DRC-2009-006751 - 0901a0688015233a

Permit No. UGW370004

STATE OF UTAH
DIVISION OF WATER QUALITY
DEPARTMENT OF ENVIRONMENTAL QUALITY
UTAH WATER QUALITY BOARD
SALT LAKE CITY, UTAH 84114-4870

GROUND WATER DISCHARGE PERMIT

In compliance with the provisions of the Utah Water Quality Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,

Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 17th Street
Denver, Colorado 80265

is granted a ground water discharge permit for the operation of a uranium milling and tailings
disposal facility located approximately 6 miles south of Blanding, Utah. The facility is located on a
tract of land in Sections 28, 29, 32, and 33, Township 37 South, Range 22 East, Salt Lake Base and
Meridian, San Juan County, Utah.

The permit is based on representations made by the Permittee and other information contained in the
administrative record. It is the responsibility of the Permittee to read and understand all provisions
of this Ppermit.

The milling and tailings disposal facility shall be operated and revised in accordance with conditions
set forth in the Ppermit and the Utah Ground Water Quality Protection Regulations.

This modified Ground Water Quality Discharge Permit amends and supersedes all other Ground
Water Discharge permits for this facility issued previously.

This Ppermit shall become effective on _________________.
This Ppermit shall expire March 8, 2010.

Signed this ____ day of ________, 2008

_______________________.
Co-Executive Secretary
Utah Water Quality Board

i
Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS...................................................................... 1
A. GROUND WATER CLASSIFICATION....................................................................................... 1
B. BACKGROUND WATER QUALITY.......................................................................................... 2
C. PERMIT LIMITS..................................................................................................................... 2
1. Ground Water Compliance Limits ................................................................................. 2
2. Tailings Cell Operations................................................................................................. 2
3. Prohibited Discharges..................................................................................................... 2
D. DISCHARGE MINIMIZATION AND BEST AVAILABLE TECHNOLOGY STANDARDS................... 6
1. DMT Design Standards for Existing Tailings Cells 1, 2, and 3..................................... 6
2. Existing Tailings Cell Construction Authorized............................................................ 8
3. Existing Facility DMT Performance Standards.............................................................. 8
4. Best Available Technology Requirements for New Construction ............................... 11
5. BAT Design Standards for Tailings Cell 4A................................................................ 11
6. BAT Performance Standards for Tailings Cell 4A....................................................... 14
7. Definition of 11e.(2) Waste.......................................................................................... 14
8. Closed Cell Performance Requirements....................................................................... 14
9. Facility Reclamation Requirements.............................................................................. 15
10. Stormwater Management and Spill Control Requirements.......................................... 15
11. Requirements for Feedstock Material Stored Outside the Feedstock Storage Area..... 15
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING............. 16
1. Routine Groundwater Compliance Monitoring............................................................ 16
2. Groundwater Monitoring: Monitoring Wells MW-20 and MW-22............................ 17
3. Groundwater Head Monitoring .................................................................................... 18
4. Groundwater Monitoring Well Design and Construction Criteria............................... 18
5. Monitoring Procedures for Wells................................................................................. 18
6. White Mesa Seep and Spring Monitoring.................................................................... 19
7. DMT Performance Standard Monitoring ..................................................................... 19
8. BAT Performance Standard Monitoring...................................................................... 21
9. On-site Chemicals Inventory........................................................................................ 22
10. Tailings Cell Wastewater Quality Monitoring............................................................. 22
11. Groundwater Monitoring Modifications ...................................................................... 23
F. REPORTING REQUIREMENTS............................................................................................... 23
1. Routine Groundwater Monitoring Reports................................................................... 23
2. Routine DMT Performance Standard Monitoring Report............................................ 24
3. Routine BAT Performance Standard Monitoring Reports........................................... 24
4. DMT and BAT Performance Upset Reports................................................................ 25
5. Other Information......................................................................................................... 25
6. Groundwater Monitoring Well As-Built Reports......................................................... 25
7. White Mesa Seeps and Springs Monitoring Reports....................................................26
8. Chemicals Inventory Report......................................................................................... 26
9. Tailings Cell Wastewater Quality Reports................................................................... 26
10. Revised Hydrogeologic Report .................................................................................... 27
11. Annual Slimes Drain Recovery Head Report............................................................... 27
G. OUT OF COMPLIANCE STATUS............................................................................................ 27
1. Accelerated Monitoring Status..................................................................................... 28
2. Violation of Permit Limits ........................................................................................... 28
3. Failure to Maintain DMT or BAT Required by Permit................................................ 28
4. Facility Out of Compliance Status ............................................................................... 29
H. COMPLIANCE SCHEDULE REQUIREMENTS.......................................................................... 29

ii
1. On-site Chemicals Inventory Report............................................................................ 33
2. Infiltration and Contaminant Transport Modeling Work Plan and Report .................. 33
3. Plan for Evaluation of Deep Supply Well WW-2........................................................ 35
4. Supplemental Isotopic Groundwater and Surface Water Investigation and Report..... 36
5. New Decontamination Pad........................................................................................... 37
6. Existing Decontamination Pad..................................................................................... 38
PART II. REPORTING REQUIREMENTS........................................................................ 39
A. REPRESENTATIVE SAMPLING.............................................................................................. 39
B. ANALYTICAL PROCEDURES................................................................................................ 39
C. PENALTIES FOR TAMPERING............................................................................................... 39
D. REPORTING OF MONITORING RESULTS............................................................................... 39
E. COMPLIANCE SCHEDULES.................................................................................................. 39
F. ADDITIONAL MONITORING BY THE PERMITTEE.................................................................. 39
G. RECORDS CONTENTS.......................................................................................................... 39
H. RETENTION OF RECORDS.................................................................................................... 39
I. NOTICE OF NONCOMPLIANCE REPORTING.......................................................................... 40
J. OTHER NONCOMPLIANCE REPORTING................................................................................ 40
K. INSPECTION AND ENTRY..................................................................................................... 40
PART III. COMPLIANCE RESPONSIBILITIES................................................................41
A. DUTY TO COMPLY.............................................................................................................. 41
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS........................................................ 41
C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE...................................................... 41
D. DUTY TO MITIGATE............................................................................................................ 41
E. PROPER OPERATION AND MAINTENANCE........................................................................... 41
PART IV. GENERAL REQUIREMENTS.......................................................................... 42
A. PLANNED CHANGES........................................................................................................... 42
B. ANTICIPATED NONCOMPLIANCE......................................................................................... 42
C. PERMIT ACTIONS................................................................................................................ 42
D. DUTY TO REAPPLY............................................................................................................. 42
E. DUTY TO PROVIDE INFORMATION ...................................................................................... 42
F. OTHER INFORMATION......................................................................................................... 42
G. SIGNATORY REQUIREMENTS .............................................................................................. 42
H. PENALTIES FOR FALSIFICATION OF REPORTS...................................................................... 43
I. AVAILABILITY OF REPORTS................................................................................................ 43
J. PROPERTY RIGHTS ............................................................................................................. 43
K. SEVERABILITY.................................................................................................................... 43
L. TRANSFERS........................................................................................................................ 43
M. STATE LAWS...................................................................................................................... 44
N. REOPENER PROVISIONS......................................................................................................44
List of Tables
Table 1. Ground Water Classification ............................................................................................ 1
Table 2. Groundwater Compliance Limits..................................................................................... 3
Table 3. DMT Engineering Design and Specifications ................................................................. 6
Table 4. Feedstock Storage Area Coordinates............................................................................. 10
Table 5. Approved Tailings Cell 4A Engineering Design and Specifications.............................11
Table 6. Groundwater Monitoring Reporting Schedule............................................................... 23
Part I
Permit No. UGW370004
1
PART I. SPECIFIC PERMIT CONDITIONS
A. GROUND WATER CLASSIFICATION - the ground water classification of the shallow aquifer under
the tailings facility has been determined on a well-by-well basis, as defined in Table 1, below:
Table 1. Ground Water Classification
Class II Groundwater Class III Groundwater
Average TDS (mg/L) Average TDS (mg/L)
DUSA Data DUSA Data
Well
ID N(1)
Average
Concentration(2)
Standard
Deviation(2) Well ID N(1)
Average
Concentration(2)
Standard
Deviation(2)
MW-1 77 1,2761,273 93 MW-2 77 3,0313,050 252
MW-5 82 2,0812,058 170 MW-3 78 5,2005,217 263
MW-
11MW-
11
71 1,8441,834 178 MW-12 61 3,8943,939 241
MW-
30MW-
18
10 1,7452,545 87 MW-14 51 3,5823,592 176
MW-
19(4)
2,697 9 MW-15 47 3,8553,857 243
MW-
20(5)
2,977 1 MW-17 22 4,5384,444 321
MW-
18(43)
18 2,6054 297
MW-
19(34)
22 2,457 900
MW-
20(4)MW-
20?
2 5,610 57
MW-
22(45)
2 5,1057,365 361
MW-3A 9 5,547 129
MW-23 10 3,443 244
MW-24 10 4,116 117
MW-
25(56)
11 2,8432 67
MW-
26(66)
12 3,1553,120 65
MW-
27(78)
10 1,019 28
MW-28 11 3,677 87
MW-29 8 4,380 27
MW-
31(78)
10 1,265 50
MW-
32(88)
12 3,1903,669 247
Footnotes:
1) N = Number of Samples
1)2) Based on historic total dissolved solids (TDS) data provided by the Permittee for period between October, 1979 and December, 2007 May,
1999. . This data was obtained from the Permittee’s background groundwater quality reports dated October 2007 and April 30, 2008.
Average concentrations calculated by Utah Division of Radiation Control (DRC) staff in a November 29, 1999 memorandum.
Part I
Permit No. UGW370004
2
2)Based on average of DRC split samples collected from the White Mesa facility between May, 1999 and September, 2002.
3)Number of IUC or DRC samples used in the evaluation of average TDS concentrations.
4)3) Classification of well MW-19 based on the conservatively lower IUC dataBackground concentrations of uranium in well MW-18 (55.1 µg/L)
and thallium in MW-19 (2.1 µg/L) exceed the GWQS, 30 µg/L and 2.0 µg/L, respectively. Therefore these wells have been classified as
Class III groundwater rather than Class II groundwater. .
5)4) Wells MW-20 and MW-22 are not point of compliance monitoring wells, but instead are groundwater head monitoring wells as per Part I.E.2.
Average concentrations and standard deviations for wells MW-20 and MW-22 were calculated by DRC staff from data from the DUSA 2nd
and 3rd Quarters of 2008 Routine Groundwater Monitoring Reports.
5) Background concentration of manganese in well MW-25 (1,806 µg/L) exceeds the GWQS, therefore well MW-25 has been classified as Class
III groundwater rather than Class II groundwater.
6) Well MW-26 was originally named TW4-15 and was installed as a part of thea recent chloroform contaminant investigation at the facility.
Under this Permit, MW-26 is defined as a Point of Compliance (POC) well for the tailings cells (see Part I.E.1).
7) Background concentrations of uranium in well MW-27 (34 µg/L) and selenium in MW-31 (71 µg/L) exceed the GWQS, therefore these wells
have been classified as Class III groundwater rather than Class II groundwater. .
8) Well TW4-16 was installed as a part of a recent chloroform investigation at the facility, and has been included in the Permit as groundwater
head monitoring well (Part I.E.2). Groundwater classification provided here based on average of both the IUC and DRC data (2 samplesWell
MW-32 was originally named TW4-17 and was installed as a part of a recentthe chloroform contaminant investigation at the facility. Under
this Permit it is included as a POC well for the tailings cells in Part I.E.1.

B. BACKGROUND WATER QUALITY - based on groundwater samples collected through August 2007,
the upper boundary of background groundwater quality iswill be determined on a well-by-well
basis,, as and is defined by the mean plus second standard deviation concentrationpursuant to
Environmental Protection Agency (EPA) guidance, and documented in the Permittee’s
background groundwater quality reports dated October 2007 ________ and ________April 30,
2008. . After Executive Secretary approval of the Background Groundwater Quality Reports
required by Part I.H.3 and 4, this permit will be re-opened and Table 2 revised to define
background concentrations and groundwater compliance limits for all required contaminants.

C. PERMIT LIMITS - the Permittee shall comply with the following permit limits:
1. Ground Water Compliance Limits - contaminant concentrations measured in each monitoring
well shall not exceed the Ground Water Compliance Limits (GWCL) defined in Table 2,
below. Ground water quality at the site must at all times meet all the applicable GWQS and
ad hoc GWQS defined in R317-6 even though this permit does not require monitoring for
each specific contaminant.
2. Tailings Cell Operations - only 11.e.(2) by-product material authorized by Utah Radioactive
Materials License No. UT-2300478 (hereafter License) shall be discharged to or disposed of
in the tailings ponds.
3. Prohibited Discharges - discharge of other compounds such as paints, used oil, antifreeze,
pesticides, or any other contaminant not defined as 11e.(2) material is prohibited.

