DRC-2011-007565 - 0901a0688028b4c0

DENISO
MINES
November 10, 2011
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tei : 303 628-7798
Fax: [phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
IVIr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of October 6, 2011 Regarding 1 le.(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill 11e.(2)
Byproduct Disposal SOP in response to DRC's letter of October 6, 2011, which we received on October 11,
2011. In response to the comments, we have attached an edited redline copy and a clean copy ofthe
proposed changes to the SOP and its attachments.
For ease of review we have quoted DRC's comments verbatim in /te//cs below, followed by Denison's
responses.
DRC Comment
/. License Condition 10.5E states,
"The licensee shall also submit for Executive Secretary approval a revised written Standard Operating
Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised SOP shall describe the
documentation required for ISL disposal, which shall include but is not limited to the following:"
"(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an area
of the cell that is underlain by tailings sands;
"(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of the
uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed of in the
cells pursuant to License Condition 10.4, and the ISL byproduct material from each in-situ leach source will
be segregated from the byproduct material from all other in-situ leach sources;
"(4) Absence of void space inside barrels disposed, including physical verification before disposal; and
(5) Detailed engineering drawings which demonstrate:
"a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
N:\SOPsand Procedupes\SOP repsonse 11e2 Disposal\11.10.11 Response to DEQM I.10.11 Response to DEQ comments
11e2S0P.doc
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 2011
Page 2
"b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the tailings
cell."
The form enclosed in Attachments of the subject September 12, 2011 DUSA letter was proposed to fulfill
the requirements above. It appears that in some cases, additional verbiage will need to be added to the
body of the SOP for said form to reference, in order to fulfill these requirements. We note the following:
A. License Condition 10.5E(2) is not captured on the form. The form needs to call for or make
reference to the required documentation of a survey and review, or other documentation, that will
show the specific requirements of License Condition 10.5E(2) have been met It does not appear
this requirement is captured in the body of the SOP.
Denison Response: A line item has been added to the form referencing the survey or review to confirm the
elevation limit will not be exceeded.
B. License Condition 10.5E(3) is not completely captured on the form. The form needs to call for or
make reference to the required documentation to demonstrate that ISL material is segregated from
both disposed mill material/equipment as well as all other in-situ leach sources.
It appears that the form needs to make reference to:
i) . The plats of the designated ISL byproduct material disposal areas mentioned in the SOP.
ii) . Plats of the disposed mill material and equipment, which demonstrates segregation from the
ISL material.
These may be separate or joint plats containing the separation information. It does not appear this
entire requirement is captured in the body of the SOP.
Denison Response: Line items have been added to the form and text has been added to the SOP referencing
plats or figures demonstrating that the ISL material has been properly segregated from other wastes.
C. License Condition 10.5E(4) is not completely captured on the form. The form needs to call for or
make reference to the required documentation of an examination and filling the pertinent barrels
and other documentation, that will demonstrate that all disposed barrels meet the specific
requirements of License Condition 10.5.E(4).
This item is tied to License Condition 10.5B, which states that, "Barrels containing soil or sludges
shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal." It does not appear that documentation requirement for this is
captured on the form.
Denison Response: Line items requiring that the barrels be inspected for voids and that voids be filled have
been added to the form as requested.
D. License Condition 10.5.E(5) appears to not be fully captured on the form. The form needs to call
for or make reference to the required detailed engineering drawings that demonstrate that the
dimensional clearance requirements as stated in License Condition 10.5.E(5), for each disposal
area are met. Although it appears the body of the SOP contains this requirement, it does not
appear the form states or references the documentation required.
The requirements referring to documentation addressing dimensional clearance have been added to the form
as required.
DENISO
MINES
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 2011
Page 3
//. License Condition 10.5D states that, "All disposal activities shall be documented and records thereof
maintained on-site. The documentation shall include descriptions of the ISL waste and the disposal
locations, as well as all actions required by this License condition." This License Condition requires
documentation of all [ISL] disposal activities in License Condition 10.5, paragraphs A through F. Section I
of this letter above is devoted to paragraph 10.5E. License Condition 10.5A and 10.5F are adequately
covered. Therefore our comments below are limited to License Conditions, i.e. 10.5B through 10.5.D:
A. License Condition 10.5B. Our comment regarding this condition is covered by paragraph I.C of
this letter.
Denison Response: No specific response required.
B. License Condition 10.5C is not completely captured on the form. The SOP appears to make
partial reference to this condition in paragraph 3.7 of the SOP. The form needs to call for or
make reference to the required documentation to assure the complete specific requirements of
this License Condition have been met. These complete requirement needs to be added to the
body of the SOP as well.
Denison Response: Additional language addressing License Condition 10.5C has been added to the SOP and
the form as requested.
C. License Condition 10.5D. Our comments on this License Condition 10.5D are contained in the
comments of this letter.
No response required.
///. Additional Comments.
A. The subject SOP,
(i) Paragraph 6.4, the term "shipping container" may be interpreted to refer to several
things. It appears the term "shipping container" in this paragraph may be intended to
refer to shipping trailers or truck beds. Please define this in the SOP. "Shipping
containers" must be defined to not include containers such as sacks or barrels.
Denison Response: The change has been made as requested.
(ii) Paragraph 10.2b, the second bullet, after the words "void spaces," the phrase "in
barrels containing soil and sludges," must be added.
Denison Response: The phrase has been added as requested.
DENISO
MINES
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 2011
Page 4
Please contact me if you have any questions or require any further information.
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
lie.(2) Byproduct Material Disposal SOP Clean
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 1 of 12
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives 1 le.(2) byproduct material ("byproduct material")
from uranium in-situ leach operations for disposal under License Condition 10.5. The following
procedure applies to acceptance, handling, and disposal of byproduct material at the White Mesa Mill
(the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 10 and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The RSO will also verify, prior to receipt of any shipment of byproduct material, that the disposal of
such byproduct material will not cause the Mill to exceed the limit of 5,000 cubic yards of byproduct
material from a single source, set out in Mill License condition 10.5A
3.0 Designated Disposal Area
The RSO will designate from time to time one or more designated disposal areas (each a "Designated
Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each
Designated Disposal Area must meet the following criteria:
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 12
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the byproduct material from all other in-situ leach sources;
7. ISL wastes will be disposed in cells that have received prior written approval from the
Executive Secretary for this purpose.
8. Prior written approval must have been obtained from the Executive Secretary of the Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Executive Secretary
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
kept on file at the Mill.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 3 of 12
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
DUSA's safety rules and procedures while on company property. The scale house operator
will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training
Forms will be turned in to the Safety Department for future reference.
2. Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that
the shipment is destined for the Mill and confirm with the RSO that the shipment has been
approved for receipt.
