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HomeMy WebLinkAboutDRC-2010-006234 - 0901a068801e5e06C- 2010-006X3J DENISO MINES Sent VIA Federal Express December 1, 2010 Received ^ DEC 2010 1^ Division of ^"v) Radiation Control Denison Mines (USA) Corp. 105017th Street, Suite 950 Denver, CO 80265 USA Tel: 303 628-7798 Fax : 303 389-4125 www.denisonmines.com Mr. Rusty Lundberg Co-Executive Secretary Utah Water Quality Board Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144810 Salt Lake City, UT 84114-4820 Re: Transmittal of Draft Movement Monitor and Settlement Monitor SOPs and Revised 11 e.(2) SOP; White Mesa Mill Radioactive Materials License UT1900479 Dear Mr. Lundberg: Enclosed are copies of the following Standard Operating Procedures (SOPs) for Denison Mines (USA) Corp.'s White Mesa Mill required by the Utah Division of Radiation Control ("DRC") under Radioactive Materials License No. UTI900479 (the "RML") as indicated below: • One initial draft of a Settlement Monitoring SOP as required by RML Condition 11.7 • One initial draft of a Movement (Displacement) Monitoring SOP as required by RML Condition 11.8 • One clean and one redline revision (No.2) of 1 le.(2) SOP as required by RML Condition 10.5E and by a letter and Request for Information of March 1, 2010 from David Rupp of DRC. The revised 1 le.(2) SOP Revision No. 2 is redlined to indicate all changes since the existing approved October 24, 2008 Revision NO. 1. If you should have any questions regarding these documents please contact me. Yours very truly, P DENISON MINES (USA) CORP. Jo Aim Tischier Director, Compliance and Permitting CC: David C. Frydenlund Harold R. Roberts David E. Turk Kathy Weinel DENISO MINES White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 1 of 4 SETTLEMENT MONITORING STANDARD OPERATING PROCEDURES 1. SETTLEMENT MONITORING 1.1 Purpose This Standard Operating Procedure (SOP) describes the vertical monitoring of the Settlement Monitors that are placed within the tailings management cell areas. This SOP will also indicate how and where to document the findings. All data collected for these purposes, as described below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to License Condition 12.3 of the Radioactive Materials License (RML). 1.2 Locations and Frequency of Monitoring Settlement Monitors are located on covered tailings cells and shall be surveyed on a monthly basis by the Environmental Department staff and armually by a Utah Licensed Professional Land Surveyor. For any new Settlement Monitor installed (after June, 2010), within 30 days of the installation, a Utah Licensed Land Surveyor will survey the monument. The locations of new Settlement Monitors will be designated by the Mill Engineer as the intermediate cover is advanced over tailings. As stated above, Settlement Monitors will be placed on the tailing cells when temporary cover is being advanced on the placed tailings. Settlement Monitors are also required on In-situ leach (ISL) source disposal areas that have been closed to ftirther disposal pursuant to RML condition 10.5.A. Settlement monitors will be installed and surveyed by a Utah Licensed Land Surveyor within 30 days of the completion of each ISL disposal area, and then annually after that point. One Settlement Monitor will be required for approximately every 22,500 square feet or 5,000 cubic yards of ISL material. These monuments will be uniquely labeled to identify the specific ISL material. For ISL source disposal areas or trenches completed before April 1, 2010, the required settlement stands will be placed and the initial elevation survey completed prior to June 1, 2010. N:\SOPs and Procedures\Drafl tailings SOPs Nov 2010\Section 5 0 Settlement Monitoring SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 2 of 4 1.3 Design of Settlement Monitors Each Settlement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing animals and other environmental factors. The design is a 2'x2' steel plate with a 1" steel pipe welded to the center ofthe plate. This steel plate will be positioned by digging straight down in the desired location until tailing sands are contacted. Upon contacting the sands, the steel plate and pipe are lowered and placed on top of the sands. The hole will then be backfilled to within two feet of the ground surface. At this point, a 3" steel outer casing will be placed over the 1" inner pipe. After this has been completed, the last two feet of material will be backfilled. The top of the 3" casing will be threaded to allow for a cap to be installed. The settlement monitors will have the threaded caps, lubricated on an as needed basis, to allow the cap to be removed during the survey process. In order to protect the settlement monitors fi-om man-caused damage, each settlement will be bounded on three sides. This bounding will prevent equipment from accidentally coming in contact with the settlement monitor. These devices will consist of three 3" steel pipes that will be cemented into the ground. The interior of the pipe will also be filled with concrete. The barriers will then be painted red as a visual reminder. If damage, by any source, has occurred, the information will be documented and immediately tumed in to the RSO, or designee. The RSO, or designee, will make notification to the Corporate Compliance Director and a corrective action plan will be created for repairs and the surveying and documentation of those changes. 