DRC-2011-007655 - 0901a06880292886

State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
December 6, 2011
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
CERTIFIED MAIL
(Return Receipt Requeste(j)
Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: Approval of lle.(2) Byproduct Disposal Standard Operating Procedures (SOPs)
We received a letter dated November JO, 2011 letter from DUSA', which transmits a 1 le.(2) Byproduct
Disposal Standard Operating Procedui-es (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 re\'iewed 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 RADL\TION CONTROL BOARD
Rusty LundbergrExecutive Secretary ^"^^
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HI Jo Ann Tischler
° Denison Mines (USA) Corp
° Denver, Co 80265
1050 Seventeenth ST, STE 950
•PS Form; 3800. August 2006
\'-)5 North !930 Wesl • Salt Lake City. UT
,Maiiin>; Address: P.O. Box 144850'Salt Liike City. IT S4I 14-4850
Tclciihoiic (.SOI I 536-4250 • Fax (KOI) 533-4097 • T.i:).!). [phone]
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See Reverse for Instructibris-
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
October 6,2011
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:
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RE: 10/6/11; transmittals revised SOP/ DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PS Form 3800.'August, 2006 'See Reverse for Instructions,
SUBJECT: September 12, 2011 DUSA Transmittal of Revised Standard Operating Procedures
(SOPs), Title: 1 le.(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 comiiient. 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 j
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. 1
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 tlie
various License Condition requirements.
-1
Our comments 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 Wesl • Salt Lake City, UT
Maihng Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D; [phone]-
www.rleq.uiah.R/n-
Printed on lOO'/r recycled paper
Page 2
"(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an
area ofthe 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 of the
tailpigs cell."
The for^ 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.
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 ofthe 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
LC 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 of the SOP. The form needs to
call for or make reference to the required documentation to assure the complete specific
requirements of this License Condition have been met. These complete requirement needs
to be added to the body of the SOP as well.
C. License Condition 10.5D. Our comments on this license condition are contained in the
comments of this letter.
III. Additiona] 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 banels.
(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.
Sinc^ely,
d Oi/uT .^^^—-—"
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
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Stateof 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:
lle.(2) Byproduct Disposal No. PBL-10 Rev. No: R-3 June 1, 2010; April 21, 2011 DRC
Request for Information Letter, regarding similar proposed SOPs R-2 Dec.l, 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 Titie:
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,
David A. Rupp, P.E.
Licensing and Permitting Section
DAR:dr
F:\DUSA\LRA&License \1SL AmendmentM le2 Byproduct Disposal CMT2 8-2011 .doc
195 North 1950 West • Salt Uke City, UT
Mailing Address: P.O. Box 144850 • Salt Uke City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.uiah.gov
Printed on 100% recycled paper
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RE:8/4/11; COMMENT & RFI 5/13/11 SOP/S / DR
Jo Ann Tischler
Denison Mines (USA) Corp
1050 Seventeenth ST, STE 950
Denver, Co 80265
PS FornV380p, August 2006 Sec Re verse ;f or. Instructions*!
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL.
Rusty Lundberg
Director
State of Utah
GARYR. HERBERT
Governor
GREG BELL
Lieutenant Governor
April 21, 2011
CERTIFIED MAIL
(Retum Receipt Requested)
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Denison Mines (USA) Corp. (DUSA)
1050 Seventeenth Street, Suite 950
Denver, CO 80265
Dear Ms. Tischler:
SUBJECT: December 1, 2010 DUSA Transmittal Letter, Three Separate Draft Standard Operating
Procedures (SOPs); SOPs for Title: He.{2} Byproduct Disposal No. PBL-10 Rev. No.: R-2
Dec. 1, 2010: Comments and Request for Information
We have received the subject December 1, 2010 DUSA letter, transmitting three separate proposed
Standard Operating Procedures (SOPs). The subject of this letter is our review of one of these SOPs, i.e.
the Title: lie.(2) Byproduct Disposal Standard Operating Procedures [SOPs] with subject version
number. The subject Titie: 1 le.(2) Byproduct Disposal SOPs were submitted by DUSA to comply with the
requirements of Liceiise 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.
b. 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 in
this letter are captured in our red-line strike-out notations.
c. 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, l.c. (1) through (3) directiy below, concern 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 Uke City, UT
Mailing Address: P.O. Box 144850'Salt Lake City, UT 84114-4850 ,
Telephone [phone]' Fax [phone] • T.D.D. [phone]
www.deq.utah.gov . , •
Printed on 100% recycled paper
Page 2
The concept is to have byproduct materials pre-inspected before its arrival
adjacent to the disposal site. • . - - v.
(2) . As shown in red-line, we suggest that DUSA consider moving existing paragraph
6.4 and revise it to language similar to the attached new red-line paragraph 6.5.c of
the subject SOPs. The concept here is to assure after unloading, that no items of
concem were hidden or obscured in the material.
(3) . To be consistent with License Condition 10.4A, and to increase compaction and
reduce settlement, as mentioned in paragraph lc 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
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 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 of the inspection report is attached to this letter. In the "Deficiencies" paragraph on
page 2 of this report, the DRC inspector stated that at that time, the ISL documentation did
not include, "Description of how ISL material [was] being placed in the slit trenches..."
and, "Description of other activities (i.e. Barrels not being completely full being filled with
tailings or soil as described in License Condition 10.5B)." In the Conclusions and
Recommendations paragraph on page 4 of that report, it states that DUSA should ,
"Document the placement of ISL material in tailing Cell #3 with a detailed description [ofl
all dispos;al activities involved with the disposal of each shipment. License Condition
10.5D states,'All disposal activities shall be documented.'"
The disposal documentation for each shipment, including the method of disposal such as
trench disposal or other approved disposal method with backfill, needs to be documented
for each individual shipment. Documentation requirements for the above activities were
not included in the subject SOPs as submitted, but need to be.
b. Balloon comments Rl through R4 are provided in the rnargins of the attached red-line
strike out copy of the subject SOPs. Please address these comments.
Please review the above conrmrients, 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 2010\t te2 Byproduct Disposal Cmtl dr&rj.doc
BR
DENlsoJ)lI
MINES
November 10, 201 1
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 841't4-4850
-a37 r:;*
Denison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : [phone]
www.denieonmines.com
D[:ru-2u11-C07655
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 lnformation of October 6, 201 1 Regarding 1 1e.(2) Byproduct
DisposalSOP
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. ln 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 ol review we have quoted DRC's
responses.
DRC Comment
l. License Condition 10.5E states,
comments verbatim in italics below, followed by Denison's
"The licensee shall also submit for Executive Secretary approval a revised wriften Standard Operating
Procedure (SOP) for ISL disposal on or before December l, 2010. The revised SOP shall describe the
documentation required for ISL disposal, which shall include but is not limited to the following:"
"(1) The materialdisposal area must be located on a tailings beach area of the disposalcellor on an area
of the cell that is underlain by tailings sands;
"(2) The elevation of the materialdisposal 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 materialwillbe segregated from any mill materialand equipment disposed of in the
cells pursuant to License Condition 10.4, and the ISL byproduct materialfrom each in-situ leach source will
be segregated from the byproduct materialfrom allother 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 Disposal\11.10.11 Response to DEQ\11.'10.11 Response to DEQ comments
'l'le2 SOP.doc
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Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 201 1
Page2
"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. lt appears that in some cases, additionalverbiage will need to be added to the
body of the SOP for said form to reference, in order to fulfillthese requirements. We note the following:
A. License Condition 10.5E(2) is not captured on the form. The form needs to callfor or make
reference to the required documentation of a suruey and review, or other documentation, that will
show the specific requirements of License Condition 10.5E(2) have been met. lt 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 callfor or
make reference to the required documentation to demonstrate that ISL materialis segregated from
both disposed mill material/equipment as well as allother in-situ leach sources.
It appears that the form needs to make reference to:i). The plats of the designated ISL byproduct materialdisposal 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. lt 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 10.58, 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." lt 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
dimensionalclearance 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 stafes or references the documentation required.
The requirements referring to documentation addressing dimensional clearance have been added to the form
as required.
DEN'SOJ)II
MINES
Letter to Mr. Rusty Lundberg
11e.(2) SOP RFI Response
November 10, 20'11
Page 3
tt. License Condition 10.5D states that, "Alldisposalactivities shallbe documented and records thereof
maintained on-site. The documentation shall include descriptions of the ISL waste and the disposal
locations, as wellas allactions required by this License condition." This License Condition requires
documentation of all ilSLl 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. 10.58 through 10.5.D:
A. License Condition 10.58. Our comment regarding this condition is covered by paragraph l.C of
this letter.
Denison Response: No specific response required.
B. License Condition 10.5C is not completely captured on the form. The SOP appears to make
partial reference to this condition in paragraph 3.7 of the SOP. The form needs to call for or
make reference to the required documentation to assure the complete specific requirements of
this License Condition have been meL 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.
lll. Additional Comments.A. The subject SOP,(i) Paragraph 6.4, the term "shipping containef may be interpreted to refer to several
things. lt appears the term "shipping containef 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 soiland sludges," must be added.
Denison Response: The phrase has been added as requested.
DENISOJ)//MINES
Letterto Mr. Rusty
l1e.(2) SOP RFI
November 10,2011
Page 4
Please contact me if
Yours very truly,
Derson llrres (USA)
Jo Ann Tischler
Director, Compliance
David C.
Harold R.