3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Radiation Safety Department so that the shipment
can be escorted by Radiation Safety personnel to the Designated Disposal Area specified by
the RSO.
6. Prior to transporting material to the Designated Disposal Area, the driver will be instructed to
open or untarp the load. The Radiation Safety personnel will visually inspect, to the degree
possible, the byproduct material to ensure that the material matches the material description on
the shipping manifest. Any discrepancies between the byproduct material received and the
manifest information will be reported to the RSO.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the RSO
that the material in question conforms to Section 2.0 of this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
6.0 Byproduct Material Unloading
1. The RSO will specify the specific location within the broader Designated Disposal Area for
disposal of the shipment. In designating the specific location within the broader Designated
Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will
be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill
license condition 10.4, and that the byproduct material from each ISL source will be segregated
from the byproduct material from all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location in the
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Titie: 1 le.(2) Byproduct Disposal
Page 4 of 12
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
taifings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Radiation Safety personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material received and
the manifest information will be reported to the RSO. Any byproduct material suspected of not
meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 5 of 12
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of
f) Beta-gamma measurements will be taken at several locations around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 1 meter, and the average measurement,
measured in mrem/hr at 1 meter, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Radiation Department's copy of the shipment
documentation. If organics are detected, the RSO must be advised, and no compaction or
covering activities relating to the shipment shall occur until specifically instructed by the RSO.
The RSO will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The RSO will also contact DUSA corporate regulatory personnel and the shipper
to verify that the detected organics are lle.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material compaction and
covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all
other unloading activities of byproduct material from that particular ISL site will require the
use of respiratory protection, until further notice by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
I) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the byproduct
material will be spread within the designated area within the Designated Disposal Area to
facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: Ile.(2) Byproduct Disposal
Page 6 of 12
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The RSO or his designee will inspect the placement of the byproduct material prior to covering
to physically verify that the procedures in this Section 7.0 have been adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify DUSA whether a specific trailer is to be released for restricted or
unrestricted use. Any trailers that are to be released for restricted use will be decontaminated
according to the requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers
that are to be released for unrestricted use will be decontaminated according to the requirements found
in Table 1 of the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safetv
c) Use caution when the trailers are backing to the unloading area.
No.: PBL-10
Rev, No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 7 of 12
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
t) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 8 of 12
a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
Shipper's Manifest and Bill of Lading.
Laboratory/activity analysis of the byproduct material performed by the Shipper.
Completed SWT.
7-day notice to Executive Secretary.
Photo of the byproduct material.
Byproduct material radiological scan information.
Breathing zone monitoring data, if applicable.
Equipment release forms.
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Conflrmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
2. The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
3. An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Executive Secretary on or before November 1 of the calendar year. (License
Condition 10.5F). [summary due same year]
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 9 of 12
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Denison Mines (USA) Corp.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck tuming over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 10 of 12
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
Was the State of Utah given notice to the receipt^disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 12
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
RSO's Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal?
Documentation of approval
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 12
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
lie.(2) Byproduct Material Disposal SOP Redline
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 1 of 12-J-
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
©910, 2011
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives He.(2) byproduct material ("byproduct material")
from uranium in-situ leach operations for disposal under License Condition 10.5. The following
procedure applies to acceptance, handling, and disposal of byproduct material at the White Mesa Mill
(the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 10 and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The RSO will also verify, prior to receipt of any shipment of byproduct material, that the disposal of
such byproduct material will not cause the Mill to exceed the limit of 5,000 cubic yards of byproduct
material from a single source, set out in Mill License condition 10.5A
3.0 Designated Disposal Area
The RSO will designate from time to time one or more designated disposal areas (each a "Designated
Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each
Designated Disposal Area must meet the following criteria:
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 12+
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that tThe elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
b)c) ^ach disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the byproduct material from all other in-situ leach sources;
7. ISL wastes will be disposed in cells that have received prior written approval from the
Executive Secretary for this purpose.
^8. Prior written approval must have been obtained from the Executive Secretary of the Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
8T9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Executive Secretary
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
Formatted: Font: (Default) Times New
Roman, 12 pt, Not Italic
Formatted: Indent: Left: 0.5", No bullets or
numbering
Formatted: Font: Not Bold
Formatted: List Paragraph, No bullets or
numt)ering, Widow/Orphan control
Formatted: Indent: Left: 0.75"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 124
Date: Sept. I2Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
kept on file at the Mill.
5.0 Byproduct Material Receiying
1. When each truck driver enters the restricted area for the first Ume, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
DUSA's safety rules and procedures while on company property. The scale house operator
will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training
Forms will be turned in to the Safety Department for future reference.
2. Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that
the shipment is destined for the Mill and confirm with the RSO that the shipment has been
approved for receipt.
3. Record the inbound date and both the imck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Radiation Safety Department so that the shipment
can be escorted by Radiation Safety personnel to the Designated Disposal Area specified by
the RSO.
6. Prior to transporting material to the Designated Disposal Area, the driver will be instructed to
open or untarp the load. The Radiation Safety personnel will visually inspect, to the degree
possible, the byproduct material to ensure that the material matches the material description on
the shipping manifest. Any discrepancies between the byproduct material received and the
manifest information will be reported to the RSO.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the RSO
that the material in question conforms to Section 2.0 of this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
6.0 Byproduct Material Unloading
1. The RSO will specify the specific location within the broader Designated Disposal Area for
disposal of the shipment. In designating the specific location within the broader Designated
Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will
be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill
license condition 10.4, and that the byproduct material from each ISL source will be segregated
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 4 of 12+
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
Page 4 of 12+
0910. 2011
from the byproduct material from all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location in the
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to FuHy Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is. the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Radiation Safety personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material received and
the manifest information will be reported to the RSO. Any byproduct material suspected of not
meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12Nov.
0910. 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Pages of 12+
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of.
f) Beta-gamma measurements will be taken at several locadons around the unloaded material.
This information will be recorded on the Radiadon Department's copy of the shipment
documentation. The measurement range in mrem/hr at 1 meter, and the average measurement,
measured in mrem/hr at I meter, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Radiation Department's copy of the shipment
documentation. If organics are detected, the RSO must be advised, and no compaction or
covering activities relating to the shipment shall occur undl specifically instructed by the RSO.
The RSO will determine if any additional safety precaudons are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The RSO will also contact DUSA corporate regulatory personnel and the shipper
to verify that the detected organics are lie.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material compaction and
covering acdvities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activides. If
the gross alpha exceeds 25% of die applicable DAC, then die RSO will be notified, and all
other unloading activides of byproduct material from that particular ISL site will require the
use of respiratory protection, undl further nodce by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal acdvities will be documented as described in Secdon 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the byproduct
material will be spread within the designated area within the Designated Disposal Area to
facilitate compacdon and covering.
