DRC-2011-007901 - 0901a06880303bf4

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RusseU Topham - Response to DRC 9/1/11 Stormwater RFI and Confirm, Action Letter
From: Jo Ann Tischler <jtischler(gdenisonmines com>
To: Rusty Lundberg <rlundberg EQSHW EQDOMAIN(gutah gov>
Date: 10/17/2011 6 32 PM
Subject: Response to DRC 9/1/11 Stormwater RFI and Confirm, Action Letter
CC: Thomas Rushing ii <TRUSHING(gutah gov>, David Frydenlund
<DFrydenlund@denisonmines com>, Harold Roberts <HRoberts(gdenisonmines com>,
David Turk <DTurk@denisonmines com>, Kathy Weinel
<KWeinel@denisonmines com>, Meredith Goble <MGoble(gdenisonmines com>
Attachments: 101711 Responses to stormwater inspection - OCR - RED pdf
Attached please find Denison Mines (USA) Corp's responses to DRC's September 1, 2011 storm water Request
for Information and Confirmatory Action Letter A separate hard copy has been transmitted by Federal Express
Please contact me if you have any questions regarding this transmittal
Yours truly,
Jo Ann Tischler
Jo Ann Tischler
Director, Compliance and Permitting
t 303-389-4132 I f 303-389-4125
1050 17th Street, Suite 950
Denver, CO, US, 80265
DENISON MINES (USA) CORP
www denisonmines com
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A-TTAO^m^r C Pe%r/H^S To 77^5 P^eof
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file //C \Documents and Settings\rtopham\Local Settings\Temp\XPgrpwise\4EA040B9E 10/21/2011
DENISOfv^.
MINES
Denison Mines (USA) Corp
1050 17th Street. Suite 950
Denver, CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
October 17, 2011
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
PO Box 144850
Salt Lake City, UT 84114-4850
Re Demson Mines (USA) Corporation ('DUSA") White Mesa Mill Facility DRC Inspection Results Storm
Water Best Management Practices Plan ("SWBMPP"). Ground Water Module 65, October 9, 2010,
Utah Ground Water Discharge Permit No UGW370004 DRC Request for Information and
Confirmatory Action Letter
Dear Mr Lundberg
This letter transmits Demson Mines (USA) Corp's ("DUSA's") responses to the DRC Request for Information
and Confirmatory Action Letter, dated September 1, 2011
We have re-quoted each RFI and Confirmatory Action item and provided below, specific responses to each
request as required by the DRC September 1, 2011 letter
DRC Request for Information:
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 (S\/\/BI\PP) For example, the
SWBMPP requires a weekly mspection 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
1 D 10 of the Groundwater Permit
DUSA Response:
Per the telephone conversation between DRC and DUSA on September 21, 2011, the diversion ditch
Inspections will continue to be conducted monthly This inspection frequency continues to be appropnate for
identifying the types of slow-developing changes that may occur in the diversion ditches The Storm Water
Best Management Practices Plan (SWBMPP) has been revised to reflect monthly inspections of the diversion
ditches A revised SWBMPP has been enclosed in Attachment A
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 ofthe tank
bottom IS acceptable/appropnate Cathode protection for on grade tanks is prescnbed in Part ID 10(a) of the
Groundwater Permit
N Mnspections and NOVs\Stormwater lnspections\SW Inspection 2010 and 2011 RAIMO 15 11 Responses to 09 01 11
Stormwater Inspection lettertlO 17 11 Response to DEQ 09 01 11 Itr doc
Letter to Mr Rusty Lundberg
Storm Water Inspection RFI/Confirmatory Action Response
October 17, 2011
Page 2
DUSA Response:
Cathodic protection per se is not prescribed in part I D 10(a) of the GWDP Part D 10(a) refers to non-specific
general requirements However, DUSA has agreed to modify tanks for consistency with the general
requirements where appropnate as discussed below
Per email correspondence from DRC on September 26, 2011, DUSA understands that DRC requires cathodic
protection on tanks whose bases are in contact with the ground surface That is, DRC does not require tanks
which are on concrete pedestals, whether diked or not, to have cathodic protection Based on the
correspondence and the mspection report, DUSA has completed an inspection of all on-grade tanks to
determine the necessity of cathodic protection The following results of the tank inspection were noted
• There are three kerosene tanks The east tank is on a concrete pedestal The two west tanks are
placed on-grade, on the ground surface
• The ammonia tanks are on concrete pedestals
• The sulfuric acid tank is on a concrete pedestal
• The extenor VPL and water tank by the Old Decontamination Pad ("ODP") are on concrete pedestals
Dirt had filled in the area around the pedestals and, at the time of the 2010 inspection, gave the
mistaken impression that the tanks were on-grade
DUSA had discussed with DRC the installation of cathodic pnDtection on reagent or fuel tanks that were not on
pedestals, saddles, or dikes, specifically the kerosene tanks DUSA has since decided that it would be more
prudent to construct comparable concrete bases (pedestals) for the remaining kerosene tanks, as are in place
on the other flat bottomed tanks The west two kerosene tanks will be modified by being raised for pouring of
tank pedestals, and replaced after concrete for the pedestals is set and suitable for tank setting Construction
of these modifications will be complete by the end of December 2011 Based on DRC's email of September
26, 2011, tanks with concrete foundations, with or without dikes, will not be required to have cathodic protection
and will be considered to be compliant with EPA requirements for tanks where inspection procedures are not
practicable
The pedestals of the extenor VPL and water tank by the ODP were cleared of soil buildup during October,
2011 Photographs documenting the removal of the loose soil are provided in Attachment B
3 ORC requests an outline of a plant process for internal 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
DUSA Response:
DUSA has implanted an internal notification process for small quantity spills (less than reportable quantities),
with the following steps *
1) Mill environmental personnel will fill out on the daily inspection form observations of spills of reagent
chemicals of any size The fonn will be amended to add spaces for this item
2) In addition, all Mill employees will be trained to advise Mill environmental personnel of any spills that
they observe during the day, and these will also be noted in the daily inspection form
DENISON
MINES
Letter to Mr Rusty Lundberg
Storm Water Inspection RFI/Confirmatory Action Response
October 17, 2011
Page 3
3) If the spill is of a reportable quantity, environmental personnel will follow the procedures in the Mill's
SWBMPP plan
4) For spills smaller than reportable quantities, the environmental inspector will record information
regarding the spill, and the nature and type of cleanup, on the form
5) This information on the inspection form will be added to a database maintained at the Mill The
database will be updated and maintained on site indefinitely Cards are maintained for no longer than
one year
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
DUSA Response:
The Mill has historically not been considered to fall within the rules set out in 40 CFR 112, for the reasons
discussed below, therefore DUSA does not believe that the specific requirements of those regulations apply to
the site However, as a matter of prudency and good operating practice, DUSA will review those regulations to
determine whether or not any modifications to the SPCC would be appropriate for the Mill Denison will submit
the results of its review under separate cover within 30 days from the date of this letter
SPCC requirements apply to "[a]ny owner or operator of a non-transportation-related onshore facility, using,
or consuming oil and oil products, which due to its tocation, could reasonably be expected to discharge oil in
quantities that may be harmful into or upon the navigable waters of the United States or that may affect
natural resources belonging to, appertaining to. or under the exclusive management authonty of the United
States " 40CFR 112 1(b)
SPCC rules allow the owner to consider whether due to the geographical and location aspects of the facility
(such as proximity to navigable waters or adjoining shorelines, land contour, drainage, etc), it could not
reasonably be expected to discharge oil in harmful quantities to a navigable water The Mill was constructed
with an overall grade and diversion ditch system designed to channel any non-recovered portion of any material
spill to the tailings management system The land contour and drainage charactenstics of the site are
permanent geographical aspects of the site which do not involve man-made features or devices which could
fail These features, along with the Mill's relative distance from any navigable water, or means to reach
navigable water, prevent any potential discharge of oil at the Mill site from reaching navigable waters
Upon review of our files DUSA has determined that the Mill's SPCC plan was originally developed dunng the
penod when the Mill was operated by Umetco Minerals Corp , a subsidiary of Union Carbide Corporation As
with all Union Carbide operating facilities, as a matter of Union Carbide corporate policy, Union Carbide
required Umetco to prepare and maintain an SPCC plan for the Mill That is, we understand that the Mill's
SPCC plan was implemented voluntanly by the Mill operator as manner of prudent operating practices, and not
as a result of a regulatory requirement DUSA also believes that it is prudent to maintain and comply with the
SPCC plan As stated in the Introduction to the Mill's SWBPP, "(a)lthough the Mill, by design, cannot directly
impact stormwater, surface water, or groundwater, the Mill implements these practices in a good faith effort to
minimize all sources of pollution at the site "
Therefore, based on the Mill site's permanent charactenstics as described above, DUSA does not believe that
the specific requirements of the Clean Water Act are applicable to the Mill site However, as mentioned above.