1.4 Monthly Surveying (i) The monthly survey will be performed by the Mill's Radiation Safety Officer or designee (the "Surveyor") with the assistance of another Mill worker (the "Assistant"); (ii) The survey will be performed using a survey instrument accurate to 0.1 feet, such as a Sokkai No. B21, or equivalent, together with a survey rod having a visible scale in 0.1 foot increments; (iii) The reference points are known points established by a professional survey. (iv) The surveyor will set up the survey instrument in a location where both the applicable reference point and settlement monitor are visible. (v) Once in location, the surveyor will ensure that the survey instrument is level by centering the bubble in the level gauge on the survey instrument; (vi) The assistant will place the survey rod vertically on the reference point. The assistant will ensure that the survey rod is vertical by gently Tocking the rod back and forth until the surveyor has established a level reading; (vii) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "reference point N:\SOPs and ProceduresVDraft tailings SOPs Nov 2010\Section 5 0 Settlement Monitoring SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 3 of 4 reading"), which represents the niunber of feet the survey instrument is reading above the reference point; (viii) The assistant will then move to a designated settlement monitor. Once at the monitor, the assistant will remove the steel cap and place the survey rod on top of the 1" irmer pipe. A few of the original settlement monitors do not have an inner pipe. For original settlement monitors without a 1" irmer pipe, the assistant will place the survey rod on the lip of the settlement monitor; (ix) The assistant will hold the rod vertically and will ensure the survey rod is vertical by gently rocking the rod back and forth until the Surveyor has established a level reading; (x) The surveyor will focus the cross hairs of the survey instrument on the scale on the survey rod, and record the number (the "surface reading"), which represents the number of feet the survey instrument is reading above the settlement monitor. The surveyor will calculate the elevation of the settlement monitor by adding the reference point reading to the reference point elevation and then subtracting the surface reading for the settlement monitor, and will record the number accurate to 0.1 feet. The elevation information will be maintained within the Environmental Department records. The monthly documentation of the readings will be recorded on the Monthly Tailings Inspection Form. The form can be found in Section 3.1 of the Environmental Protection Manual. 1.5 Monitoring and Maintenance of Settlement Monitors 1.5.1 Monitoring and Documentation of Condition of Devices The Movement Monitors will be maintained so that the monuments remain in reliable, good working condition. Conditions at and in the vicinity of the monitoring devices will be inspected monthly by Enviroimiental Department staff. Any observations will be recorded on the monthly tailings inspection report form. On an annual basis, each monument will be photographed to document conditions at the monitoring areas. Additionally, photographs will be taken following any instances of unusually severe weather or incidents involving equipment if they result in physical damage or disturbance to any settlement monitoring device, or significant changes to the ground areas adjacent to or surrounding the settlement monitor. 1.5.2 Maintenance of Monitors If any settlement monitoring device is irreparably damaged as a result of environmental stresses or man-caused contact, it will be promptly replaced with an identical or equivalent device. The N:\SOPs and ProceduresVDraft tailings SOPs Nov 2010\Section 5 0 Settlement Monitoring SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.0 Page 4 of 4 replacement device will be placed in the same location from which the damaged device was removed. Data from the new device will be correlated to data fi-om the removed damaged device as follows: 1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the location of the new device as well as that of the nearest (undamaged) devices on either side ofthe new device. 2. If the survey indicates there has been less than 0.1 foot of vertical change in the location of the undamaged devices, no adjustment will be made to the survey data of the new device. 3. If the survey indicated 0.1 foot or greater of vertical change to either of the imdamaged devices, the survey results for the new device will be adjusted by the average change observed in the two adjacent devices. This adjustment will be documented in the Utah- Licensed Land Surveyors report and in the annual ATER. 1.6 Performance Criteria and Data Validation When the monthly data has been collected, the information will be reviewed for any errors and/or major changes in the vertical movement on the settlement monitors. If there is a difference of 0.1 foot, then the corrective actions will be taken as follows: 1 Resurvey the settlement monitor that shows vertical movement of 0. foot. 2 Document site conditions. 3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e. man-caused contact, environmental stresses, or burrowing animals, etc.). 