DRC-2011-004109 - 0901a068802222f9

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Governor
April 21, 2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
Department of
Environmental Quality
' Amanda Smith
Executive Director
DIVISION OF RADIATION GGNTROL
Rusty Lundberg
Director
SUBJECT: December 1, 2010 DUSA Transmittal Letter, Three Separate Draft Standard Operating
Procedures (SOPs); SOPs for Title: lie.(2) Byproduct Disposal No. PBL-10 Rev. No.: R-2
Dec. 1, 2010: Comments and Request for Information
We have received the subject December 1, 2010 DUSA letter, transmitting three separate proposed
Standard Operating Procedures (SOPs). The subject of this letter is our review of one of these SOPs, i.e.
the Title: 1 le.(2) Byproduct Disposal Standard Operating Procedures [SOPs] with subject version
number. The subject Title: He.(2) Byproduct Disposal SOPs were submitted by DUSA to comply with the
requirements of License Condition 10.5. We have reviewed this document, and have comments listed
below. DRC review of the other two transmitted SOPs is to be discussed in separate DRC letters.
1. General.
Please bear in mind that since the items below pertain to a License Condition that requires
Executive Secretary approval, your responses regarding them could be subject to
enforcement. Therefore, complete and thorough responses in this matter are important.
Some suggested red-line strike-out changes for the subject SOPs are attached. The
majority of these suggestions were derived from our review of the License Conditions.
Please note that some sections of the red-line strike-out copy ofthe subject SOPs may
contain several recommended changes. Also, please note that not all changes requested in
this letter are captured in our red-line strike-out notations.
Chief among the interests of DRC in changes to the subject SOPs was for DUSA to add
provisions to prevent the occurrence of any hazardous waste deposits, and to increase
density of compacted ISL byproduct materials (to reduce potential settlement) in tailings
cells. Remarks, I.e. (1) through (3) directly below, concem this.
(1). We suggest DUSA consider adding the verbiage similar to that shown in red-line
strike-out verbiage attached as new red-line paragraph 5.6 of the subject SOPs.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Primed on lOO'/c recycled paper
Page 2
The concept is to have byproduct materials pre-inspected before its arrival
adjacent to the disposal site.
(2). As shown in red-line, we suggest that DUSA consider moving existing paragraph
6.4 and revise it to language similar to the attached new red-line paragraph 6.5.c of
the subject SOPs. The concept here is to assure after unloading, that no items of
concem were hidden or obscured in the material.
(6}v To be consistent with License Condition 10.4A, and to increase compaction and
reduce settlement, as mentioned in paragraph Ic above, we have a comment. We
suggest DUSA edit paragraph 7.2, similar to the attached red-line strike out
verbiage of the subject SOPs, to require that, "byproduct material will be
compacted with the same requirements as License Condition 10.4A."
License Condition 10.5B states that,
'All ISL contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal area
and the barrels crushed. Barrels containing soil or sludges shall be verified by the Licensee to be
full prior to disposal. Barrels not completely full shall be filled with tailings or soil prior to
disposal."
DRC Findings: Some red-line strike-out verbiage attached is suggested in Section 5.6b of
the subject SOPs. The concept is to have barrels containing byproduct materials pre-
inspected for fullness before arrival adjacent to the disposal site.
3. License Condition 10.5E(3) states that,
".. .ISL byproduct material will be segregated from any mill material and equipment disposed of in
the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in-situ
leach source will be segregated from the byproduct material from all other in-situ-leach.s.ources;'.'
DRC Findings: It appears the submitted SOPs do not clearly address this condition. Some
red-line strike-out verbiage attached is suggested in Section 6.1 of the subject SOPs to
more clearly address this license condition.
License Condition 10.5E states that,
"The licensee shall also submit for Executive Secretary approval a revised written
Standard Operating Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised
SOP shall describe the documentation required for ISL disposal, which shall include but is not
limited to the following..."
DRC Findings: The emphasis here is on documentation. License Condition 10.5D also
requires documentation, "of all disposal activities." DUSA must develop a form for ISL
disposal documentation, to cover all the documentation requirements of License Condition
10.5Eand 10.5D.
Page 3
The DRC review letter of March 1, 2010 is referenced in your subject transmittal. Paragraph A
of the DRC letter states the following: "Proposed methods and procedures to fully protect the
liner while accessing tailings cells for disposal of ISL byproduct material and mill equipment
must be submitted for approval. These methods and procedures would apply to tailings Cell 4A
and newer cells."
