DRC-2012-001313 - 0901a068802c5778

DENISO
MINES
DRC
April 11 2012
VIA E MAIL AND OVERNIGHT DELIVERY
Mr Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
PO Box 144850
Salt Lake City UT 84114 4850
Denison Mmes (USA) Corp
105017th Street Suite 950
Denver CO 80265
USA
Tel [phone]
Fax [phone]
www denisonmines com
Re Transmittal of Findings of the Utah Division of Radiation Control October 18 2011 Storm Water
Inspection at the White Mesa Uranium Mill and review of Denison Mines (USA) Corporation ( DUSA )
October 17 2011 response to the DRC September 1 2011 Request for Information and Confirmatory
Action Letter ( CAL ) DRC Findings RFI and Advisory March 7 2011
Dear Mr Lundberg
This letter transmits Denison Mines (USA) Corp s ( Denison s ) responses to the above named transmittal from
the Utah Division of Radiation Control ( DRC ) which Denison received on March 14 2012
We have re quoted each item from the Findings RFI and Advisory letter below in /fa//cs along with specific
responses to each request For ease of review the responses follow the numbenng in the Findings RFI and
Advisory letter
4dwsory
Please be advised that DRC identified five violations of the Mill Ground Water Permit Permit No UGW370004
during the Inspection walk through A copy of the DRC review memo regarding the October 18 2011 inspection
IS attached which provides information and photos regarding these violations
As was discussed in the close out conference call between DRC and DUSA on February 22 2012 a Notice
of Violation and Order citing the five violations is being submitted to DUSA under separate cover
Denison Response
Denison has responded to the Notice of Violation and Order under separate cover
Request for Information
Please submit complete copies of the October 2011 Revised SWBMPP (includir^g all appendices) in both hard
copy and searchable electronic format (PDF) within 30 calendar days of receipt
full hard copy and electronic copy were not provided with the October 17 2011 DUSA response letter
of this letter It appears that a
Y \lnspections and NOVs\Stormwater lnspections\Stomiwater Inspection NOV and RFI 03 07 12\04 13 12 Response to
DRC 03 07 12 RFI4 10 12 doc '
Letter to Mr Rusty Lundberg
Response to DRC Findings RFI and Advisory
April 11 2012
Page 2
Denison Response
A complete hard copy along with a pdf copy on CD Rom of the SWBMPP and all appendices and attachments
has been included with this response letter
CAL Item #1
DUSA constructed a concrete pad for temporary storage of drums containing alternate feedstock with Executive
Secretary approval The final approval and closeout letter was sent to DUSA by the Executive Secretary dated
October 24 2011
DRC considers the DUSA follow up actions appropriate however DRC did observe opened and
rusted/perforated drums of feedstock material (outside of the feedstock management area) not in compliance
with Part ID 11 of the Groundwater Permit during the October 18 2011 storm water inspection It was noted
that the new pad had recently been poured and was still curing (was not yet in operation)
DUSA Response
Executive Secretary approval of the as builts for the new concrete pad was received on October 24 2011 and
the pad was completed and cured pnor to that date All feedstock containers which are required to be placed
on a hardened surface designed constructed and operated in accordance with engineenng plans and
specifications approved in advance by the Executive Secretary have now been placed on the prepared pad
The root cause of Denison s failure to place all opened and rusted/perforated drums of feedstock material on an
approved pad at the time of the inspection is discussed in Denison s letter in response to the March 7 2012
NOV submitted under separate cover
CAL Item #2
DUSA violated the Groundwater Permit Part ID 10 by failing to replace/repair concrete in the secondary
containment of the Caustic Soda Tank
Per the October 17 2011 DUSA response to the CAL and the 2011 DRC inspection walkthrough it was verified
that the containment has been repaired
The DUSA Action appears to be appropriate and has addressed the CAL concern No additional action needed
Denison Response
No response required
CAL Item #3
Per the October 17 2011 DUSA response to the DRC CAL and the 2011 DRC inspection walkthrough it
was verified that the soda ash tank secondary containment cracks have been repaired
The DUSA Action appears to be appropriate and has addressed the CAL concern No additional action
needed
DENISO
MINES
Letter to Mr Rusty Lundberg
Response to DRC Findings RFI and Advisory
April 11 2012
Page 3
Denison Response
No response required
RFI#1
Per DRC review the October 2011 Revised SWBMPP appears to address the RFI by changing the frequency
of the diversion ditch inspection to monthly and approval of the Revised SWBMPP is provided above DRC also
noted that the revised SWBMPP updates the tables listing quantity and types of reagents chemicals petroleum
products and solvents stored at the Mill facility DRC did note that DUSA did not submit a complete revised
copy or electronic file of the Revised SWBMPP and has included an RFI for DUSA to submit the copies within
30 calendar days above
Denison Response
As mentioned above a complete hard copy along with a pdf copy on CD Rom of the SWBMPP and all
appendices and attachments has been included with this response letter
RFI #2
The DUSA response is consistent with communication between DRC and DUSA concerning the on grade
tanks specifically DRC provided follow up response that on grade tanks will require either cathodic protection
or to be placed on concrete pedestals DRC will inspect the on grade tanks during the 2012 storm water
inspection to ensure that concrete pedestals are provided
Denison Response
No response required
RFI #3
In response to Request for Information item number 3 request with the findings of the 2010 DRC storm water
inspection DUSA provided a change to the small quantity spills protocols in the October 17 2011 response
letter as follows
DUSA has implanted an internal notification process for small quantity spills (less than reportable quantities)
with the following steps
1) Mill environmental personnel will fill out on the daily inspection form observations of spills of reagent
chemicals of any size The form will be amended to add spaces for this item
2) In addition all Mill employees will be trained to advise Mill environmental personnel of any spills that they
observe during the day and these will also be noted in the daily inspection form
3) If the spill IS of a reportable quantity environmental personnel will follow the procedures In the Mills
SWBMPP plan
4) For spills smaller than reportable quantities the environmental inspector will record information regarding the
spill and the nature and type of cleanup on the form
5) The information on the inspection form will be added to a database maintained at the Mill The
database will be updated and maintained on site indefinitely Cards are maintained for no longer than one
year
The corrective actions were not implemented at the time of the DRC October 18 2011 inspection the new
DENISO
MINES
Letter to Mr Rusty Lundberg
Response to DRC Findings RFI and Advisory
April 11 2012
Page 4
reporting and clean up processes will be reviewed during the DRC 2012 storm water inspection
Denison Response
The corrective actions were implemented in late October 2011 Amended Daily Inspection Forms are available
for inspection
RFI #4
Per the October 17 2011 DUSA response DUSA provides a historical summary of the Mill and claims that it is
not required to comply with the requirements of the SPCC rule due to the Mill being constructed with an overall
grade and diversion ditch system designed to channel any non recovered portion of any material spill to the
tailings management system DUSA does agree to review the SPCC Rule (Current 40CFR 112) to determine
whether or not any modifications to the SPCC plan would be appropriate for the Mill
DRC will follow up regarding the DUSA review of the rule and changes which are planned in the SPCC during
the 2012 storm water inspection
Denison Response
Denison will provide the results of our review of the rule and any proposed changes at the time of the 2012
storm water inspection
RFI US
DRC requested that DUSA seal interior drains in the vehicle maintenance areas that dram to outdoor uncovered
areas It was noted that this is specified in the facility SWBMPP and is considered a best management practice
to minimize the quantity of contaminated material DRC noted that the open dram is not in conformance with the
SWBMPP Part 43 1 second bullet clean up spills promptly don t let minor spills spread
The DUSA response described that water from the shop interior drains into the outdoor sump (baffle box) and is
then intermittently pumped to the tailings management system (pump is turned on/off by hand)
The system was evaluated during the October 18 2011 storm water inspection DUSA representatives turned
on the pump and drained a portion of the water contained in the baffle box DRC witnessed the discharge
underneath the CCD circuit to Roberts Pond Based on DRC review of the response and inspection the system
seems adequately designed and managed to control discharge from the shop interior No additional action is
required regarding RFI #
Denison Response
No response required
RFI #6
DRC requested that DUSA insure that the clean water tank valve is sealing properly
Per the DUSA October 17 2011 response to the RFI it was noted that the discharge was not due to a faulty or
leaking valve but was due to the water level being filled above max DUSA pointed out that the tank is filled
automatically (Recapture Reservoir Water Line) and will routinely overfill the tank DRC pointed out that this
DENISO
MINES
Letter to Mr Rusty Lundberg
Response to DRC Findings RFI and Advisory
April 11 2012
Page 5
was resulting in standing water onsite on bare ground DUSA responded that they would provide a closed pipe
system which would route the overflow to Roberts Pond without ground contact Per an e mail to DRC from
David Turk (White Mesa Mill RSO) on November 4 2011 it was verified that the construction was complete
Several photos of the construction and completed project were also provided
The DUSA action appears to be appropriate and effective to control the overflow discharge DRC will inspect
the completed construction during the 2012 Storm Water Inspection
Denison Response
No response required
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
Dan Hillsten
Harold R Roberts
David E Turk
K Weinel
DENISO
MINES
ATTACHMENT 1
:
STORMWATER
BEST MANG.EMENT PRACTICES PLAN
for
White Mesa Uranium Mill
6425 South Highway 191
P.O. Box 809
Blanding, Utah
October 2011
Prepared by:
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
TABLE OF CONTENTS
1.0 INTRODUCTION/PURPOSE ............................................................................................................................... 1
2.0 SCOPE ................................................................................................................................................................... 2
3.0 RESPONSIBILITY ................................................................................................................................................ 3
4.0 BEST MANAGEMENT PRACTICES .................................................................................................................. 4
4.1 General Management Practices Applicable to All Areas ......................................................................... 4
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water: ............................................ 4
4.1.2 Keep Potential Pollutants from Contact with Precipitation ............................................................. .4
4.1.3 Keep Paved Areas from Becoming Pollutant Sources ...................................................................... 4
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the Process and
Reagent Storage Area ...................................................................................................................................... 4
4.1.5 Recycle Fluids Whenever Possible: .................................................................................................. 4
4.2 Management Practices for Process and Laboratory Areas ....................................................................... 5
4.2.1 Clean Up Spills Properly .................................................................................................................. 5
4.2.2 Protect Materials Stored Outdoors .................................................................................................... 5
4.2.3 Management ..................................................................................................................................... 5
4.2.4 Materials Management ..................................................................................................................... 5
4.3 Management Practices for Maintenance Activities .................................................................................. 6
4.3.1 Keep a Clean Dry Shop .................................................................................................................... 6
4.3.2 Manage Vehicle Fluids ..................................................................................................................... 6
4.3.3 Use Controls During Paint Removal ................................................................................................. 6
4.3.4 Use Controls During Paint Application and Cleanup ....................................................................... 6
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment.. ........................................... 7
4.4.1 Wash Down Vehicles and Equipment in Proper Areas ..................................................................... 7
4.4.2 Manage Stockpiles to Prevent Windborne Contamination ............................................................... 7
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources .................................................... 7
Figures
Figure 1: White Mesa Mill Site Layout. ..................................................................................................................... 16
Figure2: White Mesa Mill Site Drainage Basins ........................................................................................................ 17
Figure 3: Denison Mines (USA) Corp.-White Mesa Mill Management Organization Chart .................................... 19
Figure 4: Denison Mines (USA) Corp. -Corporate Management Organizational Chart.. ......................................... 20
Tables
TABLE 1.0: White Mesa Mill Management Personnel Responsible for Implementing This BMPP ........................... 9
TABLE 2.0: REAGENT YARD LIST ....................................................................................................................... 10
TABLE 3.0: LABORATORY CHEMICAL INVENTORY LIST 1 .......................................................................... 11
TABLE 4.0: REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1 ........................................................ 12
TABLE 5.0: BAGENT YARD/BULK CHEMICALS LIST 1 ................................................................................... 13
TABLE 6.0: PETROLEUM PRODUCTS AND SOLVENTS LIST 1 ...................................................................... 14
Appendices
Appendix 1
Appendix 2
White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
White Mesa Mill Emergency Response Plan
1.0 INTRODUCTION/PURPOSE
Best Management Practices Plan
Revision 1.4: October 2011
Denison Mines (USA) Corp. ("DUSA") operates the White Mesa Uranium Mill ("the Mill) in
Blanding, Utah. The Mill is a net water consumer, and is a zero-discharge facility with respect to
water effluents. That is, no water leaves the Mill site because the Mill has:
• no outfalls to public stormwater systems,
• no surface runoff to public storm water systems,
• no discharges to publicly owned treatment works ("POTWs"), and
• no discharges to surface water bodies.
The State of Utah issued Groundwater Discharge Permit No. UGW370004 to DUSA on March 8,
2005. As a part of compliance with the Permit, DUSA i required to ubmit a Storm water Best
Management Practices Plan (''BMPP") to the Executive Secretary of the Divi ion of Radiation
Control, Utah Department of Environmental Quality. This BMPP presents operational and
management practices to minimize or prevent spiil of chemical or hazardous materiaL which
could result in contaminated surface water effluents potentially impacting surface waters or
ground waters through runoff or discharge connections to stormwater or surface water drainage
routes. Although the Mill, by design, cannot directly impact stormwater, surface water, or
groundwater, the Mill implements these practices in a good faith effort to minimize all sources of
pollution at the site.
Page 1
2.0 SCOPE
Best Management Practices Plan
Revision 1.4: October 2011
This BMPP identifies practices to prevent spills of chemicals and hazardous materials used in
process operations, laboratory operations, and maintenance activities, and minimize spread of
particulates from stockpiles and tailings management areas at the Mill. Storage of ores and
alternate feeds on the ore pad, and containment of tailings in the Mill tailings impoundment
system are not considered "spills" for the purposes of this BMPP.
The Mill site was constructed with an overall grade and diversion ditch system designed to
channel all surface runoff, including precipitation equivalent to a Probable Maximum
Precipitation/Probable Maximum Flood ("PMP/PMF") storm event, to the tailings management
system. In addition, Mill tailings, all other process effluents, all solid waste and debris (except
used oil and recyclable materials), and spilled materials that cannot be recovered for reuse are
transferred to one or more of the tailings cells in accordance with the Mill's NRC license
conditions. All of the process and laboratory building sinks, sumps, and floor drains are tied to
the transfer lines to the tailings impoundments. A site map of the Mill is provided in Figure 1. A
sketch of the site drainage basins is provided in Figure 2.
As a result, unlike other industrial facilities, whose spill management programs focus on
minimizing the introduction of chemical and solid waste and wastewater into the process sewers
and storm drains, the Mill is permitted by NRC license to manage some spills via draining or
wash down to the process sewers, and ultimately the tailings system. However, as good
environmental management practice, the Mill attempts to minimize:
1. the number and size of material spills, and
2. the amount of unrecovered spilled material and wash water that enters the process sewers
after a spill cleanup.
Section 4.0 itemizes the practices in place at the Mill to meet these objectives.
Requirements and methods for management, recordkeeping, and documentation of hazardous
material spills are addressed in the DUSA White: Mesa Mill Spill Prevention, Control and
Countermeasures ("SPCC") Plan, the Emergency Response Plan ("ERP"),, and the housekeeping
procedure incorporated in the White Mesa Mill Standard Operating Procedures ("SOPs"). The
latest revi ion of the SPCC plan and the ERP are provided in their entirety in Appendices 1 and
2, respectively.
Page 2
3.0 RESPONSIBILITY
Best Management Practices Plan
Revision 1.4: October 20 I J
All Mill personnel are responsible for implementation of the practices in this BMPP. DUSA
White Mesa Mill management is responsible for providing the facilities or equipment necessary
to implement the practices in this BMPP.
The Mill Management Organization is presented in Figure 3. The DUSA Corporate Management
Organization is presented in Figure 4.
An updated spill prevention and control notification list is provided in Table I.
Page 3
Best Management Practices Plan
Revision 1.4: October 2011
4.0 BEST MANAGEMENT PRACTICES
A summary list and inventory of all liquid and solid materials managed at the Mill is provided in
Tables 2 through 5.
4.1 General Management Practices Applicable to All Areas
4.1.1 Keep Potential Pollutants from Contact with Soil, and Surface Water:
• Store hazardous materials and other potential pollutants in appropriate containers.
• Label the containers.
• Keep the containers covered when not in use.
4.1.2 Keep Potential Pollutants from Contact with Precipitation
• Store bulk materials in covered tanks or drums.
• Store jars, bottle, or similar small containers in buildings or under covered areas.
• Replace or repair broken dumpsters and bins.
• Keep dumpster lids and large container covers closed when not in use (to keep
precipitation out).
4.1.3 Keep Paved Areas from Becoming Pollutant Sources
• Sweep paved areas regularly, and dispose of debris in the solid waste dumpsters or
tailings area as appropriate.
4.1.4 Inspection and Maintenance of Diversion Ditches and Drainage Channels within the
Process and Reagent Storage Area
• Diversion ditches, drainage channels and surface water control structures in and around
the Mill area will be inspected at least monthly in accordance with the regularly
scheduled inspections required by Groundwater Discharge Permit No. UGW370004, and
by product Materials License #UT1900479. Areas requiring maintenance or repair, such
as excessive vegetative growth, channel erosion or pooling of surface water runoff, will
be reported to site management and maintenance departments for necessary action to
repair damage or perform reconstruction in order for the control feature to perform as
intended. Status of maintenance or repairs will be documented during follow up
inspections and additional action taken if necessary.
4.1.5 Recycle Fluids Whenever Possible:
• When possible, select automotive fluids, solvents, and cleaners that can be recycled or
reclaimed
• When possible, select consumable materials from suppliers who will reclaim empty
containers.
• Keep spent fluids in properly labeled, covered containers until they are picked up for
recycle or transferred to the tailings area for disposal.
Page 4
Best Management Practices Plan
Revision 1.4: October 2011
4.2 Management Practices for Process and Laboratory Areas
4.2.1 Clean Up Spills Properly
• Clean up spills with dry cleanup methods (absorbents, sweeping, collection drums) instead of
water whenever possible.
• Clean spills of stored reagents or other chemicals immediately after discovery.
• (Groundwater Discharge Permit No. UGW370004, Section I.D.lO.c.)
• Recover and re-use spilled material whenever possible.
• Keep supplies of rags, sorbent materials (such a cat litter), pill collection drums, and personnel
protective equipment ("PPE") near the area where they may be needed for piU respon e.
• If spills must be washed down, use the minimum amount of water needed for effective cleanup.
4.2.2 Protect Materials Stored Outdoors
• If drummed feeds or products must be stored outdoors, store them in covered or diked areas when
possible.
• If drummed chemicals must be stored outdoors, store them in covered or diked areas when
possible.
• Make sure drums and containers stored outdoors are in good condition and secured against wind
or leakage. Place any damaged containers into an overpack drum or second container.
4.2.3 Management
• When possible, recycle and reuse water from flushing and pressure testing equipment. When
possible, wipe down the outsides of containers in, tead of rinsing them off in the sink.
• When possible, wipe down counter and work surfaces instead of hosing or rinsing them off to
sinks and drain
4.2.4 Materials Management
• Purchase and inventory the smallest amount oflaboratory reagent necessary.
• Do not stock more of a reagent than will be used up before its expiration date.
• All new construction of reagent storage facilities will include secondary containment which shall
control and prevent any contact of spilled reagents, or otherwise released
• reagent or product, with the ground surface. (Groundwater Discharge Permit No.
• UGW370004, Section I.D.3.g.)
Page 5
Best Management Practices Plan
Revision 1.4: October 2011
4.3 Management Practices for Maintenance Activities
4.3.1 Keep a Clean Dry Shop
• Sweep or vacuum shop floors regularly.
• Designate specific areas indoors for parts cleaning, and use cleaners and solvents only in those
areas.
• Clean up spills promptly. Don't let minor spills spread.
• Keep supplies of rags, collection containers, and sorbent material near each work area where they
are needed.
• Store bulk fluids, waste fluids, and batteries in an area with secondary containment (double drum,
drip pan) to capture leakage and contain spills.
4.3.2 Manage Vehicle Fluids
• Drain fluids from leaking or wrecked/damaged vehicles and equipment as soon as possible. Use
drip pans or plastic tarps to prevent spillage and spread of fluids.
• Promptly contain and transfer drained fluids to appropriate storage area for reuse, recycle, or
disposal.
• Recycle automotive fluids, if possible, when their useful life is finished.
4.3.3 Use Controls During Paint Removal
• Use drop cloths and sheeting to prevent windbome contamination from paint chips and
sandblasting dust.
• Collect, contain, and transfer, as soon as possible, accumulated dusts and paint chips to a disposal
location in the tailings area authorized to accept waste materials from maintenance or
construction activities.
4.3.4 Use Controls During Paint Application and Cleanup
• Mix and use the right amount of paint for the job. Use up one container before opening a second
one.
• Recycle or reuse leftover paint whenever possible.
• Never clean brushes or rinse or drain paint containers on the ground (paved or .unpaved).
• Clean brushes and containers only at sinks and stations that drain to the process sewer to the
tailings system.
• Paint out brushes to the extent possible before water washing (water-based paint) or solvent
rinsing (oil-based paint).
• Filter and reuse thinners and solvent whenever possible). Contain solids and unusable excess
liquids for transfer to the tailings area
Page 6
Best Management Practices Plan
Revision 1.4: October 2011
4.4 Management Practices for Ore Pad, Tailings Area, and Heavy Equipment
Detailed instructions for ore unloading, dust suppression, and tailings management are provided
in the Mill SOPs.
4.4.1 Wash Down Vehicles and Equipment in Proper Areas
• Wash down trucks, trailer , and other heavy equipment only in areas designated for this purpose
(such as wa h down pad areas and tile truck wash tation).
• At the truck wa h station, make sure the water collection and recycling sy tern is working before
turning on water pray .
4.4.2 Manage Stockpiles to Prevent Wiodborne Contamination
• Water spray the ore pad and unpaved areas at appropriate frequency in accordance with Mill
SOPs.
• Water pray tockpile as required by opacity standard or weather conditions.
• Don't over-water. Keep urfaces moi t but minimize runoff water.
4.4.3 Keep Earthmoving Activities from Becoming Pollutant Sources
• Schedule excavation, grading, and other earthmoving activities when extreme drynes and high
winds will not be a factor (to prevent the need for excessive du t uppression).
• Remove existing vegetation only when ab olutely necessary.
• Seed or plant temporary vegetation for erosion control on l.ope .
Page 7
TABLES
Page 8
:
Personnel
Dan Hillsten
Wade Hancock
Scot Christensen
David E. Turk
Personnel
Ron F. Hoch tein
David C. Frydenlund
TABLE1
White Mesa Mill Management Personnel
Responsible for Implementing This BMPP
Mill Manager
Maintenance
Superintendent
Mill Superintendent
Mill Staff
Work Phone
435-67 8-2221
Ext. 105
435-678-2221
Ext.l66
435-678-2221
Radiation Safety Officer 435-678-2221
Ext. 113
Corporate Management Staff
Title Work Phone
Pre ident/ Chief 604-689-7842
Operating Officer
Vice President and 303-389-4130
General Coun eJ
Home Phone/
Other Contact Number
Cell: 435-979-3041
435-678-2753
Cell: 435-979-0410
435-678-2015
435-678-7802
Cen: 435-459-9786
Home Phone/
Other Contact
Number
Cell: 604-377-1167
303-221-0098
Cell: 303-808-6648
Page 9
REAGENT ,. •)'
AMMONIUM
SULFATE(BULK)
AMMONIUM
SULFATE{BAGS)
ANHYDROUS AMMONIA
TRIDECYLALCOHOL
DIESEL FUEL
GRINDING BALLS
KEROSENE
POLO X
PROPANE
SALT (BAGS)
SALT (BULK)
SODA ASH (BAGS)
SODA ASH (BULK)
SODIUM CHLORATE
SODIUM HYDROXIDE
SULFURIC ACID
UNLEADED GASOLINE
USED OIL
TABLE 2
REAGENT YARD LIST
QUANTITY N U f\:IIBE~ OF
(L.BS) BTO~A@lE,
'TANKS
54,000 2
26,000 ---
107,920 2
45,430 ---
2
1
72,000 ---
1,344 1
2
10,360 ---
1
39,280 ---
0 1
1
39,280 ---
84,1 00 1
1
1011128 1
1
1
0 1
4,801 ,440 1
1
1
CAPACITY
(GALLO~S}
24,366
31 ,409
250
6,000
10,315
10,095
25,589
13,763
18,864
16,921
8,530
16,921
22,561
29,940
19,905
1,394,439
3,000
5,000
Page 10
TABLE 3.0
LABORATORY CHEMICAL INVENTORY LIST 1
Chemical In Lab RQ<! Quantitv in Stock
Aluminum nitrate 2270 kg 1.8 kg
Ammonium bifluoride 45.4 kg 2.27 kg
Ammonium chloride 2270 kg 2.27 kg
Ammonium oxalate 2270 kg 6.8 kg
Ammonium thiocyanate 2270 kg 7.8 kg
Antimony potassium tatrate 45.4 kg 0.454
n-8utyl acetate 2270 kg 4L
Cyclohexane 454 kg 24 L
Ferric chloride 454 kg 6.81 kg
Ferrous ammonium sulfate 454 kg 0.57
Potassium chromate 4.54 kg 0.114 kg
Sodium nitrite 45.4 kg 2.5 kg
Sodium phosphate tribasic 2270kg 1.4
Zinc acetate 454 kg 0.91 kg
Chemical. in Volatiles and RQ2 Quantit)£ in Stock
Flammables Lockers
(A B Cl
Chloroform 4.54 kg_ 8L
Formaldehyde 45.4 kg < 1 L of 37% solution
Nitrobenzene 454 kg 12 L
Toluene 454 kg 12 L
Chemical in Acid Shed RQ<! Quantity in Stock
Chloroform 4.54 kg 55 gal
Hydrochloric acid 2,270 kg 58 _gal
Nitrate acid 454 kg 5L
Phosphoric Acid 2,270 kg 10 L
Sulfuric acid 454 k_g_ 25 L
Hydrofluoric acid 45.4 kg 1 L
Ammonium h_ydroxide 454 kg 18 L
1. This list identifies chemicals which are regulated as hazardous substances under the
Federal Water Pollution Control Act 40 CFR Part 117. The lab also stores small
quantities of other materials that are not hazardous substances per the above
regulation.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3:
"Reportable Quantities of Hazardous Substances Designated Pursuant to Section
311 of the Clean Water Act."