DENISONO
MINES
Letter to Mr Rusty Lundberg
Storm Water Inspection RFI/Confirmatory Action Response
October 17, 2011
Page 4
DUSA will review the regulations at 40 CFR 112 to determme whether or not any modifications to the SPCC
plan would be appropnate for the Mill
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 matenal The open drain(s)
not in conformance with the SWBMPP part 4 3 1, second bullet "clean up spills promptly, don't let minor
spills spread"
DUSA Response:
Per Denison's communications with DRC on September 21 and 22. 2011, DRC will not require sealing of the
interior drain(s) in the vehicle maintenance areas if DUSA provides a descnption of the spill management
practices in this area demonstrating that the practices do not mcrease the volume of contaminated water sent to
the oil/water separator The maintenance area spill management practices and operation of the oil/water
separator are descnbed below
Spills m the Maintenance Shop are initially managed by on-the-spot cleanup of the majonty of the spilled
volume with clay or sorbents The sorbent media used for spill pickup is transferred to a disposal area in
tailings Cell 3 Following initial spill pickup, the floor is washed to the Inside oil/water sump
The sumps operate as follows The outside wash bay sump oil water separator on the north side of the Shop
collects wash water from washdown of mobile equipment, along with building roof runoff The separator has two
sections separated by an overflow weir The smaller section (sump), beyond the weir, allows mud to settle
Mud collected tn this sump is removed approximately annually or as operations and maintenance allows, and
transferred to Cell 3
The overflow from the overflow sump is piped through an underground line to a second stage oil/water
separator inside the building This separator also has an overflow weir and sump for collection of entrained
solids The overflow sump has not required removal of solids to date, but is monitored, as is the outside
overflow sump, and can be emptied as required Overflow solutions from the separator are transferred to the
CCD tailings sump from which they are pumped to one of the tailmgs cell as directed by operations
management
The above practice does not increase the volume of contaminated water to the oil/water separator or the
tailings, and does not combine contaminated water with clean water Regardless of the configuration, all
overflow water and all removed solids from both the inside and outside separators are transferred to the tailings
system Sealing the floor dram valves and management of water from inside the Shop would not reduce the
volume of water to the tailings system, since all the water, inside or outside, would still be transferred to tailings
system
6 ORC 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 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 enDsion 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 "
OENISONOi
MINES
Letter to Mr Rusty Lundberg
Storm Water Inspection RFI/Confirmatory Action Response
October 17. 2011
Page 5
DUSA Response:
The clean water tank valve that was noted as leaking during the inspection is an overflow valve The overflow
noted was not due to inadequate maintenance of any valve The flow which DRC observed was, in fact,
operating properly to dram an overflow of clean water makeup from the top of the tank to the drainage system
In a tank overfill situation, the overflow system, by design, allows flow of excess water until the overflow rate
reduces to a near trickle prior to the cessation of flow when the tank level is stabilized What the ORC inspector
observed during the 2010 inspection was proper normal operation of the overflow loop near the end of the
overflow, not a malfunctioning valve Moreover, the area below the clean water tank is graded such that when
the overflow valve releases clean water, the water will dram to Cell 1 so that no significant ponding will result
from this design
DRC Confirmatory Action;
1 DUSA has violated Part 1 D 11 ofthe Groundwater Permit by failing to manage drums containing alternate
feed material (located outside of the feedstock management area) in compliance with the required performance
standards
a Feedstock matenal was not stored in water tight containers,
b Feedstock matenal was not stored on a hardened engineered surface or asphalt or concrete.
c Feedstock matenal 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 containmg feedstock material on soil and located
outside of the feedstock management area
DUSA Response
Based on communications with DRC on September 21 and September 22, 2011. Denison has completed the
following modifications to the Alternate Feed area
a) Denison disagrees with DRC's statement that feedstock matenal was not stored in watertight
containers All alternate feed materials have been and will continue to be stored in water-tight drums or
in overpack drums Denison considers intact shipping drums, with no apparent leakage, as well as
overpack drums, both to be water tight containers Demson disagrees that containers that may be
"degraded" are not watertight, when no leakage is present However, one drum with perforations was
staged in the altemate feed area prior to processing As a result, regardless of the type of dmm, all
drums m the Alternate Feed area are now placed on the new concrete pad described in item b), below,
when not in the drum rack
b) A concrete pad has been installed in the alternate feed area The design of the concrete pad was
approved by DRC pnor to the installation (see the letter dated September 30. 2011 m Attachment C)
Photographic documentation and as-butit drawings of the concrete storage pad, whose construction
was completed on October 14, 2011, are mcluded m Attachment D
c) See response to item b), above
d) See response to item b), above
2 DUSA has violated Part ID10 of the Groundwater Permit by failing to replace/repair concrete in the
secondary containment ofthe Caustic Soda Tank
DENISONOi
MINES
Letter to Mr Rusty Lundberg
Storm Water Inspection RFI/Confirmatory Action Response
October 17. 2011
Pages
DUSA Response:
The secondary containment area for the Caustic Soda tanks has been repaired dunng October 2011, as shown
in the photographs included in Attachment E As discussed dunng communications between DRC and DUSA
on September 21 and 22, 2011, DUSA plans further upgrades to the caustic soda area dunng a future
maintenance outage m 2012, at which time the caustic tanks and secondary containment will be reconfigured
However, per communications between DRC and DUSA on September 21 and 22, 2011, DRC agreed to
consider the caustic soda area in compliance with Part 1 D 11 based on the repairs completed on October 14,
2011
3 DUSA has violated Part ID 10 of the Groundwater Permit by failing to repair cracks in the secondary
containment area for the soda ash tanks
DUSA Response:
The secondary containment area for the soda ash tanks has been repaired dunng the first week of October
2011. as shown m the photographs included in Attachment F Per communications between DRC and DUSA
on September 21 and 22, 2011 DRC agreed to consider the caustic soda area in compliance with Part 1 D 11
once the repairs are completed
Please contact me if you have any questions or require any further mformation
Yours very truly.
