesa Mill. .. .
Radijfibn Safety Personnel/Tailings System
Supfehdsor
White Mesa Mill- Standard Operating Procedures 2/07 Revision: DUSA-2
Bookll: Enviromnental Protection Manual^ Section 3.2 Page6of6
APPENDED D
CERTIFICATION FORM
Date: \o\l>iz^of
Name: '7^^ f^iM4.<
I have read the document titled "Tailings Management System, White Mesa Mill Tailings .
Inspector Training" and have received on-site instruction at die tailings system. This instruction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
sipiati^^~^
I certify that the above-named person is qualified to perfonn the daily inspection of the tailings
system at the White Mesa MiU.
Radiation Safety Personnel/ Tailings System
Supra^isor
White Mesa Mill - Standard Operating Procedures 2/07 Revision: DUSA-2
Book 11: Environmental Protection Manual, Section 3.2 Page6of6
APPENDIXD
CERTIFICATION FORM
Date:
Name: y^mcr
I have read the document titled "Tailings Management System, White Mesa Mill TaiUngs
Inspector Training" and have received on-site instruction at the tailings system. This instruction
included documentation of daily tailings inspections, analysis of pot^tial problems (dike
failures, unusual flows), notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the dmly inspection of the tailings
s>^tem at the White Mesa Mill.
PersonnSirtailir Radiajidn Safety PersoiinSl/Tailings System
Sundmsor
V , x4;it <;iaiMJard Operatmg Procedures
APPENDIXD
CERTIFICATION FORM
2/07 Revision: DUSA-2
Page6of 6
Date:
Name: White Mesa Mill Tailings
failures, unusual
system at Ae White Mesa Mill.
rm
tt^edaUyinspectionofthetaUings
^Tailings System Radiation
Supo^isor
White Mesa MiU - Standard Operating Procedures
Book 11: Environmental Protection Manual. Section 3.2
2/07 Revision: DUSA-2
Page 6 of 6
APPENDIXD
CERTIFICATION FORM
Date: fP/^z/v^
Name:^jp\A^vAA<^. 1?>^\/1alU/[
I have read the document titled "Tailings Management System, White Mesa Mill Tailings
Inspector Training" and have received on-site instmction at the tailings system. This instmction
included documentation of daily tailings inspections, analysis of potential problems (dike
failures, unusual flows), notification procedures and safety.
I 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
WhiteMesa Mill-Standard operating Procedures ^^^^p^!^
Book 11: Environmenta! Prolection Manual, Section 3.2
APPENDIXD
CERTIFICATION FORM
Name:
I have read the document Utled'Tailings Management System. White Mesa^
Inspector Training" and have received on-site in^^^^
included documentation of daily tailings inspections, andysis of potential problems (dik^
failures, unusual flows), notification procedures and safety.
gnature
I certify that the above-named person is qualified to perfomi the daily inspection df the tailings
system at the White Mesa Mill.
I K
Radiation Safety Personney Tailings System
Supervisor
White Mesa Mill, 2010 DRC Storm Water Inspection
Ground Water Module 65
Storm Water Management
Attachments
Attachment 3 - Photo Pages
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19,2010)
Photo Pages
Page 1 of 16
Photo 1 - Ore Tailings Pad Drain, located at the south-east comer of the tailings pad
p-^^y ::
_ ,,,, 'i--*^7%f(y'' ' .
Photo 2 ~ Drainage Berm on the eastem side of the tailings storage pad
Photo 3 - New Decontamination Pad - Note that the containment has been drained and
the concrete seams have been coated with black sealer
^:„es Wutc Mesa Urani»» 2010)
Photo Pages
Page 2 of 16
photo 4
Photo 5
Maihtenance Area
photo 6
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19,2010)
Photo Pages
Page 3 of 16
Photo 7 - Drain inside of Vehicle Maintenance Area, Subject of 2009 comment,
recommended that DUSA remove this drain
Photo 8 - Total Containment Sumps outside ofthe vehicle maintenance area, consists of
3 baffled concrete containments
Photo 8 - Area Above Treatment Area (Note old decontamination pad in background).