David E. Turk
K. Weinel
Centralfiles
have any questions or require any further infonnation.
Permitting
DEN'gOJY/
" IUIINES
11e.(2) Byproduct Material Disposal SOP Redline
No.: PBL-10
Rev. No.: R-3
Date: SepL-{4NstL
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page I of ll*
Title: I le.(2) Byproduct Disposal
2011
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives lle.(2) byproduct material ("byproduct material")
lrom 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 Bvproduct 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 Desienated 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-l2Nsv.
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page2 ot ltl
Title: lle.(2) Byproduct Disposal
20tt
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 taitings 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 tThe 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 MiU 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
bLThe bottom of the Designated Disposal Area is located at least l2 feet from the sides or dikes
of the tailings cells; and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the b]product material from all other in-situ leach sources:
7. ISL wastes will be disposed in cells that have received prior written aoproval from the
Executive Secretary for this purpose.
*S._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 Secretarv
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
Formatted: List Paragraph, No bullets or
numbering, Widoworphan control
Fomatbd: Font: (Default) Times New
Roman, 12 pt, Not Italic
Formatt€d: Indent: Left: 0.5", No bullets or
Formattedl Font: Not Bold
Fomatted: List Paragraph, No bulleB or
numbering, Widodorphan control
Fomatted: Indent: Left: 0.75"
No.: PBL-10
Rev. No.: R-3
Date: Sopt-.-t2Ng1
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page3 of ll*
Title: lle.(2) Byproduct Disposal
20tt
kept on file at the Mill.
5.0 Bvnroduct Material Receivins
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 l). 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 10.5.8).
Byproduct Material Unloading
The RSO will specify the specific location within the broader Designated Disposal Area lor
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
l.
6.0
No.: PBL-10
Rev. No.: R-3
Date: Sept-l3Nov.
DENISON MINES (USA) CORP.
STANDARDOPERATINGPROCEDURES I Page4ofl!4
Title: I le.(2) Byproduct Disposal
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 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);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least I 8 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 tailer) 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
No.: PBL-10
Rev. No.: R-3
Date: SepL-4ZNql
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 5 of l$
Title: I le.(2) Byproduct Disposal
20tI
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.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at I 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 11e.(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 257o 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.
l)
After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
Direct the driver back to the scales for an empty weight.
The scale house operator will record the empty weight on the appropriate SWT.
Shipment and disposal activities will be documented as described in Section 10, below.
Coverine of Bvproduct Material
After the byproduct material has been accepted by
material will be spread within the designated area
facilitate compaction and covering.
the RSO, or his designee, the byproduct
within the Designated Disposal Area to
j)
k)
7.0
l.
No.: PBL-10
Rev. No.: R-3
Date: Sep+*2NgL
DENISON MINES (USA) CORP.
STANDARDOPERATING PROCEDURES I Page6of 12*
Title: 1 le.(2) Byproduct Disposal
20tL
2. The byproduct rnaterial 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 fi1l voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The RSO or his designee will inspect the placement of the byproduct material prior to covering
to physically verify that the procedures in this Section 7.0 have been adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify DUSA whether a specific trailer is to be released for restricted or
unrestricted use. Any trailers that are to be released for restricted use will be decontaminated
according to the requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers
that are to be released for unrestricted use will be decontaminated according to the requirements found
in Table I 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
l.
Hazard ldentification and Safety
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
Rev. No.: R-3
Date: SepL-{2NslL
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Pasel of lll
Title: 1 le.(2) Byproduct Disposal
20t1
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.
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 o[ 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 ttre 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 offthe equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump offthe equipment.
0 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 t5 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.
No.: PBL-10
Rev. No.: R-3
Date: Sept {4N911
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 8 of 1f4
Title: l1e.(2) Byproduct Disposal
20fi
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 Shipmens
For each shipment of byproduct material the following records will be maintained in the MiU's
Radiation Department fi les:
o Shipper's Manifest and Bill of Lading.r Laboratory/activity analysis ofthe byproduct material performed by the Shipper.
o Completed SWT.o 7-day notice to Executive Secretary.o Photo of the byproduct material.. Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.o 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:
o How the material was placed in the tailing cells;
o If void spaces were filled with tailings
sands;
o How the area was compacted;o 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);
o Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom ofeach 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);
e Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uooermost flexible membrane liner of the cell.
r Confirmation that the shipment was properly covered; and
e Where settlement markers were placed. The Mill will maintain a plat of each
ITTCFROCED['BE$
I la.(z) Byptotoct Dirposd
Dmtpmd &cq whid ilturffi tho Mon of €qeh rhipmnmt ot
byprortust
the MiIl will naintcfoi fih a eopy of ihe Exsemive SEctctarJf$ ,misan rypnwal of car.Xi
Desipatad Dispocol A[ca.
An annual nram5l of amorms of blproduct s@iEl d@6Gd of in oach cakedar pat
sha[ bc E€nt to 6G Slac,etary on or bcfueNoyudcr I of ih calcadsr ym. (Ucenre
Cqdition 105D.dusem,yearl
No.: PBL-10
Rev. No.: R-3
Date: Sep#NelL
DENISON MINES (USA) CORP.
STANDARDOPERATINGPROCEDURES I Page l0of
Title: I le.(2) Byproduct Disposal I 12+
20lt
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 Safetv
l. 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.
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.
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.
Check for potential overhead hazards prior to dumping.
If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safetv
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
4.
5.
6.
Driver (Printed)Scale House Operator
I
No.: PBL-IO
Rev. No.: R-3
Date:Sep*{4Ngt
e910- 201 I
Dr
STANI
$ffION MINES(USA)CCIRP.
\RD@MATINGPROCEDURES
[e: I le.(2) Brfoduct Disposel
PflSp 11 of
tgb
Driver (Signature)DstB
No.: PBL-10
Rev. No.: R-3
Date: SepL-l2NslL
DENISON MINES (USA) CORP,
STANDARD OPERATING PROCEDURES
Title: l1e.(2) Byproduct Disposal
Date:
ATTACHMENT2
11e.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
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 blproduct material disposal area./activities:
IIas each drum been insoected to identifv the oresence of anv void snaces?
Have all drums with void soaces been filled with tailinss sands or soil?
Which tailinss cell was the material nlaced 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: Sepil2Nov.
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 13 of
Title: I le.(2) Byproduct Disposal I lZ+
20tt
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
RSO's Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disnosal?
Was the ISL material segregated from disposed Mill material and other
ISI . material?
Was the maximum lift thickness above tailinss 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 disposalarea?_
Refer to drawinss used to confirm
ls the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?,
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
Eiilwas this confirmed (e.g.. survey or reriew)
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?
MrNBS(USAICORP.
OPERATINGPROCEDURES
I lc.(2) Byprodoct Dispossl
l. WasaBreathingZnne collected? Yes orNo
2. If yes, what were the of tho sarpling?
Was a photograph ta&en during unloading activities? Yes qNo
1le.(2) Byproduct Material Disposal SOP Clean
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page I of 12
Title: 1le.(2) Byproduct Dis
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 Bvproduct 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").
lnformation 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 Desienated 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
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 2 of 12
Date: Nov. 10. 2011 Title: 1le.(2) Byproduct Disposal
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 Secretarv
DUSA shall notify the Executive Secretary in writing at least J 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.
1.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10, 2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 3 of 12
Title: 1le.(2) Bvoroduct Dis
5.0 Bvproduct Material Receivine
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.
lnspect 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.
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.
2.
4.
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 10.5.8).
Bvproduct Material Unloadine
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.
Radiation Safety personnel will escort the shipment to the designated location in the
6.0
1.
2.
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 4 of 12
Title: 11e.(2) Bvproduct Di
Designated Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the 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) Ifthe 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
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 5 of 12
Date: Nov. 10. 201I Title: 11e.(2) Byproduct Di
i)
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.
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/tr at 1 meter, and the average measurement,
measured in mrem/tr at 1 meter, shall be recorded.
Measurements using a photoionization detection meter ("PD") 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 IIe.(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.
A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25Vo 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.
After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
Direct the driver back to the scales for an empty weight.
The scale house operator will record the empty weight on the appropriate SWT.
Shipment and disposal activities will be documented as described in Section 10, below.r)
Coverins of Bvoroduct lVlaterial
After the byproduct material has been accepted by
material will be spread within the designated area
facilitate compaction and covering.
The byproduct material will be compacted with
equipment prior to placing an additional layer.
the RSO, or his designee, the byproduct
within the Designated Disposal Area to
at least four passes of the construction
e)
0
s)
h)
j)
k)
7.0
1.
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
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 6 of 12
Title: I le.(2) Byproduct Di
8.0
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
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.
Decontamination and Release of Trailers and Trucks
4.
5.
6.
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 113.443. 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 Safetv
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.
Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
L
2.
No.: PBL-10
Rev. No.: R-3
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 7 of 12
Date:Nov. lO.20ll Title: I le.(2) Byproduct Dis
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.
0 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 offthe equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects comected 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 offthe equipment.
0 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
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 8 of 12
Date: Nov. 10, 2011 Title: I le.(2) Bvoroduct Di
l. 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.
o Laboratory/activity analysis of the byproduct material performed by the Shipper.
o Completed SWT.
o '7-day notice to Executive Secretary.o Photo of the byproduct material.. Byproduct material radiological scan information.
o Breathing zone monitoring data, if applicable.
o 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:
o How the material was placed in the tailing cells;
o If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;o How the area was compacted;o 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);o 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);o 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.
o Confirmation that the shipment was properly covered; and
o 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.