4 Report this information to the Executive Secretary within a timely manner and include in that notification the investigation steps, movement evaluation, and corrective action steps. On an annual basis, a Utah Licensed Professional Engineer shall review and analyze the data and then certify the data, which will be submitted as part of the ATER as required by RML Condition 12.3. N:\SOPs and ProceduresVDraft tailings SOPs Nov 2010\Section 5 0 Settlement Monitoring SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.1 Page 1 of 3 MOVEMENT (DISPLACEMENT) MONITOR STANDARD OPERATING PROCEDURES 1. MOVEMENT (DISPLACEMENT) MONITOR 1.1 Purpose This Standard Operating Procedure (SOP) describes methods for monitoring the vertical and horizontal movement of Movement (Displacement) Monitors that are placed along the constructed dike portions of the tailings cells. All data collected for these purposes, as described below, will be included in an Annual Technical Evaluation Report (ATER) to be submitted to the Executive Secretary of the Utah Division of Radiation Control (the Executive Secretary) pursuant to License Condition 12.3 of the Radioactive Materials License (RML). 1.2 Locations and Frequency of Monitoring Within 30 days of completion of construction activities. Movement Monitors will be installed and surveyed by a Utah Licensed Land Surveyor. The installation of these movement monitors will be along the exposed dike of the tailing cells. All new movement monitors (installed after June, 2010) will be surveyed by a Utah Licensed Land Surveyor semi-annually for the first three years. After three years, each new movement monitor (installed after June, 2010) will be surveyed annually. All existing movement monitors (installed prior to June 2010) will be surveyed on an annual basis. On an annual basis, a Utah Licensed Professional Engineer will review, analyze, and certify the data which will be submitted as part of the ATER as required by RML License Condition 12.3. 1.3 Design of Settlement Monitors Each Movement Monitor is built to be resistant to shifting due to frost heave, erosion, burrowing animals and other environmental factors. The Movement Monitor placement will be established by digging a hole in the desired location, to minimize accidental damage to the monument. A piece of rebar, 24 inches in length, will be driven into the hole. The hole will be back filled and the top of the rebar will be below surface grade. Each monvunent will be individually tagged and numbered. N:\SOPs and ProceduresVDraft tailings SOPs Nov 2010VSection 5 1 Movement Monitor SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.1 Page 2 of 3 1.4 Monitoring and Maintenance of Movement Devices 1.4.1 Monitoring and Documentation of Condition of Devices The Movement Monitors will be maintained so that the monuments remain in reliable, good working condition. Conditions at and in the vicinity of the monitoring devices will be inspected by the Utah-Licensed Land Surveyor on the same schedule as the surveys discussed in Section 1.2, and documented in the surveyor's written reports and in the annual ATER. 1.4.2 Maintenance of Monitors The Movement Monitors will be installed in such a way to prevent damage by equipment. The Movement Monitors will be installed such that the monument is below the actual ground surface level, so the potential for damage by equipment is minimized. However, if a monument is disturbed, the information will be immediately given to the RSO, or designee. The RSO, or designee, will make notification to the Corporate Compliance Director and a corrective action plan will be created for repairs and the surveying and documentation of any changes. If any Movement Monitoring device is irreparably damaged as a result of environmental stresses or man-caused contact, it will be promptly replaced with an identical or equivalent device. The replacement device will be placed in the same excavated hole from which the damaged device was removed. Data from the new device will be correlated to data from the removed damaged device as follows: 1. When a new device is installed, a Utah-Licensed Land Surveyor will survey and map the location of the new device as well as that of the nearest (undamaged) devices on either side of the new device. 2. If the survey indicates there has been less than 0.1 foot of vertical or horizontal change in the location of the undamaged devices, no adjustment will be made to the survey data of the new device. 3. If the survey indicated 0.1 foot or greater of vertical or horizontal change to either ofthe imdamaged devices, the survey results for the new device will be adjusted by the average change observed in the two adjacent devices. This adjustment will be documented in the Utah-Licensed Land Surveyors report and in the annual ATER. 1.5 Documentation The Utah Licensed Land Surveyor will provide a written report of their findings along with a map depicting the locations in relationship to the tailings cells. A brief summary of work and analytical data will be provided in a written report by the Utah-Licensed Land Surveyor. All documentation will be housed at the White Mesa Mill in the Environmental Department files for inspection. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VSection 5 I Movement Monitor SOP Nov 2010.doc White Mesa Mill - Standard Operating Procedures Date: 11/2010 Revision: DUSA-1 Book #11: Environmental Protection Manual, SOP Section 5.1 Page 3 of 3 1.6 Performance Criteria and Data Validation The data will be reviewed for any errors and or major changes in the vertical movement on the movement monitors. If there is a difference of 0.1 foot, then the corrective actions will be taken as follows: 1 Resurvey the movement monitor that shows vertical movement of 0.1 foot. 2 Document site conditions. 3 Prepare a document to the Corporate Compliance Director stating possible causes (i.e. man-caused contact, environmental stresses, or burrowing animals, etc.). 