DRC Findings: It appears the submitted SOPs do not describe the actual "metho(Js
and procedures to protect the liner while accessing the tailings cells..." Please
adjust the subject SOPs to do so.
The page numbering in the subject SOPs document has errors. Please adjust the subject SOPs
to correct these errors.
DRC RAM Inspector Comments:
a. Reference a DRC inspection of ISL disposal activities, held on September 1-2, 2009. A
copy of the inspection report is attached to this letter. In the "Deficiencies" paragraph on
page 2 of this report, the DRC inspector stated that at that time, the ISL documentation did
not include, "Description of how ISL material [was] being placed in the slit trenches..."
and, "Description of other activities (i.e. Barrels not being completely full being filled with
tailings or soil as described in License Condition 10.5B)." In the Conclusions and
Recommendations paragraph on page 4 of that report, it states that DUSA should ,
"Document the placement of ISL material in tailing Cell #3 with a detailed description [of]
all disposal activities involved with the disposal of each shipment. License Condition
10.5D states,'All disposal activities shall be documented.'"
The disposal documentation for each shipment, including the method of disposal such as
trench disposal or other approved disposal method with backfill, needs to be documented
for each individual shipment. Documentation requirements for the above activities were
not included in the subject SOPs as submitted, but need to be.
b. Balloon comments Rl through R4 are provided in the margins of the attached red-line
strike out copy ofthe subject SOPs. Please address these comments.
Please review the above comments, and respond in writing, submitting an appropriately revised Title:
lle.(2) Byproduct Disposal Standard Operating Procedures document with a unique version number. Per
your email dated April 14, 2011 you committed that DUSA would fully respond to this letter within 30
calendar days of receipt. If you have any questions on the above, please contact me.
David A. Rupp, P.E.
Geotechnical Services Section
DAR:RJ:dr
Attachment: Red-line strike-out copy of the subject SOPs
Inspection Report Sept. 1-2, 2009
F.\License\ISL Amendments for 2010\1 le2 Byproduct Disposal Cmll dr&rj.doc
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
iPage 1 of 6
1.0 Purpose
I • .
Denison Mines (USA) Corp. ("DUSA") receives lle.(2) byproduct material ("byproduct
material") from uranium in-situ leach operations for disposal under License Condition
10.5. The following procedure applies to acceptance, handling, and disposal of
byproduct material at the White Mesa Mill ,(the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety
Officer ("RSO"), or his designee, prior to shipment to the Mill. The byproduct material
must conform to Titles 10 and 49 of the U.S. Code of Federal Regulations] ("CFR") and
the Shipper must certify that the byproduct material does not contain hazarcious waste as
defined in the Resource Conservation and Recovery Act ("RCRA").
Information regarding the byproduct material to be disposed of should be received prior
to receipt of the shipment at the Mill, and shall include:
1. The volume qf material in cubic feet or yards, or quantity of drums and their
size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe,
etc.) . ' j • •
3. A description of the shipping container (i.e. end dump trailer, interrriodal
container, side dump container, etc.) j
4. jResiiltsI of analysis for Una^ Ra-226, TTv230 aiid Pb^O on all sJ^
and other material that is suited to sample collection. If a representative sample
of the material was taken in connection with a previous shipment of material,
then the results of that previous representative sample may be relied upon, and
may be referred to or restated in the documentation that accompanies the
shipment of the material. For byproduct material which is not suited to sample
"""^^ collection (i.e7lmetals^~"p^
will determine the range, the average and the total activity, measured in rmVhr at
a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment
and the anticipated shipping dalt. j
The RSO will also verify, prior to receipt of any shipment of byproduct rnaterial, that the
disposal of such byproduct material will not cause the Mill to exceed the limit of 5,000
cubic yards of byproduct material from a single source, set out in Mill License condition
10.5A I
P:\WP\Division ol Radiittion CominlV.Dcnison Minos. DUSA\Lic. LR.A & License .AmcnimentsMSL
Amendment for 20I0\DRC Markup Prop 11 c2 SOPs 12-1 -10 |
DR&R.1 •dochllp://iiUianot.denis(mminej;.eomA,4efiver/Executive/DA VB/Wtoc .Mesa M*
raeHitieii ond Mill Wnslc Di:;|nr;.al/PBL 10,1 lo f2i SOP Roy i (12 01 10) t2).doc
Comment [Rl]: Does DUSA require
oflier anaiytica] that shows that the
byproduct inaterial meets the RGRA
requirements. Also is there some type of
written profile of the material?
