DRC-2011-007776 - 0901a068802a6097

State of Utah
GARY R. HERBERT
Governoi-
GREG BELL
Lieutenant Governor
f
Department of
Environmental Quality
Amanda Smith
Lyevutive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
December 6, 2011 p Li
CERTIFIED MAIL
(Return Receipt Requested)
Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
RC-2011-00777
Dear Ms. Tischler:
SUBJECT: Approval of lle.(2) Byproduct Disposal Standard Operating Procedures (SOPs)
We received a letter dated November 10, 2011 letter from DUSA, which transmits a 1 le.(2) Byproduct
Disposal Standard Operating Procedures (SOPs). These SOPs were submitted by DUSA in response to our
comment letter of October 6, 2011 and in pursuit of License Condition 10.5E.
We have reviewed the November 10, 2011 submittal, and have no further comments. Therefore, we
hereby approve the lle.(2) Byproduct Disposal SOPs No. PBL-10 Rev. No. R-3 dated November 10, ,
2011.'
If you have any questions on the above, please contact Mr. Rupp of DRC
UTAH RADIATION CONTROL BOARD
Rusty LundbergTExecutive Secretary ^"'^
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RE:approval 11e(2) byproduct disposal sop/ Dr
rq Jo Ann Tischler
° Denison Mines (USA) Corp
1050 Seventeenth ST, ST E 950
^ Denver, Co 80265
PS Form 3800, August 2006 See Reverse for Instructions
1 ^5 North 1950 West • Salt Lake City. I.T
Mailing! AddrL-ss: P.O. Box 144850 • Salt Lake C:ity. UT S4M4-4850
TelephoiiL' m)\) 5."i(.-4250 • Fax (801) 5.^.'^-4097 • T.IXD. (80 li 53f)-44l4
www.deq.Moh.tiov
Printed on 100';'('recycled p;tper
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
October 6,2011
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
CERTIFIED MAIL
(Retum Receipt Requested)
Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
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RE: 10/6/11; transmittal^ revised SOP/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PSForin 3800. August 2006 See Reverse for Instructior
SUBJECT: September 12, 2011 DUSA Transmittal of Revised Standard Operating Procedures
(SOPs), Title: l]e.(2) Byproduct Disposal No. PBL-10 Rev. No: R-3 Date: Sept. 12, 2011,
which includes a Form, for ISL [In-Situ Leach] Disposal Documentation; August 4, 2011
and April 21, 2011 DRC Comment and Request for Information Letters, regarding a
similarly named SOPs, versions R-3 June 1, 2011 and R-2 Dec. 1, 2010, respectively;
Comments and Request for Information
We received the subject September 12, 2011 letter from DUSA, which was provided in response to the
subject DRC letter of August 4, 2011. We have reviewed this response.
The subject DRC comment letter, dated August 4, 2011, had a single comment. It stated that, "Item No. 4
of your May 31, 2011 letter appears to not fully respond to DRC comment no. 4 in the subject April 21,.
2011 DRC letter." The April 21, 2011 DRC letter, comment no. 4, stated that, ".. .DUSA must develop a
form for ISL disposal documentation requirements of License Condition 10.5E and 10.5D." The primary
focus of this letter is to assure that the related documentation requirements are captured on the form.
However, the form appears to be proposed as a checklist by DUSA, and the documentation requirements
and needed references are not always included on the form.
In some cases, additional verbiage needs to be added to the body of the SOP for the form to reference the
various License Condition requirements.
Our conmients follow below pertain to License Conditions 10.5E, 10.5D and some additional comments:
I. License Condition 10.5E states, /
"The licensee shall also submit for Executive Secretary approval a revised written Standard Operating
Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised SOP shall describe the
documentation required for ISL disposal, which shall include but is not limited to the following:"
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 53.'?-4097 • T.D.D. [phone]-
www.deq.iilnh.fitn-
Printed on lOO'/t recycled piiper
Page 2 f
"(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 ofthe 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
"b. The bottom of each disposal area is located at least 12 feet from the sides or dikes ofthe
tEffilngs cell."
The foriii 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 ofthe SOP.
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.
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.
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.
Page 3
II. 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.
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 ofthe SOP. The forTn 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. ' " .
C. License Condition 10.5D. Our comments on this license condition are contained in the
comments of this letter.
III. 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.
(ii) Paragraph 10.2b, the second bullet, after the words "void spaces," the phrase "in
barrels containing soil and sludges," must be added.
Please review the above comment, and respond in writing, submitting an appropriately revised Title:
1 le.(2) Byproduct Disposal Standard Operating Procedures document, with a unique version number. Per
your email message of October 3, 2011 you committed that DUSA would fully respond to this letter within
30 calendar days of receipt. If you have any questions on the above, please contact me.
Sine ^ely.
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
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State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
August 4,2011
CERTIFIED MAIL
(Retum Receipt Requested)
Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: May 31, 2011 DUSA Transmittal of Revised Standard Operating Procedures (SOPs), Title:
1 le.(2) Byproduct DisposalHo. PBL-10 Rev. No: R-3 June 1, 2010; April 21, 2011 DRC
Request for Information Letter, regarding similar proposed SOPs R-2 Dec. 1, 2010.
Comment and Request for Information
We received the subject May 31, 2011 letter from DUSA, and have reviewed the same. We have one
comment below:
Item No. 4 of your May 31, 2011 letter appears to not fully respond to DRC comment no. 4 in the
subject April 21, 2011 DRC letter.
Please review the above comment, and respond in writing, submitting an appropriately revised Title:
1 le.(2) Byproduct Disposal Standard Operating Procedures document, with a unique version number. Per
our telephone conversation on August 4, 2011 you committed that DUSA would fully respond to this letter
within 30 calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
/ XJ <
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
F:\DUSA\LRA&License \ISL AmendmentM le2 Byproduct Disposal CMT2 8-2011.doc
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.eieq.utah.gov
Printed on 100% recycled paper
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RE:8/4/11; COMMENT & RB 5/13/11 SOP/S / DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PS Form 3800. August 2006
Sec Reverse lor liislruclions
,»»' OF riur-..
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
pec ^ 2^11 * vo^io^
April 21, 2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: December 1, 2010 DUSA Transmittal Letter, Three Separate Draft Standard Operating
Procedures (SOPs); SOPs for Title: 1 le.(2) Byproduct Disposal No. PBL-10 Rev. No.: R-2
Dec. 1, 2010: Comments and Request for Information
We have received the subject December 1, 2010 DUSA letter, transiriitting three separate proposed
Standard Operating Procedures (SOPs). The subject of this letter is our review of one of these SOPs, i:e.
the Title: 1 le.(2) Byproduct Disposal Standard Operating Procedures [SOPs] with subject version
number. The subject Title: He.(2) Byproduct Disposal SOPs were submitted by DUSA to comply with the
requirements of License Condition 10.5. We have reviewed this document, and have comments listed
below. DRC review of the other two transmitted SOPs is to be discussed in separate DRC letters. -
1. General,
a. Please bear in mind that since the items below pertain to a License Condition that requires
Executive Secretary approval, your responses regarding them could be subject to
enforcement. Therefore, complete and thorough responses in this matter are important.
Some suggested red-line strike-out changes for the subject SOPs are attached. The
majority of these suggestions were deriveci from our review ofthe License Conditions.
Please note that some sections of the red-line strike-out copy of the subject SOPs may
contain several recommended changes. Also, please note that not all changes requested in
this letter are captured in our red-line strike-out notations.
Chief among the interests of DRC in changes to the subject SOPs was for DUSA to add
provisions to prevent the occurrence of any hazardous waste deposits, and to increase
density of compacted ISL byproduct materials (to reduce potential settlement) in tailings
cells. Remarks, I.e. (1) through (3) directly below, concem this.
(1). We suggest DUSA consider adding the verbiage similar to that shown in red-line
strike-out verbiage attached as new red-line paragraph 5.6 of the subject SOPs.
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone]- Fax [phone] • T.D.D. [phone]
wwiv.deq.Utah.gov , ,
Printed on 100% recycled paper ,
Page 2
The concept is to have byproduct materials pre-inspected before its arrival
adjacent to the disposal site. - - '
(2) . As shown in red-line, we suggest that DUSA consider moving existing paragraph
6.4 and revise it to language similar to the attached new red-line paragraph 6.5.c of
the subject SOPs. The concept here is to assure after unloading, that no items of
concern were hidden or obscured in the material.
(3) . To be consistent with License Condition 10.4A, and to increase compaction and
reduce settlement, as mentioned in paragraph Ic above, we have a comment. We
suggest DUSA edit paragraph 7.2, similar to the attached red-line strike out
verbiage of the subject SOPs, to require that, "byproduct material will be
compacted with the same requirements as License Condition 10.4A."
License Condition 10.5B states that,
"All ISL contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal area
and the barrels crushed. Barrels containing soil or sludges shall be verified by the Licensee to be
full prior to disposal. Barrels not completely full shall be filled with tailings or soil prior to
disposal."
DRC Findings: Some red-line strike-out verbiage attached is suggested in Section 5.6b of
the subject SOPs. The concept is to have barrels containing byproduct materials pre-
inspected for fullness before arrival adjacent to the disposal site.
License Condition 10.5E(3) states that,
".. .ISL byproduct material will be segregated from any mill material and equipment disposed of in
the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in-situ
leach source will be segregated from the byproduct material from all other in-situ leach sources;"
DRC Findings: It appears the submitted SOPs do not clearly address this condition. Some
red-line strike-out verbiage attached is suggested in Section 6.1 of the subject SOPs to
more clearly address this license condition.
