DRC-2011-007566 - 0901a0688028b4c4

DENISO
MINES
November 10, 2011
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax: [phone]
www.denisonmines.com
VIA E-MAIL AND OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
Re: State of Utah Groundwater Discharge Permit ("GWDP") No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division of
Radiation Control ("DRC") Request for Information of October 6, 2011 Regarding 11e.(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill 11e.(2)
Byproduct Disposal SOP in response to DRC's letter of October 6, 2011, which we received on October 11,
2011. In response to the comments, we have attached an edited redline copy and a clean copy of the
proposed changes to the SOP and its attachments.
For ease of review we have quoted DRC's comments verbatim in italics below, followed by Denison's
responses.
DRC Comment
/. License Condition 10.5E states,
"Ttie licensee sliall 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 sliall describe the
documentation required for ISL disposal, which shall include but is not limited to the following:"
"(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an area
of the cell that is underlain by tailings sands;
"(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of the
uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed of in the
cells pursuant to License Condition 10.4, and the ISL byproduct material from each in-situ leach source will
be segregated from the byproduct material from all other in-situ leach sources;
"(4) Absence of void space inside barrels disposed, including physical verification before disposal; and
(5) Detailed engineering drawings which demonstrate:
"a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
N:\SOPs and Procedures\SOP repsonse 11e2 DisposalM 1.10.11 Response to DEQMI .10.11 Response to DEQ comments
11e2S0P.doc
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 2011
Page 2
"b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the tailings
cell."
The form enclosed in Attachment 2 of the subject September 12, 2011 DUSA letter was proposed to fulfill
the requirements above. It appears that in some cases, additional verbiage will need to be added to the
body of the SOP for said form to reference, in order to fulfill these requirements. We note the following:
A. License Condition 10.5E(2) is not captured on the form. The form needs to call for or make
reference to the required documentation of a survey and review, or other documentation, that will
show the specific requirements of License Condition 10.5E(2) have been met. It does not appear
this requirement is captured in the body of the SOP.
Denison Response: A line item has been added to the form referencing the survey or review to confirm the
elevation limit will not be exceeded.
B. License Condition 10.5E(3) is not completely captured on the form. The form needs to call for or
make reference to the required documentation to demonstrate that ISL material is segregated from
both disposed mill material/equipment as well as all other in-situ leach sources.
It appears that the form needs to make reference to:
i) . The plats of the designated ISL byproduct material disposal areas mentioned in the SOP.
ii) . Plats of the disposed mill material and equipment, which demonstrates segregation from the
ISL material.
These may be separate or joint plats containing the separation information. It does not appear this
entire requirement is captured in the body of the SOP.
Denison Response: Line items have been added to the form and text has been added to the SOP referencing
plats or figures demonstrating that the ISL matehal has been propeirly segregated from other wastes.
C. License Condition 10.5E(4) is not completely captured on the form. The form needs to call for or
make reference to the required documentation of an examination and filling the pertinent barrels
and other documentation, that will demonstrate that all disposed barrels meet the specific
requirements of License Condition 10.5.E(4).
This item is tied to License Condition 10.5B, which states that, "Barrels containing soil or sludges
shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal." It does not appear that documentation requirement for this is
captured on the form.
Denison Response: Line items requiring that the barrels be inspected for voids and that voids be filled have
been added to the form as requested.
D. License Condition 10.5.E(5) appears to not be fully captured on the form. The form needs to call
for or make reference to the required detailed engineering drawings that demonstrate that the
dimensional clearance requirements as stated in License Condition 10.5.E(5), for each disposal
area are met. Although it appears the body of the SOP contains this requirement, it does not
appear the form states or references the documentation required.
The requirements referring to documentation addressing dimensional clearance have been added to the form
as required.
DENISO
MINES
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 2011
Page 3
//. License Condition 10.5D states that, "All disposal activities shall be documented and records thereof
maintained on-site. The documentation shall include descriptions of the ISL waste and the disposal
locations, as well as all actions required by this License condition." This License Condition requires
documentation of all [ISL] disposal activities in License Condition 10.5, paragraphs A through F. Section I
of this letter above is devoted to paragraph 10.5E. License Condition 10.5A and 10.5F are adequately
covered. Therefore our comments below are limited to License Conditions, i.e. 10.5B through 10.5.D:
A. License Condition 10.5B. Our comment regarding this condition is covered by paragraph I.C of
this letter
Denison Response: No specific response required.