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 6 of 12+
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910, 2011
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or taiHngs sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The RSO or his designee will inspect the placement of the byproduct material prior to covering
to physically verify that the procedures in this Section 7.0 have been adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify DUSA whether a specific trailer is to be released for restricted or
unrestricted use. Any trailers that are to be released for restricted use will be decontaminated
according to the requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers
that are to be released for unrestricted use will be decontaminated according to the requirements found
in Table 1 of the Nuclear Regulatory Commission's (NRC's) Pohcy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be wom in the restricted area of the Mill. Prior to
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 7 of 12+
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safetv
c) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is Ln a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 8 of 12+
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
Shipper's Manifest and Bill of Lading.
Laboratory/activity analysis of the byproduct material performed by the Shipper.
Completed SWT.
7-day notice to Executive Secretary.
Photo of the byproduct material.
Byproduct material radiological scan information.
Breathing zone monitoring data, if applicable.
Equipment release forms.
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 9 of 12+
Date: Sept. l2Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
Designated Disposal Area, which illustrates the location of each shiprnent of
byproduct material.
The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
3. An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Executive Secretary on or before November 1 of the calendar year. (License
Condition I0.5F). [summary due same year]
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 10 of
Date: Sept. I2Nov. Tide: 1 le.(2) Byproduct Disposal 12+
0910. 2011
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Denison Mines (USA) Corp.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck tuming over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 11 of
Date: Sept. 12Nov. Tide: 11 e.(2) Byproduct Disposal 12+
0910. 2011
Driver (Signature) Date
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 12 of
Date: Sept. 12Nov. Title: 11 e.(2) Byproduct Disposal 12+
0910, 2011
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 13 of
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal 12+
0910,2011
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved bv the executive Secretary
for ISL waste disposal?
Documentation of approval
Was the ISL material segregated from disposed Mill material and odier
ISL material?
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness_of subsequent Ufts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g.. survey or review)
Engineer's or
RSO's Initials
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
Are additional settiement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 14 of
Date: Sept. 12Nov. Tide: 1 le.(2) Byproduct Disposal 12+
0910. 2011
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
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UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
DRC-04
Page 8 of 20
License #l|T!_900479
Amendment
tr,\*:::ffi71:::M-:::,.,:,:::c.nduc,edasdescribedin
' "--4li."rr" q,94 andMay 23,1995. with the
following addition:
The maximum lift thickness for materials placed over tailings shall be less than 4-feet
thick. Subsequent lifts shall be less than 2-feet thick. Each lift shall be compacted by
tracking of heavy equipment, such as a Cat D-6, at least 4 times prior to placement of
subsequent lifts.
."bA 10.5 In accordance with the licensee's submittal to the NRC dated May 20,1993, the licensee is
hereby authorized to dispose of byproduct material generated at licensed in-situ leach (ISL)
facilities, subject to the following conditions:
d oirporu6ffG*te is limited to 5000 cubic yards from a single source..-/
B.
application, including the January 10, 1990 Drainage Report. Discharge of any surface
water or wastewater from Cell I is expressly prohibited.
The freeboard limit for Cells 3,4A, and 48 shall be recalculated annually in accordance
with the procedures approved by the Executive Secretary Said calculations for freeboard
limits shall be submitted as part of the Annual Technical Evaluation Report (ATER), as
described in Condition 12.3 below.
The discharge of any surface water, stormwater or wastewater from Cells 3, 4,A., and 48
shall only be through an Executive Secretary authorized spillway structure.
[Applicable NRC Amendment: ]61 [Applicable UDRC Amendment 3] [Applicable
,{[frArtaminated equipment shall be dismantled, crushed, or sectioned to minimize\.<--4--voasteotherthansoilorsludgesshallbeemptiedintothe
disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified
by the Licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal.
All ISL waste shall be buried i l is obtained
from the Executive Secretary for alternate burial locations.
All disposal activities shall be documented and records thereqf&il1gllg3-e0=SiLe. The
documentationshallincludeosallocations,as
C.
C.
D.
well as all actions requi
UTAH DIVISION OF RADIATION CONTROL
RADIOACTIVE MATERIALS LICENSE
SUPPLEMENTARY SHEET
DRC-04
Page 9 of 20
License #W)999479'
Amendment
v
E.The licensee shall also submit for Executive Secretary approval a revised written
The revised SOP shall describeth ired for ISL disposal, which shall
include but is not limited to thef<i
(l)The material disposal area must be located oJ a tailings beach ryqa of the
JZ"-4 ,i- tz>
the elevati-ons of the uppermost flexible membrane liner of the tailings cell;
r.,f**."{Q)-g@"t disposed of_in the cells purffiidFicense Conditi
Sucffi)vnroduct material will be sesresated from anv mill
cio'eu ISL bvoroduct material from each in-situ leach source will be sesresated from
the byproduct material from all other in-situ leach sglggs;
-
ebr"n." of roia tp*e inside barrels disposed. ir.Iudirgltry@[94lgglig_,
before disposal; and
Detailed engineering drawings which demonstrate:
a. There are at least 4 feet of tailings sands under the bottom of each
disposal area; and
b. The bottom of each disposal area is located at least l2feetfrom the sides
or dikes of the tailings cell.
,T,,F (4)
(s)
disposal ""l@o, un -"u of th" ""ll th rd.;
The elevation of the !qq!g!ql1!!gp@ area will not exceed the plane or grade of
The Licensee shall notify the Executive Secretary in writing at least 7 calendar days
materi-4l generated at
ISL facilities in the tailings cells.
F.
An annual summary of the amounts of waste disposed of from off-site ISL eenerators:nhall be sent to the Executive QgqeEl}pn or bef-o{gi!,eye4gbct I of each calendar year.
[Applicable UDRC Amendment: 4]
10.6 The licensee is authorized to receive and process source materials from the Allied Signal
Corporation's Metropolis, Illinois, facility in accordance with the amendment request to the
NRC dated June 15, 1993.
10.7 The licensee is authorizedto receive andprocess source material from Allied Signal, Inc. of
Metropolis, Illinois, in accordance with the amendment request to the NRC dated September 20,
1996, and amended by letters to the NRC dated October 30,1996 and November 11, 1996.
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DTVISION OF RADIATION CONTROL
Dane L. Finerfrock
Director
March 1,2010
CERTIFIED MAIL
(Return Receipt Requested)
David C. Frydenlund
Vice President and General Counsel
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: October 30, 2008 DUSA Request for Amendment to Update Existing License Conditions
Relating to Disposal of Byproduct Material for ISL Facilities and Mill-Generated Non-
Tailings Wastes in Tailings Cells; September 14, 2009 DRC lnspection Letter; Radioactive
Materials License No. UT1900479; Request for Information
Dear Mr. Frydenlund:
We have reviewed the subject October 30, 2008 letter from DUSA. ln the letter, DUSA proposes an
amendment to the license. It appears the primary purpose for the amendment would be to allow disposal of
non-tailings mill waste and ISL byproduct material into any active tailings cells at the site. The DUSA letter
also proposes using similar requirements for mill waste and ISL byproduct material.
