DRC-2010-003261 - 0901a0688018c935

RC-2010-00326
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 l?"" 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 infonnation contained in the
administrative record. It is the responsibility of the Permittee to read and understand all provisions of
this Permit.
The milling and tailings disposal facility shall be operated and revised in accordance with conditions
set forth in the Permit 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 Permit shall become effective on .
This Permit shall expire March 8. 2010 (This Permit is in Timely Renewal)
Application for Permit Renewal was received September 1, 2009
Signed this day of , 2010
Co-Executive Secretary
Utah Water Quality Board

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Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS................................................................................ 1
A. GROUND WATER CLASSIFICATION....................................................................................... 1
B. BACKGROUND WATER QUALITY.......................................................................................... 1
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
12. BAT Design Standards for Tailings Cell 4B .............................................................. 16
13. BAT Performance Standards for Tailings Cell 4B ..................................................... 19
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING............. 19
1. Routine Groundwater Compliance Monitoring..........................................................19
2. Groundwater Monitoring: Monitoring Wells MW-20 and MW-22 ........................... 21
3. Groundwater Head Monitoring................................................................................... 21
4. Groundwater Monitoring Well Design and Construction Criteria.............................. 21
5. Monitoring Procedures for Wells................................................................................ 22
6. White Mesa Seep and Spring Monitoring................................................................... 22
7. DMT Performance Standard Monitoring.................................................................... 23
8. BAT Performance Standard Monitoring..................................................................... 24
9. On-site Chemicals Inventory....................................................................................... 25
10. Tailings Cell Wastewater Quality Monitoring............................................................ 25
11. Groundwater Monitoring Modifications..................................................................... 26
12. BAT Performance Standard Monitoring..................................................................... 26
F. REPORTING REQUIREMENTS............................................................................................... 27
1. Routine Groundwater Monitoring Reports................................................................. 27
2. Routine DMT Performance Standard Monitoring Report .......................................... 28
3. Routine BAT Performance Standard Monitoring Reports.......................................... 29
4. DMT and BAT Performance Upset Reports............................................................... 29
5. Other Information ....................................................................................................... 29
6. Groundwater Monitoring Well As-Built Reports.......................................................29
7. White Mesa Seeps and Springs Monitoring Reports.................................................. 30
8. Chemicals Inventory Report ....................................................................................... 31
9. Tailings Cell Wastewater Quality Reports.................................................................. 31
10. Revised Hydrogeologic Report................................................................................... 31
11. Annual Slimes Drain Recovery Head Report ............................................................. 31
G. OUT OF COMPLIANCE STATUS............................................................................................ 32
1. Accelerated Monitoring Status.................................................................................... 32
2. Violation of Permit Limits.......................................................................................... 32

ii
3. Failure to Maintain DMT or BAT Required by Permit .............................................. 32
4. Facility Out of Compliance Status.............................................................................. 33
H. COMPLIANCE SCHEDULE REQUIREMENTS.......................................................................... 33
1. On-site Chemicals Inventory Report........................................................................... 33
2. Infiltration and Contaminant Transport Modeling Work Plan and Report................. 34
3. Plan for Evaluation of Deep Supply Well WW-2.......................................................35
4. New Decontamination Pad ......................................................................................... 36
5. Existing Decontamination Pad.................................................................................... 36
6. Installation of New Groundwater Monitoring Wells.................................................. 36
7. Background Groundwater Quality Report for New Monitoring Wells....................... 37
8. Revised BAT Operations and Monitoring Plan.......................................................... 38
9. Cell 4B As-Built Report.............................................................................................. 38
10. Additional Hydrogeologic Investigation and Report.................................................. 39
11. Corrections to Engineering Drawing Sheet 6 of 8 ...................................................... 39
PART II. REPORTING REQUIREMENTS................................................................................. 40
A. REPRESENTATIVE SAMPLING.............................................................................................. 40
B. ANALYTICAL PROCEDURES................................................................................................ 40
C. PENALTIES FOR TAMPERING............................................................................................... 40
D. REPORTING OF MONITORING RESULTS............................................................................... 40
E. COMPLIANCE SCHEDULES.................................................................................................. 40
F. ADDITIONAL MONITORING BY THE PERMITTEE.................................................................. 40
G. RECORDS CONTENTS.......................................................................................................... 40
H. RETENTION OF RECORDS.................................................................................................... 41
I. NOTICE OF NONCOMPLIANCE REPORTING.......................................................................... 41
J. OTHER NONCOMPLIANCE REPORTING................................................................................ 41
K. INSPECTION AND ENTRY..................................................................................................... 41
PART III. COMPLIANCE RESPONSIBILITIES........................................................................ 42
A. DUTY TO COMPLY.............................................................................................................. 42
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS........................................................ 42
C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE...................................................... 42
D. DUTY TO MITIGATE............................................................................................................ 42
E. PROPER OPERATION AND MAINTENANCE........................................................................... 42
PART IV. GENERAL REQUIREMENTS................................................................................... 43
A. PLANNED CHANGES........................................................................................................... 43
B. ANTICIPATED NONCOMPLIANCE......................................................................................... 43
C. PERMIT ACTIONS................................................................................................................ 43
D. DUTY TO REAPPLY............................................................................................................. 43
E. DUTY TO PROVIDE INFORMATION ...................................................................................... 43
F. OTHER INFORMATION......................................................................................................... 43
G. SIGNATORY REQUIREMENTS .............................................................................................. 43
H. PENALTIES FOR FALSIFICATION OF REPORTS...................................................................... 44
I. AVAILABILITY OF REPORTS................................................................................................ 44
J. PROPERTY RIGHTS ............................................................................................................. 44
K. SEVERABILITY.................................................................................................................... 44
L. TRANSFERS........................................................................................................................ 44
M. STATE LAWS...................................................................................................................... 45
N. REOPENER PROVISIONS......................................................................................................45

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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. Approved Tailings Cell 4B Engineering Design and Specifications..............................16
Table 7. Groundwater Monitoring Reporting Schedule................................................................28
Part I.A & I.B
Permit No. UGW370004
1
PART I. SPECIFIC PERMIT CONDITIONS
A. GROUND WATER CLASSIFICATION - the groundwater 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 1,273 93 MW-2 77 3,050 252
MW-5 82 2,058 170 MW-3 78 5,217 263
MW-11 71 1,844 178 MW-12 61 3,894 241
MW-30 10 1,745 87 MW-14 51 3,592 176
MW-15 47 3,857 243
MW-17 22 4,444 321
MW-18(3) 18 2,605 297
MW-19(3) 22 2,457 900
MW-20(4) 2 5,610 57
MW-22(4) 2 7,365 361
MW-3A 9 5,547 129
MW-23 10 3,443 244
MW-24 10 4,116 117
MW-25(5) 11 2,843 67
MW-26(6) 12 3,155 65
MW-27(7) 10 1,019 28
MW-28 11 3,677 87
MW-29 8 4,380 27
MW-31(7) 10 1,265 50
MW-32(8) 12 3,669 247
Footnotes:
1) N = Number of Samples
2) Based on historic total dissolved solids (TDS) data provided by the Permittee for period between October, 1979 and December, 2007. This
data was obtained from the Permittee’s background groundwater quality reports dated October 2007 and April 30, 2008.
3) Background 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.
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 part of the 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 MW-32 was originally named TW4-17 and was installed as part of the 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 June 2007 for
existing 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) and through December 2007 for new wells (MW-3A,
MW-23, MW 24, MW-25, MW-27, MW-28, MW-29, MW-30 and MW-31), the upper boundary
of background groundwater quality is determined on a well-by-well basis, pursuant to
Part I.B & I.C
Permit No. UGW370004
2
Environmental Protection Agency (EPA) guidance, and documented in the Permittee’s
background groundwater quality reports dated October 2007 and April 30, 2008.
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. Groundwater 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.

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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

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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) Ground Water Compliance Limits (GWCL) were set after Executive Secretary review and approval of two Background Groundwater Quality Reports dated October_2007 and April 30, 2008 from the Permittee..
7) GWCLs listed in the table above in Normal Font 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 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.

Part I.D
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
upstream toe of the cross-valley dike.
Part I.D
Permit No. UGW370004
7
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.
Beneath this underlay, native sandstone and other foundation materials were graded
Part I.D
Permit No. UGW370004
8
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 Permit 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.D
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), 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 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 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 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 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, 2013, 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
2010 2009 2009 2009 2009 2009 2009
2011 2010 2009 2009 2010 2009 2009
2012 2011 2010 2009 2011 2010 2009
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.
Part I.D
Permit No. UGW370004
10
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 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. The Permittee shall maintain a minimum 4-foot
wide buffer zone on the inside margin of the Feedstock Storage Area between the storage
area fence and the Feedstock which shall be absent of feed material in order to assure that
materials do not encroach on the boundary of the storage area.
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 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
the currently approved Stormwater Best Management Practices Plan. For any new
construction of reagent storage facilities, said secondary containment and control shall
Part I.D
Permit No. UGW370004
11
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
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.
Part I.D
Permit No. UGW370004
12
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 and1990, 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; each 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
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.
Part I.D
Permit No. UGW370004
13
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) Cell 4A 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) Cell 4A 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 Cells 2 and 3, will be managed and contained in Cell 4A, including the
Probable Maximum Precipitation and flood event.
Part I.D
Permit No. UGW370004
14
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. Any failure to achieve or maintain the required BAT performance
standards shall constitute a violation of the Permit and shall be reported to the Executive
Secretary in accordance with Part I.G.3. PThe plan’s performance standards for Tailings Cell
4A 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 floor.
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 11e.(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,
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.D
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.
11. 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 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.D
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.
12. BAT Design Standards for Tailings Cell 4B - the BAT design standard for Tailings Cell 4B
shall be defined by and constructed in accordance with the requirements as summarized by
the engineering drawings, specifications, and description in Table 6, below:
Table 6. Approved Tailings Cell 4B Engineering Design and Specifications
Engineering Drawings
Name Date Revision No. Title
Sheet 1 of 8 January 2009 Rev. 1 Cover Sheet
Sheet 2 of 8 January 2009 Rev. 1 Site Plan
Sheet 3 of 8 January 2009 Rev. 1 Base Grading Plan
Sheet 4 of 8 January 2009 Rev. 1 Pipe Layout and Details
Sheet 5 of 8 December 2007 Rev. 0 Lining System Details I
Sheet 6 of 8 (1) January 2009 Rev. 1 Lining System Details II
Sheet 7 of 8 January 2009 Rev. 1 Lining System Details III
Sheet 8 of 8 January 2009 Rev. 1 Lining System Details IV
Figure 1 January 2009 - Mill Site Drainage Basins (supporting reference)
Engineering Specifications
Date Document Title Prepared by
January 2009 Slope Stability Analysis Calculation Package Geosyntec Consultants
January 2009 Seismic Deformation Analysis Calculation
Package
Geosyntec Consultants
January 2009 Revised Pipe Strength Analysis Calculation
Package
Geosyntec Consultants
January 2009 Revised Comparison of Flow Though Compacted
Clay Liner and Geosynthetic Clay Liner
Calculation Package
Geosyntec Consultants
January 2009 Revised Action Leakage Rate Calculation Package Geosyntec Consultants
August 2009 Blasting - Locations and Profiles, Attachment:
Figures 1 and 2
Geosyntec Consultants
August 2009 (Revised) Technical Specifications, with the
exception of Section 02200 (Earthwork)
Geosyntec Consultants
August 2009 Cell 4B Capacity Calculations Geosyntec Consultants
August 2009 Revised Cushion Fabric Calculations
August 2009 Construction Quality Assurance Plan for the
Construction of Cell 4B Lining System
Geosyntec Consultants
September 2009 (Revised) Technical Specification Section 02200
(Earthwork)
Geosyntec Consultants

August 6, 2009
Blast Plan, KGL and Associates and Blast Plan
Review, Geosyntec Consultants letter dated
September 10, 2009
KGL and Associates and
Geosyntec Consultants
September 2009 Probable Maximum Precipitation (PMP) Event
Computation
Geosyntec Consultants
January 2009 Slope Stability Analysis Calculation Package Geosyntec Consultants

1. Engineering drawing Sheet 6 of 8 is approved subject to conditions and requirements outlined in Part I.H.11 of
this Permit.
Part I.D
Permit No. UGW370004
17
Tailings Cell 4B Design and Construction - approved by the Executive Secretary will consist
of the following major elements:
a) Dikes - consisting of newly constructed dikes on the south and west side of the cell, each
including a 20-foot wide road at the top (minimum) to support an access road. The
grading plan for the Cell 4B excavation includes interior slopes of 2H to 1V. The exterior
slopes of the southern and western dikes will have typical slopes of 3H to 1V. Limited
portions of the Cell 4B interior sideslopes in the northwest corner and southeast corner of
the cell, (where the slimes drain and leak detection sump will be located will also have a
slope of 3H to 1V. The base width of the southern dikes varies from approximately 92
feet at the western end to approximately 190 feet at the eastern end of the dike, with no
exterior embankment present on any other side of the cell.
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% at a moisture content between +3% and
-3% of optimum moisture content, as determined by ASTM D-1557. The floor of Cell 4B
has an average slope of 1% that grades from the northwest corner to the southeast corner.
c) Tailings Capacity - the floor and inside slopes of Cell 4B encompass about 44 acres, and
the cell will have a water surface area of 40 acres and a maximum capacity of about 1.9
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 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 4B 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 that extends across the
entire area under the primary FML in Cell 4B, and drains to a leak detection sump in
the southeast 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 a sump having dimensions of 15 feet by 10 feet by 2 feet deep that contains a
leak detection system sump area. 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 a 60-mil HDPE membrane found immediately below
the leak detection geonet. Said FML also extends across the entire Cell 4B 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 4B, the
Part I.D
Permit No. UGW370004
18
Permittee shall demonstrate that the GCL has achieved a moisture content of at least
50% by weight.
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 4B 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 northwest corner downhill to the far southeast corner of
Cell 4B 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 4B at the southeast 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) Cell 4B North and East Dike Splash Pads - Nine 20-foot-wide splash pads will be
constructed on the north and east dikes 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 4B, from the top of the dike, under the inlet pipe, and down the inside slope to a
point at least 5 feet onto the Cell 4B floor beyond the toe of the slope.
g) Cell 4B Emergency Spillway - a concrete lined spillway will be constructed near the
southeastern corner of the east dike to allow emergency runoff from Cell 4A into Cell
4B. This spillway will be limited to a 6-inch reinforced concrete slab, with a welded wire
fabric installed within it at its midsection, set atop a cushion geotextile placed directly
over the primary FML in a 4-foot deep trapezoidal channel. A 100-foot wide, 60-mil
HDPE membrane splash pad will be installed beneath the emergency spillway. No other
Part I.D & I.E
Permit No. UGW370004
19
spillway or overflow structure will be constructed at Cell 4B. All stormwater runoff and
tailings wastewaters not retained in Cells 2 and 3, and 4A will be managed and contained
in Cell 4B, including the Probable Maximum Precipitation and flood event.
13. BAT Performance Standards for Tailings Cell 4B - the Permittee shall operate and maintain
Tailings Cell 4B so as to prevent release of wastewater to groundwater and the environment
in accordance with an approved Cell 4B BAT, Monitoring, Operations and Maintenance Plan
pursuant to Part I.H.8 of this Permit. Any failure to achieve or maintain the required BAT
performance standards shall constitute a violation of the Permit and shall be reported to the
Executive Secretary in accordance with Part I.G.3. Performance standards for Tailings Cell
4B 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. At all times the Permittee shall operate the LDS pump and transducer
in a horizontal position at the lowest point of the LDS sump floor.
b. LDS Maximum Allowable Daily Leak Rate - shall not exceed 26,145 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 4B, 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
5.5 years or less.
d. Maximum Weekly Wastewater Level - under no circumstance shall the freeboard be less
then 3-feet in Cell 4B, as measured from the top of the upper FML.
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING - beginning with
the effective date and lasting through the term of this Permit 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 groundwater 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 groundwater monitoring period
Part I.E
Permit No. UGW370004
20
will be corrected and reported to the Executive Secretary on or before submittal of the
next quarterly groundwater 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-25, MW-26 (formerly TW4-
15), MW-30, and MW-31.
3) Future Cell 4B Downgradient Wells to be Installed - quarterly monitoring shall begin
within 30 calendar days of installation of new groundwater monitoring wells MW-33,
MW-34, and MW-35 required by Part I.H.6 of this Permit, and continue until
otherwise determined by the Executive Secretary pursuant to Part I.H.7.
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,
MW-17, MW-23, MW-24, 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, specific conductance, and
redox potential (Eh).
2) Laboratory Parameters
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 - all 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
Part I.E
Permit No. UGW370004
21
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 groundwater 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.
c) After completion of eight consecutive quarters of groundwater sampling and analysis of
MW-20 and MW-22, the Permittee shall submit a Background Report that will include:
1) Data preparation and statistical analysis of groundwater quality data, including but
not limited to: evaluation of data characteristics and internal data consistency,
treatment of non-detectable values, and statistical methods used. 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.
d) 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, 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 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.
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:
Part I.E
Permit No. UGW370004
22
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 groundwater, 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
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.,
b) Water Quality Sampling and Analysis - the Permittee shall collect grab samples and
perform laboratory analysis of all water quality parameters identified in Table 2 of this
Permit., and
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 seeps or springs water quality analyses reported shall
have a minimum detection limit or reporting limit that is less than or equal to the
respective:
Part I.E
Permit No. UGW370004
23
1) Ground Water Quality Standards 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.
7. DMT Performance Standards Monitoring - the Permittee shall perform technology
performance monitoring in accordance with the currently approved DMT Monitoring Plan
to 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 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) 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,
3) Make all slimes drain recovery head test (depth to fluid) measurements from the
same designated water level measuring point, and
4) Record 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
Part I.E
Permit No. UGW370004
24
DMT operations standards in Part I.D.3. Said measurements shall be made in accordance
to the currently approved DMT Monitoring Plan.
d) Weekly Feedstock Storage Area Inspection - the Permittee shall conduct weekly
inspections of all feedstock storage to: 1) Confirm the bulk feedstock materials are
maintained within the approved Feedstock Storage Area defined by Table 4, and 2)
Verify that all alternate feedstock materials located outside the Feedstock Area defined in
Table 4, are stored in accordance with the requirements found in Part I.D.11.
e) Feedstock Material Stored Outside the Feedstock Storage Area Inspections
1) Weekly Inspection - the Permittee will conduct weekly inspections to verify that 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. In the event that
any liner defect or damage is identified during a liner system inspection, the Permittee
shall immediately: 1) report and repair said defect or damage pursuant to Part I.G.3 by
implementation of the currently approved Liner Maintenance Provisions, and 2) report all
repairs made pursuant to Part I.F.2.
8. Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the
currently approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, pursuant
to Part I.H.8 of this Permit, the Permittee shall immediately implement all monitoring and
recordkeeping requirements therein. The Cell 4A BAT monitoring includes the following:
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 LDS 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. For purposes of compliance
Part I.E
Permit No. UGW370004
25
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.
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
pursuant to Part I.H.8.
c) Liner Maintenance and Repair - all repairs to the liner shall be completed in accordance
with Section 9.4 of the approved June 2007 Geosyntec Consultants Cell 4A Construction
Quality Assurance Plan (CQA/QC Plan) as found in Table 5 of this Permit. Repairs shall
be performed by qualified liner repair personnel and shall be reported in a Liner Repair
Report, certified by a Utah licensed Professional Engineer. The Liner Repair Report shall
be submitted to for Executive Secretary approval in accordance with Part I.F.3 of the
Permit. Any leak, hole, or other damage to the liner will be reported to the Executive
Secretary pursuant to the requirements found in Part I.G.3.
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. One surface impounded wastewater location at each of Tailings Cells 1, 3, and , 4A, and
4B.
b. One slimes drain wastewater access pipe at each of Tailings Cells 2, 3, and 4A, and 4B.
For Cells 3, and 4A, and 4B, this requirement shall apply immediately after initiation of
de-watering operations at these cells, and
c. One leak detection wastewater access pipe at Tailings Cells 4A and 4B.
d. 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. Said annual monitoring shall include, but is not limited to:
1) Field Measurements - including: pH, temperature, and specific conductivity.,
Part I.E
Permit No. UGW370004
26
2) Water Quality Sampling and Analysis - the Permittee shall collect grab samples and
perform laboratory analysis of all:
i. Water quality parameters identified in Table 2 of this Permit, and
ii. Semi-volatile compounds identified in EPA Method 8270D.
3) Certified Laboratory Analysis - all laboratory analysis will be conducted by a Utah
certified laboratory.
4) 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.
5) Minimum Detection Limits - all water quality analyses reported shall have a
minimum detection limit or reporting limit that is less than or equal to the respective:
i. Ground Water Quality Standards concentrations defined in Table 2 of this Permit,
ii. 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
iii. Lower limits of quantitation for groundwater for semi-volatile organic
compounds listed in Table 2 of EPA Method 8270D, Revision 4, dated February,
2007.
6) 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.
7) Prior Notification - at least 30 calendar days before any 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.
8) 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.
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.
12. Cell 4B BAT Performance Standards Monitoring and Maintenance - immediately following
Executive Secretary approval of the Cell 4B BAT, Monitoring, Operations and Maintenance
Plan, pursuant to Part I.H.8 of this Permit, the Permittee shall immediately implement all
monitoring and recordkeeping requirements therein. The Cell 4B BAT monitoring shall
include the following:
Part I.E & I.F
Permit No. UGW370004
27
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 LDS pumping or related 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 (LDS) sump exceed a 1-foot level above the lowest
point in the lower flexible membrane liner on the cell floor. Any occurrence of leak
detection system fluids above this 1-foot limit shall constitute failure of BAT, and a
violation of this Permit.
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 26,145 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 4B. Said measurements shall be made to the nearest 0.1 foot.
b) Slimes Drain Recovery Head Monitoring - immediately after the Permittee initiates
pumping conditions in the Tailings Cell 4B 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
pursuant to Part I.H.8.
c) Liner Maintenance and Repairs - all repairs to the liner shall be completed in accordance
with Section 10.4 of the approved August 2009 Geosyntec Consultants Cell 4B
Construction Quality Assurance Plan (CQA/QC Plan) as found in Table 6 of this Permit.
Repairs shall be performed by qualified liner repair personnel and shall be reported in a
Liner Repair Report, certified by a Utah licensed Professional Engineer. The Liner Repair
Report shall be submitted for Executive Secretary approval in accordance with Part I.F.3
of the Permit. Any leak, hole, or other damage to the liner will be reported pursuant to the
requirements found in Part I.G.3.
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 of this Permit for Executive Secretary review and approval.
Reports shall be submitted according to the following schedule:
Part I.F
Permit No. UGW370004
28
Table 7.6 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
Permit. 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, 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 radiological
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 groundwater 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
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Permit No. UGW370004
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Permit and the currently approved DMT Monitoring Plan. When a liner repair is performed
at the Roberts Pond or any DMT impoundment, a Repair Report is required by the Liner
Maintenance Provisions. This Repair Report shall be included with the next quarterly DMT
Report. Said monitoring reports and results shall be submitted for Executive Secretary
approval on the schedule provided in Table 76, above.
3. Routine Cell 4A and 4B BAT Performance Standards Monitoring Reports - the Permittee
shall provide quarterly monitoring reports of all BAT performance standards monitoring
required by Parts I E.8 and I.E.12 of this Permit. BAT Monitoring at Cells 4A and 4B shall
be conducted in compliance with the currently approved BAT Monitoring, Operations and
Maintenance Plan. When a liner repair is performed at Tailings Cell 4A or 4B, a Repair
Report is required by Parts I.E.8(c) and I.E.12(c) of the Permit. This Repair Report shall be
included with the next quarterly BAT Report. Said monitoring report and results shall be
submitted for Executive Secretary approval on the schedule provided in Table 76 above. At a
minimum, reporting of BAT monitoring for Cells 4A and 4B will include:
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 Cells 4A and 4B 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
Part I.F
Permit No. UGW370004
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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
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:
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
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Permit No. UGW370004
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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.1. 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
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.
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.
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Permit No. UGW370004
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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) Evaluate all data collected, data collection methods, and all related calculations
required by this Permit, and
2) Verify the accuracy and reliability of both the data and calculations reported.
e) 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
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 the concentration of a
pollutant in two consecutive samples from a compliance monitoring point exceeds a GWCL
in Table 2 of this Permit.
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 Permit, 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 Permit 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).
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Permit No. UGW370004
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c) Affirmative Defense - in the event a compliance action is initiated against the Permittee
for violation of Permit 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 Permit 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 Permit conditions, 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 groundwater quality to insure that Permit 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 in order to regain and maintain compliance with the Permit
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 Permit, 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. 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) Identification of all chemicals used in the milling and milling related processes at White
Mesa, and
b) Determination of the total volumes currently in use and historically used, as data is
available.
Part I.H
Permit No. UGW370004
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At the time of Permit renewal, the Permittee shall submit an updated inventory report
pursuant to Part I.F.8.
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.86 of
this Permit. The Permittee shall submit an infiltration and contaminant modeling for
Executive Secretary approval, that:
a) Identifies all applicable and pertinent historic studies and modeling reports relevant to
tailings cell cover design and tailings cell system performance.
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) 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) 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) 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.86 of this Permit.
f) Provides, describes and justifies the following:
1) Model Results - including electronic input and output files from all infiltration,
groundwater flow and contaminant transport models used the report.
2) Model Calibration - including description of results and efforts used to demonstrate
how the model adequately reproduced field measured heads, flows, and contaminant
concentrations.
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Permit No. UGW370004
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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.
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.
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 I.H.2
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.
3. 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.
On or before January 31, 2012, the Permittee shall:
a) Conduct an investigation of water supply well WW-2 to verify that the casing and
annular seal is intact and creates both a physical barrier and hydraulic isolation between
the shallow unconfined and the deep confined aquifers, said investigation shall include
one or more of the following investigation techniques performed in accordance with
applicable guidance from the U.S. Environmental Protection Agency: well casing video
logs, cement bond logs, and/or temperature logs,
b) Show that the well casing and annular seal have physical and hydraulic integrity to isolate
the two aquifers mentioned above. In the event that hydraulic isolation of the two
aquifers is uncertain or unsubstantiated for any reason, the Permittee shall repair the well
casing and annular seal(s) to provide well construction that complies with the regulations
of the Utah State Engineer (UAC R655-4-9). After such repairs are completed, the
Permittee will conduct repeat testing using the investigation techniques required under
Part I.H.3(a) to demonstrate existence of the required hydraulic isolation, and
c) Submit a written report for Executive Secretary approval to document the investigation
and its findings, and any well repair activities. Said report shall be certified by a Utah-
licensed Professional Engineer or Geologist.
Part I.H
Permit No. UGW370004
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4. 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 wash pad’s
exposed concrete surface. If discrepancies are identified [i.e. crack in the concrete
with greater than 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.
5. 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.
6. Installation of New Groundwater Monitoring Wells - the Permittee shall install at least
three hydraulically downgradient wells adjacent to Tailings Cell 4B, in accordance with
the following requirements:
a) New Compliance Monitoring Wells MW-33 and MW-34 - install two new
Part I.H
Permit No. UGW370004
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compliance monitoring wells (MW-33 and MW-34) prior to placement of tailings and
wastewater in Cell 4B. The locations of the wells MW-33 and MW-34 shall be the
same as shown on Figure 4 of the February 8, 2010 submittal by Hydro Geo Chem
Inc. Said monitoring wells shall:
1) Provide early detection of tailings cell contamination of shallow groundwater
from Tailings Cell 4B.
2) Provide discrete groundwater monitoring for tailings Cell 4B.
3) Comply with the design, construction, and development requirements found in
Part I.E.4 of this Permit.
b) Within 45 calendar days of completing well installation, submit a monitoring well As-
Built report for wells MW-33 and MW-34 to document said well construction for
Executive Secretary approval. Said report shall comply with the requirements of Part
I.F.6. The As-Built report shall be approved by the Executive Secretary before
placement of tailings or wastewater in Tailings Cell 4B. 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.
c) New Compliance Monitoring Well MW-35 - before placement of tailings or
wastewater in Tailings Cell 4B, the Permittee shall submit to the Executive Secretary
for approval a proposed location for new compliance monitoring well MW-35.
Installation of well MW-35 shall be completed within 30 calendar days of Executive
Secretary approval of said location. The exact location of the well MW-35 shall be
determined after consideration of hydrogeologic information acquired through
installation / development of wells MW-33 and MW-34 and other related field
investigations. The design, construction and development of well MW-35 shall
comply with the requirements of Part I.E.4 of this Permit.
d) Within 45 calendar days of completing installation of well MW-35, the Permittee
shall submit a monitoring well As-Built report to document said well construction for
Executive Secretary approval. Said report shall comply with the requirements of Part
I.F.6. 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.
e) The Permittee shall provide at least a 7 calendar day written notice to allow the
Executive Secretary to observe all drilling and well installation activities. In the event
the Executive Secretary determines that additional monitoring wells are required,
these new wells will be installed and related As-Built Report(s) submitted (for
approval) within a time frame approved by the Executive Secretary.
7. Background Groundwater Quality Report for New Monitoring Wells - within 30 calendar
days of receipt of written Executive Secretary approval for use of Tailings Cell 4B, the
Permittee shall commence a quarterly groundwater sampling program that will 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.
Part I.H
Permit No. UGW370004
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c) After completion of eight consecutive quarters of groundwater sampling and analysis of
these new wells (MW-33, MW-34 and MW-35), the Permittee shall submit a
Background Report for Executive Secretary approval, that will include:
1) Data preparation and statistical analysis of groundwater quality data, including, but
not limited to, evaluation of data characteristics and internal data consistency,
treatment of non-detectable values, and statistical methods used. 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) Shallow aquifer average linear groundwater velocity calculated for the new wells,
based on well specific hydraulic conductivity, hydraulic gradient, and effective
aquifer porosity.
d) If after review of the report, and 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 an appropriate monitoring
frequency in accordance with the criteria found in Part I.E.1(b) or (c), and establish
Groundwater Compliance Limits in Table 2 for the each of the new wells.
8. Revised BAT, Monitoring, Operations, and Maintenance Plan for Cells 4A and 4B - prior
to any tailings or wastewater disposal in Cell 4B, the Permittee shall submit and receive
Executive Secretary approval of a revised Cell 4A BAT, Monitoring, Operations and
Maintenance Plan, and a Cell 4B BAT, Monitoring, Operations and Maintenance Plan.
At a minimum, said plans must include:
a) Description of the minimum required qualifications, experience, definition of roles
and responsibilities of all personnel acting in liner repair activities with respect to
Construction Quality Assurance Plans (CQA/QC Plans) prepared by Geosyntec
Consultants, dated June 2007 (see Table 5) and August 2009 (see Table 6).
b) Certification of each Liner Repair Report by a Utah Licensed Professional Engineer,
pursuant to Parts I.E.8 and I.E.12 of this Permit, and subsequent submittal thereof to
the Executive Secretary for approval in accordance with Part I.F.3 of the Permit.
c) For Cell 4A, the plan shall include all related elements described in Parts I.D.6 and
I.E.8 of the Permit.
d) For Cell 4B, the plan shall include all related elements described in I.D.13 and I.E.12
of the Permit.
9. Cell 4B As-Built Report - before any disposal of wastes or wastewaters into Cell 4B, the
Permittee shall submit an engineering As-Built report to document all construction
activities, for Executive Secretary review and approval. Any deviations from the
Executive Secretary approved engineering design and/or specifications will be clearly
disclosed and described. Said report shall be certified by a Utah licensed Professional
Engineer. If after review of the As-Built report, and the Executive Secretary determines
Part I.H
Permit No. UGW370004
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that additional information is required, the Permittee shall provide all requested
information, and resolve all issues identified, before Cell 4B is put into service.
10. Additional Hydrogeologic Investigation and Report - prior to any tailings or wastewater
disposal in Cell 4B, the Permittee shall:
a) Conduct additional field investigations to confirm elevation survey data for springs
and seeps at the margin of White Mesa, including, but not limited to, Cottonwood
Seep and/or Westwater Seep and Ruin Spring. The purpose of such studies will be to
determine representative elevation of shallow groundwater and the upper geologic
contact of the Brushy Basin Shale Member of the Morrison Formation at these seeps
and springs.
b) Provide written explanation and resolution of final survey data for seeps and Ruin
Spring and shall use appropriate data points to construct a representative Brushy
Basin/Burro Canyon geologic contact surface map of White Mesa that includes, but
is not limited to, areas west and southwest of the tailings management cell areas,
including Cell 4B. The geologic contact surface map shall include data from all
nearby monitoring wells, seeps and springs;
c) Submit a report to the Executive Secretary for approval that demonstrates compliance
with the requirements described above. Said report shall be signed and certified
(stamped) by a Utah Licensed Geologist or Professional Engineer, and shall: 1)
resolve the apparent uncertainties associated with local geologic structural directions
/ gradient of the Brushy Basin/Burro Canyon geologic contact of the local perched
water system and its relationship to seeps located west and southwest of the tailings
management cells and Ruin Spring, 2) identify the closest point(s) of surface
discharge of groundwater for the White Mesa perched water system (point of
exposure), and 3) estimate travel time for shallow groundwater to reach the nearest
surface discharge point(s). In the event that the Executive Secretary determines that
additional information is necessary, the Permittee shall submit all requested
information on a timeframe approved by the Executive Secretary.
11. Corrections to Engineering Drawing Sheet 6 of 8 - prior to construction of Cell 4B, the
Permittee shall revise Cross-section B-7 presented in Engineering Drawing Sheet 6 of 8 and
any related technical specifications, to reflect the following changes:
(a) Both cushion geotextile material flaps must be extended at least 1-foot laterally
beyond the sewn seam at the right (north) side of toe of the drainage aggregate
windrow, and
(b) Sandbags placed on both the right (north) and left (south) side of the drainage
aggregate windrow, must be placed and abutted continuously along the length of the
windrow.
Part II
Permit No. UGW370004
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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 Permit.
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 Permit 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 Permit, 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 Permit shall be
submitted no later than 14 calendar days following each schedule date.
F. ADDITIONAL MONITORING BY THE PERMITTEE. If the Permittee monitors any pollutant more
frequently than required by this Permit, using approved test procedures as specified in this
Permit, 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.
Part II
Permit No. UGW370004
41
H. RETENTION OF RECORDS. The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and copies of all reports required by this
Permit, and records of all data used to complete the application for this Permit, 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 Permittee 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 Permittee
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 Permittee 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 Permittee 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 Permit;
2. Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this Permit;
3. Inspect at reasonable times any facilities, equipment (including monitoring and control
equipment), practices, or operations regulated or required under this Permit; and,
4. Sample or monitor at reasonable times, for the purpose of assuring Permit compliance or as
otherwise authorized by the Act, any substances or parameters at any location.
Part III
Permit No. UGW370004
42
PART III. COMPLIANCE RESPONSIBILITIES
A. DUTY TO COMPLY. The Permittee must comply with all conditions of this Permit. Any Permit
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 Permittee 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 Permit requirements.
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS. The Act provides that any person who
violates a Permit 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
Permit 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 Permit shall be construed to relieve the Permittee 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 Permittee 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 Permit.
D. DUTY TO MITIGATE. The Permittee shall take all reasonable steps to minimize or prevent any
discharge in violation of this Permit which has a reasonable likelihood of adversely affecting
human health or the environment.
E. PROPER OPERATION AND MAINTENANCE. The Permittee 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 Permittee to achieve compliance with the conditions of this Permit.
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 Permittee only when the operation is necessary to
achieve compliance with the conditions of the Permit.
Part IV
Permit No. UGW370004
43
PART IV. GENERAL REQUIREMENTS

