DRC-2011-007350 - 0901a0688026cfd5

C-201
ISO
MINES
September 12, 2011
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: [phone]
www.denisdnmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: StateofUtah 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 August 4, 2011 Regarding 11.e(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill 11 e.(2)
Byproduct Disposal SOP in response to DRC's letter of August 4, 2011, which we received on August 11,
2011. This ALigust 4, 2011 letter contained one comment, detailed below, regarding Item No 4 of our May 31,
2011 letter and draft revisions to the SOP. We have attached an edited redline copy ofthe SOP in which
Denison's modifications or additional language in response to DRC's comment are indicated in a second
color.
We have discuss^lj the comment in DRC's August 4, 2011 letter with Mr. David Rupp, who indicated that
although our draft revisions to the SOP attempted to address Item No. 4, the response letter was unclear or
incorrectvr He indicated that Denison needed to:
a) Correct the letter's quotation of DRC's comment, and
b) Modify the SOP and attachment, as necessary, to more exactly address each word in the license
conditions referred to in DRC's comment
We have re-quoted below, DRC's comment on Item No. 4, and revised our response.
DRC Comment
"Item No. 4 of your May 31, 2011 letter appears to not fully respond to DRC comment no. 4 in the subject
April 21, 2011 DRC letter."
For ease of reference. Comment No. 4 of DRC's April 21, 2011 letter is also provided below in its entirety.
"License Condition 10.5E states that,
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...'
N:\SOPs and Procedures\SOP repsonse 11e2 Disposal\09.12.11 response to comment 4\09.12.11 Response to DEQ
08.04.11 RFI 11e2S0P.doc
Letter to Mr. RustyLundberg
l ie.(2) SOP RFI Response
September 12, 2011
Page 2
DRC Findings: The emphasis here is on documentation. License Condition 10.5D also requires
documentation, "of all disposal activities." DUSA must develop a form for ISL disposal
documentation, to cover all the documentation requirements of License Condition 10.5E and 10.5D."
Denison Response: The revisions have been made as requested. The proposed language has been
accepted with the additional text shown in color in Section 10.0 of the SOP. A form has been added as
Attachment 2 of the SOP.
We hope this clarifies any confusion that resulted from our former response to Comment No. 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
Mii^ES
1 le.(2) Byproduct Disposal SOP
Clean Copy
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 1 of 11
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives lle.(2) byproduct material ("byproduct material")
from uranium in-situ leach operations for disposal under License Condition 10.5. The follovving
procedure applies to acceptance, handling, and disposal of byproduct material at the White Mesa Mill
(the "Mill").
2e0 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 Umit 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: Sept. 12,2011
DENISON MINES (USA) CORP,
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 11
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. 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
7. 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.
8. 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. |
j
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
No.: PBL-10
Rev. No : R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 3 of 11
Forms will be tumed 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
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
No.: PBL-10
Rev. No.: R-3
Date: Sept 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 4 of 11
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 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.
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.
No.: PBL-10
Rev. No.: R-3
Date: Sept 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
PageSof 11
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.
1) 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.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantied, 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
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 6 of 11
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 v^ill 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 ofthe 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 Safety
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.
No.: PBL-10
Rev. No.: R-3
Date: Sept 12,2011
DENISON MINES (USA) CORP,
STANDARD OPERATING PROCEDURES
Title: lie.(2) Byproduct Disposal
Page 7 of 11
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.
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.
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.
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
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 8 of 11
3.
• 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 wiU include:
• How the material was placed in the tailing cells;
• If void spaces 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);
• Confirmation 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.
The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
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: Sept 12, 2011
DENISON MINES (USA) CORP,
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 9 of 11
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. tmcks 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: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 10 of 11
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal area?