We need to collect additional information prior to completing the processing of your request. To safeguardthelinersofthenewercellswerequeSt:,.*ffi"@c4^c49
/
1$ 1,. troposed methods and procedr16s to fully protect the liner while accessinn taili for disposal\' / otlSL byproduct material and'mill equipment must be submitted for approval Tttc:se: methods and
@ procedures would apnly to tailings Cell 4A and ne."er cells. #-
. \ B. The Executive Secretary shall be notified in writing at least 7 calendar days prior to disposal ofYy byproduct material generated at in-situ leach facilities,
r C. Proposed methods and procedures to assure that all disposal activities shall be documented. The
ff) documentation shall include descriptions of the waste and the disposal locations, as well as all actions
| , ./ required by this condition, including the following:
1). the disposal area is on a tailings beach area of the cell or on an area of the cell that is
underlain by tailings sands;
2). the elevation of the disposal area, once filled with such material and equipment, will not
exceed the elevation of the flexible membrane liner of the tailings cell; and
168 North 1950 West . Salt lake Ciry, UT
Mailing Address: P.O. Box 144850 . Salt take Ciry, UT 84114-4850
Telephone [phone]. Fax [phone] . T.D.D. (801) 5364414
www.deq.utah.gov
Printed on 100% recycled paper
* C" .vrA 1i
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J*r
Mr. David C. Frydenlund
March 1,2010 '_LPage2 \(@
3). such byproduct material will be segregated from any material and equipment disposed of
in the cell pursuant to license condition 10.4, and the byproduct material from each in-
situ leach source will be segregated from the byproduct material from all other in-situ
leach sources.
4). drawings which demonstrate:
a. there are at least 4 feet of tailings sands under the bottom "@ ISL source
disposal area;
3; ii,i"lXT?ft",ff1*
ISL source disposal area is located at least t2 reet from the sides
With respect to the above, some provisions in the upcoming license amendment will be added for these items.
Please review the above comments, and respond in writing submitting the requested information. We will
continue our review ofthe subject request on receipt ofthe above information. Ifyou have any questions on
the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
LBM:DAR:dr
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DENIsOJ)J/
MINES
October 30, 2008
VIA PDF AND FEDERAL EXPRESS
Mr. Dane L. Finerfrock
Executive Secretary
Utah Fladiation Control Board
State of Utah Department of Environmental Quality
168 North 1950 West
Salt Lake City, UT 84114-4850
0 -n- .'/LiL/r.t L.t''l '2A-a- t
'Dcnigon Mincs (USA) Cotp.
1050 17th Strcct, Sultc 950
Donver, CO 8m65
usA
Tel : 303 62&7798
Fax : 3G1 38S4125
wrcw,dcnilonmincg.com
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Re: lftlhite Mesa Uranium Mill; Radioactive Materials License No. UT19fi)479 - Request
for Amendment to Update Existing License Conditions Relating to Disposal of
Byproduct Material from ISL lacilities and Milt-Generated Non-tailings Wastes in
Tailings Cells
Dear Mr. Finerfrock:
Denison Mines (USA) Corp. ("Denison") hereby requests an amendment to its State of Ulqh
Radioactive Mat6rials'License No. UT1900479 (the "License") lor the White Mesa Uranium Mill
(the "Mill") to update the existing license condit'rons relating to the disposal of 11e.(2) byproduct
material ("Bypioduct Material")-from in situ leach ("lSH uranium recovery facilities and site-
generated non-tailings wastes ("MillWaste") in the Mill's tailings cells.
1. tntroduction and Summary
License conditions 10.4 and 10.5 currently authorize the Mill to dispose of Mill Waste into a
designated area of tailings Cell 2 and Bypioduct Material into tailings Cell 3, respectively. The
designated area for disp-osal of Mill Waite in Tailings Cell 2 has now reached its_capacity and
the iemaining disposal area for Byproduct Material in tailings Cell 3 is limited. By this letter,
Denison requests an amendment- to its License that would authorize disposal of Byproduct
Material and MillWaste into other tailings cells at the site, as described in detail below.
2. Background lnformation
2.1. Descriotion of Current and Future Tailinqs Cells
The tailings impoundment system at the Mill is currently comprised of four celts. Tailings Cell 1,
which is an evaporation pond, was completed and put into use in June 1981. Tailings Cell 2
was completed and put into use in May 1980, and is currently covered with interim. cover.
Tailings Cell 3 was 6ompleted and put-into use in September 1982 and is currently active,
although its remaining disposal capacity is limited. Tailings Cell 4A was constructed and put
into use in 1989 and-was used foi a s6ort period of time to receive tailings solutions untit Mill
operations ceased in 1991. Cell 44 fell into disrepair after that time. All oJ the tailings solutions
\
(
re-lined and
was authorizedby the Executive Secretaryfor use on September 17,2008.
The initial environmental analysis and license application for the Mill contemplatgd six tailings
cells, currently existing Cells {, 2 and 3, as well as 3 additional 80-acre cells, Cells 4, 5 and 6.
With the construction 6f Cett4A, which is 40 acres, Cell48 willconsume the second,40 acres of
the previously authorized 8O-acre Celt 4. On June 11,2008, Denison applied lor a License
amehdment to authorize the construction of Cell 48. ln the future, as operations. warrant,
Denison will submit applications for the construction of the remaining tailings cells.
2.2. Generation and Disposalof MillWaste at the Mill
Under normal Mill operations non-taitings waste, such as waste paper, lightbulbs, scrapped
equipment, trash and other waste is generated on a day-to-day basis. The Nuclear Begulatory
Gommission has advised that:
nVaste generated within the site boundary are wastes related to ore
processing and, as such, can be disposed of as 11e.(2) byproduct
material. Waste disposed of in the tailings impoundment should be
placed so that it does not impact the long term stability of the
impoundment."l
Accordingly, such wastes have been authorized for disposal in the Mill's tailings cells. The
current authorization is contained in License condition 10.4, which states that:
"10.4 Disposal of material and equipment generated at the mill site shall
be bonducted as described in the licensee's submittals to the NRC
dated December 12, 1994 and May 23, 1995, with the following
addition:
A. The maximurn lift thickness for materials placed over tailings
shall be less than 4-feet thick. Subsequent lifts shall be less
than 2-feet thick. Each lift shall be compacted by tracking of
heavy equipment, such as a Cat D-6, at least 4 times prior to
placement of subsequent lifts."