A. PLANNED CHANGES. The Permittee 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 Permittee shall give advance notice of any planned changes
in the permitted facility or activity which may result in noncompliance with Permit requirements.
C. PERMIT ACTIONS. This Permit may be modified, revoked and reissued, or terminated for cause.
The filing of a request by the Permittee 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 Permittee wishes to continue an activity regulated by this Permit after
the expiration date of this Permit, the Permittee must apply for and obtain a new permit. The
application should be submitted at least 180 calendar days before the expiration date of this
Permit.
E. DUTY TO PROVIDE INFORMATION. The Permittee 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 Permit, or to
determine compliance with this Permit. The Permittee shall also furnish to the Executive
Secretary, upon request, copies of records required to be kept by this Permit.
F. OTHER INFORMATION. When the Permittee 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 Permit 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
44
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 Permit, 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 Permittee, all
reports prepared in accordance with the terms of this Permit shall be available for public
inspection at the offices of the Executive Secretary. As required by the Act, permit applications,
permits, effluent data, and groundwater quality data shall not be considered confidential.
J. PROPERTY RIGHTS. The issuance of this Permit 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 Permit are severable, and if any provision of this Permit, or
the application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this Permit, shall not
be affected thereby.
L. TRANSFERS. This Permit may be automatically transferred to a new Permittee if:
1. The current Permittee notifies the Executive Secretary at least 30 calendar days in advance of
the proposed transfer date;
Part IV
Permit No. UGW370004
45
2. The notice includes a written agreement between the existing and new Permittee containing a
specific date for transfer of permit responsibility, coverage, and liability between them; and,
3. The Executive Secretary does not notify the existing Permittee and the proposed new
Permittee 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 Permit shall be construed to preclude the institution of any legal
action or relieve the Permittee 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 Permit 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 Permit may be reopened and
modified to extend the terms of the Permit or to include pollutants covered by new standards.
The Permittee may apply for a variance under the conditions outlined in R317-6-6.4(D).
2. Changes have been determined in background groundwater quality.
3. The Executive Secretary determines permit modification is necessary to protect human health
or the environment.

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TABLE OF CONTENTS
Section Page

ACRONYMS AND ABBREVIATIONS...................................................................................................IV
UAC R313-24-3A: ENVIRONMENTAL ANALYSIS - RADIOLOGICAL AND NONRADIOLOGICAL
IMPACTS ........................................................................................................................................1
UAC R313-24-3B: ENVIRONMENTAL ANALYSIS - IMPACT ON WATERWAYS AND
GROUNDWATER...........................................................................................................................6
UAC R313-24-3C: ENVIRONMENTAL ANALYSIS - ALTERNATIVES...............................................11
UAC R313-24-3D: ENVIRONMENTAL ANALYSIS - LONG-TERM IMPACTS ................................13
10CFR40.26(C)(2): GENERAL LICENSE ................................................................................................16
10CFR40.31(H): APPLICATION FOR SPECIFIC LICENSES................................................................18
10CFR40.61: RECORDS ...........................................................................................................................19
10CFR40.65(A)(1): EFFLUENT MONITORING REPORTING REQUIREMENTS..............................21
10CFR40 INTRODUCTION: CAPACITY OF TAILINGS OR WASTE SYSTEMS OVER THE
LIFETIME OF MILL OPERATIONS...........................................................................................22
10CFR40 APPENDIX A, INTRODUCTION: ALTERNATIVE REQUIREMENTS................................23
10CFR40 APPENDIX A, CRITERION 1: PERMANENT ISOLATION WITHOUT ONGOING
MAINTENANCE..........................................................................................................................24
10CFR40, APPENDIX A, CRITERION 2: PROLIFERATION.................................................................27
10CFR40, APPENDIX A, CRITERION 3: PLACEMENT BELOW GRADE.........................................29
10CFR40, APPENDIX A, CRITERION 4: LOCATION AND DESIGN REQUIREMENTS..................31
10CFR40, APPENDIX A, CRITERION 5A(1): GROUND-WATER PROTECTION STANDARDS....36
10CFR40, APPENDIX A, CRITERION 5A(1): GROUND-WATER PROTECTION STANDARDS....36
10CFR40, APPENDIX A, CRITERION 5A(2): LINER............................................................................37
10CFR40, APPENDIX A, CRITERION 5A(4): PREVENT OVERTOPPING.........................................39
10CFR40, APPENDIX A, CRITERION 5A(5): DIKES............................................................................41
10CFR40, APPENDIX A, CRITERION 6(2): VERIFY EFFECTIVENESS OF FINAL RADON
BARRIER......................................................................................................................................44
10CFR40, APPENDIX A, CRITERION 6(3): PHASED EMPLACEMENT OF FINAL RADON
BARRIER......................................................................................................................................46
10CFR40, APPENDIX A, CRITERION 6(4): REPORT RADON BARRIER EFFECTIVENESS..........49
10CFR40, APPENDIX A, CRITERION 6(5): ELEVATED RADIUM CONCENTRATIONS IN COVER
MATERIALS.................................................................................................................................51
10CFR40, APPENDIX A, CRITERION 6(6): CONCENTRATIONS OF RADIONUCLIDES OTHER
THAN RADIUM IN SOIL............................................................................................................53
10CFR40, APPENDIX A, CRITERION 6(7): NONRADIOLOGICAL HAZARDS................................55
10CFR40, APPENDIX A, CRITERION 6A(1): COMPLETION OF FINAL RADON BARRIER..........56
10CFR40, APPENDIX A, CRITERION 7: PREOPERATIONAL AND OPERATIONAL
MONITORING PROGRAMS.......................................................................................................57
10CFR40, APPENDIX A, CRITERION 8: EFFLUENT CONTROL DURING OPERATIONS.............59
10CFR40, APPENDIX A, CRITERION 8A: DAILY INSPECTIONS.....................................................61
10CFR40, APPENDIX A, CRITERION 9: FINANCIAL SURETY ARRANGEMENTS.......................62
10CFR40, APPENDIX A, CRITERION 10: COSTS OF LONG-TERM SURVEILLANCE...................65
UAC R317-6-6.3: GROUND WATER DISCHARGE PERMIT APPLICATION....................................66
UAC R317-6-6.4: ISSUANCE OF DISCHARGE PERMIT......................................................................72
UAC R317-6-6.9: PERMIT COMPLIANCE MONITORING ..................................................................74
UAC R317-6-6.10: BACKGROUND WATER QUALITY DETERMINATION.....................................76
UAC R317-6-6.12: SUBMISSION OF DATA ..........................................................................................78

iii
UAC R317-6-6.13: REPORTING OF MECHANICAL PROBLEMS OR DISCHARGE SYSTEM
FAILURES ....................................................................................................................................79
UAC R317-6-6.14: CORRECTION OF ADVERSE EFFECTS..................................................................80
UAC R317-6-6.16: OUT-OF-COMPLIANCE STATUS...........................................................................81
UAC R317-6-6.17: PROCEDURE WHEN A FACILITY IS OUT-OF-COMPLIANCE..........................83
REFERENCES: ..........................................................................................................................................84

iv
ACRONYMS AND ABBREVIATIONS
ALARA As Low As Reasonably Achievable
ASTM American Society for Testing and Materials
BAT Best Available Technology
BLM U.S. Bureau of Land Management
Cell 4B ER Environmental Report submitted in support of the Cell 4B License
Amendment Request.
CFR Code of Federal Regulations
CL, CH and CL-ML Soil classes under Unified Soil Classification System
cm centimeter
DCGL Derived concentration guideline
DG Draft Regulatory Guide (NRC)
Division Utah Radiation Control Division
DOE U.S. Department of Energy
DQO Data quality objective
DUSA Denison Mines (USA) Corp.
D&M Dames & Moore, Inc.
EA Environmental Assessment
EPA U.S. Environmental Protection Agency
ER Environmental Report
FES Final Environmental Statement
FWPCA Federal Water Pollution Control Act
g gram
gpd, gal/day gallons per day
gpm gallons per minute
GW and GP Soil classes under Unified Soil Classification System
HGCI Hydro Geo Chem, Inc.
IUC International Uranium Corporation