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1,2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 2 of 6
3.0 IPesigiiated jPisposal Area _ _ __________
The RSO will designate from time to time one or more designated disposal areas (each a
"Designated Disposal Area") being a general area within a tailings cell for the disposal of
byproduct material. Each Designated Disposal Ai-ea must meet the following criteria:
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings
cell that is not fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on
an area of the cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or
dikes of the tailings cell;
5. The elevation of the Designated Disposal Area once filled with byproduct
material must not exceed the plane or grade of the elevation of the uppermost
flexible membrane liner of the tailings cell;
Comnient [R2i::Defiik type of:
disposal, i.e. placed in a trench or piit on
the tailing beach and describe the
difenc^s for each t)T« 1
iiave seen evidence of botfi types of
disposal during my inspections.
7.
Detailed engineering drawings must have been prepared and kept on file at the
Mill that demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated
Disposal Area; and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the
sides or dikes of the tailings cells; and
Prior written approval must have been obtained from the Executive Secretary of
the Utah Radiation Control Board (the "Executive Secretary") for each
Designated Disposal Area, under Mill License condition 10.5C, and evidence of
s"uch approval m'usrbe^n"fiTe atlhe^Mill. "
4.0 Notification to Executive Secretarv
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the
proposed scheduled date for disposal of any byproduct material. Written evidence of this
notification will be kept on file at the Mill.
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale
house operator will provide hazard training for the driver. The driver will be
F:\WP\Division ol Radiittion ConLroi\Denisoii Mines, DUS.A\Lic. LR.A & License .AmendinentsMSL
Amendment for 2010\DRC .Markup Prop 1 le2 SOPs 12-1-10
DR&RJ•doetv^tf^//wk^^^^^e^.denis(>lw»+f^#^bem/de^vcr/Executivc^^ .Me-ia Mi-
lacilitioii and Mil! WiiJle Dii;po:ial/PBL I0__1 le (2) SOP Rev 1 (12 01 10) i2).doc
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 3 of 6
4.
5.
6.
provided with the Safety Training Form (copy attached). All drivers will be
required to read the Safety Training Form and sign and date the Safety Training
Form indicating that they understand and agree to follow DUSA's safety rules
and procedures while on company property. The scale house operator will sign
the Safety Training Form as the instructor for DUSA. Completed Safety
Training Forms will be tumed in to the Safety Department for future reference.
Inspect kll copies of the Shipping Manifest and the transporter's Bill of Lading to
ensure that the shipment is destined for the Mill and confirm with the RSO that
the shipment has been approved for receipt.
Record the inbound date and both the truck and trailer numbers on the Scale
house Weight Ticket (SWT).
Enter the loaded weight of the truck and trailer on the SWT.
The scale house operator will contact the Radiation Safety Department so that
the shipment can be escorted by Radiation Safety personnel to the Designated
Disposa] Area specified by the RSO.
Prior to transporting materiaU the driver wiilbe .instructed to.open (H: untarp ther
load. The Radiation Safetv personnel will visually inspect the byproduct
material to ensure- thai the mateiiai matches the material descri]?tion on the
shipping manifest. Anv discrepancies betv^-een the byproduct tiiateriai received
and.the manifest iirformation will be reported to the RSO.
a. Any byproduct material suspected not conforming to Section 2.0 of-*
this SOP will not be transported to the disposal site, unless a
determination is made bv the RSO that the material in question
conforms to Section 2.0 of this SOP.
b. BaiTcIs containing soil or sludges shall be checked to determine if thev-
arc full prior to transporting them for disposal. Barrels not completely
Yijij-^l^^jjf tailines or soil prior to
disposal. (License Condition 10.5.B).
1 Fbmiatted: Bullets and Numbering
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start
at: 1 + Alignment: Left + Aligned at:
1" -1- Tab after: 0" + Indent at:
1.25"
Formatted: Indent: Left: 1"
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start
at: 1 + Alignment: Left + Aligned at:
1" + Tab after: 0" + Indent at:
1.25"
6.0 Byproduct Material Unloading
1. The RSO will specify the specific location within the broader Designated
Disposa] Area for: disposal of the shipment. In designating the specific location
within the broader Designated Disposal Area for disposal of the shipment, the
RSO will ensure that all byproduct material will be segregated from any Mill
material and equipment disposed of in the cell pursuant to Mill license condition
F:\WP\Division ol'Radiaiion CtnurolxDcnison .Mines, DUS.A'',Lic. LR.A & License .Amendincnjji'dSL:
Amendment Ibr 2010\DRC .Markup Pi..)p 1 Ie2 SOPs 12-1-10
DR&R.l.d()ci^tp^Mianet.dcn44wwwH^t^fH¥iAienv^^ Mesa -N44t4/^44^-244"mff?-lj»L
ruciiiiie-i; and Mill Wai,lc P)!ipo:.al/PFjL 10. 1 lo (2) SOP Roy 1 112 01 10) t.2).doc
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Paee 4 of 6
10.4, and that the byproduct material from each in-situ leach source will be
segregated from the byproduct material from ea<rh-all other in-situ leach source;,.