Page 11
TABLE 4.0
REAGENT YARD/SMALL QUANTITY CHEMICALS LIST 1
CHEMICAL RQZ QUANTITY IN
STORAGE
COMPOUND
Acetic Acid, Glacial 1,000 lbs 4gal
Ammonium Hydroxide 1,000 lbs 5L
Calcium Hypochlorite 101bs 2 kg_(4.4 lbs)
Chlorine 10ibs Olbs
Ferrous Sulfate Heptahydrate 1,000 lbs 5 kg (111bs)
Hydrochloric 5,000 lbs 60 gal of 40% solution
Nitric Acid 1,000 lbs 10 L
Potassium Permanganate 0.1 N 32gal 5 kg (11 1bs)
Sodium Hypochlorite 5.5% 1001bs 2 kg (11 lbs) of 5.5%
solution
Silver Nitrate 1 lb Olbs
Trichloroethylene 1001b 2L
1. This list identifies chemicals which are regulated as hazardous
substances under the Federal Water Pollution Control Act 40 CFR
Part 117, Materials in this list are stored in a locked storage
compound near the bulk storage tank area. The Mill also stores small
quantities of other materials that are not hazardous substances per
the above regulation.
2. Reportable Quantities are those identified in40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 12
TABLE 5.0
REAGENT YARD/BULK CHEMICALS LIST1
REAGENT RQ' QUANTITY IN REAGENT
YARD
Sulfuric Acid 1,000 lbs 9,000,000 lbs
Hyperfloc 1 02 None 1,500 lbs
Ammonia -East Tank 1001bs Olbs
Ammonia-West Tank 100ibs 105,000 lbs
Kerosene 100 gal 500 gal
Salt (Bags) None 20,000 lbs
Soda Ash Dense (Bag) None 50,000 lbs
Polyox None 490ibs
Tributyl phosphate None 9,450 lbs
Diesel 100 gal Approx. 3300 gal
Gasoline 100 gal Approx. 6000 gal
Alamine 336 drums None 8,250 gal
Salt(Bulk Solids) None 50,000 lbs
Salt(Bulk Solutions) None 9,000 gal
Caustic Soda 1,000 lbs 16,000 lbs
Ammonium Sulfate None 150,000 lbs
Sodium Chlorate None 350,000 lbs
Alamine 31 0 Bulk None Olbs
lsodecanol None 2,420 gal
Vanadium Pentoxide3 1000ibs 30,000 lbs
Yellowcake3 None <1 00,000 lbs
Ammonia Meta Vanadate 10001bs Olbs
Floc 655 21,000 lbs
Floc 712 1,250 lbs
1. This list identifies all chemicals in the reagent yard whether or not they are regulated as
hazardous substances under the Federal Water Pollution Control Act 40 CFR Part 117.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table 117.3: "Reportable
Quantities of Hazardous Substances Designated Pursuant to Section 311 of the Clean
Water Act."
3. Vanadium Pentoxide and Yellowcake, the Mill's products, are not stored in the Reagent
Yard itself, but are present in closed containers in the Mill Building and/or Mill Yard
Page 13
TABLE 6.0
PETROLEUM PRODUCTS AND SOLVENTS LIST1
PRODUCT RQ QUANTITY IN
WAREHOUSE
Lubricating Oils in 55 gallon drums 100 gal 1 ,540 gallons
Transmission Oils 100 gal 110 gallons
Water Soluble Oils 100 gal 110 gallons
Xylene (mixed isomers) 100 gal 0 gallons
Toluene 1000 gal 0 gallons
Varsol Solvent 100 gal 0 gallons
(2% trim ethyl benzene in petroleum
distillates)
1. This list includes all solvents and petroleum-based products in the Mill
warehouse petroleum and chemical storage aisles.
2. Reportable Quantities are those identified in 40 CFR Part 117 Table
117.3: "Reportable Quantities of Hazardous Substances Designated
Pursuant to Section 311 of the Clean Water Act."
Page 14
FIGURES
Page 15
Figure 1
White Mesa Mill
Mill Site Layout
Page 16
sx
BUILDING
SAMPLE PLANT
! 10
D
100 50 100 200
SCALE IN FEET
Figure2
White Mesa Mill
Mill Site Drainage Basins
Page 17
Figure 3
White Mesa Mill
Mill Management Organization Chart
Page 18
Mill Superintendent
Operations
Foreman
Shift Foreman
(4)
Operating
Crews
Maintenance
Foreman
Maintenance
Personnel
I
White Mesa
Inc. Foreman
Figure3
Denison Mines (USA) Corporation
White Mesa Mill Management
Organizational Structure
President & CEO t-
l
Mill Manager
j_
I I
Radiation Safety
Officer
Senior Metallurgist
1--
;-----1
Safety
Radiation
Tech
L--1 Environmental
Tech
.______. Chief Chemist
I
Purchasing Manager
I
Payroll/
Administrator
Page 19
Figure 4
White Mesa Mill
Denison Mines (USA) Corporation
Organizational Structure
Page 20
'
1 J
VP & General VP Corporate
Counsel Development
\
Figure4
Denison Mines (USA) Corporation
Organizational Structure
President & CEO
VP & Chief Financial
Officer
Controller
Director Project
Development
Technical Manager
'----------· ----
'·.
I ....,
Administration Manager
Page 21
;
APPENDICES
Page 22
:
Appendix 1
White Mesa Mill Spill Prevention, Control, and Countermeasures Plan
Page 23
:
WHITE MESA MILL
SPILL PREVENTION, CONTROL, AND COUNTERMEASURES
PLAN FOR CHEMICALS AND PETROLEUM PRODUCTS
1.1 OBJECTIVE:
The objective of the Split Prevention, Control, and Countermeasures (SPCC}
Plan is to serve as a site-specific guideline for the prevention of and
response to chemical and petroleum spills. The plan outlines spill potentials,
containment areas, and drainage characteristics of the White Mesa Mill site.
The plan addresses chemical spill prevention, spill potentials, spill discovery,
and spill notification procedures. Spills are reportable if the spill leaves the
site. Ammonia Is the only chemical (as vapor) that has the potential to leave
the site. In addition, chemical and petroleum spills will be reported In
accordance with applicable laws and regulations.
Figure 1 , Site Layout Map shows a map of the mill site including the locations
of the chemical tanks on-site. Figure 2 shows the basins and drainage ditch
areas for the mill site. Table 1.0 is an organization chart for Mill operations.
Table 2.0 lists the reagent tanks and their respective capacities. Table 3.0
lists the laboratory chemicals, their amounts, and their reportable quantities.
Table 4.0 lists the operations chemicals. Table 5.0 lists the chemicals In the
reagent yard, their amounts, and their reportable quantities. Table 6.0 lists
the petroleum products and solvents on site.
1.2 RESPONSIBILITIES:
Person in charge of facility responsible for spill prevention:
Mr. Dan Hillsten, Mill Manager
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
[phone] (home)
Person in charge of follow-up spill reporting:
Mr. David Turk, Department Head, Health, Safety, and Environmental
6425 South Highway 191
Blanding, UT 84511
[phone] (work)
{435) 678-7802 (home)
Refer to Section 1.9 Spill Incident Notification for a list of personnel to be
notified in case of a spill. In addition, an organizational chart is provided in
Table 1.0.
1.3 DRAINAGE BASINS, PATHWAYS, AND DIVERSIONS:
The main drainage pathways are illustrated In Plate 1 .• 0. The map shows
drainage basin boundaries, flow paths, constructed diversion ditches, tailing
cells, the spillway between Cell 2 and 3, dikes, berms, and other relevant
features. The White Mesa Mill is a "2:ero" discharge facility for process liquid
wastes. The mill area has been designed to ensure that all spills or leaks
from tanks will drain toward the lined tailing cells.
The tailings cells, in turn, are operated with sufficient freeboard (minimum of
three feet) to withstand 100% of the PMP (Probable Maximum Precipitation).
This allows for a maximum of 10 Inches of rain at any given time.
1.4 DESCRIPTION OF BASINS:
Precipitation and unexpected spills from the mill site are contained within
their prospective drainage basins. Overflow ultimately drains into one of the
four lined tailings cells.
1.4.1 Basin A1
Basin A 1 is north of Cell 1·1 and Diversion Ditch No. 1. The basin
contains 23 tributary acres, all of which drain into Westwater Creek.
1.4.2 Basin A2
Basin A2 contains all of Cell 1 ~1 Including an area south of the Diversion
Ditch No. 1. The basin covers 84 acres. Any overflow from this basin
would be contained within Cell1-l.
1.4.3 Basin B1
Basin 81 is north of the mill area. The basin contains 45.4 tributary
acres.
Overflow from this basin drains Into a flood retention area by flowing
through Diversion Ditch No. 2. Diversion Ditch No. 2 drains Into
Westwater Creek.
1.4.4 Basin B2
Basin 82 is northeast of the mill area and contains only 2.6 tributary
acres. Overflow from this basin would drain into Diversion Ditch No. 3.
Diversion Ditch No.3 ultimately drains into Diversion Ditch No. 2.
2
1.4.5 Basin B3
Basin 83 contains most of the mill area, buildings, ore stockpiles, process
storage tanks, retention ponds, spill containment structures, pipelines,
and roadways. The normal direction of flow in this basin Is from the
northwest to the southwest. Any overflow from this basin would drain into
Cell1-l. The basin contains 64 acres. This basin has sufficient
freeboard to withstand 1 00% of the PMP (Probable Maximum
Precipitation). This allows 1 0 Inches of rain for any given storm event.
1.4.6 Basin C
Basin C contains all of Cell2. The basin consists of 80.7 acres. Areas In
this basin include earth stockpiles and the heavy equipment shop. The
direction of flow in this basin is to the southwest. All overflows In this
basin is channeled along the southern edge of the basin. Overflow then
flows into Cell 3 via the spillway from Cell2 to Cell 3.
1.4.7 Basin D
Basin D contains all of Cell3. This basin consists of 78.3 acres including
a portion of the slopes of the topsoil stockpile and random stockpile. The
basin contains all flows, including those caused by the PMF.
1.4.8 Basin E
Basin E contains Cell 4A and consists of 40 acres. All anticipated flows
Including those caused by the PMF will be contained within the basih and
will flow directly Into Ceii4A.
1.4.9 Basin F
Basin F will contain Ceii4B, if and when constructed. The area consists
of 44 acres at a relatively low elevation. Direction of flow in this basin is
towards the southwest.
1.5 POTENTIAL CHEMICAL SPILL SOURCES AND SPILL
CONTAINMENT
1.5.1 Reagent Tanks (Tank list Included in Table 2.0)
1.5.2 Ammonia
The ammonia storage tanks consist of two tanks with a capacity of
31,409 gallons each. The tanks are located southeast of the Mill building.
Dally monitoring of the tanks for leaks and routine integrity inspections will be
conducted to minimize the hazard associated with ammonia. The reportable
quantity for an ammonia spill Is 7 gallons.
----------·· -
3
:
Ammonia spills should be treated as. gaseous. Ammonia vapors will be
monitored closely to minimize the hazard associated with Inhalation. If
vapors are detected, effort.s will be made to stop or repair the leak
expeditiously. Ammonia Is the only chemical (as vapor) that has the potential
to leave the site.
1.5.3 Ammonia Meta-Vanadate
Ammonia meta-vanadate is present in the SX building as the process
solutions move through the circuit to produce the vanadium end product.
But, the primary focus will be on the transportation of this chemical. The
reportable spill quantity for ammonia meta-vanadate is 1 ,000 pounds.
1.5.4 Caustic Storage (Sodium Hydroxide)
The caustic storage tank Is located on a splash pad on the northwest corner
of the SX building. The tank has a capacity of 19,904 gallons. The tank
supports are mounted on a concrete curbed catchment pad which directs
spills Into the sand filter sump In the northwest corner of the SX building.
The reportable spill quantity for sodium hydroxide Is 85 gallons.
1.5.5 Sodium Carbonate (Soda Ash)
The soda ash solution tank has a capacity of 16,921 gallons and is located in
the northeast comer of the SX building. The smaller soda ash shift tank has
a capacity of 8,530 gallons and Is located In the SX building. Spills will be
diverted Into the boiler area, and would ultimately drain Into Cell 1-1. There is
no reportable spill quantity associated with sodium carbonate.
1.5.6 Sodium Chlorate
Sodium chlorate tanks consist of two fiberglass tanks located within a dike
east of the SX building. The larger tank is used for dilution purposes and has
a maximum capacity of 17,700 gallons. The smaller tank serves as a
storage tank and has a capacity of 10,500 gallons. Daily monitoring of the
tanks for leaks and Integrity inspections will be conducted to minimize the
hazard associated with sodium chlorate.
Sodium chlorate that has dried and solidified becomes even more of a safety
hazard due to its extremely flammable nature. The reportable spill quantity
for sodium chlorate is 400 gallons.
1.5.7 Sulfuric Acid
The sulfuric acid storage tanks consist of one large tank with the capacity of
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons
each.
The large tank is located in the northwest corner of mill area basin B3 and Is
primarily used for acid storage and unloading. The tank support for the large
tank is on a mound above a depression which would contain a significant
spill. All flows resulting would be channeled to Cell 1-1. The tank is equipped
4
:
with a high level audible alarm which sounds prior to tank overflows. A
concrete spill catchment with a sump In the back provides added
containment around the base of the tank. However, the catchment basin
would not be able to handle a major tank failure such as a tank rupture. The
resulting overflow would flow towards Cell 1-1.
The two smaller storage tanks are located within an equal volume spill
containment dike east of the mill building. The tanks are not presently in
use, but are equipped with high level audible alarms.
The reportable spill quantity for sulfuric acid is 65 gallons.
1.5.8 Vanadium Pentoxide
Vanadium pentoxide Is produced when vanadium Is processed through the
drying and fusing circuits and is not present in the vanadium circuit until after
the deammoniator. Efforts will be made to minimize leaks or line breaks that
may occur In processes in the circuit that contain vanadium pentoxlde.
Special care will be taken in the transportation of this chemical. The
reportable spill quantity for vanadium pentoxide is 1000 pounds.
1.5.9 Kerosene (Organic)
The kerosene storage area is located In the central mill yard and has a
combined capacity of 10,152 gallons in three tanks. Any overflow from these
three tanks would flow around the south side of the SX building and then Into
Cell 1-1. These tanks have drain valves which remain locked unless
personnel are supervising draining operations. The reportable spill quantity
for kerosene is 1 00 gallons.
1.6.0 Used/ Waste Oil
Used/ Waste oil for parts washing is located north of the maintenance shop
in a tank and has a capacity of 5,000 gallons. The tank is contained within a
concrete containment system. Ultimate disposal of the used oil is to an EPA
permitted oil recycler. Any oil escaping the concrete containment system will
be cleaned up. Soil contaminated with used oil will be excavated and
disposed of in Cell2.
1.&.1 Propane
The propane tank is located in the northwest corner of the mill yard and has
a capacity of 30,000 gallons. Daily monitoring of the tank for leaks and
integrity inspections will be conducted to minimize potential hazards
associated with propane leaks. Propane leaks will be reported immediately.
There is no reportable quantity associated with propane.
5
:
1.7 POTENTIAL PETROLEUM SPILL SOURCES AND
CONTAINMENT
1.1.1 Petroleum Tanks
1.1.1.1 Diesel
There are two diesel storage tanks located north of the mill building. The
tanks have capacities of 250 gallons each. One of the diesel tanks is for the
emergency generator. The other tank is located In the pumphouse on an
elevated stand. Spillage from either tank would uHimately flow Into Cell1-l.
The reportable spill quantity for diesel is 1 00 gallons. The spill Is also
reportable If the spill has the potential for reaching any nearby surface waters
or ground waters.
1.7.2 Aboveground Fuel Pump Tanks
1. 7 .2.1 Diesel
The diesel tank is located on the east boundary of Basin 83 and has a
capacity of 6,000 gallons. The tank is contained within a concrete catchment
pad. The reportable spill quantity for diesel is 100 gallons. A diesel spill is
also reportable If the spill has the potential for reaching any surface waters or
ground waters.
1. 7 .2.2 Unleaded Gasoline
The unleaded gasoline tank is located next to the diesel tank. The unleaded
gasoline tank has a capacity of 3,000 gallons and Is contained within the
same containment system as the diesel tank. Spills having the potential for
reaching any surface waters or ground waters will need to be reported. The
reportable spill quantity for unleaded gasoline is 1 00 gallons.
1.7.2.3 Pump Station
Both the diesel and the unleaded gasoline tanks will be used for refueling
company vehicles used around the mill site. The pump station is equipped
with an emergency shut-off device in case of overflow during fueling. In
addition, the station is also equipped with a piston leak detector and
emergency vent. Check valves are present along with a tank monitor
console with a leak detection system. The catchment Is able to handle a
complete failure of one tank. However, if both tanks failed the concrete
catchment pad would not be able to contain the spill. In this case, a
temporary berm would need to be constructed. Absorbent diapers or floor
sweep would be used in an effort to limit and contain the spill. The soil would
have to be cleaned up and placed in the authorized dump in Cell 2.
6
1.7. 2.4 Truck Unloading
In the event of a truck accident resulting in an overturned vehicle in the mill
area, proper reporting and containment procedures will be followed when
warranted, such as when oil or diesel fuel is spilled. Proper clean-up
procedures will be followed to minimize or limit the spill. The spill may be
temporarily bermed or localized with absorbent compounds. Any soils
contaminated with diesel fuel or oil will be cleaned up and placed In Cell 2.
1.8 SPILL DISCOVERY AND REMEDIAL ACTION
Once a chemical or petroleum spill has been detected, it is Important to take
measures to limit additional spillage and contain the spill that has already
occurred. Chemical or petroleum spills will be handled as follows:
The Shift Foreman will direct efforts to shut down systems, If
possible, to limit further release.
The Shift Foreman will also secure help if operators are requiring
additional assistance to contain the spill.
The Shift Foreman is also obligated to initiate reporting procedures.
Once control measures have begun and personal danger is
minimized, the Shift Foreman will notify the Production
Superintendent, Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will notify the Mill
Manager, who in turn will notify the Department Head of EA/HS
and/or the Environmental Coordinator.
The Mill Manager will assess the spill and related damage and direct
remedial actions. The corrective actions may Include repairs, clean·
upt disposal, and company notifications. Government notifications
may be necessary in some cases.
If a major spill continues uncontrolled, these alternatives will be considered:
1. Construct soil dikes or a pit using heavy equipment.
2. Construct a diversion channel into an existing pond.
3. Start pumping the spill into an existing tank or pond.
4. Plan further clean-up and decontamination measures.
1.9 SPILL INCIDENT NOTIFICATION
1.9.1 External Notification
For chemical and petroleum spills that leave the site, the following agencies
should be notified:
7
1. EPA National Response Center
2. US Nuclear Regulatory Commission
3. State of Utah
:
1-800-424-8802
301/816-5100
801/538-7200
In case of a tailings dam failure, contact the following agencies:
1. US Nuclear Regulatory Commission 301/816-5100
2. Sta1e of Utah, Natural Resources 801/538-7200
1.9.2 Internal Notification
Internal reporting requirements for incidents, spills, and significant spills are
as follows:
Report Immediately
Event Criteria:
1. Release of toxic or hazardous substances
2. Fire, explosions, and accidents
3. Government investigations, information requests, or enforcement
actions
4. Private actions or claims (corporate or employee)
5. Deviations from corporate policies or government requirements by
management
Which have or could result in the following:
1. Death, serious injury, or adverse health effects
2. Property damage exceeding $1,000,000
3. Government investigation or enforcement action which limits
operations or assesses penalties of $100,000 or more
4. Publicity resulted or anticipated
5. Substantial media coverage
Report at the Beginning of the Next Day
Event Criteria:
1. Was reported to a government agency as required by law
2. Worker (employee or contractor) recordable injury or illness associated
with a release
3. Community impact-reported or awareness
4. Publicity resulted or anticipated
5. Release exceeding 5,000 pounds of process material, waste, or by-
product
8
HmD!
:
In the event of a spill requiring reporting, the Mill Manager Is required to call
the Corporate Environmental Manager or the President and Chief Executive
Officer. The spill will first be reported to the Shift Foreman. The Shift
Foreman will then report the spill to the Production Superintendent,
Maintenance Superintendent, or Mill Manager.
The Production or Maintenance Superintendent will report to the Mill
Manager. The Department Head of EA/HS and the Environmental
Coordinator will be contacted by the Mill Manager.
Home Phone
Mill Personnel:
Dan Hlllsten
David Turk
Scot Christensen
Wade Hancock
Jeremy Gagon
Thayne Holt
Denver Personnel:
Mill Manager
RSO
Production Superintendent
Maintenance Superintendent
Mill Foreman
Mill Foreman
[phone]
[phone]
[phone]
[phone]
[phone]
[phone]
Ronald F. Hochstein
David C. Frydenlund
Jo Ann Tischler
President and Chief Executive Officer (303) 986·3634
Vice President and General Counsel (303) 221·0098
Environmental Manager [phone]
In the event the next person In the chain-of-command cannot be reached,
then proceed up the chain-of-command to the next level. Table 1.0 shows the
organizational chart for the mill site.
1.10 RECORDS AND REPORTS
The following reports and records are to be maintained in Central File by the
Environmental Coordinator for inspection and review for a minimum of three
years:
1. Record of site monitoring inspections
a. Daily Tailings Inspection Data
b. Weekly Tailings Inspection and Survey
c. Monthly Tailings Inspection, Pipeline thickness
d. Quarterly Tailings Inspection
2. Tank to soil potential measurements
9
3. Annual bulk oil and fuel tank visual inspections
4. Tank and pipeline thickness tests
5. Quarterly and annual PCB transformer inspections (if transformer
contains PCBs)
6. Tank supports and foundation Inspections
7. Spill Incident reports
8. Latest revision of SPCC plan
1.11 SPILL REPORTING REQUIREMENTS
~. Report to applicable government agency as required by laws and
regulations
2. Report any recordable injury or illness associated with the release
3. Fulfill any communication requirements for community awareness of
spill impacts
4. Report release of 5,000 pounds or more of any process material or
waste product
1.12 PERSONNEL TRAINING AND SPILL PREVENTION
PROCEDURES
All new employees are instructed on spills at the time they are employed and
trained. They are briefed on chemical and petroleum spill prevention and
control. They are informed that leaks in piping, valves, and sudden
discharges from tanks should be reported immediately. Abnormal flows from
ditches or impoundments are of Immediate concern. In addition, a safety
meeting Is presented annually by the Environmental Coordinator to review
the SPCC plan.
1.12.1 TrainIng Records
Employee training records on chemical and petroleum spill prevention are
maintained in the general safety training files.
1.12.2 Monitoring Reports
Shift Jogs shall provide a checklist for inspection items.
1.13 REVISION
This procedure is to be reviewed by the mill staff and a registered
professional engineer at least once every three years, and updated when
circumstances warrant a revision.
10
; ;
1.14 MILL MANAGER APPROVAL
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison Mines (USA) Corp.
White Mesa Mill facilities, and attest that this SPCC plan has been prepared
in accordance with the Standard Operating Procedures currently In effect.
1.15 CERTIFICATION BY
~--·----~-
Dan Hlllsten
Mill Manager
REGISTERED PROFESSIONAL ENGINEER
I hereby certify that I have reviewed the foregoing chemical and petroleum
product SPCC plan, that I am familiar with the Denison Mines (USA) Corp.
White Mesa Mill facilities, and attest that this SPCC plan has been prepared
in accordance with good engineering practices.
~
? Harold R. Roberts
Registered Professional Engineer
State of Utah No. 165838
1.16 Summary
11
Chemical and petroleum spills will be reported in accordance with applicable
laws and regulations. Spills that leave the property need to be reported
immediately. Below is a table listing the specific reportable quantities
associated with the major chemical and petroleum products on-site.
CHEMICAL REPORTABLE
QUANTITY (RQ)
AMMONIA 100 POUNDS
AMV 1,000 POUNDS
SODIUM 1,000 POUNDS
HYDROXIDE
SODA ASH No Reportable
Quantity
SODIUM 400GALLONS
CHLORATE
SULFURIC ACID 1,000 POUNDS
VANADIUM 1000 POUNDS
PENTOXIDE
KEROSENE 100GALLONS
OIL No Reportable
Quantity
PROPANE No Reportable
Quantity
DIESEL & 100 GALLONS
UNLEADED
FUEL
12
Appendix2
White Mesa Mill Emergency Response Plan
Page 24
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 1 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
INTRODUCTION
The purpose of this Emergency Response Plan (this "Plan") is to reduce the risk to our
employees and to the community from potential health, safety and environmental emergencies
that could arise at the Denison Mines (USA) Corp. ("DUSA") White Mesa Uranium Mill (the
"Mill").
This plan includes the following:
• evaluation of the potential risks for accidents, including fire, explosions, gas releases,
chemical spills and floods (including tailings dam failure), that could occur at the Mill;
• specific emergency programs for each potential event;
• administrative response actions; and,
• emergency response contacts -both internal and externaL
The Mill operates under the jurisdiction of the following regulatory agencies:
• Utah State Department of Environmental Quality, Division of Radiation Control;
• Mine Safety and Health Administration;
• Environmental Protection Agency;
• Utah State Department of Environmental Quality, Division of Air Quality; and,
• Utah State Division of Natural Resources Bureau of Dam Safety.
This Plan follows the standard format and content for emergency plans for fuel cycle and
materials facilities set out in U.S. Nuclear Regulatory Commission ("NRC") Regulatory Guide
3.67 (January 1992) ("Reg. Guide 3.67"), to the extent applicable to the Mill. Section 3 of Reg.
Guide 3.67 states that "in its emergency response plan and in coordination meetings with offsite
authorities, the licensee should convey the concept that fuel cycle and materials facilities do not
present the same degree of hazard (by orders of magnitude) as are presented by nuclear power
plants. Thus the cla sification scheme for these facilities is different." Reg. Guide 3.67 also
refers to NRC's NURBG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel
Cycle and Other Radioactive Material Licensees", S.A. McGuire, January 1988, for a description
of past incidents involving radioactive materials.
NUREG-1140 analyzed potential accidents for 15 types of fuel cycle and other radioactive
material licensees, including uranium mills, for their potential for offsite releases of radioactive
materials. NUREG-1140 concludes that for most of these licensees, for example uranium mills,
the degree of hazard is small and that "the low potential offsite doses ... the small area, where
actions would be warranted, the small number of people involved, and lhe fact that the local
police and fire departments would be doing essentially the same things they noxmally do, are all
factors that tend to make a simple plan adequate." NUREG-1140 concludes that "an appropriate
plan would (1) identify accidents for which protective actions should be taken by people offsite.
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 2 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
(2) list the licensee's responsibilities for each type of accident, including notification of local
authorities (fire and police generally), and (3) give sample messages for local authorities
including protective action recommendations. This approach more closely follows the approach
used for research reactors than for power reactors."
As a result, this Plan incorporates the most appropriate responses for the Mill, in accordance with
the requirements of Reg. Guide 3.67 and the conclusions set out in NUREG-1140.