v
kg kilogram
km kilometer; 1000 meters
lb pound (16 ounces)
m meter
mg/l milligram per liter
mi mile
millirem one thousandth of one Roentgen Equivalent Man
mm millimeter, 0.001 meter
m2s square meter second; used as a measure of radon flux, e.g., pCi/m2s
NRC U.S. Nuclear Regulatory Commission
NUREG Series of reports prepared and issued by staff of USNRC
pCi picocurie; 10-12 curie
RCRA Resource Conservation and Recovery Act
rem Roentgen Equivalent Man
RG Regulatory Guide (NRC)
s second
SC, SP, and SW Soil classes under Unified Soil Classification System
TDS total dissolved solids
TEDE Total Effective Dose Equivalent
UAC Utah Administrative Code
UDRC Utah Division of Radiation Control
UMETCO UMETCO Minerals Corporation
URS URS Corporation, including Washington Division
USGS US Geological Survey
yd, yd2 yard, square yards
5h:1v five horizontal units (5h) to one vertical unit (1v); represents slope or
steepness
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UAC R313-24-3A: ENVIRONMENTAL ANALYSIS - RADIOLOGICAL AND
NONRADIOLOGICAL IMPACTS
REGULATORY BASIS:
UAC R313-24-3:
(1) Each new license application, renewal, or major amendment shall contain an environmental
report describing the proposed action, a statement of its purposes, and the environment affected.
The environmental report shall present a discussion of the following:
(a) An assessment of the radiological and nonradiological impacts to the public health from
the activities to be conducted pursuant to the license or amendment;
SAFETY EVALUATION:
The Licensee submitted an Environmental Report on April 30, 2008 (DUSA 2008a). Additional
and related environmental information is found in other Licensee documents provided. The
Licensee provided updated meteorological data, including observations through calendar year
2006, in Section 1.1 of Rev. 4.0 of the Reclamation Plan, recently submitted by letter dated
November 24, 2009 (DUSA 2009b). Currently the November 24, 2009 Reclamation Plan is
under separate review by the Division. The Licensee has summarized that data in its responses
to Division interrogatories.
Section 3.10 of the Environmental Report in Support of the License Renewal Application, State
of Utah Radioactive Materials License No. UT1900479 (DUSA 2007a) shows that land use has
changed little in the area of the mill since the FES, with the exception that the nearest residence
is now approximately 1.6 miles from the mill, whereas the nearest residence at the time of the
FES was approximately 4.8 miles from the mill. However, dose calculations found in the Mill's
2008 MILDOS Evaluation modeled the nearest potential residence, which is at the northern
boundary of the mill property, approximately 1.2 miles from the mill, and found acceptable dose
rates to the public at this location under current Division regulations.
Populations within a 50-mile radius of the mill have been updated since the FES and are included
in Section 4.0 and Section 3.9 of DUSA 2008a. These updated demographics are also
incorporated into the 2008 MILDOS Evaluation (Senes 2008). No significant trends are expected
in population or industrial use patterns in the foreseeable future.
No significant changes have occurred nor are expected in:
• Average values of meteorological parameters.
• Locations, natures, and amounts of present and projected surface and ground-water use
within five miles downgradient of the site.
• Present and projected population associated with each use point during the active life of
the mill.
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• Locations, distances from the mill, withdrawal rates, return rates, type of water use,
depth of wells, groundwater elevation, drawdown rates or water use estimates
downgradient of the proposed Cell 4B.
• Locations and populations of neighboring schools, facilities; hospitals; and residential
areas within 5 miles from the Mill.
The 2008 MILDOS Evaluation (Senes 2008) takes into account recent demographic information
within a 50-mile radius of the mill, and calculates the dose to the nearest potential residence,
which is at the northern boundary of the mill. Therefore the potential radiological impacts from
the addition of Cell 4B on populations and neighboring residences has been taken into account in
that modeling.
For the purposes of evaluating radiological doses from the addition of Cell 4B, as set out in
Senes 2008, the dose at the nearest potential residence, located approximately 1.2 miles north of
the mill and some 0.40 miles closer to the site than the current actual nearest residence, has been
calculated as the dose to the person likely to receive the highest dose from mill operations. .
Cattle grazing on lands abutting the mill's restricted area is similar to grazing that occurred at the
time of the 1979 ER, and is taken into account in the 2008 MILDOS Evaluation (Senes 2008).
There are no significant transient or seasonal population variations applicable to the area of the
mill.
MILDOS-AREA calculates the impacts based on annual average air concentrations of
radionuclides considered. The human pathways considered in MILDOS-AREA for individual
and population impacts are: inhalation, external exposure from ground concentrations, external
exposure from cloud immersion, ingestion of vegetables, ingestion of meat and ingestion of milk.
With respect to the ingestion of vegetables, the 2008 MILDOS Evaluation incorporated the
default provisions of the MILDOS-AREA code, which assume that nearby receptors consume
specified percentages of their total vegetable consumption from vegetables grown at their
respective receptor locations (Senes 2008).
With respect to ingestion of meat and milk, the area immediately north of the mill is used only
for grazing of beef cattle. A second location to the east and south of the mill is also used for the
grazing of beef cattle. Although considered unlikely, the 2008 MILDOS Evaluation
contemplated that in one worst case scenario, it is possible that the beef cattle grazed at these
locations would be eaten by the residents near the mill. A scenario which supports dairy cattle
grazing at these locations was not included in the modeling because the prospect of supporting
dairy cattle grazing near the mill is not credible, given the arid climate and the much larger feed
requirements of dairy cattle as opposed to beef cattle. Further, no dairy cattle have been observed
near the Mill. The 2008 MILDOS evaluation assumed, as a worst case scenario, that the
inhabitants at the nearest potential residence consumed all of their beef from the cattle grazing at
the locations near to the Mill described above, which, based on historic grazing practices, were
assumed to graze at those locations for two months each year. The 2008 MILDOS Evaluation
also conservatively assumed that such residents drank all of their milk from cows that grazed at
the location of the nearest potential residence (Senes 2008).
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In this worst case scenario, the total dose to the person most likely to receive the highest
exposure (i.e., residents at the nearest potential residence) was calculated to be well below the
regulatory limit, as shown in Section 5.0 of the 2008 MILDOS Evaluation.
The updated meteorological data, thru 2006 has been used in the “2008 MILDOS simulations”
(Senes 2008). No significant changes to MILDOS results were caused by incorporating this
revised data into the MILDOS simulations. The Licensee provided the MILDOS input and
output files from which the results presented in the 2008 MILDOS Evaluation were summarized.
The Division has reviewed these files and concluded that they appropriately represent the White
Mesa facility in its proposed operating and closed conditions.
The Licensee submitted a sensitivity analysis to demonstrate that reasonable variations in
MILDOS input parameters (related to Cell 4B performance) do not change the conclusion of the
2008 MILDOS Evaluation (Senes 2008). The Division has reviewed this sensitivity study and
concluded that it provides confidence that the projected dose rates during operations and
following closure will satisfy applicable regulatory dose limits.
The construction and operation of Cell 4B will not add any new constituents of concern over and
above existing licensed facilities at the Mill. The physical, chemical and radiological make up of
the tailings to be disposed of in Cell 4B is expected to be appreciably similar to that of existing
tailings and the assumptions upon which the 2008 MILDOS Evaluation is based.
The hazards and risks to human health and the environment created by all potential constituents
of concern at the Mill site were originally assessed in detail by Dames and Moore in Section 5.0
of the 1978 Environmental Report (ER; D&M 1978) and by NRC in Section 4.0 of the Final
Environmental Statement (FES; NRC 1979).
The 2008 MILDOS Evaluation provides an estimate of the maximum total effective dose
equivalent ("TEDE") for a number of receptors, including the nearest potential residence using
updated meteorology. The nearest potential residence is at the northern boundary of the Mill
property, close to air particulate monitoring station BHV-1, which is the closest private property
that could be occupied full time by a member of the public. That location, BHV-1, is also in one
of the predominant wind directions. All other site boundaries abut property managed by United
States Bureau of Land Management (BLM), which could not be inhabited full time by a resident.
Therefore, the person likely to receive the highest dose from the licensed operation, as
contemplated by Utah Administrative Code (UAC) R313-15-301 and -302, would be a person at
the nearest potential residence. BHV-1, the location of the nearest potential residence, is
approximately 1.2 miles north of the mill site itself. The current nearest actual residence is
approximately 1.6 miles north of the mill site. Therefore, the analyses and results of the 2008
MILDOS Evaluation conservatively overstate likely doses.
For processing of Colorado Plateau Ore, the maximum TEDE was calculated (Senes 2008) to be
1.4 mrem/yr for an infant at the nearest potential residence, BHV-1, while for processing higher
grade Arizona Strip ores, it was calculated to be 3.1 mrem/yr for the same individual. This
maximum projected dose to the nearest potential resident is about 3.1% of the 100 mrem/yr limit.
The Licensee asserts and the Division agrees that no changes to doses that result from transport
via groundwater or surface water transport are likely to result from the updated meteorology
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database. This conclusion is based on the relatively small changes that were reflected in
meteorological parameters that affect the projected doses, namely, parameters such as wind
speed, wind direction, wind stability, precipitation rates, evaporation rates, and temperatures.
The concentrations of air particulate radionuclides and gamma concentrations at various receptor
locations, including at the nearest potential residence (BHV-1) are reported in the Mill's Semi-
Annual Effluent Reports that are submitted to the Executive Secretary. Doses (TEDEs) at the
locations where humans or environmental populations could be reasonably exposed are
estimated in the 2008 MILDOS Evaluation (Senes 2008).
The mill's training program is described in Section 6.3 of the 2007 License Renewal Application
(DUSA 2007b). The training program was subsequently revised, as described in a letter dated
May 15, 2009 from the Licensee to the Executive Secretary. The mill's training program applies
to the mill generally and to the mill's tailings cells as a whole, and is currently being considered
by the Executive Secretary as part of the 2007 License Renewal Application review process. The
United States Mines Safety and Health Administration (MSHA) also reviews and approves the
mill's training program.
Addendum 5 of the mill's current training program addresses general emergency procedures.
Those procedures take into account the general shutdown of operational activities during an
emergency evacuation event. During new hire training, the Emergency Response Plan is
presented and specific items are covered including procedures and actions to take during the
different emergency scenarios. The instructor covers the roles and responsibilities of each
person, the organizational chart and who should be informed and when, and finally where the
employees can periodically review the Plan to keep themselves familiar.
During annual refresher training for all employees, this information is again reviewed during the
Escape and Emergency Evacuation Plans section. This usually takes place in August of each
year. During this training, the instructor will address the existing Plan and then review the main
ideas for the various scenarios. This information is presented orally with general feedback used
as the evaluation method of knowledge.
All employees who receive training at the facility are documented using the MSHA 5000-23
form. These documents show the training received, i.e. Annual Refresher, Newly Employed
Inexperienced Miner, or Experienced Miner. The amount of training each employee receives will
vary depending on his or her classification upon hire. These documents are held in the
employee's Safety folders which are maintained in the Mill's Radiation Safety Officer's office.
The Licensee is responding to Division directives to address and resolve groundwater
contamination issues that predated operation of the milling facility or construction of the mill’s
tailings system (UDRC 1999). The groundwater chloroform contamination plume has been
attributed to the operation of a temporary laboratory facility that was located at the site prior to
and during construction and initial operation of the mill facility, and from septic drain fields that
were used for laboratory and sanitary waste disposal during initial operation of the mill. DUSA
efforts are underway to comply with all applicable regulatory requirements and License
conditions. The evaluation of compliance of the recently discovered nitrate plume is still under
investigation.
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During mill operations, the doses to the member of the public most likely to be exposed are
expected to continue to be approximately the same as they have been to date. Upon site closure,
all mill buildings and contaminated areas, including wind-blown contamination, will be removed
and placed into one of the tailings cells. The clean up standard for all non-tailings areas and
surrounding areas is set out in Criterion 6(6) of 10 CFR 40, Appendix A (incorporated by
reference into UAC R313-24-4).
After all non-tailings areas are cleaned up and contaminated materials are placed into one of the
tailings cells, the tailings cells will be capped in place. The tailings cell cap must be designed and
constructed to ensure that radon emanations do not exceed the regulatory limit of 20 pCi/m2 per
second, for 1,000 years to the extent reasonable practicable, and in any event for 200 years, as
required by 10 CFR 40, Appendix A, Criterion 6. Additional requirements are found in Section
3.3.2 of the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), which is currently
under Division review. In the interim, the Division will approve Cell 4B for use in operations
only after the Licensee provides revised cover system design documents and assurance that all
applicable regulatory requirements and license conditions will be satisfied (see License
Condition 9.11).
Upon License termination, the tailings cells will be transferred to the U.S. Department of Energy
(DOE) for perpetual care and maintenance.
The doses to members of the public following facility closure and stabilization will be minimal
and within regulatory standards over a 1,000 year time frame (Senes 2008). Upon transfer, DOE
will be responsible to ensure that the tailings cells maintain their integrity and that these
standards will continue to be met in perpetuity.
The accidents already considered in previous submittals to NRC or the Division adequately
represent the accidents that might result during construction and operation of the proposed Cell
4B. The NRC’s and Division’s previous acceptance of such analyses for cell construction is the
basis for accepting them as adequately representing accidents associated with Cell 4B.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-3(1)(a).
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UAC R313-24-3B: ENVIRONMENTAL ANALYSIS - IMPACT ON WATERWAYS AND
GROUNDWATER
REGULATORY BASIS:
UAC R313-24-3:
(1) Each new license application, renewal, or major amendment shall contain an environmental
report describing the proposed action, a statement of its purposes, and the environment affected.
The environmental report shall present a discussion of the following:
…(b) An assessment of any impact on waterways and groundwater resulting from the
activities conducted pursuant to the license or amendment;
SAFETY EVALUATION:
The Licensee provided information on aquifer horizontal and vertical permeabilities and other
physical / hydraulic properties, as well as well drawdown characteristics in Sections 6.3, 7.2, and
7.3 of the ER (DUSA 2008a). In addition, in response to the Round 1 Interrogatory, the
Licensee discussed updated information obtained by the Licensee between January 8, 2008 and
August 27, 2009 and that additional information in Section 2.5 of the September 1, 2009 Permit
Renewal Application (DUSA 2009e).
The Licensee provided updated information on current uses of surface water in the area
surrounding the mill in Section 1.4.1 of the November 24, 2009 Reclamation Plan submittal
(DUSA 2009b), which is currently under Division review.
The State of Utah Division of Water Rights listed 261 ground water appropriations within a 5-
mile radius of the mill. A summary of this list was included in DUSA 2009c. The legend to
Table 2.2.2-1 was inadvertently omitted for that submittal. The legend clarifies the status of each
of the water rights as Approved, Perfected, Terminated, or Unapproved. The legend is included
as Attachment C to DUSA 2010a. Neither the list, nor the Division of Water Rights web site,
lists pending water rights.
A search of the State of Utah, Division of Water Rights yielded information on six shallow wells
located within one mile of the site. Two of the wells are located on the property owned by the
Licensee, and have been previously described. These are the Hawkins and Jones wells. The
records did contain a drill log for the Hawkins well, a copy of which is included as Attachment B
to the Licensee’s response to Round 2 Interrogatories (DUSA 2010a). The file also included
correspondence on appropriation of the water rights. The Hawkins well was abandoned as a part
of the construction of tailings Cell 2. No driller's log was available for the Jones well, although
the file did include correspondence on appropriation of the water rights, a listing of which is
included in Attachment B of DUSA 2010a. Both of these wells are downgradient or cross-
gradient to the mill and tailings area.
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Information was obtained on four other wells located up gradient and cross gradient (to the east)
of the mill property. Records for the Holt well contained no drill logs, but did have an extensive
correspondence file. Two wells drilled by Dale Lyman had drill logs, but no application number
or correspondences file. The "USA Utah Launch Complex White Sands Missile Range" drilled a
well east of the mill site. The records contained an extensive correspondence file but no drill log.
Copies of the Lyman drill logs and the correspondence list for the other wells were submitted in
Attachment B to DUSA 2010a.
The Licensee provided a discussion of groundwater usage in Section 1.5.6 of the November 24,
2009 Reclamation Plan submittal (DUSA 2009b), currently under Division review). The
information provided indicates that: (1) the well yields from wells completed in the Burro
Canyon formation within the White Mesa site are generally lower than those obtained from wells
in this formation upgradient of the site; and (2) documented pumping rates from on-site wells
completed in the Burro Canyon formation are generally less than 0.7 cubic feet per second (cfs).
The information provided shows that some on-site wells are located in a perched aquifer with
limited permeability and saturated thickness. In addition, the saturated thickness of the perched
aquifer appears to generally decrease in a southward direction. It is unknown if this thinning of
saturation is caused by artificial recharge at the eastern part of the site caused by the Licensee’s
wildlife ponds, or to an overall limited vertical recharge at the land surface. Recent groundwater
geochemical and isotopic studies by Hurst and Solomon (Hurst 2008) indicate the perched
aquifer at the site is recharge limited. The groundwater mound caused by the Licensee’s wildlife
ponds in the eastern margin part of the site also demonstrates that a hydraulic connection exists
between the land surface and the perched aquifer. To provide an improved understanding of the
physical extent of the perched aquifer, its hydraulic connection to nearby surface water seeps and
springs, and better estimate groundwater flow directions and travel times to downgradient
discharge points, a new requirement has been added to the Groundwater Discharge Permit (Part
I.H.10) as further described below.
The information provided by the Licensee indicates that similar observations have been noted in
studies performed for the DOE's disposal site at Slick Rock, Colorado site, where the Dakota
Sandstone, Burro Canyon Formation, and upper claystone of the Brushy Basin Member were not
considered aquifers due to their low permeabilities, discontinuous natures, and limited
thicknesses. The Executive Secretary agrees with this finding as it pertains to the Brushy Basin
Member in that it provides a basal hydrogeologic no-flow boundary for the perched aquifer.
However, while the two other overlying formations may have a low yield, this condition does not
negate the need to protect groundwater quality there, in that no limitation for yield is provided in
the definition of an aquifer under the Utah Ground Water Quality Protection Regulations (UAC
R317-6-1.1). Further, it is also important to consider the arid nature of the mill site area, and the
potential that nearby surface water sources may be hydraulically connected to the perched
aquifer. Potential uses of said surface water sources, including wildlife and recreation, need to
be considered. This information will also be helpful as the Licensee and Executive Secretary
further determine long-term solutions for both the chloroform and nitrate groundwater
contaminant plumes known to exist at the mill site property.
The Licensee’s information also indicates that insufficient data are available to define the
groundwater flow direction in the deep confined aquifer found in the Entrada / Navajo sandstone
in the vicinity of the mill. However, because the Morrison and Summerville Formations form
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greater than a 1,000-foot-thick, low-permeability barrier to vertical ground water flow separating
the Entrada / Navajo Aquifer from the Burro Canyon perched zone, it is considered unlikely that
constituents potentially released from the tailings disposal cells would ever impact water quality
of this deep aquifer.
The Licensee provided updated information on surface water and groundwater quality and
chemical characteristics for potentially impacted surface waters and groundwater out to at least a
1-mile radius from the site. The information was provided in Sections 1.5.2 though 1.5.5 of the
November 24, 2009 Reclamation Plan submittal (DUSA 2009b), which is currently under
Division review.
The Licensee has stated that “no significant changes are expected to occur in the surface water or
groundwater use within a 5-mile radius of the mill site.” Surface water flows in the vicinity of
the mill site are intermittent, fed only by storm water runoff and seasonal snow melt. Several
springs, located in the canyon walls east and west of the mill site provide very small, seasonal
contributions to surface water flows. The Licensee indicates that only Ruin Spring, located over
two miles southwest of the mill site provides enough water to support wildlife and cattle grazing.
The Division does not concur with the Licensee’s conclusion, in that other seeps west of the mill
site also convey small, seasonal amounts of surface water flow. The Division’s requirement
(added to the Permit as Part I.H.10) that the Licensee conduct an additional hydrogeologic and
field investigation of the seeps west of the mill site and of Ruin Spring to further verify the
relationship of groundwater flow in the perched water zone and these seeps and the spring, is
intended to help resolve this issue. Prior to mill construction, several small surface water
holding ponds were constructed in the vicinity of the Mill site to trap surface water flows to
support cattle grazing. Since the construction of Recapture Reservoir in the 1980's, cattle grazing
is now supported by stock watering tanks fed from water piped from Recapture Reservoir, and
the land use has shifted from dry land farming and grazing to irrigated crops.
The Licensee provided information on groundwater resources in the vicinity of the mill site
(from the shallow perched aquifer zone) in Sections 7.1 through 7.3 of DUSA 2008a, and the
deeper confined Entrada / Navajo Aquifer is described in section 7.4 of DUSA 2008a. Within a
5-mile radius of the Mill site, groundwater appropriations from the shallow perched zone are
mostly to the north of the mill site. Additional information on the shallow perched zone is
included in the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), currently under
Division review. The Licensee controls the land approximately 1.6 miles to the north of the mill.
Therefore, no additional shallow wells can be drilled beyond that area. The location of the
existing wells is upgradient of the mill site so they would not be impacted by mill operations.
State and Federal agencies own the land to the west of the Mill. Therefore it is “highly unlikely
that a residential development or single family homes would be constructed on land adjacent to
the Mill property. Even if that were to occur, it is highly likely that domestic water would be
supplied by the City of Blanding distribution system, which now extends past the municipal
airport on the southern edge of the city.”
The Licensee provided information in DUSA 2010a to indicate that the community of White
Mesa is the only known use of groundwater within a 5-mile radius to the south of the Mill site.
The community of White Mesa draws domestic water from two deep wells drilled into the
Entrada / Navajo Aquifer. The deep wells are located about 2 miles southeast of the Licensee's
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southern property boundary, and just under five miles southeast of tailings Cell 4A, and supply
all the needed water for domestic use. It is possible that a third well can be drilled if the White
Mesa community population were to grow and require water in addition to what can be produced
by the two deep wells. The White Mesa community wells are deep wells that have a thick
interval of intervening low-permeability (Brush Basin Member and other formations) materials
separating the perched water zone from the deep underlying aquifers. Another possible scenario,
although not financially attractive, would be that the community could pay to extend the pipeline
supplying domestic water from the City of Blanding distribution system.
The Licensee also has five deep wells drilled into the Entrada / Navajo Aquifer, located north,
east and south of the mill facilities. Under the requirements of the Part I.H.3 of the existing
Ground Water Quality Discharge Permit (hereafter Permit, UDRC 2010b), the Licensee is to
evaluate and determine the physical integrity of the casing and annular casing seal in water
supply well WW-2. In the event that hydraulic isolation of the perched aquifer and Entrada /
Navajo Aquifer is uncertain or unsubstantiated for any reason, the Licensee is required to repair
the well casing and annular seal to provide well construction that complies with applicable
regulations or to abandon the well. This effort is being made as a means to protect groundwater
quality conditions in the deep confined aquifer.
In DUSA 2010a, the Licensee provided additional information pertaining to the issue of
projected future changes in surface water or groundwater use within five miles of the White
Mesa mill site. The 5-mile radius is an acceptable distance for providing such information. The
flow of surface water in the vicinity of the mill site is intermittent and fed by storm water runoff
and seasonal snow melt. The majority of the shallow perched zone groundwater appropriations,
within a 5-mile radius of the mill site, are to the north of the mill site. The Licensee currently
controls the land approximately 1.2 miles to the north of the mill, so no additional shallow wells
supplying culinary water for residential use can be drilled within that area.
FINDING:
The Division will require the Licensee to submit an updated, final Reclamation Plan, and revised
Specifications for Reclamation, and any appropriate supporting analyses and calculations, as part
of an ongoing License Renewal process. The Division will review the updated Reclamation Plan
to ensure that it presents an assessment of any impact on waterways and groundwater resulting
from proposed activities at the White Mesa Mill Facility, including final reclamation activities at the
site. In addition, a new requirement (Part I.H.10) has been added to the forthcoming Permit
modification to require the Licensee to conduct an additional hydrogeologic and field
investigation in the area to the west of the Cell 4B footprint area, extending to, and including
existing seeps (e.g. Cottonwood Seep and Westwater Seep) and Ruin Spring located west and
southwest of the tailings management cells, and submission by the Licensee for approval by the
Division of a report describing results of that hydrogeologic investigation prior to placing Cell
4B into service. The investigation will be conducted to further delineate the relationship of the
(geologic) contact between the Brushy Basin and the Burro Canyon formations, and flow in the
perched water zone downgradient of the mill site, to these seeps and Ruin Spring. The geologic
contact surface could exert control on local groundwater flow directions in the perched zone, and
location of potential points of exposure of the public to possible groundwater contamination.
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Part I.H.10 of the Permit will also require that the Licensee determine the estimated travel time
to the nearest perched water zone discharge location that potentially could receive contamination
from the tailings management cells area, including Cell 4B.
The required changes to the Permit and the information contained in the Cell 4B Environmental
Report and other relevant documents the Applicant has submitted, indicate that the requirements
of UAC R317-6-6.3 will yet be satisfied by complying with the Permit conditions prior to
placing Cell 4B into service.

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UAC R313-24-3C: ENVIRONMENTAL ANALYSIS - ALTERNATIVES
REGULATORY BASIS:
UAC R313-24-3:
(1) Each new license application, renewal, or major amendment shall contain an
environmental report describing the proposed action, a statement of its purposes, and
the environment affected. The environmental report shall present a discussion of the
following: ... (c) Consideration of alternatives, including alternative sites and
engineering methods, to the activities to be conducted pursuant to the license or
amendment; and
SAFETY EVALUATION:
It is appropriate not to address alternatives to the site or milling process, since the mill is already
licensed, constructed, and operating, and has been for more than 25 years. It is also appropriate
not to address engineering alternatives to the design of the proposed Cell 4B, since the Licensee
incorporates the same general design features for Cell 4B that the Division has already reviewed
and approved for Cell 4A (URS 2009).
Cost estimates for decommissioning and stabilization of Cell 4B will be provided once the
Licensee submits an As-Built Report for Cell 4B (see Permit, Part I.H.9), and a revised
Reclamation Plan (see License Condition 9.11). The Division has reviewed the final engineering
design and specifications for Cell 4B and intends to approve such through issuance of a modified
Groundwater Quality Discharge Permit (see Permit, Part I.D.12). To ensure that the State’s
interests are adequately protected, conditions will be included in the forthcoming License
amendment to require submission and approval of cost estimates and financial assurances related
to Cell 4B prior to placing Cell 4B into service (see License Condition 9.5).
Discussion of cost estimates for closure and decommissioning of facility components other than
Cell 4B is beyond the scope of this review.
The Licensee is responding to Division directives to address and resolve the chloroform
groundwater contamination issues that predated, or are related to initial operation of the milling
facility. It is the intent of the Division to require the Licensee to include an allowance for costs
for the chloroform groundwater remediation during the review process for the 2010 annual
surety report. Further, this new cost allowance will also be re-evaluated annually hereafter.
FINDING:
With the exception of information that the Licensee must yet submit and that the Division will
review and to ensure that it satisfies applicable requirements, the information submitted by the
Licensee in the Cell 4B ER and related documents appears to satisfy the requirements of UAC
R313-24-3(1)(c).
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Information yet to be submitted, reviewed, and approved include, but are not limited to: a Cell
4B As-built Report, results of infiltration and transport modeling to justify a final cover design
(see Permit, Part I.H.2), revised final cover system design information, and a revised
Reclamation Plan and Specifications for Reclamation (see License Condition 9.11). To ensure
that the State’s interests are adequately protected, new conditions are included in the forthcoming
License and Permit to require submission and approval of such information related to Cell 4B
prior to placing Cell 4B into service.

