DRC-2011-001889 - 0901a068802023cb

- 201 1-00 1889
GROUND WATER QUALITY DISCHARGE PERMIT UGW370004
Statement of Basis
For a
Uranium Milling Facility
South of Blanding, Utah
Owned and Operated by
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 17th Street
Denver, Colorado 80265
February 2011
PURPOSE
The purpose of this Statement of Basis (hereafter SOB) is to describe the technical and
regulatory basis to proposed modifications to requirements found in a Ground Water Quality
Discharge Permit No. UGW370004, (hereafter Pennit) for the Denison Mines (USA) Corp.
(hereafter DUSA) uranium mill facility located about six miles south of Blanding, Utah in
Sections 28, 29, 32, and 33, Township 37 South, Range 22 East, Salt Lake Baseline and
Meridian, San Juan County, Utah.
The changes to the permit are considered minor by the Executive Secretary, and therefore do not
need to be submitted for public comment. Major changes to fhe Permit are those that may have a
potential impact on the protection of public health and the environment. Minor changes to the
Permit are those that are considered to: 1) have no impact on the protection of the environment,
or 2) are more stringent or protective than those already authorized in the existing Permit. The
proposed changes to the Permit are highlighted in redline-strikeout format in Attachment 1.
The changes associated'with Ihis Minor Permit modification include, but are not limited to, the
following:
• Average Total Dissolved Solids (hereafter TDS) concentrations updated for monitoring
wells MW-20 and MW-22.
• Establishment of Ground Water Compliance Limits (hereafter GWCL) for new
monitoring well MW-3 5.
• Addition of Best Available Technology (hereafter BAT) Performance Standards,
monitoring, and reporting requirements for the New Decontamination Pad.
Establishment of sampHng fi-equency for wells MW-20, MW-22, and MW-3 5.
Designation of monitoring wells MW-20 and MW-22 as General Monitoring Wells rather
than Point of Compliance (hereafter POC) wells.
Requirement that at least two new groundwater compliance monitoring wells be installed
hydraulically downgradient, on the southem and westem margins of Tailings Cell 4B.
Requirement that DUSA conduct a detailed hydrogeologic investigation ofthe both the
shallow aquifer and a nearby unsaturated stmctural high located between Tailings Cell
4B and the western margin of White Mesa.
Page 1 of 13
a
Page 2 of 13

BACKGROUND

The White Mesa uranium mill was constructed in 1979 - 1980 and licensed under federal
regulations by the Nuclear Regulatory Commission (hereafter NRC), Source Material License
SUA-1358. On August 16, 2004, the NRC delegated its uranium mill regulatory program to the
State of Utah, by extending Agreement State status. As a result, the Utah Division of Radiation
Control (hereafter DRC) became the primary regulatory authority for the DUSA White Mesa
mill for both radioactive materials and groundwater protection. Later, DUSA was issued a State
Ground Water Quality Discharge Permit No. UGW370004 on March 8, 2005. Previous to the
modification proposed herein today, the Permit was last modified on June 17, 2010.

MINOR PERMIT CHANGES - NEW AND MODIFIED REQUIREMENTS

Ground Water Classification, Part I.A - Table 1

The content of original March 8, 2005 Ground Water Quality Discharge Permit was described in
the related DRC December 1, 2004 Statement of Basis. In it, groundwater classification was
determined on a well-by-well approach in order to acknowledge the spatial variability of
groundwater quality at the DUSA facility, and afford the most protection to those portions of the
shallow aquifer that exhibited the highest quality groundwater. On an interim basis, the
Executive Secretary decided to base the well-by-well groundwater classification on the mean
total dissolved solids (TDS) concentration available at the time, and omit any consideration of
concentration variance. Part IV.N.2 allows the Permit, to be re-opened and modified when a
change in background groundwater quality has been determined.

Groundwater quality data documented in DUSA’s June 1, 2010 Background Groundwater
Quality Report for Wells MW-20 and MW-22, provided an updated mean TDS concentration
and standard deviation for both of these wells. The report showed average TDS in wells MW-20
and MW-22 at 5,663 and 7,537 mg/L, respectively. As a result, Table 1 of the Permit has been
updated with the new mean TDS and standard deviation concentrations.

Groundwater classification was also assigned for well MW-35, for details see discussion below.

Groundwater Monitoring: Monitoring Well MW-35, Part I.C, Table 2

In the previous DUSA Permit modification (dated June 17, 2010), DUSA was required to install
at least three hydraulically downgradient wells (MW-33, MW-34, and MW-35) adjacent to
tailings management Cell 4B in Part I.H.6 of the Permit, under the presumption that they would
be the cell’s monitoring well network.

DUSA installed monitoring wells MW-33, MW-34, and MW-35 between August 30 and
September 2, 2010. After review of the October 11, 2010 technical report prepared by Hydro
Geo Chem, Inc, the Executive Secretary determined that the Tailings Cell 4B well network was
unacceptable and incomplete, as only one well, MW-35, had a sufficient saturated thickness
suitable for both head and groundwater quality sampling. Unfortunately, well MW-33 was
found to be dry, and well MW-34 had only a very thin zone of saturation (around 1-foot).