License Condition 10.5E states that,
"The licensee shall also submit for Executive Secretary approval a revised written
Standard Operating Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised
SOP shall describe the documentation required for ISL disposal, which shall include but is not
limited to the following..."
DRC Findings: The emphasis here is on documentation. License Condition 10.5D also
requires documentation, "of all disposal activities." DUSA must develop a form for ISL
disposal documentation, to cover all the documentation requirements of License Condition
10.5E and 10.5D.
Page 3
The DRC review letter of March 1, 2010 is referenced in your subject transmittal. Paragraph A
of the DRC letter states the following: "Proposed methods and procedures to fully protect the
liner while accessing tailings cells for disposal of ISL byproduct material and mill equipment
must be submitted for approval. These methods and procedures would apply to tailings Cell 4A
and newer cells."
DRC Findings: It appears the submitted SOPs do not describe the actual "methods
and procedures to protect the liner while accessing the tailings cells..." Please
adjust the subject SOPs to do so.
6. The page numbering in the subject SOPs document has errors. Please adjust the subject SOPs
to correct these errors.
7. DRC RAM Inspector Comments:
a. Reference a DRC inspection of ISL disposal activities, held on September 1-2, 2009. A
copy ofthe inspection report is attached to this letter. In the "Deficiencies" paragraph on
page 2 of this report, the DRC inspector stated that at that time, the ISL documentation did
not include, "Description of how ISL material [was] being placed in the slit trenches..."
and, "Description of other activities (i.e. Barrels not being completely full being filled with
tailings or soil as described in License Condition i0.5B)." In the Conclusions and
Recommendations paragraph on page 4 of that report, it states that DUSA should ,
"Document the placement of ISL material in tailing Cell #3 with a detailed description [of]
all disposal activities involved with the disposal of each shipment. License Condition
10.5D states,'All disposal activities shallbe documented.'"
The disposal documentation for each shipment, including the method of disposal such as
trench disposal or other approved disposal method with backfill, needs to be documented
for each individual shipment. Documentation requirements for the above activities were
not included in the subject SOPs as submitted, but need to be. >
b. Balloon comments R1 through R4 are provided in the margins of the attached red-line
strike out copy of the subject SOPs. Please address these comments.
Please review the above comments, and respond in writing, submitting an appropriately revised Title:
1 le.(2) Byproduct Disposal Standard Operating Procedures document with a unique version number. Per
your email dated April 14, 2011 you committed that DUSA would fully respond to this letter within 30
calendar days of receipt. If you have any questions on the above, please contact me.
Sincerely,
David A. Rupp, P.E.
Geotechnical Services Section
DAR:RJ:dr
Attachment: Red-line strike-out copy of the subject SOPs
Inspection Report Sept. 1-2, 2009
F:\License\ISL Amendments for 20I0\1 Ie2 Byproduct Disposal Cmtl dr&rj.doc
DENISO
MINES
November 10, 2011
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
Denison Mines (USA) Corp.
105017th Street, Suite 950
Denver, CO 80265
USA
Ter:303 628r7798
Fax:[phone]
www.denisonmlnes.com
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 stiall also submit for Executive Secretary approval a revised written Standard Operating
Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised SOP shall describe the
documentation required for ISL disposal, which shall include but is not limited to the following:"
"(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 t .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 material has been properly 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
Pages
//. 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.y 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 requirerrients 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
11e.(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. Frydeniund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISO
MINES
lle.(2) Byproduct Material Disposal SOP Redline
#
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page t of 124-
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
mo, 2011
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 dme 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:
5
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 2 of 124-
Date: Septr4aNov. Title: lle.(2) Byproduct Disposal
0910. 2011
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 t¥he 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 haye been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at lea:st 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
1 •''
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
h)c) ^ach disposed ISL byproduct material has been segregated fro tn 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 die
Executive Secretary for this purpose.
^TS. 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 die 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 norify 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
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
Formatted: Font: (Oefault) Times New
Roman, 12 pt. Not Italic
Formatted: Indent: Left: 0.5", No bullets or
numbenng
( Formatted: Font: Not Bold
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
: ( Formatted: Indent: Left: 0.75"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 3 of 124-
Date: Septr4SNov. Tide: 1 le.(2) Byproduct Disposal
0910.2011
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 provided with the Safety
Training Form (Attachment I). All drivers will be required to read the Safeity Training Form
and sign and date the Safety Training Form indicating that they iinderstand 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 diat
the shipment is destined for the Mill and confirm with the RSO that the shipment has been
approved for receipt.
3. Record die inbound date and bodi die 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 diat the shipment
can be escorted by Radiation Safety personnel to the Designated Disposal Area specified by
die RSO.
A.Sfe S '•• 1*1 Ji» J";/s ji '••
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 die material matches the material description on
the shipping manifest. Any discrepancies between the byproduct material received and the
manifest information will be reported to die 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
I. The RSO will specify the specific location within the broader Designated Disposal Area for
disposal of the shipment. In designating die specific location within die broader Designated
Disposal Area for disposal of the shipment, die RSO will ensure that all byproduct material wdl
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
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 4 of 124-
Date: Sept. 12Nov. Tide: 1 le.(2) Byproduct Disposal
0910.2011
from the byproduct material from all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location in the
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be ti-ansported to die 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 settiement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under die Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If die 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 (diat is. die 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 die designated area.
b) If the material is in a self-unloading container, die driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material wUl 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 matoh the material
description on die shipping manifest. Any discrepancies between the byproduct material received and
die manifest information will be reported to the RSO. Any byproduct material suspected of not
meeting die requirements set forth in Section 2.0 of diis SOP will be kept segregated from other waste
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 5 of 124-
Date: Seet7-45Nov. Tide: 1 le.(2) Byproduct Disposal
0910. 2011
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of die 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 die 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 die 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 diat 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 die shipment shall occur until specifically instructed by die RSO.
The RSO will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of die detection of the organics, and will implement any such
precautions. The RSO will also contact DUSA corporate regulatory personnel and die shipper
to verify that die detected organics are lle.(2) byproduct material from the shipper's ISL
facility. Once die 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 die applicable DAC, then die 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.
••'k-yMr:i-S
-fir-
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 die 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 die 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.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 6 of 124-
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal
0910. 2011
2. The byproduct material will be compacted with at least four passes of die construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismanded, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and die barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled widi 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 die requirements found
in Table 1 ofthe Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For die appropriate decontamination procedures, refer to the following Standard Operating Procedures
for die appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
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
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 7 of 124-
Date: Sept. 12Nov. Title: lle.(2) Byproduct Disposal
0910. 2011
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside die 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.
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
die 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 weadier conditions,
subject to a maximum speed limit of 15 mph.
h) Keep die 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 die equipment until your supervisor has released it.
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 8 of 124-
Date: Sept. 12Nov. Title: lle.(2) Byproduct Disposal
0910. 20H
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
• Shipper's Manifest and Bill of Lading.
• Laboratory/activity analysis of the byproduct material performed by die 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 bodi. 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 diat materials placed on tailings are no more dian 4 feet thick and
subsequent lifts no more than 2 feet thick (diis 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 diat 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 die shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 9 of 124-
Date: Sept. 12Nov. Title: 11 e.(2) Byproduct Disposal
0910.2011
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
2. The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
3. 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]
, 'Ki, »' \ \ <.i . _
No.: PBL-10
Rev. No.: R-3
Date: Segtr4aNov.
0910. 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Tide: 1 le.(2) Byproduct Disposal
Page 10 of
124-
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 die 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 die 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 diat die 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 die 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 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.
'^'ii^iM::Xji':ri^''''j>,''^
Driver (Printed) Scale House Operator
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 11 of
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal 124-
0910.2011
Driver (Signature) Date
. - "'j ? • .''" f'*^ i :
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 12 of
Date: Sept. 12Nov. Title: lle.(2)Byproduct Disposal 124r
0910.2011
ATTACHMENT 2
lle.r2) 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 die 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 of die cell or on an area of the cell that was underlain
by tailings sands?
:i!!Mi^^>^K-:
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: 11 e.(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 by the executive Secretary
for ISL waste disposal?
Documentation of approval
Was the ISL material segregated from disposed Mill material and odier
ISL material?
Refer to plat(s) used to confirni.
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 maintainied under each disposal
area?
Refer to drawings used to confirm
Is die 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 die cell?
How was this confirmed (e.g.. survey or review)
Engineer's OT
RSO's Initials
m.:
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 DENISON MINES (USA) CORP.
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 14 of
Date: Sept. 12Nov. Title: 1 le.(2) Byproduct Disposal 124-
©910.2011
Radiological receipt survey measurements:
Breadiing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of die sampling?
Was a photograph taken during the unloading activities? Yes or No
lle.(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: lle.(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. Resuhs 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: 1 le.(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 of the 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: 1 le.(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: 1 le.(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 ofthe
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (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: 1 le.(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: 1 le.(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 taiUngs 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 Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required,
2. Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
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.
Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion,
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph,
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENISON MINES (USA) CORP.
STANDARD OPERAT^G PROCEDURES
Title: 1 le.(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 hke 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 decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area,
2, All equipment, i,e, trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 10 of 12
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:.
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
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: 1 le.(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:
Engineer's or
RSO's Mitials
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 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 of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g., survey or review)
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: 1 le.(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
DENISO
MINES
May 31, 2011
Denison Mines (USA) Corp.
1050 17th 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 April 21, 2011 Regarding 11.e(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill 11e.(2)
Byproduct Disposal SOP. This letter also responds to DRC's letter of April 21, 2011, which we received on
April 28, 2011 providing DRC's proposed redlines and comments on the subject SOP. We have attached an
edited redline copy of the SOP in which Denison's modifications or additional language in response to DRC
comments are indicated in a second color.