The May 23, 1995 letter referred to in License condition 10.4 specifies that the Mill Waste will be
disposed of in a designated area of Cell2. That area has been filled with Mill Waste_ and interim
iorier has been placed over all of Cel! 2. There is therefore no rq)m remaining in Gell 2 for the
disposalof MillWaste.
2.9. Disposalof Bvoroduct Material at the Mill
On May 20, 1993, Urnetco Minerals Corporation, the then operator of the Mill, applied for a
License amendment to permit the disposal of Byproduct Material from third pafi ISL uranium
recovery facilities at the Mill. ln response to that application, NRG amended the License by
adding what is now License condition 10.5, which provides that:
"10.5 ln accordance with the licensee's submittal to the NRC dated May
20, 1993, the licensee is hereby authorized to dispose of byproduct
material generated at licensed in-situ leach facilities, subject to the
following conditions:
! See correspondence dated March 7 ,2W3 from Mr. Paul l,ohaus, Direclor, Officc of State and Tribal Programs to
Mr. William J. Sinclair, then Director of the State of Utah Department of Environrnental Quality, Division of
Radiation Control.
oEN'soJ)/l
I}IINES
I
,
yards from
)
': fir:E i '{i:,:;
a single
B. All contaminated equipment shall be dismantled, crushed, or
sectioned to minimize void spaces. Barrels containing waste
other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or
sludges shall be verified to be full prior to disposal. Barrels not
completely full shall be filled with tailings or soil.
C. All waste shall be buried in Cell No. 3 unless prior written
approval is obtained from the Executive Secretary lor alternate
burial locations.
D. All disposal activities shall be documented. The
documentation shall include descriptions of the waste and the
disposal locations, as well as all actions required by this
condition. An annual summary of the amounts of waste
disposed of from off-site generators shall be sent to the
Executive Secretary."
3. Proposed License Amendment
As can be seen from the foregoing, there are two issues to be addressed. First, the License
needs to be amended to allow for the disposa! of Mill Waste in tailings cells other than Cell 2,
since the designated disposal area in Cell 2 is no longer available. Second, as the rernaining
disposal capacity in Cell 3 is limited, it would also be beneficial at this time to provide for the
disposal of Byproduct Material in other tailings cells.
!n order to address these issues, Denison proposes the following License amendments:
3.1. Amendment to License Condition 10.4
Denison proposes that License condition 10.4 be amended as follows:
(a) By adding the phrase "and the licensee's submittal to the Executive Secretary dated
October 30, 2008" after the phrase "May 23, 1995";(b) By changing the phrase 'lvith the following addition" in the third line of the condition to
"subject to the following conditions"; and(c) Br;Adfid tii; turiowild fi'"sr."ph B: -
"8. The Mill may designate any area in an active tailings cell as the
designated area for disposal ol such material and equipment in that
cell, provided that:
l. the disposal area is on a tailings beach area of the cell or on
an area of the cellthat is underlain by tailings sands;11. there are at least 4 feet of tailings sands under the disposal
area;lll. the disposal area is located at least 4 feet from the sides or
dikes of the tailings cell;lV. the elevation of the disposal area once filled with such material
and equipment will not exceed the elevation of the flexible
membrane liner of the tailings cell; and
to
Disposal ol waste is limited to 5000 cubic
source.
A.
(
DENlsoJ)l/ilrNES
()
license condition 10.5."
As amended, License condition 10.4 would read as follows:
"10.4 Disposal of material and equipment generated at the mil! site shall be
conducted as described in the licensee's submittals to the NRC dated
December 12, 1994 and May 23, 1995 and the licensee's submittal. tothe Executive Secretary dated October 30, 2008, subject to the
following conditions:
A. The maximum lift thickness for materials placed over tailings
shall be less than 4-feet.thick. . Subsequent lifts shall be less
than 2-feet thick. Each lift shall be compacted by tracking of
leH,ri"?rl'3i1"Jl'a"'#,il.?in,i.tat
D-6' at reast 4 times prior to
B. The Mill may designate any area in an active tailings cell as
frl'r1f:'f,1f,\"r1, 3!?,?ofJ,o35P,n"ff'
or such materiar and
t. the disposalarea is on a tailings beach area of the cell or
on an area of the cellthat is underlain by tailings sands;ll. there are at least 4 feet of tailings sands under the
disposalarea;, il3[i*iif:?H'#[I'i::'i,,:: LT;[ :H
material and equipment will not exceed the elevation of
the flexible membrane liner of the tailings cell; andV. such materialand equipment will be segregated from any
11e.(2) byproduct material disposed of in the cell
pursuant to license condition 10-5."
This amendment will allow lor the orderly disposal of Mill Waste in appropriate locations in
active tailings cells, without the need for similar license amendments in the luture as new cells
are commissioned.
3.2. Amendment to License condition 10.5
Denison proposes that License condition 10.5 be amended as follows:
(a) By adding the phrase 'and the licensee's submittal to the Executive Secretary dated
October 30, 2008" after the phrase "May 20, 1993; and(b) By replacing existing subparagraph C. with the following:
"C. The Mill may designate any area in an active tailings cell as the
designated area for disposal of such byproduct material in that cell,
provided that:
l. the disposal area is on a tailings beach area of the cellor on
an area of the cell that is underlain by tailings sands;ll. there are at least 4 feet of tailings sands under the disposal
area;lll. the disposal area is located at least 4 feet from the sides or
dikes of the tailings cell;
OENISOJ)//TIINES
)
lV. the elevation ol the disposal area once filled with such
byproduct rnaterial will not exceed the elevation of the
flexible membrane liner of the tailings cell; andV. such blryroduct materialwill be segregated from any material
and equipment disposed of in the cell pursuant to license
condition 10.4, and the byproduct material from each in-situ
leach source will be segregated frorn the byproduct material
lrom each other in-situ leach source."
As amended, License condition 10.$npuldread as follows:
"10.5 ln accordance with the licensee's submittal to the NRG dated May
20, 1993 and the licensee's submittal to the Executive Secretary
dated October 30, 2008, the licensee is hereby authorized to
dispose of byproduct material generated at licensed in-situ leach
facilities, subiect to the following conditions:
A. Disposal of waste is limited to 5,000 cubic yards lrom a
single source.
B. All contaminated equipment shall be dismantled, crushed, or
sectioned to minimize void spaces. Barrels containing waste
other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or
sludges shall be verified to be full prior to disposal. Barrels
not completely full shall be filled with tailings or soil.