4 Report this information to the Executive Secretary within a timely manner and include in that notification the investigation steps, movement evaluation and corrective action steps. Movement monitors that show vertical movement of 0.2 foot or greater for two consecutive monitoring periods may be subject to accelerated monitoring at a frequency and in a manner approved by the Executive Secretary. On an annual basis, a Utah Licensed Professional Engineer will review, analyze, and certify the data which will be submitted as part ofthe ATER as required by RML License Condition 12.3, along with a description of any corrective actions performed. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VSection 5 1 Movement Monitor SOP Nov 2010.doc No.: PBL-10 DENISON MINES (USA) CORP. Rev. No.: R-i2 STANDARE 1 OPERATING PROCEDURES Page I of 6 Date: ©etDec. 341, Title: 1 le.(2) Byproduct Disposal 200«10 1.0 Purpose Denison Mines (USA) Corp. ("DUSA") receives lle.(2) byproduct material ("byproduct material") from uranium in-situ leach operations for disposal under License Condition 10.5. The 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 ofthe U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct material does not contain hazardous waste as defined in the Resource Convsersvation and Recovery Act ("RCRA"). Information regarding the byproduct material to be disposed of should be received prior to receipt of the shipment at the Mill, and shall include: 1. The volume of material in cubic feet or yards, or quantity of drums and their size. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.) A description of the shipping container (i.e. end dump trailer, intermodal container, side dump container, etc.) Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other material that is suited to sample collection. If a representative sample of the material was taken in connection with a previous shipment of material, then the resuhs of that previous representative sample may be relied upon, and may be referred to or restated in the documentation that accompanies the shipment of the material. For byproduct material which is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the Shipper will determine the range, the average and the total activity, measured in mr/hr at a range of one meter, for each shipment. L A copy of the completed shipping manifest that will accompany the shipment and the anticipated shipping date. ^ The RSO will also verifV. prior to receipt of anv shipment of byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the limit of 5,000 cubic yards of byproduct material fi'om a single source, set out in Mill License condition 10.5A N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1 (12 0110) 2. 3. 4. (2).dochttp://intranet.dcni5 i.com/denvcr/Executive/DAVEAVhite Mesa Mill/1 le.fll from jSfc facilities and Mill Woflto Disposal/PBL 10 1 lc (2) SOP Rev 1 (12 01 10) (21docZ:VDAVEVWhite Mesa MillVl le.(2) from ISL facilities and Mill Waste DisposalVPBL 10_1 le (2) SOP Rev 1 (10.29.08).doc No.: PBL-IO DENISON MINES (USA) CORP. Rev. No.: R-42 STANDARD OPERATING PROCEDURES Page 2 of 6 Date: OetDec. 341, Titte: 1 le.(2) Byproduct Disposal 20e«I0 3.0 Designated Disposal Area The RSO will designate from time to time one or more designated disposal areas (each a "Designated Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following criteria: 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 ofthe 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 fi'om the sides or dikes of the tailings cell: 6. 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: 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 The bottom ofthe 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 such approval must be on file at the Mill. 7. 4.0 Notification to Executive Secretary DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any byproduct material. Written evidence of this notification will be kept on file at the Mill. 3^5.0 Byproduct Material Receiving N:VS0Ps and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 le (2) SOP Rev 1 (12 01 10) (2).dochttp://intranet.denisonmines.com/denver/Executivo/DAVEAVhite Mesa Mill/1 le.(2) from ISL facilities and Mill Waste Disposal/PBL 10 lie (2) SOP Rev 1 (12 01 10) (2).docZ:VDAVEVWhite Mesa MillVl le.(2) from ISL facilities nnd Mill Waste DisposalVPBL 101 lo (2) SOP Rev 1 (10.29.08).doc No.: PBL-10 DENISON MINES (USA) CORP. Rev. No.: R-t2 STANDARD OPERATING PROCEDURES Page 3 of 6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 206810 4. 5. When each truck driver enters the restricted area for the first time, the scale house operator will provide hazard training for the driver. The driver will be provided with the Safety Training Form (copy attached). All drivers will be required to read the Safety Training Form and sign and date the Safety Training Form indicating that they understand and agree to follow DUSA's safety rules and procedures while on company property. The scale house operator will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training Forms will be tumed in to the Safety Department for future reference. Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm with the RSO that the shipment has been approved for receipt. Record the inbound date and both the truck and trailer 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 dDisposal aArea in Cell 3 specified by the RSO. 4.^6.0 Byproduct Material Unloading I, _Radiation Safety personnel will escort the shipment to the designated looation in Cell 3 for unloading of the byproduct matcrial.The RSO will specify the specific location within the broader Designated Disposal Area for disposal of the shipment. In designating the specific location within the broader Designated Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill license condition 10.4. and that the byproduct material from each in-situ leach source will be segregated from the byproduct material from each other in-situ leach source. 