We have provided, below, specific responses to each request in DRC's April 21, 2011 letter. The sections
and numbering of the remainder of this letter follow the DRC April 21, 2011 letter. Each DRC request is
shown in italics, below, followed by Denison's response.
DRC Comments and Responses
1. General.
a. Some suggested red-line strike-out changes for the subject SOPs are attached. The majority
of these suggestions were derived from our review of the License Conditions. Please note
that some sections of the red-line strike-out copy of the subject SOPs may contain several
recommended changes. Also, please note that not all changes requested are captured in our
red-line strike-out notations.
Denison Response: So noted. Denison has also replied to the four additional DRC comments provided in
the margins of the SOP. Our responses are provided in the margins of the SOP directly below the
comments. As general background to our response to DRC's comment in the margin of Section 3.0
of the SOP, Denison feels it is important to clarify that trench disposal and tailings beach disposal are
not two different types of disposal.
The disposal location for material from each ISL source is pre-determined by the RSO as a
Designated Disposal Area for that source. Designated Disposal Areas were selected primarily to
C:\Users\itischler\Desktop\SOP repsonse 11e2 monitor\05.27.11 Response to DEQ 04.20.11 RFI 11e2 SOP.doc
Letter to Mr. Rusty Lundber
11e.(2) SOP RFI Response
May 31, 2011
Page 2
assure the ability to segregate material from each ISL source, and to ensure that every designated
Disposal Area meets the requirements of License Condition 10. E, including the requirement to
maintain 4 feet of tailings sands below and 12 feet of clearance between the material and the sides or
dikes of the cell, regardless of whether the material is placed in a trench area or beach area. There
are no physical differences in the way material is placed in trenches versus beach areas. Therefore,
the SOP does not describe two different placement processes because there are not two different
placement processes.
b. Chief among the interests of DRC in changes to the subject SOPs was for DUSA to add
provisions to prevent the occurrence of any hazardous waste deposits, and to increase
density of compacted ISL byproduct materials (to reduce potential settlement) in tailings cells.
Remarks, I.b. (1) through (3) directly below, concern this.
Denison Response: DUSA feels it is important to clarify the issue of "hazardous waste deposits," as well as
the DRC comment noted in the margin of the redline SOP regarding whether the "byproduct material meets
the RCRA requirements."
1)
2)
3)
4)
5)
6)
7)
To be regulated by RCRA as a hazardous waste, a material must be a solid waste per the RCRA
definition. Source Material, Special Nuclear Material, and 11e.(2) Byproduct Material are expressly
excluded from the definition of solid waste under RCRA (42 USC 6903 and 40 CFR 261.4(a)(4).
Process wastes and debris from ISL facilities are 11e.(2) byproduct by definition and are therefore
excluded from the definition of solid waste, and from the definition of hazardous waste, under RCRA.
DUSA's license allows us to accept 11e.(2) byproduct material under Conditions 9.8 and 10.5.
RCRA defines two types of hazardous waste. Hazardous wastes can be either characteristic
hazardous wastes (i.e., ignitable, corrosive, toxic, or reactive) or listed hazardous waste (i.e. listed
under 40 CFR 271.30-33 or under comparable State law provisions.
Because 11e.(2) byproduct may include some of the same types of constituents and properties as
RCRA characteristic wastes, analysis for RCRA characteristics would not have any value in
confirming that a waste is not a RCRA characteristic waste. Because 11e.(2) material is not a solid
waste, it cannot be a RCRA characteristic waste.
Because RCRA listed wastes are determined by source or origin, analysis fpr RCRA constituents
would not have any value determining if the material is a RCRA listed waste. Because the material's
process of origin in the processing of source material as defined 10 CFR 40.4, the waste a) is not
from any RCRA listed process and b) the waste is 11e.(2) byproduct by definition and cannot be solid
waste, and therefore not a RCRA listed waste.
Because 11e.{2) material is exempted from RCRA due to its origin, no analysis or specific
documentation is required. DUSA requires the certification described in Section 2.0 of this SOP as
an added assurance that the material consists solely of 11e:(2) byproduct and is not combined with
any other material or waste.
A chemical profile of the material is not required, and not requested from the shipper. The only
reason DUSA asks for the radiological characterization is for our own radiological safety assessment
by the Mill's RSO.
(1). We suggest DUSA consider adding the verbiage similar to that shown in red-line
strike-out verbiage attached as new red-line paragraph 5.6 of the subject SOPs. The
concept is to have byproduct materials pre-inspected before its arrival adjacent to the
disposal site.
Denison Response: The verbiage has been accepted as provided
DENISO
MINES
Letter to Mr. Rusty Lundben
11e.(2) SOP RFI Response
May 31,2011
Page 3
(2) . As shown in red-line, we suggest that DUSA consider moving existing paragraph 6.4
and revise it to language similar to the attached new red-line paragraph B.S.c of the
subject SOPs. The concept here is to assure after unloading, that no items of
concern were hidden or obscured in the material.
Denison Response: The verbiage has been accepted as provided.
(3) . To be consistent with License Condition 10.4A, and to increase compaction and
reduce settlement, we suggest DUSA have paragraph 7.2 be rewritten as shown in
the attached red-line strike out verbiage of the subject SOPs, to require that,
"byproduct material will be compacted with the same requirements as License
Condition 10.4A."
Denison Response: The text change regarding compaction has not been included for the following reasons.
License condition 10.4, as cited by DRC in the proposed text change, applies to disposal of material
and equipment generated at the Mill site. The License condition applicable to disposal of ISL waste.
Condition 10.5, refers to, and is based on, the UMETCO May 20, 1993 letter to the US Nuclear
Regulatory Commission. The May 20, 1993 letter, a copy of which has been attached for your
reference, states that "Each layer of the waste material will be compacted with at least one pass of
the construction equipment prior to placing an additional layer." DRC's proposed language is
inconsistent with the License. The existing language in Section 7.2 of the SOP, which is consistent
with the License, has been retained.
2. License Condition 10.5B states that.
"All ISL contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces.
Barrels containing waste other than soil or sludges shall be emptied into the disposal area and the
barrels crushed. Barrels containing soil or sludges shall be verified by the Licensee to be full prior to
disposal. Barrels not completely full shall be filled with tailings or soil priorto disposal."
DRC Findings: Some red-line strike-out verbiage attached is suggested in Section 5.6b ofthe
subject SOPs. The concept is to have barrels containing byproduct materials pre-inspected for
fullness before arrival adjacent to the disposal site.
Denison Response: DRC's proposed change has been accepted as provided.
3. License Condition 10.5E(3) states that.
"...ISL byproduct material will be segregated from any mill material and equipment disposed of in the
cells pursuant to License Condition 10.4, and the ISL byproduct material frorh each in-situ leach source
will be segregated from the byproduct material from all other in-situ leach sources;"
DRC Findings: It appears the submitted SOPs do not clearly address this condition. Some
red-line strike-out verbiage attached is suggested in Section 6.1 of the subject SOPs to more
clearly address this license condition.
Denison Response: DRC's proposed change has been accepted as provided.
4. License Condition 10.5E states that.
"The licensee shall also submit for Executive Secretary approval a revised written
DENISO
MINES
Letter to Mr. Rusty Lundben
11e.(2) SOP RFI Response
May 31, 2011
Page 4
9
Standard Operating Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised
SOP shall describe the documentation required for ISL disposal, which shall include but is not limited to
the following..."
PRC Findings: It appears the submitted SOPs do not capture the documentation requirements
of License Condition items 10.5E.(1) through (4). Please adjust the subject SOPs to do so.
Denison Response: The change has been made as requested. The proposed language has been accepted
with the additional text shown in an alternate color in Section 6.5i). A form has been provided in Attachment 1
of the SOP.
5. The DRC review letter of March 1, 2010 is referenced in your subject transmittal. Paragraph A of
the DRC letter states the following:
"Proposed methods and procedures to fully protect the liner while accessing tailings cells for
disposal of ISL byproduct material and mill equipment must be submitted for approval. These
methods and procedures would apply to tailings Cell 4A and newer cells."
DRC Findings: It appears the submitted SOPs do not completely capture this item. Please
adjust the subject SOPs to do so.
Denison Response: The SOP does, in fact, address "actual methods and procedures to fully protect the liner
while accessing the tailings cells." The reviewer is referred to Sections 3.2, 3.3, 3.4 and 6.3 in the previous
version where the methods were discussed. However, the methods and procedures that were already
provided in these sections have been combined in a new Section 6.3 entitled "Proposed Methods and
Procedures to Fully Protect the Liner While Accessing Tailings Cells for Disposal of ISL Byproduct Material
and Mill Equipment." This rearrangement should "fully capture this item."
6. The page numbering in the subject SOPs document has errors. Please adjust the subject SOPs to
correct these errors.
Denison Response: The change has been made as requested.
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. Frydeniund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISO
MINES
Umetco Minerals Corporation
IVlay 20,1993 Letter
Umetco Minerals worporation
0_ UMJUuijtUJC^.K
WHrrE MESA MILL • P. O. BOX
» (B01) S7B-SSS1
BSa • BLANDING. UTAH B4S11
May 20, 1993
Mr. Ramon E. Hall Director
U. S. Nuclear Regulatory Commission
Region IV
Uranium Recovery Field Office
Box 25325
Denver, CO 80225
Re: SUA-1358, Docket Number 40-8681
Disposal of Atomic Energy Act 11
Dear Mr. Hall:
RECEIVED
WAy2 4 1993
CONCOKD iviiMiNG UNIT
(e) 2 Material Docket
The White Mesa Mill (the "Mill") has an opportunity to
dispose of 11 (e) 2 by-product material. As you know,
similar materials have been disposed of in the past at the
Mill. Umetco wishes to pursue an amendment to the above
referenced license to allow the disposal of 11 (e) 2
by-product material generated under the licensing authority
of the NRG and/or the agreement states.