C. The Mill may designate any area in an active tailings cell as
the designated area for disposal of such byproduct material
in that cell, provided that:
I. the disposal area is on a tailings beach area of the cell
or on an area of the cell that is underlain by tailings
sands;ll. there are at least 4 feet of tailings sands under the
disposalarea;lll. the disposal area is located at least 4 teel from the
sides or dikes of the tailings cell;!V. the elevation of the disposal area once lilled with such
byproduct material will not exceed the elevation of the
flexible mernbrane liner of the tailings cell; andV. such byproduct material will be segregated from any
material and equipment disposed of in the cell pursuant
to license condition 10.4, and the byproduct material
from each in-situ leach source will be segregated from
the byproduct material from each other in-situ leach
source.
D. All disposal activities shall be documented. The
documentation shall include descriptions of the waste and
the disposal.locations, as well as all actions required by this
condition. An annual summary of the amounts of waste
disposed of from off-site generators shall be sent to the
Executive Secretary."
OENlsOJilIiltNES
o
Material
in the
4. Standard Operating Procedures
The Mill's current standard operating procedures relating to the disposal of ,Mill Waste and
Byproduct Material are attached to this letter. Denison will amend these procedures as
necessary to reflect any amendments made by the Executive Secretary to License conditions
10.4 and 10.5.
5. Staging of Mill Waste Pending Amendment to License Condition 10.4
As the designated disposal area in tailings Cell 2 is no longer available, any Mill Waste
generated at the site that requires disposal at this time is being staged on the interim cover of
Cell 3 pending amendment to License condition 10.4. The staging area is fenced to minimize
any windblown dispersion of the staged MiltWaste- lf the amendment is granted as requested,
the staged Mill Waste will be disposed of in a designated area in Cell 3. However, if the
proposed amendment is not granted as requested, the staged Mill Waste can be moved to
another location designated by the Executive Secretary.
As the Mill is already authorized to dispose of Mill Waste and Byproduct Material in its tailings
impoundment system, and the proposed amendment merely addresses the specific disposal
locations within the system, Denison believes that the requested amendment is not a "major
amendmenf within the meaning of UAC R313-24-3. As a result, an environmental report as
contemplated by that rule for major amendments is not necessary and is not contained in this
application.
lf you have any questions or require any further information, please contact the undersigned.
This amendment will allow for the orderly disposal of Byproduct
in active tailings cells, without the need for specific approvals
commissioned.
Regulatory Affairs and Counsel
Ron F. Hochstein
Harold R. Roberts
Steven D. Landau
David E. Turk
in appropriate locations
future as new cells are
DEN'SOJ)/I,SINE'
No.: PBL-7
Rev. No.: R-l
DENISON MrNES (USA) COR
STANDARD OPERATING PROCEDURES
Title: Mill Waste Di
t
l. Purpose
License Condition 10.4 authorizes disposal of material and equipment ("Mill Waste")
generated at the White Mesa Mill (the "Mill"). The following procedure applies to
disposal of Mill Waste at the Mill. This procedure may be amended, subject to approval
by Denison Mines (USA) Corp.'s ("DUSA's") Safety and Environmental Review Panel
(SERP).
2. Disposal Site
The disposal area for Mill Waste comprises approximately 10.3 acres in tailings Cell2
and is shown as the shaded area on the attached Figure 1.0.
The disposal area is composed of coarse tailings material deposition, providing adequate
cover over the liner to prevent liner rupture. Disposal will occur in those areas in the
designated disposal area where the elevation is significantly below the final deposition
elevation of 5615 feet.
3. Mill Waste Authorized for Disposal
Mill Waste includes all non-tailings wastes generated at the Mill site. Some examples of
Mill Waste are:
All trash from office buildings and plant buildings, which includes all typical
trash items as well as such things as light bulbs, NiCd batteries, discarded office
equipment, etc;
Discarded Mill equipment, including mobile equipment, pumps, structural tanks,
structural steel, piping, rubber tank liners, conveyor belting etc.;
Rubber (seals, gaskets, pump liners);
Wood items;
Product; feed and reagent drums, crushed to eliminate void spaces;
Wastes generated by the Radiation Safety Department (e.g., filters, bioassay
containers, etc.);
Wastes generated by the Mill's laboratory;
Discarded clothing and respirator cartridges generated within the Mill;
Debris from conventional ores and alternate feed materials;
Clean up materials from spills or other on-site or offsite contamination generated
from Mill activities; and. Any other waste materials generated within the Mill site boundary and
surrounding property in connection with Mill activities.
a
a
o
a
a
o
a
o
)
4, Placement and Covering of Mill Waste
4.1. Placement
Mill Waste will be placed in the designated disposal area and compacted in a manner to
minimize void spaces and nesting and to enhance compaction, as follows:
(a) Mill Waste will be placed at the edge of the tailings Cell cover, where the
cover ends and the beaches begin. The Mill Waste will then be pushed over
the edge of the tailings Cell cover where the tailings beaches begin;
(b) Heavy items, or those with sharp or protruding surfaies, will be placed in an
area of the cell containing a sufficient thickness of deposited tailings to ensure
that no damage will occur to the Cell's liner and drain system;
(c) The maximum lift thickness for Mill Waste placed over tailings shall be 4-feet
thick. Subsequent lifts shall be less than 2-feet thick;
(d) Each lift will be compacted by tracking of heavy equipment, such as a Cat D5,
at least 4 times prior to placement of subsequent lifts;
(e) All Mill Waste with void spaces will be crushed, filled or sectioned in an effort
to minimize these void spaces and to enhance compaction;
(0 All equipment shall be dismantled, crushed, or sectioned as required to
minimize void spaces. Solid metals, concrete, masonry, and wooden members
will be cut into pieces no greater than lO-feet long and no more than 27 cubic
feet in volume. Structural steel members, pipe and other long items will be cut
or broken into l0-foot lengths or smaller;
(g) Large structural tanks will be dismantled or filled with tailings solids to
minimize void spaces. Large structural tanks that are not dismantled will
require written approval by the Mill Manager or Radiation Safety Officer, prior
to disposal;
(h) Barrels containing waste other than soil or similar material shall be emptied
into the disposal area and the barrels crushed. Barrels containing soil or
similar material shall be verified to be full prior to disposal. Barrels not
completely full shall be frlled with tailings or soil. AII empty bamels shall be
crushed prior to placement;
(i) To the extent necessary to minimize the migration of waste, small items such
as coveralls, office waste, and other lightweight materials will be placed in
plastic trash bags or other containers. These plastic bags or other containers
will then be disposed of in layers with the rest of the materials; and
DENTSON MINES (USA) COR
STANDARD OPERATING PROCEDURES
Title: Mill Waste Di
No.: PBL-7
Rev. No.: R-1
Date: Oct.28,2008
No.: PBL-7
Rev. No.: R-l
DENISON MINES (USA)
STANDARD OPERATING PROCEDURES
Title: Mill Waste
t
0) If necessary, random fill or tailings will be used to fill voids in and around the
Mitl Waste.