Radiation Safety personnel will escort the shipment to the designated location in
the Designated Disposal Area for unloading of the byproduct material.
The shipment will be transported to the Designated Disposal Area only on
established roadways onto the tailings cells. At no time will a shipment be
transported over or in a manner that will damage unprotected dikes, liners, other
structures or settlement monitors associated with any of the tailings cells.
Prior to unloading, the driver will be inritructed to open or linttirp the load. The
Radiation Safety personnel will visually inspect the byproduct material to ensure
that the materia) tnatches the material description on the r,hipping manifof>t. Any
discrepancies—between—the—byproduct—material—received—and—the—manifest
infonnation will be reported to the RSO., An>- byproduct material suspected of
not meeting the require ments set forth in Section 2.0 of this SOP will be kept
segregated from other woste material until a determination is made of its
acceptability for dispoiuil.
If the 7 calendar day notice referred to in Section 4.0 above has not been given, or
the 7 days have not lapsed, then the shipment may be, but is not required to be
contained in the shipping container on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
If the shipment is determined to be acceptable, the following procedures will be
followed:
Formatted: Not Highlight
Formatted: Not Highlight
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar
days have lapsed, the byproduct material will then be unloaded in the designated
area. If such notice has not been given or if such 7 day period has not lapsed, then
the byproduct materia] will be unloaded in an area of the tailings cell that is not
covered with interim cover and from which the material can be removed if
necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the ,material is in a self-unloading container, the driver will be instructed to
unload ensuring all personnel are clear of the trailer and the immediate area.
Byproduct material will be dumped from the transport in a safe manner to
minimize dust. If the material requires unloading by a fork truck, a ramp will be
installed and unloading will proceed.
c) After unloading, the Radiation Safety personnel vvili visually in.spect the unloaded"
byproduct material to ensure that there is iio newly discovered material which
Anv does not match the material description on the shipping manifest.
FA\\T\Dmsignjjr Rju C(^niiol\Denison .Mines. DUS.AXLic. LR.A & License .AmendmentsMSL
Amendmenl for 20iO\DRC .Markup Prop 1 le2 SOPs 121-10
DR&RJ.d()cltftf^;//tt^tfa^^t4;-dtHHM4m .Me^u) Mil!/I \o.(2) I'ft^-lj^L
rueiliticii and Mill Wa:,le Di-;i^ii.'ial/PBL iO.J lo (2) SOP Rev 1(12 01 10) \.2).doc
Formatted: Indent: Left: 0.25",
I Hanging: 0.25"
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1,2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Pa.ee 5 of 6
discrepancies between the byproduct material received and the manifest
infomiation will be reported to the RSO. Any byproduct material suspected of
not meeting the requirements set forth in Section 2.0 of this SOP- will be kept
segregated from other waste material until a determination is made of its •
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached-
to the shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the-*
plat of each Desigriated Disposal Area illustrating the disposal area within the
Designated Disposal Area where the byproduct material will be disposed of.
f) Beta-gamma measurements will be taken at several locations around the unloaded*
material. This information will be recorded on the Radiatipn Department's copy
of the shipment documentation. The measurement range in mr/hr at 1 meter, and
the average measurement, measured in mr/hr at 1 meter, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at*
several locations around the unloaded material to ensure that there are no organics
present. The information will be recorded on the Radiation Department's copy of
the shipment documentation. If organics are detected, the RSO must be advised,
and no compaction or covering activities relating to the shipment shall occur until
specifically instructed by the RSO. The RSO will determine if any additional
safety precautions are required to be taken by workers or otherwise as a result of
the detection of the organics, and will implement any such precautions. The RSO
will also contact DUSA corporate regulatory personnel and the shipper to verify
that the detected organics are lie.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material
compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover*
activities. If the gross alpha exceeds 25% of the applicable DAC, then the RSO
will be notified; and all other unloading activities of byproduct material from that
particular ISL site will require the use of respiratory protection, until further
notice by the RSO.
i) |Disposa|l„ activities shall be documented through photogi;aphs, a written
description or both. They shall include:
How the material was placed in the tailing cells: *-
If void spaces were filled with tailings;
- How the area w^as compacted:
Document that the 4 foot tailing sands under the shipment was maintained
The shipment was properiy covered; and ,
Where settlement markers were placed.