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
No.: PBL-10
Rev. No : R-3
Date: Sept 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 11
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
Are additional settiement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
No.: PBL-10
Rev. No.:
Date:
feS^SegtjDee
201 JO
^TD^
STANDARD OPERATING PROCEDURES
iitJe: ne.(2) Byproduct Disposal Page 1 of
£106
faiEQse
Denison Mines (USA) CorD r^Di A
materiaro from uranium iT-s tu ^a^^^ i^T'' ^l''^^^ byproduct material (^^product
0.5. The followmg procX "^^^^^^^
'^P^^^^^^'-^^^rial at the White Mes handling, and disposal of
5.
KSCS,:-- ~- -^^os. ,y .e Mn, Ra.a.on Safe,
must conform to Titles 10 and ^9 o?I ut'co7 f.'''"- ''^^ ^yP^o^uot mateS
the Shipper certify that the byprla tSfa T ^^SuMions ("CFR") and
defined m the Resource Conservat.o'n andTove^^^^^^^^^^ --^^ as
totSS ES^^^^^ Of Should he received Prior
The volume of « in cuhic feet or yards, or quantity of drums and their
A descnption Of the materia, (e., sludge, process materials, filter med.a, pipe,
'oSSdl?:,££te:r"^^ ^""^ ^-rmodal |
of the material was taken ifctrniTon ^f
then the results of that prevLrrrpresemrv ' '''T''' '"'P""^"' °f "'^'^"al,
may be referred to or restST th " f '""P^" """y ^^"^^ upon, and
shipment of the material FrbvoLf'. ''^^""'ftation that accompanie the
collection (i.e. metals, process eadle ''"^"'^ "^'^ ^^mple
will determine the IgT lL^^F^.T'^^^^^
"'^-^lO^a^^ali^"^:^^^ measuJ^n
-^r^i^tSSi^S"' ""^^^^ ---P-y ''^e shipment
2.
3.
4.
sal of such byprodict^ateriirwi^na c^^^^^^^^^^^ ^^P^^^"'^^ '"-ferial, that the
cubic yards of byproduct material from a '''''''^ ^^^^ '^it of 5,000
^^^i^j^gg^f^g^^^^^^m^^ source, set out m Mill License condition
meets the RCRArequirenients. ' Also is tf^re.^}rie.
RC^ as a hazardous waste, a iriatend S ^ a
^hd wastei^r the^RC]^definiuorf^ sSI^
foS A If ^^^^^^^^^^^"^t^^'^^stSs^. analysis for RCRA eharactenstics w^^^^ anv^vilue ^
in co^mmns thattaV^teirndVakc^^ ,' characteristic waste. "Becausf* nV^ov^u ,
KVKA.due tfi its dngin, no-analysis or specific
on Ie,(2),l^pro<iuct and is not .combined with anv other matenal'or wa<it^ 7111,1, ;"™"V"«'iy,
radiological safety assessment by the RSO
No.: PBL-10
Rev. No.: R-33
Date:
toeSeetDee. 1,
20110
DENISON MINES (USA) CORP
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal Page 2 of
£106
10.5 A
5.
6.
Designated nisposali ArP5>
an area Ot the cell that is underlain by tailings sands;
3^ The„ mu„ be teas, 4 feet of ,aili„p sands under fte Designated Disposal Area;
The elevation ofthe Designated Disposal Area once filed wid, byproduct n™r2:irjr,?^e''Sngs?:r'*^'"™"°""*^^^^^^^
r.ss=feS^hXes-^^^
" S'SAle'a"::^""'"'''"^^""*""*''''''"""-"''^'^^^^^^
"""fh'i nr?D^",-^P?''*'^^' """'^ ''^''^ ol'f^med from the Executive Secretary of ^e Utah Radiation Control Board (the "Executive Secretary") for each
suchinnf ""r^'^'^' underMill License condition lasc and 'dence of such approval must be on file at the Mill. "cvmenceor
trench areas ortailm^rs heacjiare^. The procf.fl..r^. F»r ni^^f^mmt irr nnt
I 2.