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UAC R313-24-3D: ENVIRONMENTAL ANALYSIS - LONG-TERM IMPACTS
REGULATORY BASIS:
UAC R313-24-3:
(1) Each new license application, renewal, or major amendment shall contain an environmental
report describing the proposed action, a statement of its purposes, and the environment affected.
The environmental report shall present a discussion of the following:
… (d) Consideration of the long-term impacts including decommissioning,
decontamination, and reclamation impacts, associated with activities to be
conducted pursuant to the license or amendment.
SAFETY EVALUATION:
Currently, the Mill has a reclamation plan for tailings Cells 1, 2, and 3 (IUC 2000) that was
approved by NRC on July 21, 2000 and judged to meet all applicable regulatory criteria,
including those identified above. In a letter to the Executive Secretary, the Licensee submitted
revised figures to the Reclamation Plan relating to Cell 4A (DUSA 2008b). The Executive
Secretary approved these amendments prior to Cell 4A being authorized for re-use (UDRC
2008c).
The Licensee has provided engineering design and specifications for the liner and leak detection
systems proposed beneath Cell 4B (see Geosyntec 2007, Geosyntec 2009, DUSA 2009d and
DUSA 2009f). Review of these plans and reports has been conducted by the URS Corporation
(URS) on behalf of the Executive Secretary; and findings thereof found in a November 5, 2009
URS memorandum (URS 2009). Based on this review, the Executive Secretary has determined:
1) The Cell 4B liners and leak detection system design is adequate to control and contain
tailings wastes and wastewaters in the near-term,
2) The leak detection system proposed for Cell 4B will provide rapid reporting of any
leakage to allow detection thereof before release to underlying groundwater resources,
3) Existing and soon to be installed groundwater monitoring wells near Cell 4B will detect
any leakage releases before contamination has an opportunity to leave DUSA property,
and
4) The long-term containment of tailings and wastewaters at Cell 4B can be addressed under
a future Reclamation Plan, yet to be submitted by the Licensee, and approved by the
Executive Secretary (before Cell 4B is put into service), pursuant to new License
Condition 9.11. As a part of the Cell 4B application process, and in response to a
Division interrogatory, the Licensee provided a November 24, 2009 Reclamation Plan
submittal (DUSA 2009b) , in part as an update to Revision 3.0 of the Reclamation Plan
(IUC 2000), and to reflect current conditions at the site. This was necessary since the
Revision 3.0 largely reflects site conditions when it was last approved by NRC in 2000.
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However, the November 24, 2009 Reclamation Plan did not include cover design
information for Cell 4B. Instead it provided, among other things, information on closure
of Cells 1, 2, 3, and 4A. As a result, while the November 24, 2009 Reclamation Plan is
an improvement over the existing reclamation plan previously approved by the Division
for Cell 4A in August, 2008 (UDRC 2008c), additional information, specific to Cell 4B,
is required by the Division to incorporate cover design requirements for Cell 4B that are
similar to those already approved for Cell 4A (i.e., Revision 3.1 of the Reclamation Plan).
The Licensee indicated (DUSA 2010a, p. 11) that “The principal revisions and updates to the
Plan that are incorporated into Rev 4.0 (the November 24, 2009 Reclamation Plan submittal)
include:
• The addition of approved provisions relating to the Cell 1 Tailings Disposal Area;
• The addition of approved provisions relating to Cell 4A as an operating tailings cell,
including the updates to the Plan conveyed by the Licensee’s letter of July 25, 2008;
• Updates to plans and figures, as applicable, to reflect current conditions;
• Administrative changes to reflect transfer of primary regulatory authority over the
Mill site from NRC to the Division and the change in the name of the Licensee from
International Uranium (USA) Corporation;
• Administrative changes in the nature of "clean-up" for internal consistency of the
document;
• Updates to various information, including the following:
o Updated climate data;
o Updated archaeological status for the site;
o Updated sections relating to surface water, groundwater, site hydrogeology, seeps
and springs etc. to reflect new information about the site since 2000;
o Other various updates to environmental information; and
o Updated disclosure relating to current monitoring programs, particularly
describing new groundwater and DMT monitoring requirements at the site since
2000.”
In addition to the Cell 4B Reclamation Plan required under License Condition 9.11, the Division
is in the process of reviewing the 2007 License Renewal Application (DUSA 2007a and 2007b),
which includes the November 24, 2009 Reclamation Plan (DUSA 2009b). In this process, the
Executive Secretary will confirm that all of the foregoing requirements have been adequately
addressed. This review may result in additional future changes to the Cell 4B Reclamation Plan
required by License Condition 9.11.
The Licensee is also preparing an infiltration and contaminant transport model of the final
tailings cover system (the "Infiltration Study") to demonstrate the long-term ability of the cover
to protect nearby groundwater quality (see Permit, Part I.H.2). When this study is complete and
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approved, the Executive Secretary will review the current Reclamation Plan and determine if
future changes to the cover system are needed to ensure compliance with the performance
criteria contained in Parts I.D.13 and I.D.12 of the Permit. If it is determined that changes are
needed, the Reclamation Plan will be revised to incorporate any such changes. Being that the
details have not been finalized at this time, the approved 2000 cover design and basis (Revision
3.0) continue to be referenced in the November 24, 2009 Reclamation Plan submittal.
To protect the State’s interests, the Division will not authorize Cell 4B to operate until an
updated financial surety is in place for completing final reclamation of the Mill Facility and for
conducing post-closure care of the site. A new condition has been added to the License (see
License Condition 9.11) to require that an updated Reclamation Plan, and revised Specifications
for Reclamation, be submitted to the Executive Secretary for review and approval prior to
placement of tailings and wastewater in Cell 4B. The revised Reclamation Plan required by
Condition 9.11 requires that information on final cover design and final stormwater control
systems be provided, together with estimated costs to complete final closure of the Mill Facility,
including the costs for constructing the final closure cover and drainage systems associated with
Cell 4B. The revised surety would then be based on that revised, approved plan. If, at the time of
commencement of operation of Cell 4B, the Executive Secretary has approved amendments to
the November 24, 2009 Reclamation Plan submittal, either as a result of the 2007 License
Renewal Application review process or as a result of the Infiltration Study, then such
amendments would also apply to Cell 4B and the revised surety. Any changes to the Reclamation
Plan made after operations of Cell 4B begin, either through the 2007 License Renewal
Application review process, the Infiltration Study, or otherwise, will apply to all tailings cells,
and the surety will be revised at that time to reflect any such amendments.
Refer also to evaluation under UAC R317-6-6.3: Ground Water Discharge Permit Application,
as stated below.
FINDING:
The Division will incorporate a new License condition to ensure that the requirements of UAC
R313-24-3(1)(d) are satisfied and that Licensee submits the promised revisions to the cover
design, the Reclamation Plan, and the Specifications for Reclamation to incorporate Cell 4B, and
the appropriate required supporting analyses and calculations, and that the Division will review
and approve these submittals before Cell 4B is placed into service.

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10CFR40.26(C)(2): GENERAL LICENSE
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40.26(c)(2): “The general
license in paragraph (a) of this section is subject to the documentation of daily inspections of
tailings or waste retention systems and the immediate notification of the Executive Secretary, of
any failure in a tailings or waste retention system that results in a release of tailings or waste
into unrestricted areas, or of any unusual conditions (conditions not contemplated in the design
of the retention system) that if not corrected could lead to failure of the system and result in a
release of tailings or waste into unrestricted areas; and any additional requirements the
Executive Secretary may by order deem necessary. The licensee shall retain this documentation
of each daily inspection as a record for three years after each inspection is documented.”
SAFETY EVALUATION:
The system of conducting inspections, submitting reports, and retaining documents used at the
mill is set out in the mill's original License Application and in subsequent renewal applications.
The most recently approved License renewal application was submitted to NRC in August, 1991
and was approved by NRC in March 1997, at which time NRC renewed the License for 10 years,
with an expiration date of March 31, 2007.
The Licensee submitted License Renewal Application in February 2007 (DUSA 2007b), thereby
placing the License into timely renewal. Section 6.3 of the 2007 License Renewal Application
describes the mill's systems relating to Management Controls, the ALARA Program, Training
and Security, and refers to a number of Standard Operating Procedures, such as the mill's
Environmental Protection Manual, Radiation Protection Manual and ALARA Program that are
appended to the 2007 License Renewal Application and which further detail the mill's systems of
inspections, reporting and retaining documents.
The Executive Secretary is currently reviewing the 2007 License Renewal Application through
which the Executive Secretary will determine whether the administrative systems listed above
continue to satisfy all regulatory requirements. Those matters apply to the mill generally and the
mill's tailings system as a whole, not to Cell 4B alone, and are therefore more appropriately part
of the License Renewal review process rather than the review process for Cell 4B.
NRC evidenced its approval of all such systems through the renewal of the License in 1997, with
an expiration date of March 31, 2007. License Condition 9.3 of the mill's renewed NRC Source
Material License states:
"The licensee shall conduct operations in accordance with statements, representations,
and conditions contained in the license renewal application submitted by letter dated
August 23, 1991, as revised by submittals dated January 13, and April 7, 1992,
November 22, 1994, July 27, 1995, December 13, and December 31, 1996, and January
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30, 1997, which are hereby incorporated by reference, and for the Standby Trust
Agreement, dated April 29, 1997, except where superseded by license conditions below.”
License Condition 9.3 currently contains similar language.
The Licensee has implemented an extensive environmental monitoring and reporting system,
including the conducting and documenting daily inspections of tailings and waste retention
systems. The Licensee’s program requires the Executive Secretary immediately to be notified of
any failure in a tailings or waste retention system that results in a release of tailings or waste into
unrestricted areas (refer to Section 2.3 of the November 24, 2009 Reclamation Plan submittal
(DUSA 2009b, currently under Division review), Part I.G.3 of the Permit, and the mill's
Emergency Response Plan). Documentation of daily inspections is retained for at least three
years after each inspection is documented.
These monitoring, inspection, and record keeping requirements will apply to Cell 4B upon
completion of construction and start of operations.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40.26(c)(2), as they
involve Cell 4B.

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10CFR40.31(H): APPLICATION FOR SPECIFIC LICENSES
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40.31(h): “An application for a
license to receive, possess, and use source material for uranium or thorium milling or byproduct
material, as defined in 10CFR40, at sites formerly associated with such milling shall contain
proposed written specifications relating to milling operations and the disposition of the
byproduct material to achieve the requirements and objectives set forth in Appendix A of
10CFR40. Each application must clearly demonstrate how the requirements and objectives set
forth in Appendix A of 10CFR40 have been addressed. Failure to clearly demonstrate how the
requirements and objectives in Appendix A have been addressed shall be grounds for refusing to
accept an application.”
SAFETY EVALUATION:
The original application for the License and each renewal, including the 2007 License Renewal
Application submitted to and currently being by the Division, contain written specifications
relating to milling operations and the disposition of the resulting byproduct material to achieve
the requirements and objectives set forth in Appendix A of 10 CFR Part 40. Each such
application has demonstrated how the requirements and objectives set forth in Appendix A of 10
CFR Part 40 have been addressed. Issuance of the License in 1980 and renewals in 1985 and
1997 by NRC attest to the fact that such requirements have been satisfied.
Refer also to the evaluation under 10CFR40.26(C)(2): General License (refer to pages 16 and 17,
above).
The written mill specifications relating to milling operations and the disposition of the resulting
byproduct material prepared to achieve the requirements and objectives set forth in Appendix A
of 10 CFR Part 40 are contained in Sections 4.0 and 5.0 of the 2007 License Renewal
Application and in Sections 3.0 and 4.0 of the 1992 License Renewal Application. NRC approval
of those specifications is evidenced by License Condition 9.3 of the License. Those
specifications are currently being reviewed by the Executive Secretary as part of the 2007
License Renewal Application review process.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents demonstrate
that the requirements of UAC R313-24-4 that invokes the requirements of 10CFR40.31(h) have
been satisfied, as they involve Cell 4B.
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10CFR40.61: RECORDS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40.61:
“(a) Each person who receives source or byproduct material pursuant to a license issued
pursuant to the regulations in 10CFR40 shall keep records showing the receipt, transfer, and
disposal of this source or byproduct material as follows:
(1) The licensee shall retain each record of receipt of source or byproduct material as
long as the material is possessed and for three years following transfer or disposition of the
source or byproduct material.
(2) The licensee who transferred the material shall retain each record of transfer or
source or byproduct material until the Executive Secretary terminates each license that
authorizes the activity that is subject to the recordkeeping requirement.
(3) The licensee shall retain each record of disposal of source or byproduct material until
the Executive Secretary terminates each license that authorizes the activity that is subject to the
recordkeeping requirement.
(4) If source or byproduct material is combined or mixed with other licensed material
and subsequently treated in a manner that makes direct correlation of a receipt record with a
transfer, export, or disposition record impossible, the licensee may use evaluative techniques
(such as first-in-first-out), to make the records that are required by 10CFR40 account for 100
percent of the material received.:
(b) The licensee shall retain each record that is required by the regulations in 10CFR40 or by
license condition for the period specified by the appropriate regulation or license condition. If a
retention period is not otherwise specified by regulation or license condition, each record must
be maintained until the Executive Secretary terminates the license that authorizes the activity
that is subject to the recordkeeping requirement.”
SAFETY EVALUATION:
The mill has been operating since 1980 subject to and in compliance with the requirements of 10
CFR 40.61. The construction and operation of Cell 4B will not affect the application of these
existing requirements to the mill, which requirements will continue to be met. Records of Cell
4B construction, tailings and wastewater placement, and other operational activities conducted in
Cell 4B will be maintained in accordance with requirements specified in the Ground Water
Discharge Permit. Commitments the Licensee has previously made in licensing actions by the
NRC and the Division, when applied to the construction and operation of Cell 4B, will satisfy
applicable requirements.
Refer also to the evaluation under 10CFR40.26(C)(2): General License (refer to pages 16 and 17,
above).
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Direct requirements of the applicable regulations, such as the time period for which records must
be retained, apply to the entire mill facility, and need not be repeated or reflected in the Cell 4B
procedures.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40.61, as they involve
Cell 4B.

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10CFR40.65(A)(1): EFFLUENT MONITORING REPORTING REQUIREMENTS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40.65(a)(1): “Each licensee
authorized to possess and use source material in uranium milling … shall . . . within 60 days
after January 1 and July 1 of each year thereafter, submit a report to the Executive Secretary;
which report must specify the quantity of each of the principal radionuclides released to
unrestricted areas in liquid and in gaseous effluents during the previous six months of operation,
and such other information as the Executive Secretary may require the licensee to estimate
maximum potential annual radiation doses to the public resulting from effluent releases. If
quantities of radioactive materials released during the reporting period are significantly above
the licensee's design objectives previously reviewed as part of the licensing action, the report
shall cover this specifically. On the basis of such reports and any additional information the
Executive Secretary may obtain from the licensee or others, the Executive Secretary may from
time to time require the licensee to take such action as the Executive Secretary deems
appropriate.”
SAFETY EVALUATION:
The Licensee has implemented an environmental monitoring and reporting system, including
semi-annually documenting liquid and gaseous effluents from the facility. The requirements for
this monitoring program are mandated under existing License Condition 11.2.
Refer also to the evaluation under 10CFR40.26(C)(2): General License (refer to pages 16 and 17,
above).
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40.65(a)(1), as they
involve Cell 4B.
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10CFR40 INTRODUCTION: CAPACITY OF TAILINGS OR WASTE SYSTEMS OVER
THE LIFETIME OF MILL OPERATIONS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40. Appendix A, Introduction:
“The specifications must be developed considering the expected full capacity of tailings or waste
systems and the lifetime of mill operations. Where later expansions of systems or operations may
be likely (for example, where large quantities of ore now marginally uneconomical may be
stockpiled), the amenability of the disposal system to accommodate increased capacities without
degradation in long-term stability and other performance factors must be evaluated .”
SAFETY EVALUATION:
While proposed Cell 4B has not yet been constructed, it was contemplated, described, and
assessed in the original License application to the NRC, being a critical component of the facility
design and evaluated as part of the FES (NRC 1979). Initial environmental analyses and the
License contemplated six tailings cells that would contain approximately 11 million tons of
tailings solids, which would be the tailings resulting from 15 years of mill operations at full
capacity (see Section 3.2.4.7 of NRC 1979 and Section 3.4 in both Appendices H and I of D&M
1978). These are evaporation pond Cell 1-I (now referred to as Cell 1), a second evaporation
pond (Cell I-E), which has not been constructed, and a series of 80-acre cells, including Cells 2,
3, 4, and 5 (see Figure 3.4 of NRC, 1978). To date, Cells 2 and 3 (80 acres each) and half of Cell
4 (Cell 4A, 40 acres) have been constructed. Construction of Cell 4B (area of floor and interior
slopes of Cell 4B will encompass approximately 40 acres) will consume the second 40 acres of
the previously authorized 80 acre Cell 4 footprint, but will not exceed the total footprint
contemplated in the original License application. Cell 4B would have a maximum capacity of
about 1.9 million cubic yards of tailings material storage (as measured below the required 3-foot
freeboard).
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40. Appendix A,
Introduction, as they involve Cell 4B.
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10CFR40 APPENDIX A, INTRODUCTION: ALTERNATIVE REQUIREMENTS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40. Appendix A, Introduction:
“Licensees or applicants may propose alternatives to the specific requirements in this appendix.
The alternative proposals may take into account local or regional conditions, including geology,
topography, hydrology, and meteorology. The Executive Secretary may find that the proposed
alternatives meet the Executive Secretary‘s requirements if the alternatives will achieve a level
of stabilization and containment of the sites concerned, and a level of protection for public
health, safety, and the environment from radiological and nonradiological hazards associated
with the sites, which is equivalent to, to the extent practicable, or more stringent than the level
which would be achieved by the requirements of this Appendix and the standards promulgated by
the Utah Administrative Code, Rule R317-6, Ground Water Quality Protection.”
SAFETY EVALUATION:
Proposed Cell 4B has been designed and will be constructed and operated in accordance with all
applicable regulations, permits and licenses. Beyond the more specific requirements and Permit /
License conditions imposed by the State of Utah, the Licensee has proposed no alternatives to
the specific requirements in 10 CFR Part 40, Appendix A in the design, construction, or
operation of Cell 4B.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40, Appendix A,
Introduction, as they involve Cell 4B.

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10CFR40 APPENDIX A, CRITERION 1: PERMANENT ISOLATION WITHOUT
ONGOING MAINTENANCE
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40 Appendix A, Criterion 1: “The
general goal or broad objective in siting and design decisions is permanent isolation of tailings
and associated contaminants by minimizing disturbance and dispersion by natural forces, and to
do so without ongoing maintenance. For practical reasons, specific siting decisions and design
standards must involve finite times (e.g., the longevity design standard in Criterion 6). The
following site features which will contribute to such a goal or objective must be considered in
selecting among alternative tailings disposal sites or judging the adequacy of existing tailings
sites:
• Remoteness from populated areas;
• Hydrologic and other natural conditions as they contribute to continued immobilization and
isolation of contaminants from ground-water sources; and
• Potential for minimizing erosion, disturbance, and dispersion by natural forces over the long
term.
The site selection process must be an optimization to the maximum extent reasonably achievable
in terms of these features.
In the selection of disposal sites, primary emphasis must be given to isolation of tailings or
wastes, a matter having long-term impacts, as opposed to consideration only of short-term
convenience or benefits, such as minimization of transportation or land acquisition costs. While
isolation of tailings will be a function of both site and engineering design, overriding
consideration must be given to siting features given the long-term nature of the tailings hazards.
Tailings should be disposed of in a manner that no active maintenance is required to preserve
conditions of the site.”
SAFETY EVALUATION:
The NRC has evaluated and accepted the natural site at which the White Mesa facility is located
in its review of the original License application. The initial NRC evaluation, as well as
evaluations of subsequent License renewal applications, have involved consideration of all
tailings management (impoundment) areas, including the area of proposed Cell 4B. Thus,
suitability of the existing site is beyond the appropriate scope of this evaluation. Because of the
climatic conditions at the mill site, potential surface water inflows are typically very small and
easily diverted and managed by engineering design, without massive diversion structures.

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Notwithstanding the above, during review of the License renewal application the Executive
Secretary will require the Licensee to examine certain other criteria related to isolation of the
tailings, including engineering design of the final cover system and final drainage systems for
final reclamation of the tailings management cells, including Cell 4B, and to prepare and submit
a final Reclamation Plan, together with associated final Specifications for Reclamation, for the
Mill Facility. Elements addressed in the final Reclamation Plan will include, but not be limited
to, the following:
• The ability of the cover system to respond without damage to whatever settlement and
differential settlement may occur following construction of the cover;
• Stability against intermixing of cover layers with different size gradations;
• Protection provided to clay layers, if applicable, from freeze-thaw damage and
desiccation;
• Protection provided against wind and surface water erosion;
• Protection of the radon barrier against biointrusion by deep-rooted plants and burrowing
animals; and
• The Division will review the final design of drainage systems included for the final
reclamation of the tailings management cells, including Cell 4B, as provided in the final
Reclamation Plan that the Division will require the Licensee to submit, to assess design
features for transitioning to, and conforming with, the natural surrounding landscape.
The cover design will also provide for reduction of all perimeter slopes of the final cover
closed tailings management cells to 5h:1v, or less, to minimize the potential for active
management and repair of the slopes to be required.
The Licensee is currently operating Cell 4A under the Cell 4A BAT Monitoring, Operations and
Maintenance Plan (UDRC 2008a). That Plan describes the acceptable operational methods for
discharge into the cell of tailing solids and solution from pre-determined locations around the
perimeter of the cell. The final tailings elevation will be less than the top of the flexible
membrane liner (FML). Once the tailings solids reach the prescribed elevation, they will be
contoured to final grades and the dewatering process will begin, concurrently with placement of
the initial platform fill. Due to the proposed approval of Cell 4B, certain changes are needed in
the existing BAT Monitoring, Operations and Maintenance Plan. These are mandated by the
Permit, and will be approved prior to final approval for use of Cell 4B and prior to receiving
liquids and tailings.
Installation of the final reclamation cap will be in accordance with the final Reclamation Plan
approved at the time of cell closure. Currently the November 24, 2009 Reclamation Plan
submittal (DUSA 2009b) is under Division review and is part of the License Renewal
Application. That final Reclamation Plan, once approved, is intended to prepare the facility so
that it can be transferred to DOE for perpetual care and maintenance. DOE’s perpetual care and
maintenance will be funded by the Licensee's Long Term Care fund.
With respect to Cell 4B, prior to placement of the approved cover, free water will be evaporated
or pumped from the cell and the tailings will be graded to ensure that the final tailings elevations
and contours are according to the approved design. The initial layer of the reclamation cap, or
platform fill, will be installed over the contoured tailings. This activity may take place in
increments as distinct portions of the cell are filled. The purposes of the platform fill are to
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minimize the amount of radon emanating from the tailings sands; to minimize the potential for
windblown tailings; and to place overburden material to create a surcharge on the placed tailings
to aid in dewatering of the tailings.
Once free water has been evaporated or pumped from Cell 4B, the slimes drain system will be
actively pumped to remove as much solution as possible from the tailings sands and slimes.
Dewatering of the tailings will allow the material to consolidate, reducing potential differential
settlement after final cover placement, and reducing the potential for liquefaction of the tailings
during possible seismic events. The slimes drain design and dewatering modeling is presented in
the Revised Cell 4B Design Report, Appendix D (DUSA 2009a). Based on these calculations,
DUSA predicted that approximately 5.5 years of de-watering operations at Cell 4B will provide a
steady-state condition of 1 foot of leachate over the cell’s flexible membrane liner at the time of
closure. All these factors will help to ensure that the final cover installation is maintenance free
once the site is turned over to DOE for long term surveillance and monitoring.
The geotechnical stability of the tailings impoundment, slope stability, liquefaction potential and
settlement are addressed in Appendix D of the November 24, 2009 Reclamation Plan submittal
(DUSA 2009b), which is currently under Division review. The liquefaction potential of the
tailings solids was evaluated in Attachment E to the November 24, 2009 Reclamation Plan
submittal (DUSA 2009b), which is currently under Division review. Any additional evaluations
relating to embankment stability will be presented in the updated, final Reclamation Plan once it
is prepared and submitted for review under the License Renewal Application process. The
Division will review any such additional evaluations to confirm that these evaluations satisfy
applicable requirements. If necessary, the Division will also impose additional License
conditions to ensure that all requirements applicable to Cell 4B are satisfied as part of its final
closure.
FINDING:
As described above, the Division will require the Licensee to submit a final Reclamation Plan,
and revised Specifications for Reclamation, with appropriate required supporting analyses and
calculations, as part of the License Renewal Application process.
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, in combination with the proposed License condition indicate that
the requirements of UAC R313-24-4 that invokes the requirement 10CFR40, Appendix A,
Criterion 1 will yet be satisfied prior to placing Cell 4B into service.