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 I of the calendar year. (License
Condition 10.5F). [summary due same year]
No.: PBL-10
Rev. No.: R-3
Date: Nov. 10,2011
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 9 of 12
Title: l1e.(2) Byproduct Di
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 Safetv
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Denison Mines (USA) Corp.'s equipment has the right of way
on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7 . Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safetv
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed)Scale House Operator
Driver (Signature)Date
No.: PBL-10
Rev. No.: R-3
Date: Nov. l0,20ll
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page 10 of 12
Title: l1e.(2) Byproduct Di
ATTACHMENT 2
tle.Ql 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 arealactivities:
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
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES I Page ll of 12
Date: Nov. 10. 2011 Title: l le.(2) Bvproduct Di
Have the thickness and placement measurements been verified and documented for the
by the engineer, specifically:
area
Engineer's or
RSO's Initials
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 materi al? _
Refer to plat(s) used to confirm.
Was the maximum lift thickness above tailinss less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands
area?_
Refer to drawings used to confi
been maintained under each disposal
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
elevation of the uppermost flexible membrane liner
H* *u, this confirmed (e.g., survey
grade of the
of the cell?
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 I OENISON MINES (USA) CORP.
Rev. No.: R-3 | SIaNDARD OPERATING PROCEDL;RES I Page 12of 12
Date: Nov. 10, 2011 I Title: 11e.(2) Byproduct Di
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
DENI
May 31 ,2011
;::r:::T,=.NGHTDELVER' [JRC_ 20 11 _006 44g
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4850
t
SOJT
INES
State of Utah Groundwater Discharge Permit ('GWDP') No. UGW370004
Transmittal of Revised Standard Operating Procedures ("SOPs") and Response to Division ofRadiation Control ('DRC') Request for lnformation of April21,2O11 Regarding 11.e(2) Byproduct
DisposalSOP
Dear Mr. Lundberg:
This letter transmits Denison Mines (USA) Corp's proposed revisions to the White Mesa Mill l1e.(2)
Byproduct Disposal SOP. This letter also responds to DRC's letter of April 21, 2011, which we received onApril 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 sectionsand 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 aftached. The majorityof these suggesfions 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-l i n e stri ke-o ut n otatio n s.
Denison Response: So noted. Denison has also replied to the four additional DRC comments provided inthe margins of the SOP. Our responses are provided in the margins of the SOP directly below thecomments. 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
:..1 *7
li !i-'l1 " f '
JU,II 2C1i
f lv: ,ioi r:f,xiitrircl i-llritlOI
Donison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax : [phone]
www.denisonmines.com
Re:
C:\Users\jtischler\Desktop\SOP repsonse 11e2 monitoMS.2T.ll Responseto DEQ 04.20.11 RFt 11e2 SOp.doc
Letter to Mr. Rusty r-unooert)
11e.(2) SOP RFI Response
May 31 ,2011
Page2
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 ditferent
placement processes.
b. Chief among the interesfs of DRC in changes to the subject SOPs was for DUSA to add
provisions to prevent the occurrence of any hazardous wasfe deposifs, and to increase
density of compacted ISL byproduct materials (to reduce potential settlement) in tailings cells.
Remarks, 1.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) 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 2il.a@)($.
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.2) DUSA's license allows us to accept 11e.(2) byproduct material under Conditions 9.8 and 10.5.3) 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
under40 CFR 271.30-33 or undercomparable State law provisions.4) 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.5) Because RCRA listed wastes are determined by source or origin, analysis for 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.6) 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.7) 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
stike-out verbiage aftached as new red-line paragraph 5.6 of the subject SOPs. Ihe
concept is to have byproduct materials pre-inspected before its arrival adjacent to the
disposa/ sife.
Denison Response: The verbiage has been accepted as provided.
DENISOND//
ftIINES
Letter to Mr. Rusty Lundberp
11e.(2) SOP RFI Response
May 31,2011
Page 3
(2). As shourn in red-line, we suggesf that DUSA consider moving existing paragraph 6.4
and revise it to language similar to the aftached new red-line paragraph 6.5.c of the
subject SOPs. The concept here ls fo 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 consrsfenf with License Condition 10.4A, and to increase compaction and
reduce seftlement, we suggesf 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 Lrbense
Condition 10.44.'
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 10.58 sfafes fhaf,
"All ISL contaminated equipment shall be dismantled, crushed, or sectioned to minimize tzold spaces.
Barrels containing waste other than soil or s/udges shall be emptied into the dr.sposa/ area and the
barrels crushed. Barrels containing soil or s/udges 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 Findinas: Some red-line strike-out verbiage attached ls suggesfed 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 disposa/ sife.
Denison Response: DRC's proposed change has been accepted as provided.
3. License Condition 10.5E(il sfafes ffiat
".../SL byproduct material will be segregated from any mill mateial and equipment disposed of in the
cells pursuant to License Condition 10.4, and fhe /SL byproduct material from each in-situ leach source
will be segregated from the byproduct materialfrom all other in-situ leach sources;"
DRC Findinos: lt appears the submifted SOPs do not clearly address this condition. Some
red-line strike-out verbiage attached is suggesfed 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 stafes fhat
"The licensee shall also submit for Executive Secretary approval a revised written
DENISOJ)//M!NES
Letter to Mr. Rusty f-unOUerp
11e.(2) SOP RFI Response
May 31,2011
Page 4
Standard Operating Procedure (SOP) for ISL dlsposa/ on or before December 1,2010. The revised
SOP sfia// descibe the documentation required for ISL disposal, which shall include but is not limited to
the following..."
DRC Findinos: lt appears the submifted SOPs do not capture the documentation requirements
of License Condition items 10.5E.(1) through (4). Please adjust the subject SOPs fo 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 lefter of March 1 , 2010 is referenced in your subject transmittal. Paragraph A of
the DRC /ettersfafes the following:
"Proposed methods and procedures fo fully protect the liner while accessing tailings cells for
drsposa/ of /SL byproduct material and mill equipment must be submifted for approval. These
methods and procedures would apply to tailings Cell4A and newer cells."
DRC Findinos: lt appears the submifted SOPs do not completely capture this item. Please
adjust the subject SOPs fo 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 Drsposa/ of /SL Byproduct Material
and Mill Equipment." This rearrangement should "fully capture this item."
6. The page numbering in the subjecf SOPs document has errors. Please adjust the subject SOPs fo
conect 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,
Derrsor,r Mnes (USA) Gonp. \m
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Centralfiles
OENISOJ)//
MINES
Umetco Minerals Corporation
May 20, 1993 Letter
Umetco Mln"roltorporcrilon
\A/FTTE MESAMIIJ- E P. O. BOXAEISE (EE1)67B€E€1
. BL.AAJDING. UTAH8451 .1
l,[r. Ramon E. HaIl DirectorU. S. Nuclear Regulatory ConrnissionRegion IVUranium Recovery Field OfficeBox 25325Denver, CO 80225
Re: SUA-1358, Docket Nunber 40-BOg1Di.sposal of Atomic Energy Act 11 (e)
.{.'\- -v
,tt7- L.,
^'rr,
Itlay 20, 1993
RECEIVED
ttAY 24 igg3
CONC(]HL/ IIIINING UNII
2 Material Docket
,a. .
0- \I,ANful-d-++Yt
(6 -B'q3
Dear Mr. HaII:
The white Mesa l,tirl (the ,uirrr) has an opportunity todispose of rr. (9) ? by-product material. -l,s you kiow,similar materials have been disposed of in thl p"=t-.t tn.l.tilI. umetco wishes to pursue in amendnent to Lhe abovereferenced license to alron the disposal of 11 (e) 2by-product material generated under- the licensing authorityof the NRC and/or the agreement states.
umetco's proposal is to request a license amenrrment, to runconcurrently with and to be- renened (if appropriatei duringeach licensing cycre, for the disposal of-not-more irr"n5,0oo cubic_yards of 11 (e) 2 by-product naterial pergenerating licensee. rf umetco rLceived a request'todispose of nore than 5,OOO cubic yards of 11 iel 2by-product naterial, umetco would notify uRFo'iir sriting sothat the appropriate review and approval could be receiiedfrom the URFO staff prior to executing a contact.
The_receipt and disposal of 11 (e) 2 by-product materiarvould be accomplished under the Radiation protectionProcedure seetion of the License Renewar Application, usingthe attached procedure entitled rThird farty 11 (e) iBy-product Disposal.r
The first shipnent projected for reception to the l{irl isby-product rnateriar originating fron Lhe tntercontinentalEnergy conpany ("rEcn) insitu operation near Three Rivers,Texas. rEc is an affiliated company of Energry FuersNuclear, rnc. (rrEFl{rn), which has partiar ownership in theniIl. Attachment A of this letter incrudes an estiiatedvolume, description, and radiologicar characterization ofmateriars to be received at the ttirl fron the rEC facirity.
WHITE MESA MILL . UMETCO OPERATIONS
PLAN THIRD PARTY WASTE
MATERIAL FROM URANTUM
OPERATIONS FOR DISPOSAL TO TAILINGS POND NO.
STANDARD OPERATING
PROCEDURES
1. 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 andb) Without specific approval by Umetco's Site Manager
(801-678-22211.