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc David C Frydenlund
Harold R Roberts
David E Turk
K Weinel
Central files
DENISO
MINES
Attachment A
S,„„,«ater Best Managen,ent practices Plan
Redline
STORMWATER
BEST MANGEMENT PRACTICES PLAN
ft>r
White Mts.i Uriiiitiim Mill
6425 South Highway 191
PO Box 809
Bl.tndini;. Dial)
Prepare*) hy
Dtnison Mini-s (USA) f orp
lOM) 17th Street. Suit^ y-^O
IVnvcr COS026S
TAIILCOFCONILNTS
1 0 INTKODUCTION/PURI'OSF-
2 0 SCOFI-
3 0 RLSPONSIBILITY
4 0 BE.ST MANAGFMl NT I'RACTICI^
4 1
4 2
43
44
Gmual ManagciTitnl I'rpcticts Applicable lo All Areits . 4
4 1 1 Keep Potcnual Polluianis from Conldct with Soil and Surracu. Walcr 4
4 1 2 Keep Potcn*i.il Pollutanis frum Contact with Frccipiiatirm 4
4 I 3 Keep P.ivrfl Areni ironi RLCorning PolUnunl Souico 4
4 1 4 Inspectuni and Mamiciwncc of Divpision Ditches ind Drainage Channels withm the Ptott-ss intl
Rcagcm Storage Aaa 4
4 I 5 Rtc>tlc Fluidi Whenever Possible 4
Mfln.igcnitnt Praetici's lor Process ard Laboratory Anns 5
4 2 I Clean Up Spills Properly 5
42 2 ProiLet Mitcriali Stored Outdoors, 5
4 2 1 Matagcment S
4 24 Maicnals Management • 5
Minngciiicnt Piacticcs for Mainicnanci AciiviiiC'* 6
41 1 Keep a Clean Dry Shop . 6
4 12 Manage Vehicle f luids .. 6
4 13 Use Controls During Pdini Ri niuva' . . „ _ 6
4 3 4 Use Con;roK Dunng Paint Application and Cleanup , 5
Managemmt Pracln.es for Ore Pad, Tailings Area and Heavy Fquipinent 7
4 4 I W.ish Down Vehicles and Fquipriicni in Proper Area.s ^
4 4 2 Minagc Stockpiles lo Prevent Windborne Conianunaiion 7
4 4 3 Keep FiTihnioving Ac f vitics from RLcnming Po'hilani Sciirees 7
Figures
/^igurc 1 White Misa Mill Siu Uiyoiii
^tgurc2 WhitL Misa Mill Sue Drainage Hasins
/Mgure 1 Denis,on Mines (USA) Corp White Mcsi Mill Management Orguniji/ilion Chart
/-igure 4 Denison Minci lUSA) Corp Coiporatc Management Orgonuaiionil Chan
12«
2119
Field Code Changed
Field Code Changed
Field Code Changed
Field Code Changed
Tables
JABLF 1 0 White Mci.i Mill M in.igcmcni Personnel Rcspoivsiblc for Implementing 1 his BMPP
JABLR2 0 RtAGFNT YARD LIST
JABLb 3 0 LABOR Al ORY CHJ MlCAL rNVb^4•^0RY LKST 1
.lABLF 4 0 RhAGFNT YARD/SMALL QUANTITY CIIRMICALS I LSI )
.lABLI 50 hAGFNT YARD/BULK CHtMlCALS MS r 1
IABLI b 0 PFTROLLUM PROnUCTvS AND SOLVENTS UST 1
Appcmliees
Appendix 1
Appendix 2
Whitt Mesa Mill Spill Preveniion Control and Coiinternieabures Plan
White Mesa Mill bniergcncy Response Plan
9
10
1244.
14+#
1544
Reid Code Changed
Field Code Changed
Field Code Changed
Field Code Changed
Field Code Changed
Field Code Changed
IU:s( Management Practices Plan
1.0 INTOODUCTION/PURPOSE
Demson Mines (USA) Corp ("DUSA") operate-) ihe While Mesa Uranium Mill ("the Mil!) in
Blandmg, Utah 'I he Mill is a net water ainsumer, and ti a /cro-dischargt lacihty wiih respect to
water effluents That is, no water leaves the Mill sue because the Mill has
• no outfalls lo pubhc siomiwaier systems,
• no surface runol f to pubhc stormwater systems,
• no discharges to publicly owned treauncnt uorks ("POTWs"). and
• no discharges to surface water bodies
The Slaic of Utah issued Groundwater Discharge Permit No UGW370G04 to DUSA on March 8,
2005, As a part of compliance with the Hermit, DUSA is required to submii a Stormwater Best
Management Practjccs Flan ("BMPP") to the Executive Secretary ofthe Division of Radiation
Control, Utah Department of Environmental Quality This BMPP prucnts operational and
management pracuces to minimi/c or prevent spills of chemicals or hazardous matenals, which
could result m contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes Although the Mill, by design, cannot directly impact stormwoter, surface water, or
groundwater, the Mill implements these practices in a good faith cffon to mininiue all sources of
polluuon at the site
Page 1
Hcu Managciaent Practices Plan
Revision I M jwfte-44rjmOctolifr 201 i
2 0 SCOPK
This BMPPidemifics practices to prevent spills of chemicals and hazardous materials used in
process operations, labtiraiory ope'rauons, and m.iuitcnantc activities and mimmi/c spread ol
particulates from stockpiles and tailings managemeni areas HI the Mill. Storage ot ores and
alicrnaic tecds on the ore pad, and containment ot tailings in the Mill tailings impoundment
system arc not considered "spills' lor the purposes ofthis BMPP
The Mill site was constmcted with an ovtnall grade and diversion ditch system designed to
channel all surtace runoK, including precipitation equivalent lo a Probable Maximum
Prccipitation/Probable Maximum flood {'PMP/PMF ) storm event, lo the tailings managemeni
system In addiiioii, Mill tailings, all other proce.ss cffluenis, uil solid waste and debris (except
used oil and recyclable matertals), and spilled materials that cannot be rccoveied for reuse arc
transferred to one or mt)re of the tailings cells in accordance \viih the MiH'^i NRC license
conditions All of the process and laboratory building .sinks, sumps, and flovir drains are tied lo
the transfer lines to the tailings impoundments A site map ol the Mill is pawtded in figure I A
sketch of the site diamage basins is provided m Figure 2
As a result, unlike other industnal facilities, whose spill management projirams focus on
minimi/ing the introduction of chemical and solid waste and wastewater into the process sewers
and storm dnms, the Mill is permitted by NRC licence tu manage some spills via draining or
u.ish.down to the process sewers, and ultirnalclv ihe tailings system However, as good
environmental management practice, the Mill attempts to minirni/e
1 the nitmher and si/e of maternl spills, and
2 the amount of unrecn\ered spilled material and wash water that fillers the process sewers
after a spill cleanup
Section 4 0 iicmucs the practices in place at the Mill to meet these ob|ectives
RcquircmcnLS and methods lor management, recordkeeping, md documentation of ha/ardous
material spills are addressed in the DUSA White Me<;a Mill Spill Prevention, Control and
Counlermeasurcs ("SPCC") Plan Rev4;>ed i-cbmnrV' 2(K)7, the Emergency Response Plan
("URP"), oUio iwtst'd >f> T'ebnuiry 2()07, and the housekeeping procedures inairporated in the
White Mesa Mill Standard Operating Pnnedurcs (' SOPs') T he j,jtgst revisions t)t thi SPCC plan
and the ERP are provided in the tr entirety in Appendites I and 2 rcspeciiveiv
Page 5
Best Management Practices Plan
Revision 1 ltHiv-ar^K»AOad>i> I
3.0 RESPONSIBILITY
All Mill personnel arc responsible tor implcmcntaiion ofthe practices in this BMPP DUSA
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices m this BMPP
The Mill Management Organization ts presented m Figure 3 The DUSA Corporate Management
Organi/aUon is presented in Figure 4
An updated spill prevention and control notificaiion list is provided in Table 1
Page 3
Best Management Praclices Plan
Revision I ^o«fr43-i»t)0>K)cinl)cr 201 [
4 0 EESr MANAGEMENT PRACI ICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5