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10CFR40, APPENDIX A, CRITERION 2: PROLIFERATION
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40 Appendix A, Criterion 2: “To
avoid proliferation of small waste disposal sites and thereby reduce perpetual surveillance
obligations, byproduct material from in situ extraction operations, such as residues from
solution evaporation or contaminated control processes, and wastes from small remote above
ground extraction operations must be disposed of at existing large mill tailings disposal sites;
unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite
disposal is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh
the benefits of reducing the perpetual surveillance obligations.”
SAFETY EVALUATION:
The mill's tailings management system has been designed as a large permanent waste disposal
site, which can help to reduce proliferation of small sites on a national level, and thereby reduce
perpetual surveillance obligations for the Federal government. This includes DUSA acceptance
for permanent disposal, byproduct material from in situ leach (ISL) operations from outside of
Utah that are licensed by the NRC or a corresponding Agreement State. License Condition 10.5
permits the mill to dispose of such ISL byproduct material, subject to specified conditions. Such
disposal has historically and is currently done at the White Mesa mill.
License Condition 10.5.E requires the Licensee to submit for Executive Secretary approval a
revised written Standard Operating Procedure (SOP) for ISL disposal on or before December 1,
2010. The revised SOP shall describe the documentation required for ISL disposal, which is to
include several items.
FINDING:
The revised SOP to be submitted by the Licensee as required by License Condition 10.5.E. is to
include several items, mentioned below, that will protect tailings cell liners from damage, as well
as increase the compaction and organization of the ISL material disposal areas.
A. These items are specified to include that the ISL material disposal area must be
located on a tailings beach area of the disposal cell or on an area of the cell that is
underlain by tailings sands;
B. The elevation of the material disposal area will not exceed the plane or grade of
the elevations of the uppermost flexible membrane liner of the tailings cell; ISL
byproduct material will be segregated from any mill material and equipment and
other ISL byproduct material sources;
C. Absence of void space inside barrels disposed, including physical verification
before disposal; and
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D. Detailed engineering drawings which demonstrate there is at least 4 feet of
tailings sands under the bottom of each disposal area; and the bottom of each
disposal area is located at least 12 feet from the sides or dikes of the tailings cell.
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40, Appendix A,
Criterion 2, as they involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 3: PLACEMENT BELOW GRADE
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 3: “The
"prime option" for disposal of tailings is placement below grade, either in mines or specially
excavated pits (that is, where the need for any specially constructed retention structure is
eliminated). The evaluation of alternative sites and disposal methods performed by mill
operators in support of their proposed tailings disposal program (provided in applicants'
environmental reports) must reflect serious consideration of this disposal mode. In some
instances, below grade disposal may not be the most environmentally sound approach, such as
might be the case if a ground-water formation is relatively close to the surface or not very well
isolated by overlying soils and rock. Also, geologic and topographic conditions might make full
below grade burial impracticable: For example, bedrock may be sufficiently near the surface
that blasting would be required to excavate a disposal pit at excessive cost, and more suitable
alternative sites are not available. Where full below grade burial is not practicable, the size of
retention structures, and size and steepness of slopes associated exposed embankments must be
minimized by excavation to the maximum extent reasonably achievable or appropriate given the
geologic and hydrologic conditions at a site. In these cases, it must be demonstrated that an
above grade disposal program will provide reasonably equivalent isolation of the tailings from
natural erosional forces.”
SAFETY EVALUATION:
The first stage construction of the Mill's Tailings Management System, consisting of Cell 1
(originally designated Cell 1-I), Cell 2, and the Cell 2 Safety Dike (Cell 3 Dike) was authorized
by NRC License Amendment 1, to SUA-1358, on October 12, 1979. The authorization referred
to design documents, questions and responses during the review of the design. A copy of the
License Amendment was included in Attachment D to DUSA 2010a.
Construction of the embankments and liner systems for the Initial Phase and Second Phase
(including Cell 1, Cell 2, Cell 3, and the Cell 4 dike) was authorized by NRC License
Amendment 10, to SUA-1358, on February 10, 1982. The authorization referred to design
documents, questions and responses during the review of the design, and was essentially a
revision to the earlier construction authorization of the first stage construction. A copy of that
License amendment is included in Attachment D to DUSA 2010a.
Construction and operation of Cell 4A was authorized by NRC License Amendment 20, to SUA-
1358, on March 1, 1990. The authorization referred to design documents, questions and
responses during the review of the design, and was essentially a revision to the earlier
construction authorization of the first stage construction. The authorization also set maximum
solution elevations for Cell 1, Cell 3 and Cell 4A. A copy of that License amendment is included
in Attachment D to UDSA 2010a.
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Cell 4B will be excavated and constructed in a manner similar to that used for existing Cells 1, 2,
3 and 4A. It is anticipated that some blasting will be required in order to construct Cell 4B.
Existing cells are partially below grade because of constraints imposed by the natural topography
and bedrock conditions at the site. All tailings cells at the site are situated in a natural swale,
thanks to the presence of minor natural north-south ridges that were located immediately west
and east of the tailings cell locations. During construction, the tailings cells have been and will
be excavated to the top of and partially within bedrock. This results in the north and east dikes of
the cells being at or near surface grade. The southern dike of the southern-most cells (Cells 4A
and 4B) has and will have an above-grade dike. Similarly, the western dike of Cell 4B will be
partially above grade.
Geologic and topographic conditions make full below grade burial impracticable for two reasons.
First, bedrock is sufficiently near the surface that blasting, at excessive cost, would be required to
fully excavate a cell. Second, because of the natural topography that grades to the southwest,
surface grade burial at the southwest corners of the cells would require much deeper sub-grade
burial at the northeast corners. Previously, the NRC determined that more suitable alternative
sites are not available. However, the size and steepness of the slopes associated with the exposed
embankments of existing cells are, and Cell 4B will be, limited by excavation to the maximum
extent reasonably achievable or appropriate depth given the geologic and hydrologic conditions
at the site. As required by 10 CFR Part 40, Appendix A, Criterion 6, the cells, including Cell 4B
have been designed to provide reasonable assurance that radiological hazards will be suitably
controlled for 1,000 years, to the extent reasonably achievable, and, in any case, for at least 200
years.
FINDING:
The information submitted by the Licensee in the Cell 4B ER and related documents satisfies the
requirements of UAC R313-24-4 that invokes the requirements of 10CFR40, Appendix A,
Criterion 3, as they involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 4: LOCATION AND DESIGN REQUIREMENTS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 4: “The
following site and design criteria must be adhered to whether tailings or wastes are disposed of
above or below grade.
(a) Upstream rainfall catchment areas must be minimized to decrease erosion potential and the
size of the floods which could erode or wash out sections of the tailings disposal area.
(b) Topographic features should provide good wind protection.
(c) Embankment and cover slopes must be relatively flat after final stabilization to minimize
erosion potential and to provide conservative factors of safety assuring long-term stability. The
broad objective should be to contour final slopes to grades which are as close as possible to
those which would be provided if tailings were disposed of below grade; this could, for example,
lead to slopes of about 10 horizontal to 1 vertical (10h:1v) or less steep. In general, slopes
should not be steeper than about 5h:1v. Where steeper slopes are proposed, reasons why a slope
less steep than 5h:1v would be impracticable should be provided, and compensating factors and
conditions which make such slopes acceptable should be identified.
(d) A full self-sustaining vegetative cover must be established or rock cover employed to reduce
wind and water erosion to negligible levels.
Where a full vegetative cover is not likely to be self-sustaining due to climatic or other
conditions, such as in semi-arid and arid regions, rock cover must be employed on slopes of the
impoundment system. The … (Executive Secretary) will consider relaxing this requirement for
extremely gentle slopes such as those which may exist on the top of the pile.
The following factors must be considered in establishing the final rock cover design to avoid
displacement of rock particles by human and animal traffic or by natural process, and to
preclude undercutting and piping:
• Shape, size, composition, and gradation of rock particles (excepting bedding material
average particles size must be at least cobble size or greater);
• Rock cover thickness and zoning of particles by size; and
• Steepness of underlying slopes.
Individual rock fragments must be dense, sound, and resistant to abrasion, and must be free from
cracks, seams, and other defects that would tend to unduly increase their destruction by water
and frost actions. Weak, friable, or laminated aggregate may not be used.
Rock covering of slopes may be unnecessary where top covers are very thick ( or less); bulk
cover materials have inherently favorable erosion resistance characteristics; and, there is
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negligible drainage catchment area upstream of the pile and good wind protection as described
in points (a) and (b) of this Criterion.
Furthermore, all impoundment surfaces must be contoured to avoid areas of concentrated
surface runoff or abrupt or sharp changes in slope gradient. In addition to rock cover on slopes,
areas toward which surface runoff might be directed must be well protected with substantial rock
cover (rip rap). In addition to providing for stability of the impoundment system itself, overall
stability, erosion potential, and geomorphology of surrounding terrain must be evaluated to
assure that there are not ongoing or potential processes, such as gully erosion, which would lead
to impoundment instability.
(e) The impoundment may not be located near a capable fault that could cause a maximum
credible earthquake larger than that which the impoundment could reasonably be expected to
withstand. As used in this criterion, the term "capable fault" has the same meaning as defined in
section III(g) of Appendix A of 10 CFR Part 100. The term "maximum credible earthquake"
means that earthquake which would cause the maximum vibratory ground motion based upon an
evaluation of earthquake potential considering the regional and local geology and seismology
and specific characteristics of local subsurface material.
(f) The impoundment, where feasible, should be designed to incorporate features which will
promote deposition. For example, design features which promote deposition of sediment
suspended in any runoff which flows into the impoundment area might be utilized; the object of
such a design feature would be to enhance the thickness of cover over time.”
SAFETY EVALUATION:
In its initial licensing process and subsequent License renewal reviews, the NRC has reviewed
and accepted site characteristics, including upstream rainfall catchment area, wind protection,
and proximity to capable faults.
Seismic Hazards - DUSA provided a Technical Memorandum (Tetra Tech 2010) presenting an
updated seismic hazard evaluation study that includes: (1) a summary of seismic studies done
through 2006 to develop a design peak ground acceleration (PGA) for the design of disposal
cells and for use during the operational period of those cells; (2) a review of updated data
(through January 2010) on seismic activity within 200 miles of the White Mesa mill site; and (3)
derivation of an updated predicted peak Horizontal Ground Acceleration (Peak HGA) value,
based on a 10,000-year return period, for use in the final disposal closure design effort for
proposed Cell 4B. The study addressed updated published information, including the most
recent USGS National Seismic Hazard Maps. The study also considered other studies, including
2008 Deaggregation data, Next Generation Attenuation (2007) Project information, and
consideration of the attenuation relationship of Campbell and Bozorgnia (2007).
Results of the study indicated that Peak HGA value of 0.15 g is appropriate for use in evaluating
the stability of structures proposed in the final closure design of site facilities, including Cell 4B.
The study concluded that, for a pseudo-static analysis, a value of 2/3 the Peak HGA, or 0.1 g, is
appropriate, which is consistent with International Building Code (IBC) guidelines (IBC 2006),
and with guidance contained in DOE 1989. The value of 0.1 g is consistent with the value of
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design acceleration used in previous stability analyses done for the site. The Division has
reviewed and found this updated seismic study to be acceptable.
Cover System Slopes - All slopes on the reclaimed mill site and tailings are 5h:1v or less
(gentler). As one of several conditions in the Permit (Part I.H.2), an infiltration analysis of the
tailings cover and re-design of the cover for better performance is in progress for all disposal
cells at the site. It is anticipated that the final revised cover design will address surface water
management issues and other design improvements associated with the addition of Cell 4B.
To ensure that the State’s interests are adequately protected with regards to Cell 4B, as stated in
License Condition 9.11, the Division will require submission and approval of a revised, final
Reclamation Plan and revised Specifications for Reclamation (Attachment A to the Reclamation
Plan) that include the final cover design selected for implementation at the White Mesa Mill site,
including Cell 4B, and required supporting analyses. The revised Plan and revised Specifications
for Reclamation are to be submitted and receive Executive Secretary approval before disposal of
any tailings in Cell 4B.
Cover Material Properties - Physical properties of the construction materials and the stability
of the Cells 1, 2, 3, and 4A impoundments are discussed in the November 24, 2009 Reclamation
Plan recently submitted by the Licensee and currently under separate review by the Division.
Physical properties and stability issues for Cell 4B will be addressed by the revised Reclamation
Plan required under License Condition 9.11. Potential alternative cover designs for all the
disposal cells are currently being reviewed by the Division for the facility in conjunction with the
Division’s review of an Infiltration and Contaminant Transport Study (see Permit, Part I.H.2). It
is possible that a future acceptable alternative design could reduce the quantity, or eliminate most
of the rip rap material needed for the final reclamation top slope.
The Licensee also provided information confirming that, based on the guidance contained in
NUREG-1623, rock from the potential Brown Canyon Site borrow site would not be acceptable
for use in areas of the White Mesa Site that the NRC would define as potentially “frequently
saturated” areas. In terms of the cover design now found in the currently approved Reclamation
Plan (Revision 3.0), this would include rock material for the base of the side slope areas of the
tailings cells. If volume requirements necessitated the use of a second source, additional testing
would need to be conducted on the Brown Canyon site. However, absent additional acceptable
test results, the Brown Canyon site will be rejected by the Executive Secretary as a potential
borrow source for rip rap in areas classified as "frequently saturated areas". As a result, the
Brown Canyon rock material could potentially be used in other areas not classified as "frequently
saturated areas". The revised cover design currently being evaluated under Part I.H.2 of the
Permit, may reduce the amount of rip rap material required, and therefore reduce the volumes
required from each of the designated source areas.
With regards to Cell 4B, it is assumed that the cover material will be specified in a similar
fashion as was already approved by the NRC in the Licensee’s Reclamation Plan, Rev. 3.0 (IUC
2000); under the assumption that the final cover system will be of a rock-armored design, similar
to that found in Attachment H of the November 24, 2009 Reclamation Plan submittal (DUSA
2009b). Said Attachment H presents the investigation and testing details for three potential
borrow sources for the rip rap material needed for the final reclamation cap. The Brown Canyon
site was found to be the least preferable of the sites, and also happens to be the second least
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accessible of the sites. For the cost estimate included as Attachment C to the November 24, 2009
Reclamation Plan submittal (DUSA 20090b), the North Pit was assumed. The original basis for
looking at several potential sites in the area was to ensure that sufficient quantities would be
available for the top surface as well as the side slopes and toe aprons.
Material characteristics of tailings material and cover soils proposed for use at the site are
described in D&M, 1978 and in Rev. 3.0, (IUC 2000) of the Reclamation Plan. Surface water
management, erosion protection design, and tailings cell cover design are described in
Attachment A and Attachment G of the November 24, 2009 Reclamation Plan submittal (DUSA
2009b). Analysis of freeze-thaw cycles on the radon barrier are included in the 1978 ER, and the
Reclamation Plan, Rev. 3.0 (IUC 2000). It is assumed that these characteristics are still included
in the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), and will be further
evaluated as part of the License Renewal process.
Identification of, and characteristics and performance of, materials to be used in the final cover
system design for the tailings management cells that include Cell 4B will be addressed when the
revised Reclamation Plan Revision 3.2, is submitted pursuant to License Condition 9.11.
Additional updates and possible changes to the cover system design may occur during Division
review of the November 24, 2009 Reclamation Plan submittal (DUSA 2009b). As described
above, the Division will require submission and approval of a revised Reclamation Plan, and
Revised Specifications for Reclamation, that include the final cover design selected for
implementation at the White Mesa Mill site, including Cell 4B, and supporting analyses.
Settlement / Movement Monitoring - Settlement monitors will be installed over areas of
tailings that have reached the final design grade for disposal cells 1, 2, 3, and 4A, as described in
the November 24, 2009 Reclamation Plan submittal (2009b). The vertical movement of these
monitors is evaluated during the placement of the initial platform fill and the dewatering of the
disposal cell. Final cover will be placed following dewatering of the placed tailings platform fill,
reducing the potential for differential settlement and cracking of the radon barrier. Settlement
due to earthquake-induced liquefaction of the tailings solids and the potential impact on the cell
cover is discussed in Attachment E to the November 24, 2009 Reclamation Plan submittal
(DUSA 2009b), currently under Division review as a part of License renewal process.
Additionally, as described above, the Division will require submission and approval of a revised
Reclamation Plan, and Revised Specifications for Reclamation, that include the final cover
design selected for implementation at the White Mesa Mill site, including Cell 4B. The
November 24, 2009 Reclamation Plan submittal (DUSA 2009b) will be reviewed by the
Executive Secretary as part of the ongoing License Renewal process.
Further, the Division will incorporate new License conditions (Condition 11.7 and 11.8)
requiring the Licensee to submit, for Division approval, written Settlement Monitoring and
Movement (Displacement) Monitoring Standard Operating Procedures for monitoring vertical
settlement in the tailings management cell cover systems and monitoring potential vertical and
horizontal movements in the constructed dike portions of the tailings management cells, as
further described below.
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FINDING:
As described above, on a separate track the Division has added a new license condition (License
Condition 9.11) to ensure that before Cell 4B is put into service that an adequate cover design,
and updated Reclamation Plan (Revision 3.2) and updated Specifications for Reclamation are
provided and approved by the Executive Secretary. Further, at some future time, and as part of
an ongoing License Renewal process this Reclamation Plan may be amended. .
The Division will require submission and approval of a Revision 3.2 of the Reclamation Plan and
revised Specifications for Reclamation that include information on final cover design and final
drainage system design to support updating of the cost estimate for completing reclamation
activities at the White Mesa Mill site, including incorporating cover design requirements for Cell
4B that are similar to those already approved for Cell 4A (i.e., Revision 3.1 of the Reclamation
Plan). This revised Plan and revised Specifications for Reclamation are to be submitted and
receive Executive Secretary approval before disposal of any tailings in Cell 4B.
Additional License Condition 11.7 has been added to require the Licensee to submit, for
Executive Secretary approval, a written Settlement Monitoring Standard Operating Procedure
(SOP)_ that describes methods for monitoring vertical settlement in the tailings management cell
cover systems. A new License Condition 11.8 has been added to require the Licensee to submit
for review and approval a second SOP for monitoring potential vertical and horizontal
movements in the constructed dike portions of the tailings management cells. The purpose for
both of the SOPs is to record and document cover system and dike settlement and displacement
monitoring data and comparing such data to previous data to track potential movement and
settlement.
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, in combination with the proposed License Conditions, and with the
requirement by the Division that the Licensee submit a revised, final Reclamation Plan, and
Revised Specifications for Reclamation for Executive Secretary approval, indicate that the
requirements of UAC R313-24-4 that invokes the requirement 10CFR40, Appendix A, Criterion 4
will yet be satisfied prior to placing Cell 4B into service.

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10CFR40, APPENDIX A, CRITERION 5A(1): GROUND-WATER PROTECTION
STANDARDS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 5A(1):
“The primary ground-water protection standard is a design standard for surface impoundments
used to manage uranium and thorium byproduct material. Unless exempted under paragraph
5A(3) of this criterion, surface impoundments (except for an existing portion) must have a liner
that is designed, constructed, and installed to prevent any migration of wastes out of the
impoundment to the adjacent subsurface soil, ground water, or surface water at any time during
the active life (including the closure period) of the impoundment. The liner may be constructed of
materials that may allow wastes to migrate into the liner (but not into the adjacent subsurface
soil, ground water, or surface water) during the active life of the facility, provided that
impoundment closure includes removal or decontamination of all waste residues, contaminated
containment system components (liners, etc.), contaminated subsoils, and structures and
equipment contaminated with waste and leachate. For impoundments that will be closed with the
liner material left in place, the liner must be constructed of materials that can prevent wastes
from migrating into the liner during the active life of the facility.”
SAFETY EVALUATION:
As detailed in the Cell 4B Design Report (DUSA 2009a), Cell 4B has been designed with two
synthetic liners, a leak detection layer, and geosynthetic clay liner system, using Best Available
Technology ("BAT"), that will prevent or minimize migration of wastes out of Cell 4B to the
adjacent subsurface soil, ground water, or surface water at any time during the active life
(including closure period) of the cell. Further, Cell 4B has been designed to be closed with the
liner system left in place. As a result, the liner system will be constructed of materials that can
prevent or minimize wastes from migrating into the liner during the active life of the facility. It
is the intent of the Division to approve the liner system proposed for Cell 4B, based on recent
recommendations of the URS Corporation (URS 2009).
The design approach for the liner system to be incorporated into Cell 4B is identical to that used
to design the liner system for Cell 4A, previously approved by the Division (UDRC 2008b).
Final construction of Cell 4B will be documented by DUSA in a report that will be submitted for
Executive Secretary review and approval before Cell 4B is put into service (see Permit, Part
I.H.9).
Refer also to the evaluation under Appendix A, Criterion 3: Placement Below Grade, (refer to
pages 29 and 30 above).
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted indicate that the requirements of UAC R313-24-4 that invokes the
requirement 10CFR40, Appendix A, Criterion 5A(1) have been met.
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10CFR40, APPENDIX A, CRITERION 5A(2): LINER
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 5A(2):
“The liner required by paragraph 5A(1) above must be:
(a) Constructed of materials that have appropriate chemical properties and sufficient strength
and thickness to prevent failure due to pressure gradients (including static head and external
hydrogeologic forces), physical contact with the waste or leachate to which they are exposed,
climatic conditions, the stress of installation, and the stress of daily operation;
(b) Placed upon a foundation or base capable of providing support to the liner and resistance to
pressure gradients above and below the liner to prevent failure of the liner due to settlement,
compression, or uplift; and
(c) Installed to cover all surrounding earth likely to be in contact with the wastes or leachate.”
SAFETY EVALUATION:
On September 17, 2008, after submittal of an As-Built Report, the Executive Secretary
authorized the use of the relined Tailings Cell 4A. The relining was completed in accordance
with the previously approved Cell 4A Lining System Design Report. A copy of the approval was
included in Attachment D of the Licensee’s responses to Round 2 interrogatories.
Cell 4B has also been designed to utilize current BAT, as approved by the Executive Secretary
(URS 2009). This means that Cell 4B will be constructed of materials that have appropriate
chemical properties and sufficient strength and thickness to prevent failure due to pressure
gradients (including static head and external hydrogeologic forces); physical contact with the
waste or leachate to which they are exposed; climatic conditions; the stress of installation; and
the stress of daily operation.
Further, the Cell 4B liner system will be placed upon a foundation or base capable of supporting
the liner and resisting pressure gradients above and below the liner to prevent failure of the liner
due to settlement, compression, or uplift.
Finally, the Cell 4B liner system will cover all surrounding earth likely to be in contact with the
wastes or leachate.
The Cell 4B liner system will be virtually identical to the Cell 4A liner system, which has
previously been reviewed and approved by the Executive Secretary (URS 2009). The physical,
chemical and radiological nature of the tailings to be disposed of in Cell 4B will not be
significantly different from the tailings to be disposed of in Cell 4A.
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FINDING:
The information contained in the proposed engineering design and construction specifications,
and the Cell 4B Environmental Report and other relevant documents the Applicant has submitted
indicate that the requirements of UAC R313-24-4 that invokes the requirement 10CFR40,
Appendix A, Criterion 5A(2) have been met.
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10CFR40, APPENDIX A, CRITERION 5A(4): PREVENT OVERTOPPING
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 5A(4):
“A surface impoundment must be designed, constructed, maintained, and operated to prevent
overtopping resulting from normal or abnormal operations, overfilling, wind and wave actions,
rainfall, or run-on; from malfunctions of level controllers, alarms, and other equipment; and
from human error.”
SAFETY EVALUATION:
On September 17, 2008, the Executive Secretary authorized the use of the relined Tailings Cell
4A. The relining was completed in accordance with the previously approved Cell 4A Lining
System Design Report. A copy of the approval is included in Attachment D. The approval also
included the Cell 4A Best Available Technology, Operations and Maintenance Plan which
included a calculation for measuring the acceptable freeboard. A minimum freeboard of 3.0 feet
is specified based on State of Utah regulation, and the Plan also includes a provision for an
annual re-calculation of the Cell 4A freeboard based on area and elevation of tailings sands.
Freeboard limits for Cell 1 and Cell 3 (Cell 2 is currently full and does not have a pond area)
were initially set on the basis of the 1990 UMETCO Minerals Drainage Report, and approved by
NRC License Amendment 20, to SUA-1358, on March 1, 1990. The authorization referred to
design documents, questions and responses during the review of the design. The authorization
also set maximum solution elevations for Cell 1, Cell 3 and Cell 4A. The maximum elevations
for Cell 3 and Cell 4A were later modified by the Executive Secretary, by interim variance, to
take into account changes in available storage volumes. See the letter dated October 9, 2008
from the Licensee to the Executive Secretary, and the Executive Secretary's response of
November 20, 2008. Copies of those letters are attached as Attachment F to the Licensee’s
responses to Round 2 interrogatories.
Parts I.D.2 and I.D.6 of the Permit provide that under no circumstances shall the freeboard be
less than 3 feet in tailings cells 1, 3, and 4A. Likewise Part I.D.13 of the proposed Permit
mandates an equal freeboard requirement for Cell 4B. Cell 2 is filled with tailings solids, has an
interim cover, and does not contain a pool area. In addition, freeboard limits have been
calculated with an adequate level of protection against overtopping resulting from normal or
abnormal operations, overfilling, wind and wave actions, rainfall, run-on, malfunctions of level
controllers, alarms, and other equipment and from human error. Freeboard limits are set out in
License Condition 10.3 and in the Cell 4A BAT, Monitoring, Operations and Maintenance Plan.
License Condition 10.3.C prohibits the Licensee from discharging of any surface water,
stormwater or wastewater from Cells 3, 4A, and 4B other than through an Executive Secretary
authorized spillway structure. Currently, the approved Cell 4B design has no spillway for release
of such water from that impoundment to nearby adjoining native grades and elevations.
Consequently, Cell 4B is designed to retain all surface and stormwater contributions from all
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contributing upgradient locations. The restrictions in License Conditions 10.3.A and C do not
apply to solutions that are pumped from time to time from one cell to another for operational
purposes or to manage freeboard requirements.
Further, Part I.D.3(c) of the Ground Water Discharge Permit provides that 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 flexible membrane liner in the cell.
A letter dated August 7, 2009 from the Licensee to the Division, also addresses questions
relating to the Design Report and presents cell capacity calculations for Cell 4B as they relate to
the freeboard requirement for Cell 4B (DUSA 2009d).
FINDING:
The Division has modified the License to reference Cell 4B in License Condition 10.3. That
License Condition has also been modified to require that the discharge of any surface water,
stormwater, or wastewater from Cells 3, 4A, and 4B shall only be through an Executive
Secretary authorized spillway structure. This condition is designed to ensure that all surface
water / stormwater runoff that drains to areas occupied by Cells 3, 4A, and 4B, and all process
waters associated with the operation of Cells 3, 4A, and 4B, be contained within these three cells
without overtopping, unless, in the future, if construction of a new cell were to be authorized,
discharge from Cell 4B to that cell would be approved to occur, but only through an Executive
Secretary-authorized spillway structure. This condition behooves the Licensee take action to
assure that water does not overtop the specified tailings cell dikes, by constructing diversion
channels or other means, such as pumping between cells, as needed.
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, in combination with the modified License condition, indicate that
the requirements of UAC R313-24-4 that invokes the requirements contained in 10CFR40,
Appendix A, Criterion 5(A4) will yet be satisfied prior to placing Cell 4B into service.