Umetco's proposal is to request a license amendment, to run
concurrently with and to be renewed (if appropriate) during
each licensing cycle, for the disposal of not more than
5,000 cubic yards of 11 (e) 2 by-product material per
generating licensee. If Umetco received a request to
dispose of more than 5,000 cubic yards of 11 (e) 2
by-product material, Umetco would notify URFO in writing so
that the appropriate review and approval could be received
from the URFO staff prior to executing a contact.
The receipt and disposal of 11 (e) 2 by-product material
would be accomplished under the Radiation Protection
Procedure section of the License Renewal Application, using
the attached procedure entitled "Third Party 11 (e) 2
By-product Disposal."
The first shipment projected for reception to the Mill is
by-product material originating from the Intercontinental
Energy Company ("lEC") insitu operation near Three Rivers,
Texas. lEC is an affiliated company of Energy Fuels
Nuclear, Inc. ("EFNI"), which has partial ownership in the
mill. Attachment A of this letter includes an estimated
volume, description, and radiological characterization of
materials to be received at the Mill from the lEC facility.
WHITE MESA MILL • UMETCO OPERATIONS
PLAN THIRD PARTY WASTE
MATERIAL FROM URANIUM
OPERATIONS FOR DISPOSAL TO TAILINGS POND NO. 3
STANDARD OPERATING
PROCEDURES
Waste material will be accepted for disposal during normal business hours,
Monday through Thursday.
1.1 No waste material will be delivered to the White Mesa disposal site:
a) Without Umetco's personnel present and
b) Without specific approval by Umetco's Site Manager
(801-678-2221).
1.2 Only one waste transport will be allowed on the disposal site at a time.
Additional transports will wait their turn to unload at the staging area,
located in the mill yard.
All waste material must be approved for disposal by Umetco prior to shipment
to the disposal site. Waste material must conform to US-NRC License SUA-
1358 conditions and contain no other hazardous material as defined in RCRA.
2.1 Information regarding the waste material to be disposed of shall include
the minimum of:
a) The volume of material (in cubic feet or yards or quantity of
drums and their size),
b) Description of material (sludge, process materials, filter media,
etc.), and
c) Laboratory results of material to include total "°Ra, uranium
natural, and any other chemical or radiological analysis requested
by Umetco personnel deemed necessary to characterize waste.
Ail analytical results will be submitted to Umetco Minerals prior
to shipment and acceptance. Records will be retained at the
White Mesa Mill.
Waste generator will give 30 days notice of material delivery. Each notice wiil
include a copy of the properly completed shipping manifest that will
accompany the shipment, U.S. DOT Hazardous Materials Certificate required
by 49 CFR Part 107, Subpart G, description of waste materials, appropriate
laboratory results, and a description of shipping containers, if used.
Umetco will review the manifest for completeness and schedule a site visit
with the waste generator.
4.1 The waste generator site inspection of the material will include:
a) Inventory of material being shipped and comparison to the mani-
fest submitted.
b) Inspection of materials for nonconformity to US-NRC license.
The inspection may include, representative sample collecting and
inspection of the contents of sealed containers. The frequency
of sample gathering and opening of containers wiil be determined
at the discretion of Umetco's Site Manager or Radiation Safety
Officer (RSO).
c) The waste shipment will not be scheduled for delivery until the
results of the sampling are submitted to Umetco.
d) Waste material not conforming to Umetco's US-NRC License will
be refused for disposal.
A delivery date and estimated arrival time will be established and conveyed to
the site personnel involved with the actual receiving and accepting the waste
material.
A location in the disposal area will be selected, within the US-NRC approval
disposal area (Cell 3). The third party waste material's location of disposal
will be noted on the shipping manifest and waste disposal plat. The manifest
and plat will be entered into Umetco's permanent records when the shipment
is received and permanently disposed of. The records will be maintained for
review by Umetco's NRC personnel.
SITE SPECIFIC ACTIVITIES
A breathing zone sample will be taken periodically during disposal and cover
activities. If the gross alpha approaches or exceeds 2.5 x 10-11Ci/ml, then
site personnel will be required to notify the Manager of Operations and the
RSO. Activities will be suspended and an investigation wiil be made of the
events that lead to the elevated airborne gross alpha activity. Recommenda-
tions and modifications to activities required to bury waste will be changed.
7.1 Employees will be required to wear appropriate protective equipment,
as deemed necessary by RSO.
7.2 Transport drivers will have to sign the visitor log and site hazard recog-
nition form prior to entering the restricted area. Transport drivers will
not be allowed to assist in unloading activities other than to operate the
transport vehicle.
7.3 All personnel will be required to survey themselves prior to leaving the
site. Survey results wiil be maintained at White Mesa Mill.
7.4 Transport vehicles will be surveyed for removable and fixed alpha and
beta/gamma surveys prior to leaving Umetco's facility. These surveys
will be documented and retained in Umetco's permanent records.
8. Upon arrival of the waste shipment at the White Mesa Miii, the Manager of
Operations or designee will inspect the shipment for conformity to the accom-
pany shipping manifest and previously received documentation described in
3.0. The manifest will be examined by the responsible personnel and the
following items will be checked for accuracy:
a) Manifest number.
b) Description of waste materials shipped.
c) Quantity shipped and received.
d) Conformity to manifest description of waste materials to be disposed
of.
e) Identification of any suspicious materials, such as organics, oils,
solvents, chemicals, etc.
f) Originator and site where waste material was generated.
g) Generator's US-NRC License Number.
h) Appropriate signatures by all parties.
i) Correct dates of shipping and receiving, and
j) Notation will be made on Umetco's manifest of the location of the
waste material's placement within the disposal area,
k) U.S. DOT Hazardous Materials Certificate of Registration.
8.1 Any discrepancies will be brought to the attention of Umetco's person-
nel in charge and the generator. The discrepancy will be immediately
resolved.
8.2 Waste material may be spot surveyed (at the discretion of the receiving
personnel or at the request of management) on the surface for alpha
and beta/gamma. The activity results will be recorded on the shipping
manifest and White Mesa records.
8.3 Material suspected of not meeting the requirements set forth in US-
NRC License SUA-1358 will be kept segregated from the other waste
material until a determination is made of its acceptability for disposal.
Suspect material will be containerized, if necessary, to avoid contami-
nation of other materials. The suspect material will be returned to the
transport vehicle for immediate delivery back to the generator or addi-
tional laboratory tests will be performed to determine the acceptability
of the suspect material. All material that is rejected for disposal will be
returned to the generator within a reasonable time. The shipping mani-
fest will be appropriately marked and a copy will be maintained by
Umetco for documentation of items not acceptable for waste disposal.
9. Acceptable waste material will be dumped from the transport in a safe manner
to minimize dust. If determined that dust will be generated, a water spray will
be applied to the material during disposal. Care will be taken, prior to and
during off loading from the transport not to saturate the material.
10. Accepted solid waste material will be placed on the tailings surface in the
designated disposal area in layers. Each layer of the waste material will be
compacted with at least one pass of the construction equipment prior to
placing an additional layer. Free volumes in the waste material will be mini-
mized by filling, sectioning, or crushing. Random fill or tailings will be used to
fill voids in and around the waste material. A one foot (V) thick, or thicker, if
required, of native soil or mine spoil or mine spoil cover will be placed over the
waste material disposal working area at the end of each shipment or work
day. The fill and cover material will each be compacted with at least one pass
of the construction equipment.
11. A complete set of waste disposal records will be kept at Umetco's White
Mesa Mill. Samples of the forms are located in Appendix A to this SOP. The
records shall consist of:
a) Plat of waste disposal site for each waste shipment.
b) Umetco shipping manifest.
c) Air zone monitoring data.
d) Equipment release forms.
e) US-EPA waste manifest form.
f) Transportation company's Bill of Lading.
g) Laboratory analysis of waste.
h) Waste receipt log.
-4-
12. The SOP may not be modified without the authorization of the Site Manager
or RSO. Waste disposal operations shall be executed in accordance with this
SOP. Any deviation from the SOP must be approved by the Manager of
Operations and RSO. Procedural deviation from the SOP must be in writing
and maintained in the daily site records.
13. In case of any emergency, the following should be performed:
a) Contact the appropriate emergency vehicles. The list of phone
numbers should be conspicuously displayed next to the phone located
in the office trailer (see attached).
b) Contact Site Manager
c) Contact the RSO, and
d) Await further instructions from Manager of Operations or RSO, if situa-
tion warrants.
13.1 Take care of life threatening situations immediately.
13.2 Call the appropriate support facility (medical, vehicle, etc.).
13.3 Call Umetco personnel in the following order:
a) Site personnel calls W.W. Brice (Operations Manager) and/or
G.G. Ray (Maintenance Manager) and S.L. Schierman (RSO).
b) U.S. NRC, if required.
13.4 EMERGENCY PHONE NUMBERS
San Juan County Emergency Response
Fire Department
Emergency Medical Assistance
Hospital
Police
Highway Patrol
911
911
911
911
911
W.W. Brice
G.G. Ray
S.L. Schierman
R. Van Horn
(Director of Operations)
678-2084
678-2912
587-2872
[phone]
lie.(2) Byproduct Material Disposal SOP Redline
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 1 of
Date: JuneDee. 1, Title: l le.(2) Byproduct Disposal 9106
20110
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.
2.