3
Table 2. Groundwater Compliance Limits (GWCL)
Upgradient Wells Down or Lateral Gradient Wells
MW-1
(Class II)
MW-18
(Class III)
MW-19
(Class III)
MW-27
(Class III)
MW-2
(Class III)
MW-3
(Class III)
MW-3A
(Class III)
MW-5
(Class II)
MW-11
(Class II)
MW-12
(Class III)
MW-14
(Class III)
MW-15
(Class III)
Contaminant GWQS (1) GWCL (6) GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL (7) GWCL GWCL GWCL
Nutrients (mg/L)
Ammonia (as N) 25(2) 6.25 0.27 0.31 12.5 12.5 1.16 0.6 1.02 6.25 0.6 12.5 0.21
Nitrate + Nitrite (as N) 10 2.5 2.5 2.83 5.6 0.12 0.73 1.3 2.5 2.5 5 5 0.27
Heavy Metals (µg/L)
Arsenic 50 12.5 25 25 25 25 25 25 17 15 25 25 25
Beryllium 4 1 2 2 2 2 2 2 1 1 2 2 2
Cadmium 5 4.2 2.5 2.5 2.5 2.5 4.67 8.3 2 1.25 7 2.5 2.5
Chromium 100 50 50 50 50 50 50 50 25 25 50 50 50
Cobalt 730 (5) 182.5 365 365 365 365 365 365 182.5 182.5 365 365 365
Copper 1,300 325 650 650 650 650 650 650 325 325 650 650 650
Iron 11,000 (5) 2,750 414.68 5,500 5,500 151.6 427.13 5,500 2,750 2,750 5,500 5,500 81.7
Lead 15 5.59 7.5 7.5 7.5 7.5 7.5 7.5 4.1 3.75 7.5 7.5 7.5
Manganese 800 (4) 289 350 400 400 378.76 4,233 6,287 376.74 131.29 2,088.80 2,230.30 400
Mercury 2 0.5 1 1 1 1 1 1 1 0.5 1 1 1
Molybdenum 40 (2) 10 20 20 20 20 20 20 10 10 20 25 30
Nickel 100 (3) 25 50 50 50 60 100 105 44.1 46.2 60 50 97
Selenium 50 12.5 25 28.96 25 26.6 37 89 12.5 12.5 25 25 128.7
Silver 100 25 50 50 50 50 50 50 25 25 50 50 50
Thallium 2 0.5 1.95 2.1 1 1 1.6 1.4 0.5 0.5 1 1 1
Tin 17,000(4) 4,250 8,500 8,500 8,500 8,500 8,500 8,500 4,250 4,250 8,500 8,500 8,500
Uranium 30 (3) 7.28 55.1 21.43 34 18.45 47.32 35 7.5 7.5 23.5 98 65.7
Vanadium 60 (4) 15 30 30 30 30 30 30 15 15 30 30 40
Zinc 5,000 251 2,500 2,500 2,500 2,500 173.19 155 87.38 1,250 2,500 35.04 2,500
Radiologics (pCi/L)
Gross Alpha 15 3.75 7.5 2.36 2 3.2 1 7.5 3.75 3.75 7.5 7.5 7.5
Volatile Organic Compounds (µg/L)
Acetone 700 (4) 175 350 350 350 350 350 350 175 175 350 350 350
Benzene 5 1.25 2.5 2.5 2.5 2.5 2.5 2.5 1.25 1.25 2.5 2.5 2.5
2-Butanone (MEK) 4,000 (2) 1,000 2,000 2,000 2,000 2,000 2,000 2,000 1,000 1,000 2,000 2,000 2,000
Carbon Tetrachloride 5 1.25 2.5 2.5 2.5 2.5 2.5 2.5 1.25 1.25 2.5 2.5 2.5
Chloroform 70 (4) 17.5 35 35 35 35 35 35 17.5 17.5 35 35 35
Chloromethane 30 (2) 7.5 15 15 15 15 15 9.4 7.5 7.5 15 15 15
Dichloromethane 5 (3) 1.25 2.5 2.5 2.5 2.5 2.5 2.5 1.25 1.25 2.5 2.5 2.5
Naphthalene 100 (2) 25 50 50 50 50 50 50 25 25 50 50 50
Tetrahydrofuran 46 (4) 11.5 23 23 23 23 23 23 11.5 11.5 23 23 23
Toluene 1,000 250 500 500 500 500 500 500 250 250 500 500 500
Xylenes (total) 10,000 2,500 5,000 5,000 5,000 5,000 5,000 5,000 2,500 2,500 5,000 5,000 5,000
Others
Field pH (S.U.) 6.5 - 8.5 6.77 - 8.5 6.25 - 8.5 6.78 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.62 - 8.5
Fluoride (mg/L) 4 0.56 0.45 1.39 0.85 0.43 0.68 1.6 1.42 1 2 0.2 2
Chloride (mg/L) 22.1 69.23 104.41 38 20 76 70 71 39.16 80.5 27 57.1
Sulfate (mg/L) 838 1,938.90 2,534.10 462 2,147 3,663 3,640 1,518 1,309 2,560 2,330 2,549.02
TDS (mg/L) 1,567 3,198.77 4,257.42 1,075 3,800 6,186 5,805 2,575 2,528 4,323 4,062 4,530

4
Table 2 Continued. Groundwater Quality Compliance Limits (GWCL)
Down or Lateral Gradient Wells
MW-17
(Class III)
MW-23
(Class III)
MW-24
(Class III)
MW-25
(Class III)
MW-26
(Class III)
MW-28
(Class III)
MW-29
(Class III)
MW-30
(Class II)
MW-31
(Class III)
MW-32
(Class III)
Contaminant GWQS (1) GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL (7)
Nutrients (mg/L)
Ammonia (as N) 25 (2) 0.26 0.6 7 0.77 0.92 12.5 1.3 0.14 12.5 1.17
Nitrate + Nitrite (as N) 10 5 5 5 5 0.62 5 5 2.5 5 5
Heavy Metals (µg/L)
Arsenic 50 25 25 17 25 25 21 25 12.5 25 25
Beryllium 4 2 2 2 2 2 2 2 1 2 2
Cadmium 5 2.5 2.5 2.5 1.5 2.5 5.2 2.5 1.25 2.5 4.72
Chromium 100 50 50 50 50 50 50 50 25 50 50
Cobalt 730 (5) 365 365 365 365 365 47 365 182.5 365 75.21
Copper 1,300 650 650 650 650 650 650 650 325 650 650
Iron 11,000 (5) 5,500 5,500 4,162 5,500 2,675.83 299 1,869 2,750 5,500 14,060
Lead 15 7.5 7.5 7.5 7.5 7.5 7.5 7.5 3.75 7.5 7.5
Manganese 800 (4) 915.4 550 7,507 1,806 1,610 1,837 5,624 61 400 5,594.90
Mercury 2 1 1 1 1 1 1 1 0.5 1 1
Molybdenum 40 (2) 20 20 20 20 20 20 20 10 20 20
Nickel 100 (3) 50 50 50 50 50 50 50 25 50 94
Selenium 50 25 25 25 25 25 11.1 25 34 71 25
Silver 100 50 50 50 50 50 50 50 25 50 50
Thallium 2 1 1.5 1 1.1 1 1 1.2 0.5 1 1
Tin 17,000(4) 8,500 8,500 8,500 8,500 8,500 8,500 8,500 4,250 8,500 8,500
Uranium 30 (3) 46.66 32 11.9 6.5 41.8 4.9 15 8.32 9.1 5.26
Vanadium 60 (4) 30 30 30 30 30 30 30 15 30 30
Zinc 5,000 2,500 74 2,500 2,500 2,500 83 30 1,250 2,500 230
Radiologics (pCi/L)
Gross Alpha 15 2.8 2.86 7.5 7.5 4.69 2.42 2 3.75 7.5 3.33
Volatile Organic Compounds (µg/L)
Acetone 700 (4) 350 350 350 350 350 350 350 175 350 350
Benzene 5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 1.25 2.5 2.5
2-Butanone (MEK) 4,000 (2) 2,000 2,000 2,000 2,000 2,000 2,000 2,000 1,000 2,000 2,000
Carbon Tetrachloride 5 2.5 2.5 2.5 2.5 5 2.5 2.5 1.25 2.5 2.5
Chloroform 70 (4) 35 35 35 35 70 35 35 17.5 35 35
Chloromethane 30 (2) 15 5.7 15 15 30 4.6 15 7.5 6.1 15
Dichloromethane 5 (3) 2.5 2.5 2.5 2.5 5 2.5 2.5 1.25 2.5 2.5
Naphthalene 100 (2) 50 50 50 50 50 50 50 25 50 50
Tetrahydrofuran 46 (4) 23 23 23 23 23 23 23 11.5 23 23
Toluene 1,000 500 500 500 500 500 500 500 250 500 500
Xylenes (total) 10,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 2,500 5,000 5,000
Others
Field pH (S.U.) 6.5 - 8.5 6.40 - 8.5 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 6.74 - 8.5 6.1 - 8.5 6.46 - 8.5 6.5 - 8.5 6.5 - 8.5 6.4 - 8.5
Fluoride (mg/L) 4 2 2 0.36 0.42 2 0.73 1.1 0.51 2 2
Chloride (mg/L) 46.8 10 71 35 58.31 105 41 128 143 35.39
Sulfate (mg/L) 2,860 2,524 2,903 1,933 2,082.06 2,533 2,946 972 532 2,556.70
TDS (mg/L) 5,085.42 3,670 4,450 2,976 3,284.19 3,852 4,400 1,918 1,320 3,960

5
Footnotes:
1) Utah Ground Water Quality Standards (GWQS) as defined in UAC R317-6, Table 2. Ad hoc GWQS also provided herein, as noted, and as allowed by UAC R317-6-2.2.
2) Ad hoc GWQS for ammonia (as N), molybdenum, 2-Butanone (MEK), chloromethane, and naphthalene based on EPA drinking water lifetime health advisories.
3) Ad hoc GWQS for nickel, uranium, and dichloromethane (methylene chloride, CAS No. 75-09-2) based on final EPA drinking water maximum concentration limits (MCL).
4) Ad hoc GWQS for manganese, tin, vanadium, acetone, chloroform (CAS No. 67-66-3), and tetrahydrofuran based on drinking water ad hoc lifetime health advisories prepared by or in collaboration with EPA Region 8 staff.
5) Ad hoc GWQS for cobalt and iron based on EPA Region 3 Risk Based Concentration limits for tap water.
6)Mean concentration and standard deviation (S.D.) to be determined on a well-by-well and individual parameter basis at some future date.
7)6) Ground Water Compliance Limits (GWCL) based on one of the following formulas: for Class II Groundwater, GWCL = 0.25 * GWQS, for Class III Groundwater, GWCL = 0.5 * GWQSwere set. A after ExecutuveExecutive
Secretary review and submittal and approval of two Background Groundwater Quality Reports dated October_2007____ and April 30, 2008 from the Permittee._____.s, required by Part I.H. 3 and 4 of this Permit, the Executive
Secretary will re-open and modify the Ground Water Compliance Limit (GWCL) to be equal to the mean concentration plus two standard deviations (X+2 ) for each well and contaminant.
7)Future monitoring wells to be installed in accordance with Part I.H.1 of this Permit.
7) TBD = to be determined after Executive Secretary approval of the Background Groundwater Quality Reports for existing and new monitoring wells required by Part I.H.3 GWCLs listed in the table above in Normal Fontand I.H.4,
respectively are those proposed by the Permittee in the October 2007 and April 30, 2008 DUSA Background Groundwater Quality Reports, and approved by the Executive Secretary.
8) GWCLs listed in the table above in Bold Text are values modified by the Executive Secretary after review of GWCLs proposed in the Permittee’s;s October 2007 and April 30, 2008 Background Groundwater Quality Reports. For
wells MW-1, MW-2, MW-3, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-18, MW-19, MW-26, and MW-32; these modifications are documented in the June 16, 2008 URS Completeness Review for the October,
2007 Revised Background Groundwater Quality Report for Existing Wells. For wells MW-3A, MW-23, MW-24, MW-25, MW-27, MW-28, MW-29, MW-30, and MW-31; these modifications are documented in the June 24,
2008 DRC Findings Memorandum regarding the April 30, 2008 Revised Background Groundwater Quality Report for New Wells.
10) Ad hoc GWQS for tin of 17,000 ug/l based on an ad-hoc drinking water lifetime health advisory prepared by EPA Region 8 staff (see 10/27/05 EPA Region 8 memorandum by Robert Benson to Dean Henderson).

Part I
Permit No. UGW370004
6
D. DISCHARGE MINIMIZATION AND BEST AVAILABLE TECHNOLOGY STANDARDS - the tailings
disposal facility must be built, operated, and maintained according to the following Discharge
Minimization Technology (DMT) and Best Available Technology (BAT) standards:
1. DMT Design Standards for Existing Tailings Cells 1, 2, and 3 - shall be based on existing
construction as described by design and construction information provided by the Permittee,
as summarized in Table 3 below for Tailings Cells 1, 2, and 3:

Table 3. DMT Engineering Design and Specifications
Tailings
Cell
Report
Type Engineering Report Design Figures
Construction
Specifications
Cell 1 Design June, 1979 D’Appolonia
Consulting Engineers, Inc (1)
Appendix A, Sheets 2, 4, 8,
9, 12-15
Appendix B
Cell 2 Design June, 1979 D’Appolonia
Consulting Engineers, Inc (1)
Appendix A, Sheets 2, 4, 7-
10, 12-15
Appendix B
As-Built February, 1982 D’Appolonia
Consulting Engineers, Inc (2)
Figures 1, 2, and 11 N/A
Cell 3 Design May, 1981 D’Appolonia
Consulting Engineers, Inc (3)
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear, Inc. (4)
Figures 1-4 N/A
Footnotes:
1) D’Appolonia Consulting Engineers, Inc., June, 1979, “Engineers Report Tailings Management System White Mesa Uranium Project
Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado”, unpublished consultants report, approximately 50 pp., 2 figures, 16 sheets, 2
appendices.
2) D’Appolonia Consulting Engineers, Inc., February, 1982, “Construction Report Initial Phase - Tailings Management System White Mesa
Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado”, unpublished consultants report, approximately 7 pp., 6 tables,
13 figures, 4 appendices.
3) D’Appolonia Consulting Engineers, Inc., May, 1981, “Engineer’s Report Second Phase Design - Cell 3 Tailings Management System White
Mesa Uranium Project Blanding, Utah Energy Fuels Nuclear, Inc. Denver, Colorado”, unpublished consultants report, approximately 20 pp., 1
figure, 5 sheets, and 3 appendices.
4) Energy Fuels Nuclear, Inc., March, 1983, “Construction Report Second Phase Tailings Management System White Mesa Uranium Project
Energy Fuels Nuclear, Inc.”, unpublished company report, 18 pp., 3 tables, 4 figures, 5 appendices.
a) Tailings Cell 1 -– consisting of the following major design elements:
1) Cross-valley Dike and East Dike -– constructed on the south side of the pond of
native granular materials with a 3:1 slope, a 20-foot crest width, and a crest elevation
of about 5,620 ft above mean sea level (amsl). A dike of similar design was
constructed on the east margin of the pond, which forms a continuous earthen
structure with the south dike. The remaining interior slopes are cut-slopes at 3:1
grade.
2) Liner System - including a single 30 mil PVC flexible membrane liner (FML)
constructed of solvent welded seams on a prepared sub-base. Top elevation of the
FML liner was 5,618.5 ft amsl on both the south dike and the north cut-slope. A
protective soil cover layer was constructed immediately over the FML with a
thickness of 12-inches on the cell floor and 18-inches on the interior sideslope.
3) Crushed Sandstone Underlay -– immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
Beneath this underlay, native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
Part I
Permit No. UGW370004
7
upstream toe of the cross-valley dike.
b) Tailings Cell 2 -– which consists of the following major design elements:
1) Cross-valley Dike -– constructed at the south margin of Cell 2 of native granular
materials with a 3:1 slope, a 20-foot crest width, and crest elevation of about 5,615 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3:1 grade. The
Cell 1 south dike forms the north margin of Cell 2, with a crest elevation of 5,620 ft
amsl.
2) Liner System -– includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 2 is 5,615.0 ft and 5,613.5 ft amsl on
the north and south dikes, respectively. Said Cell 2 FML liner is independent of all
other disposal cell FML liners. Immediately above the FML, a nominal 12-inch (cell
floor) to 18-inch (inside sideslope) soil protective blanket was constructed of native
sands from on-site excavated soils.
3) Crushed Sandstone Underlay -– immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
Beneath this underlay, native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
4) Slimes Drain Collection System immediately above the FML a nominal 12-inch thick
protective blanket layer was constructed of native silty-sandy soil. On top of this
protective blanket, a network of 1.5-inch PVC perforated pipe laterals was installed
on a grid spacing interval of about 50-feet. These pipe laterals gravity drain to a 3-
inch diameter perforated PVC collector pipe which also drains toward the south dike
and is accessed from the ground surface via a 24-inch diameter, vertical non-
perforated HDPE access pipe. Each run of lateral drainpipe and collector piping was
covered with a 12 to 18-inch thick berm of native granular filter material. At cell
closure, leachate head inside the pipe network will be removed via a submersible
pump installed inside the 24-inch diameter HDPE access pipe.
c) Tailings Cell 3 -– consisting of the following major design elements:
1) Cross-valley Dike -– constructed at the south margin of Cell 3 of native granular
materials with a 3:1 slope, a 20-foot crest width, and a crest elevation of 5,610 ft
amsl. The east and west interior slopes consist of cut-slopes with a 3:1 grade. The
Cell 2 south dike forms the north margin of Cell 3, with a crest elevation of 5,615 ft
amsl.
2) Liner System -– includes a single 30 mil PVC FML liner constructed of solvent
welded seams on a prepared sub-base, and overlain by a slimes drain collection
system. Top elevation of the FML liner in Cell 3 is 5,613.5 ft and 5,608.5 ft amsl on
the north and south dikes, respectively. Said Cell 3 FML liner is independent of all
other disposal cell FML liners.
3) Crushed Sandstone Underlay -– immediately below the FML a nominal 6-inch thick
layer of crushed sandstone was prepared and rolled smooth as a FML sub-base layer.
Part I
Permit No. UGW370004
8
Beneath this underlay, native sandstone and other foundation materials were graded
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System -– immediately above the FML, a nominal
12-inch (cell floor) to 18-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils (70%) and dewatered and
cyclone separated tailings sands from the mill (30%). On top of this protective
blanket, a network of 3-inch PVC perforated pipe laterals was installed on
approximately 50-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a 12-inch diameter, inclined HDPE access pipe.
Each run of the 3-inch lateral drainpipe and collector pipe was covered with a 12 to
18-inch thick berm of native granular filter media. At cell closure, leachate head
inside the pipe network will be removed via a submersible pump installed inside the
12-inch diameter inclined access pipe.
2. Existing Tailings Cell Construction Authorized -– tailings disposal in existing Tailings Cells
1, 2, and 3 is authorized by this Ppermit as defined in Table 3 and Part I.D.1, above.
Authorized operation and maximum disposal capacity in each of the existing tailings cells
shall not exceed the levels authorized by the License. Under no circumstances shall the
freeboard be less than three feet, as measured from the top of the FML. Any modification by
the Permittee to any approved engineering design parameter at these existing tailings cells
shall require prior Executive Secretary approval, modification of this Permit, and issuance of
a construction permit.
3. Existing Facility DMT Performance Standards - the Permittee shall operate and maintain
certain mill site facilities and the existing tailings disposal cells to minimize the potential for
wastewater release to groundwater and the environment, including, but not limited to the
following additional DMT compliance measures:
a) DMT Monitoring Wells at Tailings Cell 1 -– at all times the Permittee shall operate and
maintain Tailings Cell 1 to prevent groundwater quality conditions in any nearby
monitoring well from exceeding any Ground Water Compliance Limit established in
Table 2 of this Permit.
b) Tailings Cells 2 and 3 -– including the following performance criteria:
1) Slimes Drain Maximum Allowable Head -– the Permittee shall at all times maintain
the average wastewater recovery head in the slimes drain access pipe to be as low as
reasonably achievable (ALARA) in each tailings disposal cell, in accordance with the
currently approved DMT Monitoring Plan.
2) Monthly Slimes Drain Recovery Test -– the Permittee shall conduct a monthly slimes
drain recovery test at each tailings cell slimes drain that meets the following
minimum requirements:
i. Includes a duration of at least 90-hours, as measured from the time that pumping
ceases, and
Part I
Permit No. UGW370004
9
ii. Achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements, with no change in water
level, as measured to the nearest 0.01 foot.
3) Annual Slimes Drain Compliance - shall be achieved when the average annual
wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to the currently approved DMT Monitoring Plan, meets the conditions in Equation
1, below:
Equation 1:
[Ey + Ey-1 + Ey-2 ] / [Ny + Ny-1 + Ny-2 ] < [Ey-1 + Ey-2 + Ey-3 ] / [ Ny-1 + Ny-2 + Ny-3 ]
Where:
Ey = Sum of all monthly slimes drain tailings fluid elevation measurements that meet the test
performance standards found in Part I.D.3(b)(2), made at the end of each 90-hour recovery test
collected during during the calendar year of interest. Hereafter, these water level measurements are
referred to as slimes drain recovery elevations (SDRE). Pursuant to the currently approved DMT
Monitoring Plan, these recovery tests are to be conducted monthly and the SDRE values reported in
units of feet above mean sea level (amsl).
Ey-1 = Sum of all SDRE measurements made in the year previous to the calendar year of
interest.
Ey-2 = Sum of all SDRE measurements made in the second year previous to the calendar year of
interest.
Ey-3 = Sum of all SDRE measurements made in the third year previous to the calendar year of
interest.
Ny = Total number of SDRE slimes drain 90-hour recovery tests that meet the test performance
standards found in Part I.D.3(b)(2), conducted during the calendar year of interest.
Ny-1 = Total number of SDRE slimes drain 90-hour recovery tests that meet the test performance
standards found in Part I.D.3(b)(2), conducted in the year previous to the calendar year of interest.
Ny-2 = Total number of SDRE slimes drain 90-hour recovery tests that meet the test performance
standards found in Part I.D.3(b)(2), conducted in the second year previous to the calendar year of
interest.
Ny-3 = Total number of SDRE slimes drain 90-hour recovery tests that meet the test performance
standards found in Part I.D.3(b)(2), conducted in the third year previous to the calendar year of
interest.
Prior to January 1, 20112013, the following values for E and N values in Equation 1
shall be based on SDRE data from the following calendar years.

Source of Data By Calendar Year for Equation 1 Variables (right side) Report for
Calendar
Year Ey-1 Ey-2 Ey-3 Ny-1 Ny-2 Ny-3
20082010 20072009 20072009 2009 20072009 20072009 2009
20092011 20082010 20072009 2009 20082010 20072009 2009
20102012 20092011 20082010 2009 20092010201
1
200820101 2009

Part I
Permit No. UGW370004
10
Failure to satisfy conditions in Equation 1 shall constitute DMT failure and non-
compliance with this Permit. For Cell 3, this requirement shall apply after initiation of
de-watering operations.
c) Maximum Tailings Waste Solids Elevation -– upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailings waste solids does not
exceed the top of the FML liner.
d) DMT Monitoring Wells -– at all times the Permittee shall operate and maintain Tailings
Cells 2 and 3 to prevent groundwater quality conditions in any nearby monitoring well
from exceeding any Ground Water Compliance Limit established in Table 2 of this
Permit.
e) Roberts Pond -– the Permittee shall operate this wastewater pond so as to provide a
minimum 2-foot freeboard at all times. Under no circumstances shall the water level in
the pond exceed an elevation of 5,624 feet amsl. In the event that the wastewater
elevation exceeds this maximum level, the Permittee shall remove the excess wastewater
and place it into containment in Tailings Cell 1 within 72- hours of discovery. At the
time of mill site closure, the Permittee shall reclaim and decommission the Roberts Pond
in compliance with a the final Reclamation Plan approved under the License (hereafter
Reclamation Plan).
f) Feedstock Storage Area -– open-air or bulk storage of all feedstock materials at the
facility awaiting mill processing shall be limited to the eastern portion of the mill site
area described in Table 4, below. Storage of feedstock materials at the facility outside
this area, shall meet the requirements in Part I.D.11. At the time of mill site closure, the
Permittee shall reclaim and decommission the Feedstock Storage Area in compliance
with an approved Reclamation Plan.
Table 4. Feedstock Storage Area Coordinates (1)
Corner Northing (ft) Easting (ft)
Northeast 323,595 2,580,925
Southeast 322,140 2,580,920
Southwest 322,140 2,580,420
West 1 322,815 2,580,410
West 2 323,040 2,580,085
West 3 323,120 2,580,085
West 4 323,315 2,580,285
West 5 323,415 2,579,990
Northwest 323,600 2,579,990
Footnote:
1) Approximate State Plane Coordinates beginning from the extreme northeast corner and progressing clockwise around
the feedstock area (from 6/22/01 IUC DUSA Response, Attachment K, Site Topographic Map, Revised June, 2001.)
g) Mill Site Chemical Reagent Storage -– for all chemical reagents stored at existing storage
facilities and held for use in the milling process, the Permittee shall provide secondary
containment to capture and contain all volumes of reagent(s) that might be released at
any individual storage area. Response to spills, cleanup thereof, and required reporting
shall comply with the provisions of the approved Emergency Response Plan as found in
an approved the currently approved Stormwater Best Management Practices
PlanStormwater Best Management Practices Plan, stipulated by Parts I.D.10 and I.H.16
of this Permit. For any new construction of reagent storage facilities, said secondary
Part I
Permit No. UGW370004
11
containment and control shall prevent any contact of the spilled or otherwise released
reagent or product with the ground surface.
4. Best Available Technology Requirements for New Construction -– any construction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facilities shall require submittal of engineering design plans and specifications, and prior
Executive Secretary review and approval. All engineering plans or specifications submitted
shall demonstrate compliance with all Best Available Technology (BAT) requirements
stipulated by the Utah Ground Water Quality Protection Regulations (UAC R317-6). Upon
Executive Secretary approval this Permit may be re-opened and modified to include any
necessary requirements.

5. BAT Design Standards for Tailings Cell 4A - the BAT design standard for Tailings Cell 4A
shall be defined by and construction conform to the requirements of the June 25, 2007
Executive Secretary design approval letter for the relining of former existing Tailings Cell
No. 4A, and as summarized by the engineering drawings, specifications, and description in
Table 5, below:
Table 5. Approved Tailings Cell 4A Engineering Design and Specifications
Engineering Drawings
Name Date Revision
No.
Title
Sheet 1 of 7 June, 2007 Title Sheet
Sheet 2 of 7 June 15, 2007 Rev. 1 Site Plan
Sheet 3 of 7 June 15, 2007 Rev. 1 Base Grading Plan
Sheet 4 of 7 June 15, 2007 Rev. 1 Pipe Layout Plan
Sheet 5 of 7 June 15, 2007 Rev. 1 Lining System Details I
Sheet 6 of 7 June 15, 2007 Rev. 1 Lining System Details II
Sheet 7 of 7 June 15, 2007 Rev. 1 Lining System Details III
Figure 1 August, 2008 - Spillway Splash Pad Anchor
Engineering Specifications
Date Document Title Prepared by
June, 2007 Revised Technical Specifications for the
Construction of Cell 4A Lining System
Geosyntec Consultants
June, 2007 Revised Construction Quality Assurance Plan
for the Construction of Cell 4A Lining System
Geosyntec Consultants
March 27, 2007 Revised Geosynthetic Clay Liner Hydration
Demonstration Work Plan (1)
Geosyntec Consultants
November 27, 2006 Cell Seismic Study (2) MFG Consulting
Scientists and Engineers
October 6, 2006 Calculation of Action Leakage Rate Through
the Leakage Detection System Underlying a
Geomembrane Liner
Geosyntec Consultants
June 22, 2006 Slope Stability Analysis Cell 4A -– Interim
Conditions
Geosyntec Consultants
June 23, 2006 Settlement Evaluation of Berms (2) Geosyntec Consultants
August 22, 2006 Pipe Strength Calculations Geosyntec Consultants
Part I
Permit No. UGW370004
12
September 27, 2007 DMC Cell 4A -– GCL Hydration Geosyntec Consultants
Footnotes:
1) As qualified by conditions found in May 2, 2007 Division of Radiation Control letter.
2) As clarified by February 8, 2007 Division of Radiation Control Round 6 Interrogatory.