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 a(ea,
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 lnformation regarding the waste material to be disposed of shall include
the minimum of:
2.
a)
bl
cl
The volume of material (in cubic feet or yards or quantity of
drums and their sizel,
Description of material (sludge, process materials, filter media,
etc.l, and
Laboratory results of material to include total 226Ra, uranium
natural, and any other chemical or radiologicalanalysis requested
by Umetco personnel deemed necessary to characterize waste.
All analytical results will be submitted to Umetco Minerals prior
to shipment and acceptance. Records will be retained at the
White Mesa Mill.
3.Waste generator will give 3O days notice of material delivery. Each notice will
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.
The waste generator site inspection of the material will include:
a) lnventory of material being shipped and comparison to the mani-
fest submitted.
b) lnspection 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 will be determined
at the discretion of Umetco's Site Manager or Radiation Safety
Officer (RSOl.
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 th€ 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
7. A breathing zone sample will be taken periodically during disposal and cover
activities. lf the gross alpha approaches or exceeds 2.5 x 1O-11Ci/ml, then
site personnel will be required to notify the Manager of Operations and the
RSO. Activities will be suspended and an investigation will 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.
4.1
5.
6.
8.
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 willnot be allowed to assist in unloading activities other than to operate the
transport vehicle.
7.3 All personnel will be required to survey themsetves prior to leaving thesite. Survey results will 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 surveyswill be documented and retained in umetco's permanent records.
Upon arrival of the waste shipment at the White Mesa Mill, the Manager of
Operations or designee will inspect the shipment for conformity to the accom-pany shipping manifest and previously received documentation described in3.0. The manifest will be examined by the responsible personnel and thefollowing items will be checked for accuracy:
a)
b)
c)
d)
el
Manifest number.
Description of waste materials shipped.
Ouantity shipped and received.
Conformity to manifest description of waste materials to be disposed
of.
ldentification of any suspicious materials, such as organics, oils,
solvents, chemicals, etc.
Originator and site where waste material was generated.
Generator's US-NRC License Number.
Appropriate signatures by all parties.
Correct dates of shipping and receiving, and
Notation will be made on umetco's manifest of the location of the
waste material's placement within the disposal area.
U.S. DOT Hazardous Materials Certificate of Registration.
Any discrepancies will be brought to the attention of Umetco's person-
nel in charge and the generator. The discrepancy will be immediately
resolved.
f)
e)
hl
il
i)
k)
8.1
8.2 Waste material may be spot surveyed (at the discretion of the receiving
personnel or at the request of managementl on the surface for alpha
-3-
9.
10.
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.
Acceptable waste material will be dumped from the transport in a safe manner
to minimize dust. lf 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.
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 toplacing 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 tofill voids in and around the waste material. A one foot (1') thick, or thicker, if
required, of native soil or mine spoil or mine spoil cover will be placed over thewaste 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.
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:
al Plat of waste disposal site for each waste shipment.bl Umetco shipping manifest.c) Air zone monitoring data.dl Equipment release forms.el US-EPA waste manifest form.fl Transportation company's Bill of Lading.gl Laboratory analysis of waste.h) Waste receipt log.
11.
-+
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.
ln 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).
Contact Site Manager
Contact the RSO, and
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 Managerl 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
13.
b)
c)
d)
Fire Department
Emergency Medical Assistance
Hospital
Police
Highway Patrol
W.W. Brice
G.G. Ray
S.L. Schierman
R. Van Horn
(Director of Operations)
911
911
911
911
911
678-2084
678-2912
587-2872
(3031 243-838s
-5-
I
I
11E.(2) Byproduct Material Disposal SOP Redline
No.: PBL-10
Rev. No.: R-32
Date: JgreDee. l,
DENTSON MrNES (USA) CORP.
STANDARD OPERATTNG PROCEDURES
Title: I le.(2) Byproduct Disposal
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 Bvproduct 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 l0 and 49 of the U.S. Code of Federal Regulations ("CFR') and
the Shipper must certifu that the byproduct material does not contain hazardous waste as t
defined in the Resource Conservation and Recovery Act ("RCRA").
f
Information regarding the byproduct material to be disposed of should be received prior i' i
to receipt of the shipment at the Mill, and shall include: li
L The volume of material in cubic feet or yards, or quantity of drums and their ii
size. ll
2. A description of the material (e.g. sludge, process materials, filter media, pipe, ietc.) i3. A description of the shipping container (i.e. end dump trailer, intermodal /
container, side dump container, etc.) i
4. fi.esult{of analy-rp-fgt A!qt,\c-2?Q, Tb-?jg glC !!-2lQ-ol-a!l-s!qdg9q eqa- r!-ib i
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
milliremr/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 verifu, 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
Comtrent [RU: Does DUSA rcquire othu
malyical that slrows that the byproduct material
meets the RCRA requiremmts. Also is there some
type of witten prcfile of the material?
Comment [rAT2R1]: l) To be r€gulated by
RCRA as a hazardou waste, a matsial must bc a
mlid waste per lhe RCRA definitim. Soue
Material, Specisl Nwlear Matmial and I le.(2)
Byproduct Material are exprcssly excluded from tfie
defnition ofsolid waste mder RCRA (42 USC 6903
md 40 CFR 261.4(a)(4). Process wases md debris
from ISL facilities m I te.(2) byproduct by
defnition and re thmfore xcluded from the
definition of solid rerc md therefore also excluded
tom the definition of haardous weste rmder RCRA.
2) DUSA's licms allows us to accept lle.(2)
byproduct material under Conditims 9.8 md t0.5.
3) RCRA defines two types ofhaz,Idou waste.
Hazardous wastes m be eilher ch0actedstic
haadou wases (i.e., ignitcble, mmsive, toxic, or
rerctiw) or lisEd hazardou waste (i.e. listed uder
rl0 CFR 271.3O.33 or under comp0rable Stste law
prcvisim. 4) Becaw I le.(2) byproduct may
include sme of the same types of coNtituents md
prcpertim m RCRA chrracteristic wastes, malysis
for RCRA charactqistics would not have any value
in mnfiming that a waste is not I RCRA
chamcttristic waste. Because I le.(2) msterial is not
a solid waste, it cannot be a RCRA chmtristic
w8te. 5) BtraN RCRA listed wasEs ffi
detemined by mrre or origin, analysis for RCRA
constiiucats would mt bave my valrr dccmining if
drc material is a RCITA listed waste. Becaus the
mterial's process of origin in the pocessing of
sourpe material as defued l0 CFR 40.4, the waste a)
is not from my RCRA listed process and b) the
wste is I le.(2) byprodrt by defmition and carurot
be solid waste, md therefffe not a RCITA listed
waste. 6) Becaus Ile.(2) mat€rial is exmped from
RCRA du€ to its origiq no malysis c ryecifcdmmmtation is requircd. DUSA rcquircs the
certilication described in Smtion 2.0 ofthis SOP as
m added assurance ftar fie material onsists solely
of I le.(2) byprcdrct md is mt combined wift any
ottsmsterial orwste. 7) A chmical profile of tre
Drterial is nof require4 md not requested from the
shipper. The only reason DUSA mks for dre
rrdiological chmcteriation is for our own
ndiological safety assessment by the RSO.
No.: PBL-10
Rev. No.: R-12
Date: fuggDee. l,
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
3.0 Desienated bisnosai 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:
l. 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 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 oftailings sands under the bottom ofthe Designated
Disposal Area; and
b) The bottom of the Designated Disposal Area is located at least l2 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.
*!- Byproduct material from each ISL facility is disposed in Desienated 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.
4.0 Notification to Executive Secretary
Formatted: Indent: Left: 0.5", No bullets or
numbering
Comment [Rirl: Define type ofdisposl. i.e.
placed in I trmch or put on the tailing beach md
de*ribe the diffmes for each type of disposal. I
have sem evidence ofboth types ofdisposl duing
Corntn€nt [JAr4I: There is no difference in
pmedure for matmial placed in either trench sreas
or tailings beach areas. Moterial from each ISL is
placed in its designated ma as predaemined fo
the RSO. Designated rcm re rsigned m the basis
of what ua is available, to mintain segrcgation of
mterial from erch ISL som. Thm is no criteria
for selection of tsmches vmus be&hes ud no
differmce in olrcmilt or 6ver.
No.: PBL-10
Rev. No.: R-12
Date: fuggDe€. I,
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
DUSA shall notifo 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 Byoroduct 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 (@). 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 transportins 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
discreoancies 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 sludees shall be checked to determine if theyn--
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
Amendmentfu€gf0\DRe Markuo Preo I lez SeP
Formatted: Bullets and
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c, ... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
7.25"
Fomatted: Bullets and Numbering
Formatted: Indent: Left: I
Fomatted: Numbered + Level: 2 +
Numbering Style: a, b, c, ... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1.25"
Formatted: Bullets and Numberinq
Rev. No.: R-32
Date: JuneDee. I,
DENISON MTNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
disoosal. (License Condition 10.5.B).
6.0 Bvoroduct Material Unloadins
l. The RSO will speci$ 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;n*i+u-+eaehtSl source will be
segregated from the byproduct material from eaeh-afl_other i+-situ--[eeeh!g!
sourceE.
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
a. The shipment will be hansported 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 Desisnated
Disposal Area:d. The Designated Disposal Area must be located at least l2 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 l8 inches of soil or fill material at the point of
access.