4^ -Radiation Safetv personnel will escort the shipment to tho designated looation in the Designated Disposal Area for unloading of the byproduct materialv 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 anv of the tailings cells. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1(12 01 10) (2).doclrttp://intranot.deni5onmines.oom/denver/Exeoutive/DAVE/White Mesa Mill/1 le.(2) frorH4SL facilities and Mill Waste DisposaVPBL-10 1 lc (2) SOP Rev 1 (12 01 10) (2).docZ:VDAVEVWhito Ntoaa MillVl le.(2) from ISL facilities und Mill Waste DisposalVPBL 10_1 le (2) SOP Rev 1 (10.29.08).doc 2. 3. No.: PBL-IO DENISON MINES (USA) CORP. Rev. No.: R-42 STANDARD OPERATING PROCEDURES Page 4 of 6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 206810 3v4^__Prior to unloading, the driver iswill be instructed to open or untarp the load. The Radiation Safety personnel will visually inspect the byproduct material to ensure that the material matches the material description on the shipping manifest. Any discrepancies between the byproduct material received and the manifest information will be reported to the RSO. Any byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste material until a determination is made of its acceptability for disposal. 5. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 davs have not lapsed, then the shipment may 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 davs have lapsed. .If the shipment is determined to be acceptable;- the following procedures will be followed: If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed, the byproduct material iswill then be_unloaded in the designated area. If such notice has not been given or if such 7 day period has not lapsed, then ai the byproduct material will be unloaded in an area of the tailings cell that is not covered with interim cover and from which the material can be removed if necessary. Once the required notice has been given and the required 7 days have lapsed, the byproduct material will then be placed into the designated area. 3^b}___If the material is in a self-unloading container, the driver iswill 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. 4zc} After unloading, a photo of the unloaded material will be taken which is attached to the shipping documentation for verification of shipment contents. d) The location of the shipment of the byproduct material will be documented on the plat of €eH-^each Designated Disposal Area illustrating the disposal area within the Designated Disposal Area where the byproduct material will be disposed ofal &7e} Beta-gamma measurements will be taken at several locations around the unloaded material. This information will be recorded on the Radiation N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1(12 01 10) (2).dochttp://intranet.denisonmines.oom/denver/Executivo/DAVE/White Mesa Mill/1 le.(2) from4Sfc facilities and Mill Waste Disposal/PBL-10 1 le (2) SOP Rov 1 (12 01 10) (2).docZ:VDAVEVWhite Mesa MillVl le.(2) ftom ISL facilities and Mill Waste DisposalVPBL 10_1 le (2) SOP Rov 1 (10.29.08).doc No.: PBL-IO DENISON MINES (USA) CORP. Rev. No.: R-42 STANDARD OPERATING PROCEDURES Page 5 of 6 Date: OetDec. 341, Title: le.(2) Byproduct Disposal 200810 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 I meter, shall be recorded. TrflMeasurements using a photoionization detection meter ("PID") will be taken at several locations around the unloaded material to ensure that there are no organics present. The information will be recorded on the Radiation Department's copy of the shipment documentation. If organics are detected, the RSO must be advised, and no compaction or covering activities relating to the shipment shall occur until specifically instructed by the RSO. The RSO will determine if any additional safety precautions are required to be taken by workers or otherwise as a result of the detection of the organics, and will implement any such precautions. The RSO will also contact DUSA corporate regulatory personnel and the shipper to verify that the detected organics are lle.(2) byproduct material from the shipper's ISL facility. Once the RSO has verified that the organics are ^byproduct Mmaterial compaction and covering activities will proceed. ^£i__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. 9.h) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is being decontaminated for unrestricted release. ^^iL__Direct the driver back to the scales for an empty weight. SWT. _The scale house operator will record the empty weight on the appropriate 5^7.0 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 prior to placing an additional layer. 3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing. Random fill or tailings will be used to fill voids in and around the byproduct material. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1 (12 01 10) (2).dochttp://i^tra^et.deniso^mi^os.conl/donvor,'Executive/DAVEA^^lite Mesa Mill/1 lo.(2) from ISL facilities and Mill Waste Disposal/PBL 10 1 lo (2) SOP Rov 1 (12 01 10) (2).docZ:VDAVEVWhite Mesa MillVl le.(2) from ISL facilities and Mill Wasto DisposalVPBL 101 le (2) SOP Rov 1 (10.29.08).doc No.: PBL-10 DENISON MINES (USA) CORP. Rev. No.: R-42 STANDARD OPERATING PROCEDURES Page 6 of 6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 200810 4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior to disposal. Barrels not completely full shall be filled with tailings or soil. _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. 