Page 3 of 13

Because well MW-35 is currently the only suitable down gradient well that is adjacent to
Tailings Cell 4B, it is important that Ground Water Compliance Levels (GWCLs) be set now
rather than after approval of the Background Report for MW-35. This same approach was used
when GWCLs were first established for the existing wells at the White Mesa Uranium Mill in the
original March 8, 2005 Permit (see DRC December 1, 2004 Statement of Basis, p.7).

Because groundwater quality sampling and analysis at well MW-35 has not been reported, nor a
statistical based background quality determined by DUSA or approved, the Executive Secretary
cannot verify if the TDS or any other contaminant is naturally occurring there for purposes of
selecting GWCLs. Historically, all other monitoring wells installed at the facility have been
found to contain either Class II (500 mg/L < TDS < 3,000 mg/L) or Class III groundwater (3,000
mg/L < TDS < 10,000 mg/L). Hence, to accelerate the process of collecting sufficient
groundwater quality data, and provide a groundwater quality Point of Compliance (POC) well at
Tailings Cell 4B, the Executive Secretary will initially and conservatively assign a Class II
designation to well MW-35 in both Tables 1 and 2 of the Permit. This assignment is made on the
conservative presumption that naturally occurring contaminants at well MW-35 are
“undetectable.” Accordingly, the GWCLs set today for well MW-35 in Table 2 of the Permit
were calculated by multiplying the Ground Water Quality Standard (hereafter GWQS) by a
factor of 0.25, as allowed by UAC R317-6-4.5(B)(2).

After submittal and Executive Secretary approval of the Background Ground Water Quality
Report for wells MW-35, MW-36, MW-37, pursuant to Part I.H.5, (formally Part I.H.7) the
Permit will be reopened and the GWCLs modified for well MW-35.

The Executive Secretary acknowledges that the interim GWCLs for MW-35 are not based on
background groundwater quality for that well and that any exceedances of the interim GWCLs
for MW-35 may be solely due to background influences.

BAT Performance Standards for the New Decontamination Pad, Part I.D.14

Performance standards for the New Decontamination (hereafter NDP) have been added at Part
I.D.14. The most significant of these standards include a requirement to define non-compliance
when fluids are measured in the NDP leak detection system, and periodic cleaning, inspection,
and repair of the floor of the wash bay.

Routine Groundwater Compliance Monitoring Frequency - Quarterly Monitoring - Future
Cell 4B Downgradient Wells to be Installed, Part I.E.1(b)(2 and 3)

In the previous DUSA Permit modification (dated June 17, 2010), DUSA was required to install
at least three hydraulically downgradient wells (MW-33, MW-34, and MW-35) adjacent to
tailings management Cell 4B in Part I.H.6 of the Permit. These monitoring wells were to be the
well monitoring network for Tailings Cell 4B. As described above, DUSA installed monitoring
wells MW-33, MW-34, and MW-35 between August 30 and September 2, 2010 and of these
three wells only one (MW-35) was found to be suitable for head and groundwater quality
sampling.

As described above, the Executive Secretary has conservatively assigned a Class II aquifer status
to well MW-35. Further, a conservative quarterly sampling frequency has been assigned in order
Page 4 of 13

to accelerate collection of groundwater quality data and future determination of background
groundwater quality.

Part I.H.4 (formally Part I.H.6) has been revised to required DUSA to install replacement wells
for wells MW-33 and MW-34 (for more information, see p.5 below). These replacement wells
will be known as MW-36 and MW-37. Part I.E.1(b)(3) of the Permit has been modified, in that,
wells MW-33 and MW-34 have been replaced with MW-36 and MW-37, respectively.

Routine Groundwater Compliance Monitoring - Semi-annual Monitoring, Part I.E.1(c)(3)

In the original March 8, 2005 Permit, the Executive Secretary approved a previous DUSA
proposal that allowed two different frequencies of baseline groundwater compliance monitoring,
based on local groundwater velocity (see DRC December 1, 2004 Statement of Basis), as
follows:
• Semi-annual (2-times/year) where groundwater velocity is less than 10 feet/year, and
• Quarterly (4-times/year) where groundwater velocity is equal to or greater than 10
feet/year.

Part I.E.2 of the Permit required DUSA to submit a Background Report that included an average
linear groundwater velocity calculated for MW-20 and MW-22, based on well specific hydraulic
conductivity, hydraulic gradient, and effective aquifer porosity. On June 1, 2010, DUSA
submitted the Background Quality Report for Wells MW-20 and MW-22 (hereafter June 1, 2010
Background Report). The June 1, 2010 DUSA Background Report provided aquifer
permeability test results in wells MW-20 and MW-22 and calculated average linear groundwater
velocities at 0.33 feet per year (ft/yr) and 0.43 ft/yr, respectively (see June 1, 2010 Background
Report, Table 2). Therefore, the Executive Secretary has assigned a semi-annual sampling
frequency to wells MW-20 and MW-22 in Part I.E.1(c) of the Permit.

Groundwater Monitoring: General Monitoring Wells MW-20 and MW-22, Part I.E.2

Monitoring wells MW-20 and MW-22 were installed in 1994 and are located at a distance of
more than 3,000 feet south of the tailings cells. Because DUSA had not provided any monitoring
data for these wells, the DRC added a new requirement at Part I.E.2 of the Permit during the
March 17, 2008 Permit modification to mandate DUSA begin quarterly monitoring in both wells.
After eight consecutive quarters of sampling, DUSA was required to submit a report determining
background groundwater quality and a calculation of groundwater velocities in the vicinity of
wells MW-20 and MW-22.