4, Prier te unleading; the driver will be instrueted to open er untarp the leed, The
drat the material metehes the meterial deseriptien en the shipping manifest. nny
infermetien will be reperted te the RSe, ,tny bypreduet material suspeeted ef
@
*4. Ifthe 7 calendar day notice referred to in Section 4.0 above has not been given, or
Fomatted: Indent: Left: 0", Hanging: 0,75",
Outline numbered + Level: 1 + Numbering
Style: 1,2,3,... + Startat: 1 + Alignment: Left
+ Aligned at: 0" + Tab after: 0.5" + Indent
at: 0.5", Tab stops: 0.75", List tab + Not at
0.5'
Formatted3 List Paragraph. No bullets or
control
Formatted3 Indent: Left: 0.75", No bullets or
No.: PBL-10
Rev. No.: R-32
Date: fungD€€. I,
DENISON MINES (USA)
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
the7dayshavenotlapsed,thentheshipmentmay!-.-!qt_i_s_qo-t_rgqu_i1e4_ts-bg----
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. Ifsuch notice has not been given or ifsuch 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 Safe8 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 byoroduct 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 mrglg/hr at I meter,
and the average measurement, measured in mrgm/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
Formatted: Indent: Left: 0.25", Hanging:
0.25"
Formatted: Indent: Left: 0.25", Hanqing:
0.25"
Formatted: Indent: Left: 0.25", Hanging:
0.25'
Formattedt Indent: Left: 0.25", Hanging:
0.25"
No.: PBL-10 I DENISON MINES (USA) CORP.
Rev. No.: R-32 | STaNDARD OPERATING PROCEDURES I Page 6 of
Date: fu4gDee. l. I Title: I le.(2) B)?roduct Disposal I g!_06
201l0
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 verifu
that the detected organics are I le.(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.
_--tt
Hew tne mnteriat we .\ ',
\,. '----{+erv+h€-aree.was-€empaeteoq ',"
,,
ilj.i)After unloading the byproduct material, replace the tarp or close the trailer, unless.-
the trailer is being decontaminated for unrestricted release.
l.
Formatted; Indent: Left: 0.25", Hanging:
0.25"
Comment [R5]: This mighr be I bener fit in a
difrermt spot of the SOP or slightly different
lmguage butyou get the idea. Themain thing is
that the mtire activity from acceptance to final
deposition needs to be docrmented
Comm€nt [,ATOI3 Please w Sectim l0
FormatEd: Bulleted + Level: I + Aligned at:
0.54" + Tab after: 0.79" + Indent at: 0.79"
Formatted: Bullets and Numberino
Fomattedi Indent: Left: 0.25", Hanging:
0.25"
Dki) Direct the driver back to the scales for an empty weight.
Hlk)Thescalehouseoperatorwillrecordtheemptyweightontheappropriate*_
SWT.
l) Shinment and disposal activities will be documented as described in Section 10.
below.
Coverine of Byproduct Material
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.
nR*RJ,doehttF#intrmet
7.0
No.: PBL-
Rev. No.: R-12
Date: JuneDee. l,
20r l0
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 7 of
9106
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.AIlcontaminatedequipmentshallbedismantled,crushed,orsectionedtr-__
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.
+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 verifu that the procedures in this Section 7.0 have
been adequately performed.
fa€ititi€s aild Mitt Was
No.: PBL-10
Rev. No.: R-32
Date: JuneDee. l,
STANDARD OPERATTNG PROCEDURES
Title: I le.(2) Byproduct Disposal
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving theMill. Shippers or transporters will notifr 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 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
resfficted 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
9.0 Hazard ldentification and Safetv
l. Required Personal Protective Eouipment (PPE)
SOP PBL-g
SOP PBL-2
SOP.PBL-2
2.
[r{ell gf.eq _o{![e \,l_il.! _cgye_rg{ _by tlrl proce_dgqe, _hard-!qts, safe_ry gla_ss_e_s and_- -
steel-toed shoes are required at a minimum. These must be worn in the restricted '.
area of the Mill. Prior to disgosal. the RSO will determine what level of
respiratory protection. if an)L 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.
c) Drivers must use caution during the unloading process and be aware of any
overhead hazards.
faoitities and Mill Wast
Comment [R.7]: Dry soils might need respintor
prctection or dust confrol to contol airbome
contmination md exposurc md should be evaluted
by the RSO prior to disposal.
Comrn€nt [JATE]: Please *e in*rtion.
Respiratory prctstion is the subject of other plms
thrt will not be mated herc.
a)
b)
No.: PBL-10 | DENISON MINES (USA) CORP.
Rev. No.: R-32 | STANDARD OPERATTNG PROCEDURES I Page 9 ol
Date: fu4gDee. l, I Title: I le.(2) Byproduct Disposal I 9l_06
201
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.
0 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.
Audible backup alarms shall be in operating condition.
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.
Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump off the equipment.
Seat belts shall be used at all times when equipment is in motion.
Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of l5 m'ph.
Keep the cabs of equipment clean. Loose items that could jam controls or create
other hazards are not allowed.
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.
nR&RJ,de€http:#intr t
c)
d)
e)
0
c)
h)
No.: PBL-10 | DENISON MINES (USA) CORP.
Rev. No.: R-3? | STANDARD OPEMTING PROCEDURES I Page l0 of
Date: fu4gDee. l, I Title: I le.(2) Byproduct Disposal I 9f_06
10.0 Documentation
I . a) Documentation of Shipments
+ For each shipment of byproduct material the following records will be
maintained in the Mill's Radiation Department files:
o Shipper's Manifest and Bill of Lading.
o Laboratory/activity analysis of the byproduct material performed by
the Shipper.o Completed SwT.o 7-day notice to Executive Secretary.o Photo of the byproduct material.r Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.r Equipment release forms.
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disoosal Documentation*- -
Form orovided in Attachment 2. Attachment 2 may be accompanied by
nhotographs. a written description or both. Attachment 2 or other written
descriotion will include:
o How the material was olaced in the tailing cells:o If void spaces were filled with tailings sands:o How the area was compacted:o Document that the 4 foot depth of tailing sands under the shipment
was maintained:r Document that each disnosal area is located at least 12 feet from the
sides or dikes ofthe tailings area:r Confirmation that the shipment was properly covered: and
*Where settlement mark
L1The Mill will maintain a plat of each Designated Disposal e."u, *f,i"t]l I l
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.
43. 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 fette*4*g-calendar year. (License Condition 10.5F). lsummary due same yearl
trR&RJ,d€ehtF:#i+ranet,
Formatted: Indent: Left: 0.5", No bullets or
numbering
Fomatted3 Indent: Left: 1.25"
Fomatted: Outline numbered + Level: 1 +
Numbering Style: Bullet + Aligned at: 1" + Tab
after: 1.25" + Indent at: 1.25"
ATTACHMENT I
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 Safetv
l. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 m,ph, Denison Mines (USA) Corp.'s equipment has the right of
way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck tuming over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7 . Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safetv
l. 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
ATTACHMENT 2
I Ie.(2) DISPOSAL DOCUMENTATION FORM
Name nf emnlovee receivins the load:
Generator of the I le.(2) Bvoroduct Material:
Was the State of Utah given notice to the receipVdisposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of bvproduct material disoosal area./activities:
How was the material *a+placed in the tailine cells?Formatted: Indent: Left: -0,25", No hJllets or
numbering
FomatEd: Indent: Left: -0.25", No hrllets or
Were void soaces filled with tailinss?
Formathd: Indent: Left: -0.25", No fulhts or
How was the area compacted?
Formatted: Indent: Left: -0.25", No bullets or
Document that the 4 foot depth of tailing sands under the shipment was maintained
Document that each disposal area is located at least I 2 feet from the sides or dikes of the tailinss area:
Formatted! Indent: Left: -0.25", No bullets or
numbering
Was the shipment properly covered?FormatHs lrdent: Left: -0.25', Nobulletsor
Are additional settlement monitors reouired to be placed for this eenerator?
Fonnattd: Indent: Left: -0.25". No bulletsor
numberirE
If required. where were s€ttlement markers were placed?
Formattcd: Indent: Left: -0.25" No bulktsor
Radiological receipt survey measurements:
Breathine Zone:
l. 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 unloadine activities? Yes or No
t]e.(Z) Byproduct Material Disposa! SOP Clean
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES Page I of 10
No.: PBL-10
Rev. No.: R-3
Date: June. l. 201 1
1.0 Purpose
Denison Mines (USA) Corp.("DUSA") receives 1le.(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 Bvproduct 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:
l. 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
(mrlhr) 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 Desisnated 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:
C:\Users\tischler\Desktop\SOP repsonse I le2 monitor\Markup Prop I 1e2 SOPs 05.31.1 I clean.doc
No.: PBL-I0
Rev. No.: R-3
Date: June. 1.2011
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2)
Page 2 of 10
2.
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);
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;
There must be at least 4 feet of tailings sands under the Designated Disposal Area;
The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
The elevation of the Designated Disposal Area once filled with byproduct material must not
exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the
tailings cell;
Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
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 Secretarv
DUSA shall notifu 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 Bvproduct Material Receivins
l. 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\tischler\Desktop\SOP repsonse I le2 monitorWlarkup Prop 1le2 SOPs 05.31.1I clean.doc
J.
4.
5.
6.
Page 3 of 10
No.: PBL-10
Rev. No.: R-3
Date: June. 1. 201 I
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROC EDURES
Title: I le.(2) Bwroduct Disposal
2.
DUSA's safety rules and procedures while on company property. The scale house operator
will sign the Safety Training Form as the instructor for DUSA. Completed Safety Training
Forms will be tumed in to the Safety Department for future reference.
Inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that
the shipment is destined for the Mill and confirm with the RSO that the shipment has been
approved for receipt.
Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
Enter the loaded weight of the truck and trailer on the SWT.
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.
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 10.5.8).
Bvproduct Material Unloadins
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.
Radiation Safety personnel will escort the shipment to the designated location in the
Designated Disposal Area for unloading of the byproduct material.
Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings Cells
for Disposal of ISL Byproduct Material and Mili Equipment
J.
4.
6.
6.0
1.
2.
J.
C:\Usersltischler\Desktop\SOP repsonse [ 1e2 monitor\Markup Prop I 1e2 SOPs 05.31 .l I clean.doc
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: l le
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 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;
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.
If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container on site until the required 7 day notice has been given and the 7 calendar days have
lapsed.
If the shipment is determined to be acceptable, the following procedures will be followed:
Ifthe 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.
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.
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.
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.
ClUsers\tischler\Desktop\SOP repsonse 1le2 monitor\Markup Prop 1le2 SOPs 05.31.11 clean.doc
a)
b)
c)
d)
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENISON MrNES (USA) CORP.
STANDARD OPERATTNG PROCEDURES
Title: I le.(2) Bvnroduct Di
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 verifu that the detected organics are lle.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material compaction and
covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25%o 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.
l) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Coverins of Byproduct Material
l. 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 full shall be filled with tailings or soil.
C:\Users\jtischler\Desktop\SOP repsonse I le2 monitorMarkup Prop I le2 SOPs 05.31.1I clean.doc
No.: PBL-10
Rev. No.: R-3
Date: June. l,20ll
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: l1e.(2) Byproduct Disposal
Page 6 of l0
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
Intermodal Container
Standard Container Trailer
SOP PBL-g
SOP PBL-2
SOP-PBL.2
9.0 Hazard Identification and Safetv
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 ata 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.
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.
Drivers must use caution during the unloading process and be aware of any overhead hazards.
1.
2.
a)
b)
c)
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No.: PBL-10
Rev. No.: R-3
Date: June. l. 2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I I
Page 7 of l0
a-r.
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.
Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
Always use a ladder when entering and/or exiting the interior of a trailer.
Mobile Equipment
Only trained and authorized persons may operate mobile equipment.
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.
Audible backup alarms shall be in operating condition.
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.
Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
Seat belts shall be used at all times when equipment is in motion.
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.
All gasoline engines must be shut off when refueling.
Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
l. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
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d)
e)
a)
b)
c)
d)
e)
0
g)
i)
k)
No.: PBL-10
Rev. No.: R-3
Date: June. l. 201I
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1le.(2) Bwroduct Dis
Page 8 of l0
Radiation Department files:
o Shipper's Manifest and Bill of Lading.o Laboratory/activity analysis of the byproduct material performed by the Shipper.o Completed SWT.o 7-day notice to Executive Secretary.
o Photo of the byproduct material.. Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.o 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:
o How the material was placed in the tailing cells;
o If void spaces were filled with tailings sands;
o How the area was compacted;o Document that the 4 foot depth of tailing sands under the shipment was maintained;o Document that each disposal area is located at least 12 feet from the sides or dikes
of the tailings area;
o Confirmation that the shipment was properly covered; ando 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]
2.
3.
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DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Bwroduct Di
Page 9 of l0
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2071
ATTACHMENT I
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 Safetv
l. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
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.
7.
8.
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.
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.
Check for potential overhead hazards prior to dumping.
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.
Be aware of slippery conditions on the ore pad during periods of inclement weather.
Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
Use caution when entering or exiting equipment.
Radiation Safetv
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
9.
2.0
1.
2.
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No.: PBL-I0
Rev. No.: R-3
Date: June. l.20ll
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le
Driver (Signature)Date
ClUsers\itischler\Desktop\SOP repsonse I le2 monitorWarkup Prop I le2 SOPs 05.31.11 clean.doc
No.: PBL-10
Rev. No.: R-3
Date: June. 1,2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I I
ATTACHMENT 2
11e.(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 arealactivities:
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
C:\Users\itischler\Desktop\SOP repsonse I le2 monitor\Markup Prop I le2 SOPs 05.31.1I clean.doc
No.: PBL-I0
Rev. No.: R-3
Date: June. l- 2011
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
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?
lf 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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DR -0
/
c- 2olT
soJ)/
INES
473 50
DENI
September 12,2011
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
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 lnformation 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,
201 1 . This August 4,2011 letter contained one comment, detailed below, regarding ltem 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 discusseb 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 ltem 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 ltem No. 4, and revised our response.
DRC Comment
"ltem No. 4 of your May 31 ,2011 letter appears to not fully respond to DRC comment no. 4 in the subject
April21, 2011 DRC letter."
For ease of reference, Comment No. 4 of DRC's April21,2011 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\0g.12.11 response to comment 4\09.12.11 Response to DEQ
08.04.11 RFI 11e2 SOP.doc
A
Received
sEP 2011
Dlvision of
Radiation Contro!
oenison Mines (USA) Corp.
1050 17th Street, Suite 950
Denver, CO 80265
USA
Tel : [phone]
Fax: [phone]
www.denisonm ines.com
Letter to Mr. Rusty f-rnOOt
11e.(2) SOP RFI Response
September 12,2011
Page2
DRC Findinqs: 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.'
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,
Denrsox Mrues (USA) Conp.
CC^,"- 1;)/,u
/
Jo Ann Tischler
Director, Compliance and Permitting
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
K. Weinel
Centralfiles
DEN'SOJ)//
mtNEs
lle.(Z) Byproduct Disposal SOP
Clean Copy
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Pagelofll
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,20ll
2.0
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA") receives lle.(Z) 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").
Prior to Shipment of Bvproduct 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:
l.The volume of material in cubic feet or yards, or quantity of drums and their size.
A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
Results of analysis for Unat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the 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.
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:
2.
-).
4.
5.
Page2ofll
No.: PBL-10
Rev. No.:R-3
Date: Sept. 12,20ll
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
2.
3.
4.
5.
6.
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);
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;
There must be at least 4 feet of tailings sands under the Designated Disposal Area;
The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
The elevation of the Designated Disposal Area once filled with byproduct material must not
exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the
tailings cell;
Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
Prior written approval must have been obtained from the Executive Secretary of the Utah
Radiation Control Board (the "Executive Secretary") for each Designated Disposal Area, under
Mill License condition 10.5C, and evidence of such approval must be on file at the Mill.
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 Secretarv
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the proposed
scheduled date for disposal of any byproduct material. Written evidence of this notification will be
kept on file at the Mill.
5.0 Bvproduct Material Receiving
L 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
1.
8.
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: l le.(2) Byproduct Dis
Page3ofll
2.
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.
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.
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.
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).
1.
Bvproduct Material Unloadins
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.
Radiation Safety personnel will escort the shipment to the designated location in the
Designated Disposal Area for unloading of the byproduct material.
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
J.
4.
a.
b.
6.0
2.
-J.
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
Page4of1l
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,2011
4.
5.
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.
If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container on site until the required 7 day notice has been given and the 7 calendar days have
lapsed.
If the shipment is determined to be acceptable, the following procedures will be followed:
If the 7-day notice has been given under Section 4.0 above and the J calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. [f 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.
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.
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.
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/tr at 1 meter, and the average measurement,
measured in mrem/hr at 1 meter, shall be recorded.
a)
b)
e)
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12,20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
Page5ofll
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 11e.(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 25Vo 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
l) Shipment and disposal activities will
the empty weight on the appropriate SWT.
be documented as described in Section 10, below.
7.0 Covering of Bvproduct Material
1. After the byproduct material has been accepted by
material will be spread within the designated area
facilitate compaction and covering.
the RSO, or his designee, the byproduct
within the Designated Disposal Area to
at least four passes of the construction2. The byproduct material will be compacted with
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
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Di
Page6ofl1
8.0
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.
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
Intermodal Container
Standard Container Trailer
SOP PBL-g
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safetv
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.
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.
0 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.
t.
2.
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12.20ll
DENTSON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11e.0'tB
Page7of11
Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
Always use a ladder when entering and/or exiting the interior of a trailer.
Mobile Equipment
Only trained and authorized persons may operate mobile equipment.
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.
Audible backup alarms shall be in operating condition.
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.
Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
Seat belts shall be used at all times when equipment is in motion.
Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
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.
All gasoline engines must be shut off when refueling.
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:
s)
h)
a)
b)
c)
d)
e)
0
s)
h)
i)
j)
k)
Page8ofll
No.: PBL-10
Rev. No.: R-3
Date: Sept. 12.20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) B
o Shipper's Manifest and Bill of Lading.o Laboratory/activity analysis of the byproduct material performed by the Shipper.
o Completed SWT.o 7 -day notice to Executive Secretary.
o Photo of the byproduct material.
o Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.o 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 L2 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 1 of the calendar year. (License
Condition 10.5F). [summary due same year]
o
a
o
a
a
a
2.
J.
No.: PBL-10
Rev. No.: R-3
Date: SeDt. 12.20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: l le.(2) Byproduct Di
Page9ofl1
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 Safetv
1.
2.
Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
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.
J.Maintain a safe speed at all times when
speed limit is posted at 15 mph Denison
on the ore pad and Mill roadways.
driving in the Mill Restricted Area. The maximum
Mines (USA) Corp.'s equipment has the right of way
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.
Check for potential overhead hazards prior to dumping.
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.