Comment fRSJ: Define^^pe of disposal, fe'
placed iha'trenchoi^putoh
.descnbe.th^diffencesfpreabhtypet^^ I,
have seen evidence ofBoth types of disposal during
my inspections; V . ^ '
Comment" PAT43; There is no.differencein
procedure for material placed in either trench areas
or taihngs beach areas Matenal frora each ISL is
placed jn its designated area as'pre-deteniwped by' 1
the RSO. Designatedareas^ai^e^^ssigned on the basis ^
Qt. what af-e> .IS ayalable;\tQ^
matenal from each'lSL so^rie. ' Jher6iLno criteria'^'
.forselectioh^of tr^^^
difference in ptacerhent or cover:. . \, ' f> ;
Formatted: Indent: Left: 0.5", No bullets or numbering
STANDARD OPERATING PROCEDURES
Title: l le.(2) Byproduct Disposal
Page 3 of
9106
4,0 NotificatimtoEsecu^^ Secretary
notification will be kept on file at the Mill
5.0 pypr"'<"'-* Material RecemnS
1 When each truck driver enters the restrictedjea fo^^^^^^ %t'twefwm be
house operator will P-ide^haxard tr.mng,
I provided with the Safety Trammg Fom ^^^^^^^^ ^ign and date the
' Lets will be required to re^ the S^^J^ ^ agree to follow
Safety Training Form indicating ^^^^^J/^f! "^^^pany property. The scale
DUSX'S safety r"l^^ instructor for DUSA.
future reference.
2.
4.
5.
the shipment has been approved for ,ece,p,^
house Weight Ticket (SWT).
Enter the loaded weight of the truck and trailer on the SWT.
Disposal Area specified by the RSO.
instructedio.^^
yisuallxil^EeeUei^^
infonnatiQavd^^
confonmiQjectim2.0^^
Formatted: Numbered + LeveL 2 +
Nutribering Style: a, b, c + ^tert at 1 + Alignment: Left + Aligned at: 1 + Indent at.
1.25"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 4 of
Date: Title: 1 le.(2) Byproduct Disposal £106
JuncSept.DsG. 1,
20110
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
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1.25"
Formatted: Bullets and Numbering
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 in situ leachlSL source will be
segregated from the byproduct material from eaeh-ail other in situ leachlSL
source^. Formatted: Not Highlight
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 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.
h, 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 taihngs 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 taihngs 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.
Formatted: Indent: Left: 0", Hanging: 0.75",
Outline numbered + Level: 1 + Numbering
Style: 1, 2, 3,... + Start at: 1 + Alignment: Left
+ Aligned at: 0" + Tab after; 0.5" + Indent
at: 0.5", Tab stops: 0.75", List tab + Not at
0.5"
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
Formatted: Indent: Left: 0.75", No bullets or
numbering
4T- Prior to unloading, the drivor will bc instructed to open or untarp the load. The
Radiation Safety personnel will visually inspect the byproduct material to ensure
that the material matches tho material description on the shipping manifest. Any
discrepancies betw^een the byproduct—material received and the manifest
F:\WP\Divi5ion of Radiation ControlVDoniGon Minos, DUSAXLic. LRA & Liconso AmondmontsMSL
Amondmontfor2010\DRCMarkupProp llo2 SOPs 12 1 10
DR&RJ.dochttp://intranot.donisonmines.coni/donver/Executive/DAVE/White Mes
facilitioa and Mill Waoto DispoaayPBL 10_1 lo (2) SOP Rov 1 (12 01 10) (2).doc
MiIl/llo.(2) from ISL
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 5 of
Date: Title: 1 le.(2) Byproduct Disposal £106
JuneSept.D@c. L
20110
information will be reported to the RSO. Any byproduct material suspected of
not mooting the requirements set forth in Section 2.0 of this SOP will bo kept
scgrogatod from other waste material until a determination is made of its
acceptability for disposaL
Jf 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 J3e, but is not required to be
contained in the shipping container on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
{Formatted: Not Highlight
6.5. _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 RSQ. 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.
Formatted: Indent: Left: 0.25", Hanging:
0.25"
d) After unloading, a photo of the unloaded material will be taken which is attached*
to the shipping documentation for verification of shipment contents.
Formatted: Indent: Left: 0.25"
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.