4 I General Management Practices Applicable to All Areas
4.1.1 Keep Potential Polluttints from Contact with Soil, und Surface Water.
• Store ha7ardous materials and other potenii.il pollutants in appropnate containers
• Label the containers
• Keep the eonnitiers eovered when noi in use
4 U Keep Potential Pollutants Imm Contact with Precipitation
• Store bulk materials tn covered lariks or drums
• Store lars, bottle, or similar small containers in buildings or under covered areas
• Rcpldc e or repair broken dumpsicrs and bins
• Keep diiinpstcr lids and large container covers closed when not in use (to keep
precipitation out)
4 13 Keep Paved Areas I rom Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debns m the solid waste dumpsters or
tailings itrea as appropriate
414 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control strucuires in and around
the Mill area will be inspected at least wtt'kly monthly in aceordancc with the regularly
seheduled inspections icquired by Groundwater Discharge Permit No UGW37()0(M, and
Bhy product Matenals License tfUT1900479 Areas requinng maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be rcport^jj lo site management and maintenance dcpaiiments for necessary action to
repair d.'Hmagc or perform rcconsiniciion in order for the criiUrol feature to perfonn as
intended Status ot maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary
4 15 Recycle Fluids Whenever Possible
• When possible, select auuimotivc fluids, solvents, and cleaners that can be recycled oi
reclaimed
• When possible, select consumable materials fiom suppliers who will reclaim empiy
containers
• Keep spent fluids m properly labeled, cover(.d containers until ihey are picked up tor
recycle or irnnslerred lo the tailings area for disposal
Page 4
Best Minngenieni Praciiees Ptiin
Revision 1 M Juna 12 2(Mt»Qciob'>r 2011
4.2 Management Practices for Procevs and Ijiburatory Areas
4 2 1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping collection drunes) instead of
water whenever possible
• C lean spills c)l stored re.igents or other chemicals immediaicly alter discovery
• (Groundwater Discharge Permit No LGW^7()0{M. Section IJ>Lj> *^Jl< t)
• Recover and re use spilled m.Uerial whenever possible
• Keep supplies ot rags sorbent matenals (such as eat lilter) spill collection dmrns and personnel
piolective equipment ("PPE') ne:u- ihe areas where ihey may be needed for spill lesponsc
• 11 spills must bt washed down, use the minimum amount of water needed lor cfteciive cleanup
4.2 2 Protect Materials Stored Outdoors
• If drummed feeds or prcxlueis must be stored outdoors, store them in covered or diked areas when
pt^ssiblc
• If drummed chemicals must be sttired outdoors, store them in covered or diked areas when
possible
• Make sure drums and containers stored outdoors are in good ci>ndition and seeurcd against wind
or leakage Place any damaged contuiners into an overpack drum or second container
4 2 3 Managcfnent
• When possible, recycle and reuse water from flushing and pressure testing eqnipmcni,. When
possible, wipe down the oufsidcs ol containers instead of rinsing diem oil in thc.sink
• When possible, wipe down counters and work surfaces instead of hosmg tv rinsinp them.off lo
sinks and drain
4 2.4 Materials Management
• Purchase and inventory the smallest amount of laboratory reagent necessary
• Do not stock more of a reagent ilian will be used up before ila expiration date
• -All new constmction of reagent storage facilities will inc lude sccond.u-y coniainment.which shall
control and prevent any contact of spilled reagents, orcithcrVMse released
• reagent or product, with the ground surface (Croundwatei Dischaigc Pcmiil No
• UGW mOUA, Section 1 0 )
Page 5
Best Managemmt Practices Plan
RcMSion 1 H ^no f5. 20(>}<Oet.;ht r 201 i
4 3 Management Practices tot Miiintentince Activities
4 3 1 Keep a Clean Dry Shop
• Sweep or vacuum sh<^p floors regularly
• Designate specific are*is indoors lor parts cleaning and use cleaners and sf)lvcnts only in those
areas
• Clean up spills promptly Don t let minor spills spread
• Keep supplies ol rags, collection containers, and sorbent matenal near eacfi work area where they
are needed
• Store bulk fluids, w.i,sic fiuids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills
4,3 2 Manage Vehicle Fluids
• Dram lluids from leaking or wrecked/damaged vehieli s and equipment as boon as possible Use
drip pans or plasiic tarps to prevent spillage and spread i^f fluids
• Promptly contain and transfer drained Hinds to appropriate sloiage area lor reuse recvcic or
disposal
• Reeycle automotive fluids, tf possible, when their useful lilc is linished
4.3.3 Use Controls During Paint Removal
• Use drop eltJihs and shcaing to prevent vvindborne contamination trom paint chips and
sandblasting dust
• Collect contain, and ininsfcr as soon as possible accumulated dusts and paini chips io a disposal
location in the tailings .u-ea authorized to accept wa.ste materials from maintenance or
consirucuon acuviiies
4 34 Use Controls During Paint Application and Cleanup
• Mix and use the nght amount of paint lor the job Use up one eonlainer before opening a second
one
• f<ecyele or reuse leftover paint vvhentver possible
• Never clean brushes or rinse or dram paini eoniaincrs on the ground (p.tved or unpaved)
• Clean brushes and containers only at sinks and stations ihat dram to the process sewer to the
tailings system
• Paint out brushes to ihe extent possible bclore watei washing (vk'aier-based paint) or sc>lvcnt
iinsing (oil based paint)
• niter and reuse thinners and solvent whenever possible.) Contain solids and unusable excess
liquids f(^r transfer to Ihe tJihiigs area
Page 6
Best Management !*racUces Plan
Revision I ium-Ur^fim^aaiyT 2ul J
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Kquipment
Detailed instructions forcire tinloadin}?. dust suppression and t.4ilings management arc provided
m the Mill SOPs
4 41 Wash Down Vehicles and Equipment in Proper Areas
• W.ish down trucks, trailers, and othei heiNy eqiiipmeni onl> m ireas designuted tot ihis puipose
(siieh as wash down pad are.'is and tile tmck wash station)
• Al the inick wash station make sure the w.iier et»lleCtK)n and reeyelmj: system is working hefoic
turning on water sprats
4 4 2 Manage .^tockpiie>< to Prevent Windborm Contamination
• Water spniy the ore pad and unpaved areas at appropri.ite Irequenev in .iccorclance wiih Mill
SOPs
• Water sprav stockpiles as retjuircd by t^pacity standards or wcaihci conditions,
• Don't over-water Keep surf ices moist but miniini/e runol I water
4 4 3 Keep Eurthmuving ActiMlies from Becoming Pollutant Sources
• Sehedule excavation gr.idin^ and oihci eailhmoving .ictivitics when exiieine diyness and high
winds will not be a f ictor (to prevent tlK need lorexccssivi dust suppiesMoni
• Remove existing vegetation tiniy when .ibsohnelv necessary
• Seed OI pkiiil leinpnr.tty vegcl.Uiuii lorerosiiin conliol on sltipes
Page?