B. License Condition 10.5C is not completely captured on the form. The SOP appears to make
partial reference to this condition in paragraph 3.7 of the SOP. The form needs to call for or
make reference to the required documentation to assure the complete specific requirements of
this License Condition have been met. These complete requirement needs to be added to the
body of the SOP as well.
Denison Response: Additional language addressing License Condition 10.5C has been added to the SOP and
the form as requested.
C. License Condition 10.5D. Our comments on this License Condition 10.5D are contained in the
comments of this letter
No response required.
///. Additional Comments.
A. The subject SOP,
(i) Paragraph 6.4, the term "shipping container" may be interpreted to refer to several
things. It appears the term "shipping container" in this paragraph may be intended to
refer to shipping trailers or truck beds. Please define this in the SOP. "Shipping
containers" must be defined to not include containers such as sacks or barrels.
Denison Response: The change has been made as requested.
(ii) Paragraph 10.2b, the second bullet, after the words "void spaces," the phrase "in
barrels containing soil and sludges," must be added.
Denison Response: The phrase has been added as requested.
DENISO
MINES
Letter to Mr. Rusty Lundberg
11 e.(2) SOP RFI Response
November 10, 2011
Page 4
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISO
MINES
lie.(2) Byproduct Material Disposal SOP Clean
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 1 of 12
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives 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 hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The RSO will also verify, prior to receipt of any shipment of byproduct material, that the disposal of
such byproduct material will not cause the Mill to exceed the limit of 5,000 cubic yards of byproduct
material from a single source, set out in Mill License condition 10.5A
3.0 Designated Disposal Area
The RSO will designate from time to time one or more designated disposal areas (each a "Designated
Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each
Designated Disposal Area must meet the following criteria:
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 2 of 12
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom ofthe Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the byproduct material from all other in-situ leach sources;
7. ISL wastes will be disposed in cells that have received prior written approval from the
Executive Secretary for this purpose.
8. Prior written approval must have been obtained from the Executive Secretary of the Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Executive Secretary
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
kept on file at the Mill.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 3 of 12
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
DUSA's safety rules and procedures while on company property. The scale house operator
will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training
Forms will be turned in to the Safety Department for future reference.
2. Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that
the shipment is destined for the Mill and confirm with the RSO that the shipment has been
approved for receipt.
3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Radiation Safety Department so that the shipment
can be escorted by Radiation Safety personnel to the Designated Disposal Area specified by
the RSO.
6. Prior to transporting material to the Designated Disposal Area, the driver will be instructed to
open or untarp the load. The Radiation Safety personnel will visually inspect, to the degree
possible, the byproduct material to ensure that the material matches the material description on
the shipping manifest. Any discrepancies between the byproduct material received and the
manifest information will be reported to the RSO.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the RSO
that the material in question conforms to Section 2.0 of this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
6.0 Byproduct Material Unloading
1. The RSO will specify the specific location within the broader Designated Disposal Area for
disposal of the shipment. In designating the specific location within the broader Designated
Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will
be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill
license condition 10.4, and that the byproduct material from each ISL source will be segregated
from the byproduct material from all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location in the
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 4 of 12
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the taiUngs cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Radiation Safety personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material received and
the manifest information will be reported to the RSO. Any byproduct material suspected of not
meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 5 of 12
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of
f) Beta-gamma measurements will be taken at several locations around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 1 meter, and the average measurement,
measured in mrem/hr at 1 meter, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Radiation Department's copy of the shipment
documentation. If organics are detected, the RSO must be advised, and no compaction or
covering activities relating to the shipment shall occur until specifically instructed by the RSO.
The RSO will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The RSO will also contact DUSA corporate regulatory personnel and the shipper
to verify that the detected organics are 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) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the byproduct
material will be spread within the designated area within the Designated Disposal Area to
facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 6 of 12
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The RSO or his designee will inspect the placement of the byproduct material prior to covering
to physically verify that the procedures in this Section 7.0 have been adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify DUSA whether a specific trailer is to be released for restricted or
unrestricted use. Any trailers that are to be released for restricted use will be decontaminated
according to the requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers
that are to be released for unrestricted use will be decontaminated according to the requirements found
in Table 1 of the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Direcfive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
hitermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safetv
c) Use caution when the trailers are backing to the unloading area.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 7 of 12
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump o^ the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
No.: PBL-IO
Rev. No.; R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 8 of 12
a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
Shipper's Manifest and Bill of Lading.
Laboratory/activity analysis of the byproduct material performed by the Shipper.