F:\WP\Division of Radiation Control\Dcnison Mines. PUSAXLic. LR.\ &. License AmendmeritsMSL
Amendment for 201()\DRC .Maikup Prop 1 Ie2 SOPs 12-1-10
DR&R.l.i.lochttp:/,^'intranci.denirK')nmifle?^vt^m¥"denvci/B^^ Me.'
laeiliiie': and Mill Wa.'jie Dispoiial/'PBL i0_, 1 ie (2) SOP Rev ! (12 01 10) (2}.doc
Formatted: Indent: Left: 0.25"
Formatted: Indent: Left: 0.25"
Hanging: 0.25"
Formatted: Indent: Left: 0.25",
Hanging: 0.25"
Formatted: Indent: Left: 0.25", |
Hanging: .0.25"
1 Formatted: Indent: Left:
[Hanging: 0.25"
0.25"
Comment [R3]: this might-be a tietter
fit in a different spot of the SOP or
slightly different Janguage l)ut you get the
idea: The main thing is that the eiitire •
activity frorn accepumce to fmal ^
deposition needs to lie documented :
Formatted: Bulleted + Level: 1 -i-
Aligned at: 0.54" -i- Tab after: 0.79"
+ Indent at: 0.79"
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Paee 6 of 6
After unloading the byproduct material, replace the tarp or close the trailer, unless*
the trailer is being decontaminated for unrestricted release.
f)k)Direct the driver back to the scales for an empty weight. "
k^DThe scale house operator will record the empty weight on the appropriate SWT. *
Formatted: Indent: Left: 0.25"
i Hanging: 0.25"
Formatted: Indent: Left: 0.25"
Formatted: Indent: Left: 0.25"
7.0 Covering of Byproduct Material
"1. After the byproduct "material has been accepted by the RSO, or his designee, the
byproduct material will be spread within the designated area within the
Designated Disposal Area to facilitate compaction and covering.
2. . The byproduct material will be compacted with at least one pass of the
construction equipment .with the same requiretnents as prior to placing an
additional layer .License Condition 10.4A.
3. - Pj-ee volumes in the byproduct material will be minimized by filling, sectioning,
or crushing. Random fill or tailings will be used to fill voids in and around the
byproduct material.
4. All. contaminated equipment shall be dismantled, crushed, or sectioned to*
minimize void spaces. Barrels containing waste other than soil or sludges shall be
emptied into the disposal area and the banels crushed. Barrels containing soil of
sludges shall be verified to be full prior to disposal. Banels not completely full
shall be filled with tailings or soil.
3. A one foot thick, or thicker, cover comprised of native soil will be placed over the
byproduct material working area. The fill and cover material will be compacted
with at least one pass of the-construction equipment.
4. ' The; RSO' oi^ his designee'wilf ihspisct'the plaTcement of Ihe byprbduct^iriaterial
prior to covering to physically verify that the procedures in this Section 7.0 have
been adequately performed.
[ Formatted: Not Highlight
Formatted: Indent: Left: 0"
Hanging: 0.5"
F:\\VP\Division orRadiaiion ConuoiXDenisoii Mines, I^USAXLic. LRA License AmendmentsXlSL
Amendmenl for 2010\DRC .Markup Prop i Ie2 SOPs 12-1 - !0
DR&RJ.diK't^ttp^tfwtefflet.dcnisiWffl^^ lc.(2) fr-em-tSt^
faeiliiies and Mill WaiUe Disptv.al/PBL IOLMO (2) SOP Rov 1(12 01 10) (2,).doc
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1,2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 7 of 6
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the
Mill: Shippers or transporters will notify DUSA whether a specific trailer is to be
released for restricted or unrestricted use. Any trailers that are to be released for
restricted use will be decontaminated according to the requirements contained in DOT
Part 49 CFR 173.441(b) and 173.443. Any trailers that are to be released for unrestricted
use will be decontaminated according to the requirements found in Table 1 ofthe Nuclear
Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987. Trailers requiring repair will be decontaminated for
unrestricted release, to facilitate repairs by the transporter at the transporter's own site.