IABI.ES
Page 8
A complete copy of Table 1 will be mcluded m the Stormwater Best Management Practices Plan
maintained at the Mill Site
TABLE 2
REAGENT YARD UST
REAGENT QUANTITY (LBS) NUMBER OF CAPACITY
STORAGE TANKS (GALLONS)
6r1-30 —
ADVANTAGE 101M 2 /]75
AMERSITE 0 —
AMINF 9^RA 19 "110 —
AMMONIUM 54^000 —2 24.366
SULFATE(BULK)
AMMONIUM 4-50026.000 ...
SULFATE(BAGS)
ANHYDROUS AMMONIA 107.920 2 31,409
OH£"ft^ ^ AG' 00 — n ARiFi OP N inip 3 QQQ — TRIDECYLALCOHOL 45,430 —
DIESEL FUEL 2 250
1 6,000
PfcOGGULENT Miotic 30^660 —
FLOCCULENT M130aC —
GRINDING BALLS 4S7S9©72.000 —
ISODECANOL 46,^30 —
KEROSENE 1,344 31 10 16210.315
2 10.095
MACKANATE 3 -[gQ — MUiLSPERSE —
NALCO 2468 0 —
NALCO 8&1^ 0 —
PERCOL 361 1.6000 — PERCOL106 13,060 —
PERCOL7'16 0 —
POLOX 10,360 —
POLYHALL YCF e — PROPANE 1 30.«eQ25.589
SALT (BAGS) 39,280 —
SALT (BULK) 0 —1 13,763
1 18.864
SODA ASH (BAGS) 39.280 —
SODA ASH (BULK) 84,100 1 16.921 SODA ASH (BULK)
1 8,530
SODIUM CHLORATE 101,128 1 47^70016.921
1 4^^60022.561
1 29.940
SODIUM HYDROXIDE 0 T 19,9054
SULFURIC ACID 4,801,440 1 1.600.0001,394.439
?fin ifin
UNLEADED GASOLINE 1 3.000
USED OIL 1 5.000
Page 10
Page 11
TABLE 3 0
LABORATORY CHEMICAL INVENTORY LIST'
Chemical In Lab RQ^ Quantity In Stock
Aluminum nitrate 2270 kg 1 8 kg
Ammonium bifluoride 45 4 kg 2 27 kg
Ammonium chloride 2270 kg 2 27 kg
Ammonium oxalate 2270 kg 6 8 kg
Ammonium thiocyanate 2270 kg 7 8 kg
Antimony potassium tatrate 45 4 kg 0 464
n-8utyl acetate 2270 kg 4L
Carbontotrachlondo 4 64 kg 4-t
Cyclohexane 454 kg 24 L
Ferric chlonde 454 kg 6 81 kg
Ferrous ammonium sulfate 454 kg 0 57
Potassium chromate 4 54 kg 0 1Ukg
Sodium nitrite 45 4 kg 2 5 kg
Sodium phosphate tribasic 2270kg 1 4
Zinc acetate 454 kq 0 91 kq
Chemical, in Volatiles and
Flammables Lockers
(AB.Cl
QQ! Quantity in Stock
Chlorofonn 4 54 kq 8L
Formaldehyde 45 4kq <1Lof 37% solution
Nitrobenzene 454 kq 12 L
Toluene 454 kg J 12 L
Chemical m Acid Shed RQ'^ Quantity in Stock
Chloroform 4 54 kq 55 qal
Hydrochlonc acid 2.270 kq 56 qal
Nitrate acid 454 kq 5L
Phosphoric Acid 2.270 kq 10L
Sulfuric acid
Hydrofluoric acid
454 kg
45 4kq
25 L
1 L
Ammonium hydroxide 454 kq 18L
1 This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117 The lab also stores small
quantities of other matenals that are not hazardous substances per the above
regulation
2 Reportable Quantities are those identified in 40 CFR Part 117 Table 117 3
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act"
Page 12
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST'
CHEMICAL QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,000 Ibs 4 gal
Ammonium Hydroxide 1.000 Ibs 5L
Gar^oo-Dtsttlfi4e 100 lbs
Calcium Hypochlonte 10 lbs 2 kg (4 4 Ibs)
Chlorine 10 lbs Olbs
Ferrous Sulfate Heptahydrate 1,000 Ibs 5 kg (11 Ibs)
Hydrochlonc 5,000 lbs 60 aal of 40% solution
Nitric Acid 1,000 Ibs 10 L
Potassium Permanganate 0 1 N 32 qal 5 kg (11 lbs)
Sodium Hypochlorite 5 5% 100 Ibs 2 kg (11 lbs) of 5 5% Sodium Hypochlorite 5 5%
solution
Silver Nitrate 1 lb Olbs
Trichloroethylene 100 lb 2L
Xylen94Mix«d- Isomer-e^ 400-lte6 04b6
This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Matenals »n this list are stored in a locked storage
compound near the bulk storage tank area Tho Mill also stores small
quantities of other matenals that are not hazardous substances per
the above regulation
Reportable Quantities are those identified in40 CFR Part 117 Table
117 3 "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act"
Page 13
TABLE 5 0
REAGENT YARD/BULK CHEMICALS LIST'
REAGENT RQ' QUANTITY IN REAGENT RQ'
YARD
Sulfuric Acid 1,000 lbs 9 000,000 lbs
F4e6-ff301-4T500-lbs
Hyperlloc 102 None 1.500 Ibs
Ammonia - East Tank 100 lbs Olbs
Ammonia - West Tank 100 lbs 105,000 Ibs
Kerosene 100 gal 500 gal
Salt (Bags) None 2.O0O4bs20.000 lbs
AnirnnniiiiT^ M^^rlff^nrsnH'^**'^*''^^
rTTTTT rTCTrTT WIT r T IVlJTUywl i*JrTTUI^ IU" No^ on 4r^n Ihq
Soda Ash Dense (Bag) None 0-]feG50.000 Ibs
Phosphofltj-Aoid drOOO-lbs 6}300' Ib'S
Polyox None 490 lbs
IUlli|f>r\rtrc><n If IIIIVJ^^^I IJIXJ Nono 1,410 Ibe
NalooTX760 Nofio 9-^afrels
Naloo 7200 Nono 1,600 lbs
Tributyl phosphate None 9.450 lbs
^iono 400-931
Diesel 100 gal Approx 3300 gal
Gasoline 100 gal Approx 6000 gal
Alamlne 336 drums None »4bG8,250 aal
Floe 100 Mono &4b&
0-ltes
Nono
l-l"nnrflnr* fi9/t r^Jono Q
Salt(BulK Solids) None O4be50.000 lbs
Salt(Bulk Solutions) None 04^69.000 oal
Caustic Soda 1.000 lbs 0-lbe16.000 Ibs
Ammonium Sulfate None ©4be150.000 lbs
Sodium Chlorate None 20.000 Ibc350.000 Ibs
Alamlno 336 Bulk Nono 0-lb6
Atamine 310 Bulk None Olbs
Isodecanol None O4tes2.420 oal
Vanadium Pentoxide3 1000 lbs 30.000 lbs
Yellowcake3 None <100,000 Ibs
Ammonia Meta Vanadate 1000 lbs Olbs
Floe 655 21,000 lbs
Floe 712 1.250 lbs
1 This list identifies all chemiceils in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117
2 Reportable Quantities are those identified in 40 CFR Pan 117 Table 117 3 "Reportable
Quantities of Hazardous Substances Designated Pui^uant to Section 311 of the Clean
Water Act'
3 Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or l^ill Yard
Page 14
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST^
PRODUCT 30 QUANTITY IN 30 WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 0-110 gallons
Water Soluble Oils 100 gal 30 110 gallons
Xylene (mixed isomers) 100 gal 0 gallons
Toluene 1000 gal 0 gallons
Varsol Solvent 100 gal 0 gallons
(2% tnmethyl benzene in petroleum
distillates)
This list includes all solvents end petroleum-based products In the Mill
warehouse petroleum and chemical storage aisles