5T The RSO or his designee will inspect the placement of the byproduct material prior to covering to physically verify that the procedures in this Section 7.0 have been adequately performed. N:VSOPs and ProceduresVDraft tailings SOPs Nov 201OVPBL-10 11 e (2) SOP Rev 1 (12 01 10) (2).dochttp://intranet.deniaonmine5.coni/denver/Exeoutive/DAVE/White Mesa Mill/1 le.(2) from ISL facilities and Mill Waste Disposal/PBL 10 1 le (2) SOP Rev 1 (12 01 10) (2).docZ:VDAVEVWhitc Mesa MillVl lo.(2) from ISL facilities and Mill Waste DisposalVPBL 101 lo (2) SOP Rev 1 (10.29.08).doc No.: PBL-10 DENISON MINES (USA) CORP. Rev. No.: R-4-2 STANDARE OPERATING PROCEDURES Page 7 of 6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 200810 6;;O8.0 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 unresfricted use. Any trailers that are to be released for restricted use will be decontaminated according to the requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers that are to be released for unrestricted use will be decontaminated according to the requirements found in Table 1 of the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Terminadon of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987. Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired without undergoing full decontamination if repaired within the restricted area of the Mill. For the appropriate decontamination procedures, refer to the following Standard Operating Procedures for the appropriate conveyance: End Dump Trailer SOP PBL-9 Intermodal Container SOP PBL-2 Standard Container Trailer SOP-PBL-2 7i09.0 Hazard Identification and Safetv 1. Required Personal Protective Equipment (PPE) In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes are required at a minimum. These must be wom in the restricted area of the Mill. 2. Indusfrial Hazards and Safetv Use caution when the trailers are backing to the unloading area. a) 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. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1(12 01 10) (2).dochttp://intranet.denisonmines.coni/denyer/Executive/DAVE/White Mesa Mill/1 le.(2) from ISL facilities and Mill Waste Disposal/PBL-10 1 le (2) SOP Rev 1(12 0110) (2).docZ:VDAVEVWhito Mesa MillVl le.(2) from ISL facilities and Mill Waste DisposalVPBL 10_1 le (2) SOP Rev 1 (10.29.08).doc No.: PBL-IO DENISON MINES (USA) CORP. Rev. No.: R-42 STANDARD OPERATING PROCEDURES Page 8 of6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 200810 d) Do not place any part of your body inside the trailer when the trailer is being tipped and the tailgate is open. Only work around the tailgate after it has been properly blocked open. e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. 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. 8^10.ODocumentation N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 1 le (2) SOP Rev 1 (12 01 10) (2).dochttp://intranet.denis i.oom/denver/Exeoutive/DAVE/White Mesa Mill/1 le.(2) from ISL facilities ond Mill Waste Disposal/PBL 10_lle (2) SOP Rev 1 (12 01 10) (2).docZ:VDAVEVWhito Mesa MillVl le.(2) from ISL facilities and Mill Waste DisposalVPBL 10_1 lc (2) SOP Rev 1 (10.29.08).doc No.: PBL-IO DENISON MINES (USA) CORP. Rev. No.: R-1-2 STANDARD OPERATING PROCEDURES Page 9 of 6 Date: OetDec. 341, Title: 1 le.(2) Byproduct Disposal 200810 2. 3. For each shipment of byproduct material the following records will be maintained in the Mill's Radiation Department files: • Shipper's Manifest and Bill of Lading. • Laboratory/activity analysis of the byproduct material performed by the Shipper. • Completed SWT. • 7-day notice to Executive Secretary. • Photo of the byproduct material. • Byproduct material radiological scan information. • Breathing zone monitoring data, if applicable. • Equipment release forms. _The Mill will afee-maintain a plat of €etl-4each Designated Disposal Area, which illustrates the location of each shipment of byproduct material. The Mill will maintain on file a copy of the Executive Secretary's written approval of each Designated Disposal Area. An annual summary of the amounts of byproduct material disposed of in each calendar year shall be sent to the Executive Secretary on or before November 1 of the following calendar year. 2.4. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10 lie (2) SOP Rev 1 (12 01 10) (2).dochttp://intranet.denisonmines.com/denvcr/Executive/DAVE/Whitc Mesa Mill/1 le.(2) from ISL facilities and Mill Wa.stc Disposal/PBL-10 lie (2) SOP Rev 1 (12 01 10) (2).docZ:VDAVEVWhite Mesa MillVl le.(2) from ISL facilities and Mill Waste DisposalVPBL-10_l le (2) SOP Rev 1 (10.29.08).doc SAFETY TRAINING FOR DELIVERV 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 mles and procedures, which you will 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 tuming over while dumping. Ensure that the truck is on level ground and brakes are set prior to dumping. 5. Check for potential overhead hazards prior to dumping. 6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must be lowered. 7. Be aware of slippery conditions on the ore pad during periods of inclement weather. 8. Be aware of the potential for ice build-up on and around the decontamination pad during periods of cold weather. 9. Use caution when entering or exiting equipment. 2.0 Radiation 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 No.: PBL-10 Rev. No.: R-2 Date: Dec. 1,2010 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: lle.(2) Byproduct Disposal Page 1 of 6 1.0 Purpose Denison Mines (USA) Corp. ("DUSA") receives lle.