Be aware of slippery conditions on the ore pad during periods of inclement weather.
Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
5.
6.
7.
8.
9.
2.0
1.
2.
Use caution when entering or exiting equipment.
Radiation Safetv
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
No.: PBL-10
Rev. No.: R-3
Date: Seot. 12-20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
Page l0 of 11
ATTACHMENT 2
11e.(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 arealactivities:
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 tailines less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailinss sands been maintained under each disoosal 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. 12.20ll
DENTSON MrNES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: I le.(2) B
Pagellofll
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
2. If yes, what were
Zone Sample collected? Yes or No
the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
Ile.(Z) Byproduct Disposal SOP
Redline Copy
No.: PBL-10 I DENISON MINES (USA) CORP.
Rev. No.: R-li STANDARD OPERATTNC PROCEDURES I Page I of
Date: Title: I le.(2) Byproduct Disposal I 9106
Jc*eSept.l)ee. I,
201ri)
1.0 Purpose
Denison Mines (USA) Corp. ("DUSA"; receives lle.(21 byproduct material ("byproduct
material") from uranium in-situ leach operations for disposal under License Condition
10.5. The lollowing procedure applies to acceptance, handling, and disposal of
byproduct material at the White Mesa Mill (the "Mill").
2.0 Prior to Shipment of Bvproduct 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 confbrm to Titles l0 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 ol the shipment at the Mill, and shall include:
l. The volume of material in cubic feet or yards, or quantity of drums and their
size.
A description ol the material (e.g. sludge, process materials, filter media. pipe,
etc.)
A description ol 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-2 l0 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
milliremr/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 verity, 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
jM
*mes ++i)
+X+*eR&krch{+p:#ifl {rafl er-tlr*isen++cM+esa+{+U/Hi*:+fi iit+l+;},
laeilirie; *r+tl Mrll Wast+l)isp*,al/l'llt l[]=l le (lt S(,)" Rer l-t l-l 0l l(]) {l}'doc
Comment [rAT2RlI: t) To be regulated by
RCRA as a headous waste, a material must be a
solid waste per the RCRA definitim. Souce
Material, Special Nrclea Material md I le.(2)
Br?rcduct Material e erpressly excluded fmm the
defmition of slid wste undtr RCITA (42 USC 6903
md 40 CFR 261.4(aX4). Process wastes and debris
from tSL frcilities ffi I le.(2) byproduct by
definition and m therefore excluded from the
definition of solid wcte and therefore also excluded
ftom the delmition of haztrdou waste under RCRA.
2) DUSA'S license allows us to accept I le.(2)
byfoduct material under Conditions 9.8 md 10.5.
3) RCRA defines two types of hutrdous w6te.
Huardous wastes can b€ eiths characttristic
hmdous wastes (i.e., ignitable, cmsive. toxic, or
rcactive) or listed hazardous waste (i.e. listed under
40 CFR 27L30-33 or under comparable State law
provisions. 4) Becaus I le-(2) byprcduct may
include some of the m types of constinrcnts md
properties as RCRA chfficl€ristic wastes, analysis
for RCRA chtracteristics would not have my value
in confming that a waste is not a RCRA
characteristic waste. Because I le.(2) material is not
a slid waste, it cmnot be a RCRA chmceristic
waste. 5) Becaus RCRA listed wastes re
detemined by suce or origin, malysis fc RCRA
constituents would not have my value detemining if
the material is a RCRA listed w6ie. Because the
material's pmess of origin in the prffessing of
some material as defined l0 CFR 40.4. the waste a)
is not from my RCRA listed process and b) the
waste is I le.(2) byprcduct by definition md cmot
be $lid wtrte ild therefore not a RCRA listod
waste. 6) Becaus I le.(2) materia-l is exempted from
RCRA due to its origin, no malysis or specific
documentation is required. DUSA requires the
certification desribed in Section 2.0 of this SOP as
m added assumce that the material consists rcle ly
of I le.(2) byproduct md is not combined with my
other maErial or waste. 7) A chemical profile of the
maErial is not required, md not requested from the
shipper. The only reason DUSA asks for the
mdiological chilacterization is for our own
radiological safety as$ssment by the RSO,
Comment [RU: Does DUSA require othr
analytical that shows that the byproduct material
meets the RCRA requirements. Also is there sme
typ€ of written profil€ of the material?
NO.: PBL-10 I DENISON MINES (USA) CORP.
Rev. No.: R-12 | STANDARD OPERATING PROCEDURES I Page 2 of
Date: I Title: I le.(2) Byproduct Disposal I 9106
JtmeSept.Dee. I,
201r0
10.5A
3.0 Desienated 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:
l. 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 l2 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. Detaited 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 l2 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.
As Bvproduct material lrom each ISL facility is disposed in Designated Disoosal
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
orocedures are the same for both trench areas and tailings beach areas.
tjR&R+,doehrte:/
faeilitics ilnd N{i
Formatted: Indent: Left: 0.5", No bullets or
numbering
Crmment [R:lI: Defire typeof di{osal. i.e.
placed in a ts€nch or put on th€ tailing b€rch and
describe the diffences for each type of disposal. I
have seen eviderce of bolh types of dispoMl duing
Comment [rAI4]: Thue is no difference in
procedure for mal€rial placed in eilh€r Eench {eas
or tailings berch areas. Mat€rial &om each ISL is
ptaced in iE designated aea as predetermined by
the RSO. DesignaEd areas me assigned on the basis
of what rm is available, to maintaio segregatiofl of
material frcm each ISL source. Th€re is no crit3ria
for s€tection of renches vesus berches and no
difference ir placencnt or cover.
2.
No.: PBL-10 I oENISON MINES (USA) CORP.
Rev. No.: R-13 | STANDARD OPERATING PROCEDURES I Page 3 ofDate: I Title: I le.(2) Byproduct Disposal | 91CI6
JuneSeot.Dee. I,
201l0
4.0 Notification to Executive Secretarv
DUSA shall notify the Executive Secretary in writing at least 7 calendar days prior to the
proposed scheduled date for disposal of any byproduct material. Written evidence of this
notification will be kept on file at the Mill.
5.0 Bvoroduct Material Receivins
l. 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 t@). 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.
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).
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 byoroduct material to ensure that the
material matches the material description on the shippins manifest. Any
discreoancies between the bvproduct material received and the manifest
information will be renorted to the RSO.
a. Any byproduct material suspected of not conforming to Section 2.0 of*
this SOP will not be transoorted to the disposal site. unless a
determination is made by the RSO that the material in ouestion
conforms to Section 2.0 of this SOP.
A,menamen+ fer 201g\DRe M
Fomatted: Bullets and Numbering
Formatted: Numbered + Level: 2 +
Numbering Stylei a, b, c, ... + Start at: 1 +
Alignment: Left + Aligned at: 1" + Indent at:
1.25',
Formatted: Bullets and
Formatted: Indent: Left: 1"
No.: PBL-10 | DENISON MINES (USA) CORP.
Rev. No.: R-J2 | STANDARD OPERATING PROCEDURES I Page 4 of
Date:
JuneSept.Dee. l,
Title: I le.(2) Byproduct Disposal I 9105
201te
b. Barrels containing soil or sludses shall be checked to determine ifthey.
are full prior to transportins 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 Byoroduct Material Unloadine
l. 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-sig+-teae+ISL source will be
segregated from the byproduct material from eaeh-4!!_other in-sit*-leaeh!$!
sourcep.
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.
Tailinss Cells for Disposal of ISL Bvoroduct 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 tailines sands under the Designated
Disposal Area (documentation of the disoosal area must be comoleted and on
file orior to an), disposal activities):
d. The Desienated Disposal Area must be located at least l2 feet
from the sides or dikes of the tailinss cell (documentation of the disposal area
must be completed and on file prior to any disoosal activities):& e. No travel into the disposal area will be allowed unless the disposal
cell liner is covered by at least l8 inches ofsoil or filI material at the point of
access.
4, Prior te urleading; the driver rvill be instrueted te epen er untarp the load, The
Radiation Safety persennel will visually inspeet the bypreduet material te ensure
faeilities and Mill Waste DispesaUPBr 10=l le (2) Sel Rev I (12 0l l0) (2)'Cee
Formatted: Numbered + Level: 2 +
Numbering Style: a, b, c, .., + Start at: 1 +
Alignment; Left + Aligned at: 1" + Indent at:
1.25"
Formatted: Bullets and
Formatted: Indent: Left: 0", Hanging: 0.75",
OuUine numbered + Level: 1 + Numbering
Style: 1,2,3,... + Startat: 1 + Alignment: Left
+ Aligned at: 0" + Tab after: 0.5" + Indent
at: 0.5", Tab stops: 0.75". List tab + Not at!j"
Formatted: List Paragraph, No bullets or
numbering, WidoVO
Formatted: Indent: Left: 0.75", No bullets or
numbering
No.: PBL-10 | DENISON MINES (USA) CORP.
Rev. No.: R-33 | STaNDARD OPERATING PROCEDURES I Page 5 ofDate: I Title: I le.(2) Byproduct Disposal | 9106
JuneSept.Dee. I,
201rg
not me€ting the requi
irs@
*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 !gr_!ut is not required to be
contained in the shipping container on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
6.5._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 byoroduct material susoected of
not meeting the requirements set forth in Section 2.0 of this SOP will be kept
segresated from other waste material until a determination is made of its
acceptability for disposal.
g!)_After unloading, a photo of the unloaded material will be taken which is attached.
to the shipping documentation for verification of shipment contents.
slThe 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.