Reportable Quantities are those identified in 40 CFR Part 117 Table
117 3 "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act"
Page 15
FIGURES
Page 16
Figure 1
White Mesa Mill
Mill Site Layout
Page 17
Figure 2
White Mesa Mill
Mill Site Drainage Basins
Page 18
,09 mo
Sufrace Water Flow
Drainage Basins
Diversion Ditches
Diversion Bemi
Demson Mines (USA) Corp oiNitoNOii
WHITE MESA I^IU.
„ , T fSutt ,
Project
REVISKM3 County
Locaton
71 Mr m
Bit
BV
/7«» tm ^10
(^ili Site Drainage Basins
Figure 3
White Mesa Mill
Mill Management Organization Chart
Page 19
It &
C
E
O
la
n
a
g
e
r
es
i
d
e
r
Mi
l
l IV
a.
en
a
n
c
e •
c
n
1 en
a
n
c
e
lo
n
r
t
e
l
c
5
O a. e a.
Figure 4
White Mesa Mill
Denison Mines (USA) Corporation
Organizational Structure
Page 21
Si c o *
5
CJ
APPENDICF-S
Page 23
Appendix 1
Whitt Mesa MIIISIHU Pryventnm. CnntruK iniH Counfcrnie'tsures Plan
Page 24
The Spill Prevention, Control and Countermeasures Plan ("SPCC") Is currently under review
Appendix 2
White Mesni Mill Emergency Resp<inse Plan - " | Formatted Certereti
Page 25
at this time.
stormwater Best Management Practices Plan
Non-Redline
STORMVi^ATER
BEST MANGEMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P O. Box 809
Blanding, Utah
October 201
Prepared by
Denison Mines (USA) Corp
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
1 0 INTRODUCTION/PURPOSE 1
2 0 SCOPE 2
3 0 RE.SPONSIBrLITY . .3
4 0 BEST MANAGEMENT PRACTICES 4
4 1 General Management Practices Applicable to All Areas . ... — 4
4 1 1 Keep Potential Pollutants from Contact with Soil, and Surface Water 4
4 1.2 Keep Potenual Pollutants from Contact with Precipitation ^ .......4
4 1 3 Keep Paved Areas Irom Becoming Pollutant Sources . 4
4 1 4 Inspecnon and Maintenance of Diversion Ditches and Drainage Channels withm ihe Process and
Reagent Storage Area 4
4 I 5 Recycle Fluids Whenever Possible , . 4
4 2 Management Practices for Process and Laboratory Areas ... . ... . . 5
4 2 1 Clean Up Spills Properly . 5
4 2 2 Proiect Matenals Stored Outdoors . 5
4 2 3 Management . 5
4 2 4 Matenals Management . . 5
4 3 Management Practices for Maintenance Acltviues ... 6
4 3 1 Keep a Clean Dry Shop 6
4 3 2 Manage Vehicle Fluids 6
43 3 Use Controls Dunng Paint Removal - .6
4 3 4 Use Controls Dunng Paint Application and Cleanup . . ... 6
4 4 Management PracUccs for Ore Pad, Tailings Area, and Heavy Equipment 7
4 4 1 Wash Down Vehicles and Equipment m Proper Area-s ... 7
4 4 2 Manage Stockpiles to Prevenl Windborne Contamination . . - ^7
44 3 Keep Earthmoving Acuviues from Becoming Pollutant Sources . . .7
Figures
Figure 1 While Mesa Mill Site Layout . . » 16
Figure2' White Mesa Mill Site Drainage Basins 17
Figure 3 Denison Mines (USA) Corp - White Mesa Mill Management Organi7.auon Chart .. 19
Figure 4 Denison Mines (USA) Corp - Corporate Management Organi/auonal Chan 20
Tables
TABLE 1 0 White Mesa Mill Management Personnel Responsible for Implementing This BMPP .9
TABLE 2 0 REAGENT YARD LIST . ... ... 10
TABLE 3 0 LABORATORY CHEMICAL INVENTORY LIST 1 . . . 11
TABLE 4 0 REAGENT YARD/SMALL QUANTITY CHEMICAI.S LIST 1 . , . 12
TABLE 5 0 EAGENT YARD/BULK CHEMICALS LIST 1 . . . 13
TABLE 6 0 PETROLEUM PRODUCTS AND SOLVENTS LIST 1 . . 14
Appendices
Appendix 1 White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
Appendix 2 White Mesa Mill Emergency Response Plan
Best Management Practices Plan
Revision I 4 October 2011
1.0 INTRODUCTION/PURPOSE
Denison Mines (USA) Corp ("DUSA") operates the White Mesa Uranium Mill ("the Mill) in
Blanding, Utah The Mill is a net water consumer, and is a zero-discharge facility with respect to
water effluents. That is, no water leaves the Mill site because the Mill has
• no outfalls to public stormwater systems,
• no surface runoff to public stormwater systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies
The State of Utah issued Groundwater Discharge Permit No UGW370004 to DUSA on March 8,
2005 As a part of compliance with the Permit. DUSA is required to submit a Stormwater Best
Management Practices Plan ("BMPP") to the Executive Secretary of the Division of Radiation
Control, Utah Department ofEnvironmental Quality This BMPP presents operational and
management practices to minimize or prevent spills of chemicals or hazardous materials, which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices m a good faith effort to mininu/e all sources of
pollution at the site
Page 1
Best Managemeni Practices Plan
Revision 1 4 October 2011
2.0 SCOPE
This BMPP identifies practices to prevent spills of chemicals and hazardous matenals used m
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill Storage of ores and
altemate feeds on the ore pad, and containment of tailings m the Mill tailmgs impoundment
system are not considered "spills" for the purposes of this BMPP
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system In addition. Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable matenals), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailmgs cells in accordance with the Mill's NRC license
conditions All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments A site map of the Mill is provided m Figure 1 A
sketch of the site drainage basins is provided in Figure 2
As a result, unlike other industnal facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system However, as good
environmental management practice, the Mill attempts to minmuze
1 the number and size of matenal spills, and
2 the amount of unrecovered spilled matenal and wash water that enters the process sewers
after a spill cleanup.