(2) byproduct material ("byproduct material") from uranium in-situ leach operations for disposal under License Condition 10.5. The 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 ofthe U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act ("RCRA"). Information regarding the byproduct material to be disposed of should be received prior to receipt of the shipment at the Mill, and shall include: 1. The volume of material in cubic feet or yards, or quantity of dnmis and their size. 2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.) 3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump container, etc.) 4. Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other material that is suited to sample collection. If a representative sample of the material was taken in connection with a previous shipment of material, then the results of that previous representative sample may be relied upon, and may be referred to or restated in the documentation that accompanies the shipment of the material. For byproduct material which is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the Shipper will determine the range, the average and the total activity, measured in mr/hr at a range of one meter, for each shipment. 5. A copy of the completed shipping manifest that will accompany the shipment and the anticipated shipping date. The RSO will also verify, prior to receipt of any shipment of byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the limit of 5,000 cubic yards of byproduct material from a single source, set out in Mill License condition 10.5A N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1 (12 01 10) (2) Clean.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 Page 2 of 6 3.0 Designated Disposal Area The RSO will designate from time to time one or more designated disposal areas (each a "Designated Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following criteria: 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 ofthe cell that is imderlain by tailings sands; 3. There must be at least 4 feet of tailings sands under the Designated Disposal Area; 4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the tailings cell; 5. The elevation of the Designated Disposal Area once filled with byproduct material must not exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the tailings cell; 6. Detailed engineering drawings must have been prepared and kept on file at the Mill that demonstrate for each Designated Disposal Area that: a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area; and b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes of the tailings cells; and 7. Prior written approval must have been obtained from the Executive Secretary of the Utah Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under Mill License condition 10.5C, and evidence of such approval must be on file at the Mill. 4.0 Notification to Executive Secretary DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any byproduct material. Written evidence of this notification will be kept on file at the Mill. 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 N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010\PBL-10_1 le (2) SOP Rev 1 (12 01 10) (2) Clean.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 Page 3 of 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. 2. Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm with the RSO that the shipment has been approved for receipt. 3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight Ticket (SWT). 4. Enter the loaded weight of the truck and trailer on the SWT. 5. The scale house operator will contact the Radiation Safety Department so that the shipment can be escorted by Radiation Safety personnel to the Designated Disposal Area specified by the RSO. 6.0 Byproduct Material Unloading 1. The RSO will specify the specific location within the broader Designated Disposal Area for disposal of the shipment. In designating the specific location within the broader Designated Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill license condition 10.4, and that the byproduct material from each in-situ leach source will be segregated from the byproduct material from each other in-situ leach source. 2. Radiation Safety personnel will escort the shipment to the designated location in the Designated Disposal Area for unloading of the byproduct material. 3. 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. 4. Prior to unloading, the driver will be instructed to open or imtarp the load. The Radiation Safety persoimel will visually inspect the byproduct material to ensure that the material matches the material description on the shipping manifest. Any discrepancies between the byproduct material received and the manifest information will be reported to the RSO. Any byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste material until a determination is made of its NiVSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10J le (2) SOP Rev 1 (12 01 10) (2) Clean.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 Page 4 of 6 acceptability for disposal. 5. 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 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. 