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10CFR40, APPENDIX A, CRITERION 5A(5): DIKES
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 5A(5):
“When dikes are used to form the surface impoundment, the dikes must be designed, constructed,
and maintained with sufficient structural integrity to prevent massive failure of the dikes. In
ensuring structural integrity, it must not be presumed that the liner system will function without
leakage during the active life of the impoundment.”
SAFETY EVALUATION:
Refer to 10CFR40.26(C)(2)-02: General License. All dikes used to form Cell 4B have been
designed and will be maintained and monitored to verify that they maintain sufficient structural
integrity to prevent massive failure of the dikes. Division review has found the engineering
design and construction specifications for Cell 4B to be acceptable (URS 2009). Through
issuance of this SER, the proposed License and Permit, and related public participation, the
Division intends on approving the Cell 4B design.
In a related effort, the Licensee is currently in preparation of an infiltration and transport
modeling report under the requirements of Part I.H.2 of the Permit. Division review of this
future report may result in additional changes to the cover system design for all tailings cells at
the site.
FINDING:
The Division has incorporated a new License condition (Condition 11.8) to require that the
Licensee submit a Movement (Displacement) Monitoring Standard Operating Procedure (SOP)
by December 1, 2010, for Executive Secretary review and approval, to describe methods for
monitoring the dikes for movement and submittal of monitoring results to the Division. This
change to the License combined with information contained in the Cell 4B Environmental
Report and other relevant documents the Licensee has submitted, indicate that the requirements
of UAC R313-24-4 that invokes the requirement 10CFR40, Appendix A, Criterion 5A(5) will yet
be satisfied, as they involve Cell 4B.
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10CFR40, APPENDIX A, CRITERION 6(1): COVER AND CLOSURE AT END OF
MILLING OPERATIONS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(1):
“In disposing of waste byproduct material, licensees shall place an earthen cover (or approved
alternative) over tailings or wastes at the end of milling operations and shall close the waste
disposal area in accordance with a design which provides reasonable assurance of control of
radiological hazards to (i) be effective for 1,000 years, to the extent reasonably achievable, and,
in any case, for at least 200 years, and (ii) limit releases of radon-222 from uranium byproduct
materials, and radon-220 from thorium byproduct materials, to the atmosphere so as not to
exceed an average release rate of 20 picocuries per square meter per second (pCi/m2s) to the
extent practicable throughout the effective design life determined pursuant to (1)(i) of this
Criterion. In computing required tailings cover thicknesses, moisture in soils in excess of
amounts found normally in similar soils in similar circumstances may not be considered. Direct
gamma exposure from the tailings or wastes should be reduced to background levels. The effects
of any thin synthetic layer may not be taken into account in determining the calculated radon
exhalation level. If non-soil materials are proposed as cover materials, it must be demonstrated
that these materials will not crack or degrade by differential settlement, weathering, or other
mechanism, over long-term intervals.”
SAFETY EVALUATION:
The Division will require that the Licensee submit an updated Reclamation Plan, and Revised
Specifications for Reclamation (required by new License Condition 9.11) providing information
demonstrating that an adequate Reclamation Plan and adequate financial surety are in place
before it grants permission for the Licensee to use Cell 4B in support of operations. In a parallel,
but related effort, the Licensee is in the process of preparing an infiltration and transport
modeling report under the requirements of Part I.H.2 of the Permit. Division review of this
future report may result in changes / refinements to the final cover system design for all tailings
cells at the site.
Refer also to the evaluation under UAC R313-24-3D: Environmental Analysis - Long-Term
Impacts (refer to pages 13 through 15 above).
FINDING:
The Division will require that the Licensee submit an updated Reclamation Plan, and Revised
Specifications for Reclamation, for Cell 4B, and receive Executive Secretary approval before
Cell 4B is placed into service. This requirement in License Condition 9.11, combined with the
information contained in the Cell 4B Environmental Report and other relevant documents the
Applicant has submitted, and with the requirement by the Division that the Licensee
subsequently submit a revised, final Reclamation Plan and Revised Specifications for
Reclamation that describes the final cover design selected for implementation at the Mill
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Facility, indicate that the requirements of UAC R313-24-4 that invokes the requirements contained
in 10CFR40, Appendix A, Criterion 6(1) will yet be satisfied, prior to placing Cell 4B into
service.
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10CFR40, APPENDIX A, CRITERION 6(2): VERIFY EFFECTIVENESS OF FINAL
RADON BARRIER
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(2):
“As soon as reasonably achievable after emplacement of the final cover to limit releases of
radon-222 from uranium byproduct material and prior to placement of erosion protection
barriers or other features necessary for long-term control of the tailings, the licensee shall verify
through appropriate testing and analysis that the design and construction of the final radon
barrier is effective in limiting releases of radon-222 to a level not exceeding 20 pCi/m2s
averaged over the entire pile or impoundment using the procedures described in 40 CFR part 61,
appendix B, Method 115, or another method of verification approved by the Executive Secretary
as being at least as effective in demonstrating the effectiveness of the final radon barrier.”
SAFETY EVALUATION:
As discussed in Section 2.4.1 of the DUSA December 23, 2009 Response to Interrogatories on
the Cell 4B ER, in the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), the
Licensee presents a plan for reclamation of the site, as it exists today, prior to the construction of
Cell 4B. The Reclamation Plan will be further revised to incorporate the addition of Cell 4B
prior to acceptance and authorization for use of Cell 4B by the Division, see proposed License
Condition 9.11. Additional future changes to the Reclamation Plan may be made after Division
review and approval of an infiltration and transport study (the "Infiltration Study") of the tailings
cover and re-design of the cover for better performance, which is currently in progress.
The current tailings cover design proposed by the Licensee, and included as Appendix D to the
November 24, 2009 Reclamation Plan submittal (DUSA 2009b), is currently under Division
review. This version of the Plan includes an analysis of radon attenuation characteristics of the
cover, which appears to be designed to satisfy all radon emission standards. Section 3.3.2.1 of
said Reclamation Plan describes the modeling that was performed to demonstrate that the current
tailings cover design at Cells 1, 2, 3, and 4A will meet these regulatory criteria. At some future
date, the Executive Secretary will complete review of the November 24, 2009 Reclamation Plan
as a part of the License Renewal Application process. In this process it will be the burden of
both the Licensee and the Executive Secretary to determine if any changes to cover system
design and/or construction specifications satisfy all radon emission standards.
As required by UAC R3l3-24-4 [10 CFR Part 40, Appendix A, Criterion 6(2)], as soon as
reasonably achievable after emplacement of the final cover over Cell 4B, and prior to placement
of erosion protection barriers or other features necessary for long-term control of the tailings,
DUSA will verify through appropriate testing and analysis that the design and construction of the
final radon barrier is effective in limiting releases of radon-222 to a level not exceeding 20
pCi/m2s, averaged over the entire pile or impoundment using the procedures described in 40
CFR Part 61, Appendix B, Method 115, or another method of verification approved by the
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Executive Secretary as being at least as effective in demonstrating the effectiveness of the final
radon barrier.
FINDING:
The Division will require the Licensee to submit an updated Reclamation Plan, and Revised
Specifications for Reclamation for Cell 4B, and receive approval thereof before Cell 4B is placed
into service. Other changes to the Reclamation Plan may be made after Division review of the
November 24, 2009 submittal, as a part of the License renewal process. Ultimately, the
requirement to report the effectiveness of the radon barrier can only be satisfied once it is
constructed and its effectiveness measured, which is not at question in this amendment request
for construction of Cell 4B.
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, in combination with the above requirement, indicate that the
requirements of UAC R313-24-4 that invokes the requirements contained in 10CFR40, Appendix
A, Criterion 4 will yet be satisfied, as they involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 6(3): PHASED EMPLACEMENT OF FINAL
RADON BARRIER
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(3):
“When phased emplacement of the final radon barrier is included in the applicable reclamation
plan, the verification of radon-222 release rates required in paragraph (2) of this criterion must
be conducted for each portion of the pile or impoundment as the final radon barrier for that
portion is emplaced.”
SAFETY EVALUATION:
The Licensee provided information that the final reclamation of the tailings cells is planned as a
phased approach. The timing of placement of the final cover over the platform fill is based on the
physical condition of the tailings cell and management's decision on overall long range mill
operations and economics. Final Cell 4B cover design will be evaluated as a part of the revised
Reclamation Plan required by proposed License Condition 9.11.

The Licensee also stated that per 40 CFR Part 192 the EPA requires that a "uranium tailings
cover be designed to produce reasonable assurance that the radon-222 release rate would not
exceed 20 pCi/m2/sec for a period of 1,000 years to the extent reasonably achievable and in any
case for at least 200 years when averaged over the disposal area over at least a one year period"
(NRC, 1989). NRC regulations presented in 10CFR Part 40 (incorporated by reference into UAC
R313-24-4) also restrict radon flux to less than 20 pCi/m2/sec.

The Licensee also provided a description of the modeling that was performed to demonstrate that
the current tailings cover design will meet these regulatory criteria as described in Section
3.3.2.1 of the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), which is currently
under Division review. Section 3.3.2.2 of said Reclamation Plan also sets out actual radon flux
measurements through the temporary cover for Cells 2 and 3 from 2004 through 2008. Radon
flux rates over those years have all been lower than the regulatory standard, based solely on the
interim random fill cover that has been placed over portions of those cells. Despite these
promising recent radon measurements, it is unknown if the soil and moisture characteristics
found in the existing Cell 2 and 3 temporary cover will be representative of long-term
performance of the final cover system.

The Licensee also stated that a revised cover design for the Mill's tailings cells is currently being
developed. The Licensee indicated that the revised cover design evaluation will include a
demonstration that the revised cover design will also satisfy the regulatory radon emission
standards for the facility.

The Licensee has indicated that when the maximum amount of tailings has been placed in Cell
4B, all the free water will be evaporated or pumped from the cell and the tailings will be graded
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to ensure that the final tailings elevations and contours conform to the approved design. The
initial layer of the reclamation cap, the platform fill, will be installed over the contoured tailings.
This activity may take place in increments as distinct portions of the cell are filled, and therefore
may take several years to be fully complete, depending on the mill's operating schedule.

If the mill were operated at full capacity, the Licensee has indicated that Cell 4B could be filled
in 3 to 3.5 years. Realistically the Cell 4B operational period will be somewhat longer, as a
portion of the tailings from mill operations will also be placed in Cell 4A. The active cells will
be operated to maximize evaporation potential, while also bringing partial areas of a cell up to
final grade as rapidly as possible in order to reduce radon emanation by placing the platform fill
as soon as possible. The purposes of the platform fill are to minimize the amount of radon
emanating from the tailings; to minimize the potential for windblown tailings, and to place a
surcharge on the tailings to aid in dewatering. As platform fill is placed, settlement monitors will
be installed to record the consolidation and settlement of the tailings. A Standard Operating
Procedure (SOP) for this work is now required under new License Condition 11.7, which will
need to be submitted to the Executive Secretary on or before December 1, 2010.

The Licensee stated that once the cell is filled and the free water has been evaporated or pumped
from the cell, and the platform fill has been placed over the entire area, the slimes drain system
will be actively pumped to remove as much solution as possible from the tailings sands and
slimes. Dewatering of the tailings will allow the tailings sands and slimes to consolidate,
reducing the potential differential settlement after final cover placement, and reducing the
potential for liquefaction of the tailings during possible seismic events. The slimes drain design
and dewatering modeling is presented in the Revised Design Report, Appendix D (DUSA
2009a).

Based on calculations provided by the Licensee, the time required to dewater Tailings Cell 4B,
once the slimes drain pumping has started, and maintain a steady-state maximum head of 1.0 feet
in the tailings (as measured from the lowest point of upper flexible membrane liner) is about 5.5
years or less. Once the satisfactory degree of dewatering has been achieved and the settlement
monitors are showing little or no consolidation, the final layers of the reclamation cap can be
placed. The Licensee has indicated that placement of the final layers of cap material should take
less than one year.
FINDING:
The Division will incorporate a new license condition (Condition 9.11) to ensure that the existing
Reclamation Plan (Revision 3.0) is revised to incorporate cover design requirements for Cell 4B
that are similar to those already approved for Cell 4A. This revision will be named as Revision
3.2. As a part of the on-going License Renewal Application review process, the Division will
examine the November 24, 2009 Reclamation Plan submittal (DUSA 2009b) to determine if it is
adequate. If additional requirements are found to be necessary, the final Reclamation Plan may
be modified at a future date. This requirement, combined with the information contained in the
Cell 4B Environmental Report and other relevant documents the Applicant has submitted,
indicate that the requirements of UAC R313-24-4 that invokes the requirements contained
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10CFR40, Appendix A, Criterion 6(3) have been met or will yet be satisfied, as they involve Cell
4B.

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10CFR40, APPENDIX A, CRITERION 6(4): REPORT RADON BARRIER
EFFECTIVENESS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(4):
“Within ninety days of the completion of all testing and analysis relevant to the required
verification in paragraphs (2) and (3) of 10CFR40, Appendix A, Criterion 6, the uranium mill
licensee shall report to the Executive Secretary the results detailing the actions taken to verify
that levels of release of radon-222 do not exceed 20 pCi/m2s when averaged over the entire pile
or impoundment. The licensee shall maintain records until termination of the license
documenting the source of input parameters including the results of all measurements on which
they are based, the calculations and/or analytical methods used to derive values for input
parameters, and the procedure used to determine compliance. These records shall be kept in a
form suitable for transfer to the custodial agency at the time of transfer of the site to DOE or a
State for long-term care if requested.”
SAFETY EVALUATION:
As required by UAC R313-24-4 [10 CFR Part 40, Appendix A, Criterion 6(4)], within ninety
days of the completion of all testing and analysis relevant to the required verification in
paragraphs (2) and (3) of 10 CFR Part 40, Appendix A, Criterion 6, the Licensee will report to
the Executive Secretary the results detailing the actions taken to verify that levels of radon-222
released from the closed embankment do not exceed 20 pCi/m2s when averaged over the entire
pile or impoundment. The Licensee will maintain records until termination of the License
documenting the source of input parameters including the results of all measurements on which
they are based, the calculations and/or analytical methods used to derive values for input
parameters, and the procedure used to determine compliance. These records will be kept in a
form suitable for transfer to the custodial agency at the time of transfer of the site to the DOE or
the State for long-term care, if requested.
FINDING:
The Division will require that the Licensee submit an updated Reclamation Plan, and Revised
Specifications for Reclamation (License Condition 9.11), and that this plan be approved by the
Division before Cell 4B is placed into service. The information contained in the Cell 4B
Environmental Report and other relevant documents the Licensee has submitted indicate that the
requirements of UAC R313-24-4 that invokes the requirement 10CFR40, Appendix A, Criterion
6(4) will yet be satisfied, as they involve Cell 4B. The requirement to report the effectiveness of
the radon barrier will need to be satisfied once it is constructed and its effectiveness measured.
The Division will review the revised, final Reclamation Plan for Cell 4B to ensure that the
information needed to satisfy UAC R313-24-4, which invokes the requirement from 10CFR40,
Appendix A, Criterion 6(4), is included and is appropriate and complete. Reasonable assurances
have been provided in previous analyses that effective radon barriers can be constructed and
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commitments made to report the measured effectiveness of such a barrier. Nothing done or left
undone at this stage of the Cell 4B life cycle will preclude satisfying this requirement.