Completed SWT.
7-day notice to Executive Secretary.
Photo of the byproduct material.
Byproduct material radiological scan information.
Breathing zone monitoring data, if applicable.
Equipment release forms.
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Executive Secretary on or before November 1 of the calendar year. (License
Condition 10.5F). [summary due same year]
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 9 of 12
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Denison Mines (USA) Corp.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck 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 deeontaminafion pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 10 of 12
ATTACHMENT 2
lle.a) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:.
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notificafion given?
Description of byproduct material disposal area/acfivifies:
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 11 of 12
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal?
Documentation of approval .
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent hfts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g., survey or review)
Engineer's or
RSO's Initials
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings'
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 12 of 12
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
lie.(2) Byproduct Material Disposal SOP Redline
DENISON MINES (USA) CORP
STANDARD OPERATING PROCEDURES
Title; 1 le.(2) Byproduct Disposal Page 1 of 12-!-
No.: PBL-10
Rev. No.: R-3
Date: Sept. 13Nov,
mo, 2011
LO Purpose
^TjZj:lZ\!^'^\^l'S^^^^ >"' <2) ^yP"^"« material ("byproduct ™.erian
DrocedurTZli^c operations for disposal under License Condition 10 5. The foUowins
(the "Mr-r °f « White Me 'a Mill
2-« Prior (o Ship-nent of Ryprnduct Mali-rial
rrpt^t^t^r^iirLXti^cirdr^^^'° '"^^^ °^ -^'^^ - -'p' °f
size. 1. The volume of material in cubic feet or yards, or quantity of drums and their :
2. A description ofthe material (e.g. sludge, process materials, filter media, pipe, etc.)
3.
c^onSnereto f '^'^^^"^ '"'^ ^"""^^ inte™odal container, side dump
material tLT '"', °;.""'^' "f"'^*' '''-2''' •'""^'O °" sludges and soils and other
~n * necdo'n ti h ' -P-->'^«- of the notarial IZ
represeire LTnir T'°r f "P""^"' *^ I""! previous
representative sample may be relied upon, and may be referred to or restated in the
documen ation that accompanies the shipment of the material. For byproduct maTrtal whkh
B not suited to sample collection (i.e. metals, process equipment, filte7m«lTa pip« etc ) he
(^X:frirfTn:t:s;t^^^^^^^^ —-'^^'^
a^nti:;T/shtpingTar ^ *^ ^'P-"'
PesignateH Disposal Area
Stpos'a?Ala'tSf: '™ 'T '° °'' ^^P™'" "'^^'^ ("^h a "Designated
,^^^o^~PBlW0~
I '^ev. No.: R-3
DaterSepMaNov,
L^ia20i; — 'e-(2) Byproduct Disposal Page 2 of 124-
I.
2.
3.
4.
6.
J ne Designated Disnn.*,! A
;-...«.c;:ri---..-.»,...„...,„^
There must be at least 4 fee, of, T
« 4 tee, of tatlmgs sands under the •
™= Designated Disposal Are Disposal Area;
'ailmgscell; located at least 17 f ,
, 'fc-n2feetfron,thesidesordteofthe
^nereareat]e;i.f4f.„. . ... Area that: ' me Mill that
\™-area.least4feetof.i„,„^,^„„^
laTheb '"""""^^^^^DisposalArea; ihe bottom Of thp n« •
--*.se*Sr^----Arealsloca.datlea.tl.feer,o„, •
i^Eachd- '""'^^^'^t^e sides or dikes
7.
^8__Priorw ^---^^^-^^^^^^^^^ ^^^^^^^^^-^^^^^^^^^
^ T> ^"^retary
i^l-^SA shall notify th^ P
'aence of this notification will be
No.; PBL-10
f^ev. No.; R-3
Date;SepM3Nov
^ia2on^ —'
kept on file at the Mill.
5.0
4.
5.
6.
STA^^^^ff^^SAjcORK—
T^M^'ffe^J^^^^OCEDURES "e.(2) Byproduct Disposal Page 3 of 124-
6.0
^hen each truck dri
r^^s:^^:;^ ^^:t:^ ^r: s^e hou^ o
j^pccc an copies of thp Qh- •
R ^Vment has been
Tiris^;f--a„dbo.,he.o.a„dtrai,ernumberso„,heSlh
p , • ^'^^^^ ^0"se Weight Enter fhp . ^'"^ Enter the loaded weight of
''^^'^'^^^^-dtrailerontheSWT
°Pen o? ll^mrpTiT^t' Designated Disposal Are ,„
fte shtppuig manifest A„V H the material matrh? ,t ^ ""P^- <° *e degree
a- "^"y byproduct materiaUnc
torofetMate^^ Posal. (LicenseCondition 10.5.BJ.