4.2. Covering
Random fill cover will be advanced along the disposal areas as needed, to minimize the
migration of Mill Waste. The random fill will be taken from stockpiles at the site, and
will contain varying sizes of rocks intermixed with soil. The waste and cover material
will be compacted with at least one pass of the construction equipment. The disposal
area will be considered full when the entire disposal site reaches the final authorized
tailings deposition elevation of 5615 feet. The disposal area will then be covered with an
interim random fill cover in the siune manner as other areas of the tailings cell once the
final tailings deposition elevation is reached in those other areas.
5. Inspections and Documentation
The Mill Waste disposal area will be inspected on a daily basis during daily tailings
inspections, in order to ensure that the materials are sized and disposed of properly. Any
observations of concern will be noted on the daily tailings inspection forms.
If no observations of concem are noted during the daily inspections, the weekly tailings
inspection form will document any unusual conditions of the disposal areas each week.
6. Hazard Identification and Safety
The following safety procedures apply to all activities covered by this SOP:
6.1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed
shoes are required at a minimum. These must be worn in the restricted area of the Mill.
6.2. Industrial Hazards and Safety
(a) Use caution when any trailers are backing to the disposal area.
O) Ensure that all personnel within 50 feet of the area where an end dump trailer
is about to dump its load are awiue that unloading is about to commence.
Move at least 25 feet away from the rear of the trailer during the initial
unloading operation.
(c) Drivers must use caution during the unloading process and be aware of any
overhead hazards.
No.: PBL-7
Rev. No.: R-l
Date: Oct.28,2008
DENISON MINES (USA) COR
STANDARD OPERATING PROCEDURES
Title: Mill Waste Di
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(d) Do not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
(e) Use caution when entering or exiting equipment. Be sure to use the ladders
and hand rails. Ilo notjump offthe equipmenl
(0 Always use a ladder when entering and/or exiting the interior of a trailer.
6.3, Mobile Equipment
(e)
Only trained and authorized persons may operate mobile equipment.
All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be
driven to the shop for repairs. Otherwise, the equipment must be towed or
repaired at the location.
Audible backup alarms shall be in operating condition.
Walk around any piece of equipment before starting or moving it. Make
certain no one is in a dangerous position and there are no obvious defects or
hazards.
Use caution when entering or exiting equipment. Be sure to use the ladders
and hand rails. Do not jump offthe equiprnent.
Seat belts shall be used at all times when equipment is in motion.
Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of l5 m.p.h.
Keep the cabs of equipment clean. Loose items that could jam controls or
create other hazards are not allowed.
(D Report all accidents to your supervisor regardless of how minor they are. If
property damage or personal injury is involved, do not move the equipment
until your supervisor has released it.
0) All gasoline engines must be shut off when refueling.
(k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain
adequate berms where required.
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No.: PBL-10
Rev. No.: R-l
Date: Oct.24,2008
DENISON MIIIES (USA) CORP.
STANDARD OPERATING PROCED
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1.0 hrrpose
Denison Mines (USA) Corp. ("DUSA") receives l1e.(2) byproduct material ("byproduct
material") from uranium in-situ leach operations for disposal under License Condition
10.5. The following procedure applies to acceptance, handling, and disposal of
byproduct material at the White Mesa Mill (the "Mill"). This procedure may be
amended, subject to approval by DUSA's Safety and Environmental Review Panel
(SERP).
2.O Prior to Shiprnent of Bvoroduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety
Off,rcer ("RSO"), or his designee, prior to shipment to the Mill. The byproduct material
must conform to Titles 1O and 49 of the U.S. Code of Federal Regulations ("CFR") and
the Shipper must certify that the byproduct material does not contain hazardous waste as
defined in the Resource Conversation and Recovery Act (*RCRA").
lnformation regarding the byproduct material to be disposed of should be received prior
to receipt of the shipment at the Mill, and shall include:
volume of material in cubic feet or yards, or quantity of drums and their
A description of the material (e.g. sludge, process materials, filter media, pipe,
etc.)
A description of the shipping container (i.e. end dump trailer, intermodal
container, side dump container, etc.)
Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils
and other material that is suited to sample collection. If a representative sample
of the material was taken in connection with a previous shipment of material,
then the results of that previous representative sample may be relied upon, and
may be referred to or restated in the documentation that accompanies the
shipment of the material. For byproduct material which is not suited to sample
collection (i.e. metals, process equipment, filter media, pipes, etc.) the Shipper
will determine the range, the average and the total activity, measured in mrfttr at
a range of one meter, for each shipment.
A copy of the completed shipping manifest that will accompany the shipment
and the anticipated shipping date.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL facilities and Mill Waste Disposal\PBl-10-l le (2) SOP Rev
I (10.29.08).doc
No.: PBL-10
Rev. No.: R-l
Date: Oct.24,2008
DENTSON MINES (USA) CORP
STANDARD OPERATING PROC
Title: I le.(2) B
3.0
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4.
5.
When each truck driver enters the restricted area for the first time, the scale
house operator will provide hazard training for the driver. The driver will be
provided with the Safety Training Form (copy attached). All drivers will be
required to read the Safety Training Form and sign and date the Safety Training
Form indicating that they understand and agree to follow DUSA's safety rules
and procedures while on company property. The scale house operator will sign
the Safety Training Form as the instructor for DUSA. Completed Safety
Training Forms will be turned in to the Safety Department for future reference.
Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to
ensure that the shipment is destined for the Mill and confirm with the RSO that
the shipment has been approved for receipt.
Record the inbound date and both the truck and trailer numberc on the Scale
house Weight Ticket (SWT).
Enter the loaded weight of the truck and trailer on the SWT.
The scale house operator will contact the Radiation Safety Department so that
the shipment can be escorted by Radiation Safety personnel to the designated
disposal area in Cell 3.
Bvproduct Material Unloadine
Radiation Safety personnel will escort the shipment to the designated location in
Cell 3 for unloading of the byproduct material.
Prior to unloading the driver is instructed to open or untalp the load. The
Radiation Safety personnel will visually inspect the byproduct material to ensure
that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material received and the manifest
information will be reported to the RSO. Any byproduct material suspected of
not meeting the requirements set forth in Section 2.0 of this SOP will be kept
segregated from other waste material until a determination is made of its
acceptability for disposal.
If acceptable, the byproduct material is then unloaded in the designated area. If
the material is in a self-unloading container, the driver is instructed to unload
ensuring all personnel are clear of the trailer and the immediate area. Byproduct
material will be dumped from the transport in a safe manner to minimize dust. If
the material requires unloading by a fork truck, a ramp will be installed and
unloading will proceed.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL facilities and Mill Waste Disposal\PBl-I0-l le (2) SOP Rev
I (10.29.08).doc
4.0
I.