Trailers may be repaired without undergoing full decontamination if repaired within the
restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard
Operating Procedures for the appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
9.0 , Hazard Identification and Safetv
1. Required Personal Protective Equipment (PPE)
llni all areas of^the Mill covered J)y this procedui;e, hard hats^safety glasses mid
steel-toed shoes are required at a minimum. These must be wom in the restricted
area of the Mill.
2. Industrial Hazards and Safety
a) Use caution when the trailers are backing to the unloading area.
b) Ensure that all personnel within 50 feet of the area where an end dump trailer is
about to dump its load are aware that unloading is about to,commence. Move at
least 25 feet away from the rear of the trailer during the initial unloading
operation.
c) Drivers must use caution during the unloading process and be aware of any
overhead hazards.
d) Do not place any part of your body inside the trailer when the trailer is being
F:\WP\Division of Radiation Contiol\Denison Mines. PUSAXLic. LRA & License Amendments\lSL
Amen(Jinent for 20i()\DRC .Markup Prop 1 le2 SOPs 12-110
DR&R.l.dcK-fftlp:.^/iniianet.defti«4nRw^HTbWWelenveiv^ Mena Mill/1 ie.(2)-fiwThtSL
laeilitio^i and Mill Waste Disposal/PBL 10„ 1 lo (2) SOP Rov I (12 01 10) (2).doc
Comineht [R4]: Dry soils inight iieed
respirator protection ctr dust control - to
control airborne cMitamination and
exposure and should be evaluated by the
RSO prior to disposal
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 Ie.(2) Byproduct Pisposal
Pace 8 of 6
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off the equipment.
f) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be
driven to the shop for repairs. Otherwise, the equipment must be towed or
repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain
no one is in a dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of 15 m.p.h.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create
other hazards are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If
property damage or personal injury is involved, do not move the equipment until
your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
berms where required.
10.0 Documentation
1. For each shipment of byproduct material the following records will be maintained
F:\\VP\Pivision of Radiation ConiiolXDenison Mines. PUSAXLic. LR.A & License .AmendmentsMSL
Amendment for 2010\DRC Markup Prop I le2 SOPs 12- MO ,
DR&R.l.dochtH^-^i4Hfm>etTeleftise^w^ifles.convdenver-,^Hxec-u^ VE,AV^ite-!
facilitie;! and Wa::.ie DiL,i^o:;.nf/PBL I0._1 lo (2) SOP Roy l.( 12 01 I0).i2).doc
No.: PBL-10
Rev. No.: R-2
Date: Dec. 1, 2010
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Pisposal
Paee 9 of 6
in the Mill's Radiation Department files:
2.
3.
Shipper's Manifest and Bill of Lading.
Laboratory/activity analysis of the byproduct material performed by
the Shipper.
Completed SWT.
7-day notice to Executive Secretary.
Photo of the byproduct material.
Byproduct material radiological scan information.
Breathing zone monitoring data, if applicable.
Equipment release forms.
The Mill will maintain a plat of each Designated Disposal Area, which illustrates
the location of each shipment of byproduct material.
The Mill will maintain on file a copy of the Executive Secretary's written
approval of each Designated Disposal Area.
An annual sumLmai7 of the amounts of byproduct material disposed of in each
calendar year shall be sent to the Executive Secretary on or before November 1 of
the following calendar year. (Licen.se Condition IC'^F). Isummarv due same year]
F:\\VP\Division of Radiation ContiolXDenison .Mines, DUS.A'\Lic. 1-R.A & License .AmendinenlsMSL
Amendmenl for 20iO\DRC Markup Prop 1 ie2 SOPs 12-1-10 . .
DR&RJ.dtK-Mtfiht/wt4;tBetT^ftiiuini^^ MC-.a Mill/ I4^^^^fem-4SL
lacililio'-. and .Mill Wa:Me Dinposal/PBL 10.. ilo (2) SOP Rov 1(12 01 10) (2).doe
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you wilf be
required to follow while on our property.
1.0 General Safetv
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 m.p.h. Denison Mines (USA) Corp.'s equipment has the right of
way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safetv
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
INSPECTION REPORT
Inspection Module: RADMOD-AFIL-01: Alteinate Feed/ Insitu Leach Facility Materials
Inspection Location: Denison Mines-White Mesa Uranium Mill, Blanding Utah.