On June 1, 2010, DUSA submitted the Background Quality Report for Wells MW-20 and MW-
22 (June 1, 2010 Background Report). After reviewing the June 1, 2010 Background Report, the
DRC has determined the following:

• Monitoring wells MW-20 and MW-22 are far downgradient from the nearest tailings
impoundment. MW-20 is about three quarters of a mile away and MW-22 is about a mile
away and cross gradient from the downgradient edge of Cell 4A making it unlikely that
groundwater quality in samples from these wells today has been influenced by potential
tailings cell seepage.
Page 5 of 13

• Two far-downgradient monitoring wells (MW-3 and MW-3A already exist between MW-
20 and the nearest tailings cell.
• Calculated average linear groundwater velocities for MW-20 and MW-22 are 0.33 feet
per year (ft/yr) and 0.43 ft/yr, respectively.

For the reasons stated above, monitoring wells MW-20 and MW-22 will not be added as Point of
Compliance (POC) wells at this time; however, they will remain as General Monitoring Wells
where aquifer head and groundwater quality information will be collected for informational
purposes. The Executive Secretary reserves the right to revisit the status of monitoring wells
MW-20 and MW-22 in the future. Because groundwater velocities at wells MW-20 and MW-22
are less than 10 feet a year, these wells will be sampled on a semi-annual frequency (as per Part
I.E.1). However, groundwater head monitoring will continue to be measured on a quarterly basis
in these wells, as required by Part I.E.3 of the Permit and Section 6.1.1 of the DUSA QAP.

Groundwater Head Monitoring, Part I.E.3(c)

In the previous DUSA Permit modification (dated June 17, 2010), DUSA was required to install
at least three hydraulically downgradient wells (MW-33, MW-34, and MW-35) adjacent to
tailings management Cell 4B (Part I.H.6). These monitoring wells were to be the well
monitoring network for Tailings Cell 4B.

As discussed above, of the three wells installed near Tailings Cell 3, only MW-35 was found
acceptable for both head and groundwater quality monitoring needs. Well MW-33 was found to
be dry and MW-34 showed very limited saturation (around 1-foot), making it very difficult to
sample for groundwater quality.

Well MW-34 was added to Part I.E.3(c) as a Head Monitoring Well. Groundwater head
monitoring in well MW-34 will be measured on a quarterly basis, as required by Part I.E.3 of the
Permit and Section 6.1.1 of the DUSA QAP.

Weekly New Decontamination Pad Inspection, Part I.E.7(g)

Part I.E.7(g) was added to the Permit, to require DUSA to conduct weekly inspections of the
NDP, as to demonstrate compliance with the performance standards found in Part I.D.14.

Decontamination Pads Annual Inspection Report, Part I.F.12

Part I.F.12 was added to the Permit, to require DUSA to conduct annual inspection of the wash
bay concrete floor at the New and Existing Decontamination Pads. These inspections will take
place during the second quarter of each year, and will include, but is not limited to cleaning,
visual inspection for deterioration, proper repair / maintenance, documentation, and reporting.
The inspection findings will be included in the 2nd Quarter DMT Monitoring Report due
September 1, of each calendar year.

Installation of New Groundwater Monitoring Wells, former Part I.H.6 - New Part I.H.4

In the previous DUSA Permit modification (dated June 17, 2010), DUSA was required to install
at least three hydraulically downgradient wells (MW-33, MW-34, and MW-35) adjacent to
Page 6 of 13

tailings management Cell 4B in Part I.H.6 of the Permit. These monitoring were to be the well
monitoring network for Tailings Cell 4B.

As discussed above, of the three wells installed near Tailings Cell 3, only MW-35 was found
acceptable for both head and groundwater quality monitoring. Therefore, the Executive
Secretary has determined the Cell 4B monitoring well network to be incomplete. To resolve this
issue, Part I.H.4 (formally Part I.H.6) of the Permit has been revised to require that the Permittee
install at least two additional hydraulically downgradient wells adjacent to Tailings Cell 4B, to
replace wells MW-33 (dry) and MW-34 (very limited saturation). In the future, these two new
wells will be known as MW-36 and MW-37. If additional wells are needed, they will be
uniquely labeled and identified at a later date. Such new wells must be located and completed as
follows:

1. At least one well needs to be placed on the south side of Cell 4B between existing wells
MW-15 and MW-34,
2. At least one well needs to be located on the west side of Cell 4B, between MW-33 and
MW-35.
3. All new wells must be properly screened / completed in accordance with Part I.F.6 of the
Permit, and demonstrate a saturated thickness of about 5-feet or more inside the well
screen.

These replacement wells are required be installed, and an as-built report submitted for Executive
Secretary review / approval before June 30, 2011. In the event that additional work or
information is required by the Executive Secretary, the Permittee will fully provide such
information within a schedule agreed upon by the Executive Secretary.

Reference to former Part I.H.6 of the Permit elsewhere in the Permit (in Parts I.E.1(b)(3) and
I.H.5) have been updated.