2.
3.
No.: PBL-I0
Rev. No.: R-l
DENTSON MIVES (USA) CORP
STANDARD OPERATING
Title: I le.(2) B
4.
5.
6.
After unloading, a photo of the unloaded material will be taken which is attached
to the shipping documentation for verification of shipment contents.
The location of the shipment of the byproduct material will be documented on the
plat of Cell 3 illustrating the byproduct disposal area.
Beta-gamma measurements will be taken at several locations around the unloaded
material. This information will be recorded on the Radiation Department's copy
of the shipment documentation. The measurement range in mr/hr at I meter, and
the average measurement, measured in mr/hr at I meter, shall be recorded.
Measurements using a photoionization detection meter ("PID") will be taken at
several locations around the unloaded material to ensure that there are no organics
present- The information will be recorded on the Radiation Department's copy of
the shipment documentation. If organics are detected, the RSO must be advised,
and no compaction or covering activities relating to the shipment shall occur until
specifically instructed by the RSO. The RSO will determine if any additional
safety precautions are required to be taken by workers or otherwise as a result of
the detection of the organics, and will implement any such precautions. The RSO
will also contact DUSA corporate regulatory personnel and the shipper to verify
that the detected organics are I le.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are Byproduct Material
compaction and covering activities will proceed.
A breathing zone sample will be taken periodically during unloading and cover
activities. If the gross alpha exceeds 257o of the applicable DAC, then the RSO
will be notified, and all other unloading activities of byproduct material from that
particular ISL site will require the use of respiratory protection, until further
notice by the RSO.
After unloading the byproduct material, replace the tarp or close the trailer, unless
the trailer is being decontaminated for unrestricted release.
Direct the driver back to the scales for an empty weight.
The scale house operator will record the empty weight on the appropriate SWT.
Coverine of Bvproduct Material
After the byproduct material has been accepted by the RSO, or his designee, the
byproduct material will be spread to facilitate compaction and covering.
The byproduct material will be compacted with at least one pass of the
construction equipment prior to placing an additional layer.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL facilities and Mill Waste DisposalUPBL-10_l le (2) SOP Rev
I (10.29.08).doc
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3- Free volumes in the byproduct material will be minimized by f,rlling, sectioning,
or crushing. Random fill or tailings will be used to fill voids in and around the
byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to
minimize void spaces. Barrels containing waste other than soil or sludges shall be
emptied into the disposal area and the barels crushed. Barrels containing soil or
sludges shall be verified to be full prior to disposal. Barrels not completely full
shall be filled with tailings or soil.
5- A one foot thick, or thicker, cover comprised of native soil will be placed over the
byproduct material working area. The fill and cover material will be compacted
with at least one pass of the construction equipment.
6.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving theMill. Shippers or transporters will notify DUSA whether a specific trailer is to be
released for restricted or unrestricted use. Any trailers that are to be released for
restricted use will be decontaminated according to the requirements contained in DOT
Part 49 CFR 173.441(b) and 173,443. Any trailers that are to be released for unrestricted
use will be decontaminated according to the requirements found in Table I of the Nuclear
Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987. Trailers requiring repair will be decontaminated for
unrestricted release, to facilitate repairs by the transporter at the transporter's own site.
Trailers may be repaired without undergoing full decontamination if repaired within the
restricted area of the Mill.
For the appropriate decontamination procedures, refer
Operating Procedures for the appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
to the following Standard
SOP PBL-9
SOP PBL-2
SOP-PBL-2
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Hazard Identification and Safetv
Required Personal Protective Equipment (PPE)
ln all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be worn in the restricted
area of the Mill.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL facilities and Mill Waste Disposal\PBl-10-l le (2) SOP Rev
I (10.29.08).doc
No.: PBL-10
Rev. No.: R-l
Date: Oct.24,2W8
DENISON MrNES (USA) CORP
STANDARD OPERATING
No.: PBL-10
Rev. No.: R-l
DENISON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
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2.Industrial Hazards and Safety
Use caution when the trailers are backing to the unloading area.
Ensure that all personnel within 50 feet of the area where an end dump trailer is
about to dump its load are aware that unloading is about to commence. Move at
least 25 feet away from the rear of the trailer during the initial unloading
operation.
Drivers must use caution during
overhead hazards.
the unloading process and be aware of any
Do not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump offthe equipment.
Always use a ladder when entering and./or exiting the interior of a trailer.
Mobile Equipment
Only trained and authorized persons may operate mobile equipment.
All mobile equiprnent shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be
driven to the shop for repairs. Otherwise, the equipment must be towed or
repaired at the location.
Audible backup alarms shall be in operating condition.
Walk around any piece of equipment before starting or moving it. Make certain
no one is in a dangerous position and there are no obvious defects or hazards.
Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump offthe equipment.
Seat belts shall be used at all times when equipment is in motion.
Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of 15 m.p.h.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL facilities and Mill Waste Disposal\PBL-10_l le (2) SOP Rev
I (10.29.08).doc
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b)
c)
d)
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3.
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b)
c)
d)
e)
f)
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No.: PBL-10
Rev. No.r R-l
Date: Oct. U,2ffi8
DENISON MrNES (USA) CORP
STANDARD OPERATING
h) Keep the cabs of equipment clean. l,oose items that could jam controls or create
other hazards are not allowed.
Report all accidents to your supervisor regardless of how minor they are. If
property damage or personal injury is involved, do not move the equipment until
your supervisor has released it.
All gasoline engines must be shut offwhen refueling.
Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required.
Documentation
For each shipment of byproduct material the following records will be maintained
in the Mill's Radiation Department files:
. Shipper's Manifest and Bill of Lading.o Laboratory/activity analysis of the byproduct material performed by
the Shipper.o Completed SWT.o Photo of the byproduct material.. Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.. Equipment release forms.
The Mill will also maintain a plat of Cell 3, which illustrates the location of each
shipment of byproduct material.
Z:\DAVE\White Mesa Mill\l le.(2) from ISL tacilities and Mill Waste Disposal\PBl-10_l le (2) SOP Rev
I (10.29.o8).doc
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SAEETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safetv
l. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 m.p.h. Denison Mines (USA) Corp.'s equipment has the right of
way on the ore pad and Mill roadways.
Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
Check for potential overhead hazards prior to dumping.
If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
Be aware of slippery conditions on the ore pad during periods of inclement weather.
Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
Use caution when entering or exiting equipment.
Radiation Safetv
All drivers are required to scan for alpha radiation prior to leaving the Milt Restricted Area.
All equipment, i.e. tnrcks and trailers, will be scanned for radiation prior to Ieaving the Mill's
Restricted Area.
Driver (Printed)Scale House Operator
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4.
5.
6.
7.
8.
9.
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1.
2.
Driver (Signature)Date