Inspection Items: Alteinate Feed Acceptance, Storage and Circuit and In-situ Leach (ISL)
Facility Material Acceptance and Disposal
Inspection Dates: September 1, 2009 and September 2, 2009
Inspectors: Ryan Johnson, Utah Division of Radiation Control (DRC)
Personnel Contacted: Dave Turk (RSO); Ryan Palmer (Environmental Coordinator)
Goveming Documents:
• UACR3I3-I5
• Radioactive Materials License (RML) UTI900479
• RML UTI900479 License Renewal Application (2/28/07)
Opening Meeting
Denison Mines: Dave Turk (Radiation Safety Officer)
Utah DRC: Ryan Johnson (DRC Inspector)
Kevin Carney (DRC Inspector)
During the opening meeting, the inspectors discussed the inspection items of each inspection
which include the documentation to be reviewed and the specific areas of the Mill that the
inspector wanted to see during the inspection.
Inspection Summary
The inspection consisted of reviewing the documentation that is required by the RML regarding the
acceptance and storage of alternate feed material and acceptance and disposal of ISL material, an
RSO interview and mill tour. The following discussion provides more detail of the specific items.
Item 1. Documentation:
Alternate Feed Documentation
The inspector reviewed the documentation for the Alternate Feed Material. The inspector observed
that there were two different files a paper file and a computer file. The paper file contained the
shipping papers of each shipment.
The computer file contained the following information:
• Date the shipment was received;
1 of Page 4
U;^QOLtMLrAnrupi)\LO(:ALS~lVlemp\XP^ip\visc\lns^^^^ Report RA1)M()P-AFIL-01 Rj.doc^-^d\^>N4MO-NA4.-iftwitfm
mill'AI !o(2)i-TM)(X).t7<> j)cTii;.(>n Mine;. While Mo!,a I'MiiAHP lru;pcc(i^iii modult:;.\2n()9\inNpecii()n RepoioAinspeeiioii Report RADMOl) \FIL 01
(W-KJ-.-dt)c
/I fi ,n
Net Weight (in lbs., kgs., tons and element weight) of each Shipment;
Running total of each weight;
The number of Units (e.g. drums);
Corresponding Transportation number;
Corresponding Bill of Lading number for each shipment; and
A brief description of the Alternate Feed material.
ISL Material Documentation (License Condition 10.5.D)
The inspector reviewed the documentation for the ISL Material for 2008 and 2009. The inspector
observed that there were two different files, a paper file and a computer file. In the paper file the
following were observed for each shipment:
• Shipping Papers (Bill of Lading);
• Description of each shipment;
• Photographs of each shipment with radiological readings and PID readings of each
shipment written on the photographs;
• Tare Tickets;
• Date of Each Shipment; and
• A waste profile with analytical information (multiple shipments per profile).
The computer file contained the following information:
• Date the shipment was received;
• Net Weight (in lbs, tons and cubic yards) of each Shipment;
• Running total of each weight;
• Corresponding Bill of Lading number for each shipment; and
• A brief description of the waste received.
Deficiencies:
The inspector observed that the ISL documentation (License Condition 10.5.D) did not include:
• Description (i.e. narrative and/or photographs) of how ISL material being placed in the slit
trenches on tailings Cell #3;
• Descriptions of other activities (i.e. Barrels not being completely full being filled with
tailings or soil as described in License Condition I0.5.B).
Item 2. RSO Interview:
The RSO and inspector discussed PPE requirements, postings, air monitoring, and area gamma
monitoring within the Alternate Feed Circuit and how these requirements will be adjusted to meet
the specific needs for different Alternate Feed materials with RWPs or Specific SOPs for each
Alternate Feed material. The inspector also discussed with the RSO and the Environmental
Coordinator how ISL material is accepted and disposed of in Tailing Cell #3. During these
discussions the following steps were outlined:
• The generator will send a waste profile to White Mesa for review;
• Truck Shipments will contain soil, trash (i.e. filters, hoses, PPE), and drums full of
miscellaneous debris;
2 of Page 4
QMX:UME-l\Drupp\LOCALS~IVTcmp\XPgrp\vise\lnspectioti Reixiri RAJ..)N_10D-AF1L-()1 9-^;-()') RJ.docUi\fad>mMMONUj<^aw«TH
niilis\ i ]cr2>l iTI'n)()47'> Di'iiison Mi'ies While Mt:;nJ UMill\HP lm;peeiion mixlule;v,2()()9\ln;:peei)un RepoiijMnMpoeiion Report RADMOl) AFIL 01
i^->v-09-l^:l^)e
• A trench will be dug in tailings Cell #3 until liquid appears. Typically the trenches are 10
feet wide and 8 feet deep;
• Each shipment is surveyed for radiological contaminates and volatile organic compounds;
• Soils and trash are dumped out into the trenched and covered. Drums are transferred to a
flatbed truck and then placed into the trench using a crane arm with a barrel clamp and
tagline. Then the drums are crushed with a CAT. The Trench is then backfilled and
recompacted.