Background Groundwater Quality Report for New Monitoring Wells, former Part I.H.7 -
New Part I.H.5

In the previous DUSA Permit modification (dated June 17, 2010), DUSA was required to
commence a quarterly groundwater sampling program in three new wells (MW-33, MW-34,
MW-35) within 30 calendar days of receipt of written Executive Secretary approval for use of
Tailings Cell 4B. It was also anticipated that after completion of eight consecutive quarters of
groundwater sampling and analysis of these three new wells, that DUSA would submit for
Executive Secretary approval a Background Groundwater Quality Report.
As discussed above, unexpected hydrogeologic conditions were found in two of the monitoring
wells required for Cell 4B. Therefore, it is appropriate to modify the requirements of Part I.H.5
(formally Part I.H.7). In general, Part I.H.5 (formally Part I.H.7) remains largely the same as
before, except the new wording references for the new wells required under Part I.H.4 (formally
Part I.H.6) of the Permit.

Reference to former Part I.H.7 of the Permit elsewhere in the Permit [Part I.E.1(b)(3)] has been
updated.

Page 7 of 13

New Compliance Schedule Item for Detailed Southwest Hydrogeologic Investigation and
Report (new Part I.H.6)
In Part I.H.10 of the previous DUSA Permit modification (dated June 17, 2010), DUSA was
required to conduct an additional hydrogeologic and field investigation to, among other things:
1) resolve uncertainties and apparent discrepancies in elevation survey data for the upper
geologic contact of the Brushy Basin Shale and its relationship to springs and seeps at the
western margin of White Mesa largely thru surface geologic mapping and elevation survey work,
2) identify the closest points of shallow groundwater discharge at the western margin of White
Mesa, and 3) estimate travel time for the shallow groundwater near Tailings Cell 4B to reach the
nearest surface discharge point(s).

Part I.H.10 also mandated that before use of Cell 4B for tailings disposal that DUSA: 1) have the
report certified by a Utah Licensed Professional Geologist or Engineer, and submitted for
Executive Secretary review, and 2) if the Executive Secretary determines that additional
information is needed, DUSA will provide the requested information and resolve all issues
identified on a schedule approved by the Executive Secretary.

DUSA submitted a November 12, 2010 Hydrogeology of the Perched Groundwater Zone and
Associated Seeps and Springs Near the White Mesa Uranium Mill Site Report, prepared by
Hydro Geo Chem, Inc. (hereafter November 12, 2010 HGC Report). In the November 12, 2010
HGC Report, HGC claims the subsurface dry zone to the southwest of Cell 4B is defined by an
area where the structural elevation of the Brushy Basin Shale contact rises above the perched
water level elevation. HGC plots this dry area on Figure 4 of the November 12, 2010 HGC
Report, but admits “the actual extent of the dry area shown in Figure 4 is uncertain because
there are few data points to define it.” After review of this report, the Executive Secretary
hereby determines:

1. The November 12, 2010 HGC Report did not determine the shallow aquifer pathway or
travel time between Tailings Cell 4B and Cottonwood Seep, based on the elevation and
apparent lithology near Cottonwood Seep. This finding is illustrated in the Figure 11 of
the November 12, 2010 HGC Report.
2. Additional hydrogeologic investigation is required to accomplish this task, more than
what was anticipated at the time of the June 17, 2010 Permit modification. This
additional work will likely include, but is not limited to: multiple new borings and
geologic logging, installation of multiple piezometers and/or monitoring wells, collection
of other critical hydraulic properties and information, interpretation of said information,
and preparation of a new investigation report.
3. The Additional hydrogeologic study will be conducted by the Permittee to eliminate the
uncertainty now associated with the location and extent of the subsurface “dry area”
identified in the November 12, 2010 HGC Report, and its impact on local shallow
groundwater flow directions and travel times.

To this end, the Executive Secretary has removed Part I.H.10 from the Permit and in its place
added a new compliance item at Part I.H.6, based on the understanding that the new
requirements will provide adequate protection of underlying groundwater resources and also
allow for Cell 4B to begin tailings disposal operations, because:

Page 8 of 13

1. Tailings Cell 4B has been designed and constructed with a double High Density
Polyethylene (HDPE) liner and an intervening leak detection system (LDS) that meets
Best Available Technology (BAT) requirements under UAC R317-6.
2. BAT operational, maintenance, and monitoring procedures have been approved by the
Executive Secretary. As a result, the modified Permit mandates DUSA maintain the
tailings wastewater head inside the Cell 4B LDS at a level of 1-foot or less, thereby
minimizing potential for seepage release to foundation soils / rock, or groundwater.
3. The vadose zone below Cell 4B is approximately 100-feet thick, and should require a
significant amount of time for potential cell leakage to reach the shallow water table and
travel to a nearby monitoring well. This time can be used to complete the required
investigation, submit the report, and secure Executive Secretary approval.

Therefore, under these provisions, the Executive Secretary has determined it appropriate for
DUSA to commence disposal operations at Cell 4B.

The new Permit requirements under Part I.H.6, mandate DUSA to conduct a new hydrogeologic
investigation and submit a report to determine, among other things:

1. The full extent and degree of hydraulic connection of the shallow aquifer near Tailings
Cell 4B with all springs / seeps at the western margin of White Mesa (including
Cottonwood Seep).
2. The full physical extent of the subsurface structural ridge or dry area at the upper Brushy
Basin Shale contact found between Tailings Cell 4B and the western margin of White
Mesa.
3. Key and representative hydraulic properties of the shallow groundwater across the same
area, including, but not limited to: flow direction(s), hydraulic gradient(s), hydraulic
conductivities, average groundwater linear velocities and travel times to points of
discharge found at the western margin of White Mesa (including Cottonwood Seep).