6. If the shipment is determined to be acceptable the following procedures will be followed: a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed, the byproduct material will then be unloaded in the designated area. If such notice has not been given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an area of the tailings cell that is not covered with interim cover and from which the material can be removed if necessary. Once the required notice has been given and the required 7 days have lapsed, the byproduct material will then be placed into the designated area. b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring all personnel are clear of the trailer and the immediate area. Byproduct material will be dumped from the transport in a safe manner to minimize dust. If the material requires unloading by a fork truck, a ramp will be installed and unloading will proceed. c) After unloading, a photo of the unloaded material will be taken which is attached to the shipping documentation for verification of shipment contents. d) The location of the shipment of the byproduct material will be documented on the plat of each Designated Disposal Area illustrating the disposal area within the Designated Disposal Area where the byproduct material will be disposed of e) Beta-gamma measurements will be taken at several locations around the unloaded material. This information will be recorded on the Radiation Department's copy of the shipment documentation. The measurement range in mr/hr at 1 meter, and the average measurement, measured in mr/hr at 1 meter, shall be recorded. f) 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 NiVSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1 (12 01 10) (2) Clean.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 Page 5 of 6 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. g) A breathing zone sample will be taken periodically during imloading 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. h) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is being decontaminated for unrestricted release. i) Direct the driver back to the scales for an empty weight. j) The scale house operator will record the empty weight on the appropriate SWT. 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 prior to placing an additional layer. 3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing. Random fill or tailings will be used to fill voids in and around the byproduct material. 4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior to disposal. Barrels not completely fiill shall be filled with tailings or soil. 5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct material working area. The fill and cover material will be compacted with at least one pass of the construction equipment. 6. The RSO or his designee will inspect the placement of the byproduct material prior to covering to physically verify that the procedures in this Section 7.0 have been adequately performed. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1(12 01 10) (2) Clean.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 Page 6 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 of the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Materiaf issued May 1987. Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired without undergoing full decontamination if repaired within the restricted area of the Mill. For the appropriate decontamination procedures, refer to the following Standard Operating Procedures for the appropriate conveyance: End Dump Trailer SOP PBL-9 Intermodal Container SOP PBL-2 Standard Container Trailer SOP-PBL-2 9.0 Hazard Identification and Safetv 1. Required Personal Protective Equipment (PPE) In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes are required at a minimum. These must be wom in the restricted area ofthe Mill. 2. Industrial Hazards and Safetv 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 N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1 (12 01 10) (2) Clean.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 Page 7 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 NiVSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1(12 01 10) (2) Clean.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 Page 8 of6 in the Mill's Radiation Department files: 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 ofthe 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 summary of the amounts of byproduct material disposed of in each calendar year shall be sent to the Executive Secretary on or before November 1 of the following calendar year. N:VSOPs and ProceduresVDraft tailings SOPs Nov 2010VPBL-10_1 le (2) SOP Rev 1 (12 01 10) (2) Clean.doc SAFETY TRAINING FOR DELIVERY PERSONNEL Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on our property, we would like to acquaint you with the safety rules and procedures, which you will be required to follow while on our property. 1.0 General Safety 1. Approved hard hats and safety glasses are required at all times except when inside the cab of your truck. 2. This is a smoke free facility. No smoking is allowed on the property. Eating anything, drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due to radiation hazards. 3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum speed limit is posted at 15 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 tmck tuming over while dumping. Ensure that the tmck is on level ground and brakes are set prior to dumping. 5. Check for potential overhead hazards prior to dumping. 6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must be lowered. 7. Be aware of slippery conditions on the ore pad during periods of inclement weather. 8. Be aware of the potential for ice build-up on and around the decontamination pad during periods of cold weather. 9. Use caution when entering or exiting equipment. 2.0 Radiation Safety 1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area. 2. All equipment, i.e. tmcks and trailers, will be scanned for radiation prior to leaving the Mill's Restricted Area. Driver (Printed) Scale House Operator Driver (Signature) Date