"^product material from each IsLolTjZ'"''°
^urce will be segregated
\ DENlSOraiNES^^ Page 4 of VZ^
"^i^PP^ \ STANDARD OPERATING PROCEDURES
Rev. No.: R-3 ^^^"^TUle: I le.(2) Byproduct Disposal J^_^
Date:Sept4SNov, ^
L^12^201J— J —
,„„.ebyptoauc.tnatenaHro™a,,ot.et.S.so.ces^^^ ^^^^^^^ ^^^^^ ^
Radiation Safety persomKl '^^J^^^^*^ *Suct tnaterial. ;.
PesisnatedDisposalMeaforunlo ^ ^^^^ ,messing Tailings
Proposed Methods arijm—^^F^;^ : ,
Cells tor Disposal ot ISL Bypr Area onlv on established :-
•1, be transported to the Designated Disposal Area only , ,
unprotected dikes, unci a, ted Disposal Area : •
f^::ustbe..a..^u^^ :i
(documentation of the disposal feet from the sides of dikes of ; > „
f ^;:UnatedDisposalAr«™.be.ca^^ :|,
t tailings cell (docun^ntation ot the dispos ^^^^^^ . .
any disposal aotivtt^s); „„„ed unless the disposal cell !
e/NoU-avetinto,l«dipo^|^^^^.^,^^
by at least 18 inches ot soil or tl „, Keen given, or the 7 days .
inhcshipmentisdeterminedtobeaccepta «iendar days have lapsed, .
:;Seb;"X-i.erialwill.henbe,aced,n.othed ^
b, Itthematerialis.asel.—^^^^^^ l^l^ri^^^ d unloading by a fork truck, a ramp wi ^^^^^^^^ ^^^^^^
, Mter unloading, the Radiation Safety P—tllt^^s n^^^^^^^
tter^l ,0 ensure :^,:r Any c^:c'^^^ °^
meeting the requirements set term
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 5 of 12-1-
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910.2011
Title: 1 le.(2) Byproduct Disposal
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material wili be disposed of.
f) Beta-gamma measurements will be taken at several locadons around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 1 meter, and the average measurement,
measured in mrem/hr at 1 meter, shall be recorded.
g) Measurements using a photoionization detecdon meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Radiation Department's copy of the shipment
documentation. If organics are detected, the RSO must be advised, and no compaction or
covering activities relating to the shipment shall occur until specifically instructed by the RSO.
The RSO will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The RSO will also contact DUSA corporate regulatory personnel and the shipper
to verify that the detected organics are lle.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material compaction and
covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activides. If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be nodfied, and all
other unloading activities of byproduct material from that pardcular ISL site will require the
use of respiratory protection, until further notice by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal acdvities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the byproduct
material will be spread within the designated area within the Designated Disposal Area to
facilitate compaction and covering.
No.:"?^!^
Rev. No.: R-3
Date: Septr43MQV
p r.c,«ps of the construction
equipment prior to placmg . . . , .v filling sectioning, or ctushing.
material working area. The till ana PO
fl,e construction equipnien. , „f u,e byproduct material prior to covering
8.0 Dec2nt2iffl.nit.»ni.ndRekaS£- " •„.„ leaving the MiU. Shippers
or uansponers wil^otify be rLasea ^^^'^^^^.^^jl'm. Any trailers
unrestricted use. Any traue . p^rt 49 CFR 1^ reouirements found
according to the requirements ^"""^ " , iecontaminated ^<''°l^^^.'°^S^^ai'^e FC-85-23,
that are to be released —^cot^Ln's (NRC's) Policy -"l^-^^X U^^^^^^^
in Table lot the Nuclear Regulatory CO j^^.,
"Guidelines tor Decontamination om^^^ 4 , ^ "^ ^,1 ate repairs by the
Termination of Licenses Jor ByP^^J^^^,,,, t„ „„estricted undergoing full
Trailers requirmg repair wii D ^^^.^^^^ be repairea
transporter at the transporter s oj -^ ^^^^^^^^^^ill.