Section 4 0 itemizes the practices m place at the Mill to meet these objectives
Requirements and methods for management, recordkeeping, and documentation of hazardous
matenal spills are addressed in the DUSA White Mesa Mill Spill Prevention, Control and
Countermeasures ("SPCC") Plan, the Emergency Response Plan ("ERP"),, and the housekeeping
procedures incorporated in the White Mesa Mill Standard Operating Procedures ("SOPs") The
latest revisions of the SPCC plan and the ERP are provided in their entirety in Appendices 1 and
2, respectively
Page 2
Best Management Practices Plan
Revision 1 4. October 2011
3.0 RESPONSIBILITY
All Mill personnel are responsible for implementation of the practices in this BMPP DUSA
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP
The Mill Managemeni Organization is presented in Figure 3 The DUSA Corporate Management
Organization is presented in Figure 4
An updated .spill prevention and control notification list is provided in Table 1
Page 3
Best Management Practices Plan
Revision 1 4 October 2011
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid matenals managed at the Mill is provided in
Tables 2 through 5
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous matenals and other potential pollutants in appropriate containers.
• Label the containers
• Keep the contamers covered when not in use
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk matenals m 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 m use (to keep
precipitation out)
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debns in the solid waste dumpsters or
tailmgs area as appropnate
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures m and around
the Mill area will be inspected at least monthly' in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No UGW370004, and
by product Materials License #UT1900479 Areas requinng maintenance or repau-, such
as excessive vegetative growth, channel erosion or poolmg of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended Status of maintenance or repairs will be documented dunng follow up
inspections and additional action taken if necessary
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable matenals from suppliers who will reclaim empty
containers
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal
Page 4
Best Management Practices Plan
Revision 1 4 October 2011
4 J Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible
• Clean spills of stored reagents or other chemicals immediately after discovery
• (Groundwater Discharge Permit No UGW370004, Section ID 10 c )
• Recover and re-use spilled matenal whenever possible
• Keep supplies of rags, sorbent matenals (such as cat litter), spill collection drums, and personnel
protective equipment ("PPE") near the areas where they may be needed for spill response
• If spills must be washed down, use the minimum amount of water needed for effective cleanup
4.2.2 Protect Materials Stored Outdoors
• If dmmmed feeds or products must be stored outdoors, store them in covered or diked areas when
possible
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible
• Make sure drums and containers stored outdoors are m good condition and secured against wind
or leakage Place any damaged containers into an overpack drum or second container
423 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment When
possible, wipe down the outsides of containers instead of nnsmg them off in the sink.
• When possible, wipe down counters and work surfaces instead of hosing or nnsmg them off to
sinks and drain
4.2.4 Matenals Management
• Purchase and inventory the smallest amount of laboratory reagent necessary
• Do not stock more of a reagent than will be u.sed up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface (Groundwater Discharge Permit No
• UGW370004, Section I.D 3 g)
Page 5
Best Managemeni Practices Plan
Revision 1 4 October 2011
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas
• Clean up spills promptly Don't let minor spills spread
• Keep supplies of rags, collection containers, and sorbent matenal near each work area where they
are needed
• Store bulk fluids, waste fluids, and batteries m an area with secondary containment (double dmm,
dnp pan) to capture leakage and contain spills
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
dnp pans or plastic tarps to prevent spillage and spread of fluids
• Promptly contain and transfer drained fluids to appropnate storage area for reuse, recycle, or
disposal
• Recycle automotive fluids, if possible, when their useful life is finished
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windborne contamination from paint chips and
sandblasting dust
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authonzed to accept waste matenals from maintenance or
construction activities
4.3.4 Use Controls During Paint Application and Cleanup
Mix and use the nght amount of pamt for the job Use up one container before opening a second
one
Recycle or reuse leftover paint whenever possible
Never clean brushes or nnse or dram 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 pamt) or solvent
nnsing (oil-based paint)
Filter and reuse thinners and solvent whenever possible) Contain solids and unusable excess
liquids for transfer to the tailings area
Page 6
Best Managemeni Practices Plan
Revision 1 4 October 2011
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
m the Mill SOPs
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailers, and other heavy equipment only m aieas designated for this purpose
(such as wash down pad areas and tile truck wash station)
• At the truck wash station, make sure the water collection and recycling system is working before
turning on water sprays.
4.4.2 Manage Stockpiles to Prevent Windborne Contamination
• Water spray the ore pad and unpaved areas at appropnate frequency in accordance with Mill
SOPs
• Water spray stockpiles as required by opacity standards or weather conditions.
• Don't over-water Keep surfaces moist but minimize mnoff water
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme dryness and high
winds will not be a factor (to prevent the need for excessive dust suppression).
• Remove existing vegetation only when absolutely necessary
• Seed or plant temporary vegetation for erosion control on slopes.