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.
container, side dump container, etc.)
end dump trailer, intermodal
4.
5.
|Results[of analysis for Unat^ Ra-226, Th-230 and Pb-_2j 0 on_all_s]udjes 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
milliremf/hpur (mr/hr) at a range of one meter, for each shipment.
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
F:\WP\Division of Radiation Control\Denison Mines. DUSA\Lic. LRA & License AmendmentsMSL
Amendment for2010\DRC Marlcup Prop lle2 SOPs 12 1 10
DR&RJ.dochttp://intranet.denisonmines.oom/denver/Exeoutive/DAVEAVhite Mesa Mill/1 Io.(2) from ISL
facilities and Mill Waste Disposal/PBL 10_1 le (2) SOP Rev 1 (12 0110) (2).doo
Comment [Rl]: IJoes pUSA require other
analytical that shows that the byproduct rnaterial.
meets the RCRA requirements.- 'Also;is there sortie
type of written pipfile piF the material ? : '' •
Comment [JAT2R1]: l) To be regulated by ;
RCRA as a ha2^dous waste, a tnaterial riiust be a ••
^lid waste per thVRCRA.definition^
Material,'Specijal Niicleir Material and 1 le.(2)'-r:
Byproduct Material are" expressly excluded from the •
.definition-ofsoUd waste uiider RfcRir(42,ySC,6903;^^^
and 40 CFR 2'61-;4{aX4y I^cess wiastes and debr^
from ISL facilities are 1 le;(2) byprpduct:by v ^y--\ •''
definition and<are therefore excludedltfom.Ae' C ^ -
defmitioh.of solid .waste and therefqrejalM^^
•frptn the (fefinition.'of hazardousjwaste m RCRA.-
!2ypUSA'slicqise allows-US:to aixeptUj^ f'. ^ '
byproduct material imder GpnditionSj9.8' and-10^5. %
•3) 'RCRA defines two tjT)es-6f hazairdoiK w . ..
Hazardous wastes can;be.ieidier'charactenstic.- ,.:^^^^ {
hazardous wastes (i.e., ignitaW or
reactive) or listed hazardous.waste (ile/ Hsted under, _
40 eFR;271.30r33 or imder'coiiiparable Ste^^^ '
provisions., 4)-Because lle.(2)t^roductifiay*':- >-• "
include some ofthe same types:pf,cpnstitiieM and .• -
"properties'as RCRA characteristic wastes, analysis^"-"
for RCRA characteristics would hpt hav^;aiiy. value ' -
•in cohfirniing that.a waste is no^^ '•' -.
-characteristic.waste. Because'lie.(2)materi£d. is iiW^
a.'sblid vyaste. 'it cannot be a'RCI?^ charactetistic '
waste. 5) Because RCPLAdisted|Wastes..ar^ ,; .-its;r
determihed by source or origin; analysis for RCRA
cpnstituents wpuld not'have anyijivalue'determiningif:
the.material is'a RCRA Usted wiste. i|Because thei
material's pipcess.pf ofigiii in the 'prpcessing of --^ •
iSource'iiiaterial.as.deiBned 10.CFiR -40.4, the waste a) '
U hot frpm any ilCRA listed .prdcess|^^
'wa*ite is l le;(2) byproduct by definition^ari^^
• be solid waste,.arid,there.fore not k RCRA listed ';' -V
waste. • 6) Because 1 le:(2).materid 'is ,exempted
:RCRA-due to its origin. no andysis.p^^ , .
documentarion'is required; wDUS ^;
ceitificatibn described iii Section 2.pfpf diis SOP as •"
an;added assuraiice that the material consists'solely . '
pf l'i? (2) byproduct and is'not combined with any ,;,
other material or waste. • 7) A chemical.prpfile of flie
inateria] is not required^ and notrreqiiested from the ,
shipper. The oidy reason DUSA asks for die' .-
radiological characterization is.for our pwri • *
,radi6logicEd safety assessment by. therRSO. -
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 2 of
Date: JuneDee. 1, Title: lle.(2) Byproduct Disposal 9106
20110
3.0 IPesignated jPisposall 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 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.
Comment [R3]: Define^e'of disposal, i.e.
placed in a trmch or put on ihe tailing beach andj
describe the diffences for each ^e of disposal. I - '
have seen evidence of both types of disposal diuing
my inspections. \. ',v
Comment [JAT4]: There is iio difference m, '
•procedure for material placed in either trench areas 'y
or'tailings beach areas.. Material fipm each ISL is /
placed in its designated area as pre-detennihe'd.by' s
; the RSO. Designated areas aire assigned Pn-t^^^
pf wliat^ea is availiable, tp maintain!segregation of '
matefial:from'each ISL spurce. ;Thetie is tip criteria '
;for selectipiipf;trenches versusjbeaches and no, , ;
difference in plac'emeiit or coyer.;' "-i " ' "• '
^8. Byproduct ma:terial from each ISL facilitv is disposed in Designated Disposal
Areas specific to that ISL facilitv. 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.
Formatted: Indent: Left: 0.5", No bullets or
numbering • - •
4.0 Notification to Executive Secretary
F:\WP\Division of Radiation ControlVDenison Mines. DUSA\Lio. LRA & License AmendmentsMSL
Amendment for 2010\DRC Marltup Prop 1 le2 SOPs 12 1 10
DR&RJ.doohttp://intranet.denisonmines.com/denver/Exeoutive/DAVE/Whito Mesa Mill/1 le.(2) from ISL
facilities and Mill Waste Disposal/PBL I0_1 le (2) SOP Rev 1 (12 01 10) (2).doo
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 3 of
Date: JuneDee. I, Title: 1 le.(2) Byproduct Disposal 9106
20110
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
provided with the Safety Training Form foopy attaohedAttachment 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.
5.
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
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 bie 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
F:\WP\Division of Radiation ControlVDenison Mines. DUSA\Lic. LRA & License AmendmentsVtSL
Amendment for 201OVDRC Marlcup Prop IIe2 SOPs 12 1 10
DR&RJ.doohttp://intranot.donisonmines.oom/denvcr/Excoutivo/DAVE/White Mesa Mill/110.(2) from ISL
facilities and Mill Waste Disposal/PBL I0_l lc (2) SOP Rev 1 (12 01 10) (2).doo
\ Formatted: Bullets and Numbering
Formatted: Numbered + Level; 2 +
Numbering Style: a, b, c,... + Start at: 1 + .
Alignment: Left + Aligned at: 1" + Indent at:
1.25"
Formatted: Bullets and Numbering
Formatted: Indent: Left: 1"
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1.25" . • '
Formatted: Bullets and Numbering
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 4 of
Date: JuneDee. 1, Title: 1 le.(2) Byproduct Disposal 9106
2011©
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 in situ leaohlSL source will be
segregated from the byproduct material from eaeh-all other in-sitU leachlSL
sourc^. --{ Formatted: Not Highlight
2. Radiation Safety personnel will escort the shipment to the designated location in
the Designated Disposal Area for unloading ofthe 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:
d. The Designated Disposal Area must be located at least 12 feet
from the sides or dikes of the tailings cell:
h e. No travel into the disposal area will be allowed unless the disposal
cell liner is covered by at least 18 inches of soil or fill material at the point of
access.
Formatted: Indent: Left: 0", Hanging; 0.75",
Outline numbered + Level: 1 + Numtiering
Style: 1, 2, 3,... + Start at: 1 + Alignment: Left
+ Aligned at: 0" + Tab after: 0.5" + Indent
at: 0.5", Tab stops: 0.75", List tab + Not at
0.5"
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
Formatted: Indent: Left:
numbering
0.75", No bullets or
4: Prior to unloading, the driver will be instructed to open or untarp the load. The
Radiation Safety personnel will visually inspect tho byproduct material to ensure
that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material rcooived and the manifest
information will be reported to the RSO. Any bypfodupt material suspected of
not meeting the requirements set forth in Section 2.0 of this SOP will bo kept
segregated from other waste material until a determination is made of its
acceptability for disposal.
ST4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, Or
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Date: JuneDee. 1, Title: l le.(2) Byproduct Disposal 9106
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the 7 days have not lapsed, then the shipment may ^ei_but is iiot required to be
contained in the shipping container on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
•{ Formatted: Not Highlight
6.5. If the shipment is determined to be acceptable^ the following procedures will be
followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar
days have lapsed, the byproduct material will then be unloaded in the designated
area. If such notice has not been given or if such 7 day period has not lapsed, then
the byproduct material will be unloaded in an area ofthe 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 liewlv 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 materiarsuspected of
not meeting the requirements set forth in Section 2.0 of this SOP will be kept
segregated from other waste material until a determination is made of its
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached*
to the shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the*
plat of each Designated Disposal Area illustrating the disposal area within the
Designated Disposal Area where the byproduct material will be disposed of.
fL_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 I 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
F:\WP\Division of Radiation ControlVDenison Mines. DUSA\Lic. LRA & License AmendmentsMSL
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facilities and Mill Waste Disposal/PBL 10_1 lo (2) SOP Rev I (12 01 10) (2).doc
Formatted: Indent: Left; 0.25", Hanging;
0.25"
-{ Formatted: Indent; Left: 0.25"
Formatted: Indent: Left; 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25"
No.: PBL-10 DENISON MFNES (USA) CORP.