Further, Part I.H.6 requires that this investigation report be certified by a Utah Licensed
Professional Engineer or Geologist, and also include:
• Installation of multiple piezometers and/or wells where the shallow aquifer saturated
thickness is 5-feet or more is encountered. These new piezometers / wells shall comply
with the design, construction, and development requirements found in Part I.E.4 and I.F.6
of this Permit.
• Demonstration of the geologic and hydrologic relationship of this structural high with
groundwater that flows at all springs / seeps at the western margin of White Mesa,
including nearby Cottonwood Spring.
• Perform geologic logging of all borings / wells. These borings shall be certified by a
Utah licensed Professional Geologist
• Collection of continuous core samples. At a minimum, said core will be collected in each
boring / piezometer / well immediately above and across the upper geologic contact of
Brushy Basin Shale member of the Morrison Formation.
Page 9 of 13

Under Part I.H.6, DUSA will complete all field investigation work and shall submit the
investigation report for Executive Secretary review and approval on or before June 30, 2011.
The content of this is report will include, but is not limited to:
1. A revised structural contour map for the upper Brushy Basin Shale for the entire DUSA
facility and White Mesa proper.
2. A revised shallow aquifer saturation thickness map and equipotential map (with
groundwater stream tubes), based on contemporaneous groundwater head data for the
entire DUSA facility and White Mesa proper.
3. Appropriate geologic and hydrogeologic maps and cross-sections (to scale).
4. All supporting hydrogeologic field data, laboratory results, and calculations.
This investigation is critical in helping the DRC and DUSA determine groundwater flow
directions near Cell 4B, and will also be helpful for determining locations for future wells for
future tailings cells, if DUSA continues to expand tailings disposal to the south.

MINOR PERMIT CHANGES - RESOLVED / REMOVED COMPLIANCE SCHEDULE
ITEMS

Since the last Permit modification (June 17, 2010) several compliance schedule requirements
(Part I.H) have been resolved; allowing the Executive Secretary to remove from the current
Permit, as discussed below.

Completion of Compliance Item 4, New Decontamination Pad, Part I.H.4

Part I.H.4 of the Permit required DUSA to perform a number of items that were required to be
resolved before DUSA could begin using the NDP, including: approvals of a revised Discharge
Minimization Technology Plan (DMT Plan), NDP As-Built drawings, and a revised Contingency
Plan. This requirement was resolved as follows:

• DUSA submitted a Revised DMT Plan on January 10, 2011. This DMT was approved by
the Executive Secretary on January 20, 2011.
• On March 12, 2010 DUSA submitted a response to the DRC February 4, 2010 NDP
Request For Information (RFI). The March 12, 2010 submittal included revised As-Built
drawings (dated November 12, 2009) for the NDP. DRC review of the As-Built
drawings showed that DUSA appropriately addressed the DRC concern (B.6) in the DRC
February 4, 2010 NDP RFI.
• DUSA submitted a revised Contingency Plan (Revision 3) on September 2, 2010. In an October
11, 2010 DRC letter, the DRC stated regarding the Contingency Plan: “…our response regarding
the Contingency Plan will not be addressed in this letter, but will be addressed under separate
cover. Review of that plan will proceed independently, and will not be tied to the use of the
NDP.”

As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.4 of the Permit. Therefore, the Executive Secretary has struck this requirement from the
Permit.

Page 10 of 13

Completion of Compliance Item 5, Existing Decontamination Pad, Part I.H.5

Part I.H.5 of the Permit required DUSA to submit an updated BAT/DMT Monitoring Plan for
Executive Secretary approval, and perform an annual inspection of the EDP. DUSA compliance
is summarized below:

• DUSA submitted a Revised DMT Plan on January 10, 2011. This DMT Plan included
monitoring requirements and inspection details for the EDP. This DMT was approved by
the Executive Secretary on January 20, 2011.
• DUSA conducted the first annual inspection of the EDP on May 14, 2010, which was
documented in the August 30, 2010 DMT Performance Standards Monitoring Report and
Cell 4A BAT Performance Standards Monitoring Report.

As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.5 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the Permit

Completion of Compliance Item 8 Revised BAT, Monitoring, Operations, and Maintenance
Plan for Cells 4A and 4B, Part I.H.8

Part I.H.8 of the Permit required DUSA to 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 before any tailings or wastewater disposal in Cell
4B. DUSA compliance is summarized below:

• DUSA submitted a Revised revised Cell 4A BAT, Monitoring, Operations and
Maintenance Plan, and a Cell 4B BAT, Monitoring, Operations and Maintenance Plan on
January 21, 2011. These operations maintenance plans were approved by the Executive
Secretary on January 26, 2011.

As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.8 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the Permit.