MILL OVERVIEW
Master files containing Material Safety Data Sheets ("MSDSs") for all materials in use at the
Mill are maintained at the Safety Office, Mill Maintenance Office, Mill Laboratory and Mill
Central Control Room. Copies are also on file at the Blanding Clinic, Doctor's Offices, Blanding
Fire House and Office of the San Juan County Emergency Medical Coordinator.
PLAN OBJECTIVES
The primary objectives of this plan are:
• To save lives, prevent injuries, prevent panic, and minimize property/environmental
damage to the lowest possible level;
• To evacuate and account for all people in the area including visitors, truck drivers,
contractors, etc.;
• To provide assembly areas that are as safe as possible and which can be reached without
traveling through a hazardous area. Assembly areas will be properly manned to deal with
sick or injured persons, and provisions will be made to evacuate those persons to proper
shelter; and
• To make adequately trained personnel available to cope with rescue and recovery
operations as directed by the Incident Commander.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 3 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
1. FACILITY DESCRIPTION
1.1 Description of Licensed Activity
The Mill is located approximately 6 miles south of Blanding, Utah. The Mill processes
conventional uranium or uraniurnfvanadium ores to recover uranium and vanadium. In addition
to tbe processing of conventional ores, the Mill also processes alternate feed materials using
similar process steps and chemicals. The conventional ore is stored on the Ore Pad (shown on
the Site Layout Map included as Exhibit 3). Alternate feed materials are also stored on the Ore
Pad and may be stored in bulle form, tined burrito bags, liners or drums. In certain
circum tances, containerized altemale feed materials may be stored in locations off of the ore
pad.
All of the ores and feeds processed at the Mill contain natural uranium and its daughter products.
Uranium is in equilibrium with its daughters for conventional ores and is generally in various
degrees of disequjJib:dum with its daughters for alternate feed materials, depending on the
specific feed material. The descriptions of each alternate feed material are maintained by the
Mill's Radiation Safety Officer. However, the Mill does not receive, process or produce
enriched uranium of any sort, therefore there is no risk of a criticality accident at the Mill. The
products produced at the Mill include ammonium metavanadate (AMV), vanadium pregnant
liquor (VPL), vanadium pentoxide (V20 5), and yellowcake, or uranium concentrate (U30 8). The
VzOs and U30s producls are packaged in steel drums for shipment. The AMV is packaged in
either steel drwns or super-saks while the VPL i~ sold in liquid form in bulk.
Drums containing U308 and vanadium product are stored from time to time in a fenced, locked,
paved area in the Mill's restricted area, pending shipment offsite.
The Mill utilizes a semi-autogenous grind circuit (SAG mill) followed by a hot sulfuric acid
leach and a solvent extraction process to extract uranium and vanadium from ores, using large
amounts of sulfuric acid, sodium chlorate, kerosene, amines, ammonia and cau tic soda in the
process. The reagent storage tank locations m·e described in further detail in Section 1.2.9 below.
At any one time, there may by 1.4 million gallons of sulfuric acid, 63,000 gallons of anhydrous
ammonia, 220,000 gallons of kerosene, 20,000 gallons of cau tic soda and 30,000 gallon of
propane and various quantities of other reagents stored or located on site. See Sections 1.26,
1.27 and 1.29 for a more detailed discussion of the chemicals and reagents used and stored at the
site.
Tailings and wastes generated fTOm processing conventional ores and alternate feed materials are
disposed of permanently in fue Mill's lined tailings impoundments. The Mill's tailings cells are
comprised of four below grade engineered cells, Celll, 2, 3 and 4A. Liquids are stored in Cell
1, Cell3 and Cell 4A the active tailings cell. The liquid in the tailings cells is very acidic. In
addition to the tailings cells, there is also an emergency lined catchment basin ("Roberts Pond")
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west of the Mill building. Solutions in this basin or the tailings cells should not be used to fight
fires in the Mill facility.
1.2 Description of Facility and Site
1.2.1 Site Drawing
The Mill facilities are shown on the Site Layout Map included as Exhibit 3 and on the General
Area Map included as Exhibit 4. See also Exhibit 7 for a listing and the locations of the main
shut-off valves.
1.2.2 Communication and Assessment Centers
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation area will serve as the initial assessment
center. Other_cororo_un_ic_ations and assessment centers will he set up_ in the_Mill's Office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
1.2.3 Assembly and Relocation Areas
When the evacuation alarm sounds or when persmmel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• North side of Tailings Celll; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The Radiation Safety Officer ("RSO")/Fire Chief or Shift Foreman will specify the
appropriate assembly site.
1.2.4 Fire Water Supply and Alarm Systems
a) Fire Water Supply
The fire water supply facilities include:
• 400,000 gallon Storage Tank of which 250,000 gallons are reserved for fire
emergencies; and
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• Centrifugal diesel driven pump rated at 2,000 gpm at 100 psi. This pump statts
automatically when the pressure in the fire main drops below 100 psi (See Figure 1,
Fire System Schematic).
When more water is needed for an emergency an additional source is the Recapture Reservoir
supply pipeline, which can be utilized in emergencies at a rate of about 1,200 gpm.
b) Alarm System
The alarm systems include the following:
• public address system;
• hand held radios; and
• siren.
1.2.5 Office Building and Laboratory
a) Office Building
The office building (approximately 10,000 square feet) contains the administration offices,
radiation health and safety offices and the Mill laboratory. The central file vault and the main
computer system are also in this building. The ambulance is kept on the west side of the office
building near the safety office entrance.
b) Laboratory
The laboratory facilities contain the following:
• three flammable cabinets (keys required);
• chemical storage room south of main lab;
• seven fume hoods-hoods 1,2, 3 and 4 are in the chemical laboratory and hoods 5, 6
and 7 are in the metallurgical laboratory. Only hoods 1 and 2 may be used for
perchloric acid;
• outside laboratory chemical storage north of office building (key required); and
• perchloric acid storage vault located underground west of office building (key
required).
A wide variety of chemicals in small quantities are located in the Mill laboratory. These
chemicals range from acids to bases along with flammable metal compounds and peroxide
forming compounds. Oxidizers and organic chemicals are stored in a storage room in the
laboratory, which have a strong potential of producing harmful vapors if the containers are
damaged to the point that the chemicals are exposed. There are no acids stored in this storage
room. The acids (including but not limited to sulfuric, nitric, acetic perchloric, phosphoric and
hydrochloric acids) are stored in the main laboratory area in 2.5 liter or 500-ml bottles. MSDS
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books for all chemicals in the laboratory are located in the Laboratory, Safety Department, Mill
Maintenance office and Mill Central Control room.
c) Electrical
Electrical transformers and electrical switches are located in the laboratory at the east end of the
chemical storage room.
d) Fire Protection System
The fire protection systems in the office building and laboratory include:
• a fire hose station located on the east end o£ the office building. The station includes
two sets of tumout gear, two SCBA units and Incident Commander materials;
• automatic "wet" sprinkler system which is actuated at 212° F; and
• portable dry chemical extinguishers strategically located throughout the building.
1.2.6 Solvent Extraction Building
The solvent extraction (SX) building (approximately 21,000 square feet) houses the uranium and
vanadium solvent extraction circuits and the ELUEX circuit. The SX circuits may contain up to
200,000 gallons of kerosene (757 ,000 liters ) which has a flash point of 185° F.
Associated equipment in the SX building includes a temporary boiler located at the southwest
end of the SX building which maintains the temperature for the fire system.
Chemicals which may be encountered in the SX building include:
• Kerosene;
• Caustic Soda;
• Anhydrous Ammonia;
• Sulfuric Acid;
• Salt (Brine);
• Soda Ash;
• Ammonium Sulfate;
• Amines;
• Alcohol;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane .
The VPL product is stored in the SX building.
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a) Electrical
All electrical switches are located outside in the Mill Central Control room north of the SX
building. The main control panel for all of the equipment is located in the Central Control Room
in the main Mill building.
b) Fire Protection System
The SX building fire protection systems include:
• a "wet" AFFF foam sprinkler system with heat actuated sprinkler heads that release at
212°F; and
• portable dry chemical extinguishers strategically located throughout the building.
For fire hydrant and hose cabinet locations in the SX building refer to the Fire System Schematic
included as Figure 1 in this Plan.
1.2.7 Mill Building
The mill building (approximately 22,000 square feet) contains process equipment related to
grind, leach, counter current decantation, precipitation, and drying and packaging of uranium and
vanadium products.
Chemicals which may be encountered in the mill building include:
• Caustic Soda;
• Anhydrous Ammonia;
• Sulfuric Acid;
• SodaAsh;
• Ammonium Sulfate;
• Sodium Chlorate;
• Sodium Vanadate; and
• Propane.
The finished products which are contained in the mill building include AMY, V20 5 and U30 8 (or
yellowcake).
a) Electrical
The main electrical switch gear is located west of the SAG mill on the ground floor in the north
west comer of the mill building. Circuit control panels are located in the SAG mill control room,
the central control room, the vanadium roaster control room and the AMY area.
b) Fire Protection System
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The main mill building fire protection systems include:
• portable dry chemical extinguishers strategically located throughout the building; and
• water hoses throughout the building.
For fire hydrant and hose cabinet locations in the mill building refer to the Fire System
Schematic included as Figure 1 of this Plan.
1.2.8 Maintenance Shop/Warehouse/Change Room Building
This building (approximately 20,000 square feet) contains the main maintenance shop area
(located on the north end of the building), the main warehouse (located on the south end of the
building) and the personnel change rooms and lunch/training room (located on the extreme south
end of the building on the ground and second floors).
Within the maintenance shop area are the following work area and specialty shops:
• the main maintenance shop area contains welding and cutting equipment, lathes,
presses, and drill presses;
• a carpenter shop which contains various saws and planes. Fiberglass work is also
done within this shop area and it is located at the northwest end of the maintenance
shop area;
• an electrical shop which is located south of the carpenter shop;
• a heavy equipment maintenance shop area is located at the north end of the
maintenance shop in the center of the building;
• a rubber room for rubber lining of equipment is located east of the equipment shop
area; and
• the maintenance shop office, instrument shop and tool room are located at the south
end of the maintenance shop area.
The warehouse area contains primarily dry good storage for repair parts and consumables for the
operation of the Mill. There is an electrical water heater for the change room which is located in
the warehouse area at the south end.
Within the warehouse and maintenance shops there are some oils and chemicals stored in the
following locations:
• small quantities of flammable material such as starting fluid and spray paint are kept
in the warehouse;
• drums of new oil and anti-freeze are stored along the east wall of the equipment
maintenance area and on the east side of the warehouse on oil storage racks;
• used oil is stored in a tank located northeast of the equipment shop. The tank has a
capacity of approximately 5,800 gallons;
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• in the main maintenance shop area and the rubber room there are flammable storage
cabinets and east of the warehouse there is a trailer which is used to store flammable
items such as rubber cements, paints and fiberglass resins; and
• compressed gas cylinder storage, both empty and full is located outside, east of the
maintenance shop.
a) Electrical
The main electrical circuit breaker for the maintenance shop and warehouse building is located
on the east wall inside the Maintenance shop. Auxiliary electrical panels for the change room
and warehouse are located in the southwest comer of the warehouse area.
b) Fire Protection System
The fire protection system within the maintenance shop/warehouse/change room building
includes:
• "wet" automatic sprinkler system that releases at 212° F; and
• portable dry chemical extinguishers strategically located throughout the maintenance
area, warehouse area and the change room and lunch room.
For fire hydrant and hose cabinet locations refer to the Fire System Schematic (Figure 1).
1.2.9 Reagent and Fuel Storage
The following lists the reagents and fuel stored at the Mill site:
• a sulfuric acid tank located northwest of the mill building which has a capacity of
approximately 1.4 million gallons;
• a storage tank for propane is located on the north edge of the Mill site, northwest of
the mill building. It has a storage capacity of 30,000 gallons;
• four sodium chlorate tanks located east of the SX building, north of the office
building and east of the pulp storage tanks. The two tanks east of the SX building are
for sodium chlorate storage and the other two tanks are for dilution of the sodium
chlorate;
• two anhydrous ammonia tanks located east of the SX building, with capacity of
31,409 gallons each;
• three kerosene tanks located east of the SX building, with a capacity of 10,152
gallons each;
• one caustic soda tank north of the SX building, with a capacity of 19,904 gallons; and
• three soda ash tanks which are located east of the SX building. One tank is the dry
soda ash tank with a capacity of 70,256 gallons. Two of the tanks are soda ash
dilution tanks with capacities of 16,921 gallons each.
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• diesel fuel and gasoline are stored in two tanks located on the eastern side of the ore
pad. The gasoline storage capacity is 3,200 gallons, while diesel storage capacity is
8,000 gallons.
Other reagents are stored in steel barrels or super saks in a reagent yard located east of the office
building. Typical reagents which are stored in this yard include:
• polymers and flocculants;
• boiler feed water chemicals;
• methanol;
• tributyl phosphate;
• "dirty" soda ash and ammonium sulfate;
• SX amines and emulsion breakers;
• decyl alcohol;
• minimal amounts of acid in barrels; and
• used oil in drums and overpacks.
1.2.10 Boiler Fa__cilities
The main building (approximately 12,400 square feet) is located on the west side of the Mill site
and contains air compressors and water treatment facilities. To the north of the main building is
a building which houses a propane-fired boiler. The vanadium oxidation tank, oxidation
thickener, and pH adjustment tank are located south of the boiler house facilities.
a)
b)
Electrical
The main electrical panel for the boiler facilities is located outside of the building, on the
south wall.
Fire Protection System
The fire protection system for the boiler facilities is comprised of strategically
located portable dry chemical extinguishers.
1.2.11 Sample Plant
The sample plant building (approximately 8,000 square feet) is located on the ore pad, east of the
maintenance shop/warehouse building. The sampling plant equipment has been removed from
the building and it is currently used as a storage area for maintenance.
a) Electrical
The electrical panel for the sample plant building is located on the east wall upstairs.
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b) Fire Protection System
There are no extinguishers or sprinkler systems in the sample plant.
1.2.12 Tailings Cells and Roberts Pond
TaiHngs and wastes generated from processing conventional ores and alternate feed materials are
disposed of permanent! y in the Mill's lined tailings impoundments. The Mill's tailings cells are
comprised of four below grade engineered cells, Cell 1, 2, 3 and 4A. Liquids are stored in Cell
1 Cell 3 and Cell4A the active tailings cell. The liquid in the tailings cells is very acidic. It also
contains virtually all of the radionuclides contained in the ores and alternate feed materials that
are processed at the Mill, other than uranium, which is included in the tailings at approximately
5% of its concentration in the ores and alternate feed materials.
In addition to the tailings cells, there is also an emergency lined catchment basin (Roberts Pond)
west of the mill building. Solutions in this basin or the tailings cells should not be used to fight
fires in the Mill facility.
1.2.13 Stack Heights, Diameters and Typical Flow Rates
Emissions from the Mill process are in the form of air emissions from exhaust stacks and
solid/liquid tailings which are stored in the Mill's tailings cells located west/southwest of the
main Mill building. The major exhaust stack parameters are shown in the following table.
Height (ft from Diameter Estimated Flow Rate
Description surface) (inches) (cfm)
Leach Exhaust -100 36 13,700
Yell ow Cake Drying -85 18 4,000 per stack
(3 stacks)
Vanadium Roasting & -85 38 4100
Fusion
There are also smaller exhaust stacks associated with the Laboratory in the Mill Office building
and the boiler exhaust stack.
1.2.14 Main Shut-Off Valves
The main shut-off valves and their locations are indicated on Exhibit 7.
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1.3 Description of At;ea Near the Site
The site and sun·ounding area are indicated on the general area map included as Exhibit 4 and on
the Drainage Map indicated on Exhibit 5.
The Mill lies within a region designated as the Canyon Lands section of the Colorado Plateau
physiographic province. Elevations in the region range from approximately 3,000 feet in the
bottom of canyons to over 11,000 feet among the peaks of the Henry, Abajo and La Sal
Mountains. The average elevation for the area, excluding deeper canyons and isolated mountain
peaks is about 5,000 feet. The average elevation at the Mill site is approximately 5,600 feet
above mean sea level.
Although varying somewhat with elevation and terrain, the climate in the vicinity of the Mill can
be considered as semi-arid with normal annual precipitation of about 13.4 inches. Primary land
uses in the region include livestock grazing, wildlife range, recreation, and exploration of
minerals, oil and gas. The area within 5 miles of the Mill site is predominantly range land owned
by residents of Blanding or of the White Mesa Ute community of the Ute Mountain Ute Tribe.
There are no pereriilial surface waters on or iii the vicinity of the Mill site. Cornil Creek, located
east of the site is an intermittent tributary to Recapture Creek. Westwater Creek is an
intermittent tributary of Cottonwood Wash, with its confluence with Cottonwood Wash located
1.5 miles west of the Mill site. Both Recapture Creek and Cottonwood wash are similarly
intermittent. They both drain to the south and are tributaries to the San Juan River
approximately 18 miles south of the Mill Site.
The Mill site is near Utah State Highway 191 and can be accessed by a paved access road from
the highway to the Mill facilities. This would be the primary route for access of emergency
equipment and evacuation. A municipal airport is also located approximately 3 miles north of
the Mill site. There are no significant potential impediments to traffic flow in the area, such as
rivers, drawbridges, railroad grade crossings, etc.
The nearest residence to the Mill is approximately 1.2 miles to the north of the Mill, the next is a
residence approximately two miles north of the Mill, followed by the community of White Mesa,
about 3.5 miles to the south. The City of Blanding is located approximately 6 miles to the
northeast. Exhibit 6 shows these population centers.
The local fire station and police station are located in Blanding, Utah. Blanding also has a
medical clinic. The closest hospital is located in Monticello, Utah, approximately 30 miles north
of the Mill. St. Mary's hospital in Grand Junction, Colorado, approximately 3 hours drive by
highway, is the nearest trauma center. Specialized medical attention for radioactive
contamination or chemical exposure would be located either in Salt Lake City at the University
of Utah Medical Center (approximately 5 hours drive by highway), or in Denver, Colorado
(approximately 7 hours drive by highway).
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There are 110 faci lities close to the Mill sile that could presenL potential protective acti(>n
problems. All schools, arenas, stadiums, prisons, nul'Sing homes and hospitals are located in
Blanding, approximately 6 miles north of the Mill site.
There nre no sites of potential eme(gency significance such as liquefied petroleum gas (LPG)
terminals, chemical plants, pipelines, electrical lt~msformers and underground cables in the
vicinity of the Mill, oU1er than Mill site facilities described in detail in Section 1.2 above.
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2. TYPES OF ACCIDENTS
2.1 Description of Postulated Accidents
The following is a description of each type of radioactive materials and other accident that could
potentially occur at the Mill site that could require a1i emergency response.
2.1.1 Unloading, Storage of Ammonia
A release of anhydrous ammonia could occur through tank failure, overfilling, and failures of
piping, loading hoses, hose couplings, and emergency relief valves.
No radiological impacts are foreseen from a release of anhydrous ammonia. However, in the
event of an ammonia tank spill, the material would be expected to evaporate quickly. Release of
the entire contents of one or both of the onsite ammonia tanks during a short period of time could
result in a significant release to the environment (the atmosphere) of a hazardous material that
could require a response by an offsite organization to protect persons offsite. Such a release is
addressed hi the Mill's Risk Management Pfan, required under Section 1i2r of the Clean Air
Act, a copy of which plan is attached hereto as Appendix K. The Risk Management Plan
contemplates a worst case scenario of the release of the entire 140,000 pound contents of one of
the anhydrous ammonia tanks over a 10 minute period, which could result in a dangerous cloud
of anhydrous ammonia that could extend 12 miles from the point of origin at the Mill. An
alternate scenario of a release of 500 pounds of ammonia over a one minute period could result
in a dangerous cloud of anhydrous ammonia that extends 0.8 miles from the point of origin.
Therefore, an uncontrolled release of ammonia that could result in the release of 100 or more
pounds of ammonia is classified as a Site Area Emergency. Any other uncontrolled release of
ammonia, other than a minor release, is classified as an Alert. A minor release of ammonia is
classified as an On-Site Emergency. See Section 3 below for a discussion of the significance of
these classifications.
A minor release of ammonia would be any release that is expected to be of a small amount (less
than 7 gallons (36 pounds)) that is not expected to be uncontrolled. Minor releases of ammonia
are not subject to the notification requirements of this Plan; however they are subject to the
procedures for response to an ammonia release outlined in Appendix A.
The procedures for response to an ammonia release are outlined in Appendix A. An
uncontrolled release of 100 lbs or more of anhydrous ammonia would also require that notice be
given to the Community Emergency Coordinator for the local Emergency Planning Committee
under the Emergency Response and Community Right to Know Act (see Section 10 below). The
procedures for giving such notifications are also set out in Appendix A to this Plan.
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2.1.2 Ammonia Explosion in a Building
An ammonia-air explosive mixture could be formed inside the Mill and SX buildings if a line
ruptured. Existing controls include emergency powered vent fans, operator presence at all times
for surveillance, and one-half inch piping that minimizes potential release amounts.
Radiological impacts from the explosion would be minimal and mo t likely contained within the
restricted area, unless the explosion resulted in a fire (see Sections 2.1.6 and 2.1.7 below for the
emergency response procedmes to follow in the event of a fire). An ammonia explo ion would
be classified as a Site Area Emergency if it involved the uncontrolled release of greater than
IOOlbs of anhydrous ammonia, and as an Alert if it involved an uncontrolled release of 36 lbs (7
gallons) to 100 lbs of anhydrous ammonia. Releases of less than 7 gallons are classified as On-
Site Emergencies (see Section 3 for significance of this classification). Any contamination
would be recycled or disposed of, as appropriate.
The procedure for response to an ammonia explosion are set out in Appendix B.
2.1.3 Unloading/Storage of Propane/Propane Fire or Explosion
A release of propane could occur through tank failure, overfilling, and failures of piping, loading
hoses, hose couplings, and emergency relief valves.
Daily inspections of the propane tank for leaks and integrity are conducted to minimize potential
hazards associated with propane leaks.
No radiological impacts are predicted for a release of propane, unless the release is a ·sociated
with a fire. Inhalation of propane is also Jess a hazard than inhalation of ammonia, and would
not be expected to be a significant threat to the public, although it could pose hazards to workers
in the immediate vicinity of the release. Vapors can cau e dizziness or asphyxiation without
warning.
However, there is a significant risk of fire or explosion in the event that the release was
uncontrolled and the propane was ignited. Such a release is addressed in the Mill's Risk
Management Plan, required under Section 112r of the Clean Air Act, a copy of which plan is
attached hereto a Appendix K. The Risk Management Plan contemplates a worst case scenario
of the release of 110,000 pounds of propane, resulting in a vapor cloud explosion extending 0.40
miles from the point of origin. An alternate scenario of a release of 500 pounds of propane could
result in a vapor cloud explosion extending 0.01 miles from the point of origin. The propane
tank is located approximately 0.5 miles from Highway 191 and the nearest Mill property
boundary, o a propane explosion is unlikely to have direct offsite impacts. However, as a
maHer of caution, notice i provided to offsite authorities.
An uncontrolled release of propane that could result in the possibility of an explosion is
classified as an Alert. A minor release of propane (see below) is classified as an On-Site
Emergency. See Section 3 below for a discussion of the significance of these classifications.
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A minor release of propane would be any release that is expected to be of a small amount and
that is not expected to be uncontrolled or pose a risk of explosion. Minor releases of propane are
not subject to the notification requirements of this plan; however, they are subject to the
procedures set out in Appendix C.
The procedures for response to a propane release are outlined as Appendix C.
2.1.4 Leach Tank Failure
The rubber lined leach tanks contain the nearly boiling ore/sulfuric acid slurry. Tank failure due
to corrosion and break-out is a possibility. Procedures and practices are in place and functioning
to minimize this possibility. Failure due to loss of structural integrity is also possible. The tanks
are evaluated periodically to determine structural stability and the potential need for replacement.
Radiological impacts are minimal from an occurrence of this type. Any release of material
would be contained in the leach area or would flow to the lined catchment basin (Roberts Pond)
west of the Mill for containment, as designed.
Accidents of this type are classified as On-Site Emergencies. See Section 3 for the significance
of this classification.
The procedures for response to a leach tank failure are outlined in Appendix C and in the Mill's
Spill Prevention, Control, and Countermeasures Plan For Chemicals and Petroleum Products (the
Spill Response Plan"), a copy of which is attached as Appendix L to this Plan.
2.1.5 Sulfuric Acid Storage Tank Failure
The Mill's sulfuric acid storage tanks consist of one large above ground tank that can hold up to
1,600,000 gallons and two smaller tanks with capacities of 269,160 gallons each. Tank failure
due to corrosion and break out is possible. Failure due to loss of structural integrity, as well as
failures of piping, loading hoses, hose couplings, and emergency relief valves.
A sulfuric acid tank spill would flow via an above ground path to tailings Cell 1 or to Roberts
Pond.
There would be no radiological impacts associated with an accident of this type. Nor would
there be any significant hazards to the environment from off gases from any such release.
However, there would be potential hazards to workers in the close vicinity from contact with
sulfuric acid or inhalation of sulfuric acid vapors, and a release to the surface soils.
The large tank is equipped with a high level audible alarm which sounds prior to tank overflows.
The two smaller tanks are also equipped with high level audible alarms.
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Accidents of this type are classified as On-Site Emergencies, because they will not lead to a
significant release to the environment of radioactive or other hazardous material. See Section 3
below for the significance of this classification.
The procedures for response to a sulfuric acid tank failure are outlined in Appendix D and in the
Mill's Spill Response Plan.
2.1.6 SX Fire
The possibility of a major fire in the solvent extraction building is remote, as very strict safety
precautions are adhered to. This part of the process is kept isolated and in separate buildings due
to the large quantities of kerosene present. These facilities are equipped with an independent fire
detection and protection system. In the event of a fire in the solvent extraction building, the fire
suppression system delivers foam to the affected area. The foam is designed to spray for 25
minutes, followed by water at 100 psig and up to 2,000 gpm.
In spite of the safety precautions, a major fire in the solvent extraction building could occur.
NRC staff concluded in NUREG-1140 that a fire in the solvent extraction circuit is the accident
of greatest significance for emergency preparedness for a uranium mill, from the point of view of
potential radiological impacts offsite. However, NRC staff concluded that the calculated dose
from this type of accident is small (0.1 rem or less) because of the very low specific activity of
the uranium and the low volatility of the uranium compounds, which causes a low release
fraction. NRC staff noted that these low release fractions are the reason why no offsite ground
contamination was ever detected due to the historic fires that have occurred at other uranium
mills. In the 1980s, two solvent extraction fires occurred at other uranium Mills. Neither fire
resulted in appreciable release of uranium to the unrestricted environment, and essentially
complete recovery of the uranium was obtained.