Rev. No.:R-33 STANDARD OPERATING PROCEDURES Page 6 of
Date: JuneDee. I, Title: I le.(2) Byproduct Disposal 9106
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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 tp 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 iinloading and cover*-
activities. If the gross alpha exceeds 25% of the applicable DAC, then the RSO
will be notified, and all other unloading activities of byproduct material from that
particular ISL site will require the use of respiratory protection, until further
notice by the RSO.
i) |Disposa| aqtivitjes shall be dooumented _through _ photographs. a_ written_^^,
description or both. They shall include: \
How tho material was placed in the tailing oellst *\ ^
If void spaces were filled with tailings? ^
How the area was compacted:
Document that the A foot tailing sands under the shipment was maintained
The shipment was properly covered: and
Where settlement markcris were plaoedr
i^After unloading the byproduct material, replace the tarp or close the trailer, unless*
the trailer is being decontaminated for unrestricted release.
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Comment [R5]: This might be a ^tter fit in a
different spot of the SOP or slightly different
language but you get the idea. The main thing is
that the entire activity .from acceptance to final
deposition needs to be docuinented .;: '
Comment [JAT6]: Please see Section 10
Formatted: Bulleted + Level: 1 + Aligned at:
0.54" + Tab after: 0.79" + Indent at: 0.79"
Formatted: Bullets and Numbering
Formatted: Indent: Left: 0.25", Hanging;
0.25"
f^j) Direct the driver back to the scales for an empty weight. *-
kjHk) The scale house operator will record the empty weight on the appropriate*-
SWT.
n Shipment and disposal activities will be documented as described in Section 10.
below.
-( Formatted: Indent: Left: 0.25"
-( Formatted: Indent: Left: 0.25"
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the
byproduct material will be spread within the designated area within the
Designated Disposal Area to facilitate compaction and covering.
FiVWPVDivision of Radiation ControlVDenison Mines. DUSAM^ic. LRA & License AmendmentsVtSL
Amendment for 201 OVDRC Markup Prop 1 le2 SOPs 12 1 lO
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No : R-32 STANDARD OPERATING PROCEDURES Page 7 of
Date: JuneDee. 1, Title: I le.(2) Byproduct Disposal 9106
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4.
I 4.1
^4.
The byproduct material will be compacted with at least one pass of the
construction equipment prior to placing an additional layer.
-Free volumes in the byproduct material will be minimized by filling, sectioning,
or crushing. Random fill or tailings sands will be used to fill voids in and around
the byproduct material.
_A11 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.
_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.
_The RSO or his designee will inspect the placement ofthe byproduct material
prior to covering to physically verify that the procedures in this Section 7.0 have
been adequately performed.
-[ FofTTiatted: Indent: Left: 0", Hanging: 0.5" ]
FiVWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmentsVISL
Amendment for 201 OVDRC Marltup Prop lIo2 SOPs 12 1 10
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 8 of
Date: JuneDee. 1, Title: I le.(2) Byproduct Disposal 9106
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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 resfricted 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
Material" issued May 1987. Trailers requiring repair will be decontaminated for
unrestricted release, to facilitate repairs by the transporter at the transporter's own site.
Trailers may be repaired without undergoing full decontamination if repaired within the
restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard
Operating Procedures for the appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
a)
b)
all areas of the Mill covered by Jhis procedure^ har'l hats, safety Blasses and
steel-toed shoes are required at a minimum. These must be worn in the restricted
area of tiie Mill. Prior to disposal, the RSO will determine what level of
respiratory protection, if any, will be required.
Industrial Hazards and Safety
Use caution when the trailers are backing to the unloading area.
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.
Comment [R7]: Dry soils might heed respirator
protection or dust control to coiitrol'airbome
cphtaihination and exposure and should be evaluated
by the RSO prior to disposal. ;
Comment [jAT8]: Please.see insertipn. - -.^
:Kesjp,ii^diy'protection is the subjectjpf other plans;
tfjiat norb^^^ . ;
c) Drivers must use caution during the unloading process and be aware of any
overhead hazards.
F:VWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmentsMSL
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 9 of
Date: JuneDee. I, Title: 11e.(2) Byproduct Disposal 9106
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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
handrails. 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 mTprh.
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.
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Amendment for 201 OVDRC Marlcup Prop Ile2 SOPs 12 I 10
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 10 of
Date: JuneDee. I, Title: lle.(2) Byproduct Disposal 9106
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10.0 Documentation
I. a) Documentation of Shipments
+T 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 vyritten description or both. Attachment 2 or other written
description will include:
• How the material was placed in the tailing cells:
• If void spaces were filled with tailings sands:
• How the area was compacted:
• Document that the 4 foot depth of tailing sands under the shipment
was maintained:
• Document that each disposal area is located at least 12 feet from the
sides or dikes of the tailings area:
• Confirmation that the shipment was properly covered: and
•—Where settlement markers were placed.
•-
3T»_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.
Formatted: Indent: Left: 0,5", No bullets or
numbering
-( Formatted: Indent: Left: 0.25", First line: 0"
-{ Formatted: Indent: First line: 0"
Formatted: Indent: Left: 1.25"
Formatted: Outline numbered + Level: 1 +
Numbering Style: Bullet + Aligned at: 1" + Tab
after: 1.25" + Indent at; 1.25"
4T1: 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. (License Condition 10.5F). [summary due same veaf1
F:VWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmentsMSfc
Amendment for 201 OVDRC Marlcup Prop 1 Ie2 SOPs 13-^40
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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 cafidy, 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-prh: Denison Mines (USA) Corp.'s equipment has the right of
way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signattire) Date
ATTACHMENT 2
1 le.(2) DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the 1 le.(2) 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:
How was the material was-placed in the tailing cells?
Were void spaces filled with tailings?
How was the area compacted?
^ 1 Formatted: Indent: Left: -0.25", No bullets or
numbering
• i Formatted: Indent: Left: -0.25", No bullets or
numbering
Formatted: Indent: Left: -0.25", No bullets or
numbering
Document that the 4 foot depth of tailing sands under the shipment was maintained
•*•- ---] Formatted: Indent: Left: -0.25", No bullets or
numbering
Formatted: Indent: Left: -0.25", No bullets or
numbering
Document that each disposal area is located at least 12 feet from the sides or dikes of the tailings area:
"( Formatted: No bullets or numbering ]
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
- Formatted: Indent: Left: -0.25", No bullets or
numbering
Formatted: Indent: Left: -0.25", No bullets or
numbering
-{ Formatted: No bullets or numbering
If required, where were settlement markers were placed?
Formatted: Indent: Left: -0.25", No bullets or
numbering
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
lle.(2) Byproduct Material Disposal SOP Clean
No.: PBL-10
Rev. No.: R-3
Date: June. 1, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 1 of 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
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:
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 10
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 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 ofthe
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 ofthe
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 ofthe Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
8. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Executive Secretary
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
kept on file at the Mill.
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
C:\Users\jtischler\Desktop\SOP repsonse 1 le2 monitorVMarkup Prop I le2 SOPs 05.31.11 clean.doc
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 3 of 10
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
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
C:\Users\jtischler\Desktop\SOP repsonse I Ie2 monitor\Markup Prop 1 le2 SOPs 05.31.11 clean.doc
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 4 of 10
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 ofthe
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell;
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container on site until the required 7 day notice has been given and the 7 calendar days have
lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and imloading will proceed.
c) After unloading, the Radiation Safety personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the RSO. Any byproduct material
suspected of not meeting the requirements set forth in Section 2.0 of this SOP will be kept
segregated from other waste material until a determination is made of its acceptability for
disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of.
f) Beta-gamma measurements will be taken at several locations around the unloaded material.
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 5 of 10
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 one pass of the construction equipment
prior to placing an additional layer.
Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing. Random
fill or tailings sands will be used to fill voids in and around the byproduct material.4. All
contaminated equipment shall be 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.
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 6 of 10
3. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
4. The RSO 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 Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or
Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
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 ofthe trailer during the initial unloading operation.
c) Drivers must use caution during the unloading process and be aware of any overhead hazards.
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 7 of 10
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 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 8 of 10
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 were filled with tailings sands;
• How the area was compacted;
• Document that the 4 foot depth of tailing sands under the shipment was maintained;
• Document that each disposal area is located at least 12 feet from the sides or dikes
ofthe tailings area;
• 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 amoimts 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]
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 9 of 10
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 decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
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No.: PBL-10 W DENISON MINES (USA) CORP. ^
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 10 of
Date: June. 1,2011 Title: 11 e.(2) Byproduct Disposal 10
Driver (Signature) Date
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No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 11 of
10
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
How was the material placed in the tailing cells?
Were void spaces filled with tailings?
How was the area compacted?
Document that the 4 foot depth of tailing sands under the shipment was maintained
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No.: PBL-10 W DENISON MINES (USA) CORP. ^
Rev. No.: R-3 STANDARD OPERATING PROCEDURES Page 12 of
Date: June. 1, 2011 Title: 1 le.(2) Byproduct Disposal 10
Document that each disposal area is located at least 12 feet from the sides or dikes of the tailings area;
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
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DENISO
MINES
September 12, 2011
Deiiison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel: [phone]
Fax: 303 389^125
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 August 4, 2011 Regarding 11.e(2) Byproduct
Disposal SOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA)'Corp's proposed revisions to the White Mesa Mill 11e.(2)
Byproduct Disposal SOP in response to DRC's letter of August 4, 2011, which we received on August 11,
2011. This ALigust 4, 2011 letter contained one comment, detailed below, regarding Item No 4 of our May 31,
2011 letter and draft revisions to the SOP. We have attached an edited redline copy of the SOP in which
Denison's modifications or additional language in response to DRC's comment are indicated in a second
color.
We have discusseij the comment in DRC's August 4, 2011 letter with Mr. David Rupp, who indicated that
although our draft revisions to the SOP attempted to address Item No. 4, the response letter was unclear or
incorrect. " He indicated that Denison needed to:
a) Correct the letter's quotation of DRC's comment, and
b) Modify the SOP and attachment, as necessary, to more exactly address each word in the license
conditions referred to in DRC's comment.