Tailings Cell 4A Design and Construction -– approved by the Executive Secretary will
consist of the following major elements:
a) Dikes -– consisting of existing earthen embankments of compacted soil, constructed by
the Permittee between 1989-1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these dikes have
slopes of 3H to 1V. The west dike has an interior slope of 2H to 1V. Width of these
dikes varies, eEach has a minimum crest width of at least 15 feet to support an access
road. Base width also varies from 89-feet on the east dike (with no exterior
embankment), to 211-feet at the west dike.
b) Foundation -– including existing subgrade soils over bedrock materials. Foundation
preparation included excavation and removal of contaminated soils, compaction of
imported soils to a maximum dry density of 90%. Floor of Cell 4A has an average slope
of 1% that grades from the northeast to the southwest corners.
c) Tailings Capacity -– the floor and inside slopes of Cell 4A encompass about 40 acres and
have a maximum capacity of about 1.6 million cubic yards of tailings material storage (as
measured below the required 3-foot freeboard).
d) Liner and Leak Detection Systems -– including the following layers, in descending order:
1) Primary Flexible Membrane Liner (FML) -– consisting of impermeable 60 mil high
density polyethylene (HDPE) membrane that extends across both the entire cell floor
and the inside side-slopes, and is anchored in a trench at the top of the dikes on all
four sides. The primary FML will be in direct physical contact with the tailings
material over most of the Cell 4A floor area. In other locations, the primary FML
will be in contact with the slimes drain collection system (discussed below).
2) Leak Detection System -– includes a permeable HDPE geonet fabric that extends
across the entire area under the primary FML in Cell 4A, and drains to a leak
detection sump in the southwest corner. Access to the leak detection sump is via an
18-inch inside diameter (ID) PVC pipe placed down the inside slope, located between
the primary and secondary FML liners. At its base this pipe will be surrounded with
a gravel filter set in the leak detection sump, having dimensions of 10 feet by 10 feet
by 2 feet deep. In turn, the gravel filter layer will be enclosed in an envelope of
geotextile fabric. The purpose of both the gravel and geotextile fabric is to serve as a
filter.
3) Secondary FML -– consisting of an impermeable 60-mil HDPE membrane found
immediately below the leak detection geonet. Said FML also extends across the
entire Cell 4A floor, up the inside side-slopes and is also anchored in a trench at the
top of all four dikes.
4) Geosynthetic Clay Liner -– consisting of a manufactured geosynthetic clay liner
(GCL) composed of 0.2-inch of low permeability bentonite clay centered and stitched
between two layers of geotextile. Prior to disposal of any wastewater in Cell 4A, the
Part I
Permit No. UGW370004
13
Permittee shall demonstrate that the GCL has achieved a moisture content of at least
50% by weight. This item is a revised requirement per DRC letter to DUSA dated
September 28, 2007.
e) Slimes Drain Collection System -– including a two-part system of strip drains and
perforated collection pipes both installed immediately above the primary FML, as
follows:
1) Horizontal Strip Drain System -– is installed in a herringbone pattern across the floor
of Cell 4A that drain to a “backbone” of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed immediately over the primary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection pipe. A
series of continuous sand bags, filled with filter sand cover the strip drains. The sand
bags are composed of a woven polyester fabric filled with well graded filter sand to
protect the drainage system from plugging.
2) Horizontal Slimes Drain Collection Pipe System -– includes a “backbone” piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC) pipe
found at the downgradient end of the strip drain lines. This pipe is in turn overlain by
a berm of gravel that runs the entire diagonal length of the cell, surrounded by a
geotextile fabric cushion in immediate contact with the primary FML. In turn, the
gravel is overlain by a layer of non-woven geotextile to serve as an additional filter
material. This perforated collection pipe serves as the “backbone” to the slimes drain
system and runs from the far northeast corner downhill to the far southwest corner of
Cell 4A where it joins the slimes drain access pipe.
3) Slimes Drain Access Pipe -– consisting of an 18-inch ID Schedule 40 PVC pipe
placed down the inside slope of Cell 4A at the southwest corner, above the primary
FML. Said pipe then merges with another horizontal pipe of equivalent diameter and
material, where it is enveloped by gravel and woven geotextile that serves as a
cushion to protect the primary FML. A reducer connects the horizontal 18-inch pipe
with the 4-inch SDC pipe. At some future time, a pump will be set in this 18-inch
pipe and used to remove tailings wastewaters for purposes of de-watering the tailings
cell.
f) North Dike Splash Pads -– three 20-foot wide splash pads will be constructed on the
north dike to protect the primary FML from abrasion and scouring by tailings slurry.
These pads will consist of an extra layer of 60 mil HDPE membrane that will be installed
in the anchor trench and placed down the inside slope of Cell 4A, from the top of the
dike, under the inlet pipe, and down the inside slope to a point 5-feet beyond the toe of
the slope.
g) Emergency Spillway -– a concrete lined spillway will be constructed near the western
corner of the north dike to allow emergency runoff from Cell 3 into Cell 4A. This
spillway will be limited to a 6-inch reinforced concrete slab set directly over the primary
FML in a 4-foot deep trapezoidal channel. No other spillway or overflow structure will
be constructed at Cell 4A. All stormwater runoff and tailings wastewaters not retained in
Part I
Permit No. UGW370004
14
Cells 2 and 3, will be managed and contained in Cell 4A, including the Probable
Maximum Precipitation and flood event.
6. BAT Performance Standards for Tailings Cell 4A -– the Permittee shall operate and maintain
Tailings Cell 4A so as to prevent release of wastewater to groundwater and the environment
in accordance with the currently approved Cell 4A BAT Monitoring Operations and
Maintenance Plan., as currently approved by the Executive Secretary, pursuant to Part I.H.19.
At a minimum theThe plan’sse performance standards shall include : the following:
a) Leak Detection System (LDS) Maximum Allowable Daily Head -– the fluid head in the
LDS shall not exceed 1 foot above the lowest point on the lower flexible membrane liner
on the cell floor. For purposes of compliance this elevation will equate to a maximum
distance of 2.28 feet above the LDS transducer. At all times the Permittee shall operate
the LDS pump and transducer in a horizontal position at the lowest point of the LDS
sump floorlower membrane liner.
b) LDS Maximum Allowable Daily Leak Rate -- shall not exceed 24,160 gallons/day.
c) Slimes Drain Monthly and Annual Average Recovery Head Criteria -– after the Permittee
initiates pumping conditions in the slimes drain layer in Cell 4A, the Permittee will
provide: 1) continuous declining fluid heads in the slimes drain layer, in a manner
equivalent to the requirements found in Part I.D.3(b)., and 2) a maximum head of 1.0 feet
in the tailings (as measured from the lowest point of upper flexible membrane liner) in
6.4 years or less.
d) Maximum Weekly Wastewater Level - - under no circumstance shall the freeboard be
less then 3-feet in Cell 4A, as measured from the top of the upper FML.
7. Definition of 11a (2) Waste -– for purposes of this Permit, 11e.(2) waste is defined as: "...
tailings or wastes produced by the extraction or concentration of uranium or thorium from
any ore processed primarily for its source material content", as defined in Section 11e.(2) of
the U.S. Atomic Energy Act of 1954, as amended; which includes other process related
wastes and waste streams described by a March 7, 2003 NRC letter from Paul H. Lohaus to
William J. Sinclair.
8. Closed Cell Performance Requirements -– before reclamation and closure of any tailings
disposal cell, the Permittee shall ensure that the final design, construction, and operation of
the cover system at each tailings cell will comply with all requirements of an approved
Reclamation Plan, and will for a period of not less than 200 years meet the following
minimum performance requirements:
a) Minimize infiltration of precipitation or other surface water into the tailings, including,
but not limited to the radon barrier,., and
b) Prevent the accumulation of leachate head within the tailings waste layer that could rise
above or over-top the maximum FML liner elevation internal to any disposal cell, i.e.
create a “bathtub” effect, and.
c) Ensure that groundwater quality at the compliance monitoring wells does not exceed the
Ground Water Quality Standards or Ground Water Compliance Limits specified in Part
I.C.1 and Table 2 of this Permit.
Part I
Permit No. UGW370004
15
9. Facility Reclamation Requirements -– upon commencement of decommissioning, the
Permittee shall reclaim the mill site and all related facilities, stabilize the tailings cells, and
construct a cover system over the tailings cells in compliance with all engineering design and
specifications in an approved Reclamation Plan. The Executive Secretary reserves the right
to require modifications of the Reclamation Plan for purposes of compliance with the Utah
Ground Water Quality Protection Regulations, including but not limited to containment and
control of contaminants, or discharges, or potential discharges to Waters of the State.
10. Stormwater Management and Spill Control Requirements -- the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices Plan. Said
plan includes the following minimum provisions:
a) Protect groundwater quality or other waters of the state by design, construction, and/or
active operational measures that meet the requirements of the Ground Water Quality
Protection Regulations found in UAC R317-6-6.3(G) and R317-6-6.4(C),
b) Prevent, control and contain spills of stored reagents or other chemicals at the mill site,
c) Cleanup spills of stored reagents or other chemicals at the mill site immediately upon
discovery, and
d) Report reagent spills or other releases at the mill site to the Executive Secretary in
accordance with UAC 19-5-114.
Reconstruction of stormwater management and/or chemical reagent storage facilities,
existing at the time of original Permit issuance, may be required by the Executive Secretary
after occurrence of a major spill or catastrophic failure, pursuant to Part IV.N.3 of this
Permit.
DMT11. BAT Requirements for Feedstock Material Stored Outside the Feedstock Storage
Area -– the Permittee shall store and manage feedstock materials outside the ore storage pad
in accordance with an approved Feedstock Management Plan pursuant to Part I.H.21 of the
permit.with the following minimum performance requirements:
a) Feedstock materials will be stored at all times in water-tight containers, and
b) Aisle ways will be provided at all times to allow visual inspection of each and every
feedstock container, or
c) Each and every feedstock container will be placed inside a water-tight overpack prior to
storage, or
d) Feedstock containers shall be stored on a hardened surface to prevent spillage onto
subsurface soils, and that conforms with the following minimum physical requirements:
1) A storage area composed of a hardened engineered surface of asphalt or concrete, and
2) A storage area designed, constructed, and operated in accordance with engineering
plans and specifications approved in advance by the Executive Secretary. All such
engineering plans or specifications submitted shall demonstrate compliance with Part
I.D.4, and
3) A storage area that provides containment berms to control stormwater run-on and
run-off, and
Part I
Permit No. UGW370004
16
4) Stormwater drainage works approved in advance by the Executive Secretary, or
5) Other storage facilities and means approved in advance by the Executive Secretary.

E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING -- beginning with
the effective date and lasting through the term of this Ppermit or as stated in an approved closure
plan, the Permittee shall sample groundwater monitoring wells, tailing cell wastewaters, seeps
and springs, monitor groundwater levels, monitor water levels of process solutions, and monitor
and keep records of the operation of the facility, as follows:
1. Routine Groundwater Compliance Monitoring -– the Permittee shall monitor upgradient,
lateral gradient, and downgradient ground water monitoring wells completed in the shallow
aquifer in the vicinity of all potential discharge sources that could affect local groundwater
conditions at the facility, as follows:
a) Ground Water Monitoring Quality Assurance Plan -– all groundwater monitoring and
analysis performed under this Permit shall be conducted in accordance with a Quality
Assurance Plan (QAP) currently approved by the Executive Secretary. Any non-
conformance with QAP requirements in a given quarterly ground water monitoring
period will be corrected and reported to the Executive Secretary on or before submittal of
the next quarterly ground water monitoring report pursuant to Part I.F.1.
b) Quarterly Monitoring -– the Permittee shall monitor on a quarterly basis all monitoring
wells listed in Table 2 of this Permit where local groundwater average linear velocity has
been found by the Executive Secretary to be equal to or greater than 10 feet/year. For
purposes of this Permit, quarterly monitoring is required at the following wells:
1) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-11, MW-14, MW-24, MW-25, MW-26
(formerly TW4-15), MW-30, and MW-31.MW-32 (formerly TW4-17).
c) Semi-annual Monitoring -– the Permittee shall monitor on a semi-annual basis all
monitoring wells listed in Table 2 of this Permit where local groundwater average linear
velocity has been found by the Executive Secretary to be less than 10 feet/year. For
purposes of this Permit, semi-annual monitoring is required at the following wells:
1) Upgradient Wells: MW-1, MW-18, MW-19, and MW-27,.
2) Lateral or Downgradient Wells: MW-2, MW-3, MW-3A, MW-5, MW-12, MW-15,
and MW-17, MW-23, MW-28, MW-29, and MW-32 (formerly TW4-17).
d) Compliance Monitoring Parameters -- all groundwater samples collected shall be
analyzed for the following parameters:
1) Field Parameters - –depth to groundwater, pH, temperature, and specific
conductance, and redox potential (Eh).
1)
2) 2) Laboratory Parameters
Part I
Permit No. UGW370004
17
i. GWCL Parameters -- all contaminants specified in Table 2.
ii. General Inorganics -– chloride, sulfate, carbonate, bicarbonate, sodium,
potassium, magnesium, calcium, and total anions and cations.
e) Special Provisions for Groundwater Monitoring -– the Permittee shall ensure that all
groundwater monitoring conducted and reported complies with the following
requirements:
1) Depth to Groundwater Measurements -– shall always be made to the nearest 0.01
foot.
2) Minimum Detection Limits -– all groundwater quality analyses reported shall have a
minimum detection limit or reporting limit that is less than its respective Ground
Water Compliance Limit concentration defined in Table 2.
3) Gross Alpha Counting Variance -– Aall gross alpha analysis shall be reported with an
error term. All gross alpha analysis reported with an activity equal to or greater than
the GWCL, shall have a counting variance that is equal to or less than 20% of the
reported activity concentration. An error term may be greater than 20% of the
reported activity concentration when the sum of the activity concentration and error
term is less than or equal to the GWCL.
4) All equipment used for purging and sampling of ground water shall be made of inert
materials.
2. Groundwater Monitoring: Monitoring Wells MW-20 and MW-22 -– Starting with the 1st
Quarter 2008 groundwater event the Permittee shall implement a quarterly groundwater
sampling program. Said sampling shall comply with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part I.E.1.
b) Well monitoring procedure requirements of Part I.E.5.
After completion of eight (8) consecutive quarters of groundwater sampling and analysis of
MW-20 and MW-22, the Permittee shall submit a Background rReport that will include:
1) Data preparation and statistical analysis of groundwater quality data, including
treatment of non-detectable values, statistical methods. These statistics shall be
calculated using the Decision Tree/Flowchart used for the previous Background
Reports that was conditionally approved by the DRC on August 24, 2007.
2) Aquifer test results to determine local hydraulic conductivity and other aquifer
properties at wells MW-20 and MW-22.
3) Average linear groundwater velocity calculated for MW-20 and MW-22, based on
well specific hydraulic conductivity, hydraulic gradient, and effective aquifer
porosity.
1) the groundwater quality data, and 2) calculated groundwater velocities in the vicinity of
MW-20 and MW-22. The said report shall be submitted by March 1, 2010. After review of
this report the Executive Secretary will evaluate if wells MW-20 and MW-22 should be
added as POC wells re-open the Permit, and adjust the sampling frequency in accordance
with criteria found in Part I.E.1(b) or (c). If it is determined that wells MW-20 and MW-22
should be added as POC wells, the Executive Secretary will re-open this Permit and establish
Part I
Permit No. UGW370004
18
Groundwater Compliance Limits in Table 2 for wells MW-20 and MW-22.