Completion of Compliance Item 9, Cell 4B As-Built Report, Part I.H.9

Part I.H.9 of the Permit required DUSA to submit and receive Executive Secretary approval of a
Cell 4B engineering As-Built report to document all construction activities before any tailings or
wastewater disposal in Cell 4B. DUSA compliance is summarized below:

• DUSA submitted a Cell 4B Construction Quality Assurance Report (hereafter QA/QC
Report) on November 30, 2010. DUSA also submitted Addendums to the November 30,
2010 QA\QC Report on January 21 and 27, 2011. The Cell 4B Construction Quality
Assurance Report was approved by the Executive Secretary on January 27, 2011.

As described above, DUSA has satisfied the requirements of Permit compliance schedule item
I.H.9 of the Permit. Therefore, the Executive Secretary has struck this compliance schedule item
from the Permit.

Page 11 of 13

Completion of Compliance Item 10, Additional Hydrogeologic Investigation and Report,
Part I.H.10

Part I.H.10 of the Permit required DUSA to conduct an additional hydrogeologic and field
investigation to: resolve uncertainties and apparent discrepancies in elevation survey data for the
upper geologic contact of the Brushy Basin Shale and its relationship to springs and seeps at the
western margin of White Mesa largely thru surface geologic mapping and elevation survey work,
identify the closest points of shallow groundwater discharge at the western margin of White
Mesa, and estimate travel time for the shallow groundwater near Tailings Cell 4B to reach the
nearest surface discharge point(s).

DUSA submitted a November 12, 2010 Hydrogeology of the Perched Groundwater Zone and
Associated Seeps and Springs Near the White Mesa Uranium Mill Site Report, prepared by
Hydro Geo Chem, Inc. After DRC review of this report, it was determined that additional work
was required to determine the shallow aquifer pathway or travel time between Tailings Cell 4B
and Cottonwood Seep. This finding is illustrated in the Figure 11 of the November 12, 2010
HGC Report.

Therefore, to address this problem, the Executive Secretary decided to modify the requirement to
clarify the Permittee’s obligations (i.e. perform additional studies). The Executive Secretary has
chosen to add a new compliance item at Part I.H.6 of the Permit; which requires DUSA to
conduct an additional and broader hydrogeologic investigation, for details see pages 6 - 9, above.

Because the former Part I.H.10 is in need of these changes, and has been replaced by Part I.H.6,
the Executive Secretary has struck the former compliance schedule item from the Permit.

Completion of Compliance Item 11, Corrections to Engineering Drawing Sheet 6 of 8, Part
I.H.11

Part I.H.11 of the Permit required DUSA to submit a revised Engineering Drawing Sheet 6 of 8
prior to construction of Tailings Cell 4B. DUSA compliance is summarized below:

• The prior requirement mandated that DUSA submit this engineering drawing before
construction of Cell 4B.
• Contrary to this requirement, DUSA did not submit a revised drawing before
construction. However, they did submit the revised drawing with the Cell 4B
Construction Quality Assurance Report Addendum submitted on January 27, 2011. After
review of the drawing the Executive Secretary determined the required design changes
were made during construction. Further, the Cell 4B Construction Quality Assurance
Report was approved by the Executive Secretary on January 27, 2011.

The Executive Secretary has decided to use enforcement discretion in this situation, and has
determined that DUSA has satisfied the original requirement. Therefore, the Executive Secretary
has struck this compliance schedule item from the Permit. The reference to Part I.H.11 of the
Permit at Part I.D.12, Table 6 has also been deleted.

Page 12 of 13

References

Denison Mines (DUSA) Corp., January 10, 2010, “White Mesa Mill Tailings Management
System and Discharge Minimization Technology (DMT) Monitoring Plan,” 49 pp.
Hydro Geo Chem, Inc., Prepared for Denison Mines (USA) Corp., November 12, 2010,
“Hydrogeology of the Perched Groundwater Zone and Associated Seeps and Springs
Near the White Mesa Uranium Mill Site Report.” 90 pp., 1 table, 12 figures, 2 appendices
GeoSyntec Consultants, San Diego, California., Prepared for Denison Mines (USA) Corp.,
November 30, 2010, “Cell 4B Construction Quality Assurance Report.” 2,200 pp., 13
appendices.
GeoSyntec Consultants, San Diego, California., Prepared for Denison Mines (USA) Corp.,
January 21, 2011, “Response to Review of Cell 4B Construction and Request for
Information Cell 4B Construction Quality Assurance Report Addendum White Mesa Mill
- Cell 4B.” 38 pp., 3 attachments.
GeoSyntec Consultants, San Diego, California., Prepared for Denison Mines (USA) Corp.,
January 26, 2011, “Response to Division of Radiation Control Letter 25 January 2011 -
Response to Review of Cell 4B Construction and Request for Information Cell 4B
Construction Quality Assurance Report Addendum White Mesa Mill - Cell 4B.” 12 pp., 2
attachments.
INTERA, Inc., Prepared for Denison Mines (USA) Corp., June 1, 2010, “Background
Groundwater Quality Report for Wells MW-20 and MW-22 for Denison Mines (USA)
Corp.’s White Mesa Mill Site, San Juan County, Utah.”
Utah Division of Radiation Control, December 1, 2004, “Statement of Basis for a Uranium
Milling Facility at White Mesa, South of Blanding, Utah,” unpublished regulatory
document, 57 pp., and 12 attachments.
Utah Division of Radiation Control, April 6, 2010, “Statement of Basis for a Uranium Milling
Facility at White Mesa, South of Blanding, Utah,” unpublished regulatory document, 20
pp., and 1 attachment.
Utah Division of Radiation Control, January 20, 2011, “January 10, 2011 DUSA Letter,
Transmits Revised DMT and BAT O&M Plans, which addresses White Mesa Uranium
Mill Tailings Cell 4B, etc.; January 6, 2011 DRC Letter, Review of Revised DMT and
BAT O & M Plans; Contingent Approval of the Proposed DMT Plan,” letter from
Rusty Lundberg to Jo Ann Tischler 1 p.
Utah Division of Radiation Control, January 26, 2011, “January 21, 2011 DUSA Letter, which
Transmits a Revised Cell 4A and 4B BAT O&M Plan (BAT O&M Plan); January 21,
2011 DRC Comment Letter, Requesting Information on the BAT O&M Plan; Plan
Approval,” letter from Rusty Lundberg to Jo Ann Tischler 1 p.
Utah Division of Radiation Control, January 27, 2011, “November 30, 2010, “Cell 4B
Construction Quality Assurance Report; Report Approval,” letter from Rusty Lundberg
to Harold R. Roberts 1 p.
Utah Division of Radiation Control, January 27, 2011, “Part I.H.4 of the DUSA White Mesa
Uranium Mill Ground Water Discharge Permit No. UGW370004 - New Decontamination Pad
(NDP): Authorization to Operate the NDP,” letter from Rusty Lundberg to David C.
Frydenlund 2 p.
Page 13 of 13