We have re-quoted below, DRC's comment on Item No. 4, and revised our response.
DRC Comment
"Item No. 4 of your May 31, 2011 letter appears to not fully respond td DRC comment no. 4 in the subject
April 21, 2011 DRC letter."
For ease of reference. Comment No. 4 of DRC's April 21, 2011 letter is also provided below in its entirety.
"License Condition 10.5E states that.
The licensee shall also submit for Executive Secretary approval a revised written Standard Operating
Procedure (SOP) for ISL disposal on or before December 1, 2010. The revised SOP shall describe the
documentation required for ISL disposal, which shall include but is not limited to the following...'
N:\SOPs and Procedures\SOP repsonse 11e2 Disposal\09.12.11 response to comment 4\09.12.11 Response to DEQ
08.04.11 RFI11e2SOP.doc
Letter to Mr. Rusty Lundbe!^
11e.(2) SOP RFI Response
September 12, 2011
Page 2
DRC Findings: The emphasis here is on documentation. License Condition 10.5D also requires
documentation, "of all disposal activities." DUSA must develop a form for ISL disposal
documentation, to coverall the documentation requirements of License Condition 10.5E and 10.5D."
Denison Response: The revisions have been made as requested. The proposed language has been
accepted with the additional text shown in color in Section 10.0 of the SOP. A form has been added as
Attachment 2 of the SOP.
We hope this clarifies any confusion that resulted from our former response to Comment No. 4.
Please contact me if you have any questions or require any further information.
Yours very truly,
DENISON MINES (USA) CORP.
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydeniund
Harold R. Roberts
David E. Turk
K. Weinel
Central files
DENISO
MINES
1 le.(2) Byproduct Disposal SOP
Clean Copy
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 1 of 11
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives 1 le.(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 hmit of 5,000 cubic yards of byproduct
material from a single source, set out in Mill License condition 10.5A
3.0 Designated Disposal Area
The RSO will designate from time to time one or more designated disposal areas (each a "Designated
Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each
Designated Disposal Area must meet the following criteria:
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 11
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. The elevation of the Designated Disposal Area once filled with byproduct material must not
exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the
tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
7. Prior written approval must have been obtained from the Executive Secretary of the Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
8. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Executive Secretary
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
kept on file at the Mill.
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
DUSA's safety rules and procedures while on company property. The scale house operator
will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 3 of 11
4.
5.
Forms will be turned 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 Disposal Area specified by
the RSO.
6. Prior to transporting material to the Designated Disposal Area, the driver will be instructed to
open or untarp the load. The Radiation Safety personnel will visually inspect, to the degree
possible, the byproduct material to ensure that the material matches the material description on
the shipping manifest. Any discrepancies between the byproduct material received and the
manifest information will be reported to the RSO.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the RSO
that the material in question conforms to Section 2.0 of this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
6.0 Byproduct Material Unloading
1. The RSO will specify the specific location within the broader Designated Disposal Area for
disposal of the shipment. In designating the specific location within the broader Designated
Disposal Area for disposal of the shipment, the RSO will ensure that all byproduct material will
be segregated from any Mill material and equipment disposed of in the cell pursuant to Mill
license condition 10.4, and that the byproduct material from each ISL source will be segregated
from the byproduct material from all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location in the
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 4 of 11
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container on site until the required 7 day notice has been given and the 7 calendar days have
lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading' the Radiation Safety personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material received and
the manifest information will be reported to the RSO. Any byproduct material suspected of not
meeting the requirements set forth in Section 2.0 of this SOP will be kept segregated from other waste
material until a determination is made of its acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of
0 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 I meter, shall be recorded.
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 5 of 11
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Radiation Department's copy of the shipment
documentation. If organics are detected, the RSO must be advised, and no compaction or
covering activities relating to the shipment shall occur until specifically instructed by the RSO.
The RSO will determine if any addifional 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.
I) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the RSO, or his designee, the byproduct
material will be spread within the designated area within the Designated Disposal Area to
facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be 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
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 6 of 11
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The RSO or his designee will inspect the placement of the byproduct material prior to covering
to physically verify that the procedures in this Section 7.0 have been adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks 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
Terminafion of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987.
Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the
transporter at the transporter's own site. Trailers may be repaired without undergoing full
decontamination if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
e) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MC^S (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 7 of 11
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Radiation Department files:
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 8 of 11
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 were filled with tailings sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
The Mill will maintain on file a copy of the Executive Secretary's written approval of each
Designated Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Executive Secretary on or before November I of the calendar year. (License
Condition 10.5F). [summary due same year]
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12, 2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 9 of 11
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eafing 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 neeessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 10 of 11
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal area?
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 11
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings'
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
1 le.(2) Byproduct Disposal SOP
Redline Copy
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-^ STANDARD OPERATING PROCEDURES Page 1 of
Date: Title: 1 le.(2) Byproduct Disposal £106
Jun^Scpt.E^oc. 1 •
20110
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives He.(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. ^fflli 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
milUremf/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
F:\WP\Division of Radiation ControlNDonison Mines. DUSAVLic. LRA & License AmondmcntsMSb
Amondtncnt for 2010VDRC Marltup Prop llo2SOPo 12 1 10
DR&RJ.dochttp://intranet.denisonmines.com/donver/Exocutive/DAVEAVhite Mesa MiU/1 lo.(2) from ISL
facilitioo and Mill Waoto Dioposal/PBL 1Q_1 lo (2) SOP Rev 1(12 01 10) (2).doo
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No.: PBL-10 DENISON MINES (USA) CORP.
Page 2 of Rev. No.: STANDARD OPERATING PROCEDURES Page 2 of
Date: Title: 1 le.(2) Byproduct Disposal
JttfHsS.Cpt .0^6- I,
20110
10.5 A
3.0
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 of the cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or
dikes of the tailings cell;
5. The elevation of the Designated Disposal Area once filled with byproduct
material must not exceed the plane or grade of the elevation of the uppermost
flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the
Mill that demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated
Disposal Area; and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the
sides or dikes of the tailings cells; and
7; Prior written approval must have been obtained from the Executive Secretary of
the Utah Radiation Control Board (the "Executive Secretary") for each
Designated Disposal Area, under Mill License condition I0.5C, and evidence of
such approval must be on file at the Mill.
;^8. Byproduct material from each ISL facilitv is disposed in Designated Disposal.
Areas specific to that ISL facilitv. 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.
F:\WPVDivision of Radiation ControlVPonison Minos. DUSAVLio. LRA &. Liconoe j\mondmontf.VtSb
Amendment for 201 OVDRC Markup Prep-t4o2 SOPs 12119
DR&RJ.dQChttp://intranet-.donisonminoii.com/donver/Exocutive/DAVEAVhito Mesa Milt/1 lo.(2) from tSL
facilities and Mill Waoto DisposayPBL 10_1 lo (2) SOP Rev 1 (12 01 10) (2).doe
Formatted: Indent; Left: 0.5", No bullets or
numbering
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 3 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
20110
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
nodfication 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
provided with the Safety Training Form (copy attachedAttachment 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).
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
Disposal Area specified by the RSO.
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 bv the RSO that the material in question
conforms to Section 2.0 of this SOP.
F:VWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmetrtsMSL
Amendment for 201 OVDRC Markup Prop 1 le2 SOPs 12 1 10
DR&RJ.dochttp://intranet.denisonmines.com/denver/Executive/DAVE/White MesaMill/l lo.(2) from ISL
facilitioo and Mill Waste DispooayPBL 10_lle (2) SOP Rev 1 (12 01 10) (2).doo
Formatted: Bullets and Numbering
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1.25"
(Formatted: Bullets and Numbering
{Formatted: Indent: Left: 1"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-^ STANDARD OPERATING PROCEDURES Page 4 of
Date: Tide: 1 le.(2) Byproduct Disposal 9106
Juii^Scpt.'Doc. 1.
20110
Barrels containing soil or sludges shall be checked to determine if they
are full prior to transporting them for disposal. Barrels not completely
full shall be documented and shall be filled with tailings or soil prior to
disposal. (License Condition 10.5.B).
6.0 Byproduct Material Unloading
1. The RSO wiil specify the -specific location within the broader Designated
Disposal Area for disposal of the shipment. In designating the specific location
within the broader Designated Disposal Area for disposal of the shipment, the
RSO will ensure that all byproduct material will be segregated from any Mill
material and equipment disposed of in the cell pursuant to Mill license condition
10.4, and that the byproduct material from each in situ leachlSL source will be
segregated from the byproduct material from eaefa-all other in situ leachlSL
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. Proposed Methods and Procedures to Fully Protect the Liner While Accessing *
Tailings Cells for Disposal of ISL Byproduct Material and Mill Equipment
_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 tailings cell (documentation of the disposal area
must be completed and on file prior to any disposal activities);
3T e. No travel into the disposal area will be allowed unless the disposal
cell liner is covered by at least 18 inches of soil or fill material at the point of
access.