3. Groundwater Head Monitoring -– on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.1, the Permittee shall measure depth to
groundwater in the following wells and/or piezometers:
a) Point of Compliance Wells -– identified in Table 2 and Part I.E.1 of this Permit,.
b) Piezometers -– P-1, P-2, P-3, P-4, P-5.
c) Existing Monitoring Wells -– MW-20 and MW-22.
d) Contaminant Investigation Wells -: any well required by the Executive Secretary as a
part of a contaminant investigation or groundwater corrective action, and.
e) Any other wells or piezometers required by the Executive Secretary.
4. Groundwater Monitoring Well Design and Construction Criteria -– all new groundwater
monitoring wells installed at the facility shall comply with the following design and
construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other potential
origin of groundwater pollution,.
b) Screened and completed in the shallow aquifer,.
c) Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including the EPA
RCRA Ground Water Monitoring Technical Enforcement Guidance Document, 1986,
OSWER-9950.1..
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
5. Monitoring Procedures for Wells -– beginning with the date of Permit issuance, all
monitoring shall be conducted by the Permittee in conformance with the following
procedures:
a) Sampling -- grab samples shall be taken of the ground water, only after adequate removal
or purging of standing water within the well casing has been performed.
b) Sampling Plan -– all sampling shall be conducted to ensure collection of representative
samples, and reliability and validity of groundwater monitoring data.
c) Laboratory Approval -- all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
d) Damage to Monitoring Wells -- if any monitor well is damaged or is otherwise rendered
inadequate for its intended purpose, the Permittee shall notify the Executive Secretary in
writing within five calendar days of discovery.
e) Field Monitoring Equipment Calibration and Records -– immediately prior to each
monitoring event, the Permittee shall calibrate all field monitoring equipment in
accordance with the respective manufacturer's procedures and guidelines. The Permittee
shall make and preserve on-site written records of such equipment calibration in
Part I
Permit No. UGW370004
19
accordance with Part II.G and H of this Permit. Said records shall identify the
manufacturer's and model number of each piece of field equipment used and calibration.
6. White Mesa Seeps and Springs Monitoring -– the Permittee shall conduct annual monitoring
of all seeps and springs identified in the currently approved Sampling Plan for Seeps and
Springs in the Vicinity of the White Mesa Uranium Mill. Said monitoring shall include, but
is not limited to:
a. Field Measurements -– including: pH, temperature, and specific conductivity,
Water Quality Sampling and Analysis –- the Permittee shall collect grab samples and
perform laboratory analysis of all :
b. Wwater quality parameters identified in Table 2 of this Permit, and
Semi-volatile compounds identified in EPA Method 8270.
c. Certified Laboratory Analysis –- all laboratory analysis will be conducted by a Utah
certified laboratory.
d. Analytical Methods –- all laboratory analysis shall be conducted using analytical methods
listed in the currently approved QAP pursuant to Part I.E.1 of this Permit.
Minimum Detection Limits -– all seeps or springs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal to than the
respective:
e. Groundthe respective:
1) Ground Water Quality Standards Compliance Limit concentrations defined in Table
2 of this Permit, and
2) For TDS, Sulfate, and Chloride, the Minimum Detection Limit for those constituents
for seeps and springs monitoring will be as follows: 10 mg/L, 1 mg/L, and 1 mg/L,
respectively
f. Quality Control Samples -– the Permittee will conduct quality control (QC) sampling and
analysis as a part of all seeps and springs sampling, in accordance with the requirements
of Section 4.3 of the currently approved QAP; pursuant to Part I.E.1 of this Permit. Said
QC samples shall include, but are not limited to: trip blanks, duplicate samples, and
equipment rinse blanks.
g. Prior Notification -– at least 15 calendar days before any fieldwork or water quality
sample collection, the Permittee shall provide written notice to allow the Executive
Secretary to observe or split sample any or all seeps or springs.
h. Sample Omission -– in the course of each annual sampling event, the Permittee shall
sample and analyze all six (6) seeps and springs identified in Table 1 of the currently
approved Sampling Plan for Seeps and Springs in the Vicinity of the White Mesa
Uranium Mill. The Permittee shall not omit sampling of any seep or spring during said
annual event, without prior written approval from the Executive Secretary.

7. DMT Performance Standards Monitoring -- the Permittee shall perform technology
performance monitoring in accordance with the currently approved DMT Monitoring Plan to
Part I
Permit No. UGW370004
20
determine if DMT is effective in minimizing and controlling the release of contaminants
pursuant to the provisions of Parts I.D.1 and I.D.3 of this Permit, including, but not limited to
the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells 1 and 3 -– the Permittee
shall monitor and record weekly the elevation of wastewater in Tailings Cells 1 and 3 to
ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the License. Said measurements shall be made from a wastewater
level gauge or elevation survey to the nearest 0.01 foot.
b) Monthly Slimes Drain Water Level Monitoring: Cells 2 and 3 -– the Permittee shall
monitor and record monthly the depth to wastewater in the slimes drain access pipes as
described in Part I.D.3 of this Permit and the currently approved DMT Monitoring Plan
at Tailings Cells 2 and 3 to determine the 90-hour fluid recovery head. For purposes of
said monitoring, the Permittee shall at each tailings cell:
1) Perform at least 12 separate slimes drain recovery tests at each disposal cell in each
calendar year that meet the requirements of Part I.D.3,
2) 2) Designate, operate, maintain, and preserve one water level measuring point at the
centerline of the slimes drain access pipe that has been surveyed and certified by a
Utah licensed engineer or land surveyor,.
b.3) 23Make all slimes drain recovery head test (depth to fluid) measurements from
the same designated water level measuring point, and, and
c.4) 34Record and report all fluid depth measurements to the nearest 0.01 foot.
5) For Cell 3 these requirements shall apply upon initiation of tailings de-watering
operations.
c) Weekly Wastewater Level Monitoring: Roberts Pond -– the Permittee shall monitor and
record weekly wastewater levels at the Roberts Pond to determine compliance with the
DMT operations standards in Part I.D.3. Said measurements shall be made in accordance
to the currently approved DMT Monitoring Plan.
c)d) Weekly Feedstock Storage Area Inspection -– the Permittee shall conduct weekly
inspections of develop a Standard Operating Procedure for the License and inspect the all
Ffeedstock Sstorage Areas to:

i.1) Confirm the bulk feedstock materials are maintained within the approved Feedstock
Storage Area defined by Table 4, and

ii.2) Verify that all alternate feedstock materials located outside the Feedstock Area defined
in Table 4, are maintained within water-tight containersare stored in accordance with the
requirements found in Part I.D.11.
e) Feedstock Material Stored Outside the Feedstock Storage Area Maintenance
PlanInspections
1) -Weekly Inspection - the Permittee will conduct weekly inspections to verify that
Part I
Permit No. UGW370004
21
each feed material container complies with the requirements of Part I.D.11.
2) Hardened Surface Storage Area -– in the event the Permittee constructs a hardened
surface storage area for feed materials, pursuant to Part I.D.11, prior Executive
Secretary approval will be secured for the following:

i. Engineering Design and Specifications - in accordance with the requirements of
Part I.D.4, and
ii. Operation and Maintenance Plan.
f) Inspections of Tailing Cell and Pond Liner Systems - the Permittee shall inspect the liner
system at Tailing Cells 1, 2, and 3 on a daily basis pursuant to the requirements of
Sections 2.1 and 2.2 of the currently approved DMT Monitoring Plan. The Permittee
shall conduct visual inspections at the Roberts Pond on a weekly basis. If a discrepancy
is identified during a liner system inspection, the Permittee shall immediately implement
the currently approved Liner Maintenance Provisions.
a)8. Cell 4A BAT Performance Standards Monitoring -– in accordance with the currently
approved Cell 4A BAT Monitoring Operations and Maintenance Planafter Executive
Secretary approval of the Tailings Cell 4A Operations and Maintenance Plan, required by
Part I.H.19 of this Permit, the Permittee shall immediately implement all monitoring and
recordkeeping requirements therein. At a minimum, saidThe Cell 4A BAT monitoring
includes the shalfollowingl include:
a.a) Weekly Leak Detection System (LDS) Monitoring -– including:
1) Leak Detection System Pumping and Monitoring Equipment -– the Permittee shall
provide continuous operation of the leak detection system pumping and monitoring
equipment, including, but not limited to, the submersible pump, pump controller,
head monitoring, and flow meter equipment approved by the Executive Secretary.
Failure of any pumping or monitoring equipment not repaired and made fully
operational within 24-hours of discovery shall constitute failure of BAT and a
violation of this Permit.
2) Maximum Allowable Head -– the Permittee shall measure the fluid head above the
lowest point on the secondary flexible membrane by the use of procedures and
equipment approved by the Executive Secretary. Under no circumstance shall fluid
head in the leak detection system sump exceed a 1-foot level above the lowest point
in the lower flexible membrane liner on the cell floor. The occurrence of leak
detection system fluids above this 1-foot limit shall constitute failure of BAT
Technology and a violation of this PermitFor purposes of compliance monitoring this
1-foot distance shall equate to 2.28 feet above the leak detection system transducer.
3) Maximum Allowable Daily LDS Flow Rates - the Permittee shall measure the
volume of all fluids pumped from the LDS. Under no circumstances shall the
average daily LDS flow volume exceed 24,160 gallons/day.
4) 3-foot Minimum Vertical Freeboard Criteria -– the Permittee shall operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard in
Tailings Cell 4A. Said measurements shall be made to the nearest 0.1 foot.
Part I
Permit No. UGW370004
22
b.b) Slimes Drain Recovery Head Monitoring -– immediately after the Permittee initiates
pumping conditions in the Tailings Cell 4A slimes drain system, monthly recovery head
tests and fluid level measurements will be made in accordance with the requirements of
Parts I.D.3 and I.E.7(b) of this Permit and any plan approved by the Executive Secretary.
9. On-site Chemicals Inventory -– the Permittee shall monitor and maintain a current inventory
of all chemicals used at the facility at rates equal to or greater than 100 kg/yr. Said inventory
shall be maintained on-site, and shall include, but is not limited to:
a. Identification of chemicals used in the milling process and the on-site laboratory, , and
b. Determination of volume and mass of each raw chemical currently held in storage at the
facility.
10. Tailings Cell Wastewater Quality Monitoring -– on an annual basis, the Permittee shall
collect wastewater quality samples from each wastewater source at each tailings cell at the
facility, including, but not limited to:
a. Three surface impounded wastewaters locations at Tailings Cells 1, 3, and 4A, and
b. One slimes drain wastewaters access pipe at Tailings Cells 2, 3, and 4A. For Cells 3
and 4A, this requirement shall apply immediately after initiation of de-watering
operations at these cells, and
c. One leak detection wastewater access pipe at Tailings Cell 4A.
All such sampling shall be conducted in August of each calendar year in compliance with
the currently approved White Mesa Uranium Mill Tailing and Slimes Drain Sampling
Program Tailings Cell Wastewater Quality Sampling Plan required by Part I.H.5 of this
Permit. . Said annual monitoring shall include, but is not limited to:
a. Field Measurements -– including: pH, temperature, and specific conductivity,
b. Water Quality Sampling and Analysis -– the Permittee shall collect grab samples and
perform laboratory analysis of all:
1) Water quality parameters identified in Table 2 of this Permit, and
2) Semi-volatile compounds identified in EPA Method 8270D.
c. Certified Laboratory Analysis -– all laboratory analysis will be conducted by a Utah
certified laboratory.
d. Analytical Methods -– all laboratory analysis shall be conducted using analytical methods
listed in the currently approved QAP pursuant to Part I.E.1 of this Permit.
e. Minimum Detection Limits -– all water quality analyses reported shall have a minimum
detection limit or reporting limit that is less than or equal to than the respective:
1) Ground Water Quality Standards concentrations defined in Table 2 of this Permit,
2) For TDS, Sulfate, and Chloride, the Minimum Detection Limit for those constituents
for Tailing Cell wastewater monitoring will be as follows: 1,000 mg/L, 1,000 mg/L,
and 1 mg/L, respectively, and
3) Lower limits of quantitation for groundwater for semi-volatile organic compounds
listed in Table 2 of EPA Method 8270D, Revision 4, dated February, 2007.
Part I
Permit No. UGW370004
23
f. Quality Control Samples -– the Permittee will conduct quality control (QC) sampling and
analysis as a part of all tailings wastewater sampling, in accordance with the
requirements of Section 4.3 of the currently approved QAP; pursuant to Part I.E.1 of this
Permit. Said QC samples shall include, but are not limited to: trip blanks, duplicate
samples, and equipment rinse blanks.
g. Prior Notification -– at least 30 calendar days before any fieldwork or water quality
sample collection, the Permittee shall provide written notice to allow the Executive
Secretary to observe or split sample any tailings cell, slimes drain, or leak detection
wastewaters.
h. Sample Omission -– in the course of each annual sampling event, the Permittee shall
sample and analyze all tailings cell, slimes drain, and leak detection wastewater sources
identified in the currently approved Tailings and Slimes Drain Sampling Program (pp. 1-
3), or as required by this Permit, whichever is greater. The Permittee shall not omit
sampling of any of tailings cell wastewater source during said annual event, without prior
written approval from the Executive Secretary.
The Permittee shall also provide at least a 30 calendar -day notice in advance of the annual
sampling event, so as to allow the Executive Secretary to collect split samples of the various
tailings cells wastewater sources.
11. Groundwater Monitoring Modifications -– before any modification of groundwater
monitoring or analysis procedures, methods, or equipment, the Permittee must obtain prior
written approval from the Executive Secretary.
F. REPORTING REQUIREMENTS - The following reporting procedures for routine and compliance
reports must be met.
1. Routine Groundwater Monitoring Reports - the Permittee shall submit quarterly monitoring
reports of field and laboratory analyses of all well monitoring and samples described in Parts
I.E.1, I.E.2, I.E.3, and I.E.5, and I.E.7 of this Permit for Executive Secretary review and
approval. Reports shall be submitted according to the following schedule:

Table 6. Groundwater Monitoring Reporting Schedule
Quarter Period Due Date
First January -– March June 1
Second April -– June September 1
Third July -– September December 1
Fourth October -– December March 1
Failure to submit the reports by the due date shall be deemed as noncompliance with this
Ppermit. Said monitoring reports shall include, but are not limited to, the following
minimum information:
a) Field Data Sheets -– or copies thereof that provide the following: well name, date and
time of well purging, date and time of well sampling, type and condition of well pump,
Part I
Permit No. UGW370004
24
depth to groundwater before purging and sampling, calculated well casing volume,
volume of water purged before sampling, volume of water collected for analysis, types of
sample containers and preservatives.
b) Laboratory Results -– or copies thereof that provide the following: date and time
sampled, date received by laboratory, and for each parameter analyzed, the following
information: laboratory result or concentration, units of measurement, minimum
detection limit or reporting limit, analytical method, date of analysis, counting error for
radiologic analyses, total cations and anions for inorganic analysis.
c) Water Table Contour Map -– which provides the location and identity of all wells
sampled that quarter, the measured groundwater elevation at each well measured in feet
above mean sea level, and isocontour lines to delineate groundwater flow directions
observed during the quarterly sampling event.
d) Quality Assurance Evaluation and Data Validation -– including a written description and
findings of all quality assurance and data validation efforts conducted by the Permittee in
compliance with the currently approved Groundwater Monitoring Quality Assurance
Plan. Said report shall verify the accuracy and reliability of the groundwater quality
compliance data, after evaluation of sample collection techniques and equipment, sample
handling and preservation, analytical methods used, etc.
e) Non-conformance disclosure - with each quarterly ground water monitoring report the
Permittee shall fully and completely disclose all non-conformance with requirements of
the currently approved QAP, mandated by Part I.E.1(a).
f) Electronic Data Files and Format -– in addition to written results required for every
sampling report, the Permittee shall provide an electronic copy of all laboratory results
for groundwater quality monitoring conducted. Said electronic files shall consist of
Comma Separated Values (CSV) format, or as otherwise approved by the Executive
Secretary.
g) Time Concentration Plots - with each quarterly groundwater monitoring report the
Permittee shall submit time concentration plots for each monitoring well for the
following constituents: chloride, fluoride, sulfate, and uranium.
2. Routine DMT Performance Standards Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT performance standards monitoring required by Parts
I.D.3 and I.E.7 of this Permit. DMT monitoring shall be conducted in compliance with this
Permit and the currently approved DMT Monitoring Plan. Said monitoring reports and
results shall be submitted for Executive Secretary approval on the schedule provided in Table
6, above.
3. Routine Cell 4A BAT Performance Standards Monitoring Reports - the Permittee shall
provide quarterly monitoring reports of all BAT performance standards monitoring required
by Part I E.8 of this Permit. BAT Monitoring at Cell 4A shall be conducted in compliance
with the currently approved BAT Monitoring Operations and Maintenance Plana plan
approved by the Executive Secretary pursuant to Part I.H.19. Said monitoring report and
results shall be submitted for Executive Secretary approval on the schedule provided in Table
6 above. At a minimum, reporting of BAT monitoring for Cell 4A will include:
Part I
Permit No. UGW370004
25
a) LDS Monitoring -– including:
1) Report on the operational status of the LDS pumping and monitoring equipment
during the quarter, including identification of any intervals of non-operational status
and repairs.
2) Measurement of the weekly fluid head at the lowest point of the secondary
membrane.
3) Measurement of the volume of all fluids pumped from the LDS.
b) Measurement of the weekly wastewater fluids elevation in the Cell 4A to determine
freeboard.
c) Slimes Drain Recovery Head Monitoring as per the requirements of Parts I.D.6) and
I.E.8(b).
4. DMT and BAT Performance Upset Reports -– the Permittee shall report any non-compliance
with the DMT or BAT performance criteria of Part I.D in accordance with the requirements
of Part I.G.3 of this Permit.
5. Other Information - when the Permittee becomes aware of a failure to submit any relevant
facts in the permit application or submittal of incorrect information in a permit application or
in any report to the Executive Secretary, the Permittee shall submit such facts or information
within 10 calendar days of discovery.
6. Groundwater Monitoring Well As-Built Reports -– as-built reports for new groundwater
monitoring wells shall be submitted for Executive Secretary approval within 60 calendar
days of well completion, and at a minimum will include the following information:
a) Geologic Logs -– that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs shall be prepared by a
Professional Geologist licensed by the State of Utah, or otherwise approved beforehand
by the Executive Secretary.
b) Well Completion Diagram -– that detail all physical attributes of the well construction,
including:
1) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties of well casing and screen, including
well screen slot size,
3) Depth intervals, type and physical properties of annular filterpack and seal materials
used,
4) Design, type, diameter, and construction of protective surface casing, and
5) Survey coordinates prepared by a State of Utah licensed engineer or land surveyor,
including horizontal coordinates and elevation of water level measuring point, as
measured to the nearest 0.01 foot.
c) Aquifer Permeability Data -– including field data, data analysis, and interpretation of slug
Part I
Permit No. UGW370004
26
test, aquifer pump test or other hydraulic analysis to determine local aquifer hydraulic
conductivity in each well.
7. White Mesa Seeps and Springs Monitoring Reports - a seeps and springs monitoring report
shall be submitted for Executive Secretary review and approval with the 3rd Quarter Routine
Groundwater Monitoring Report due on December 1, of each calendar year. Said report shall
include, but is not limited to:after approval of the work plan and report required by Part
I.H.8, this Permit may be modified to require annual monitoring and reporting of selected
seeps or springs on White Mesa.
a) Field Measurement Results and Worksheets - for each sample collected that comply
with the requirements of Part I.F.1(a) of this Permit,
b) Laboratory Results - for each sample collected that comply with the requirements of Part
I.F.1(b) of this Permit,
c) Water Table Contour Map - that includes groundwater elevations for each well at the
facility and the elevations of the phreatic surfaces observed at each of the seeps and
springs sampled. The contour map will include all water level data measurements from
seeps, springs, and monitoring wells at the site from the 3rd Quarter Routine Groundwater
Monitoring event of each year. The contour map shall be at a map scale, such that, all
seeps and springs listed in the approved Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill and the monitoring wells on site may be seen
on one map,
d) Data Evaluation - and interpretation of all groundwater quality data collected,
e) Quality Assurance Evaluation and Data Validation - for the seeps and springs water
quality data that meets the requirements of Part I.F.1(d),
f) Electronic Data Files and Format - that meet the requirements of Part I.F.1(e) of this
Permit, and
g) Survey data for the seeps and springs shall be based on an elevation survey, conducted
under the direction of and certified by a Utah licensed professional engineer or land
surveyor. The survey will include State Plan Coordinates (northings and eastings) and
vertical elevations. The surveyed coordinates and elevations of the seeps and springs
shall be within 1 foot of the highest point of the saturated seepage face on the day of the
survey. This survey data must be obtained before any samples are collected.
8. Chemicals Inventory Report -– at the time of Permit renewal the Permittee shall submit a
report to update the facilities chemical inventory report required by Part I.H.19. Said report
shall provide all inventory information gathered pursuant to Part I.E.9.
9. Tailings Cell Wastewater Quality Reports -– all annual wastewater quality sampling and
analysis required by Part I.E.10 shall be reported to the Executive Secretary with the 3rd
Quarter groundwater quality report due on December 1, of each calendar year. Said report
shall include:
a) Data evaluation and interpretation of all wastewater quality samples collected,
b) All information required by Part I.F.1(a), (b), (d), and (e) of this Permit, and
Part I
Permit No. UGW370004
27
c) For slimes drain samples, the Permittee shall report depth to wastewater measurements
from the water level measurement point. Said wastewater level shall be measured
immediately before sample collection.
a)
10. Revised Hydrogeologic Report - pursuant to Part IV.D of this Permit, and at least 180
calendar days prior to Permit expiration, the Permittee shall submit for Executive Secretary
approval a revised hydrogeologic report for the facility and surrounding area. Said report
shall provide a comprehensive update and evaluation of:
a) Local hydrogeologic conditions in the shallow aquifer, including, but not limited to:
local geologic conditions; time relationships and distribution of shallow aquifer head
measurements from facility wells and piezometers; local groundwater flow directions;
and distribution of aquifer permeability and average linear groundwater velocity across
the site, and
b) Well specific groundwater quality conditions measured at facility monitoring wells for all
groundwater monitoring parameters required by this Permit, including, but not limited to:
temporal contaminant concentrations and trends from each monitoring well; statistical
tests for normality of each contaminant and well, including univariate or equivalent tests;
calculation of the mean concentration and standard deviation for each well and
contaminant.
11. Annual Slimes Drain Recovery Head Report -– on or before March 1 of each year the
Permittee shall submit for Executive Secretary approval an annual slimes drain recovery head
report for Tailings Cells 2 and 3. Said report shall conform to the requirements of Part
I.D.3(b), I.E.7(b), and II.G of this Permit, and:
a) Provide the individual monthly slimes drain recovery head monitoring data for the
previous calendar year, including , but not limited to: date and time for the start and end
of recovery test, initial water level, final depth to stable water level and equivalent
recovery water level elevation.
b) Calculate the average slimes drain recovery head for the previous calendar year.

c) Include a time series chart to show trends of the monthly recovery water level elevations
at each slimes drain.
d) Include the results of a quality assurance evaluation and data validation. Said
examination shall provide written descriptions and findings that:
1) 1) Evaluate all data collected, data collection methods, and all related calculations
required by this Permit, and
2) 2) Verify the accuracy and reliability of both the data and calculations reported.
ce) Demonstrate compliance status with the requirements of Part I.D.3(b) and I.E.7(b) of this
Permit.
G. OUT OF COMPLIANCE STATUS
Part I
Permit No. UGW370004
28
1. Accelerated Monitoring Status - is required if the concentration of a pollutant in any
compliance monitoring sample exceeds a GWCL in Table 2 of the Permit; the facility shall
then:
a) Notify the Executive Secretary in writing within 30 calendar days of receipt of data,; and
b) Immediately initiate accelerated sampling of the pollutant as follows:
1) Quarterly Baseline Monitoring Wells -– for wells defined by Part I.E.1(b) the
Permittee shall initiate monthly monitoring,.
2) Semi-annual Baseline Monitoring Wells -– for wells defined by Part I.E.1(c) the
Permittee shall initiate quarterly monitoring..
Said accelerated monitoring shall continue at the frequencies defined above until the
compliance status of the facility can be determined by the Executive Secretary.
2. Violation of Permit Limits - out-of-compliance status exists when :
a) Tthe concentration of a pollutant in two consecutive samples from a compliance monitoring
point exceeds:
a) A GWCL in Table 2 of this Permit, and;, or
1)The reported ground water concentration for that pollutant exceeds the mean by two
standard deviations. For purposes of this Permit, the standard deviation and mean will be
calculated using values for the ground water pollutant at each individual compliance
monitoring point or well; or; or
b) The concentration value of any pollutant in two or more consecutive samples is
statistically significantly higher than the applicable Ppermit limit. The statistical
significance shall be determined using the statistical methods described in Statistical
Methods for Evaluating Ground Water Monitoring Data from Hazardous Waste
Facilities, Vol. 53, No. 196 of the Federal Register, Oct. 11, 1988.
3. Failure to Maintain DMT or BAT Required by Permit
a) Permittee to Provide Information - in the event that the Permittee fails to maintain DMT
or BAT or otherwise fails to meet DMT or BAT standards as required by the Ppermit, the
Permittee shall submit to the Executive Secretary a notification and description of the
failure according to R317-6-6.16(C)(1). Notification shall be given orally within 24-
hours of the Permittee's discovery of the failure of DMT or BAT, and shall be followed
up by written notification, including the information necessary to make a determination
under R317-6-6.16(C)(2), within five calendar days of the Permittee's discovery of the
failure of best available technology.
b) The Executive Secretary shall use the information provided under R317-6-6.16.C(1) and
any additional information provided by the Permittee to determine whether to initiate a
compliance action against the Permittee for violation of Ppermit conditions. A
compliance action shall not be initiated, if the Executive Secretary determines that the
Permittee has met the standards for an affirmative defense, as specified in R317-6-
6.16(C)(3).
c) Affirmative Defense - in the event a compliance action is initiated against the Permittee
Part I
Permit No. UGW370004
29
for violation of Ppermit conditions relating to best available technology or DMT, the
Permittee may affirmatively defend against that action by demonstrating the following:
1) The Permittee submitted notification according to R317-6-6.13,;
2) The failure was not intentional or caused by the Permittee's negligence, either in
action or in failure to act,
3) The Permittee has taken adequate measures to meet Ppermit conditions in a timely
manner or has submitted to the Executive Secretary, for the Executive Secretary's
approval, an adequate plan and schedule for meeting Ppermit conditions,; and; and
4) The provisions of UCA 19-5-107 have not been violated.
4. Facility Out of Compliance Status -– if the facility is out of compliance, the following is
required:
a) The Permittee shall notify the Executive Secretary of the out of compliance status within
24- hours after detection of that status, followed by a written notice within 5 calendar
days of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part I.G.1, unless the
Executive Secretary determines that other periodic sampling is appropriate, until the
facility is brought into compliance.
c) The Permittee shall prepare and submit within 30 calendar days to the Executive
Secretary a plan and a time schedule for assessment of the sources, extent and potential
dispersion of the contamination, and an evaluation of potential remedial action to restore
and maintain ground water quality to insure that Ppermit limits will not be exceeded at
the compliance monitoring point and that DMT or BAT will be reestablished.
d) The Executive Secretary may require immediate implementation of the currently
approved contingency plan to be submitted pursuant to Part I.H.15 , in order to regain
and maintain compliance with the Ppermit limit standards at the compliance monitoring
point or to reestablish DMT or BAT as defined in the Permit.
e) Where it is infeasible to reestablish DMT or BAT as defined in the Ppermit, the Permittee may
propose an alternative DMT or BAT for approval by the Executive Secretary.