Formatted: Indent: Left: 0.25", Hanging:
0.25"
F:\WP\Division of Radiation ControADenison Mines, DUSA\Lic. LRA & Liconse AmondmontsMSL
Amondmont for 20 lOXDRC Markup Prop no2 SOPs 12 110
DR&RJ.dochttp.7/intranet.denisonmines.com/denver/Executive/DAVE/White Mesa Mili/1 lo.(2) from ISL
faciiitioG and Mill Wasto Diopooal/PBL 10_1 lo (2) SOP Rov 1(12 01 10) (2).doc
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 6 of
Date: Title: 1 le.(2) Byproduct Disposal £106
JunsSept.Dcc. 1,
20110
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 ('TID") 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
facihty. 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
nodce by the RSO.
i) iDisposal- activitios shall be documented through photographs, a vvritteft
description or both. They shall include:
How tho material was placed in thc taihng cellsr
-—If void spaces were filled with tailings;
How thc area was compacted:
Document that thc 4 foot tailing sands under the
The shipment was properly covered;-and
Where settlement markers w^ere placedT
shipment was maintained
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Comment [R5]:' This might be a better fit in a
d/fferent spot of thfe SOP or slightly different ,^ - ^ >
lariguagebut you get ^the idea.. The main thing is that the entire activity from acceptance to jfinal ,
depositioh needs.to be documented - \ •
[Comment [3At63:,vPlease see Section 10 ^
Formatted: Bulleted + Level: 1 + Aligned at:
0.54" + Tab after: 0.79" + Indent at: 0.79"
Formatted: Bullets and Numbering
i^After unloading the byproduct material, replace the tarp or close the trailer, unless*
the trailer is being decontaminated for unrestricted release.
Formatted: Indent: Left: 0.25", Hanging:
0.25"
ftkj) Direct the driver back to the scales for an empty weight.
kHk) 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.
F:\WP\Divi5ion of Radiation Control\Denison Mines, DUSA\Lic, LRA & Liconso AmondmontsMSL
Amendment for 2010\DRC Marlcup Prop 1 lo2 SOPs 12 1 10
DR&RJ.dochttp://intranet.denisonmines com/denver/Executivo/DAVEAVhito Mesa Mill/1 le.(2) from ISL
facilitioa and Mill Waste Disposal/PBL 10_1 lo (2) SOP Rov 1 (12 01 10) (2).doc
-(Formatted: Indent: Left: 0.25"
-f Formatted: Indent: Left: 0.25"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-^ STANDARD OPERATING PROCEDURES Page 9 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
JuneSept.Dcc. 1.
20110
any overhead hazards.
4)0Do 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 off the equipment.
f)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.
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 mrprh.
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 gasohne engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
F:\WP\DiviGion of Radiation ControlMDonison Minos, DUSAMjic, LRA & LicenGO AmondmontsMSL
Amendment for2010\DRCMarkupProp lle2 SQPG 12 1 10
DR&RJ.dochttp://intranet.denisonmine&.com/denver/Executive/DAVEAVhito Mesa Mill/1 lo.(2) from ISL
facilitioG and MiU Waate DiopoGal/PBL 10_llo (2) SOP Rov 1 (12 01 10) (2).doc
ST
page 10 of
Rev No-.
Title:
Date--
^^^""^^.^pment of W^^^^^^^^
V ^°^^teSvsRadlaUOO^>^P . , ^rfotmed bV
e.Ma.....^^^^^^^^^
• ^^^^^tS byproduct "^^^"^^
B,ea«xon^,e forms.
No.: PBL-10
Rev. No.: R.35
Date:
' feseSegtOee 1 2011
^^^^^^^^^^^ STANDMDOPERATSrSRES T'tle: ne,(2) Byproduct Disposal
^2. "'--,he location Of eachsh,p™t„a^,<,.„,.„,,
will maintain r:i
^ t'j'pioauct material.
the Executive Secretaiy's written
_An annual summarv of thp o
cale^year shall be sent toreTxlcultr'r «f - each
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 rrbprhT 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 turning 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