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10CFR40, APPENDIX A, CRITERION 6(5): ELEVATED RADIUM
CONCENTRATIONS IN COVER MATERIALS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(5):
“Near surface cover materials (i.e., within the top three meters) may not include waste or rock
that contains elevated levels of radium; soils used for near surface cover must be essentially the
same, as far as radioactivity is concerned, as that of surrounding surface soils. This is to ensure
that surface radon exhalation is not significantly above background because of the cover
material itself.”
SAFETY EVALUATION:
The Licensee indicated that the construction of Cell 4B will generate approximately 680,000
cubic yards of soil and clay, and 790,000 cubic yards of rock. Cell 4B reclamation requirements
are estimated to be 410,000 cubic yards of soil and rock, 68,000 cubic yards of clay, and 35,000
cubic yards of rip rap (DUSA 2009c). The Licensee also stated (DUSA 2009c) that the required
amount of cover materials for Cell 4B can easily be met from material generated during
construction or from off site locations. This conclusion is reasonable, given the amount of
property that is currently controlled by the Licensee that is not located outside of the tailings
management cells area.
The Licensee also provided information that all cover materials are native soils and rock
generated from the construction of the tailings cells or from off-site borrow locations. The
Licensee also stated that radium concentration of the cover materials will be at naturally-
occurring levels, and are, by definition, at background levels. These earthen materials will have
background concentrations of radium due to the fact that they will have been excavated from
natural sources on site. Stockpiles of these on-site stored materials will be surveyed for possible
contamination from any windblown or other contamination from ongoing mill operations on site.
Any found contamination would be removed and disposed of in the tailings cells prior to use for
the cover system (per Section 3.2.3 the November 24, 2009 Reclamation Plan submittal (DUSA
2009b), currently under Division review. Due to these precautions, radium concentrations of
earthen materials planned to be used in constructing the Cell 4B cover system will not exceed
background levels for the vicinity of the mill.
FINDING
The Division will require the Licensee to submit an updated Reclamation Plan, and Revised
Specifications for Reclamation for Cell 4B, for approval by the Executive Secretary before Cell
4B is placed into service. Other changes to the Reclamation Plan, and the associated
Specifications for Reclamation, may come about as part of an ongoing License Renewal process.
This requirement, combined with the information contained in the Cell 4B Environmental Report
and other relevant documents the Applicant has submitted, indicate that the requirements of
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UAC R313-24-4 that invokes the requirements contained in 10CFR40, Appendix A, Criterion 6(5)
will yet be satisfied, as they involve Cell 4B.
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10CFR40, APPENDIX A, CRITERION 6(6): CONCENTRATIONS OF
RADIONUCLIDES OTHER THAN RADIUM IN SOIL
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(6):
“The design requirements in this criterion for longevity and control of radon releases apply to
any portion of a licensed and/or disposal site unless such portion contains a concentration of
radium in land, averaged over areas of 100 square meters, which, as a result of byproduct
material, does not exceed the background level by more than: (i) 5 picocuries per gram (pCi/g)
of radium-226, or, in the case of thorium byproduct material, radium-228, averaged over the
first 15 centimeters (cm) below the surface, and (ii) 15 pCi/g of radium-226, or, in the case of
thorium byproduct material, radium-228, averaged over 15-cm thick layers more than 15 cm
below the surface.
Byproduct material containing concentrations of radionuclides other than radium in soil, and
surface activity on remaining structures, must not result in a total effective dose equivalent
(TEDE) exceeding the dose from cleanup of radium contaminated soil to the above standard
(benchmark dose), and must be at levels which are as low as is reasonably achievable. If more
than one residual radionuclide is present in the same 100-square-meter area, the sum of the
ratios for each radionuclide of concentration present to the concentration limit will not exceed
"1" (unity). A calculation of the potential peak annual TEDE within 1000 years to the average
member of the critical group that would result from applying the radium standard (not including
radon) on the site must be submitted for approval. The use of decommissioning plans with
benchmark doses which exceed 100 mrem/yr, before application of ALARA, requires the
approval of the … (Executive Secretary) after consideration of the recommendation of the staff of
the Executive Secretary. This requirement for dose criteria does not apply to sites that have
decommissioning plans for soil and structures approved before June 11, 1999.”
SAFETY EVALUATION:
The equivalent non-radium soil concentration requirements are set out in Section 3.2.3.2 of
Revision 3.0 of the Reclamation Plan (IUC, 2000), in Sections 3.2 and 3.3 of Attachment A
thereto, in Section 3.2.3.2 of the November 24, 2009 Reclamation Plan submittal (DUSA
2009b), and Sections 3.2 and 3.3 of Attachment A thereto. NRC approved Revision 3.0 of the
Reclamation Plan on July 21, 2000. This version was later revised by the Division in August,
2008 during approval of Cell 4A (UDRC 2008c), and it is currently in force. The November 24,
2009 Reclamation Plan (DUSA 2009b) is currently under Division review.
Section 3.3.3 of Attachment A to the November 24, 2009 Reclamation Plan submittal requires
and describes how all areas contaminated through process activities or windblown contamination
from the tailings areas will be remediated to meet applicable cleanup criteria for Ra-226, Th-230
and natural uranium. Section 3.3.3 further provides that contaminated areas will be remediated
such that the residual radionuclides remaining on the site, that are distinguishable from
background, will not result in a dose that is greater than that which would result from the radium
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soil standard, as required by UAC R313-24-4 [10 CFR Part 40, Appendix A, Criterion 6(6)]. The
procedures to be followed in taking the required surveys, including final surveys within specific
10-m by 10-m grids, are set out in Sections 3.3.3, 3.3.4, and 3.3.5 of Attachment A to the
November 24, 2009 Reclamation Plan submittal.
As provided in the November 24, 2009 Reclamation Plan submittal, at the time of site closure,
the Licensee will determine the potential peak annual total effective dose equivalent ("TEDE")
within 1,000 years to the average member of the critical group that would result from applying
the radium standard (not including radon) on the site. This determination will be documented
and submitted to the Executive Secretary for approval, as required by UAC R313-24-4 [10 CFR
Part 40, Appendix A, Criterion 6(6)].
These final site closure standards and procedures do not currently apply directly to tailings
contained within any of the tailings management (impoundment) cells, which will be capped in
place, including proposed Cell 4B. Instead they will apply to all areas impacted by the tailings
cells at the time of site closure, including Cell 4B.
FINDING:
The Division will require the Licensee to submit an updated Reclamation Plan, and Revised
Specifications for Reclamation for Cell 4B (License Condition 9.11), which will require
Executive Secretary approval prior to placing Cell 4B into service. Appropriate and required
supporting analyses and calculations may be required of the Licensee as part of an ongoing
License Renewal Application review process. Any improvements to the Reclamation Plan,
determined by the Executive Secretary, in the future, will be required during the License
Renewal process. Said changes needed to the Reclamation Plan will be submitted for Executive
Secretary approval thereafter.
This requirement, combined with the information contained in the Cell 4B Environmental Report
and other relevant documents the Applicant has submitted indicate that the requirements of UAC
R313-24-4 that invokes the requirements contained in 10CFR40, Appendix A, Criterion 6(6) will
yet be satisfied, as they involve Cell 4B.
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10CFR40, APPENDIX A, CRITERION 6(7): NONRADIOLOGICAL HAZARDS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6(7):
“The licensee shall also address the nonradiological hazards associated with the wastes in
planning and implementing closure. The licensee shall ensure that disposal areas are closed in a
manner that minimizes the need for further maintenance. To the extent necessary to prevent
threats to human health and the environment, the licensee shall control, minimize, or eliminate
post-closure escape of nonradiological hazardous constituents, leachate, contaminated
rainwater, or waste decomposition products to the ground or surface waters or to the
atmosphere.”
SAFETY EVALUATION:
The liner system for proposed Cell 4B is virtually identical to the liner system for Cell 4A, which
has previously been approved by the Executive Secretary (UDRC 2008b), and which has been
designed to hold tailings generated during mill operations during the operational life of Cell 4B,
including all nonradiological constituents. In the event of failure in the liner system, a leak
detection system is provided in the Cell 4B design. Further, nearby groundwater monitoring
wells will be present to detect any potential leakage including three new required groundwater
monitoring wells (see the evaluation under “10CFR40, Appendix A, Criterion 7: Preoperational
and Operational Monitoring” section below. As a result, the Ground Water Discharge Permit
addresses the radiological and nonradiological hazards associated with the mill tailings to be
disposed of in the tailings cells, including proposed Cell 4B.
No nonradiological emissions of any significance from the tailings cells are expected when the
cells are in operation. Following closure, additional isolation of the tailings should further reduce
nonradiological emissions.
FINDING:
The information contained in the Cell 4B engineering design, Environmental Report and other
relevant documents the Licensee has submitted, indicate that the requirements of UAC R313-24-
4 that invokes the requirement 10CFR40, Appendix A, Criterion 6(7) will yet be met, as they
involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 6A(1): COMPLETION OF FINAL RADON
BARRIER
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 6A(1):
“For impoundments containing uranium byproduct materials, the final radon barrier must be
completed as expeditiously as practicable considering technological feasibility after the pile or
impoundment ceases operation in accordance with a written, Executive Secretary-approved
reclamation plan. (The term as expeditiously as practicable considering technological feasibility
as specifically defined in the Introduction of this appendix includes factors beyond the control of
the licensee.) Deadlines for completion of the final radon barrier and, if applicable, the
following interim milestones must be established as a condition of the individual license:
windblown tailings retrieval and placement on the pile and interim stabilization (including
dewatering or the removal of freestanding liquids and recontouring). The placement of erosion
protection barriers or other features necessary for long-term control of the tailings must also be
completed in a timely manner in accordance with a written, Executive Secretary-approved
reclamation plan.”
SAFETY EVALUATION:
Refer to the evaluation under 10CFR40, Appendix A, Criterion 6(3): Phased Emplacement of
Final Radon Barrier, refer pages 46 through 48,above.
FINDING:
The Division will require the Licensee to submit an updated Reclamation Plan, and Revised
Specifications for Reclamation for Cell 4B, and secure approval thereof, before Cell 4B is put
into service. Other required supporting analyses and calculations may be required by the
Executive Secretary as part of the ongoing License Renewal Application process, as an
outgrowth of the review of the November 24, 2009 Reclamation Plan (DUSA 2009b). This
requirement, combined with the information contained in the Cell 4B Environmental Report and
other relevant documents the Applicant has submitted indicate that the requirements of UAC
R313-24-4 that invokes the requirements contained in 10CFR40, Appendix A, Criterion 6A(1) will
yet be satisfied, as they involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 7: PREOPERATIONAL AND OPERATIONAL
MONITORING PROGRAMS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 7: “At
least one full year prior to any major site construction, a preoperational monitoring program
must be conducted to provide complete baseline data on a milling site and its environs.
Throughout the construction and operating phases of the mill, an operational monitoring
program must be conducted to measure or evaluate compliance with applicable standards and
regulations; to evaluate performance of control systems and procedures; to evaluate
environmental impacts of operation; and to detect potential long-term effects.”
SAFETY EVALUATION:
An extensive preoperational monitoring program was performed at the mill site prior to initial
construction and licensing of the mill, in order to provide complete baseline data on the mill site
and its environs, as required by 10 CFR Part 40, Appendix A, Criterion 7. The results of this
preoperational monitoring program are described in detail in the 1978 ER (D&M, 1978) and the
FES (NRC 1979).
Operational monitoring programs have been conducted at the mill throughout the construction
and operating phases of the mill, to measure and evaluate compliance with applicable standards
and regulations; to evaluate performance of control systems and procedures; to evaluate
environmental impacts of operation; and to detect potential long-term effects. The mill's
operational monitoring programs are described in Section 2.3 of the November 24, 2009
Reclamation Plan submittal (DUSA 2009b). Monitoring results are reported in the mill's Semi
Annual Effluent Reports and Quarterly Groundwater Monitoring Reports and other reports filed
with the Executive Secretary.
Baseline data for new groundwater monitoring wells that will be installed in connection with the
construction of Cell 4B will be obtained over the first eight quarters after installation of the wells
(proposed Permit, Part I.H.7). Because any such monitoring wells will likely be installed in one
or more of the Cell 4B dikes, being the downgradient locations closest to the cell, it will not be
possible to install and monitor such wells prior to construction of Cell 4B. However, Cell 4B will
have a BAT and state-of-the-practice leak detection system that will be monitored regularly once
the cell begins to be used to support operations. As a result, there is reasonable assurance that the
groundwater at any newly installed wells will not have been impacted by Cell 4B operations
during the eight-quarter baseline sampling period.
Preoperational environmental monitoring was described in Sections 2.5, 2.4 and 2.9 of the 1992
License Renewal Application. Evidence of NRC approval is contained in License Condition 9.3.
In addition, the Division will include a new condition in the Permit, requiring that a minimum of
three additional downgradient groundwater monitoring wells be installed in conjunction with the
construction of Cell 4B. Two compliance monitoring wells (MW-33 and MW-34) will be
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installed as described in new Permit condition I.H.6. A condition has also been added to the
Permit to require that a plan for approval be submitted to the Executive Secretary for installation
of the third compliance monitoring well (MW-35). After approval, the location of the third well
(MW-35) will be determined after consideration of hydrogeologic information acquired through
installation and development of wells MW-33 and MW-34 and other related field investigations
(Permit Part I.H.6). The condition also requires that a monitoring well As-Built report for Wells
MW-33 and MW-34, and for Well MW-35, be submitted within 45 calendar days of completing
well installations to document said well construction for Executive Secretary approval (Permit
Part I.H.6).
FINDING:
The Division will incorporate new Permit conditions (Permit Parts I.E.1(b)(3), I.H.6, and I.H.7)
requiring that a minimum of three additional downgradient groundwater monitoring wells be
installed, with two of these wells required to be installed prior to placement of tailings or
wastewater in Tailings Cell 4B, and that within 45 calendar days of completing well installation,
a monitoring well As-Built report be submitted for these two wells to document said well
construction for Executive Secretary approval, and that a background groundwater quality report
be submitted to the Division after completion of 8 quarters of sampling and analysis in these
wells. The conditions will also require that a plan for installing the third new groundwater
monitoring well be submitted to the Division before Cell 4B is placed into service. These Permit
changes, combined with the information contained in the Cell 4B Environmental Report and
other relevant documents the Licensee has submitted, indicate that the requirements of UAC
R313-24-4 ,that invokes requirements contained in 10CFR40, Appendix A, Criterion 7, will yet be
satisfied, by complying with the Permit conditions, as they involve Cell 4B.
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10CFR40, APPENDIX A, CRITERION 8: EFFLUENT CONTROL DURING
OPERATIONS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 8:
“Milling operations must be conducted so that all airborne effluent releases are reduced to levels
as low as is reasonably achievable. The primary means of accomplishing this must be by means
of emission controls. Institutional controls, such as extending the site boundary and exclusion
area, may be employed to ensure that offsite exposure limits are met, but only after all
practicable measures have been taken to control emissions at the source. Notwithstanding the
existence of individual dose standards, strict control of emissions is necessary to assure that
population exposures are reduced to the maximum extent reasonably achievable and to avoid
site contamination. The greatest potential sources of offsite radiation exposure (aside from
radon exposure) are dusting from dry surfaces of the tailings disposal area not covered by
tailings solution and emissions from yellowcake drying and packaging operations. During
operations and prior to closure, radiation doses from radon emissions from surface
impoundments of uranium or thorium byproduct materials must be kept as low as is reasonably
achievable.
Checks must be made and logged hourly of all parameters (e.g., differential pressures and
scrubber water flow rates) that determine the efficiency of yellowcake stack emission control
equipment operation. The licensee shall retain each log as a record for three years after the last
entry in the log is made. It must be determined whether or not conditions are within a range
prescribed to ensure that the equipment is operating consistently near peak efficiency; corrective
action must be taken when performance is outside of prescribed ranges. Effluent control devices
must be operative at all times during drying and packaging operations and whenever air is
exhausting from the yellowcake stack. Drying and packaging operations must terminate when
controls are inoperative. When checks indicate the equipment is not operating within the range
prescribed for peak efficiency, actions must be taken to restore parameters to the prescribed
range. When this cannot be done without shutdown and repairs, drying and packaging
operations must cease as soon as practicable. Operations may not be restarted after cessation
due to off-normal performance until needed corrective actions have been identified and
implemented. All these cessations, corrective actions, and restarts must be reported to the
Executive Secretary, in writing, within ten days of the subsequent restart.
To control dusting from tailings, that portion not covered by standing liquids must be wetted or
chemically stabilized to prevent or minimize blowing and dusting to the maximum extent
reasonably achievable. This requirement may be relaxed if tailings are effectively sheltered from
wind, such as may be the case where they are disposed of below grade and the tailings surface is
not exposed to wind. Consideration must be given in planning tailings disposal programs to
methods which would allow phased covering and reclamation of tailings impoundments because
this will help in controlling particulate and radon emissions during operation. To control
dusting from diffuse sources, such as tailings and ore pads where automatic controls do not
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apply, operators shall develop written operating procedures specifying the methods of control
which will be utilized.
Milling operations producing or involving thorium byproduct material must be conducted in
such a manner as to provide reasonable assurance that the annual dose equivalent does not
exceed 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other
organ of any member of the public as a result of exposures to the planned discharge of
radioactive materials, radon-220 and its daughters excepted, to the general environment.
Uranium and thorium byproduct materials must be managed so as to conform to the applicable
provisions of Title 40 of the Code of Federal Regulations, Part 440, "Ore Mining and Dressing
Point Source Category: Effluent Limitations Guidelines and New Source Performance
Standards, subpart C, Uranium, Radium, and Vanadium Ores Subcategory,” as codified on
January 1, 1983.”
SAFETY EVALUATION:
This topic deals primarily with mill operations generally and the mill's tailings system as a whole
and not specifically to Cell 4B. Refer to Section 5.0 of the 2007 License Renewal Application
and Section 4.0 of the 1992 License Renewal Application for a description of the mill's emission
and dust control procedures. Evidence of NRC approval of such procedures is contained in
License Condition 9.3.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, indicate that the requirements of UAC R313-24-4 that invokes the
requirements contained in 10CFR40, Appendix A, Criterion 8 will yet be satisfied, as they involve
Cell 4B.
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10CFR40, APPENDIX A, CRITERION 8A: DAILY INSPECTIONS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 8A:
“Daily inspections of tailings or waste retention systems must be conducted by a qualified
engineer or scientist and documented. The licensee shall retain the documentation for each daily
inspection as a record for three years after the documentation is made. The Executive Secretary
must be immediately notified of any failure in a tailings or waste retention system that results in
a release of tailings or waste into unrestricted areas, or of any unusual conditions (conditions
not contemplated in the design of the retention system) that is not corrected could indicate the
potential or lead to failure of the system and result in a release of tailings or waste into
unrestricted areas.”
SAFETY EVALUATION:
Refer to the evaluation presented under 10CFR40.26(C)(2): General License, (refer to pages 16
and 17, above).
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted indicate that the requirements of UAC R313-24-4 that invokes the
requirements contained in 10CFR40, Appendix A, Criterion 8A will yet be satisfied, as they
involve Cell 4B.

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10CFR40, APPENDIX A, CRITERION 9: FINANCIAL SURETY ARRANGEMENTS
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 9:
“Financial surety arrangements must be established by each mill operator prior to the
commencement of operations to assure that sufficient funds will be available to carry out the
decontamination and decommissioning of the mill and site and for the reclamation of any
tailings or waste disposal areas. The amount of funds to be ensured by such surety arrangements
must be based on Executive Secretary-approved cost estimates in a Executive Secretary-
approved plan for (1) decontamination and decommissioning of mill buildings and the milling
site to levels which allow unrestricted use of these areas upon decommissioning, and (2) the
reclamation of tailings and/or waste areas in accordance with technical criteria delineated in
Section I of this Appendix. The licensee shall submit this plan in conjunction with an
environmental report that addresses the expected environmental impacts of the milling
operation, decommissioning and tailings reclamation, and evaluates alternatives for mitigating
these impacts. The surety must also cover the payment of the charge for long-term surveillance
and control required by Criterion 10. In establishing specific surety arrangements, the licensee's
cost estimates must take into account total costs that would be incurred if an independent
contractor were hired to perform the decommissioning and reclamation work. In order to avoid
unnecessary duplication and expense, the Executive Secretary may accept financial sureties that
have been consolidated with financial or surety arrangements established to meet requirements
of other Federal or state agencies and/or local governing bodies for such decommissioning,
decontamination, reclamation, and long-term site surveillance and control, provided such
arrangements are considered adequate to satisfy these requirements and that the portion of the
surety which covers the decommissioning and reclamation of the mill, mill tailings site and
associated areas, and the long-term funding charge is clearly identified and committed for use in
accomplishing these activities. The licensee's surety mechanism will be reviewed annually by the
Executive Secretary to assure, that sufficient funds would be available for completion of the
reclamation plan if the work had to be performed by an independent contractor. The amount of
surety liability should be adjusted to recognize any increases or decreases resulting from
inflation, changes in engineering plans, activities performed, and any other conditions affecting
costs. Regardless of whether reclamation is phased through the life of the operation or takes
place at the end of operations, an appropriate portion of surety liability must be retained until
final compliance with the reclamation plan is determined.
This will yield a surety that is at least sufficient at all times to cover the costs of
decommissioning and reclamation of the areas that are expected to be disturbed before the next
license renewal. The term of the surety mechanism must be open ended, unless it can be
demonstrated that another arrangement would provide an equivalent level of assurance. This
assurance would be provided with a surety instrument which is written for a specified period of
time (e.g., 5 years) yet which must be automatically renewed unless the surety notifies the
beneficiary (the Executive Secretary) and the principal (the licensee) some reasonable time (e.g.,
90 days) prior to the renewal date of their intention not to renew. In such a situation the surety
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requirement still exists and the licensee would be required to submit an acceptable replacement
surety within a brief period of time to allow at least 60 days for the regulatory agency to collect.
Proof of forfeiture must not be necessary to collect the surety so that in the event that the
licensee could not provide an acceptable replacement surety within the required time, the surety
shall be automatically collected prior to its expiration. The conditions described above would
have to be clearly stated on any surety instrument which is not open-ended, and must be agreed
to by all parties. Financial surety arrangements generally acceptable to the Executive Secretary
are:
(a) Surety bonds;
(b) Cash deposits;
(c) Certificates of deposits;
(d) Deposits of government securities;
(e) Irrevocable letters or lines of credit; and
(f) Combinations of the above or such other types of arrangements as may be approved by the
Executive Secretary. However, self insurance, or any arrangement which essentially constitutes
self insurance (e.g., a contract with a State or Federal agency), will not satisfy the surety
requirement since this provides no additional assurance other than that which already exists
through license requirements.”
SAFETY EVALUATION:
As required by License Condition 9.5, the mill has deposited a surety bond with the Executive
Secretary, consistent with UAC R313-24-4 (10 CFR Part 40, Appendix A, Criteria 9 and 10),
adequate to cover the estimated costs, accomplished by a third party, for decommissioning and
decontamination of the mill and mill site; reclamation of the mill's tailings or waste disposal
areas; and the long-term surveillance fee.
The amount of the surety bond is currently $15,807,429, was approved by the Executive
Secretary on December 9, 2009, and represents site conditions without Cell 4B. Annual updates
to the surety amount, required by UAC R313-24-4 (10 CFR Part 40, Appendix A, Criteria 9 and
10) are submitted for Executive Secretary for approval by March 4 of each year.
Prior to operation of Cell 4B, and after approval of the revised Reclamation Plan, the reclamation
cost estimate will be updated to reflect the eventual closure of Cell 4B. Thereafter, the surety
bond will be updated accordingly. The proposed License contains new requirements at
Conditions 9.5 and 9.11 to this effect. Further, changes in Condition 9.5 now prohibit the
Licensee from operating the facility without prior submittal of evidence of appropriate changes
to the surety amount, and Executive Secretary approval thereof.
In addition, the current surety amount ($15,807,429) does not include costs related to
groundwater restoration that might be required at the time of closure. Given that a chloroform
contaminant plume is now known to exist at the facility, and was caused by pre-construction and
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initial site operations related to 11e.(2) tailings disposal, it is appropriate for the Licensee to
include an allowance for chloroform groundwater remediation in the annual surety report to
include any activities and costs needed to meet the Criterion 9 requirements, including:
“… 1) decontamination and decommissioning of … the milling site to levels which allow
unrestricted use of these areas …” and
“ … The amount of surety liability should be adjusted to recognize any increases or
decreases resulting from inflation, changes in engineering plans, activities performed,
and any other conditions affecting costs.”
As a result, it is the intent of the Division to require the Licensee to include a cost allowance for
chloroform groundwater remediation during the review process for the 2010 annual surety
report.
Refer also to evaluation under UAC R313-24-3D: Environmental Analysis - Long-Term
Impacts, as stated on Pages 13 through 15 above.
FINDING:
The Division will require, through a new License Condition (License Condition 9.11), that the
Licensee submit a revised Reclamation Plan, and revised Specifications for Reclamation for Cell
4B, and obtain approval thereof, before Cell 4B is put into service. In addition, adequate
information for determining financial surety requirements for all tailings management cells,
including Cells 4A and 4B, and any new features or facilities that are constructed in conjunction
with operation of Cells 4A and 4B will also be required. Said revised Reclamation Plan and
Specifications and surety for Cell 4B shall be approved by Executive Secretary before disposal
of any tailings or wastewater in Cell 4B. The updated Reclamation Plan will revise both the
NRC- approved version of the Reclamation Plan (Revision 3.0) for Cells 1, 2, and 3, and the
version approved by the Division in August, 2008, referred to as Revision 3.1 (see UDRC
2008c).
The new License Condition combined with the information contained in the Cell 4B
Environmental Report and other relevant documents the Applicant has submitted, indicate that
the requirements of UAC R313-24-4 that invokes the requirements contained in 10CFR40,
Appendix A, Criterion 9 will yet be satisfied, as they involve Cell 4B.
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10CFR40, APPENDIX A, CRITERION 10: COSTS OF LONG-TERM SURVEILLANCE
REGULATORY BASIS:
UAC R313-24-4 invokes the following requirement from 10CFR40, Appendix A, Criterion 10: “A
minimum charge of [$855,000 (2008 dollars)] to cover the costs of long-term surveillance must
be paid by each mill operator to the general treasury of the United States or to an appropriate
State agency prior to the termination of a uranium or thorium mill License.
If site surveillance or control requirements at a particular site are determined, on the basis of a
site-specific evaluation, to be significantly greater than those specified in Criterion 12 (e.g., if
fencing is determined to be necessary), variance in funding requirements may be specified by the
Executive Secretary. In any case, the total charge to cover the costs of long-term surveillance
must be such that, with an assumed 1 percent annual real interest rate, the collected funds will
yield interest in an amount sufficient to cover the annual costs of site surveillance. The total
charge will be adjusted annually prior to actual payment to recognize inflation. The inflation rate
to be used is that indicated by the change in the Consumer Price Index published by the U.S.
Department of Labor, Bureau of Labor Statistics.”
SAFETY EVALUATION:
The Long Term Surveillance Fund is specific to the entire site and is not designated for
individual features of the site. There will be no increase in the calculated amount of the fund
from the addition of Cell 4B.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted, indicate that the requirements of UAC R313-24-4 that invokes the
requirements contained in 10CFR40, Appendix A, Criterion 10 have been satisfied, as they involve
Cell 4B.
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UAC R317-6-6.3: GROUND WATER DISCHARGE PERMIT APPLICATION
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6 in lieu of 10CFR40 Appendix A, Criterion 5B(1) thru 5H,
Criterion 7A, and Criterion 13. In turn, UAC R317-6-6.3 outlines the content requirements of a
State Ground Water Discharge Permit (Permit) application.
“Unless otherwise determined by the Executive Secretary, the application for a permit to discharge
wastes or pollutants to ground water shall include the following complete information:
A. The name and address of the applicant and the name and address of the owner of the
facility if different than the applicant. A corporate application must be signed by an officer
of the corporation. The name and address of the contact, if different than above, and
telephone numbers for all listed names shall be included.
B. The legal location of the facility by county, quarter-quarter section, township, and range.
C. The name of the facility and the type of facility, including the expected facility life.
D. A plat map showing all water wells, including the status and use of each well, Drinking
Water source protection zones, topography, springs, water bodies, drainages, and man-
made structures within a one-mile radius of the discharge. The plat map must also show the
location and depth of existing or proposed wells to be used for monitoring ground water
quality. Identify any applicable Drinking Water source protection ordinances and their
impacts on the proposed permit.
E. Geologic, hydrologic, and agricultural description of the geographic area within a one-
mile radius of the point of discharge, including soil types, aquifers, ground water flow
direction, ground water quality, aquifer material, and well logs.
F. The type, source, and chemical, physical, radiological, and toxic characteristics of the
effluent or leachate to be discharged; the average and maximum daily amount of effluent or
leachate discharged (gpd), the discharge rate (gpm), and the expected concentrations of any
pollutant (mg/l) in each discharge or combination of discharges. If more than one discharge
point is used, information for each point must be given separately.
G. Information which shows that the discharge can be controlled and will not migrate into
or adversely affect the quality of any other waters of the state, including the applicable
surface water quality standards, that the discharge is compatible with the receiving ground
water, and that the discharge will comply with the applicable class TDS limits, ground
water quality standards, class protection levels or an alternate concentration limit proposed
by the facility.
H. For areas where the ground water has not been classified by the Board, information on
the quality of the receiving ground water sufficient to determine the applicable protection
levels.
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I. A proposed sampling and analysis monitoring plan which conforms to EPA Guidance for
Quality Assurance Project Plans, EPA QA/G-5 (EPA/600/R-98/018, February 1998) and
includes a description, where appropriate, of the following:
1. ground water monitoring to determine ground water flow direction and gradient,
background quality at the site, and the quality of ground water at the compliance
monitoring point;
2. installation, use and maintenance of monitoring devices;
3. description of the compliance monitoring area defined by the compliance
monitoring points including the dimensions and hydrologic and geologic data used
to determine the dimensions;
4. monitoring of the vadose zone;
5. measures to prevent ground water contamination after the cessation of operation,
including post-operational monitoring;
6. monitoring well construction and ground water sampling which conform where
applicable to the Handbook of Suggested Practices for Design and Installation of
Ground-Water Monitoring Wells (EPA/600/4-89/034, March 1991), ASTM
Standards on Ground Water and Vadose Investigations (1996), Practical Guide for
Ground Water Sampling EPA/600/2-85/104, (November 1985) and RCRA Ground
Water Monitoring Technical Enforcement Guidance Document (1986), unless
otherwise specified by the Executive Secretary;
7. description and justification of parameters to be monitored;
8. quality assurance and control provisions for monitoring data.
J. The plans and specifications relating to construction, modification, and operation of
discharge systems.
K. The description of the ground water most likely to be affected by the discharge, including
water quality information of the receiving ground water prior to discharge, a description of
the aquifer in which the ground water occurs, the depth to the ground water, the saturated
thickness, flow direction, porosity, hydraulic conductivity, and flow systems characteristics.
L. The compliance sampling plan which in addition to the information specified in the above
item I includes, where appropriate, provisions for sampling of effluent and for flow
monitoring in order to determine the volume and chemistry of the discharge onto or below
the surface of the ground and a plan for sampling compliance monitoring points and
appropriate nearby water wells. Sampling and analytical methods proposed in the
application must conform with the most appropriate methods specified in the following
references unless otherwise specified by the Executive Secretary:
1. Standard Methods for the Examination of Water and Wastewater, twentieth
edition, 1998; Library of Congress catalogue number: ISBN: 0-87553-235-7.
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2. E.P.A. Methods, Methods for Chemical Analysis of Water and Wastes, 1983;
Stock Number EPA-600/4-79-020.
3. Techniques of Water Resource Investigations of the U.S. Geological Survey,
(1998); Book 9.
4. Monitoring requirements in 40 CFR parts 141 and 142, 2000 ed., Primary
Drinking Water Regulations and 40 CFR parts 264 and 270, 2000 ed.
5. National Handbook of Recommended Methods for Water-Data Acquisition, GSA-
GS edition; Book 85 AD-2777, U.S. Government Printing Office Stock Number 024-
001-03489-1.
M. A description of the flooding potential of the discharge site, including the 100-year flood
plain, and any applicable flood protection measures.
N. Contingency plan for regaining and maintaining compliance with the permit limits and
for reestablishing best available technology as defined in the permit.
O. Methods and procedures for inspections of the facility operations and for detecting
failure of the system.
P. For any existing facility, a corrective action plan or identification of other response
measures to be taken to remedy any violation of applicable ground water quality standards,
class TDS limits or permit limit established under R317-6-6.4E. which has resulted from
discharges occurring prior to issuance of a ground water discharge permit.
Q. Other information required by the Executive Secretary.
R. All applications for a groundwater discharge permit must be performed under the
direction, and bear the seal, of a professional engineer or professional geologist.
S. A closure and post closure management plan demonstrating measures to prevent ground
water contamination during the closure and post closure phases of an operation.”
SAFETY EVALUATION:
As outlined above, ground water quality protection issues at uranium mills are managed by the
Division under the authority of the Utah Ground Water Quality Protection Regulations (UAC
R317-6) and the corresponding Permit. The original Permit was issued by the Division on
March 8, 2005, and has been modified several times since; the most recent being January 20,
2010. During these Permit actions, the Permittee has submitted a substantial amount of
additional hydrogeology and groundwater quality information, and additional requirements have
been implemented at the facility. These actions have improved site performance standards for
new construction and enhanced monitoring and reporting criteria. As a result, the Division
believes improved measures are in place for protection of local groundwater quality. Despite
these improvements, the Licensee was asked to provide additional geologic, hydrogeologic, and
groundwater related information during review of the Cell 4B application. A brief discussion of
that information follows.
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The Licensee provided a Colorado Plateau geologic map and a map showing the geology of the
Mill site and surrounding areas found in the November 24, 2009 Reclamation Plan submittal
(DUSA 2009b) (Figures 1.6.1 and 1.6.2, respectively). A figure showing the generalized
stratigraphy of the mill site was included as Figure 6 of the 2008 ER and Figure 1.5-1 of the
November 24, 2009 Reclamation Plan submittal.
The Licensee provided a report, Site Hydrogeology and Estimation of Groundwater Travel
Times in the Perched Zone White Mesa Uranium Mill Site Near Blanding, Utah, as Appendix B
to the November 24, 2009 Reclamation Plan submittal (DUSA 2009b), which includes updated
site information on site hydrology and hydrogeology.
In the Round 1 response, the Licensee assured that during the Cell 4B construction process that
the existing groundwater compliance monitoring wells would be preserved, because each
groundwater monitoring well at the mill site near Cell 4B would be protected by concrete
bollards that surround the well. Each post is a four inch metal pipe filled with concrete that is
sunk three feet into the ground and that protrudes three feet above the ground. Each post and the
monitoring well casing is painted red for easy visual identification. The Licensee states that if a
monitoring well is damaged, given the above protections, the Executive Secretary would be
notified, and the well would be repaired in accordance with a plan that would be submitted to the
Executive Secretary for approval and approved prior to commencement of repair.
The Licensee furnished well boring logs for wells MW-1, MW-2, MW-3, MW-4, MW-5, MW-
11, MW-12, MW-14, MW-15, MW-16, MW-17, MW-18, and MW-19, as Appendix A to the
Hydrological Evaluation of White Mesa Uranium Mill, July 1994, prepared by Titan
Environmental Corporation (the "1994 Titan Report").
The Licensee also provided lithologic and core logs for wells MW-3A, MW-23, MW-24, MW-
25, MW-27, MW-28, MW-29, MW-30 and MW-31 as Appendix A to the Report: Perched
Monitoring Well Installation and Testing at the White Mesa Uranium Mill April Through June
2005, August 3, 2005, prepared by Hydro Geo Chem, Inc.
Also provided by the Licensee are the lithologic and core logs for wells MW-20, MW-21 and
MW-22 in a June 21, 2001 letter report from Hydro Geo Chem, Inc. (Hydro Geo Chem), which
is attachment A to Denison's June 22, 2001 letter to the Executive Secretary in response to the
Executive Secretary's request for additional site hydrology information. Lithologic and core logs
for wells TW4-4 and TW4-5 are included in an October 4, 2000 report prepared by Hydro Geo
Chem, which has previously been submitted to the Executive Secretary.