H. COMPLIANCE SCHEDULE REQUIREMENTS. The Permittee will comply with the schedules as
described and summarized below:
1.Installation of New Groundwater Monitoring Wells – within 30 days of issuance of this Permit,
the Permittee shall submit a plan for the installation of new monitoring wells for Executive
Secretary approval. Said plan shall include the following information:
a)Tailings Cell 1 DMT Wells –one (1) hydraulically upgradient well and two (2)
hydraulically downgradient wells that comply with the provisions of Part I.E.3 of this
Permit, and the well location map submitted by the Permittee on April 16, 2004.
b)New Compliance Monitoring Wells for Tailings Cells 2 and 3 –an adequate number and
Part I
Permit No. UGW370004
30
location of monitoring wells to ensure:
1)Early detection of tailings cell contamination of shallow groundwater from Tailings
Cells 2 and 3. The number and location of these wells shall conform to the
provisions of Part I.E.4, and the well location map submitted by the Permittee on
April 16, 2004, and
2)Discrete monitoring of each individual disposal cell. For Cell 2 this shall mean
installation of three (3) monitoring wells on the shared dike between Cells 2 and 3, as
per the well location map submitted by the Permittee on April 16, 2004.
c)New well design and construction details that comply with Part I.E.4 of this Permit.
2.Revised Hydrogeologic Report - the revised hydrogeologic report submitted for Executive
Secretary approval shall include:
a)Monitoring well as built report for each well that complies with the information
requirements of Part I.F.6.
b)Hydrogeologic data from each new well, including but not limited to: depth and elevation
of groundwater level, and aquifer test results to determine local permeability.
c)Comprehensive hydrogeologic evaluation of the facility that includes both new data
collected during or as a result of the new monitoring well installation required by Part
I.H.1, and all existing hydrogeologic information available for the site.
d)Aquifer test results to determine local hydraulic conductivity and other aquifer properties
at existing well MW-32 (formerly TW4-17).
e)Average linear groundwater velocity calculated for each well, based on well specific
hydraulic conductivity, hydraulic gradient, and effective aquifer porosity.
If after review of the revised hydrogeologic report, the Executive Secretary determines that
additional information is required, the Permittee shall provide all requested information,
resolve all issues identified, and re-submit the report for Executive Secretary review and
approval within a timeframe approved by the Executive Secretary.
If after review of this report, the Executive Secretary determines that additional monitoring
wells are required to adequately monitor the facility, the Permit will be re-opened and
modified to require all necessary improvements pursuant to Part IV.N.3.
c)Background Ground Water Quality Report: Existing Wells –the content of the Background
Ground Water Quality Report for all existing monitoring wells at the facility shall include:
a.All available groundwater quality data for all existing monitoring wells at the facility.
b.A quality assurance evaluation and data validation of the existing and historic on-site
groundwater quality data that on a well-by-well and contaminant specific basis:
1)Identifies, justifies, and/or culls any zero concentration values reported,
2)Determines the adequacy of minimum detection limits used, particularly with respect to the
corresponding GWQS for each contaminant,
3)Adequately addresses any special statistical needs for management of data sets with a large
proportion of non-detectable values,
Part I
Permit No. UGW370004
31
4)Determines the adequacy of laboratory and analytical methods used,
5)Determines the consistency of laboratory units of reporting,
6)Evaluates and justifies internal consistency between specific and composite types of
groundwater quality analysis (e.g. major ions and TDS),
7)Identifies and justifies any groundwater concentration outliers,
8)Tests the selected groundwater quality data for each individual well and contaminant for
normality, and justifies the use of parametric or non-parametric statistical methods for each.
1)An examination and justification of any temporal and/or spatial groundwater quality
concentration phenomena, that shall include, but are not limited to:
g)Any long term or apparently increasing contaminant concentration trends found in any existing
monitoring wells,
h)Any long term or apparently increasing contaminant concentration ratios observed in existing
monitoring wells.
i)Any contaminant concentrations that appear to exceed their corresponding GWQS.
2)Determination of descriptive statistics for each individual well and contaminant found in Table
2 of this Permit.
If after review of the report, the Executive Secretary determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues identified,
and re-submit the report for Executive Secretary review and approval within a timeframe
approved by the Executive Secretery. Upon approval of this report, the Executive Secretary
will re-open this Permit and modify the Ground Water Compliance Limits in Table 2, above
to account for natural variations in groundwater quality, not caused by current or historic
operations at the facility.
d)Background Groundwater Quality Report: New Monitoring Wells – the content of the
Background Groundwater Quality Report for the new monitoring wells shall comply with the
information requirements of Part I.H.3 of this Permit.
If after review of the report, the Executive Secretary determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues identified,
and re-submit the report for Executive Secretary review and approval within a timeframe
approved by the Executive Secretary. After approval of this report, the Executive Secretary
will re-open this Permit and establish Groundwater Compliance Limits in Table 2 for the
new monitoring wells.
e)Tailings Cells Wastewater Quality Sampling Plan –the purpose of this plan and associated
report shall be to characterize the source term quality of all tailings cell wastewaters,
including, but not limited to: impounded wastewaters or process waters in the tailings cells,
and wastewater or leachates collected by internal slimes drains. Said plan shall include, but
is not limited to:
a.Collection of samples from each wastewater source at each tailings cell, including
wastewater impoundments, slimes drains, etc.
b.Complete analysis for both field and laboratory parameters required by Part I.E.1(d), and
Part I
Permit No. UGW370004
32
all detectable volatile organic contaminants by EPA Method 8260B.
c.Detailed description of all sampling methods and sample preservation techniques to be
employed.
d.Use of standardized analytical methods.
e.Analysis by a State of Utah certified environmental laboratory.
f.30 day advance notice of each annual sampling event to allow the Executive Secretary to
collect split samples of all tailings cell wastewater sources.
If after review of the plan, the Executive Secretary determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues identified,
and re-submit the plan for Executive Secretary review and approval within a timeframe
approved by the Executive Secretary. After approval of the plan, the Permittee shall
implement the plan pursuant to the requirements of Parts I.E.10 and I.F.9. After approval of
this plan, the Executive Secretary may re-open and modify this Permit to incorporate the
provisions of the approved plan.
f)Monitoring Well Remedial Action and Report – on or before , May 1, 2008 the
Permittee shall complete the following remedial activities for selected monitoring
wells at the facility:
a.Well Development – the Permittee shall develop the following wells at the facility so
that they produce clear groundwater, including wells: MW-5, MW-11, MW-18,
MW-19, MW-20, MW-22, and TW4-16. Said well development will ensure that
groundwater clarity conforms to the EPA RCRA TEGD requirements found in Part
I.E.4(c) of this Permit to the extent reasonably achievable.
b.Protective Surface Casing: MW-3A – the Permittee shall install a steel surface casing
to protect the currently exposed PVC well casing at well MW-3A in order to:
i.Allow ready water level measurement at the well,
ii.Not interfere or disturb the existing water level measuring point, and
iii.Provide security and control access to the well.
c.Report – the Permittee shall submit a report for Executive Secretary approval that
documents well development and completion activities required by Part I.H.6(a) and
(b) of this Permit.
Monitoring Well MW-3 Verification, Retrofit, or Reconstruction Report – In the
event that the Executive Secretary determines the MW-3 well screen has been
inadequately constructed, the Permittee shall replace monitoring well MW-3 with
well MW-3A within 30 days of written notice.
g)White Mesa Seeps and Springs Sampling Work Plan and Report – the Permittee shall
implement a plan of groundwater sampling and analysis of all seeps and springs found
downgradient or lateral gradient from the tailings cells on White Mesa. Said plan shall
include, but is not limited to:
a.Location of all seeps and springs to be sampled, including maps and surveyed coordinates
Part I
Permit No. UGW370004
33
(physical location, and elevation),
b.Detailed description of sampling methods and equipment,
c.Determination of field parameters or measurements that will be made,
d.Description of sample preservation methods,
e.Determination of the laboratory analytical methods and the environmental laboratory that
will perform the analysis.
f.Sampling and analysis of all ground water compliance parameters found on Table 2 of this
Permit, including analysis of volatile and semi-volatile organic compounds by EPA SW-
846 methods 8260 and 8270.
If after review of the plan, the Executive Secretary determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues identified,
and re-submit the plan for Executive Secretary review and approval within a timeframe
approved by the Executive Secretary. Immediately after approval of the plan, the Permittee
shall complete said sampling and analysis, and submit a report for Executive Secretary
approval. Said report shall: 1) document the sampling project, 2) transmit copies of all field
measurements and laboratory results, 3) provide a water table contour map that includes
water table elevations of all the wells at the facility and the elevations of the phreatic surfaces
observed at each of the seeps and springs sampled, and 4) provide an evaluation and
interpretation of the groundwater quality data collected. The Permittee shall also provide at
least 15 days notice to allow the Executive Secretary to collect split groundwater quality
samples of the seeps and springs.
h)1. On-site Chemicals Inventory Report -– the Permittee shall complete a historical review,
and conduct an inventory of all chemical compounds or reagents stored, used, or currently in
use at the facility. Said report shall include:
a.a) Identification of all chemicals used in the milling and milling related processes at White
Mesa, and.
b.b) Determination of the total volumes currently in use and historically used, as data is
available.
At the time of Permit renewal, the Permittee shall submit an updated inventory report
pursuant to Part I.F.8.
i)2. Infiltration and Contaminant Transport Modeling Work Plan and Report -– the Permittee
shall submit for Executive Secretary approval an infiltration and contaminant transport
modeling report that demonstrates the long-term ability of the tailings cells cover system to
adequately contain and control tailings contaminants and protect nearby groundwater quality
of the uppermost aquifer. Said report shall demonstrate how the tailings cell engineering
design and specifications will comply with the minimum performance requirements of Part
I.D.6 of this Permit. The Permittee shall submit an infiltration and contaminant modeling for
Executive Secretary approval, that:
a.a) Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
Part I
Permit No. UGW370004
34
b.b) Determines and justifies all information necessary for infiltration and contaminant
transport modeling, including but not limited to representative input values for vadose
zone and aquifer soil-water partitioning (Kd) coefficients, tailings source term
concentrations, tailings waste leach rates, vadose zone and aquifer groundwater
velocities, vadose zone and aquifer dispersivity, contaminant half-life or other rates of
decay, etc. In the event that any required information is not currently available, the
Permittee may select conservative assumptions for use in the required infiltration and
contaminant transport models.
c.c) Identifies and adequately describes all computer models used to simulate long-term
performance of the tailings cells cover system. All predictive models used shall be
publicly available computer codes that adequately represent field characteristics and
physical processes at the tailings disposal site. Said description will also include
specific information on model design, including, but not limited to: governing equations
and their applicability to site conditions, grid design, duration of simulation, and
selection of time steps.
d.d) Determines the conceptual model used and justifies why it is representative or
conservative of actual field conditions at the site. Said conceptual model will identify the
physical domain(s) and geometries simulated including the tailings cell design and
construction, all boundary and initial conditions assigned in the model(s), and the
shallow aquifer locations where future potential contaminant concentrations have been
predicted.
e.e) Justifies how the infiltration and contaminant transport problem has been adequately
conceptualized, planned, and executed to demonstrate compliance with the requirements
of Part I.D.6 of this Permit.
f.f) Provides, describes and justifies the following:
i.1) Model Results -– including electronic input and output files from all infiltration,
groundwater flow and contaminant transport models used the report.
ii.2) Model Calibration -– including description of results and efforts used to
demonstrate how the model adequately reproduced field measured heads, flows, and
contaminant concentrations.
iii.3) Steady State Conditions -– including a demonstration that the models achieved a
steady state condition during the simulation. This includes, but is not limited to
disclosure, evaluation and justification of water and mass balance error values
reported by the models.
iv.4) Sensitivity Analyses -– including description of various model simulations run
and evaluated to define the range of model uncertainty. Such uncertainty includes,
but is not limited to: boundary and initial conditions, model input values, and spatial
and temporal distribution of model parameters used in the problem domain.
v.5) Post-model Audit Plan -– including plans to revisit the modeling effort at some
future time to re-assess its ability to represent site characteristics and predict long-
term performance of tailings cell design and construction, and groundwater
protection.
The Permittee shall complete all modeling in accordance with the requirements of Part
Part I
Permit No. UGW370004
35
I.H.210 and submit a final report for Executive Secretary approval. In the final report, the
Permittee may include supplemental information to justify modification of certain Permit
requirements, including, but not limited to: the number and types of groundwater
compliance monitoring parameters, tailings cell cover system engineering design and
construction specifications, tailings cell operational requirements, etc. In the event the
Executive Secretary requires additional information, the Permittee will provide all requested
information within a time frame approved by the Executive Secretary. Upon Executive
Secretary approval of the final infiltration and contaminant transport report, the Reclamation
Plan may be modified to accommodate necessary changes to protect public health and the
environment.
15.Plan for Evaluation of Deep Supply Well WW-2 -– the purpose of this plan is to evaluate the
annular casing seal in water supply well WW-2, and to ensure adequate well casing and annular
seals, in compliance with the regulations of the Utah State Engineer (UAC R655-4-9), with
special emphasis on creating both a physical barrier and hydraulic isolation between the shallow
unconfined and the deep confined aquifers. Prior to Executive Secretary approval of this plan the
Permittee shall resolve all issues within a timeframe approved by the Executive Secretary. After
Executive Secretary approval of the plan, the Permittee shall completely execute all provisions of
the plan on or before decommissioning of the White Mesa Mmill.
3.
12.Supplemental Liner Maintenance Provisions – within 90-days of issuance of this Permit, the
Permittee shall submit Liner Maintenance Provisions to be incorporated into the existing DMT
Monitoring Plan for Executive Secretary approval. The purpose of said provisions shall be for the
equipment, material, training and procedures to be used for the timely detection of any openings in
the polymer liners, and the reliable repair and quality assurance testing of any such repairs to the
polymer liners for Cells 1, 2 and 3 and the Roberts Pond.
13 <Reserved>
14.< Reserved >
3.Contingency Plan – within 180 days of issuance of this Permit, the Permittee shall implement a
Contingency Plan that provides a detailed list of actions the Permittee will take to regain
compliance with Permit limits and DMT or BAT requirements defined in Parts I.C and I.D of
this Permit. At a minimum, the Contingency Plan will include, but is not limited to measures
to resolve the following general categories of non-compliance:
a)Groundwater Contamination – as shown by any contaminant concentrations in compliance
monitoring wells that exceed their respective groundwater compliance limit found in Part
I.C.1 and Table 2 of this Permit.
b)Mill Discharge Violations – including unauthorized discharge or release of prohibited
contaminants to the tailings cells, pursuant to Part I.C.2 and I.C.3; and
c)DMT and BAT Violations – which include several types of non-compliance, including but
not limited to:
3)Excess tailings cell wastewater pool elevation above the maximum elevations
Part I
Permit No. UGW370004
36
mandated by Part I.D.3;
4)Excess head in the Tailings Cells 2 and 3 slimes drain system, pursuant to Part I.D.3
and as defined by the DMT Monitoring Plan in Part I.H.13; and
5)Excess elevation for tailings solids as required by Part I.D.3.
If after review of the plan, the Executive Secretary determines that additional information is
required, the Permittee shall provide all requested information, resolve all issues identified,
and re-submit the plan for Executive Secretary review and approval within a timeframe
approved by the Executive Secretary.
16. Revised Stormwater Best Management Practices Plan - on or before May 15, 2008, the
Permittee shall submit for Executive Secretary review and approval, a revised Stormwater Best
Management Practices Plan to address the effects of Tailings Cell 4A construction and operation.
Said plan shall comply with the requirements of Part I.D.10 of this permit. Upon Executive
Secretary approval, the Permittee is to immediately implement all provisions of such plans.
17. <Reserved>
4. 18. Isotopic Groundwater and Surface Water Investigation and Report - within 90 calendar
days of issuance of this Permit, the Permittee shall submit an isotopic groundwater and
surface water investigation report for Executive Secretary approval. The purpose of this
investigation and associated report shall be to characterize chemical composition, noble gas
composition, and age of the groundwater monitoring wells and surface water sites that were
not part of the July 2007 University of Utah Study. The following locations shall be included
in the investigation: monitoring wells MW-12, MW-17, MW-20, MW-23, MW-24, MW-25,
MW-26, MW-28, MW-32, Tailings Cell 4A, and the northernmost wildlife pond (WP1).
The report shall include, but is not limited to:
a. An examination of groundwater age using the tritium/helium-3 method in each
monitoring well and surface water sources (Tailings Cell 4A and the northernmost
wildlife pond). After tritium concentrations have been obtained for each well, the
Permittee must verify if any of the monitoring wells have been influenced by the artificial
recharge from the wildlife ponds.
b. An examination of isotopes Deuterium and Oxygen-18 in water at each sampling
location to determine geochemical characteristics including but not limited to evaporative
signature.
c. An evaluation of isotopes Oxygen-18 and Sulfur-34 on dissolved sulfate molecules in the
water samples.
The purpose of this supplemental investigation and associated report shall be to establish
isotopic benchmarks, geochemical characteristics, and a ground/surface water age at these
locations. The Permittee must conclusively demonstrate that the supplemental investigation
conducted is similar to the one performed by the University of Utah in July 2007.
Repair of Monitor Well MW-5 – on or before May 1, 2008, the Permittee shall submit an As-Built
report to document said repairs for Executive Secretary review and approval.
19. Cell 4A BAT Monitoring, Operations and Maintenance Plan. – the Permittee will submit an
Part I
Permit No. UGW370004
37
Operations and Maintenance Plan for Cell 4A for Executive Secretary review and approval.
Commencement of wastewater or tailings discharge to Cell 4A is prohibited without prior written
approval from the Executive Secretary. Said Plan shall include requirements in Part F.3 of the
Permit and include, but is not limited to the following:
a)Operation and Maintenance Procedures - including operational sequences, transporting methods,
equipment operation / maintenance, safety and emergency procedures,
b)Operation, Maintenance, Monitoring, and Recordkeeping – for evaluation of the following in
accordance with the requirements of Parts I.D.6, I.E.8, and I.F.8:
1)Leak detection system – including operational status of equipment, daily wastewater head, daily flow
rates, etc.
2)Slimes drainage system – including operational status of equipment, daily flow rates, monthly
wastewater recovery head monitoring, etc
c)Freeboard limits on dikes – including monitoring and proper management and volume inventory
controls to prevent release of wastewater to the environment.
20. <Reserved > – QAP
21.Feedstock Material Stored Outside the Feedstock Storage Area Management Plan – within 30 days of
issuance of this Permit the Permittee shall submit for Executive Secretary review and approval a
management plan for the feedstock material stored outside the feedstock ore storage area.
22. QAP Revision - on or before April 30, 2008 the Permittee shall modify the QAP and submit
a revised revision for Executive Secretary review and approval. Said changes shall require that all
non – conformance with QAP requirements discovered in a given quarterly ground water monitoring
period will be corrected and reported to the Executive Secretary on or before submittal of the next
quarterly ground water monitoring report as required in Part I.E.1(a).