Utah Division of Water Quality, January 1, 2011, Administrative Rules for Ground Water
Quality Protection, R317-6, Utah Administrative Code.
Utah Division of Water Quality, March 8, 2005, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.
Utah Division of Water Quality, June 13, 2006, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.
Utah Division of Water Quality, March 17, 2008, Ground Water Discharge Permit, DUSA,
Permit No. UGW370004.
Utah Division of Water Quality, June 20, 2010, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.
Utah Division of Water Quality, June 17, 2010, Ground Water Discharge Permit, DUSA, Permit
No. UGW370004.

PRG/LM:prg

ATTACHMENT 1

DUSA GW Permit Final - Redline/Strikeout Version
February 14, 2011

Permit No. UGW370004

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

GROUND WATER DISCHARGE PERMIT

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

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

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

The permit is based on representations made by the Permittee and other information contained in the
administrative record. It is the responsibility of the Permittee to read and understand all provisions of
this 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 ________, 20110

_______________________.
Co-Executive Secretary
Utah Water Quality Board

i
Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS................................................................................ 1
A. GROUND WATER CLASSIFICATION....................................................................................... 1
B. BACKGROUND WATER QUALITY ......................................................................................... 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.............................. 10
5. BAT Design Standards for Tailings Cell 4A.............................................................. 11
6. BAT Performance Standards for Tailings Cell 4A..................................................... 13
7. Definition of 11e.(2) Waste........................................................................................ 14
8. Closed Cell Performance Requirements..................................................................... 14
9. Facility Reclamation Requirements............................................................................ 14
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.............................................................. 15
13. BAT Performance Standards for Tailings Cell 4B..................................................... 18
14. BAT Performance Standards for the New Decontamination Pad............................... 19
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING............. 20
1. Routine Groundwater Compliance Monitoring.......................................................... 20
2. Groundwater Monitoring: General Monitoring Wells MW-20 and MW-22.............. 21
3. Groundwater Head Monitoring................................................................................... 22
4. Groundwater Monitoring Well Design and Construction Criteria............................. 22
5. Monitoring Procedures for Wells ............................................................................... 22
6. White Mesa Seep and Spring Monitoring................................................................... 23
7. DMT Performance Standard Monitoring.................................................................... 23
8. BAT Performance Standard Monitoring..................................................................... 25
9. On-site Chemicals Inventory...................................................................................... 26
10. Tailings Cell Wastewater Quality Monitoring............................................................ 26
11. Groundwater Monitoring Modifications..................................................................... 27
12. BAT Performance Standard Monitoring..................................................................... 27
F. REPORTING REQUIREMENTS .............................................................................................. 28
1. Routine Groundwater Monitoring Reports................................................................. 28
2. Routine DMT Performance Standard Monitoring Report.......................................... 30
3. Routine BAT Performance Standard Monitoring Reports ......................................... 30
4. DMT and BAT Performance Upset Reports............................................................... 30
5. Other Information....................................................................................................... 30
6. Groundwater Monitoring Well As-Built Reports....................................................... 30
7. White Mesa Seeps and Springs Monitoring Reports.................................................. 31
8. Chemicals Inventory Report....................................................................................... 32
9. Tailings Cell Wastewater Quality Reports ................................................................. 32
10. Revised Hydrogeologic Report................................................................................... 32
11. Annual Slimes Drain Recovery Head Report............................................................. 32
12. Decontamination Pads Annual Inspection Report...................................................... 33
G. OUT OF COMPLIANCE STATUS ........................................................................................... 33
1. Accelerated Monitoring Status ................................................................................... 33