Area has been regarded to control runoff into the Vanadium Pregnant Liquor (VPL) Area
D,
of 16 2010)
^hotog^
'Seinto the
see, ^»ment
bi2/^«aeftof
^hotoiQ^
^hotoii^^
^OQden, sate
areai
oimd)
ofl6 (Oct. ig 2010)
Ph oto 12^ ypL coflden,
^oto 14Z
contai '^ment
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19, 2010)
Photo Pages
Page 6 of 16
Photo 15— Sodium chlorate tanks and secondary containment, note wash down area left
of tanks on concrete pad
Photo 16 - Collection vault from tiie old decontamination pad, note that the vault is full
of sediment and needs to be cleaned out
Photo 17 - Vanadium intermediate product stored in dmms south of the old
decontamination pad (visible in background)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 7 of 16
Photo 18 - U Liquor containment area, water in containment is from washdown of
grizzly, onsite staff reported that sediment would be removed from the containment area
Photo 19 - Fresh water tank, DRC noted that the tank valve was leaking
Photo 20 ~ Area below the fresh water tank drains to Roberts Pond, DRC noted that
leakage from the fresh water tank was draining across bare ground to the discharge pipe
Denison Mines White Mesa Uranivmi Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 8 of 16
Photo 21 - New berm around sulftiric acid tank, standing water in area is fi-om
development of a monitoring well (white casing)
Photo 22 - New berm around sulfuric acid tank
Photo 23 - Graded area, former "swamp" area east of the sulfiiric acid tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19,2010)
Photo Pages
Page 9 of 16
Photo 24 - Concrete drainage area east side of the sulfiiric acid tank
Photo 25 - Discharge around CCD tanks, drains to Roberts Pond
Photo 26 - Roberts Pond, note that vegetation has been removed from perimeter
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19,2010)
Photo Pages ~.
Page lOof 16
Photo 27 - Discharge around CCD tanks into Roberts Pond, DRC noted that the source of
this water was fi-om washdown of the Leach House (see^photo 28)
Photo 28 - Washdown water firom the Leach House across bare ground (discharging info
Roberts Pond)
Photo 29 - Caustic Soda secondary containment still badly deteriorated
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispeCtion (Oct. 19, 2010)
Photo Pages
Pagell of 16
Photo 30 — Secondary containment for caustic Soda badly deteriorated, not fimctional
Photo 31 - Roof drainage area from SX building, DRC noted that imiprovement needed in
this area
Photo 32 - Area south of SX building slated for drainage improvements
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19,2010)
Photo Pages
Page 12 of 16
•.y
Photo 33 - Altemate Feed Circuit Area, note that the concrete is hghtiy deteriorated
inside of curbed berm ^
Photo 34 - Altemate Feed Circuit area holdmg tank, drainage retum tank
Photo 35 - Altemate Feed containment drainage sump, pumped back into holding tank
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 13 of 16 .
Photo 36 - Alterate Feed staging area, note that 7 drums are in area, onsite staff
reported that all dmms would be processed during the day
Photo 37 ~ Another view of altemate feed staging, note perforations in drums
Photo 3 8 - Close up view of perforated dmm
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19, 2010)
Photo Pages
Page 14 of 16
Photo 39 - Dry chemical storage area
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Photo 40 - Altemate feed drums east of the dry storage area
Photo 41 Areaof northeast berm of cell 2, south of the mill processing area, onsite
DUSA staff stated that drainage had been improved in this area
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water Inspection (Oct. 19, 2010)
Photo Pages
Page 15 of 16 v
Photo 42 ~ Diversion Ditch 1 (above cell 1) showing excessive vegetation growtii in the
bottom of the ditch
Photo 43 Diversion Ditch 1 (above cell 1) showing rilling on banks and heavy
vegetation in ditch bottom
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Photo 44 - Diversion Ditch 1 (above cell 1), slumping (photo middle left)
Denison Mines White Mesa Uranium Mill
2010 DRC Storm Water hispection (Oct. 19, 2010)
Photo Pages
Page 16 of 16
Photo 45 -- Diversion Ditch 2, good condition
Photo 46 - Upland area northeast of mill
Photo 47 - Upland area with Lawzy Lake Depression in the mid-ground