As a result, NRC staff concluded in NUREG-1140 that no credible accident would justify
emergency protective actions because radiation doses to the public offsite from an accident
would be below the EPA's protective action guides. Also, the quantity of uranium inhaled is
below the quantity where chemical toxicity effects are observed. Thus, neither radiation doses
nor chemical toxicity from licensed materials is a concern with respect to the need for prompt
protective actions.
If a major fire were to occur, the radiological environmental effects would be confined within a
few hundred feet of the buildings. Recovery of uranium that would be scattered by the burning
solvent would be accomplished. Uranium-contaminated soil would be processed in the Mill
circuit or disposed of in the Mill's tailings cells, as appropriate. The Mill would be required by
existing regulations to take certain actions. Among these, the Mill would be required by 10 CPR
20.201(b) to conduct surveys (offsite if appropriate) to determine whether the NRC's limits on
radioactivity in effluents to unrestricted areas in 10 CFR 20.106 were exceeded. A major fire
would also require immediate notification of the Executive Secretary by telephone (10 CFR
20.403)
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Consequently, the impact from such an event at the Mill would be limited to (1) cleanup of
contaminated material, (2) replacement of destroyed Mill components, and (3) a short duration
release of combustion products to the atmosphere.
A major SX fire is classified as an Alert. See Section 3 for the significance of this classification.
The procedures for response to an SX fire are outlined in Appendix E.
2.1. 7 Other Fire
A fire could start anywhere in or around Mill facilities as a result of a number of causes, such as
lightning strikes, electrical malfunction, human error etc. However, at the Mill there is an
increased risk of fire and of severe onsite or offsite consequences in the following areas, due to
the nature of the chemicals stored or used at those areas:
• SX Building (see Section 2.1.6 above);
• Propane Tanks (see Section 2.1.3 above); and
• Lab or Lab Storage Area.
Fires could start in these areas due to equipment malfunction or human error and the intensity
and consequences of the fire could be severe, although direct radiological hazard from any such
fires would be expected to be relatively low (see Section 2.1.6 for a discussion of the radiological
impacts of an SX fire, which is the type of accident con idered to have the highest risk of
radiological impacts at a uranium mill). To the extent that facilities arc damaged as a result of
any such fire, there could be secondary radiological hazards, such as fire damage in the
yellowcake product drying, packaging and storage areas that would have to be evaluated.
As discussed in Section 2.1.6 above, an uncontrolled fire in the SX building is classified as an
Alert. All other uncontrolled fires in Mill buildings are classified as On-Site Emergencies. See
Section 3 for a discussion of the significance of these classifications.
Should a fire (other than an SX fire) occur, the procedure outlined in Appendix F for reporting
and responding to fires will be followed (the procedure to be followed for an SX fire is outlined
in Appendix E).
2.1.8 Tornado
Although this is highly unlikely, a tornado could occur at the Mill. A severe tornado could cause
buildings and other structures to collapse, chemical or gas releases, major fires as well as general
panic. The environmental impacts from a tornado could be the transport of tailings solids and
liquids, ores or product from the Mill area into the environment. This dispersed material would
contain some uranium, radium, and thorium. An increase in background radiation could result,
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and, if sufficient quantities are detected and isolated, they would be cleaned up. However, NRC
staff have concluded in NUREG-1140 that while tornadoes could release a large amount of
radioactive material, they spread the material so greatly that resulting doses are very small. As a
result, tornadoes are not discussed further in NUREG-1140 and are not considered to be a
significant radiological risk at uranium mills.
However, to the extent that a tornado has caused or is likely to result in an ammonia leak or
propane release, an SX building fire or a breach of the Mill's tailings cells, it would be classified
as a Site Area Emergency or Alert depending on which one of these other accidents resulted
from the tornado. All other tornadoes would be classified as On-Site Emergencies. See Section
3 below for the significance of these classifications.
In the event of a major tornado, the procedures outlined in Appendix G will be followed.
2.1.9 Major Earthquake
Although this is highly unlikely, an earthquake could occur at the Mill. A severe earthquake
could cause buildings and other structures to collapse, chemical and/or gas releases, major fires
as well as general panic. NRC staff concluded in NUREG-1140 that earthquakes were not
identified as leading to significant releases of radionuclides unless they were followed by a fire.
To the extent that an earthquake has caused or is likely to result in an ammonia leak or propane
release, an SX building fire or a breach of the Mill's tailings cells, it would be classified as a Site
Area Emergency or Alert, depending on which one of these accidents resulted from the
earthquake. All other major earthquakes would be classified as On-Site Emergencies. See
Section 3 for the significance of these classifications.
In the event of a major earthquake the procedures outlined in Appendix G will be followed.
2.1.10 Tailings Accidents
2.1.10.1 Flood Water Breaching ofRetention System
In general, flood water breaching of tailings embankments presents one of the greatest dangers
for the sudden release of tailings solids and impounded water. The tailings cells are designed
with sufficient freeboard (at least three feet) to withstand back-to-hack 100-year storm events or
40% of the probable maximum flood (PMF) followed by the 100-year storm event. The flood
design is equivalent to 15 inches of rainfall. In addition, the tailings dikes were designed in
accordance with NRC regulations and allow a sufficient margin of safety even in the event of an
earthquake.
The possibility of floods in Westwater Creek, Corral Creek, or Cottonwood Wash causing
damage to the tailings retention facility is extremely remote. This is due to the approximately
200 foot elevation difference between the streambeds of the creeks and the toe of the tailings
dikes.
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Flood water breaching a tailings embankment is classified as an On-Site Emergency, because it
is unlikely that any re1eases to the environment will leave the Mill properly, and in the event that
any contamination were to leave the property, it is Llnlikely that the release is expected to require
a response by an offsite response organi~alion to protect persons offsite. See Section 3 below for
the significance of this classification.
In the event of a Flood Water Breach of the tailings retention system, to procedures in Appendix
H will be followed.
2.1.10.2 Structural Failure of Tailings Dikes
All tailings dikes have been designed with an ample margin of safety as per NRC regulations.
This has included design calculations showing dike stability even when the dike is saturated with
moisture during a seismic event, the most severe failure mode. In addition, the tailings discharge
system is checked at least once per shift during operation, or once per day during Mill standby.
NRC staff concluded in NUREG-1140 that tailings pond failures also release a large quantity of
material. However, NRC taff concluded that rapid emergency response is not needed to avoid
doses exceeding protection action guides because dose rates at a spill site are very low. NRC
staff concluded that an appropriate response is to monitor drinking water, especially for radium-
226, to be sure that drinking water standards are met Gamma ray monitoring of the ground i
also appropriate to determine where the tailings have been deposited. However, NRC staff
concluded that ground contamination present Little immediate hazard to the public becau e the
gamma dose rates are low. Gamma dose rates in contact with tailings should be les than 0.1
mR/hr. A clean-up of the spilled tailings would be expected, but this could be done effectively
without pre-existing emergency preparedness.
Although U1e di charge from a dike failure would soon cross the restricted area boundary, the
flow path is over three miles in length before leaving the Mill property. In the event of a dam
failme, large operating equipment will be mobilized to construct temporary earthen dikes or
berms downgradient to the failed dike. In addition, the State of Utah, Division of Radiation
Control Executive Secretary (the "Executive Secretary), MSHA, and State of Utah, Department
of Natural Resources, Division of Dam Safety will be notified. The contamination from such an
event would be cleaned up and returned to the tailings area.
A tailings dam failure is classified as an On-Site Emergency, because it is unlikely that any
releases to the environment will leave the Mill propetty. and in the event that any contamination
were to leave the property, it is unlikely that the relea e is expected to require a response by an
offsite response organization to protect persons offsite. See Section 3 for the significance of this
classification.
In the event of a tailings dam failure the procedures outlined in Appendix H will be followed.
2.1.10.3 Seismic Damage to Transport System
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In the event of a seismic rupture of a tailings slurry pipeline, the released slurry will be contained
in the tailings cells regardless of the quantity released. The tailings retention system pipe is in
the same drainage basin as the retention system. Any tailings slurry released by a pipe rupture,
no matter what the cause, would flow downhill where it would be impounded inside a tailings
cell.
If a break occurred, the pumping system would be shut off, personnel removed from the
immediate area, and the Executive Secretary notified. The break would be repaired and the
affected area cleaned up in the safest and most expeditious manner. The advice and direction of
the Executive Secretary would be sought and heeded throughout the episode.
A seismic rupture in the tailings slurry pipeline would be classified as an On-Site Emergency.
See Section 3 for the significance of this classification.
In the event of a rupture in the tailings slurry pipeline the procedures outlined in Appendix H
will be followed.
2.1.11 Terrorist/Bomb Threat
In the event that any person should receive a threat of a bomb, the procedure set out in Appendix
I should be followed.
Because of the unknown nature of the risk, a terrorist/bomb threat is classified as an Alert. See
Section 3 for the significance of this classification.
In the event of a terrorist/bomb threat, the procedures in Appendix I will be followed.
2.1.12 Chemical or Reagent Spills
Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow and dikes and/or curbs are constructed around process and
storage tanks (excluding the water tank) to confine the material in the event of a tank spill,
However, as an operating facility, it is possible for spills of chemicals or reagents to occur from
time to time. Unless such a spill qualifies as an ammonia release (see Section 2.1.1 above), a
propane release (see Section 2.1.3 above) or a sulfuric acid release (see Section 2.1.5 above), the
spill will be considered a minor spill and will be addressed and cleaned up in accordance with
the Mill's Spill Response Plan.
It is unlikely that any such minor spills will impact the environment if cleaned up in accordance
with the Mill's Spill Response Plan. The entire Mill facility is graded such that run-off will drain
into the Mill's tailings cells.
A copy of the Mill's Spill Response Plan is included as Appendix L to this Plan.
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Any such minor spills are classified as Non-Subject fucidents. See Section 3 for the significance
of this classification.
2.1.13 Transportation Accident on the Mill Property Involving a Spill of Yellowcake
In the event of a transportation-related accident on the Mill property involving a spill of
yellowcake, immediate containment of the product will be achieved by covering the spilJ area
with a plastic sheeting or equivalent material to prevent wind and water erosion. If sheeting is
not available, and depending on where the spill occurs, soil from the surrounding area may be
used. Perimeter ditching will be used to contain the pill if it should occur in an area where
runoff could result from precipitation.
All human and vehicular traffic through the spill area will be restricted. The area would be
cordoned off if possible. All persons not patticipating in the accident response will be restricted
to 50 feet from the accident site. Local law enforcement officers will be notified and may be
asked to assist in controlling traffic and keeping unauthorized persons out of the spill area.
Covered containers and removal equipment, i.e., large plastic sheeting; radioactive signs, t•opes,
hoses, shovels, vacuums, axes, stakes, heavy equipment (front-end loaders, graders, etc.), will be
available to clean up the yellowcake. A Radioactive Material Spill Kit L available and tmder the
control of the Radiation Department. If conditions warrant, water will be applied to the spilled
yellowcake in a fine spray to assist in dust abatement.
Gloves, protective clothing and any personal clothing contaminated during cleanup operations
will be encased in plastic bags and kept in the plant area for decontamination or disposal.
Any fire at the site will be controlled by local experienced fire fighting personnel wearing
appropriate respiratory protective equipment.
Response team members will have a thorough knowledge in basic first aid and of the physical
hazards in inhalation, ingestion, or absorption of radionuclides. Team members will adequately
protect themselves.
As per R313-15 requirements, the Executive Secretary will be notified promptly of any accident
of this type.
Any minor spills are classified as Non-Subject Incidents. See Section 3 for the significance of
this classification.
2.1.14 Offsite Transportation Accidents
2.1.14.1 Concentrate Shipments
Concentrates will be shipped in sealed 55-gallon dmms built to withstand normal handling and
: :
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minor accidents. Each mum will contain approximately 900 pounds of yellowcake. A
maximum of 43 drums will be shipped in each closed van. The drums will be sealed and marked
"Radioactive LSA" (low specific activity), and the trucks will be properly marked. Because
most of the radioactive daughter products of uranium are removed in the extraction process and
radioactive buildup of daughter products is slow, yellowcake has a very low level of
radioactivity and is therefore classified by the Department of Transportation as a low specific
activity material.
The environmental impact of a transportation accident involving release of the product would be
minimal. Yellowcake, having a high density, even in a severe accident in which multiple drums
are breached, would not easily disperse. More than likely, the drums and any released material
would remain within the damaged vehicle or in an area of close proximity of the accident site.
Driver or carrier instructions are given to each driver of each transport leaving the plant site with
a load of yellowcake. These instructions will consist of an explanation of the product,
preliminary precautions at lhe accident site, whom to notify and what to do in case of fire. A
copy of these instructions is included in the Mill's Transportation Accidents Plan, a copy of
which is attached as Appendjx M to this Plan.
Mill persom1el would respond if reque ted fo1· the initial spill response to handle any yellowcake
transport accident. A procedure for this likelihood is included in the Mill's Transportation
Accidents Plan. DUSA may contract with a carrier or firm properly trained to handle any
yellowcake transport accident.
Offsite accidents involving the transportation of product concentrates are classified as Non-
Subject Incidents. See Section 3 for the significance of this classification.
In the event of an offsite accident involving a spill of yellowcake, the procedures outlined in the
Mill's Transportation Accidents Plan, attached as Appendix M hereto, will be followed.
2.1.14.2 Ore or Alternate Feed Material Shipments
Ore is shipped in 20 to 25 ton shipments in highway trailers that are covered by tarpaulins. The
truck trailers are labeled "Radioactive LSA". Because the ore is typically in the form of large
particles and is typically wet (2% to 5% moisture), the potential for a significant release from an
accident involving an ore shipment truck is quite small.
Alternate feed materials can be transpmted to the Mill in a number of conveyances. Most
typically, alternate feed materials are either shipped in bulk in intermodal containers (either with
or without a secondary containment such as a supersac), or in teel drums (possibly in plastic
overpacs) in the back of a van trailer. Bulk shipments in intermodal container are labeled
"Radioactive LSA". For bulk materials, the potential release from an accident is similar to
potential releases from an accident involving conventional ores, but this may vary depending on
the feed material and the manner of conveyance. The potential release from alternate feed
materials that are transported in drums will vary, depending on the particular alternate feed
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material, and in some cases could be equal to or exceed the risks associated with transportation
of yellowcake.
In the event of an accident, the transportation company will respond to clean up any spilled
material and ensure that the area is clean. Mill personnel will support the transportation
contractor in cleaning up the affected area and radiological scanning of the impacted area.
Offsite accidents involving the transportation of ores and alternate feed materials are classified as
Non-Subject Incidents. See Section 3 below for the significance of this classification.
2.1.14.3 Reagent Shipments
Reagents are shipped in properly marked trailers and the driver are trained in hazardou materials
transportation and accident procedures. In the event of an accident, all of the reagent supplier '
transportation contractors are required to have emergency response contractors to respond to an
accident and a potential spill. Many of the reagents that are used at the Mill are shipped on a
daily basis to other industrial facilities throughout the United States. The potential for an
accident is minimized due to quick respo11se of the transportation contractor's emergency
response team and the training of many of the country's emergency-response services.
Offsite accidents involving the transportation of reagents are classified 1:1· Non-Subject Incidents.
See Section 3 below for the significance of this classification. However, the State of Utah
Division of Radiation Control (80 1-536-4250) should be notified within 24 hours of the incident.
2.1 Detection of Accidents
Mill personnel perform a number of daily and weekly inspections of the Mill facilities. These
are:
• The Mill's Shift Foremen conduct inspections of all facility areas each operating shift;
• The Mill's RSO or designee performs a daily inspection of all facility areas;
• Mill personnel perform daily, weekly, monthly and quarterly inspection of the Mill's
tailings cells; and
• The Mill's RSO or designee performs weekly inspections of all areas of the Mill.
These inspections, particularly the shift and daily inspections provide a means for Mill personnel
to detect and alert the Mill's operating staff of any abnormal ope:rating condition or of any other
danger to safe operations. Thes1e in pections, along with the observations of operating personnel
in any impacted area, are the primary means of detecting the accident and alerting the operating
staff for chemical or gas leaks, any fires in areas that do not have fire detection equipment, or
any impairment to the tailings cells.
For areas of the Mill with fire detection equipment, such as the SX Building, the office building
and the Maintenance/Warehouse Building, in addition to the foregoing inspections, the fire
detection equipment would be expected to also provide an early warning of a fire.
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Tanks which are likely to overflow are equipped with high level alarms to reduce the possibility
of spillage due to tank overflow.
For terrorist or bomb threats, the threat itself would provide the means of detection of the
incident. Where no threats are given, suspicious activity would be observed during the shift and
daily inspections. In addition, the Mill employs surveillance cameras in a limited number of
areas, which are intended to aUow Mill personnel to monitor product storage areas and certain
access poinls to the facility.
The required responses to any detected accidents are set out in Section 2.1 above and in
Appendices A through I for the various types of accidents.
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3. CLASSIFICATION AND NOTIFICATION OF ACCIDENTS
In this Emergency Response Plan, accidents have been classified into four categories as
described below. It should be noted that Reg. Guide 3.67 concludes that fuel cycle and material
facilities, such as the Mill, do not present the same degree of hazard (by orders of magnitude) as
are presented by nuclear power plants. Thus the classification scheme for the Mill, which has
four classes of accidents (Alerts, Site Area Emergencies, On-Site Emergencies and Non-Subject
Incidents), is different from the classification scheme for other nuclear facilities, which have two
classes of accidents (Site Area Emergencies and Alerts).
Reg. Guide 3.67 provides that "[t]he NRC intends that licensees be allowed to have a single
emergency plan that can apply to all licensee needs and regulatory requirements. To this end it
should be understood that a licensee may wish to include in the emergency plan some incidents
that do not fall within the jurisdiction of the NRC. For example, the licen ee may wish to
include industrial accidents or fires unrelated to the licensee's work with nuclear material . The
licensee may include such incidents in the emergency plan."
As a result, this Plan includes O.n-Site Einergericies, most of which do not involve risks of offsite
releases of radiation and are therefore not specifically required by Reg. Guide 3.67 to be
included in an emergency response plan for the Mill, and Non-Subject Incidents, which are
incidents that are addressed by other plans (such as the Mill's Spill Response Plan and
Transportation Accidents Plan) and that either involve incidents that could occur on site but that
would not involve risks of offsite releases of radi.onuclides or that involve offsite accidents, and
for these reasons are not required by Reg. Guide 3.67 to be included in this Plan. These On-Site
Emergencies and Non-Subject Incidents are included in this Plan in order to compile all potential
emergencies into one Plan. Although in some cases this merely involves referencing the type of
accident or incident and then referring the reader to another plan, the pwpose is to allow Mill
personnel to have a reference source that will allow them to be able to respond quickly to each
type of incident.
3.1 Classification System
At the Mill, there are four classes of accidents, Alerts, Site Area Emergencies, On-Site
Emergencies and Non-Subject Incidents, described as follows:
a) Alert
An Alert is defined as an incident that has led or could lead to a release to the environment of
radioactive or other hazardous material, but the release is not expected to require a response by
an offsite response organization to protect persons offsite. An Alert reflects mobilization of the
Mill's emergency response organization, either in a standby mode that will activate some
portions of the Mill's organization or full mobilization, but does not indicate an expectation of
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offsite consequences. However, an Alert may require offsite response organizations to respond
to onsite condition such as a fire.
The following potential accidents are classified as Alerts:
• An uncontrolled release of 36 pounds (7 gallons) or more but less than 100 pounds of
anhydrous ammonia (see Section 2.1.1);
• An ammonia explosion that involves a release of 36 pounds (7 gallons) or more but less
than 100 pounds of anhydrous ammonia (see Section 2.1.2);
• An uncontrolled release of propane that could result in an explosion (see Section 2.1.3);
• A major fire in the SX building (see Section 2.1.6); and
• A terrorist/bomb threat (see Section 2.1.11)
b) Site Area Emergency
A Site Area Emergency is defined as an incident that has led or could lead to a significant release
to the environment of radioactive or other hazardou material and that could require a response
by an offsite organization to protect persons offsite. A Site Area Emergency reflects full
mobilization of the Mill's emergency response organization and may result in requests for offsite
organizations to respond to the site.
Although it is unlikely that a Site Area Emergency requiring offsite actions will occur at a fuel
cycle or materials facility such as the Mill, the Mill must nevertheless be able to recognize
potential offsile hazards and make the required notifications in such a manner that offsite
response organizations can take appropriate actions, such as sheltering or evacuating persons in
the affected area.
Accordingly, the following potential accidents have been classified as Site Area Emergencies,
because they could require a response by an offsite organization to protect persons offsite:
• An uncontrolled release of 100 lbs or more of anhydrous ammonia (see Section 2.1.1);
and
• An ammonia explosion that involves a release of 100 lbs or more of anhydrous ammonia
(see Section 2.1.2).
c) On-Site Emergency
An On-Site Emergency is defined as an incident that is of a nature that has not led or could not
lead to a significant release to the environment of radioactive or other hazardous material, and
hence does not qualify as an Alert or a Site Area Emergency, but that nevertheles could pose
significant and unusual safety hazards to workers at the site, and is therefore subject to the
procedures under this Plan.
The following potential accidents are or could be classified as On-Site Emergencies:
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• A minor release (less than 36 lbs (7 gallons)) of anhydrous ammonia that is not
uncontrolled (see Section 2.1.1);
• An ammonia explosion in a building, unless this results in a fire in the SX building, an
uncontrolled release of 36 pounds (7 gallons) or more of anhydrous ammonia or an
uncontrolled release of propane that could result in an explosion, in which case the
classifications applicable to those other incidents would apply (see Section 2.1.2);
• A minor release of propane that is not uncontrolled and could not lead to an explosion
(see Section 2.1.3);
• A leach tank failure (see Section 2.1.4);
• A sulfuric acid storage tank failure (see Section 2.1.5);
• A fire (other than a major fire in the SX building) (see Section 2.1.7);
• A tornado, unless thl results in a fire in the SX building, an uncontrolled release of
anhydrous ammonia or propane, in which case the classifications applicable to those
other incidents would apply (see Section 2.1.8);
• A major earthquake, unless this results in a fire in the SX building, an uncontrolled
release of anhydrous ammonia or propane, in which case the classifications applicable to
those other incidents would apply (see Section 2.1.9); and
• Tailings Accidents
o A flood water breaching of the tailings retention system (see Section 2.1.10.1)
o Structural failure of a tailings dike (see Section 2.1.10.2); and
o Seismic damage to the tailings transportation system (see Section 2.1.10.3).
d) Non-Subject Incidents
A Non-Subject Incident is defined as an incident that involves an accident of a specific nature
that is covered under a different plan and is not subject to this Plan but is listed in this Plan for
informational purposes only.
The following potential incidents are or could be classified as Non-Subject Incidents:
• A chemical or reagent spill (other than a release of anhydrous ammonia or propane, or a
sulfuric acid leak or spill). These types of spills are covered by the Mill's Spill Response
Plan (see Section 2.1.12);
• A transportation accident on the Mill property involving a spill of yellowcake. These
accidents are covered by the Mill's Spill Response Plan (see Section2.1.13); and
• An offsite transportation accident
o Concentrate shipments. These types of accidents are covered by the Mill's
Transportation Accidents Plan (see Section 2.1.14.1);
o Ore or alternate feed material shipments (see Section 2.1.14.2); and
o Reagent Shipments (see Section 2.1.14.3).
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3.2 Notification and Coordination
3.2.1 Alert
The purpose of declaring an Alert is to ensure that emergency personnel are alerted and at their
emergency duty stations to mitigate the consequences of the accident, that the emergency is
properly assessed, that offsite officials are notified, and that steps can be taken to escalate the
response quickly if necessary.
An Alert, like a Site Area Emergency, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Radiation Control. This is because there is a potential for offsite consequences.
The actions to be taken in the event of an Alert vary somewhat depending on the incident. The
actions to be taken for each incident described in Section 2.1 above that is classified as an Alert
are set out in the various subsections in Section 2.1 and corresponding Appendices A through I
to this Plan that relate to the specific incidents. The actions set out in the Appendices describe,
to the extent appropriate for each incident, how and by whom the following actions will be taken
with respect to each specific incident:
• Decision to declare an Alert (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that an Alert has been declared
(normally within 15 minutes of declaring an Alert);
• Notification to the State of Utah Division of Radiation Control immediately after
notification of offsite authorities, and in any event within one hour of the declaration of
an Alert;
• Decision to initiate any onsite protective actions;
• Decision to escalate to a Site Area Emergency, if appropriate;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
3.2.2 Site Area Emergency
The purpose of declaring a Site Area Emergency is to ensure that offsite officials are informed of
potential or actual off ite consequences, that offsite officials are provided with recommended
actions to protect persons offsite, and that the Mill's re pon e organization is augmented by
additional personnel and equipment.
A Site Area Emergency, like an Alert, differs from an On-Site Emergency or a Non-Subject
Incident in that offsite response authorities are notified, as well as the State of Utah Division of
Radiation Control. This is because there is a potential for offsite consequences. Unlike an Alert,
a Site Area Emergency assumes that offsite emergency response assistance will be required.
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The Mill has identified only two incidents that should be classified as Site Area Emergencies -
an uncontrolled release of greater than 100 pounds of anhydrous ammonia; and an ammonia
explosion that involves the release of greater than 100 pounds of anhydrou ammonia. The
actions to be taken in the event of such Site Area Emergencies are et out in subsection 2.1.1
above and in Appendices A and B to this Plan, and describe, to the extent appropriate, how and
by whom the following actions will be taken:
• Decision to declare a Site Area Emergency (this has been predetermined by incident);
• Activation of onsite emergency response organization;
• Prompt notification of offsite response authorities that a Site Area Emergency has been
declared, including recommendation for offsite protective actions (normally within 15
minutes of declaring a Site Area Emergency);
• Notification to the State of Utah Division of Radiation Control immediately after
notification of offsite authorities, not later than one hour after the Mill has declared a Site
Area Emergency;
• Decision on what onsite protective actions to initiate;
• Decision on what offsite protective actions to recommend;
• Decision to request support from offsite organizations; and
• Decision to terminate the emergency or enter recovery mode.
3.3 Information to be Communicated
Mill personnel will do their best lo provide clear, concise information to offsite response
organizations. The communication should avoid technical terms and jargon and should be
stated to prevent an under-or over-evaluation of the seriousness of the incident.
The procedures set out in the Section 2.1 and Appendices A through I de-scribe the key types
of information that will be communicated with respect to facility status, releases of
radioactive or other hazardous materials and recommendations for protective action to be
implemented by offsite response organizations, where applicable. Such Appendices also
contain the preplanned protective action recommendations the Mill will make to each
appropriate offsite organizaUon for each incident that is classified as an Alert or Site Area
Emergency, including the ize of the area where the actions are to be taken. The Appendices
also contain a standard reporting checklist to facilitate timely notifications.