• The trench coordinates are surveyed and the location of the trench is entered on the plat of
the site.
Also the RSO referred the inspector to Standard Operating Procedure PBL-10 l le(2) Byproduct
Disposal Rev 1. on how ISL material is to be handled.
Deficiencies: None
Item 3. Mill Tour:
The inspector went through the restricted area on a general site tour. Currently the main Milfis not
processing ore and different areas within the mill buildings are under renovation, repair and
cleaning. The tour focused on the new Alternate Feed Circuit but also included the ore pad, the ore
receiving trailer, the new decon pad, the mill and the tailings ponds.
While walking through the Mill's new Alternate Feed Circuit the inspectors observed the
following:
• The Cameco UF4 Alternate Feed material (License Condition 10.11) was being processed;
• PPE being wom by Mill workers in different nodes (areas) of the Alternate Feed Circuit;
• Posting in the different nodes of the Alternate Feed Circuit;
• The Air Monitoring within the Altemate Feed Circuit are done with portable (low volume)
air sampling pumps and are placed in the work areas where Mill workers are working; and
• The area gamma monitor being used at the Altemate Feed Circuit is a TLD type monitor
and is located by the control panel of the drum dumping node.
While driving through the tailing cells the inspector observed the following:
• Empty slit trenches on Tailing Cell #3 waiting for ISL material to be placed in them;
• The Cameco UF4 Altemate Feed material being stored on Tailings Cell #2. The inspector
verified that the area was properly posted and observed that the Altemate Feed material was
packed in overpack containers.
The inspector was not able to observe ISL material being placed in the slit trenches due to that
work activity was not going on that day.
Other observations made during the mill tour included:
• Other Altemate Feed materials being stored on the ore pad;
• PPE being wom by Mill workers in the main mill; and
• The new scale at the scale house being readied to be installed.
Deficiencies: None
3 of Page 4
(::\[>0(.:UMH~i\L)rupp\L0(:ALS~l\Temp\XP!2i-p\vise\insix'etioii Repon RAD,M01)-AFIL-Ol 9-8-09 RJ.ckx-yAft«j\€0{V^N40N\ttf;fflitim
rnitl'AI le(2jt •TI9C)()479 Deni-.on M'»m. W hite Mesu t '.Mill'vHP Inrtpoetion modiile-i;\2(K)9\ln;,peetioii ReponiAlnsptiction Rvpon RADMOD .AFIL Oi -
Closeout Meeting
Denison Mines: Dave Turk (RSO)
Rich Bartlett (Mill Manager)
Utah DRC: Ryan Johnson (Inspector)
Kevin Camey (Inspector)
Findings
None
Conclusions and Recommendations
During the close out meeting the DRC inspector made the following recommendations regarding
items for improvement:
1. Put larger postings of the PPE requirements in the new Altemate Feed Circuit to make them
easier to read.
2. Document the placement of ISL material in tailing Cell #3 with a detailed description all
disposal activities involved with the disposal of each shipment. License Condition 10.5.D
states "All disposal activities shall be documented."
Recommendation for Next Inspection
1. Observe ISL material being placed in slit trenches on Tailing Cell #3
2. Employee Exit Monitoring
3. Evaluation of Designated Eating Areas within the Restricted Area
4. Spills (yellowcake and other materials) being cleaned up in the mill immediately
Prepared By: Ryan Johnson 9/9/09
(Print Name) (Signature) (Date)
4 of Page 4
C::\l.X)CUME~l\Drupi)\LX)CAl.S~l\remp\XPaip\vise\lnspeelion Report RAPMOD-AFIL-01 9-8-09 RJ docl-:\rad\C(.)VtMON^4:H:am^m
mill?,\l lo(2,itJTI900479 Deni-.on Mine.v White Me-!,a t'.Mill\HP liu^pcaion module-;\2(X>9\ln:jpection ReporuAln-ipeLiion Report RADMOD ,\FIL 01
•9-K4)9-R4.defc-