„.ationifrepa.edwithmthere Oper.^^
For the appropriate decorxtamination procedures,
for the appropriate conveyance:
SOP PBL-9
SOP PBL-2
SOP-PBL-2 End Dump Trailer
Intermodal Container
Standard Container Trailer
9 0 Haza£dldentifica^^
E.»..iE.r.-^^^ .dhatssatetyglassesandsteel-toedshoes
.allareasoftheMillcoveredbyCh.^^^^^^^^^ P-or»
are required at a minimum. These must
I Rev.
Date
Page I of tt*
R-3 Title. — .,, be required.
^ ^^pro.ection.ifany,-"'^"'
lii- level of respiratory pr
disposal. *el^^"
, .j^.^^M^^^i^'^ ,ackingtotheu„.oadingarea.
, trailers are baciinig
Use caution when the ^^^^^ e
SO feet of the -J^Q.
rearot*e-..er.^-= , ,,e unloading process an" - . Heing Upped and the
,.riversrnustusecautiondur»g.^ ^^^^^^^^^^^^^^^^^^^^^^
0 Oonotp.ace.V^--:;rtb:*--"'^'^ ' *^^^'.::ee:ringore«..-ipn.nt.Besuretouse
^ ^:;S;o«.hee.^P"-e„'- .__^.,„terlorot a trailer.
V^) Always use aw
, MabifemiED!^ „,nray operate mobile equipment.
Onlytrahiedandauthori.edperso ,
. _v,oit he mspeCKu j ,;nment may
. ^ud,ble backup alarms shall ,,rting or moving «•
• „«v,en entering or exi»r-8eAU.P
=^ "^'"roB*U"P"«'"'- ris-nmotion.
t.talUi»esv.hene<impment.s« ^ ,„d weather conditions.
, Seatbeltsshallbeusedatal ^^^^^^^ .o„sisten. ^
No.: PBL-IO
Rev. No.; R-3
Date; SepM^Nov
2011 ''
NisoraSvEsTus^^
STANDARD OPERATING PROCEDURES
T'tle: ne.(2) Byproduct Disposal Page 8 of 124-
j) ^"^-•"-enginesmustbeshutoffwhenrefueUng.
t^) Keep equipment clear of edges dronnffc required.
^- documentation of Shipments
— following records will be maintained m the Mill's
• ulTor^ry^S^^^
• ComXed SW^!'^ ^^P^"^"^^ "^^^^n^' Performed by the Shipper
• ^-^^y notice to Executive Secretary '
• Photoofthebyproductmaterial.
b) Documentation of Disposal
Byproduct material disposal win h ^
• Doc'um'"^'^™"""''"""'*
more than 4 feet thick and
ISL disposal area and maintained bv Ae 11 '"forniation will be obtained for each ^
• Document that there are 4 feet of
*e bottom Of each dis^tl^'e: f X^^ Lst^tf"
• -re settlement m-——
CORP.
Title: Ue.(2) Byproduct Disposal
Page 9 of 124-
^ ';-rrZPZm.^^r^ .be location ot each shipment ot
Designated Disposal Area, wnic
byproduct material. ^^^^
of the Executive Secretary's written approval
The Mill will maintain on file a copy of the Exec
Designated Disposal Area. ^^^^ ^^^^^^^^ ^^^^
An annual summary ot the ^^^^^^^X:^"^--^ ^'''-"^^
No.: PBL-10 DENISON MINES (USA) CORP.
Page 10 of Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 10 of
Date: Sept. 12Nov. Tide: I le.(2) Byproduct Disposal 12-1-
0910,2011 • ATTACHMENT 1
SAFETY TRAINING FOR nELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safetv
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3 Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Denison Mines (USA) Corp.'s equipment has the nght 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 sHppery conditions on the ore pad during periods of inclement weather.
8. Be aware of die 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
No.: PBL-10
Rev. No.: R-3
Date;Septl43Nov mo, 201 ^ ' 1
Driver (Signature)
STANOAROOP.KATS^°^^^^
"tie. ne.f2) Byproduct DisposaJ Page 11 of
124
Date
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 12 of
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal 124
0910. 2011
ATTACHMENT 2
lle.f2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? • -
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in? . -
Was the material placed on a tailings beach area ofthe cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 13 of
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal 124
0910.2011
Have the diickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved bv the executive Secretary
for ISL waste disposal? •
Documentation of approval
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness_of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm. • • • •
Will the elevation of the material exceed the plane or grade df the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g.. survey or review)
Engineer's or
RSO's Initials
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Breathing Zone-.
^. Was a Breathing
2. If yes, wh '
jUected? Yes or No
Wasaphotogra pmaken during the un loadmg activities