Mill personnel meet annually with the various offsite emergency response providers to
ensure that:
• This Plan contains the most practical and efficient protective actions for each
postulated accident and that such providers understand and agree with the
recommended courses of action; and
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• The notifications sel oul in lhis Plan are appropriale and the cantacl information is
current.
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4. RESPONSIBILITIES
4.1 Normal Facility Organization
The Mill Manager is ultimately respon ible for the Mill site. The Mill Manager reports to the
Executive Vice President, US Operations of DUSA. The Executive Vice President, US
Operations of DUSA reports to the President and Chief Executive Officer of DUSA.
The Mill Superintendent, Maintenance Superintendent and Radiation Safety Officer report
directly to the Mill Manager. The Utility Crew, Administrative Staff and Chief Metallurgist also
report directly to the Mill Manager.
One or more Mill Foremen report to the Mill Superintendent. The number of Mill Foremen will
depend on Mill activities. In full operations, there are two Mill Foremen. The Shift Foremen
report to the Mill Foremen.
The Radiation Technicians, the Safety Coordinator and his staff and the Environmental
Coordinator and his staff report to the Radiation Safety Officer.
The Maintenance Foreman and Electrical Foreman report to the Maintenance Superintendent.
These relationships are indicated on the following diagram:
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Date: August 18, 2009 Title: White Mesa MiU Emergency Re ponse Plan
Maintenance
Superintendent
I
Maintenance
Foreman
I
Maintenance
Personnel
MILL ORGANIZATION CHART
NORMAL OPERATIONS
I
Administrative
Staff
I
Electrical
Foreman
I
Electricians
President and
Chief EF;ecutive
Officer
I
Executive Vice
President, US
Operations
1
Mill Manager
I
Mill
Superintendent
Mill Foremen
Shift Foremen
Operations
Personnel
I
Crew Radiation
Technician(s)
Utility Crew
Lead Radiation
Technician
Radiation
Technician(s)
I
Chief
Metallurgist
I
Mill Chemist
I
Lab Persmmel
I
Environmental
Coordinator
I
Environmental
Technician(s)
Page 33 of
111
Radiation Safety
Officer
I
Safety
Coord ina tor
I
Safety
Technician(s)
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The procedures to be followed for the types of possible emergencies that have been identified for
the Mill are set out in Section 2.1 above and more specifically in Appendices A through I. The
individuals who have the authority and responsibility to declare the various types of emergencies
are detailed in Section 2.1 and those Appendices.
4.2 Onsite Emergency Response Organization
The response crew for each operating shift will normally consist of the following operators under
the direction of the shift foreman. This organization may be changed for individual shifts subject
to the approval of the RSO/Fire Chief.
4.2.1 Direction and Coordination
The Incident Commander will be the Mill Manager, or in his absence, the Mill Superintendent,
or in the absence of both the Mill Manager and the Mill Superintendent, the RSO.
The Incident Commander has the overall responsibility for implementing and directing the
emergency response. The Incident Commander has the following duties and authorities:
• Control of the situation;
• directing activities during the emergency;
• coordination of staff and offsite personnel who may augment the staff;
• communication with parties requesting information about the event;
• reporting to local, State and Federal authorities;
• authority to request support from offsite agencies;
• termination of the emergency; and
• authority to delegate any of the foregoing responsibilities to:
o the Mill Superintendent;
o theRSO; or
o such other individual or individuals that the Incident Commander deems
appropriate in the circumstances.
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact or direct others to contact
all outside services.
The Incident Commander has the ultimate responsibility to account for all employees at the Mill,
using the assistance of supervisors and/or any DUSA personnel. The Incident Commander has
the responsibility for the news media and reports directly to the Executive Vice President or
President of DUSA.
:
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Shift Foremen are in charge until the Incident Commander arrives and are responsible for all
functions listed above. Shift Foremen have the respon'sibility to account for all of their people in
addition to any visitors, contractors, etc., in their areas and report to the Incident Commander; or,
in the absence of the Incident Commander, to administer all of the above duties.
4.2.2 Onsite Staff Emergency Assignments
The following individuals, organizational group or groups are assigned to the functional areas of
emergency activity listed below.
During normal working hours while the Mill is in full operation, all of the individuals or their
alternates should be available on site to fulfill their emergency assignments. During evening or
night shifts, or during other times when the Mill is not in full operation, not all of the individuals
listed below will be on site. However, there will always be a Shift Foreman on site.
Blanding is a small town, and most of the individuals listed below live within a short distance of
the Mill. In the event of an emergency during a non-working period, afternoon or night shift,
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, wiU initiate procedures to effect any
necessary evacuations of the site and will contact the required personnel from the list of
assignments below to assemble the team required in order to fill all of the necessary assignments.
Two of the first persons contacted will be the Mill Manager and the RSO, who will ensure that
the remainder of the team is assembled in order to carry out the emergency procedures set out in
this Plan for the emergency.
a) Facility System Operations
The Mill Superintendent, or in his absence a Mill Foreman or the Mill Manager, is responsible
for all operational activities on the property. In this capacity, the Mill Superintendent, Mill
Foreman or Mill Manager can shut down any affected areas within the process and render aid to
the other departments.
The Maintenance Superintendent, or in his absence the Maintenance Foreman or the Mill
Manager, is responsible for all mechanical and instrumentation on the site and has the ability to
gather resources during any declared emergency.
Shift Foremen are in charge until the foregoing personnel arrive and are responsible for all of the
foregoing functions until relieved by one or more of the foregoing individuals.
b) Fire Control
As Fire Chief, the RSO has the responsibility to maintain trained fire crews and operable
equipment, mobilize and direct the fire crews and equipment in a fire emergency or one
containing the threat of fire, and to assist in evacuation and rescue or recovery operations. The
RSO/ Fire Chief makes sure that the team or crew has been established, equipped and properly
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trained every six months. The RSO/Fire Chief works with the Safety Department and the Safety
Coordinator under 30 CFR 56.4330 Firefighting, evacuation, and rescue procedures.
In the absence of the RSO, the Mill Safety Coordinator will assume these duties. If the Safety
Coordinator is not present, those responsibilities fall to the next senior member of the Safety
Department. Scheduled time off at the Mill is worked around the RSO and Safety Coordinators
time off. Both individuals will not be given time off work at the same time, thereby ensuring
supervised coverage in the event of an emergency.
During an emergency situation, the Safety Coordinator will also be present and receive direction
from the RSO/Fire Chief as to how to proceed. If the RSO is present during the emergency, the
Safety Coordinator will act as the Assistant Fire Chief to free up the RSO' s time to deal with
radiation decontamination or other issues that may arise. If the RSO is not present the Safety
Coordinator will be the acting Fire Chief and the radiation designee will act as the Assistant Fire
Chief, but will only deal with radiation related issues.
c) Personnel Evacuation and Accountability
The Maintenance Supervisor will direct all personnel in evacuation and in activities to cope with
the emergency, including isolation of utilities and providing technical advice as needed. The
Maintenance Supervisor will be assisted by the Mill Safety Coordinator.
The Laboratory Supervisor has the responsibility to direct and account for all office persmmel
(including DUSA personnel and office visitors) in evacuation and in activities to cope with the
emergency. In case of a mill tour, the Supervisor accompanying the tour will be responsible for
evacuation of visitors.
The Scale house person on shift will be responsible to account for ore truck drivers and reagent
truck drivers.
The Mill's Emergency Evacuation and Shut-Down Procedure are outlined in Appendix J to this
Plan.
d) Search and Rescue Operations
The RSO will direct rescue operations and provide the necessary emergency medical personnel
and facilities to cope with the emergency.
e) First Aid
First aid will initially be the responsibility of the Safety Coordinator or a Safety Technician. If
the need for first aid is minimal, there may not be a need to require offsite assistance. However,
if there are any significant injuries, or there is a risk of any significant injuries, the Safety
Coordinator or a Safety Technician will have the responsibility of contacting offsite medical and
ambulance services for assistance.
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f) Communications
The Incident Commander will stop routine radio usage upon learning of an emergency and set up
the base station in a safe location for directing activities. Radio usage will be limited to the
emergency. The Incident Commander has the responsibility to contact all outside services.
g) Radiological Survey and Assessment (Onsite and Offsite)
On-site and offsite radiological surveys and assessments will be performed by one or more
Radiation Technician(s) under the direction of the RSO. The RSO may assist in performing any
such surveys.
The surveys and assessments that will be required will depend on the incident. In most cases,
radiological contamination resulting from the Mill would be expected to be limited and restricted
to the Mill site. In some cases, however, radiological contamination could be dispersed offsite.
The RSO will detennine what surveys and assessments are required in order to: a) determine to
what extent if any, radiological contamination has or could be dispersed offsite as a result of the
incident; and b) determine what surveys are necessary in the circumstances to assess any onsite
or offsite radiological contamination that may have resulted from the incident. In the absence of
the RSO, the Lead Radiation Technician will make these determinations.
The Mill has established an emergency call sheet that will be used in the event of an emergency
to alert all members of the department, whether on-site and on-duty or not. When an emergency
occurs, the RSO is notified first. If the RSO is not available, the Lead Radiation Technician is
notified. The on-shift Radiation Technicians notify the off-shift Radiation Technicians. All
Radiation Technicians are required to report to the site to assist in the emergency, unless advised
otherwise by the RSO. This ensures that there will be adequate Radiation Safety Staff available
for any emergency that may arise.
h) Personnel Decontamination
Personnel decontamination will be performed by Mill Radiation Technicians under the direction
of the RSO, or in the absence of the RSO, under the direction of the Lead Radiation Technician,
as needed.
i) Facility Decontamination
Facility decontamination will be performed by Mill operations personnel, maintenance personnel
and/or utility crew personnel under the direction of the Mill Manager, Mill Superintendent or
Maintenance Superintendent, to decontamination standards set by the RSO and monitored by
Radiation Safety Staff.
j) Facility Security and Access Control
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The Mill Superintendent, or in his absence a Mill Foreman, has the responsibility
of directing outside emergency personnel and has the responsibility for plant
security and will report directly to the Incident Commander.
k) Request Support from Offsite Agencies
During an emergency, the Incident Commander and/or the RSO/Fire Chief will coordinate that
the crew or team has the available members needed to respond to the emergency. After the team
or crew has responded and is in the process of handling the situation, the Incident Commander
and/or RSO/Fire Chief will then coordinate with the Radiation/Safety Departments to maintain
scene safety. Scene safety includes, but is not limited to, crowd control, outside emergency
assistance requests and any decontamination.
l) Post-Event Assessment
A post-event assessment of facility condition for future operations will be performed by the Mill
Manager, Mill Superintendent and/or Maintenance Superintendent. A post-event asses ment of
facilities for occupational safety will be performed by. the Safety Coordinator. A post-event
assessment of any on-site or offsite radiological contamination resulting from the incident will be
performed by lhe Radiation Safety Staff w1der the direction of the RSO.
m) Recordkeeping
The RSO will coordinate all record keeping relating to the incident and will be responsible for
the preparation of an incident report.
n) Media Contact
The Incident Commander, President and Chief Operating Officer or Executive Vice President,
US Operations of DUSA shall be the sole media contact in the event of an emergency at the Mill.
4.3 Local Offsite Assistance to Facility
Under a Letter of Agreement with the San Juan County Emergency Management Office, DUSA
will be assisted in the event of an emergency with all needed equipment and services at the
disposal of San Juan County. Local agencies have also volunteered services in the event of an
emergency. These local agencies are (see Section 4.4 below and Exhibit 1 for contact
information):
a) First Aid and Initial Medical Services
• Blanding Family Practice Medical Clinic -This facility is located approximately 8
miles north of the Mill in Blanding, Utah; and
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• Blanding Clinic-This facility is located approximately 11 miles north of the Mill in
Blanding, Utah.
b) Ambulance and Paramedic Services
• San Juan County Ambulance Service-This facility is located approximately 11 miles
north of the Mill in Blanding, Utah.
c) Fire Department
• Blanding City Fire Department-This agency is located approximately 9 miles north
of the Mill in Blanding, Utah. This agency is a volunteer fire department.
d) Law Enforcement
• Blanding City Police Department -This agency is located approximately 11 miles
nmth of the Mill in Blanding, Utah; and
• San Juan County Sheriff-This agency is located approximately 30 miles north of the
Mill in Monticello, Utah.
e) Highway Patrol
• Utah Highway Patrol-This agency is located approximately 30 miles north of the in
Monticello, Utah.
f) Hospitals
• San Juan County Hospital -This facility is located in Monticello, Utah,
approximately 33 miles north of the facility; and
• Blue Mountain Hospital -This facility is located approximately 8 miles north of the
facility in Blanding, Utah.
The Mill has provided a11 of the for~going facilities and agencies with Material Safety Data
Sheets (MSDS's) for any potential incident at the Mill. These are updated periodically by the
Mill. Also, each facility has an understanding with DUSA, that DUSA will perform all
radiological assessments and decontaminate any area or equipment that has been contaminated
during emergency activities.
Annual visits with each agency or facility are conducted to update and refresh the various
departments about potential emergencies that may be encountered. These visits are documented
and housed in the Safety Office at the Mill.
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Given that Mill personnel will be il'l attendance at any emergency situation, there is no need to
make any provisions to suspend security or safeguard measures for site access during an
emergency in order to accommodate any of the agencies referred to above.
4.4 Coordination with Participating Government Agencies
Below are listed the principal State agency and other government (local, county, State, and
Federal) agencies or organizations having responsibilities for radiological or other hazardous
material emergencies at the Mill:
• State of Utah, Division of Radiation Control.. ................. 801-536-4250
• NRC .............................................................. 301-951-0550
• MSHA Field Office--801-524-3450 District Office ........ 303-231-5465
• MSHA, Arlington ............................................................ 800-746-1553
• State Emergency Response Comm .................................. 801-538-3400
• State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
• National Response Center ................................................ 800-424-8802
• Utah Poison Control Center.-.-.•... -... .-........... -.-.,, .. -... -.-.............. -....... 800-456-7707
• Blanding City Fire Department .............................. Dial 911 or 678-2313
• Blanding City Police Department ........................ Dial911 or 678-2916 or 678-2334
• San Juan County Sheriff, Monticello, Utah ................. Dial 911 or 587-2237
• Utah Highway Patrol, Monticello, Utah .................... Dial911 or 587-2000
Mill persotmel meet annually with San Juan County Office of Emergency Management and Fire
Control and City of Blanding Fire Department to review items of mutual interest, including
relevant changes in this Plan. During those meetings Mill personnel discuss the Plan,
notification procedures, and overall response coordination, as necessary.
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5. EMERGENCY RESPONSE MEASURES
Reg. Guide 3.67 suggests that specific response measures should be identified for each class of
emergency and related to action levels or criteria that specify when the measures are to be
effected. However, rather than describe specific responses applicable to classes of emergencies,
this Plan describes the specific n.,sponse measures for each type of accident. Since the number of
different types of accidents that have been postulated for the Mill is relatively small, it was
concluded that this more direct approach is most appropriate for a facility such as the Mill.
There is no need to describe the specific actions and responses for each class of emergency when
the actual specific response measures can be described more directly for each accident.
Section 2.1 and Appendices A through I set out the specific response measures for each
postulated accident.
5.1 Activation of Emergency Response Organization
Activation of the Emergency Response Organization for each type of accident is set out in
Section 2.1 and the applicable Appendix A through I.
A contact list is maintained through the Mill Safety Department. All supervisors and key
personnel onsite have a copy of this contact list. The individuals listed are available at all times.
Blanding is a small town, and most of the individuals listed live within a short distance of the
Mill. In the event of an emergency during a non-working period, afternoon or night shift, or
during a period of limited Mill operations or other situation where there is a reduced staff at the
Mill, the Shift Forman or his supervisors, if on site, will initiate procedures. In addition, the
Radiation Safety Department has established an emergency call sheet that will require
notification throughout the department. When an emergency occurs, the RSO/Fire Chief is
notified and then the Shift Radiation Technicians notify the off shift Radiation Technicians. The
shift Radiation Technicians will maintain scene security until directed by the RSO to do
otherwise. When the off duty Radiation Technicians arrive, they will report immediately to the
RSO and receive their instructions.
5.2 Assessment Actions
For each type of emergency, the actions to be taken to determine the extent of the problem and to
decide what cotTective actions may be required are set out in Section 2.1 and the applicable
Appendix A through I. Where appropriate, Section 2.1 and the applicable Appendix describe the
types and methods of onsite and offsite sampling and monitoring that will be done in case of
release of radioactive or other hazardous material. To the extent not specifically addressed in
Section 2.1 or in Appendices A through I, Mill personnel will use procedures contained in
existing Mill Standard Operating Procedures.
5.3 Mitigating Actions
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The means and equipment provided for mitigating the consequences of each type of accident are
specified in Section 2.1 and Appendices A through I. To the extent applicable, these include the
mitigation of consequences to workers onsite as well as to the public offsite, as well as the
criteria that will be used to decide whether a single process or the entire facility will be shut
down.
The Mill's Emergency Evacuation and Shut Down Procedure is set out in Appendix J.
5.4 Protective Actions
The nature of onsite and offsite protective actions, the criteria for implementing those actions,
the areas involved, and the procedures for notification to affected persons are described in
Section 2.1 and Appendices A through I for each type of accident. In order to prevent or
minimize exposure to radiation, radioactive materials, and other hazardous materials, the
procedures specified in Section 2.1 and those Appendices provide for timely relocation of onsite
persons, timely recommendation of offsite actions, effective use of protective equipment and
supplies, and use of appropriate contamination control measures, a:Rpropriate for each specified
---·--c---•--- --•
type of accident. To the extent that any actions and equipment are described generally in Section
2.1 and those Appendices, Mill personnel will take actions and use equipment in accordance with
Mill Standard Operating Procedures.
5.4.1 Onsite Protective Actions
5.4.1.1 Personnel Evacuation and Accountability
For each type of accident, Section 2.1 and Appendices A through I include:
• Criteria for ordering an evacuation;
• The means and time required to notify persons involved;
• Evacuation routes, transpmtation of personnel;
• Locations of onsite and offsite assembly areas;
• Search and rescue;
• Monitoring of evacuees for contamination and control measures if contamination is
found;
• Criteria for command center and assembly area evacuation and reestablishment at
alternate location;
• Procedures for evacuating and treating injured personnel, including contaminated
personnel; and
• Provisions for determining and maintaining the accountability of assembled and
evacuated personnel.
5.4.1.2 Use ofProtective Equipment and Supplies
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Section 2.1 and Appendices A through I specify the required protective equipment and supplies,
to the extent not already covered by Mill Standard Operating Procedures. To the extent that
Section 2.1 and Appendices A through I do not specify protective equipment and supplies, then
protective equipment and supplies normally required or available under existing Mill Standard
Operating Procedures for the required procedure or activity will apply.
In addition to normal supplies of equipment at the Mill, such as respirators, protective clothing
etc., the Mill maintains supplies of specialized equipment in certain locations for use in
emergency situations as follows:
a) Fire Hose
Fire hose cabinets are located at the following sites with a minimum of 300 feet of 2-1/2" hose,
two spanner wrenches, spray nozzles and one hydrant wrench:
• South of SX;
• WestofCCD;
• North of mill building;
• East of pulp storage tanks;
• Northwest of Maintenance Shop;
• West of Warehouse; and
• East of office building.
b) Self Contained Breathing Apparatus
Two Self-Contained Breathing Apparatus (SCBA) units are located at each of the following
locations:
• Hose station east of office building;
• Hose Station South of SX;
• North End SX Outside Wall; and
• North end of mill building, outside wall.
c) Spill Clean-up Equipment
Barrels of soda ash are located throughout the Mill to be used in case of a chemical spill. Soda
ash is also stored in bulk if needed. There are also a few drums of absorbent stored near the
laboratory. The laboratory also contains acid spill kits and absorbent materials to be used in case
of a spill.
d) Fire Fighting PPE
.. ;
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Two complete sets of turnout gear for firefighting and/or emergency extrication are located in the
Fire Hose Station located on the east side of the office building.
e) Maintenance of Emergency Equipment
Fire extinguishers are inspected on an annual basis, as well as the fire pump system. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. (Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.)
5.4.1.3 Contamination Control Measures
Because of the nature of potential accidents that can occur at uranium mills, it is unlikely that an
accident would result in a significant risk of overexposure to any workers or members of the
public (see the conclusions of NRC staff in NUREG-1140 discussed in section 2.1.6 above).
Therefore the Mill's existing Standard Operating Procedures are considered adequate for
preventing further spread of radioactive materials and for minimizing radiation exposures from
radioactive materials that could be unshielded or released by abnormal conditions. Section 2.1
and Appendices A through I describe isolation, area access control, and application of criteria for
permitting return to normal use to the extent necessary and not otherwise covered by existing
Standard Operating Procedures for the types of accidents that could occur at the Mill.
5.4.2 Offsite Protective Actions
Section 2.1 and Appendices A through I describe the conditions that would require protective
actions offsite for the various types of accidents, and describe the protective action
recommendations that would be made to offsite authorities, when each recommendation would
be made, and what area offsite would be affected.
5.5 Exposure Control in Radiological Emergencies
Given the radioactive materials found at the Mill and the types of postulated accidents, it is not
likely that Mill personnel or offsite workers would be exposed to levels of radiation that cannot
be adequately addressed under existing Mill Standard Operating Procedures.
5.5.1 Emergency Radiation Exposure Control Program
5.5.1.1 Radiation Protection Program
During the emergency situation, the Radiation Protection Manual, SOP Book 9, will be the guide
for all decontamination and exposure monitoring.
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The Mill's RSO will be responsible for the determination of exposures to be allowed during the
event of an emergency situation. This includes the unlikely event of authorizing workers to
receive emergency doses and for permitting onsite volunteers to receive radiation doses in the
course of carrying out lifesaving and other emergency activities.
5.5.1.2 Exposure Guidelines
The onsite exposure guidelines to be used for all postulated accidents, including actions to
control fires, stop releases or protect facilities will be those set out in UAC R313-15 and the
Mill's Radiation Protection Manual. These exposure guidelines will also apply to
• Removing injured persons;
• Undertaking mitigating actions;
• Providing onsite first aid;
• Performing personnel decontamination;
• Providing ambulance service; and
• Providing offsite medical treatment.
5.5.1.3 Monitoring
DUSA will provide all needed instrumentation for determining doses received by individuals
during all emergency situations. DUSA will also provide OSL badge monitoring to those
emergency response individuals during situations that may require extended periods of exposure
to high radiation areas.
In the event of an accident, such as an accident that involved the dispersion of yellowcake, or a
fire in the SX building or elsewhere on the facility that could involve the dispersion of
radioactive materials, breathing zone samples will be taken if practicable in the circumstances.
Emergency personal who must wear respiratory devices, must have their own devices. DUSA
will not furnish these devices.
Radiation safety personnel will also monitor various areas of the facility occupied by emergency
personnel, to the extent practicable.
Records of dose and dose commitments will be maintained for Mill personnel and offsite support
organization's emergency workers involved in the accident.
5. 5 .1.4 Decontamination of Personnel
Any emergency response equipment that enters the Mill's Restricted Area in response to an
incident will be scanned and decontaminated prior to leaving the site according to the
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requirements found in Table 1 of the 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.
Any personnel leaving the Mill's restricted area, or otherwise exposed to radiation from the
incident, will be scanned and decontaminated in accordance with the procedures set out in the
Mill's Radiation Protection Manual for personnel leaving the Mill's restricted area.
Injured personnel will be evaluated for radiation contamination at the earliest convenience, if
there is a potential for contamination. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
carmot be decontaminated, the clinic/hospital personnel will be notified in advance. Mill
radiation safety personnel will be available to provide health physics support clinic/hospital
personnel.
5.6 Medical Transportation
One fur1y-equipped First Responder Unit (Ambulance) is located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
All transportation vehicles will be surveyed and decontaminated by the Radiation Department at
the Mill. Any emergency response equipment or personnel that enters the Re tricted Area in
response to an incident will be scanned and decontaminated prior to leaving the site according to
the requirements found in Table 1 of the NRC's Policy and Guidance Directive FC-85-23,
Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unre tricted
Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material" issued May
1987. If any injured personnel who may also be radiologically contaminated, will be transported
to medical treatment facilities, the inside of the transport vehicle will also be scanned and
decontaminated in accordance with the foregoing Guidance.
Injured personnel will be evaluated for radiation contamination, jf there was a potential for
contamination, at the earliest convenience. Should it be necessary, contaminated articles will be
gathered by the radiological staff after medical treatment has been rendered. If the personnel
cannot be decontaminated, clinic/hospital personnel will be notified in advance.
5. 7 Medical Treatment
All medical facilities will be made aware of potential radiological and chemical hazards
associated with the postulated accidents described in Section 2.1. St. Mary's hospital in Grand
Junction, Colorado, approximately 3 hours drive by highway, is the nearest trauma center.
Specialized medical attention for radioactive contamination or chemical exposure would be
Book.4tl6 DENISON MTNES (1JSA) CORP.
Rev. No.: R-2.1 STANDARD O.PBRATINO PROCEDURES Page47 of
Date: Augusl 18, 2009 Title: White· Mesa Mill EnrergenGy RGSpcmse Plan 111
located eil'her in Salt Lake City at the University 0f Utah Medical Center (appreximateJy 5 hours
drive by highway), or in Denver, Colorado (approximately 7 hours drive by highway).
All facilitie!S are awar~ that DlJ.SA will take responsibility for tire mouit<i>ring and potential
·tteconttu:tiltiati6i'L&f all !atilli~es :ctm~ammat¢d during these emergencies. The Mill will provide
a.mbula;n:oe: and 'h~$p;l:~1 p~'®rnJ.el with· . .kealth physics support if needed.
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 48 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
6. EMERGENCY RESPONSE EQUIPMENT AND FACILITIES
6.1 Command Center
When the evacuation alarm sounds or when personnel are verbally notified by radio or other
means, all personnel will assemble at:
• The parking lot south of the office;
• The Scalehouse;
• North side of Tailings Cell 1; or
• North of the Mill.
The assembly site will depend upon conditions, i.e. nature of the emergency, wind conditions,
etc. The Incident Commander, RSO/Fire Chief or Shift Foreman will specify the appropriate
assembly site.
The Mill does not have a specific communication or assessment center. Key personnel are
equipped with handheld VHF transceivers, which will serve as the primary means of
communication while personnel are assembling to the designated relocation areas and as needed
thereafter to deal with the emergency. The relocation an~a will , erve as the initial assessment
center. Other communications and assessment centers will be set up in the Mill's office
building, Scalehouse, Warehouse or other areas of the Mill that have communication capability,
as needed depending on the nature and location of the emergency.