Amendment for ?0lO\DR
faeilitieri and fUill Wafte DispesaVPBt l0:l I e (2) SeP Rer I ( I 2 0' l0X2),de€
Formatted: Indent: Left: 0.25", Hanging:
0.2s'
Formatted: Indent: Left: 0.25", Hanging:
0.25'
NO.: PBL.IO I OENISON MINES (USA) CORP.
Rev. No.: R-12 | STnNDARD OPERATINC PROCEDURES I Page 6 of
Date: I Title: I le.r2t Byproduct Disposal | 9106
JuneSept.Dee. I,
20t
O 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 mrq!1/hr at I meter,
and the average measurement, measured in mreldhr 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
present. The information will be recorded on the Radiation Department's copy of
the shipment documentation. If organics are detected, the RSO must be advised,
and no compaction or covering activities relating to the shipment shall occur until
specifically instructed by the RSO. The RSO will determine if any additional
safety precautions are required to be taken by workers or otherwise as a result of
the detection of the organics, and will implement any such precautions. The RSO
will also contact DUSA corporate regulatory personnel and the shipper to verify
that the detected organics are lle.(2) byproduct material from the shipper's ISL
facility. Once the RSO has verified that the organics are byproduct material
compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover'
activities. If the gross alpha exceeds 25Vo 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.
r) DisBes4; g€t:
Hew the materiat was B
irgfr@
Beeument tnat *e + feet
$j.i)After unloading the byproduct material, replace the tarp or close the trailer, unless.
the trailer is being decontaminated for unrestricted release.
i)kj) 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.
l) Shipment and disposal activities will be documented as described in Section 10.
below.
nR&RJ,de€htte:#
faeilities a'rd l'{ill Wa;te DispesaVPBt l0:l le (2, SOP Rev I (12 0l l0) (3),doe
Formattedr Indent: Left: 0.25", Hanging:
0.25"
Formatted3 Indent: Left: 0.25", Hanging:
0.25'
Formatted: Indent: Left: 0.25", Hanging:
0.2s'
Comment [R!i]: This might be a betrer fit in a
different spot of the SOP or slightly diffffint
languagebut you get tlte idea The main thing is
that the entirc etivity frcm eeptanc€ to fnal
dcposition reeds to be docurenM
Comment [,AT6I: Please see Section l0
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',
No.: PBL-10 I OEMSON MINES (USA) CORP.
Rev. No.: R-12 | STANDARD OPERATINC PROCEDURES I Page 7 of
Date: I Title: I le.(2) Byproduct Disposat | 9105
JuneSeot.Dee. I,
201
7.0 Coverine 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.
/-Jhebyproduct material will be compacted with at least ene-passfoqJ4gsgl of the'
construction equipment prior to placing an additional layer.
2--
-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.
J.
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 banels 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 placeai
over the byproduct material working area. The fill and cover material will be
compacted with at least one pass of the construction equipment.
a{-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.
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at: 0.5"
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Formatted: Numbered + Level: I +
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at: 0.5"
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at: 0.5"
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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"
NO.: PBL-10 I DENISON MINES (USA) CORP.
Rev. No.: R-l? I STATDARD OPERATING PROCEDURES I Page 8 of
Date: I Tide: I le.(2) Byproduct Disposal I g-l-06
JuneSept.Dee. I,
201r0
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
Part49 CFR 173.441(b) and 113.443. Any trailers that are to be released for unrestricted
use will be decontaminated according to the requirements found in Table I of the Nuclear
Regulatory Commission's (NRC's) Policy and Cuidance 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
Operating Procedures for the appropriate conveyance:
End Dump Trailer
lntermodal Container
Standard Container Trailer
to the following Standard
SOP PBL-g
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safetv
l. Reouired Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be wom in the restricted
area of the Mill. Prior to disposal. the RSO will determine what level of
respiratory Eotection. if any. will be required.
2. Industrial Hazards and Safety
+)!l____Use caution when the trailers are backing to the unloading area.
erd) 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.
slli-.-**Drivers must use caution during the unloading process and be aware of
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Comment [R7]: Dry sils might reed respintor
prctection or dust contml lo control aiftome
contaminatim ild exposure md should be evalu&d
by the RSO pritr b disposal.
Comment [rATSli Please see iosrtion.
Respiratory protiction is the subjrct of other plans
that will noi be r€peated herc-
NO.: PBL-10 I DENISON MINES (USA) CORP.
Rev. No.: R-J2 I STANDARD OPERATING PROCEDURES I Page 9 of
Date: I Title: I le.(2) Byproduct Disposal I 9106
JtmeSept.Dee. I,
20110
any overhead hazards.
4lDDo not place any part
tipped and the tailgate
properly blocked open.
of your body inside the trailer when the trailer is being
is open. Only work around the tailgate after it has been
sts) Use caution when entering or exiting equipment. Be sure to use the
ladders and hand rails. Do not jump off the equipment.
$tr lAlways use a ladder when entering andL/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.
Audible backup alarms shall be in operating condition.
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.
Use caution when entering or exiting equipment. Be sure to use the ladders and
hand rails. Do not jump offthe equipment.
Seat belts shall be used at all times when equipment is in motion.
Equipment shall be operated at a reasonable speed consistent with road and
weather conditions, subject to a maximum speed limit of 15 m'ph.
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) Al1 gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate
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NO.: PBL.IO I DENISON MINES (USA) CORP.
Rev. No.: R-32 | STANDARD OPERATING PROCEDURES I Page l0 of
Date:
JuneSeot.Dee. I,
Title: I te.(2) Byproduct Disposal | 9106
20110
berms where required.
10.0 Documentation
l. a) Documentation of Shipments
+ For each shipment of byproduct material the following records will be
maintained in the Mill's Radiation Department files:
o Shipper's Manifest and Bill of Lading.. Laboratory/activity analysis of the byproduct material performed by
the Shipper.. Completed SWT.o 7-day notice to Executive Secretary.o Photo of the byproduct material.
. Byproduct material radiological scan information.o Breathing zone monitoring data, if applicable.
g_Equipment release forms.
b) Documentation of Disposal
Byoroduct material disposal will -be documented on the Disposal Documentation.
Form orovided in Attachment 2. Attachment 2 may be accompanied by
photoeraphs. a written description or both. Attachment 2 or other written
description will include:
o How the material was placed in the tailing cells:
o If void spaces were filled with tailinss sands:o How the area was comoacted:o 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):o Document that there are 4 feet of tailings under the bottom of each
disposal area and the bottom ofeach disposal area is located at least l2
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
deoartment):o Confirmation that the shipment was properly covered: and
*Where settlement ma
?.9-The Mill will maintain a plat of each Designated Disposal Area, *frichl
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Formatted: Indent: Left: 1.25"
Formattedi Outline numbered + Level: 1 +
Numbering Style: Eullet + Aligned at: 1" + Tab
after: 1.25" + Indent at: 1,25"
No.: PBL-10 | DENISONMINES(USA)CORP.
Rev. No.: R-f2 | STANDARD OPERATING PROCEDURES I Page I I of
Date:
JuneSept.Dee. I,
Title: I le.(2) Byproduct Disposal I gO0
201rc
illustrates the location of each shipment of byproduct material.
*Z-The Mill will maintain on file a copy of the Executive Secretary's written
approval of each Designated Disposal Area.
4l-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 felle*iag+alendar year. (License Condition 10.5F). fsummarv due same yearl
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ATTACHMENT 1
SAFETY TRAINING FOR DELryERY PERSONNEL
Welcome to Denison Mines (USA) Corp.'s, White Mesa Mill. In order to assure your safety while on
our property, we would like to acquaint you with the safety rules and procedures, which you will be
required to follow while on our property.
1.0 General Safetv
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 rnptr, Denison Mines (USA) Corp.'s equipment has the right of
way on the ore pad and Mill roadways.
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.
Check for potential overhead hazards prior to dumping.
If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safetv
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed)Scale House Operator
Driver (Signature)Date
a "oo
ATTACHMENT2
rle.Qt BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Neme of emnlovee receiving the load'
Generator of the Bvnroduct Material:
Was the State of Utah siven notice to the receiptidisposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of bvproduct material disposal arealactivities:
Was the material placed on a railings beach area of the cell or on an area of the cell that was underlain* @
by tailings sands?
Was the material segregated frdm any Mill material or equipment disposed o[ in the cell?
Formatted: Indent: Hanoing: 0.25", No
bullets or numbering
FormatHr Indent: Left: -0.25", No bullets or
numberingWas the material segreqated from byproduct material from other ISL sources disposed of in the cell?
Have the thickness and placement measurements been verified and documented for the disBosal area
by the engineer. specifically:
Engineer's
Initials
Was the maximum lift thickness above tailinss less than 4 feet thick?
Was the maximum lift thicknessof subsequent lifts less than 2 feet
thick?
Has 4 foot of tailinos sands heen mrintained rrnder each disnosal area?
Is the bottom of each disposal area at least I 2 feet from the sides or
dikes of the tailinss cell?
How was the area comoacted? Was each lift compacted by heavv equipment (such as a Cat D-6) at
least 4 times orior to placement of subsequent lifts?
Were void spaces filled with tailings?
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Was the shipment properly covered?Formatted: Indent: Left: -0.25", No bullets or
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Are additional settlement monitors required to be placed for this generator?
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If required. where were settlement markers were placed?
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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