DRC-2024-004213

DRC-2024-004213 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director
M E M O R A N D U M

THROUGH: Phil Goble, Uranium Mill Section Manager FROM: Heather Mickelson, PE, PG
DATE: January 29, 2024
SUBJECT: White Mesa Uranium Mill, Standard Operating Procedures for the Environmental Protection Manual

Revised Standard Operating Procedures for the Environmental Protection Manual at the White Mesa Uranium Mill were received on January 3, 2024 (DRC-2024-002206). The submission included both a redline/strikeout and a clean version of the revised Standard Operating Procedures (SOPs), covering the following sections:

Section 1.2 – Air Monitoring – Radon Section 1.3 – Meteorological Data Monitoring Plan and Standard Operating Procedures Section 2.1 – Surface Water Monitoring Plan and Standard Operating Procedures Section 3.4 – White Mesa Mill Tailings Management System Tailings Line Detection
Section 5.0 – Settlement Monitoring Standard Operating Procedures
Section 5.1—Movement (Displacement Monitoring Standard Operating Procedures The Division of Waste Management and Radiation Control (Division) staff reviewed these updates and
provided comments. On January 18, 2024, the Division received further updated SOPs (DRC-2024-
004124) specifically for: Section 3.4 White Mesa Mill Tailings Management System Tailings Line Detection Section 5.0 Settlement Monitoring Standard Operating Procedures.

Compared to the previous Environmental Protection Manual, significant changes were incorporated into Section 3.4 - White Mesa Mill Tailings Management System Tailings Line Detection and Section 5.0 - Settlement Monitoring Standard Operating Procedures. All other modifications throughout the proposed revised SOPs were of a grammatical nature or involved updating the SOP in accordance with current
data or analyte collection systems.
01/29/2024
01/29/2024
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Section 3.4 - White Mesa Mill Tailings Management System Tailings Line Detection This section underwent updates to reflect the current tailings line configuration, the line is situated above ground and traverses over the top of the tailing cells. The existing line system is subject to official inspections three times daily. In the event of a malfunction detected between these inspections, pertinent
individuals are promptly notified, and necessary repairs are carried out. Any liquid discharged from the
tailings line is captured by the traversed tailing cell. Sections of the SOP pertaining to a hypothetical underground tailings line system that left the restricted area, which never existed at the White Mesa Uranium Mill, were removed. Should such a system be
installed in the future, the SOP would be updated accordingly. The current SOP is designed to
effectively communicate monitoring requirements for the existing system, avoiding potential confusion for operators. Section 5.0 Settlement Monitoring Standard Operating Procedures
This section saw updates with the categorization of the settlement monitors and the category’s
associated triggers necessitating further investigation or corrective action. The White Mesa Uranium Mill categorized settlement monitors into two types based on whether they are on actively dewatering cells (e.g., Cell 2) or on non-dewatering cells (Cell 3).
For cells that are being actively dewatered, they will retain the change in settlement (0.1 feet per month)
that requires further investigation, potential corrective action notifications, and reporting requirements. If a cell is not actively being dewatered, the trigger for further investigation and potential corrective action has been modified to a settlement of 0.5 ft in one month. Also, instead of notifying the Division
within 30 calendar days, these settlements will be reported in the Annual Technical Evaluation Report
(ATER). This modification is appropriate as a non-dewatered cell has the potential for greater movement compared to a cell undergoing dewatering.

Recommendations Staff recommends approving the White Mesa Uranium Mill’s Standard Operating Procedures for the Environmental Protection Manual that were received on January 18, 2024 and those received on January
3, 2024 that were not updated with the January 18, 2024 submission.