Page 7
TABLES
Pages
A complete copy of Table 1 will be included in the Stormwater Best Management Practices Plan
maintained at the Mill Site
TABLE 2
REAGENT YARD LIST
REAGENT QUANTITY
(LBS)
NUMBER OF
STORAGE
TANKS
CAPACITY
fGALLONS)
AMMONIUM 54,000 2 24,366
SULFATE(BULK)
54,000
AMMONIUM 26,000 —
SULFATE(BAGS)
ANHYDROUS AMMONIA 107,920 2 31,409
TRIDECYLALCOHOL 45,430
DIESEL FUEL 2 250
1 6,000
GRINDING BALLS 72,000 —
KEROSENE 1,344 1 10,315
2 10,095
POLOX 10.360
PROPANE 1 25,589
SALT (BAGS) 39.280 —
SALT (BULK) 0 1 13,763
1 18,864
SODA ASH (BAGS) 39,280 —
SODA ASH (BULK) 84.100 1 16,921
1 8,530
SODIUM CHLORATE 101,128 1 16,921
1 22,561
1 29.940
SODIUM HYDROXIDE 0 1 19,905
SULFURIC ACID 4,801,440 1.394,439
UNLEADED GASOLINE 1 3,000
USED OIL 1 5,000
Page 10
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST ^
Chemical In Lab RQ" Quantity in Stock
Aluminum nitrate
Ammonium bifluoride
Ammonium chloride
Ammonium oxalate
Ammonium thiocyanate
Antimony potassium tatrate
n-8utyl acetate
Cyclohexane 454
Feme chloride
Ferrous ammonium sulfate
Potassium chromate
Sodium nitrite
Sodium phosphate tnbasic
Zmc acetate
2270 kg
45.4 kg
2270 kg
2270 kg
2270 kg
45.4 kg
2270 kg
kg 24
454 kg
454 kg
4 54 kg
45.4 kg
2270kg
454 kg
1 Bkg
2.27 kg
2,27 kg
6 8 kg
7 8 kg
0 454
4L
L
6.81 kg
0 57
0.114 kg
2 5 kg
1 4
0.91 kg
Chemical. In Volatiles and RQ' Quantitv in Stock
Flammables Lockers
(A.B.C)
RQ'
Chloroform 4.54 kg 8L
Formaldehyde 45 4 kg <1Lof 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical In Acid Shed RQ" Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochlonc acid 2.270 kg 58 gal
Nitrate acid 454 kg 5L
Phosphonc Acid 2,270 kg 10L
Sulfuric acid 454 kg 25 L
Hydrofluonc acid 45 4 kg 1 L
Ammonium hydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2 Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3*
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act"
Page 11
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST ^
CHEMICAL RQf QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,000 Ibs 4 gal
Ammonium Hydroxide 1,000 Ibs 5L
Calcium Hypochlonte 10 lbs 2 kg (4 4 lbs)
Chlonne 10 Ibs Olbs
Ferrous Sulfate Heptahydrate 1,000 Ibs 5kg(11lbs)
Hydrochloric 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 Ibs 10L
Potassium Permanganate 0 1 N 32 gal 5 kg (11 Ibs)
Sodium Hypochlorite 5.5% 100 Ibs 2 kg (11 Ibs) of 5 5%
solution
Silver Nitrate 1 lb Olbs
Tnchloroethylene 100 lb 2L
This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area The Mill also stores small
quantities of other matenals that are not hazardous substances per
the above regulation.
Reportable Quantities are those identified in40 CFR Part 117 Table
117 3* "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act"
Page 12
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST^
REAGENT RQ' QUANTITY IN REAGENT RQ'
YARD
Suifunc Acid 1,000 Ibs 9,000.000 lbs
Hyperfloc 102 None 1,500 lbs
Ammonia ~ East Tank 100 Ibs Olbs
Ammonia - West Tank 100 Ibs 105,000 Ibs
Kerosene 100 gal 500 gal
Salt (Bags) None 20,000 Ibs
Soda Ash Dense (Bag) None 50,000 Ibs
Polyox None 490 Ibs
Tnbutyl phosphate None 9.450 Ibs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx 6000 gal
Alamine 336 drums None 8,250 gal
Salt(Bulk Sohds) None 50,000 lbs
Salt(Bulk Solutions) None 9,000 gal
Caustic Soda 1,000 Ibs 16,000 Ibs
Ammonium Sulfate None 150,000 Ibs
Sodium Chlorate None 350,000 (bs
Alamine 310 Bulk None Olbs
isodecanol None 2,420 gal
Vanadium PentoxideS 1000 lbs 30,000 Ibs
YellowcakeS None <100,000 Ibs
Ammonia Meta Vanadate 1000 Ibs Oibs
Floe 655 21.000 Ibs
Floe 712 1,250 lbs
1. This list identifies all chemicals m the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2 Reportable Quantities are those identified in 40 CFR Part 117 Table 117 3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act"
3 Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building anc^brMill Yard
Page 13
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST^
PRODUCT RQ QUANTITY IN RQ
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal 0 gallons
Toluene 1000 gal 0 gallons
Varsol Solvent 100 gal 0 gallons
(2% tnmethyl benzene in petroleum
. distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 14
FIGURES
Page 15
Figure 1
White Mesa Mill
Mill Site Layout
Page 16
Figure 2
Figure 3
White Mesa Mill
Mill Management Organization Chart
Page 18
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White Mesa Mill
Denison Mines (USA) Corporation
Organizational Structure
Page 20
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APPENDICES
Page 22
Appendix 1
White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
Page 23
The sp„. Prevention. Control and Countermeasures Plan ,"SPCC',« currently under review.
White Mesa Mill uK^iResponsePlan
Page 24
The White Mesa Mill Emergency Response Plan is not being resubmitted because there are no changes
at this time
Attachment B
Attachment C
StateofUtah
JONM HUNTSMAN,JR
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
Anunda Smith
Ae^ Executive Direcior
OrVlSlON OF RADIATION CONTROL
Dane L Pmerftock
Director
September 30,2011
CERTIFIED MAIL
(Return Receipt Requested)
Jo Ann Tischler
Director, Compliance and Penmtting
Demson Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT' Proposed Concrete Pads for Drum Management, White Mesa Uramum Mill Ground Water
Discharge PemutNo. UGW370004; Conditional Approval
On Sqjtember 26,2011 the Division of Radiation Control (DRC) received through email a single-sheet
plan for new concrete pads for dmm management at the Alternate Feed Area at the DUSA White Mesa
Uranium Mill, near Blandmg, Utah, The subject line in the cover message accompanying the plan
referenced the September 1,2011 Request for Information and Confirmatory Action Letter, Storm water
Inspection.
DRC understands the project to include placement of concrete flatwork as a management surface for drums
of feedstock. The pads will mclude low-profile rolled curb at the pwiphery to provide material contamment
for spills that may occur. The pads will slope to existing dram sumps, thus preventing spilled feedstock
matenal fiom washing onto surroimding soils.
DRC has reviewed the submitted plan for conformance with the intent of Part l.D.l 1 ofthe White Mesa
Uramum Mill Ground Water Discharge Permit No. UGW370004 (Permit) and find the plan to con^)ly with
this Permit requirement; therefore, the plan is approved, subject to the following conditions:
1, DUSA shall submit As-Built drawings withm 14 calendar days upon completion of the project
for Executive Secretary review and approval. The As-Built drawmgs will include a section or
detail ofthe curbmg constructed on the pwiphery ofthe pads as a material containment feature.
The plan will include sufficient spot elevations to detail how the pads will dram. The record
drawing will reflect any deviations fix>m the approved plan.
2 The pads shall not be placed in service until approval of the As-Built drawings by the
Executive Secretary
m North 1950 Weet * SaH Lake City, tTT
Mailing Address' P O, Box I448S0 • Salt Lake City, UT 841144SS0
Telephone(801)536^250• Fax(801)533^097 'TDD [phone]
Printed oa 100% recycled p^er
Jo Ann Tischler
September 28,2011
Page 2
DRC limited its review ofthe subject plan to evaluating conformance with the intent ofthe Pemiit. No
stmctural evaluation or value engme^g was performed as part of the review.
Ifyou have any questions on the above, please contact Russ Topham, of my stafi^ at [phone].
UTAH WATER QUALITY BOARD
Rusty Lundberg ^
Co-Executiye Secretary
RL:RT:rt
F:\itoph8m\DUSA\IHJSA Altemate Feed Dram ManBgeinenUioc
Attachment D
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Attachment E
Attachment F