The Applicant included geologic cross sections depicting the three-dimensional configuration of
the (geologic) contact between the Brushy Basin and the Burro Canyon formations representing
the area beneath and downgradient of the Cell 4B footprint (DUSA 2010b). The cross sections
depict the approximate configuration of the perched water zone in the cross sections. The
Applicant has also provided boring logs for Boring #19, MW-3A, MW-16, and MW-23, along
with angled subsurface boring logs for GH-94-1, GH-94-2A, and GH-94-3. The Applicant
concluded that there was not sufficient data on the locations of, and angles of completion of, the
angled borings to allow them to be precisely placed on a map and therefore these were not used
in developing the cross sections.
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In their response to Round 1 Interrogatories submitted relative to the Cell 4B Environmental
Report (DUSA 2009c), the Licensee also provided a letter, dated November 10, 2009, from
Hydro Geo Chem which indicated that the reported sub-horizontal, limonite-stained features
interpreted in the 1978 ER (D&M, 1978) as bedding plane fractures may not be actual fractures
but may represent structurally weaker zones along bedding planes that appear as partings in core
samples.
Hydro Geo Chem concluded, in the above-referenced report, that examination of core samples
collected during drilling of angle borings beneath tailings Cells 3 and 4A indicate that where
fractures were present in cores, they were cemented with gypsum. They indicated that open
fractures significant enough to impact groundwater movement in the perched zone were not
identified in that investigation. Hydro Geo Chem also concluded that no fractures were reported
in cores from MW-3A, MW-16, or MW-23, the existing wells adjacent to or at the location of
proposed Cell 4B. Hydro Geo Chem concluded that this makes it even less likely that potentially
undetected fractures could significantly affect subsurface fluid flow in the vicinity of proposed
Cell 4B, and that, should the sub-horizontal features reported in the 1978 ER actually represent
fractures, their sub-horizontal nature would prevent them from acting as vertical conduits from
the tailing cell to the perched groundwater.
A Hydro Geo Chem letter report dated February 8, 2010 (an attachment to DUSA 2010a) also
provided additional information recommending the installation of Cell 4B monitoring wells
MW-33 and MW-34. These wells would be screened across the perched zone, and therefore,
their installation would provide data to better define the apparent ridge-like feature identified in
the top of the Brushy Basin, near MW-16. In meetings with the Division on February 18, 2010,
the Applicant agreed to install three new wells, including a third monitoring well, MW-35,
adjacent to the western edge of Cell 4B. The installation of MW-35 is intended to aid in further
defining the potential groundwater migration patterns downgradient of proposed Cell 4B. The
Division has decided this third well is required.
The Licensee also provided information stating the design of Cell 4B and Cell 4A will be similar
and with be constructed with dual synthetic liners, a leak detection system between the synthetic
liners and a geosynthetic clay liner beneath the lowest synthetic liner. This liner system will be
overlain by a slimes drain system. The Licensee concluded that the cells are therefore designed
without any present, and therefore, no assumed future potential, points of discharge for effluents
or leachate from the cells.
FINDING:
The Division will incorporate a new Permit condition requiring that a minimum of three
additional downgradient groundwater monitoring wells be installed near Cell 4B. Two of these
new wells (MW-33 and MW-34) must be installed and approved prior to use of Cell 4B (see new
Part I.H.6). The new Permit condition also requires that the Licensee submit a plan for
installation of the third well (MW-35) prior to placement of tailings and wastewater in Cell 4B.
For additional details see the Permit and attending Statement of Basis.
A condition will also be included in the forthcoming Permit to require the Licensee to conduct an
additional hydrogeologic investigation in the area to the west of the Cell 4B footprint area,
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extending to, and including existing seeps (e.g. Cottonwood Seep and Westwater Seep) and a
spring (e.g. Ruin Spring) located west and southwest of the tailings management cells, and
submission by the Licensee of a report describing results of those hydrogeologic investigations
prior to placing Cell 4B into service (see new Part I.H.10). The investigation will be conducted
to verify the relationship of the (geologic) contact between the Brushy Basin and the Burro
Canyon formations to the seeps and springs. The Division believes this geologic contact may
have significant impact on local groundwater flow directions, and location of potential points of
exposure of the public to possible groundwater contamination.
The changes to the Permit, combined with the information contained in the Cell 4B
Environmental Report and other relevant documents the Applicant has submitted, indicate that
the requirements of UAC R317-6-6.3 will yet be satisfied, as they involve Cell 4B.
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UAC R317-6-6.4: ISSUANCE OF DISCHARGE PERMIT
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.4(A) in lieu of comparable requirements in 10CFR40:
“A. The Executive Secretary may issue a ground water discharge permit for a new facility if the
Executive Secretary determines, after reviewing the information provided under R317-6-6.3,
that:
1. the applicant demonstrates that the applicable class TDS limits, ground water quality
standards protection levels, and permit limits established under R317-6-6.4E will be
met;
2. the monitoring plan, sampling and reporting requirements are adequate to determine
compliance with applicable requirements;
3. the applicant is using best available technology to minimize the discharge of any
pollutant; and
4. there is no impairment of present and future beneficial uses of the ground water.”
SAFETY EVALUATION:
The Licensee provided information stating that the construction and operation of Cell 4B would
not create any new issues of concern over and above those considered and accepted for existing
licensed facilities at the mill. The physical, chemical and radiological make up of the tailings is
not expected to be significantly different from that of existing tailings or from the assumptions in
the previously issued Permit. Cell 4B will have a double liner/leak detection/slimes drain system
similar to that of Cell 4A that is designed not to release tailings solutions to the environment and
that the Division has already approved. The Licensee indicated that any releases at Cell 4B will
be detected by the LDS and groundwater monitoring programs and remediated before there
could be any impact on the public.
The Licensee also provided information in a Hydro Geo Chem letter dated February 12, 2010,
discussing the inferred distribution of conglomeratic zones within the Dakota Formation, and
their inferred vertical and aerial extent of the elevated portion of the contact surface of the Burro
Canyon / Brushy Basin Formations on geologic cross sections that span the Cell 4B footprint
area.
Refer also to the evaluation under UAC R317-6-6.3: Ground Water Discharge Permit
Application, presented above.
FINDING:
The Division believes that the proposed engineering design and construction specifications for
Cell 4B, along with the proposed Permit changes to address operational monitoring /
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maintenance, and groundwater monitoring satisfy the requirements of UAC R317-6-6.4(A). For
additional information on these findings, please see the related Statement of Basis.
The Division will incorporate a new Permit condition requiring that a minimum of three
additional downgradient groundwater monitoring wells be installed in conjunction with the
construction of Cell 4B (see new Part I.H.6). For a further discussion of this provision, see
R317-6-6.3, Ground Water Discharge Permit Application, above.
A new condition will also be included in the Permit to require the Licensee to conduct an
additional hydrogeologic investigation in the area to the west of the Cell 4B footprint area,
extending to, and including existing seeps (Cottonwood Seep and Westwater Seep) and a spring
(Ruin Spring) located west and southwest of the tailings management cells, and submission by
the Licensee of a report describing results of those hydrogeologic investigations prior to placing
Cell 4B into service (see new Part I.H.10). The investigation will be conducted to verify the
relationship of the (geologic) contact between the Brushy Basin and the Burro Canyon
formations to the seeps and springs.
The changes to the Permit, in combination with the information contained in the Cell 4B
Environmental Report and other relevant documents the Applicant has submitted, indicate that
the requirements of UAC R317-6-6.4 will yet be satisfied, as they involve Cell 4B.
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UAC R317-6-6.9: PERMIT COMPLIANCE MONITORING
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.9 in lieu of comparable requirements in 10CFR40:
“A. Ground Water Monitoring
The Executive Secretary may include in a ground water discharge permit requirements for ground
water monitoring, and may specify compliance monitoring points where the applicable class TDS
limits, ground water quality standards, protection levels or other permit limits are to be met.
The Executive Secretary will determine the location of the compliance monitoring point based upon
the hydrology, type of pollutants, and other factors that may affect the ground water quality. The
distance to the compliance monitoring points must be as close as practicable to the point of
discharge. The compliance monitoring point shall not be beyond the property boundaries of the
permitted facility without written agreement of the affected property owners and approval by the
Executive Secretary.
B. Performance Monitoring
The Executive Secretary may include in a ground water discharge permit requirements for
monitoring performance of best available technology standards.”
SAFETY EVALUATION:
The Licensee has provided updated site information on site hydrology (HGCI 2009), a copy of
which is included as Appendix B to the November 24, 2009 Reclamation Plan submittal (DUSA
2009b). The HGCI 2009 report provides information demonstrating that the proposed
groundwater monitoring system, including the three new monitoring wells (MW-33, MW-34,
and MW-35) proposed to be installed downgradient of Cell 4B, together with existing wells
MW-14 and MW-15, and other downgradient monitoring wells, are sufficient in number, are
properly located, and are properly designed to provide reasonable assurance of providing timely,
reliable, and representative data for detecting potential future releases from the tailings
management cells, including Cell 4B.
With regards to requirements for monitoring BAT performance, certain other changes have been
made to the Permit to require revision of the existing Cell 4A Monitoring, Operations and
Maintenance Plan to address needs for Cell 4B. Refer also to the evaluation under UAC R317-6-
6.3: Ground Water Discharge Permit Application.
FINDING:
The Division will incorporate a new Permit provision requiring that a minimum of three
additional downgradient groundwater monitoring wells be installed in connection with the
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construction and use of Cell 4B (see new Part I.H.6). For a further discussion of this provision,
see R317-6-6.3, Ground Water Discharge Permit Application, above.
A condition will also be included in the forthcoming Permit modification to require the Licensee
to conduct an additional hydrogeologic investigation in the area to the west of the Cell 4B
footprint area, extending to, and including existing seeps (Cottonwood Seep and Westwater
Seep) and a spring (Ruin Spring) located west and southwest of the tailings management cells,
and submission by the Licensee of a report describing results of those hydrogeologic
investigations prior to placing Cell 4B into service (see new Part I.H.10). The investigation will
be conducted to verify the relationship of the (geologic) contact between the Brushy Basin and
the Burro Canyon formations to the seeps and springs.
The changes to the Permit, in combination with the information contained in the Cell 4B
Environmental Report and other relevant documents the Licensee has submitted, indicate that the
requirements of UAC R317-6-6.9 will yet be satisfied, by complying with Permit conditions, as
they involve Cell 4B.

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UAC R317-6-6.10: BACKGROUND WATER QUALITY DETERMINATION
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.10 in lieu of comparable requirements in 10CFR40:
“A. Background water quality contaminant concentrations shall be determined and specified in the
ground water discharge permit. The determination of background concentration shall take into
account any degradation.
B. Background water quality contaminant concentrations may be determined from existing
information or from data collected by the permit applicant. Existing information shall be used, if the
permit applicant demonstrates that the quality of the information and its means of collection are
adequate to determine background water quality. If existing information is not adequate to
determine background water quality, the permit applicant shall submit a plan to determine
background water quality to the Executive Secretary for approval prior to data collection. One or
more up-gradient, lateral hydraulically equivalent point, or other monitoring wells as approved by
the Executive Secretary may be required for each potential discharge site.
C. After a permit has been issued, permittee shall continue to monitor background water quality
contaminant concentrations in order to determine natural fluctuations in concentrations. Applicable
up-gradient, and on-site ground water monitoring data shall be included in the ground water
quality permit monitoring report.”
SAFETY EVALUATION:
The Executive Secretary's determinations regarding background groundwater quality for the site
are set out in the 2009 Statement of Basis (UDRC 2009), and is based on previous work by both
DUSA and the URS Corporation. These background reports were also considered in light of
ground water geochemical and isotopic sampling and analysis performed by the University of
Utah Department of Geology and Geophysics (Hurst 2008). Those documents and other
documents considered by the Executive Secretary in determining background groundwater
quality at the site are listed in the References section of the September, 2009 Statement of Basis
(UDRC 2009).
New groundwater monitoring wells required to be installed in conjunction with the construction
and use of Cell 4B have yet to be installed; therefore, background ground water quality in these
wells has yet to be determined by the Executive Secretary. New conditions (Parts I.H.6 and
I.H.7) have been added to the Permit to require the installation of these three wells and require
submittal of a background report after 8 quarters of sampling and analysis of these new wells.
FINDING:
The new provisions included in the Permit, and the information contained in the Cell 4B
Environmental Report and other relevant documents the Applicant has submitted, indicate that
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the requirements of UAC R313-24-4 (that invokes UAC R317-6-6.10) will yet be satisfied, as they
involve Cell 4B.
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UAC R317-6-6.12: SUBMISSION OF DATA
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.12 in lieu of comparable requirements in 10CFR40:
“A. Laboratory Analyses
All laboratory analysis of samples collected to determine compliance with these regulations shall be
performed in accordance with standard procedures by the Utah Division of Laboratory Services or
by a laboratory certified by the Utah Department of Health.
B. Field Analyses
All field analyses to determine compliance with these regulations shall be conducted in accordance
with standard procedures specified in R317-6-6.3.L.
C. Periodic Submission of Monitoring Reports
Results obtained pursuant to any monitoring requirements in the discharge permit and the methods
used to obtain these results shall be periodically reported to the Executive Secretary according to
the schedule specified in the ground water discharge permit.”
SAFETY EVALUATION:
These requirements are met by the Ground Water Quality Assurance Plan required under Part
I.E.1(a) of the Permit. This plan was originally submitted to the Division on May 19, 2005 and
has been revised and approved several times since; with the most recent approved version,
Revision 5.0, approved on February 23, 2010. Section I.F.1 of the Permittee’s Ground Water
Discharge Permit requires that groundwater monitoring reports be submitted to the Executive
Secretary quarterly and that such reports include field data sheets and laboratory results.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted indicate that the requirements of UAC R313-24-4 (that invokes UAC
R317-6-6.12) will yet be met, as they involve Cell 4B.
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UAC R317-6-6.13: REPORTING OF MECHANICAL PROBLEMS OR DISCHARGE
SYSTEM FAILURES
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.13 in lieu of comparable requirements in 10CFR40:
“The permittee shall notify the Executive Secretary within 24 hours of the discovery of any
mechanical or discharge system failures that could affect the chemical characteristics or volume of
the discharge. A written statement confirming the oral report shall be submitted to the Executive
Secretary within five days of the failure.”
SAFETY EVALUATION:
The Permit requires such notices to be given in the event of failure to maintain discharge
minimization technology ('DMT") or BAT standards required under the Permit (Part I.G.3) and
if the facility is otherwise out of compliance (Part I.G.4 and Part II.1). The Permit has been
revised to incorporate Cell 4B into this set of requirements.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted indicate that the requirements of UAC R313-24-4 (that invokes UAC
R317-6-6.13) will yet be satisfied, as far they involve Cell 4B.
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UAC R317-6-6.14: CORRECTION OF ADVERSE EFFECTS
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.14 in lieu of comparable requirements in 10CFR40:
“A. If monitoring or testing indicates that the permit conditions may be or are being violated by
ground water discharge operations or the facility is otherwise in an out-of-compliance status, the
permittee shall promptly make corrections to the system to correct all violations of the discharge
permit.
B. The permittee, operator, or owner may be required to take corrective action as described in
R317-6-6.5 if a pollutant concentration has exceeded a permit limit.”
SAFETY EVALUATION:
Pmt I.G.4 of the Permit specifies the actions that must be taken by the Licensee / Permittee in
the event of a violation of a condition of the Permit. The Permit has been revised to incorporate
Cell 4B into this set of requirements.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Licensee has submitted, indicate that the requirements of UAC R313-24-4 (that invokes UAC
R317-6-6.14) will yet be satisfied, as they involve Cell 4B.
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UAC R317-6-6.16: OUT-OF-COMPLIANCE STATUS
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.16 in lieu of comparable requirements in 10CFR40:
“A. Accelerated Monitoring for Probable Out-of-Compliance Status
If the value of a single analysis of any compliance parameter in any compliance monitoring sample
exceeds an applicable permit limit, the facility shall:
1. Notify the Executive Secretary in writing within 30 days of receipt of data;
2. Immediately initiate monthly sampling if the value exceeds both the background
concentration of the pollutant by two standard deviations and an applicable permit limit,
unless the Executive Secretary determines that other periodic sampling is appropriate, for a
period of two months or until the compliance status of the facility can be determined.
B. Violation of Permit Limits
Out-of-compliance status exists when:
1. The value for two consecutive samples from a compliance monitoring point exceeds:
a. one or more permit limits; and
b. the background concentration for that pollutant by two standard deviations (the
standard deviation and background (mean) being calculated using values for the
ground water pollutant at that compliance monitoring point) unless the existing
permit limit was derived from the background pollutant concentration plus two
standard deviations; or
2. The concentration value of any pollutant in two or more consecutive samples is
statistically significantly higher than the applicable permit 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 and supplemental guidance in Guidance For
Data Quality Assessment (EPA/600/R-96/084 January 1998).
C. Failure to Maintain Best Available Technology Required by Permit
1. Permittee to Provide Information
In the event that the permittee fails to maintain best available technology or otherwise fails
to meet best available technology standards as required by the permit, the permittee shall
submit to the Executive Secretary a notification and description of the failure according to
R317-6-6.13. Notification shall be given orally within 24 hours of the permittee's discovery
of the failure of best available technology, and shall be followed up by written notification,
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including the information necessary to make a determination under R317-6-6.16.C.2, within
five days of the permittee's discovery of the failure of best available technology.”
SAFETY EVALUATION:
The determination of when the mill is out of compliance and the procedures to be followed once
the facility is so determined are set out in Part I.G of the Permit, which incorporates the
requirements of UAC R317-6-6.16, and has since original issuance of the Permit in March, 2005.
See also the evaluation under UAC R317-6-6.13: Reporting of Mechanical Problems or
Discharge System Failures, above. The Permit has been revised to incorporate Cell 4B into this
set of requirements.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Applicant has submitted indicate that the requirements of UAC R313-24-4 (that invokes UAC
R317-6-6.16) will yet be satisfied, as they involve Cell 4B.
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UAC R317-6-6.17: PROCEDURE WHEN A FACILITY IS OUT-OF-COMPLIANCE
REGULATORY BASIS:
UAC R313-24-4 invokes UAC R317-6-6.17 in lieu of comparable requirements in 10CFR40:
“A. If a facility is out of compliance the following is required:
1. 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 days of the
detection.
2. The permittee shall initiate monthly sampling, unless the Executive Secretary determines
that other periodic sampling is appropriate, until the facility is brought into compliance.
3. The permittee shall prepare and submit within 30 days to the Executive Secretary a plan
and time schedule for assessment of the source, extent and potential dispersion of the
contamination, and an evaluation of potential remedial action to restore and maintain
ground water quality and insure that permit limits will not be exceeded at the compliance
monitoring point and best available technology will be reestablished.
4. The Executive Secretary may require immediate implementation of the contingency plan
submitted with the original ground water discharge permit in order to regain and maintain
compliance with the permit limit standards at the compliance monitoring point or to
reestablish best available technology as defined in the permit.
5. Where it is infeasible to re-establish BAT as defined in the permit, the permittee may
propose an alternative BAT for approval by the Executive Secretary.”
SAFETY EVALUATION:
The determination of when the mill is out of compliance and the procedures to be followed once
the facility is so determined are set out in Part I.G of the Permit, which incorporates the
requirements of UAC R317-6-6.17. The Permit has been revised to incorporate Cell 4B into this
set of requirements.
FINDING:
The information contained in the Cell 4B Environmental Report and other relevant documents
the Licensee has submitted, indicate that the requirements of UAC R313-24-4 (that invokes UAC
R317-6-6.17), will yet be satisfied, as they involve Cell 4B.
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