6.2 Communications Equipment
6.2.1 Onsite Communications
Employees will be notified to evacuate the area by dialing 184 on any area telephone and
announcing that the Mill should be evacuated. This announcement will be repeated three times.
When the paging system cycles through, the evacuation siren (continuous frequency) will
automatically sound for approximately forty-five seconds, and then automatically shut off,
allowing cominw1ications by radio from that point. If the 184 number is dialed accidentally the
evacuation alarm may be canceled by disconnecting the phone until the page cycle ends, then re-
dial184. (See Exhibits 1 and 2.).
The primary onsite communications will be by radio throughout the course of the emergency and
the subsequent recovery. Onsite communication by radio is the typical day-to-day manner of
communication within the Mill facility, and is pmformed by individual hand held VHF
transceivers. There is no central relay or similar system that could be disabled in the event of an
emergency. As a result, there is no need to provide for an alternative onsite communication
system or perform operational tests of that communications system.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 49 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
6.2.2 Offsite Communications
During an emergency situation, DUSA's onsite ambulance is equipped with a radio to
communicate with the San Juan County Dispatch. This service provides a backup means of
offsite communication, other than commercial telephone, and will allow the Mill to be in
communication with all emergency response services.
Operational tests are conducted on this system periodically during the normal weekly operational
checks of the onsite ambulance.
6.3 Onsite Medical Facilities
The Mill maintains medical supplies at the site for typical occupational injuries as required by
MSHA.
One fully-equipped First Responder Unit (Ambulance) is located west of the office building.
Other motor pool vehicles on the property will be utilized as needed in emergency situations
with support as needed from the local Emergency Medical Services.
Given the types of accidents identified, it is unlikely that any personnel would require
contamination control over and above the controls set out in the Mill's Radiation Protection
Manual, which would be applied to injured personnel. If it is not possible or there is not
sufficient time to decontaminate individuals, then advance notice will be applied to offsite
medical personnel and facilities. In addition, Mill pers01mel will be available to provide health
physics assistance to such medical personnel if necessary.
6.4 Emergency Monitoring Equipment
The monitoring equipment used on a day-to-day ba is by the Radiation Safety Department will
be available to monitor personnel and petform area monitoring, as well as to assess the release of
radioactive materials to the environment. As discussed in Section 2.1.6 above, none of the
po ·tulated accidents described in Section 2.1 above is expected to release significant quantities
of radionuclides into the environment. The greatest risk of that would be a fire in the solvent
extraction building, but, as NRC concluded in NUREG-1140 the potential for overexposures
offsite would not be significant. Mill personnel will monitor to assess the magnitude and
dispersion of any releases after the fact by use of hand held gamma meters in the areas offsite
that could have been impacted. The existing high volume particulate stations will also provide
some information on the magnitude and dispersion of any such releases.
Onsite area monitoring and personnel scanning will be performed by use of existing monitoring
equipment, which is located in the Radiation Safety Department. This is considered to be as
Book 4116 DBNfSON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 50 of
Date: August 18, 2009 Titlo: White Mesil Mill Emergency Response Plnn Ill
"non-hazardous" a location as possible atlhe ~;ite, because it is not located particularly close to
any locations that could involve one of the postulated accidents.
Mill Radiation Safety Staff will usc dragger lubes primarily to detect dangerous levels of
anhyd rous nmmonia and propane and other chemically toxic materials. If necessary, monitoring
personnel wi ll be equipped with SCBA respimtory protection while performing such monilori.ng.
; :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 51 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7. MAINTAINING EMERGENCY PREPAREDNESS CAPABILITY
7.1 Written Emergency Plan Procedures
This Plan will be reviewed annually by the RSO and, if required, updated by the ALARA
Committee. The SERP Committee will then validate all changes that are being requested before
such changes will be implemented into a new revision of this Plan.
After final SERP approval, changes will be updated to the Document Control System. The
Document Control supervisor will update this Plan and then amend all current copies of the Plan
to the recipients listed on the Distribution List at the beginning of this document.
7.2 Training
Semi-annual training for the emergency response teams will be conducted. This training will
include, but not be limited to, fire suppression, emergency medical services, evacuation under
hazardous atmosphere conditions, search and rescue, proper PPE usage during each potential
emergency situation and radiological contamination surveying onsite and offsite.
Each member of the emergency response team will be assigned his or her tasks and trained in
detail about those tasks. The Radiation Staff will be trained in the proper decontamination of
personnel, PPE and potentially offsite medical facilities.
All employees onsite will be trained in the use of respiratory protection and on radiological
hazards during their normal monthly safety meetings and as needed during special radiation
training sessions as processes change at the facility.
Because appropriately trained Mill personnel will be in attendance at the Mill to accompany any
offsite emergency response personnel, there is no need to provide periodic orientation tours of
the facility to such personnel.
7.3 Drills and Exercises
Quarterly drills, as required by MSHA, are conducted by the Safety and Radiation Departments
to monitor performance of personnel responding to emergency situations. Each drill is enacted
upon one or more of the potential emergencies contemplated by this Plan. The drill and
evacuation activities are documented by the Mill's Safety Coordinator and maintained within
plant files. Management reviews all drills at quarterly ALARA Committee Meetings.
Because the impacts associated with most types of emergencies that could occur at the Mill are
limited to the Mill site itself, and the risks to the public are very low, offsite agencies are not
typically invited to participate in any drills or exercises at the Mill.
Book#16 ·DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 52 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7.3.1 Biennial Exercises
Training exercises will be held every two years with the potential offsite emergency responders.
These exercises consist of training and information pertaining to the operational activities at the
time.
7.3.2 Qual"terly Communications Checks
Quru.1erly communication checks with all potential offsite emergency responders will be
performed. The communication checks will be documented and housed in the Safety
Department records. These checks will update any changes to contact information for needed
parties.
Emergency response groups that are required to be contacted are:
• Blanding Police Department;
• Blanding City Fire Department;
• San Jua:o County Sheriff;
• San Juan County EMS;
• All local medical clinics and or hospitals; and
• Utah Highway Patrol
7.4 Critiques
This Plan is subject to audit by the ALARA audit team (see Section 7.5 below), and the periodic
drills and exercises referred to in Section 7.3 above are subject to review periodically by the
Mill's ALARA Committee. Given the nature of the potential incidents that could occur at the
Mill and the low risk to the public relative to incidents that could occur at other types of
facilities, such as nuclear power reactors, the Mill does not require that a critique be prepared for
each drill and exercise by one or more of the nonparticipating observers, other than the audits
and reviews conducted by the ALARA Audit Committee and the ALARA Committee.
7.5 Independent Audit
This Plan, including all procedures, training activities, emergency facilities, equipment, and
supplies, and records associated with offsitc snpport agency interface, described therein, is
subject to annual review by the Mill's ALARA audit team. The Mill's ALARA audit team is
comprised of DUSA corporate environmental and safety personnel who do not have direct
responsibilities for implementing the emergency response program, as well as an independent
outside consultant with expertise in environmental and radiation safety matters.
Any recommendations or deficiencies observed by the ALARA audit team will be presented to
the ALARA Committee for consideration typically within approximately 60 days after the audit
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 53 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
has been completed. Decisions by the Mill's ALARA Committee to make any changes to this
Plan will be submitted to the Mill's SERP for implementation. Any changes in plant layout,
process or facilities are included in the types of changes that will be reviewed and could warrant
revision to this Plan.
7.6 Maintenance and Inventory of Emergency Equipment, Instrumentation and
Supplies
Fire extinguishers, as well as the fire pump system, are inspected on an annual basis. The Mill
Safety Coordinator performs regular spot checks on the emergency equipment locations to
ensure that all of the equipment is in place. Extinguishers are serviced on an annual basis and
then checked monthly to make sure units are still charged. The SCBA units are also checked
monthly and then pressure tested every five years.
7.7 Letters of Agreement
Any changes to this Plan that would impact the actions of any offsite response organizations will
be communicated to such organizations. The Mill will review all letters of agreement with
offsite agencies periodically to ensure that they are kept up to date and in force.
;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 54 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
8. RECORDS AND REPORTS
8.1 Records of Incidents
A written report will be prepared for all incidents of abnormal operation, equipment failure and
accidents that led to a plant emergency that is classified as an Alert or Site Area Emergency.
The report will include the cause of the incident, persom1el and equipment involved, extent of
injury and damage (onsite and offsite) resulting from the incident, all locations of contamination
with the final decontamination survey results, corrective actions taken to terminate the
emergency, and the action taken or planned to prevent a recurrence of the incident. The report
will also include the onsite and offsite support assistance requested and received, as well as any
program changes resulting from the lessons learned from any critique of emergency response
activities.
All such reports unique to a radiological emergency, not covered by existing regulations or
License conditions will be retained until the License is terminated.
The foregoing reports will be prepared under the direction of the RSO, and will be maintained in
the Mill's files for inspection.
8.2 Records of Preparedness Assurance
Records will be maintained in accordance with all MSHA, State of Utah and ALARA criteria.
These documents will be available on site and housed in the Safety Department for review.
: :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 55 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
9. RECOVERY AND PLANT RESTORATION
The Incident Commander will make the determination as to when the facility has been restored
to safe status. In making this determination, the Incident Commander will:
i) Assess the damage to and the status of the facility's capabilities to control radioactive
materials and hazardous materials. Specifically, the Incident Commander must be
satisfied that all safety-related equipment required for safe occupation and use of the
facility, in those areas to be occupied and used (e.g., radiation monitoring
instruments, respiratory protection equipment, fire-suppression and fire-fighting
equipment, containments, and air filters) have been checked and restored to normal
operations. The Incident Commander will be assisted by the RSO, the Safety
Coordinator and the Maintenance Supervisor or Maintenance Forman in making these
determinations; and
ii) Determine the actions necessary to reduce any ongoing releases of radioactive or
other hazardous material and to prevent further incidents. The Incident Commander
will be assisted by the RSO, the Safety Coordinator and the Maintenance Supervisor
or Maintenance Forman in making these determinations.
The Incident Commander will direct the resources and personnel required in order to accomplish
the tasks to meet any required restoration action. During any planned restoration operations,
personnel exposures to radiation will be maintained within UAC R313-15limits and as low as is
reasonably achievable.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 56 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
10. COMPLIANCE WITH COMMUNITY RIGHT-TO-KNOW ACT AND CLEAN
AIR ACT
10.1 Community Right to Know Act
Section 11002 and 11004 of the Emergency Response and Community Right to Know Act
("EPCRA") of 1986; 42 U.S.C. 11001 et seq., requires that notice be given to the community
emergency response coordinator for the local emergency planning committee in the event of a
release of an extremely hazardous substance offsite. This requirement does not apply to any
release which results in exposure to persons solely within the sites or sites within which the
facility is located.
The Mill maintains inventories of two extremely hazardous substances: anhydrous ammonia and
propane. Mill personnel are required to provide notice to the community response coordinator
for the local emergency planning committee in the event of an offsite release of either of those
two substances. See Sections 2.1.1, 2.1.2 and 2.1.3 above and Appendices A, Band C.
10.2 Clean Air Act
When Congress passed the Clean Air Act Amendments of 1990, Section 112r required EPA to
publish regulations and guidance for chemical accident prevention at facilities using substances
that posed the greatest risk of harm from accidental releases. These regulations require facilities
such as the Mill that use, store or otherwise handle a threshold quantity of certain listed regulated
flammable and toxic substances to develop a Risk Management Program.
The Mill uses, stores and handles threshold quantities of two substances listed under the
regulations promulgated under Section 112r of the Clean Air Act: anhydrous ammonia and
propane, and has submitted to EPA a Risk Management Program for those two substances. A
copy of that Risk Management Program is attached as Appendix K to this Plan.
Book#16
Rev. No.: R-2.1
Date: August 18, 2009
:
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mili Emergency Response Plan
EXHIBIT 1
ElVIERGENCY NOTIFICATION LIST
ATTEND TO ANY INJURED PERSONS AND NOTIFY THE SUPERVISOR:
Give artificial respiration if necessary.
Control bleeding.
Treat for shock.
Immobilize fractures and stabilize for transportation.
Scan the injured person for excessive alpha prior to transporting if time allows.
Page 57 of
111
(If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office).
Pe1form other first aid as more specifically described in Section 2.1 or Appendices A
through I for the specific types of accidents and resulting injuries
THE INCIDENT COMMANDER OR HIS DESIGNEE WILL NOTIFY THE FOLLOWING
AS NEEDED:
Blanding Clinic ............................ 678-2254 or 678-3434 (930 N. 400 W.)
Blue Mountain Hospital, Blanding ... 678-3993 (802 S. 200 W.)
San Juan Hospital, Monticello ..... 678-2830 or 587-2116 (364 W. 1st N.)
EMT TRAINED -The following personnel should be contacted, if they are on-site, in the event
of an emergency to aid in the event of any injuries to personnel.
David Turk
AMBULANCE SERVICE
Blanding ....................................... Dial 911
If the Company Ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
OTHER EMERGENCY NUMBERS
Fire Department ........................... Dial911 or 678-2313
County Sheriff .............................. Dial911 or 587-2237
Highway Patrol ............................ Dial 911 or 587-2000
Blanding Police ............................ Dial 911, 678-2916 or 678-2334
MANAGERS
The Supervisor will notify one of the following of all incidents:
R.E. Bartlett ................................. 435-678-2495 or 435-979-3893
D. Turk ......................................... 435-678-7802 or 435-459-9786
R. Wallace ........................... .435-459-1093
Book#t6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 58 of
Date: August 18, 2009 Title: While Mesa Mill Emergency Response Plan 111
A MEMBER OF MANAGEMENT WILL NOTIFY THE PROPER REGULATING
AGENCIES AS REQUIRED F"()R EACH INCIDENT (SEE SECTION 2.1 AND
APPENDICES A THROUGH I):
State of Utah, Division of Radiation Cont1'0l. .................. 801-536-4250
MSrlAField Office--801-524-3450 District Office ........ 303-231-5465
MSHA, Arlington ............................................................ 800-746-1553
State Emergency Response Comm .................................. 801-538-3400
State of Utah, Natural Resources, Dam Safety ................ 801-538-7200
National Response Center ................................................ S00-424-8802
Utah Poison Control Center ............................................. 800-456-7707
Notification of surrounding communities and or residences will be handled by the appropriate
agencies as required by EPCRA (Emergency Planning and Community Right to Know Act). See
Section 2.1 and Appendices A through I.
Book #16
Rev. No.: R-2.1
Date: August 18, 2009
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: White Mesa Mill Emergency Response Plan
EXHIBIT2
INTERNAL NOTIFICATIONS
;
Page 59 of
111
Internal reporting requirements for Incidents, Spills and Significant Events are as follows: (see
Section 2.1 of the Plan and Appendices A through I for more specific internal notification
requirements that may apply to each type of emergency situation):
Report Immediately:
Event Criteria:
Release of toxic or hazardous substances.
Fire, explosions or other accidents.
Government investigations information, requests or enforcement actions.
Private actions or claims (corporations or employees).
Deviations from Corporate policies or government requirements by Management.
Other significant events, which have resulted or could result in:
Death, serious injury or adverse health effect (employees or public).
Property damage exceeding $1,000,000.
Government investigation or enforcement action -limiting operation or penalties
of $100,000 or more.
Significant criminal actions.
Substantial media coverage.
Unscheduled down time of more than 24 hours.
Report at the Beginning of the Next Business Day:
Incident Criteria:
Was reported to a government agency as required by law.
Worker (DUSA or contractor) recordable injury or illness associated with a
release.
Community impact-reported or awareness.
Publicity resulted or is anticipated.
Release of 5,000 pounds or more of process material, waste or product.
The local manager in charge is to call Harold Roberts, Ron Hochstein or David Frydenlund.
Harold Roberts (Executive Vice President) ........... .303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
Ron Hochstein (President/CEO) ................................ 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
Book 4~16 DENISON MINES (US!\) CORP.
Rev. N0.: R-2.1 S'f.ANDARD .OPERATING PROCEDURES
Date: Augusl 18, 2.009 Title: White MesH Mil.l Emergency Response Plan
l)a.vi4:FryitW.W1d (Vice President) ............................. 303-628-7798 (offic_e)
303-221-009.8 (home)
303-808-6.648 (cell)
Page ClO of
111
Booldt16 ))ENISON M.CNES (tTSA) CORP.
Rev . N0.: R-2.1 STANDARD OPERATING PROCEDURES Page 61 of
Dale: August l8, 2009 Title: White Mesa Mill Emergency Response Plan lll
EXlDBIT3
SITE LAYOUT MAP
-_,.. -• • _...,. •• --... vv ... VVCI .... .,U
a
!
J
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPilR/\TfNG PROCEDURES Page62 of
DaLe: Augusll8, 2009 Title: While Mesa Mill Emergency Response Plan Jll
EXHIBIT4
GENERAL AREA MAP
.·
(
(
International Uranium (USA) Corporation
ProJect WHITE MESA MILL
e: UT
Figure 3.2 - 1
White Mesa Mill
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page63 of
'• Date: August 18,2009 Title: White Mesa Mill Emergency Response Plan llJ
EXHIDITS
DRAINAGE MAP
·.
fi 1 USGS GAUGE NO. 09376900
e 2 USGS GAUGE NO. 09378630
~ 3 USGS GAUGE NO. 09378700
lntemational Uranium (USA) Corporation
ProJoat WHITE MESA MILL
Date
o: liT
Figure 3. 7 -1
Drainage Map of the Vicinity
of the White Mesa Mill
Book4/!.l6
Rev. N0.: R~2.1
Date: August 18, 2009
DENISON MINES (USA) CURP.
STANDARD OPERATING PROCEDURES
Title: White Mesa MiU Emergency Response Plnn
EXHIBITk)
POPutATION CENTERS MAP
Page 64 of
111
(
(
:. . \ t'} \1 I ,. ..
\ I L-" .. · .. \:j
i.. I it
/ ..
)
\
I
I ._,
l
I I
I
l.l BLAND N.}
l 3162 (CITY) K\
l /\ r ·) \t 250 ('SUlm! ~\P.)D 'G) l {_\....1.,1 .) t ):'!./• ( ~ u i
: -~ :~.-• 1
1.1' f i r;
t ~ : ' • 1 ~----~----+---r4~~-----r----i-~·~,(~·~-t"----r----, ( i ~ \( ./ \~. ) \1\ ~:j
(
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1
) I j)J ) I !)' ·~ \ '·.· ~f.: t-·.1 I .L.l"_: _;,.' I i . \·~f\1.,?
': 1.,._, ( ( \~ ffJ '{ ~ M SX) ':
t ( ··f _f:~ / ,, ~"·: ~> ••. ..... \ l L ·'
/ ' I ! '
\":>0.'\ f ( ..
'
0
SCALE
l 2
PROPERTY BOUNDARY
RESERVAnONBOUNDARY ·· .... · .... · ··· CANYON RIM
International Uranium (USA) Corpora1Jon
PrOfed WHITE MESA MILL
UT
Figure 3.8 • 1
Population In The
Project VIcinity • 2000 Census
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 65 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response P lan 111
EXHIBIT 7
MAIN SHUT-OFF VALVES
During an emergency this list should be used along with Site Layout Map (Exhibit 3) to locate
tanks and valves associated with these tanks.
REAGENT SHUT-OFF VALVE LOCATIONS
Sulfuric Acid
4" Main located south side of acid tank
East acid pump discharge valve
West acid pump discharge valve
3" Main (leach area) located 25 feet west of Derrick screens next to walkway
1-1/2" Main (SX area) located south of Central Control room
Ammonia
4" Main (east tank) located on end at bottom
4" Main (west tank) located on end at bottom
2" Valve located on top of tank (east tank)
2" Valve located on top of tank (west tank)
Kerosene
2" Main valve located at bottom of tank (east tank)
2" Main valve located at bottom of tank (north tank)
2" Main valve located at bottom of tank (south tank)
Pump discharge 2" valve
Soda Ash
Main valve located at bottom of tank (dry storage)
4" Main valve located at bottom of tank on 30% dilution tank
4" Main valve locate at bottom of tank on dilution tank
Book4tl6 DENISON MINES (tJSA) CQRP.
Rev. No.: R-2.1 STANDARD OPERATlNG PROCEDURES Page 66 of
Dale: Aug~rsl J 8, 2009 Title: While Mesa Mill Emergency Response. Plnn lll
')~' Mrdu Y.~~ located~. bottom::ol:~
Caustic Soda
l'' Mi!fl::\t'ti;l~' l~~~·At boltom·::aftank.: east and w.~ between supporLs
Book #16 DENISON M1NBS (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 67 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
Sodium Chlorate
3" Main valve located at bottom of tank (cast tank)
3" Main valve located at bottom of tank (norlh tank)
3" Main valve located at bottom of tank (south tank)
Propane
4" Main located 15 feet east of tank
3" Main located on pipe off top of tank
3" Main located at bottom of tank (also fill pipe)
PLANT UTILITY SHUT-OFF VALVE LOCATIONS
Process Water
Main valve located on west side of water storage tank
Discharge valve off service water pump east
Discharge valve off service water pump west
Mill process water main located east wall by SAG mill
Fire Water
Main valve located west side of water storage tank
Emergency fire pump discharge valve to fire system
Emergency fire pump discharge valve to header west side of pump house
8" Mrun valve located south of Central Control room for SX and boilers
Potable Water
2" Main (suction) from potable water storage tank
2'' Main (discharge) from potable water storage tank
4" Main located at east wall by SAG mill
4" Main located south of Central Control room for SX, Maintenance shop, and offices
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERA TIN'G PROCEDURES Page 68 of
Date: August l8, 2009 Title: White Mesa Mill Emergency Response Plan ill
Steam
Main discharge valve for Superior boiler located at top of boiler
Main steam valve located south side of boiler house
Plant Air
Main valve located atieceiver tank in compressor room at boiler house
Main valve to mill building located south of Centnl Control room
PROCESS SHUT-OFF VALVE LOCATIONS
Pulp Storage
No. 1 valve located on west side of tank
No.3 valve located on west side of tank
Pre-leach (old No.2 pulp storage) valve located on west side of tank
Pre-leach Thickener
Main valve located undemeath at center cone
Clarifier
Main valve located underneath at center cone
Main valve located underneath at center cone
CCD Thickeners
Main valve located underneath at center cone of each thickener
; ;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 69 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIX A
EMrnRGENCYRESPONSEPROCEDUREFOR A RELEASE OF ANHYDROUS
AMMONIA
(See also Section 2.1.1 of the Emergency Response Plan)
The following steps will be followed for an uncontrolled release of anhydrous ammonia. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The fucident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AM:MONIA CAN CAUSE INCAPACITATION,
SERIOUS INJURY AND DEATH.
1. A release of anhydrous ammonia would most likely occur suddenly. The person who would first
witness the release should immediately contact his or her supervisor who would activate the
evacuation alarm by using the "dial 184" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the spill, and account for all
personnel, including all contractors and visitors at the Mill and all ore, product and reagent truck
drivers, in accordance with the Emergency Evacuation and Shutdown Procedure described in
Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, Anhydrous ammonia has an ID No. of 1005 and is covered by
Guide No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 70 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
7. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water
• In case of contact with substance, immediately flush skin or eyes with running water for at
least 20 minutes;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any.fraGtures and stabilize for-transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet.
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
8. Initiate necessary steps to contain and/or neutralize the release, such as spraying with water fog,
turning off valves, etc.
• See Material Safety Data Sheet attached to this Appendix; and
• See Exhibit 7 for a list and locations of main shut-off valves.
9. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas.
:
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 71 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
10. If the incident involves an uncontrolled release of greater than 100 lbs (19 gallons) of anhydrous
ammonia, the incident is classified as a Site Area -Emergency and could pose a hazard to the
public. If the incident involves an uncontrolled release of between 36 lbs (7 gallons) and 100 lbs
of anhydrous ammonia, it is classified as an Alert. In either case, notify the community
emergency response coordinator for the local emergency planning committee as soon as possible
(within 15 minutes after declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
In its notificalions to the foregoing offsite official , the MiU pers01mel making the notification
should ad vise of the expected quantity of anhydrous ammonia released and provide the Mill's
initial recommendation for offsite protective actions, which are that the offsite response
authorities should follow the recommendations for releases of anhydrous ammonia contained in
the DOT Guidebook. ln the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005 and is
covered by Guide No. 125. Initial isolation and protective action distances are set out in Table 1
to the DOT Guidebook. Copies of the relevant portions of the Guidebook are attached to this
Appendix. An uncontrolled release of the contents of one of the anhydrou ammonia tanks at the
Mill would be similar to an uncontrolled release from a rail car or tanker truck and would be
considered to be a "large pill" tmder Table 1 of the DOT Guidebook. The foregoing offsite
officials hould also be advised of the conclu ions of the Mill s Risk Management Plan, attached
hereto as Appendix K, as itielates to anhydrous ammonia.
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 72 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
11.1£ the incident involves an Qncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Radiation Control (801-536-4250)
immediately after notification of offsite authorities, and in any event within one hour after
declaration of the emergency, if possible. This immediate notification is required because an
uncontrolled release of anhydrous ammonia of greater than 36 lbs (7 gallons) and 100 pounds is
classified as an Alert and a release of greater thanlOO pounds is classified as a Site Area
Emergency.
12. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
13. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediate! y.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
· 604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
14. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention to
low points. The RSO or Safety Coordinator will make a determination if it is safe for personnel
to re-enter the facility or any portion of the facility or whether or not any portion of the facility
must remain shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode.
16. Notification of Regulatory Agencies:
Book#l6 DENISON MINDS (USA) CORP.
Rev. No.: R-2. L STANDARD OPERATING PROCBDUHI!S Page 73 of
Dale: August 18, 2009 'Tttle; Whftc Mesa.·Mtu Bmet·gency Response Plan Ill
A membe1· of Mill management or Corporate management will notify the foJlowing regulating
agencies as indicated below:
• Report to MSHA
Any release of anhydrous ammonia at the Mill fitcility must be reported within 15' minutes to the
MSHA -1-800-746-1553.
17. Written Reports
The RSO will prepare a written report of the incident for Mill files, containing the in[orm:ation set
out in Section 8.1 of the Plan.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 74 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXB
E:MERGENCY RESPONSE PROCEDURE FOR AN AMMONIA EXPLOSION IN A
BUILDING
(See also Section 2.1.2 of the Emergency Response Plan)
The following steps will be followed in the event of an ammonia explosion in a building. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
CAUTION: INHALATION OF ANYDROUS AMMONIA CAN CAUSE INCAPACITATION,
SERIOUS INJURY AND DEATH.
1. An ammonia explosion would most likely occur suddenly. The person who would first witness
the explosion should immediately contact his or her supervisor who would activate the evacuation
alarm by us-ing the "dial 1-84" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the impacted area, and account
for all personnel, including all contractors and visitors at the Mill and all ore, product and reagent
truck drivers, in accordance with the Emergency Evacuation and Shutdown Procedure described
in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, anhydrous ammonia has an ID No. of 1005 and is covered by Guide
No. 125. A copy of Guide 125 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped as a result of the explosion; do this
only with properly trained and equipped personnel.
7. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas.
: :
Book#l6 DENISON MlNES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 75 of
Date: August 18, 2009 Title: White Mesa M ill Emergency Response Plan 111
8. In the event of fire, follow procedures set out on Guide No. 125. If the fire is in the SX Building,
follow the procedures in Appendix E in addition to the procedures in this Appendix.
9. Isolate utility lines affected by the fire.
10. Extinguish the fire and post a fire watch for flare-ups.
11. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of contact with substance, immediately flush skin or eyes with running water for at
least 20 minutes;
• In case of bums, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• Keep victim warm and quiet;
• Keep victim under observation. Effects of contact or inhalation may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 76 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. Initiate necessary steps to contain and/or neutralize the release of ammonia that caused the
explosion, such as spraying with water fog, turning off valves, etc.
• See Material Safety Data Sheet attached to this Appendix; and
• See Exhibit 7 for a list and locations of the main shut-off valves.
15. If the incident involves an unconb:olled release of greater than 00 lbs (19 gallons) of anhydrous
ammonia, the jncident is classified as a Site Area Emergency and could pose a hazard to the
public. If the incident involves an uncontrolled release of between 36 lbs (7 gallons) and 100 lbs
of anhydrous ammonia, it is classified as an Alert. In either case, notify the community
emergency response coordinator for the local emergency planning committee as soon as possible
(within 15 minutes of declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of anhydrous ammonia released and provide the Mill's
initial recommendation for offsite protective actions, which are that the offsite response
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 77 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
authorities should follow the recommendations for releases of anhydrous ammonia contained in
the DOT Guidebook. In the DOT Guidebook, Anhydrous ammonia has an ID No. of 1005 and is
covered by Guide No. 125. Initial isolation and protective action distances are et out in Table 1
to the DOT Guidebook. Copies of the relevant pmtions of the Guidebook are attached to this
Appendix. An uncontrolled release of the contents of one of the anhydrous ammonia tanks at the
Mill would be similar to an uncontrolled release from a rail car or tanker truck and would be
considered to be a "large spill" under Table 1 of the DOT Guidebook. The foregoing offsite
officials should also be advised of the conclusions of the Mill's Risk Management Plan, attached
hereto as Appendix K, as it relates to anhydrous ammonia.
16. If the incident involves an uncontrolled release of greater than 36 lbs (7 gallons) of anhydrous
ammonia, report the release to the State of Utah Division of Radiation Control (801-536-4250)
immediately after notification of offsite authorities, and in any event within one hour after
declaration of the emergency, if possible. This immediate notification is required because an
uncontrolled release of anhydrous ammonia of greater than 36 lbs (7 gallons) and 100 pounds is
classified as an Alert and a release of greater thanlOO pounds is classified as a Site Area
Emergency.
17. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
18. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ........ .303-389-4160 (office)
303-7 56-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 78 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
19. Inspect facility for residual concentrations of anhydrous ammonia, paying particular attention to
low points. The RSO or Safety Coordinator will make a determination if it is safe for personnel
to re-enter the facility or any portion of the facility or whether or not any pottion of the facility
must remain shut down;
20. Inspect facility for damage that may have resulted from a fire or explosion and identify any of the
following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations; and
• Damage to any licensed material or any device, container or equipment containing
licensed material.
21 . The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down;
22. The Incident Commander will make the decision to terminate the emergency or enter into recover
mode.
23. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 79 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposmes to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CFR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60. ; or
o any of the events listed in 10 CFR 20.2202(b),
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553.
24. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CFR
20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 80 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXC
EMERGENCY RESPONSE PROCEDURE FOR A RELEASE OF PROPANE
(See also Section 2.1.3 of the Emergency Response Plan)
The following steps will be followed for an uncontrolled release of propane. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
CAUTION: PROPANE IS EXTREMELY FLAMMABLE. RISK OF FIRE OR EXPLOSION
1. A release of propane would most likely occur suddenly. The person who would first witness the
release should immediately contact his or her supervisor who would activate the evacuation alarm
by using the "dial184" notification system.
2. Evacuate all personnel from the Mill site to a location upwind of the spill, and account for all
persom1el, including all contractors and visitors at the Mill and all ore, product and reagent truck
drivers, in accordance with the Emergency Evacuation and Shutdown Procedure desc1ibed in
Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
5. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See U.S. Department of Transpmtation, Pipeline and Hazardous Materials Safety Administration
2008 Emergency Response Guidebook (the "DOT Guidebook") for appropriate protective
clothing. In that Guidebook, propane has an ID No. of 1075 and is covered by Guide No. 115. A
copy of Guide 115 is attached to this Appendix.
6. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
7. In the event of a spill or leak, follow the procedures set out under the heading "Spill or Leak" in
Guide No. 115.
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 81 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
8. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas. See Exhibit 7 for a list and locations of main shut-off
valves.
9. In the event of fire, follow procedures set out under the heading "Fire" in Guide No. 115.
10. Isolate utility lines affected by the fire.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Move victim to fresh air;
• Give artificial respiration if victim is not breathing;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• Clothing frozen to the skin should be thawed before being removed;
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water;
• In case of bums, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhering to skin;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• Keep victim warm and quiet;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Montice11o 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves;
;
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 82 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• If the Mill ambulance is used, an attendant must ride with the i1Dured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. If the incident involves an uncontrolled release of propane that could result in an explosion it is
classified as an Alert. As a result, notify the community emergency response coordinator for the
local emergency planning committee as soon as possible (within 15 minutes after declaration of
the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
In its notifications to the foregoing offsite officials, the Mill personnel making the notification
should advise of the expected quantity of propane released and provide the Mill's initial
recommendation for offsite protective actions, which are that the offsite response authorities
should follow the recommendations for releases of propane contained in the DOT Guidebook. In
the DOT Guidebook, propane has an ID No. of 1075 and is covered by Guide No. 115. Initial
isolation and evacuation recommendations are set out in Guide No. 115. Copies of the relevant
portions of the DOT Guidebook are attached to this Appendix. An uncontrolled release of the
contents of the Mill's propane tank would be similar to an uncontrolled release from a rail car or
tanker truck. The foregoing offsite officials should also be advised of the conclusions of the
Mill's Risk Management Plan, attached hereto as Appendix K, as it relates to propane.
15. If the incident involves an uncontrolled release of propane that could result in an explosion report
the release to the State of Utah Division of Radiation Control (801-536-4250) immediately after
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 83 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible. This immediate notification is required because an uncontrolled release
of propane that could result in an explosion is classified as an Alert.
16. Perform scans on personnel that may have been exposed to areas of high radiation. Pelform
bioassays if appropriate.
17. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
18. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
19. Inspect facility for residual concentrations of propane, paying particular attention to low points.
20. Inspect facility for damage that may have resulted from a fire or explosion and identify any of the
following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 84 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
dete1mination if it is safe for personnel to re-enter the facility or any pmtion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
21. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down;
22. The Site Incident Commander will make the decision to terminate the emergency or enter into
recover mode, or to escalate the emergency to a different category if necessary.
23. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 85 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (sec 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary
The Stale of Utah, Division of Radiation Control (801-536-4250) must be notified within 24 hours
after the discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CFR 20.2202(b).
• Report to MSHA
Aily fire or explosion at the Mill facility must be reported within 15 minutes to the MSHA -1-
800-7 46-1553.
24. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CFR
20.2203(b) and 10 CPR 40.60 (c)(2), as applicable.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 86 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXD
EMERGENCY RESPONSE PROCEDURE FOR A LEACH TANK FAILURE OR
SULFURIC ACID TANK FAILURE
(See also Sections 2.1.4 and 2.1.5 of the Emergency Response Plan)
The following steps will be followed for a leach tank failure or a sulfuric acid tank failure. The steps
should be followed in the order set out below, unless more than one crew is mobilized, in which case
some of the steps can be taken simultaneously by different crews. The Incident Commander has the
authority to vary from the steps set out below if he deems it necessary in the circumstances to protect
public health, safety or the environment.
1. The person who would first witness the tank failure should immediately contact his or her
supervisor who would, as an immediate precautionary measure, isolate the spill or leak area in all
directions for at least 150 feet. All unauthorized personnel will be required to stay out of this
area.
2. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
3. Determine crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander).
4. Mobilize trained personnel and emergency equipment such as SCBAs, first aid equipment etc.
See the Material Data Safety Sheet for sulfuric acid, a copy of which is attached to this Appendix.
5. Initiate rescue operations for any people who may be trapped by the release; do this only with
properly trained and equipped personnel.
6. Guard against possible fires by shutting off electrical circuits, isolating gas lines and eliminating
ignition sources from affected areas. See Exhibit 7 for a list and locations of the main shut-off
valves.
7. Attend to any injured persons:
• One of the following EMT-trained personnel should be contacted, if they are on-site to aid
in the event of any ~uries to personnel:
o David Turk
• Move victim to fresh air;
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 87 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Give artificial respiration if victim is not breathing;
• Do not use mouth-to-mouth method if victim ingested or inhaled the substance; give
artificial respiration with the aid of a pocket mask equipped with a one-way valve or
other proper respiratory medical device;
• Administer oxygen if breathing is difficult;
• Remove and isolate contaminated clothing and shoes;
• In case of contact with substance, immediately flush skin or eyes with mnning water for at
least 20 minutes;
• For minor skin contact, avoid spreading material on unaffected skin;
• Removal of solidified molten material from skin requires medical assistance;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transpmtation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• Keep victim warm and quiet;
• Effects of exposure (inhalation, ingestion or skin contact) to substance may be delayed;
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• Ensure that medical personnel are aware of the materials involved and take precautions to
protect themselves; and
• If the Mill ambulance is used, an attendant must ride with the injured in addition to the
driver, except where the injured could normally be transported in a car or pickup.
8. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
9. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
: :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 88 of
111
10. Initiate necessary steps to contain and/or neutralize the release, in accordance with precautions set
out in the Material Safety Data Sheet attached to this Appendix .
11. In the case of a release from the sulfuric acid tank, remove any contaminated soil to the Mill's
tailings cells for disposal, in accordance with the precautions set out in the Material Safety Data
Sheet attached to this Appendix. Make any notifications required under the Mill's Spill Response
Plan, a copy of which is attached to this Plan as Appendix L.
12. Inspect facility for damage that may have resulted from a leach tank failure and identify any of
the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 89 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
13. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not any portion of the facility must remain
shut down.
14. The Incident Commander will make the decision to terminate the emergency or enter into recover
mode.
15. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary:
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified;
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the ammal permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary:
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60; or
o any of the events listed in 10 CFR 20.2202(b).
• Report to MSHA
Not reportable to MSHA.
16. Written Reports
Book 4t l 6. DENISON I\11NES (USA) CORP.
Rev. No.: R~2.J STANDARD OPERATING PROCEDURES Page 90 of
D<lte: Augusl 18, 4,009 'rHle: While Mesn Mill Emergency Response Plan 1.11
The RS'O will prepare a written report of ~ incident ~ MiiUiles. :tn. a<ldition,lf notification ofs:
required to be submitted to the State under paragraph 15 nbove, the RSO wilJ prepare a written
report and submit il to l'he State of Utah Division of" Radiation Control witbi.11 30 days of the
incident. The wxitten reporl will ~~i~ .tlil~ information rcq~lixed ~ Ul C.~20.2203(b) and JO
CFR 40.60 (c)(2), as applicable.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 91 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXE
EMERGENCY RESPONSE PROCEDURE FOR A FIRE IN THE SOL VENT EXTRACTION
BUILDING
(See also Section 2.1.6 of the Emergency Response Plan)
(See ApJ>endix F for aU other fires)
The following steps will be followed for a fire in the SX building. All other fires will be addressed in
Appendix F. The steps should be followed in the order set out below, unless more than one crew is
mobilized, in which case some of the steps can be taken simultaneously by different crews. The
Incident Commander has the authority to vary from the steps set out below if he deems it necessary in
the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by dialing 185 on any telephone in the area and announcing the location of the fire over
the paging system. This announcement will be repeated twice, for a total of three
announcements. When the paging system cycles through, the fire siren (alternating frequency)
will automatically sound for approximately forty-five seconds then automatically shut off,
allowing radio communications to resume.
2. Evacuate all personnel and account for all personnel, including all contractors and visitors at the
Mill and all ore, product and reagent truck drivers, in accordance with the Emergency Evacuation
and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Mobilize the fire crew.
5. Notify the community emergency response coordinator for the local emergency planning
committee as soon as possible (within 15 minutes after declaration of the emergency, if possible)
as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications as soon as possible:
• Blanding Police
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 92 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
Dial 911, 678-2916 or 678-2334
• Highway Patrol
Dial911 or 587-2000
6. Report the fire to and request the assistance of the following Emergency offsite centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
7. Report the fire to the State of Utah Division of Radiation Control (801-536-4250) immediately
after notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible. This immediate notification is required because a fire in the SX building
is classified as an Alert.
8. Determine other crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
9. Rescue any victims of the fire; do this only with properly trained and equipped persotlllel.
10. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 7 for a
list and locations of the main shut-off valves.
11. Extinguish the fire and post a fire watch for flare-ups.
12. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
13. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to persollllel:
o David Turk
• Give artificial respiration if necessary;
• Control any bleeding;
; : ;
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 93 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to skin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the RSO);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
14. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
15. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
43 5-459-1093
16. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
;
; :
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 94 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
303-221-0098 (home)
303-808-6648 (cell)
111
17. Perform radiation surveys to determine if the fire has caused a dispersion of radioactive materials
and record the results of the surveys. These surveys will be performed in various areas of the
Mill's restricted area as well as outside of the restricted area, particularly in areas downwind of
the fire. In addition, surveys will be taken in the vicinity of the nearest residence downwind of
the fire.
18. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
19. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
the facility or any portion of the facility or whether or not a portion of the facility must remain
shut down.
20. The Incident Commander will make the decision to terminate the emergency or enter recovery
mode or to escalate the emergency to a different category if necessary.
21. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
..
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 95 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CPR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CPR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CPR 40.60.; or
o any of the events listed in 10 CPR 20.2202(b ).
• Report to MSHA
Any fire at the Mill facility must be reported within 15 minutes to the MSHA -1-800-746-
1553.
22. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in the
Mill's tailings cells.
23. Written Reports
The RSO will prepare a written report of the incident for Mill files. fu addition, the RSO will
prepare a written report and submit it to the State of Utah Division of Radiation Control within 30
days of the incident. The written report will contain the information required by 10 CPR
20.2203(b) and 10 CPR 40.60 (c)(2), as applicable.
.
;
Book#16 DENISON ¥INES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 96 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan Ill
APPENDIXF
E.M.ERGENCY RESPONSE PROCEDURE FOR A FIRE
(See also Section 2.1. 7 of the Emergency Response Plan)
(See Appendix E for a fire in the Solvent Extraction Building)
The following steps will be followed for all fires, other than a fire in the SX building, which is
addressed in Appendix E. The steps should be followed in the order set out below, unless more than
one crew is mobilized, in which case some of the steps can be taken simultaneously by different
crews. The Incident Commander has the authority to vary from the steps set out below if he deems it
necessary in the circumstances to protect public health, safety or the environment.
1. The fire will be reported by the individual who finds the incident by activating the fire paging
system by dialing 185 on any telephone in the area and atmouncing the location of the fire over
the paging system. This announcement will be repeated twice, for a total of three
announcements. When the paging system cycles through, the fire siren (alternating frequency)
will automatically sound for approximately forty-five seconds then automatically shut off,
allowing radio communications to resume.
2. Evacuate all personnel and account for all personnel, including all contractors and visitors at the
Mill and all ore, product and reagent truck drivers, in accordance with the Emergency Evacuation
and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Mobilize the fire crew.
5. Determine other crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
6. Rescue any victims of the fire; do this only with properly trained and equipped personnel.
7. Isolate utility lines affected by the fire and shut off all valves as appropriate. See Exhibit 7 for a
list and locations of the main shut-off valves.
8. Extinguish the fire and post a fire watch for flare-ups.
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 97 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
9. If the Incident Commander determines that the fire is not capable of being controlled by the
Mill's Emergency Response crews, then Report the fire to the following Emergency offsite
centers:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or ( 435) 587-2237
10. In cases where the fire is not extinguished within thirty minutes of discovery, the area must be
barricaded off after extinguishing and left undisturbed until released by MSHA and DUSA
management.
11. Attend to any injured persons:
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Give artificial respiration if necessary;
• Control any bleeding;
• In case of burns, immediately cool affected skin for as long as possible with cold water.
Do not remove clothing if adhered to slrin;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transported in a car or
pickup.
12. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
Book #16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 98 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
13. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-67 8-7802 or 435-459-9786
435-459-1093
14. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
15. Perform radiation surveys if necessary to determine if the fire has caused a dispersion of
radioactive materials and record the results of the surveys.
16. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to perform the required safety
function.
;
.Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 99 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
17. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
he facility or any portion of the facility or whether or not a portion of the facility must remain
shutdown
18. The Incident Commander will make the decision to terminate the emergency or enter recover
mode or to escalate the emergency to a different category if necessary.
19. Notification of Regulatory Agencies:
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (80 1-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CPR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CFR 40.60);
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
B~0k m·6 DENISON MJNES (USA) CORP.
Rev. No.: R-2.1 STANDARD Ol'ERATlNG .PR,OCEDURES Fagc roo of
Dale: August 18, 2009 r['itlc: While Mesn Mill Emergency Response Plan 111
o any of (he event listed iJ1 10 CFR 40.60.; ()r
o any of lhe ·events listed in 10 CPR 20.2202(b).
• Report to MS IA
Any fire al the Mill facility must be repo.rted within 15 minutes to the MS.HA -1-800-74G-
I $53 if there is an ir~ury that has a reasonable potential to cause death.
20. Written Reports
The RSO will prepare a written report of the incident for Mill files.
In addition, if a report is required to be given to the State of Utah., Division. of Racli~tion Control
as indicated in paragraph 19 above, the RSO will prepare a written report and subri1it it to the
State of Utah Division of Radiation Control within 30 days of uch initial report The written
report will contain. the information required by 10 CFR 20.2203(b) and 0 CFR 40.60 (c)(2), a.
applicab1e.
; ; :
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 101 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXG
EMERGENCY RESPONSE PROCEDURE FOR A TORNADO OR MAJOR EARTHQUAKE
(See also Sections 2.1.8 and 2.1.9 of the Emergency Response Plan)
The following steps will be followed for a tornado or major earthquake. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. In the case of a tornado, seek cover in areas where there is no potential for falling objects. Such
as in a doorway. After the incident has concluded, the emergency evacuation alarm will be
sounded and a head count will then take place. After all employees have been accounted for, the
emergency response activities will begin, such as shutting down valves, flows, etc ...
2. In case of a major earthquake, seek cover in areas where there is no potential for falling objects.
Such as in a doorway. After the incident has concluded, the emergency evacuation alarm will be
sounded and a head count will then take place. After all employees have been accounted for, the
emergency response activities will begin, such as shutting down valves, flows, etc ...
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. If the earthquake or tornado has caused one of the other incidents referred to in the Plan, refer to
the specific procedures to be followed for that incident set out in Section 2.1 of the Plan and the
applicable Appendix A through I.
5. Determine the crews that may be required (see Section 4.2.2 of the Plan for a discussion of the
available crews at the disposal of the Incident Commander)
6. Rescue any victims of the tornado or earthquake; do this only with properly trained and equipped
personnel.
7. Isolate utility lines and turn off any valves etc necessary in order to prevent fires or explosions.
See Exhibit 7 for a list and locations of the main shut-off valves.
8. Attend to any injured persons:
Book#16 DENISON MINES (USA) GORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 102 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
• One of the following EMT -trained personnel should be contacted, if they are on-site to aid
in the event of any injuries to personnel:
o David Turk
• Give artificial respiration, if necessary;
• Control any bleeding;
• Treat for shock, if necessary;
• Immobilize any fractures and stabilize for transportation;
• Scan the injured person for excessive alpha prior to transporting if time allows
o (If alpha is excessive or there is no time to scan, notify the clinic/hospital
personnel and the Radiation Safety Office);
• The Safety Coordinator or a Safety Technician will notify the following as needed:
o Blanding Clinic 678-2254 or 678-3434 (930 N. 400 W.)
o Blue Mountain Hospital, Blanding 678-3993 (802 S. 200 W.)
o San Juan Hospital, Monticello 678-2830 or 587-2116 (364 W. 1st N.)
o Ambulance Service, Blanding Dial 911
• If the Mill ambulance is used, an attendant must ride with the injured person in addition to
the driver, except where the injured person could normally be transpmted in a car or
pickup.
9. Perform scans on personnel that may have been exposed to areas of high radiation. Perform
bioassays if appropriate.
10. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
11. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediate! y.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
Book#l6_ DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 103 of
111
12. Perform radiation surveys to determine if the tornado or earthquake has caused a dispersion of
radioactive materials and record the results of the surveys. In the case of a tornado, those surveys
will be performed in various areas of the Mill's restricted area as well as outside of the restricted
area, particularly in areas along the path of the tornado.
13. Inspect facility for damage and identify any of the following types of damage to facilities
• Structural damage that could pose a hazard to workers. Any such areas should be
cordoned off as appropriate;
• Damage or disability to equipment that is required to prevent releases of radionuclides
exceeding regulatory limits, to prevent exposures to radioactive materials exceeding
regulatory limits or to mitigate the consequences of an accident, when:
o The equipment is required to be available and operable when it is disabled or fails
to function; and
o No redundant equipment is available and operable to petform the required safety
function.
In the event of any such damage, the Incident Commander or RSO will make a
determination if it is safe for personnel to re-enter the facility or any portion of the facility
or whether or not any portion of the facility must be shut down because it cannot be
operated safely and in accordance with all license or permit conditions, laws and
regulations;
• Damage to any licensed material or any device, container or equipment containing
licensed material
14. The Incident Commander or RSO will make a determination if it is safe for personnel to re-enter
he facility or any portion of the facility or whether or not a portion of the facility must remain
shut down.
15. The Site Incident Commander will make the decision to terminate the emergency or enter recover
mode or to escalate the emergency to a different category if necessary.
16. Notification of Regulatory Agencies:
:
Book#l6 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 104 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
A member of Mill management or Corporate management will notify the following regulating
agencies as indicated below:
• Immediate Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified:
o Immediately if the event involved byproduct, source or special nuclear material
possessed by the Mill that may have caused or threatens to cause any individual to
receive doses at the levels specified in 10 CFR 20.2202 (a)(l) or the release of
radioactive material inside or outside of the restricted area that could cause an
individual to receive an intake five times the annual permissible intake as specified
in 10 CFR 20.2202(a)(2); and
o as soon as possible, but not later than 4 hours after the discovery of an event that
prevents immediate protective actions necessary to avoid exposures to radiation or
radioactive materials that could exceed regulatory limits or releases of licensed
material that could exceed regulatory limits (events may include fires, explosions,
toxic gas releases etc.) (see 10 CPR 40.60)
• 24 Hour Report to UDEQ may be necessary
The State of Utah, Division of Radiation Control (801-536-4250) must be notified within 24
hours after the discovery of:
o any of the events listed in 10 CFR 40.60.; or
o any of the events listed in 10 CPR 20.2202(b).
• Report to MSHA
Any tornado or major earthquake that resulted in structural damage or potentially life
threatening injuries at the Mill facility must be reported within 15 minutes to the MSHA -1-
800-746-1553.
17. Any contaminated soil identified off of the Mill property will be cleaned up and disposed of in the
Mill's tailings cells.
18. Written Reports
The RSO will prepare a written report of the incident for Mill files. In addition, if a report has been
given to the State under paragraph 61 above, the RSO will prepare a written report and submit it to
the State of Utah Division of Radiation Control within 30 days of the incident. The written report
will contain the information required by 10 CPR 20.2203(b) and 10 CFR 40.60 (c)(2), as applicable.
;
Book#l6 DENISON MINES (USA) CORP. _
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 105 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXH
EMERGENCY RESPONSE PROCEDURE FOR TAILINGS ACCIDENTS
(See also Sections 2.1.10.1. 2.1.10.2 and 2.1.10.3 of tlte Emcl'gency Res!lonse Plan
The following steps will be followed in the event of a tailings accident (flood water breaching,
structural failure of tailings dike or damage to tailings transport system). The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. The person who first witnesses the tailings accident should immediately contact his or her
supervisor, who will initiate the procedures set out below.
2. Evacuate personnel from areas around the impacted area as necessary to prevent possible injury
to those personnel. Access to those areas will be limited to authorized personnel.
3. Turn off all feed of tailings or solutions to the tailings cells and to the tailings transport system.
4. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Co{Ilmander arrives.
5. Notification of Mill Management
The Supervisor will notify one of the following if not already alerted and part of the Emergency
Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
6. To the extent possible, solutions from an impacted tailings cell will be pumped to an un-impacted
tailings cell.
7. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
;
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
Page 106 of
111
8. In the event of damage to the transport system, the system will be shut down and repaired. Any
spills will be cleaned up and deposited in the tailings cells.
9. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
mobilize large operating equipment to construct temporary earthen dikes or berms downgradient
to the impacted dike, if appropriate in the circumstances.
10. In the case of flood water breaching the retention system or structural failure of the tailings dikes,
report the incident to the State of Utah Division of Radiation Control (801-536-4250) within 24
hours of the discovery of the incident.
11. Take other measures and perform remediation work as necessary and in accordance with advice
and instructions of the State of Utah Division of Radiation Control.
12. Other reporting
• Report to MSHA
Does not have to be reported.
• Report to State of Utah Department of Natural Resources, Division of Dam Safety
• A written report will be made to the State of Utah Division of Radiation Control within 5
days after the incident.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 107 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIX I
EMERGENCY RESPONSE PROCEDURE FOR A TERRORIST/BOMB THREAT
(See also Section 2.1.11 of the Emergency Response Plan)
The following steps will be followed in the event of a terrorist/bomb threat. The steps should be
followed in the order set out below, unless more than one crew is mobilized, in which case some of
the steps can be taken simultaneously by different crews. The Incident Commander has the authority
to vary from the steps set out below if he deems it necessary in the circumstances to protect public
health, safety or the environment.
1. The person who would first witness the threat should immediately contact his or her supervisor
who would activate the evacuation alarm by using the "dial184" notification system.
2. Evacuate all personnel from the Mill site, and account for all personnel, including all contractors
and visitors at the Mill and all ore, product and reagent truck drivers, in accordance with the
Emergency Evacuation and Shutdown Procedure described in Appendix J.