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c,... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1,25"
(Formatted: Bullets and Numbering
-{ Formatted: Not Highlight
Formatted: Indent: Left: 0", Hanging: 0.75",
Outline numbered + Level: 1 + Numbering
Style: 1, 2, 3, ... + Start at: 1 + Alignment: Left
+ Aligned at: 0" + Tab after: 0.5" + Indent
at: 0.5", Tab stops: 0.75", List tab + Not at
0.5"
Formatted: List Paragraph, No bullets or
numbering, Widow/Orphan control
Formatted: Indent: Left: 0.75", No bullets or
numbering
4-. Prior to unloading, tho driver will bo instructed to open or untarp the load. Tho
Radiation Safety personnel will visually inspect the byproduct material to ensure
that the material matches tho material description on the shipping manifest. Any
discrepancies between tho—byproduct—material received and the—manifest
FiVWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmentsVISL
Amondmont for 201 OVDRC Markup Prop 1 lo2 SOPo 12 1 10
DR&RJ.dochttp://intranet.denisonmincs.com/donver/Executivc/DAVE/Whito Mesa Mill/1 lo.(2) from ISL
faoilitioo and Mill Waoto Dioposal/PBL 10_1 lo (2) SOP Rev 1 (12 01 10) (2).doc
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 5 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
Jun6Scpt.l36c. 1 •
20110
5T4.
information will bo reported to the RSO. Any byproduct material suspoctod of
not mooting the requirements set forth in Section 2.0 of this SOP will bo kept
segregated from other waste material until a detormination is made of its
acceptability for disposal.
_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 mav j)e^ but is not required to be
contained in the shipping container on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
{ Formatted: Not Highlight
^5, If the shipment is determined to be acceptable^j 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. AnV
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.
Formatted: Indent: Left: 0.25", Hanging:
0.25"
-{ Formatted: Indent: Left: 0.25"
The location of the shipment of the byproduct material will be documented on the*
plat of each Designated Disposal Area illustrating the disposal area within the
Designated Disposal Area where the byproduct material will be disposed of.
Formatted: Indent: Left: 0.25", Hanging:
.0.25"
F:VWPVDivision of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmcndmentoVISfc
Amendment for 201 OVDRC Markup Prop 1 le2 SOPs 12 110
DR&RJ.dochttp://intranet.denisonmines.com/denver/Executive/DAVEAVhite Mesa Mill/1 lo.(2) fronrt ISL
facilitioo and MiU Waste Diopooal/PBL 10_1 lo (2) SOP Rov 1 (12 01 10) (2).doc
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 6 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
20110
f) Beta-gamma measurements will be taken at several locations around the unloaded*
material. This information will be recorded on the Radiation Department's copy
of the shipment documentation. The measurement range in mrem/hr at 1 meter,
and the average measurement, measured in mrem/hr at 1 meter, shall be recorded.
g) Measurements using a photoionization detection meter ("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 reisult of
the detection of the organics, and will implement any such precautions. The RSO
will also contact DUSA corporate regulatory personnel and the shipper to verify
that the detected organics are lle.(2) byproduct material from the shipper's ISL
facihty. Once the RSO has verified that the organics are byproduct material
compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover*
activities. If the gross alpha exceeds 25% of the applicable DAC, then the RSO
will be notified, and all other unloading activities of byproduct material from that
particular ISL site will require the use of respiratory protection, until further
notice by the RSO.
ii: JlSpOSE activities shall bo documented through photographs, a
description or both Thev shall include:-
How the material was placed in the taihng cells;
If void spaces woro filled with tailings;
How the area was compacted:
Documerit that tho 4 foot taihng sands under the shipment was maintained
The shipment was properly covered: and
Where settlement markers wore placed.
frHDAfter unloading the byproduct material, replace the tarp or close the trailer, unless*
the trailer is being decontaminated for unrestricted release.
fikj) Direct the driver back to the scales for an empty weight.
k^k) The scale house operator will record the empty weight on the appropriate*
SWT.
I) Shipment and disposal activities will be documented as described in Section 10,
below.
F.VWPVDivioion of Radiation ControlVDenison Mines. DUSAVLic. LRA & License AmendmentsVISL
i\mendmont for 201 OVDRC Markup Prop 1 lo2 SOPo 12 110
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facilities and Mill Waoto DisposayPBL 10_1 lo (2) SOP Rov 1(12 01 10) (2).doc
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Formatted: Indent: Left; 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25"
;^1(aH|^men^[3A^
Formatted: Bulleted + Level: 1 + Aligned at:
0.54" + Tab after: 0.79" + Indent at: 0.79"
Formatted: Bullets and Numbering
Formatted: Indent: Left: 0.25", Hanging:
0.25"
{ Formatted: Indent: Left: 0.25"
{ Formatted: Indent: Left: 0.25"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-32 STANDARD OPERATING PROCEDURES Page 7 of
Date: Title: 1 le.(2) Byproduct Disposal £106
2011©
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 passfour passes of the*
construction equipment prior to placing an additional layer.
-Free volumes in the byproduct material will be minimized by filling, sectioning,
or crushing. Random fill or taiUngs sands will be used to fill voids in and around
the byproduct material.
4. 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.
AS. ^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.
Formatted: Numbered + Level: 1 +
Numbering Style: 1, 2, 3, ... + Start at: 1 +
Alignment: Left + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Indent: Left: 0.5"
Formatted: Numbered + Level: 1 +
Numbering Style: 1, 2, 3,... + Start at: 1 +
Alignment: Left + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Indent: Left: 0.5", No bullets or
numbering
Formatted: Numbered + Level: 1 +
Numbering Style: 1, 2, 3, ... + Start at; 1 +
Alignment: Left + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Indent: Left: 0.5", No bullets or
numbering
Formatted: Numbered + Level: 1 +
Numbering Style: 1, 2, 3, ... + Start at: 1 +
Alignment: Left + Aligned at: 0.25" + Indent
at: 0.5"
Formatted: Body Text 3, Indent: Left: 0.5" )
Formatted:; Numbered + Level: 1 +
Numbering Style: 1, 2, 3, ... +.Start at; 1 +
Alignment: Left + Aligned at: 0,25" + Indent
at: 0.5"
Formatted: Numbered + Level: 1 +
Numbering Style; 1, 2, 3, ... + Start at; 1 +
Alignment; Left + Aligned at: 0.25" + Indent
at: 0.5"
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 8 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
20110
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 I ofthe Nuclear
Regulatory Commission's (NRC's) PoUcy and Guidance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987. Trailers requiring repair will be decontaminated for
uru-estricted release, to facilitate repairs by the transporter at the transporter's own site.
Trailers may be repaired without undergoing full decontamination if repaired within the
restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard
Operating Procedures for the appropriate conveyance:
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
Ifiall areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be worn in the restricted
area of the Mill. Prior to disposal, the RSO will determine what level of
respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
•fe&min^rtfe[ll70-i3n;^
imjtec'tioiEprrdustw^
;conta!mn'atKm''ak(i
Use caution when the trailers are backing to the unloading area.
bjd} Ensure that all personnel within 50 feet of the area where an end dump
ti-ailer 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.
€r}^ Drivers must use caution during the unloading process and be aware of
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 9 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
S lifi^S < ^^60 • 1 *
20110
any overhead hazards.
d)flDo not place any part of your body inside the trailer when the trailer is being
tipped and the tailgate is open. Only work around the tailgate after it has been
properly blocked open.
_Use caution when entering or exiting equipment. Be sure to use the
ladders and hand rails. Do not jump off the equipment.
f)h]Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects
corrected before the equipment is used. If safe to do so, the equipment may be
driven to the shop for repairs. Otherwise, the equipment must be towed or
repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain
no one is in a dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed Umit of 15 mTprh.
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 refuehng.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
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No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 10 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
20110
berms where required.
10.0 Documentation
1. a) Documentation of Shipments
4T 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 yyill -be documented on the Disposal Documentation*
Form provided in Attachment 2. Attachment 2 mav be accompanied bv
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 were filled with tailings sands;
• How the area was compacted;
• Document that materials placed on taihngs 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 bv the
engineering department);
• Document that there are 4 feet of taiUngs 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 bv the engineering
department);
• Confirmation that the shipment was properly covered; and
•—Where settlement markers were placed.
Formatted: Indent; Left: 0.5", No bullets or
numbering
5T»_The Mill will maintain a plat of each Designated Disposal Area, which*
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: { Formatted: Indent: Left: 0.25", Fjrst line: 0" ];
"( Formatted: indent; First line: 0" ]
{ Formatted; Indent; Left; 1.25"
Formatted; Outline numbered + Level: 1 +
Numbering Style: Bullet + Aligned at: 1" + Tab
after: 1.25" + Indent at: 1.25"
No.: PBL-10 DENISON MINES (USA) CORP.
Rev. No.: R-33 STANDARD OPERATING PROCEDURES Page 11 of
Date: Title: 1 le.(2) Byproduct Disposal 9106
20110
illustrates the location of each shipment of byproduct material.
^2. The Mill will maintain on file a copy of the Executive Secretary's written
approval of each Designated Disposal Area.
4.3. 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 I of
the following calendar year. (License Condition 10.5F). Isummarv due same vearl
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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 ntprh; 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, if 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.
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
ATTACHMENT 2
lle.(2) BYPRODUCT MATERUL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain*- r - j Formatted: indent: Left; O"
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?
-[ Formatted: No bullets or numbering
Formatted: Indent: Hanging: 0.25", No
bullets or numbering
Formatted: Indent: Left: -0.25", No bullets or
numbering
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal area?
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
4 4\
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?
\ Formatted: Indent: First line: 0"
Were void spaces filled with tailings?
Was the shipment properly covered?
Formatted: Indent: Hanging: 0.25", No
bullets or numbering
Formatted: Indent; Left: -0.25", No bullets or j
numbering . . j
Formatted: Indent: Left; -0.25", No bullets or
numbenng
Are additional settlement monitors required to be placed for this generator?
^ Formatted: No bullets or numbering ]
Formatted: Indent; Left: -0.25", No bullets or
numbenng
If required, where were settlement markers were placed?
Formatted: Indent: Left: -0.25", No bullets or
numbenng
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
W^AO