5. New Decontamination Pad - the Permittee shall not use the New Decontamination Pad until
the following conditions are satisfied:
a. Within 30 calendar days of issuance of the Permit, the Permittee shall submit an updated
DMT Monitoring Plan for Executive Secretary approval that includes but is not limited
to the following:
1) The manner of weekly inspections the New Decontamination Pad, including the leak
detection system and concrete integrity of the decontamination pad.
2) Within 30 calendar days of issuance of the Permit, the Permittee shall submit an
updated Contingency Plan that clarifies what steps will be taken if there is water
found within the leak detection system and if discrepancies are observed on the
concrete pad.
3) Annual Inspection - the New Decontamination Pad will be taken out of service and
inspected annually during the second quarter, to ensure integrity of the concrete
surfaces. If discrepancies are identified [i.e. crack in the concrete with greater than
Part I
Permit No. UGW370004
38
1/8 inch separation (width) or any significant deterioration or damage of the pad
surface], repairs shall be made prior to resuming the use of the facility. The
inspection findings, any repairs required, and repairs completed shall be included in
the in the 2nd Quarter DMT Monitoring Report due September 1, of each calendar
year.
b. The Executive Secretary approves the engineering design drawings for the liner and leak
detection system, before they are constructed.
c. The Permittee shall perform a hydrostatic test that verifies that the steel liner and leak
detection system performs in accordance with the approved drawings and will provide
the test results within 30 calendar days after completion of the test. The Permittee shall
provide at least 10 calendar days notice prior to performing the hydrostatic test to allow a
DRC inspector to be present.
d. The Executive Secretary approves all the As-Built drawings for the Decontamination
Pad.
6. Existing Decontamination Pad - within 30 calendar days of issuance of the Permit, DUSA
shall perform the following:
a. Submit As-Built drawings of the Existing Decontamination Pad (EDP).
b. Submit an updated BAT/DMT Monitoring Plan for Executive Secretary approval
describing monitoring details and DMT Inspection items for the Existing
Decontamination Pad.
c. Annual Inspection - the EDP will be taken out of service and inspected annually during
the second quarter, to ensure integrity of the steel tank. The inspection findings, any
repairs required, and repairs completed shall be included in the in the 2nd Quarter DMT
Monitoring Report due September 1, of each calendar year.
Part II
Permit No. UGW370004
39
PART II. REPORTING REQUIREMENTS
A. REPRESENTATIVE SAMPLING. Samples taken in compliance with the monitoring requirements
established under Part I shall be representative of the monitored activity.
B. ANALYTICAL PROCEDURES. Water sample analysis must be conducted according to test
procedures specified under UAC R317-6-6.3.12 unless other test procedures have been specified
in this Ppermit.
C. PENALTIES FOR TAMPERING. The Act provides that any person who falsifies, tampers with, or
knowingly renders inaccurate, any monitoring device or method required to be maintained under
this Ppermit shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than six months per violation, or by both.
D. REPORTING OF MONITORING RESULTS. Monitoring results obtained during reporting periods
specified in the pPermit, shall be submitted to the Executive Secretary, Utah Division of Water
Quality at the following address no later than the date specified following the completed
reporting period:
Attention: Compliance and Monitoring Program
State of Utah
Division of Water Quality
Department of Environmental Quality
Salt Lake City, Utah 84114-4870
The quarterly due dates for reporting are: June 1, September 1, December 1, and March 1.
E. COMPLIANCE SCHEDULES. Reports of compliance or noncompliance with, or any progress
reports on interim and final requirements contained in any Compliance Schedule of this Ppermit
shall be submitted no later than 14 calendar days following each schedule date.
F. ADDITIONAL MONITORING BY THE PERMITTEE. If the Ppermittee monitors any pollutant more
frequently than required by this Ppermit, using approved test procedures as specified in this
Ppermit, the results of this monitoring shall be included in the calculation and reporting of the
data submitted. Such increased frequency shall also be indicated.

G. RECORDS CONTENTS.
1. Records of monitoring information shall include:
a) The date, exact place, and time of sampling, observations, or measurements:
b) The individual(s) who performed the sampling, observations, or measurements;
c) The date(s) and time(s) analyses were performed;
d) The name of the certified laboratory which performed the analyses;
e) The analytical techniques or methods used; and,
f) The results of such analyses.
H. RETENTION OF RECORDS. The Ppermittee shall retain records of all monitoring information,
Part II
Permit No. UGW370004
40
including all calibration and maintenance records and copies of all reports required by this
Ppermit, and records of all data used to complete the application for this Ppermit, for a period of
at least five years from the date of the sample, measurement, report or application. This period
may be extended by request of the Executive Secretary at any time.
I. NOTICE OF NONCOMPLIANCE REPORTING.
1. The Ppermittee shall verbally report any noncompliance which may endanger public health
or the environment as soon as possible, but no later than 24- hours from the time the
Ppermittee first became aware of the circumstances. The report shall be made to the Utah
Department of Environmental Quality 24- hour number, [phone], or to the Division
of Water Quality, Ground Water Protection Section at [phone], during normal
business hours (8:00 am - 5:00 pm Mountain Time).
2. A written submission shall also be provided to the Executive Secretary within five calendar
days of the time that the Ppermittee becomes aware of the circumstances. The written
submission shall contain:
a) A description of the noncompliance and its cause;
b) The period of noncompliance, including exact dates and times;
c) The estimated time noncompliance is expected to continue if it has not been corrected;
and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
3. Reports shall be submitted to the addresses in Part II.D, Reporting of Monitoring Results.
J. OTHER NONCOMPLIANCE REPORTING. Instances of noncompliance not required to be reported
within 5 calendar days, shall be reported at the time that monitoring reports for Part II.D are
submitted.
K. INSPECTION AND ENTRY. The Ppermittee shall allow the Executive Secretary, or an authorized
representative, upon the presentation of credentials and other documents as may be required by
law, to:
1. Enter upon the Permittee’s premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of the Ppermit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this Ppermit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this pPermit; and,
4. Sample or monitor at reasonable times, for the purpose of assuring Ppermit compliance or as
otherwise authorized by the Act, any substances or parameters at any location.
Part III
Permit No. UGW370004
41
PART III. COMPLIANCE RESPONSIBILITIES
A. DUTY TO COMPLY. The Ppermittee must comply with all conditions of this Ppermit. Any
Ppermit noncompliance constitutes a violation of the Act and is grounds for enforcement action;
for permit termination, revocation and re-issuance, or modification; or for denial of a permit
renewal application. The Ppermittee shall give advance notice to the Executive Secretary of the
Division of Water Quality of any planned changes in the permitted facility or activity which may
result in noncompliance with pPermit requirements.
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS. The Act provides that any person who
violates a Ppermit condition implementing provisions of the Act is subject to a civil penalty not
to exceed $10,000 per day of such violation. Any person who willfully or negligently violates
Ppermit conditions is subject to a fine not exceeding $25,000 per day of violation. Any person
convicted under Section 19-5-115 of the Act a second time shall be punished by a fine not
exceeding $50,000 per day. Nothing in this Ppermit shall be construed to relieve the Ppermittee
of the civil or criminal penalties for noncompliance.
C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE. It shall not be a defense for a Ppermittee
in an enforcement action that it would have been necessary to halt or reduce the permitted
activity in order to maintain compliance with the conditions of this Ppermit.
D. DUTY TO MITIGATE. The Ppermittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this Ppermit which has a reasonable likelihood of adversely affecting
human health or the environment.
E. PROPER OPERATION AND MAINTENANCE. The Ppermittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the Ppermittee to achieve compliance with the conditions of this Ppermit.
Proper operation and maintenance also includes adequate laboratory controls and quality
assurance procedures. This provision requires the operation of back-up or auxiliary facilities or
similar systems which are installed by a Ppermittee only when the operation is necessary to
achieve compliance with the conditions of the Ppermit.
Part IV
Permit No. UGW370004
42
PART IV. GENERAL REQUIREMENTS

A. PLANNED CHANGES. The Ppermittee shall give notice to the Executive Secretary as soon as
possible of any planned physical alterations or additions to the permitted facility. Notice is
required when the alteration or addition could significantly change the nature of the facility or
increase the quantity of pollutants discharged.
B. ANTICIPATED NONCOMPLIANCE. The Ppermittee shall give advance notice of any planned
changes in the permitted facility or activity which may result in noncompliance with Ppermit
requirements.
C. PERMIT ACTIONS. This Ppermit may be modified, revoked and reissued, or terminated for cause.
The filing of a request by the Ppermittee for a permit modification, revocation and re-issuance,
or termination, or a notification of planned changes or anticipated noncompliance, does not stay
any permit condition.
D. DUTY TO REAPPLY. If the Ppermittee wishes to continue an activity regulated by this Ppermit
after the expiration date of this Ppermit, the Ppermittee must apply for and obtain a new permit.
The application should be submitted at least 180 calendar days before the expiration date of this
Ppermit.
E. DUTY TO PROVIDE INFORMATION. The Ppermittee shall furnish to the Executive Secretary, within
a reasonable time, any information which the Executive Secretary may request to determine
whether cause exists for modifying, revoking and reissuing, or terminating this Ppermit, or to
determine compliance with this Ppermit. The Ppermittee shall also furnish to the Executive
Secretary, upon request, copies of records required to be kept by this Ppermit.
F. OTHER INFORMATION. When the Ppermittee becomes aware that it failed to submit any relevant
facts in a permit application, or submitted incorrect information in a permit application or any
report to the Executive Secretary, it shall promptly submit such facts or information.
G. SIGNATORY REQUIREMENTS. All applications, reports or information submitted to the Executive
Secretary shall be signed and certified.
1. All permit applications shall be signed as follows:
a) For a corporation: by a responsible corporate officer;
b) For a partnership or sole proprietorship: by a general partner or the proprietor,
respectively.
c) For a municipality, State, Federal, or other public agency: by either a principal executive
officer or ranking elected official.
2. All reports required by the Ppermit and other information requested by the Executive
Secretary shall be signed by a person described above or by a duly authorized representative
of that person. A person is a duly authorized representative only if:
a) The authorization is made in writing by a person described above and submitted to the
Executive Secretary, and,
Part IV
Permit No. UGW370004
43
b) The authorization specified either an individual or a position having responsibility for the
overall operation of the regulated facility or activity, such as the position of plant
manager, operator of a well or a well field, superintendent, position of equivalent
responsibility, or an individual or position having overall responsibility for
environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position).
3. Changes to Authorization. If an authorization under Part IV.G.2. is no longer accurate
because a different individual or position has responsibility for the overall operation of the
facility, a new authorization satisfying the requirements of Part IV.G.2 must be submitted to
the Executive Secretary prior to or together with any reports, information, or applications to
be signed by an authorized representative.
4. Certification. Any person signing a document under this section shall make the following
certification:
"I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations."
H. PENALTIES FOR FALSIFICATION OF REPORTS. The Act provides that any person who knowingly
makes any false statement, representation, or certification in any record or other document
submitted or required to be maintained under this Ppermit, including monitoring reports or
reports of compliance or noncompliance shall, upon conviction be punished by a fine of not more
than $10,000 per violation, or by imprisonment for not more than six months per violation, or by
both.
I. AVAILABILITY OF REPORTS. Except for data determined to be confidential by the Ppermittee, all
reports prepared in accordance with the terms of this Ppermit shall be available for public
inspection at the offices of the Executive Secretary. As required by the Act, permit applications,
permits, effluent data, and ground water quality data shall not be considered confidential.
J. PROPERTY RIGHTS. The issuance of this Ppermit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations.
K. SEVERABILITY. The provisions of this Ppermit are severable, and if any provision of this
Ppermit, or the application of any provision of this Ppermit to any circumstance, is held invalid,
the application of such provision to other circumstances, and the remainder of this Ppermit, shall
not be affected thereby.
L. TRANSFERS. This Ppermit may be automatically transferred to a new Ppermittee if:
1. The current Ppermittee notifies the Executive Secretary at least 30 calendar days in advance
Part IV
Permit No. UGW370004
44
of the proposed transfer date;
2. The notice includes a written agreement between the existing and new Ppermittee containing
a specific date for transfer of permit responsibility, coverage, and liability between them;
and,
3. The Executive Secretary does not notify the existing Ppermittee and the proposed new
Ppermittee of his or her intent to modify, or revoke and reissue the permit. If this notice is
not received, the transfer is effective on the date specified in the agreement mentioned in
paragraph 2 above.
M. STATE LAWS. Nothing in this pPermit shall be construed to preclude the institution of any legal
action or relieve the Ppermittee from any responsibilities, liabilities, penalties established
pursuant to any applicable state law or regulation under authority preserved by Section 19-5-115
of the Act.
N. REOPENER PROVISIONS. This Ppermit may be reopened and modified (following proper
administrative procedures) to include the appropriate limitations and compliance schedule, if
necessary, if one or more of the following events occurs:
1. If new ground water standards are adopted by the Board, the Ppermit may be reopened and
modified to extend the terms of the Ppermit or to include pollutants covered by new
standards. The Ppermittee may apply for a variance under the conditions outlined in R317-6-
6.4(D).
2. Changes have been determined in background ground water quality.
3. The Executive Secretary determines permit modification is necessary to protect human health
or the environment.