3. Determine Incident Commander. The Incident Commander will be the Mill Manager, or in his
absence the Mill Superintendent, or in the absence of both the Mill Manager and the Mill
Superintendent, the RSO. Shift Foremen are in charge and are responsible for all emergency
procedures until the Incident Commander arrives.
4. Since the consequences of the threat are unknown, the incident is considered an Alert. Notify the
community emergency response coordinator for the local emergency planning committee
immediately (within 15 minutes after declaration of the emergency, if possible) as follows:
• Rick M. Bailey 587-3225 (work)
587-2313 (home)
Also make the following notifications immediately:
• Blanding Fire House and Sheriff's office:
Blanding Fire
350 West 200 South, Blanding
Phone number is 911
• Sheriff's Office
297 West South Main, Monticello
Phone number is 911 or [phone]
:
Book #16 DENISON MINES (USA) CORP. .
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 108 of
Date: August 18, 2009 Title: White Mesa Mil1 Emergency Response Plan 111
• Blanding Police
Dial911, 678-2916 or 678-2334
• Highway Patrol
Dial 911 or 587-2000
5. Notify the State of Utah Division of Radiation Control (801-536-4250) immediately after
notification of offsite authorities, and in any event within one hour after declaration of the
emergency, if possible.
6. Notification of Mill Management
The Incident Commander will notify one of the following of all incidents, if not already alerted
and part of the Emergency Response crew:
• R.E. Bartlett
• D. Turk
• R. Wallace
435-678-2495 or 435-979-3893
435-678-7802 or 435-459-9786
435-459-1093
7. Notification of Corporate Management:
The Incident Commander is to call Harold Roberts, Ron Hochstein or David Frydenlund
immediately.
• Harold Roberts (Executive Vice President) ......... 303-389-4160 (office)
303-756-9050 (home)
303-902-2870 (cell)
• Ron Hochstein (President/CEO) ...................... 604-689-7842 (office)
604-931-6334 (home)
604-377-1167 (cell)
• .. David Frydenlund (Vice President) ................... 303-628-7798 (office)
303-221-0098 (home)
303-808-6648 (cell)
8. Follow instructions given by offsite emergency response officials.
9. To the extent that the threat or bomb results in any of the incidents, such as fire, release of
anhydrous ammonia etc. described elsewhere in the Plan, follow the specific procedures
applicable to such incidents set out in Section 2.1 of the Plan and in Appendices a through I, to
the extent applicable.
:
Book 4116 DENfSON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERA TTNG PROCEDURBS Page 109 of
Dale: August 18, 2009 Title: White Mesa Mill Emergeney Response Plan Ill
10. The Site Incident Commander will make the decision lo terminate the emergency or enter into
recover mode or to escalale the emergency to a different category If necessary.
:
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page 110 of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan 111
APPENDIXJ
EMERGENCY EVACUATION AND SHUT DOWN PROCEDURE
1. Activate evacuation alarm by using the "dial 184" notification system. Evacuate and account for
all personnel.
2. Personnel are to assemble in one of the following areas:
• The parking lot south of the office building;
• The scalehouse;
• The north side of Tailings Cell 1, or
• North of the Mill.
The area will be designated by the Incident Commander or Shift Foreman.
3. Specific Procedure for Operations Personnel
• See specific emergency shutdown procedure for Operations by area under the relevant
Operating Procedure for your area.
o A list of the main shut-off valves and their locations is set out in Exhibit 7 to the
Plan.
• All employees not mentioned under Operating Procedures are to immediately report to the
assembly area and congregate by crew so that all persons can be accounted for. As
employees leave their work areas, they must pass the word to evacuate to any persons who
may not be aware of the emergency.
• After the Mill has been determined to be safe for re-entry, employees will be verbally
notified to return to their work stations.
Book#16 DENISON MINES (USA) CORP.
Rev. No.: R-2.1 STANDARD OPERATING PROCEDURES Page Ill of
Date: August 18, 2009 Title: White Mesa Mill Emergency Response Plan Ill
FIGURE!
FlRE SYSTEM SCHEMATIC DRAWING
:
I
I
I
I
I
I
I
I --·*
I
I
I
I
I
I
.... ~!.,;.~
I ·. ,
u~·~ \
f'i( ~t
~! ......
t.
~ ::. If
t .. (I
)'
' F
(\ ~ :t. If J1l
I lf\ r ..( 1 -II\
() ~
IT
1:
\CJ" ..
' l t
o,
~...(& .... o
11tl :'-0
0 -0 1 Q . ~~~ :s ... , .. tO <~o
!J 11~ " -~ t
" 0 ' i:O . ,. 0
~ :,8 r ~.X: DO~ I
I -. <.; ~ " D...._ ~~~ ~~~ ~ -.. ~ ..... ~ (., f r. ,~r • • I)
t "o 0 z. ~[~
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0 0 X
' ......
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• ~ of "fl . h ~ .....
,. '· s ! •Q
-~ -tit• .. -~ U!aO <( ~'
~~~ 0 • !i XQ . t :' • .J .. J -~ ..
~··~ ~iff d; fF a "~:z:.· _6il 00 i 0 2 <JPPe&""
!!~' ,. .. &lt.lll.liC .... -
,.. ~
~t~-,-r-C' "t . ··--ft t •
t. r li Cl . ·rj (I" • , ,.. ~ . . 1 .. ~ . ·-~ ,..f. ... -~ J: n .. ;~ .......
. . . . . . . . . .
Appendix
A
. . (
112 Ammonium nitrate-fuel oil 1013 120 Carbon dioxide, compressed
mixtures 1014 122 Carbon dioxide and Oxygen mixture
158 Biological agents 1014 122 Carbon dioxide and Oxygen ::
112 Blasting agent, n.o.s. mixture, compressed ~· .,
112 Explosive A 1014 122 Oxygen and Carbon dioxide ~:.:
I
112 Explosive B mixture ·l , . . )
1014 122 Oxygen and Carbon dioxide I
114 Explosive C ,,
II
mixture, compressed lj
112 Explosives, division 1.1, 1.2, .-.: ,I
1.3,1.5or1.6 1015 126 Carbon dioxide and Nitrous 'i
oxide mixture ·' 114 Explosives, division 1.4 I ·l 1015 126 Nitrous oxide and Carbon :~~
153 Toxins ...
dioxide mixture .~f "·t ,1.
1001 116 Acetylene ;,1 .,J ·:·
1001 116 Acetylene, dissolved ~~ ;
1002 122 Air, compressed ·~ ·,
•,)
1003 122 Air, refrigerated liquid 1018 126 C hlorod ifluoromethane (
(cryogenic I iq uid) :1
1018 126 Refrigerant gas R-22 '{
;! 1003 122 Air, refrigerated liquid )
(cryogenic liquid), non-1020 126 ChI oro pen tafl uoroethane J
pressurized 1020 126 Refrigerant gas R-115
j
1021 126 1-Chloro-1 ,2,2,2-'i 'l tetrafluo roetha n e _,t ..
I
1021 126 Chlorotetrafl uoroethane I
1021 126 Refrigerant gas R-124
1022 126 C hlorotrifluoromethane 'i
1022 126 Refrigerant gas R-13 ;!
1009 126 B romotrifl uoro methane l
.'\
1009 126 Refrigerant gas R-1381 ~i
1010 116P Butadienes, stabilized )I
··I 1010 116P Butadienes and hydrocarbon ·I .,
mixture, stabilized 1027 115 Cyclopropane .I, .,
--~ 1 011 115 Butane 1028 126 Diehl orad ifluoromethane . ' '! ,'I
1011 115 Butane mixture 1028 126 Refrigerant gas R-12 l ~:~:
1012 115 Butylene 1029 126 Diehl orofluoromethane ~
; ~ .
1013 120 Carbon dioxide 1029 126 Refrigerant gas R-21 : ... ,
'· . ·,l~
~. ""~' ~~ . ·:· ·~!, ... . ... • '":, .•. ._,._ ... : :-~· ·,") .. ~-· :· ·.·· .,. \· .. , . ~ :· • ... ..• . . ~· ... ~:: ;.~~:.\-, ~~, ' ....... ,. ., . ~ ·'!;.(;·!'· :; ~ , •• · .~::: ·::...-'R._···· .~ ... ~2 ~~;,~.t ~J ·~~ • v ·' ~·~! ,~, ...... ". ···~·.r\,~ ~ . .-· .. :~:-·: ....... ,..,.., ~J '·it"~•·' .. :·,··= .. -: ... '· ;· .:·!·'·.j.~·,': :~~·'"\.~'!• !~ t~~·~·£:·~'-r '··:· .l.·: ..;":'l;'t" .... , .-v~~~.~·~.~~~ ·,·aae.~· ... ; .. \'~
• TOXIC; may be fatal if inhaled, ingested or absorbed through skin.
• Vapors are extremely irritating and corrosive.
• Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite.
• Fire will produce irritating, corrosive and/or toxic gases .
• Runoff from fire control may cause pollution.
• Some may burn but none ignite readily.
• Vapors from liquefied gas are initially heavier than air and spread along ground.
• Some of these materials may react violently with water.
• Cylinders exposed to fire may vent and release toxic and/or corrosive gas through
pressure relief devices.
• Containers may explode when heated.
• Ruptured cylinders may rocket.
• CALL Emergency Response Telephone Number on Shipping Paper first. If
Shipping Paper not available or no answer, refer to appropriate telephone
number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area for at least 100 meters
(330 feet) in all directions.
• Keep unauthorized personnel away .
• Stay upwind.
• Many gases are heavier than air and will spread along ground and collect in low or
confined areas (sewers, basements, tanks).
• Keep out of low areas .
• Ventilate closed spaces before entering.
TIVE CLOTHING
• Wear positive pressure self-contained breathing apparatus (SCBA).
• Wear chemical protective clothing that is specifically recommended by the manufacturer.
It may provide little or no thermal protection.
• Structural firefighters' protective clothing provides limited protection in fire situations
ONLY; it is not effective in spill situations where direct contact with the substance is
possible.
Spill
• See Table 1 -Initial Isolation and Protective Action Distances for highlighted materials .
For non-highlighted materials, increase, in the downwind direction, as necessary, the
isolation distance shown under "PUBLIC SAFETY".
Fire
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all
directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions.
..
• Dry chemical or C0 2•
Large Fire
I Water spray, fog or regular foam.
I Move containers from fire area if you can do it without risk.
• Do not get water inside containers.
I Damaged cylinders should be handled only by specialists.
Fire involving Tanks
I Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
• Cool containers with flooding quantities of water until well after fire is out.
I Do not direct water at source of leak or safety devices; icing may occur.
• Withdraw immediately in case of rising sound from venting safety devices or
discoloration of tank. • ALWAYS stay away from tanks engulfed in fire.
• Fully encapsulating, vapor protective clothing should be worn for spills and
leaks with no fire.
• Do not touch or walk through spilled material.
• Stop leak if you can do it without risk.
• If possible, turn leaking containers so that gas escapes rather than liquid.
• Prevent entry into waterways, sewers, basements or confined areas.
• Do not direct water at spill or source of leak.
• Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to
contact spilled material. • Isolate area until gas has dispersed.
FIRST-A
• Move victim to fresh air. • Call911 or emergency medical service.
• Give artificial respiration if victim is not breathing.
• Do not use mouth-to-mouth method if victim ingested or Inhaled the substance;
give artificial respiration with the aid of a pocket mask equipped with a one-way
valve or other proper respiratory medical device.
• Administer oxygen if breathing is difficult.
• Remove and isolate contaminated clothing and shoes.
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
• In case of contact with substance, immediately flush skin or eyes with running water for
at least 20 minutes.
In case of contact with Hydrogen fluoride, anhydrous (UN1052), flush skin and
eyes with water for 5 minutes; then, for skin exposures rub on a calcium/jelly
combination ; for eyes flush with a water/calcium solution for 15 minutes.
I Keep victim warm and quiet. • Keep victim under observation .
• Effects of contact or inhalation may be delayed.
Ensure that medical personnel are aware of the material(s} involved and take
precautions to protect themselves .
(
-. . . . . . . . .
Appendix
B
-·
HOW TO USE TABLE 1 · INITIAL ISOLATION AND
PROTECTIVE ACTION DISTANCES
The responder should already have:
• Identified the material by its ID Number and Name; (if an ID Number cannot be
found, use the Name of Material index in the blue-bordered pages to locate that
number.)
• Found the three-digit guide for that material in order to consult the emergency
actions recommended jointly with this table;
• Noted the wind direction.
Look in Table 1 (the green-bordered pages) for the ID Number and Name of the Material
involved in the incident. Some ID Numbers have more than one shipping name listed-
look for the specific name of the material. (If the shipping name is not known and
Table 1 lists more than one name for the same 10 Number, use the entry with the
largest protective action distances.)
Determine if the incident involves a SMALL or LARGE spill and if DAY or NIGHT.
Generally, a SMALL SPILL is one which involves a single, small package (e.g., a drum
containing up to approximately 200 liters), a small cylinder, or a small leak from a large
package. A LARGE SPILL is one which involves a spill from a large package, or
multiple spills from many small packages. DAY is any time after sunrise and before
sunset. NIGHT is any time between sunset and sunrise.
Look up the INITIAL ISOLATION DISTANCE.
Direct all persons to move, in a crosswind
direction, away from the spill to the
distance specified-in meters and feet.
Spill
Initial Isolation
Distance
Look up the initial PROTECTIVE ACTION DISTANCE shown in Table 1. For a given
material, spill size, and whether day or night, Table 1 gives the downwind distance-in
kilometers and miles-for which protective actions should be considered. For practical
purposes, the Protective Action Zone (i.e., the area in which people are at risk of
harmful exposure) is a square, whose length and width are the same as the downwind
distance shown in Table 1.
Initiate Protective Actions to the extent possible, beginning with those closest to the
spill site and working away from the site in the downwind direction. When a water-
reactive TIH producing material is spilled into a river or stream, the source of the toxic
gas may move with the current or stretch from the spill point downstream for a substantial
distance.
The shape of the area in which protective actions should be taken (the Protective
Action Zone) is shown in this figure. The spill is located at the center of the small
circle. The larger circle represents the I~ITIAL ISOLATION zone around the spill.
Protective
Action Zone
Spill
Wind Direction
>
....
>
Downwind Distance
.... ........ ....
1/2 Downwind
Distance
1/2 Downwind
Distance
NOTE 1: See "Introduction To Table 1 -Initial Isolation And Protective Action
Distances" for factors which may increase or decrease Protective Action
Distances.
NOTE 2: See Table 2 -Water-Reactive Materials which Produce Toxic Gases for the
list of gases produced when these materials are spilled in water.
Call the emergency response telephone number listed on the shipping paper, or the
appropriate response agency as soon as possible for additional information on the materiaL
safety precautions, and mitigation procedures.
'·.
First Then First
ISOLATE PROTECT ISOLATE
in all Directions oersons Downwind durina-in all Directions
NAME OF MATERIAL Meters (Feet) DAY I NIGHT
Kilometers (Miles) Kilometers (Miles) Meters (Feet)
Ammonia, anhydrous 30m (100ft) 0.1 km (0.1 mi) 0.2km (0.1 mi) 150m (500ft) I o.Bkm
Anhydrous ammonia
Boron 1rifluoride I 30m (100ft) I 0.1 km (0.1 mi) 0.6km (0.4 mQ I 300 m (1000 ft) 1 1.9 km (12mi) 4.8km (3.0 mi)
Boron trifluoride, compressed
Carbon monoxide I 30m (100ft) I 0.1 km (0.1 mi) 0.1 km (0.1 mQ I 150m (500ft) I 0.7km (0.5mi) 2.7 km
Carbon monoxide, compressed
Chlorine 60m (200ft) 0.4km (0.3mi) 1.6km (1.0 mi) I 600 m (2000 ft) I 3.5 km (2.2 mi) B.Okm (5.0mi)
Coal gas 30m (100ft) 0.1 km (0.1 mi) 0.1 km (0.1 mi) I 60m (200ft) I 0.3 km (0.2 mi) 0.4km (0.3mi)
Coal gas, compressed
1 30m (100ft) I 0.2 km (0.1 mi) 0.9km (0.5mi) 150m (500ft) 1.0 km (0.7mi) 3.5km
Ethylene oxide I 30m (100ft) I 0.1 krn (0.1 mi) 0.2km (0.1 mi) 150m (500ft) 0.8km (0.5 mi) 2.5km
Ethy~ne oxide with Nitrogen
Fluorine I 30m (100ft) I 0.1 km (0.1 mi) 0.3 krn (0.2 mi) I 150m (500ft) I 0.8km (0.5mi) 3.1 km (1:9 mi)
Fluorine, compressed
Hydrogen bromide, anhydrous 30m (100ft) 0.1 krn (0.1 mi) 0.4km (0.3 mD 300m (1000 ft) 1.5km (1.0 mi) 4.5km
Hydrogen chloride, anhydrous 30m (100ft) 0.1 km (0.1 mi) 0.4 krn (0.2mi) 60m (200ft) 0.3km (0.2mi) 1.4km
AC (when used as a weapon) 100m (300ft) 0.3km {02mQ 1.1krn (0.7 mi] 1000 m (3000 ft) 3.8km (2.4mi) 7.2km
Hydrocyanic acid, aqueous 60m (200ft) 0.2km (0.1 mi) 0.6 krn (0.4 mi) 400m (1250 ft) 1.6km (1.0 mi) 4.1 km
solutions, with more than 20%
Hydrogen cyanide
Hydrogen cyanide, anhydrous, stabilized
Hydrogen cyanide, stabilized
Hydrogen fluoride, anhydrous I 30m (100ft) I 0.1 km (0.1 mi) 0.5km (0.3 mi) I 300 m (1000 ft) l 1.7 km (1.1 mi) 3.6km
:
PROTECTIVE CLOTHING
Street Clothing and Work Uniforms. These garments, such as uniforms worn by police
and emergency medical services personnel, provide almost no protection from the harmful
effects of dangerous goods.
Structural Fire Fighters' Protective Clothing (SFPC). This category of clothing, often
called turnout or bunker gear, means the protective clothing normally worn by fire fighters
during structural fire fighting operations. It includes a helmet, coat, pants, boots, gloves and
a hood to cover parts of the head not protected by the helmet and facepiece. This clothing
must be used with full-facepiece positive pressure self-contained breathing apparatus (SCBA).
This protective clothing should, at a minimum, meet the OSHA Fire Brigades Standard
(29 CFR 191 0.156). Structural fire fighters' protective clothing provides limited protection
from heat and cold, but may not provide adequate protection from the harmful vapors or
liquids that are encountered during dangerous goods incidents. Each guide includes a
statement about the use of SFPC in incidents involving those materials referenced by that
guide. Some guides state that SFPC provides limited protection. In those cases, the responder
wearing SFPC and SCBA may be able to perform an expedient, that is quick "in-and-out",
operation. However, this type of operation can place the responder at risk of exposure,
injury or death. The incident commander makes the decision to perform this operation only
if an overriding benefit can be gained (i.e., perform an immediate rescue, turn off a valve to
control a leak, etc.). The coverall-type protective clothing customarily worn to fight fires in
forests or wildlands is not SFPC and is not recommended nor referred to elsewhere in this
guidebook.
Positive Pressure Self~Contained Breathing Apparatus (SCBA). This apparatus provides
a constant, positive pressure flow of air within the facepiece, even if one inhales deeply while
doing heavy work. Use apparatus certified by NIOSH and the Department of Labor/Mine
Safety and Health Administration in accordance with 42 CFR Part 84. Use it in accordance
with the requirements for respiratory protection specified in OSHA 29 CFR 1910.134
(Respiratory Protection) and/or 29 CFR 1910.156 (f) (Fire Brigades Standard). Chemical-
cartridge respirators or other filtering masks are not acceptable substitutes for positive pressure
self-contained breathing apparatus. Demand~type SCBA does not meet the OSHA 29 CFR
1910.156 (f)(1 )(i) of the Fire Brigades Standard. If it is suspected that a Chemical Warfare
Agent (CW) is involved, the use of NIOSH-certified respirators with CBRN protection are
highly recommended.
Chemical Protective Clothing and Equipment. Safe use of this type of protective clothing
and equipment requires specific skills developed through training and experience. It is
generally not available to, or used by, first responders. This type of special clothing may
protect against one chemical, yet be readily permeated by chemicals for which it was not
designed. Therefore, protective clothing should not be used unless it is compatible with the
released material. This type of special clothing offers little or no protection against heat and/
or cold. Examples of this type of equipment have been described as (1) Vapor Protective
Page 348
Suits (NFPA 1991), also known as Totally-Encapsulating Chemical Protecttve (TECP) Suits
or Level A* protection (OSHA 29 CFR 1910.120, Appendix A & B), and (2) Liquid-Splash
Protective Suits (NFPA 1992 & 1993), also known as Level B* or C* protection (OSHA 29
CFR 1910.120, Appendix A & B) or suits for chemical/biological terrorism incidents (NFPA
1994 ), class 1, 2 or 3 Ensembles. No single protective clothing material will protect you from
all dangerous goods. Do not assume any protective clothing Is resistant to cold and/or heat
or flame exposure unless it is so certified by the manufacturer. (NFPA 1991 5-3 Flammability
Resistance Test and 5-6 Cold Temperature Performance Test)
* Consult glossary for additional protection lev~ Is under the heading ftProtective Clothing" .
. ·
Page 349
Appendix
c
1063 115 Refrigerant gas R-40
1065 Neon, compressed
1 066 121 Nitrogen
1066 121 Nitrogen, compressed
1072 122
1072 122
1073 122
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
1075 115
Oxygen
Oxygen, compressed
Oxygen, refrigerated liquid
(cryogenic liquid)
Butane
Butane mixture
Butylene
lsobutane
lsobutane mixture
lsobutylene
Liquefied petroleum gas
LPG
Petroleum gases, liquefied
Propane
Propane mixture
Propylene
. :·! I o o -·~. ·-. .. . . ...... ·•. :
1077 115 Propylene
1078 126 Dispersant gas, n.o.s.
1078 126 Refrigerant gas, n.o.s.
1080 126 Sulfur hexafluoride
.1.080 126 Sulphur hexafluoride
1081 116P Tetrafluoroethylene, stabilized
118 Trimethylamine, anhydrous
1085 116P Vinyl bromide, stabilized
1086 116P Vinyl chloride, stabilized
1087 116P Vinyl methyl ether, stabilized
1088 127 Acetal
1089 129 Acetaldehyde
1090 127 Acetone
1091 127 Acetone oils
1099 131 Allyl bromide
1100 131 Allyl chloride
1104 129 Amyl acetates
1105 129 Amyl alcohols
1105 129 Pentanols
1106 132 Amylamines
1107 129 Amyl chloride
1108 128 n-Amylene
1108 128 1-Pentene
1109 129 Amyl formates
1110 127 n-Amyl methyl ketone
1110 127 Amyl methyl ketone
·i ,I
i
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llj
• tt ··;••.: • ,,. •••"' ,~. • • ' I 'P ' 29 t• ~ ~·: .. :.· .. '\, ·. · . ~· _,. Jaae· · ·
• Will be easily ignited by heat, sparks or flames.
• Will form explosive mixtures with air.
• Vapors from liquefied gas are initially heavier than air and spread along ground.
CAUTION:Hydrogen (UN1049), Deuterium (UN1957), Hydrogen, refrigerated liquid
(UN1966) and Methane (UN1971) are lighter than air and will rise. Hydrogen and
Deuterium fires are difficult to detect since they burn with an invisible flame. Use
an alternate method of detection (thermal camera, broom handle, etc.)
• Vapors may travel to source of ignition and flash back.
• Cylinders exposed to fire may vent and release flammable gas through pressure relief
devices.
I Containers may explode when heated.
• Ruptured cylinders may rocket.
• Vapors may cause dizziness or asphyxiation without warning.
• Some may be irritating if inhaled at high concentrations.
• Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite .
• Fire may produce irritating·and/or toxic gases.
• CALL Emergency Response Telephone Number on Shipping Paper first. If
Shipping Paper not available or no answer, refer to appropriate telephone
number listed on the inside back cover.
• As an immediate precautionary measure, isolate spill or leak area for at least 100 meters
(330 feet) in all directions.
I Keep unauthorized personnel away.
• Stay upwind .
• Many gases are heavier than air and will spread along ground and collect in low or
confined areas (sewers, basements, tanks).
• Keep out of low areas.
LOTH lNG
Large Spill
• Consider initial downwind evacuation for at least 800 meters (1/2 mile).
Fire
• If tank, rail car or tank truck is involved in a fire, ISOLATE for 1600 meters (1 mile) in all
directions; also, consider initial evacuation for 1600 meters (1 mile) in all directions.
• DO NOT EXTINGUISH A LEAKING GAS FIRE UNLESS LEAK CAN BE STOPPED.
CAUTION: Hydrogen (UN1049), Deuterium (UN1957) and Hydrogen, refrigerated liquid
(UN1966) burn with an invisible flame. Hydrogen and Methane mixture, compressed
(UN2034) may burn with an invisible flame.
Small Fire
• Dry chemical or C02.
large Fire
• Water spray or fog.
I Move containers from fire area if you can do it without risk.
Fire involving Tanks
I Fight fire from maximum distance or use unmanned hose holders or monitor nozzles.
I Cool containers with flooding quantities of water until well after fire is out.
• Do not direct water at source of leak or safety devices; icing may occur.
I Withdraw immediately in case of rising sound from venting safety devices or
discoloration of tank.
• ALWAYS stay away from tanks engulfed in fire.
• For massive fire, use unmanned hose holders or monitor nozzles; if this is impossible,
withdraw from area and let fire burn.
SP
• ELIMINATE all ignition sources (no smoking, flares, sparks or flames in immediate area).
• All equipment used when handling the product must be grounded.
• Do not touch or walk through spilled material.
• Stop leak if you can do it without risk.
• If possible, turn leaking containers so that gas escapes rather than liquid.
I Use water spray to reduce vapors or divert vapor cloud drift. Avoid allowing water runoff to
contact spilled material.
Do not direct water at spill or source of leak.
• Prevent spreading of vapors through sewers, ventilation systems and confined areas.
I Isolate area until gas has dispersed.
CAUTION: When in contact with refrigerated/cryogenic liquids, many materials become
brittle and are likely to break without warning.
FIRST AID.
I Move victim to fresh air. I Call 911 or emergency medical service.
I Give artificial respiration if victim is not breathing.
• Administer oxygen if breathing is difficult.
I Remove and isolate contaminated clothing and shoes.
• Clothing frozen to the skin should be thawed before being removed.
• In case of contact with liquefied gas, thaw frosted parts with lukewarm water.
• In case of burns, immediately cool affected skin for as long as possible with cold water. Do
not remove clothing if adhering to skin. • Keep victim warm and quiet.
I Ensure that medical personnel are aware of the material(s) involved and take precautions t
protect themselves.