ii
2. Violation of Permit Limits.......................................................................................... 33
3. Failure to Maintain DMT or BAT Required by Permit.............................................. 33
4. Facility Out of Compliance Status.............................................................................. 34
H. COMPLIANCE SCHEDULE REQUIREMENTS.......................................................................... 35
1. On-site Chemicals Inventory Report .......................................................................... 35
2. Infiltration and Contaminant Transport Modeling Work Plan and Report................. 35
3. Plan for Evaluation of Deep Supply Well WW-2....................................................... 36
4. Installation of New Groundwater Monitoring Wells.................................................. 38
5. Background Groundwater Quality Report for New Monitoring Wells...................... 39
6. Detailed Southwest Hydrogeologic Investigation...................................................... 41
PART II. REPORTING REQUIREMENTS ................................................................................ 43
A. REPRESENTATIVE SAMPLING............................................................................................. 43
B. ANALYTICAL PROCEDURES................................................................................................ 43
C. PENALTIES FOR TAMPERING. ............................................................................................. 43
D. REPORTING OF MONITORING RESULTS .............................................................................. 43
E. COMPLIANCE SCHEDULES .................................................................................................. 43
F. ADDITIONAL MONITORING BY THE PERMITTEE ................................................................. 43
G. RECORDS CONTENTS.......................................................................................................... 43
H. RETENTION OF RECORDS ................................................................................................... 43
I. NOTICE OF NONCOMPLIANCE REPORTING.......................................................................... 44
J. OTHER NONCOMPLIANCE REPORTING ............................................................................... 44
K. INSPECTION AND ENTRY .................................................................................................... 44
PART III. COMPLIANCE RESPONSIBILITIES....................................................................... 45
A. DUTY TO COMPLY.............................................................................................................. 45
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS ....................................................... 45
C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE ..................................................... 45
D. DUTY TO MITIGATE ........................................................................................................... 45
E. PROPER OPERATION AND MAINTENANCE .......................................................................... 45
PART IV. GENERAL REQUIREMENTS................................................................................... 46
A. PLANNED CHANGES ........................................................................................................... 46
B. ANTICIPATED NONCOMPLIANCE ........................................................................................ 46
C. PERMIT ACTIONS ............................................................................................................... 46
D. DUTY TO REAPPLY............................................................................................................. 46
E. DUTY TO PROVIDE INFORMATION ...................................................................................... 46
F. OTHER INFORMATION ........................................................................................................ 46
G. SIGNATORY REQUIREMENTS .............................................................................................. 46
H. PENALTIES FOR FALSIFICATION OF REPORTS ..................................................................... 47
I. AVAILABILITY OF REPORTS ............................................................................................... 47
J. PROPERTY RIGHTS ............................................................................................................. 47
K. SEVERABILITY ................................................................................................................... 47
L. TRANSFERS ........................................................................................................................ 47
M. STATE LAWS ...................................................................................................................... 48
N. REOPENER PROVISIONS...................................................................................................... 48

iii
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.............................. 15
Table 7. Groundwater Monitoring Reporting Schedule ............................................................... 29
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-35 TBD TBD TBD 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)72 5,6105,663 57114
MW-22(4)82 7,3657,537 361365
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 headgeneral monitoring wells as per
Part I.E.2. Average concentrations and standard deviations for wells MW-20 and MW-22 were provided by the Permittee for the period
between June, 2008 and February, 2010calculated by DRC staff from data from the DUSA 2nd and 3rd Quarters of 2008 Routine
Groundwater Monitoring Reports.. This data was obtained from the Permittee’s Background Groundwater Quality Report for wells MW-20
and MW-22 dated June, 2010.
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
Part I.B & I.C
Permit No. UGW370004
2
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 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.

3
Table 2. Groundwater Compliance Limits (GWCL)
Upgradient Wells Down or Lateral Gradient Wells
MW-1
(Class II)
MW-18
(Class III)
MW-19
(Class III)
MW-27
(Class III)
MW-2
(Class III)
MW-3
(Class III)
MW-3A
(Class III)
MW-5
(Class II)
MW-11
(Class II)
MW-12
(Class III)
MW-14
(Class III)
MW-15
(Class III)
Contaminant GWQS (1) GWCL (6) GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL (7) GWCL GWCL GWCL
Nutrients (mg/L)
Ammonia (as N) 25 (2) 6.25 0.27 0.31 12.5 12.5 1.16 0.6 1.02 6.25 0.6 12.5 0.21
Nitrate + Nitrite (as N) 10 2.5 2.5 2.83 5.6 0.12 0.73 1.3 2.5 2.5 5 5 0.27
Heavy Metals (µg/L)
Arsenic 50 12.5 25 25 25 25 25 25 17 15 25 25 25
Beryllium 4 1 2 2 2 2 2 2 1 1 2 2 2
Cadmium 5 4.2 (8) 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 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)
MW-35
(Class II)
Contaminant GWQS (1) GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL GWCL (7) GWCL (9)
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 6.25
Nitrate + Nitrite (as N) 10 5 (8) 5 5 5 0.62 5 5 2.5 5 5 2.5
Heavy Metals (ug/l)
Arsenic 50 25 25 17 25 25 21 25 12.5 25 25 12.5
Beryllium 4 2 2 2 2 2 2 2 1 2 2 1
Cadmium 5 2.5 2.5 2.5 1.5 2.5 5.2 2.5 1.25 2.5 4.72 1.25
Chromium 100 50 50 50 50 50 50 50 25 50 50 25
Cobalt 730 (5) 365 365 365 365 365 47 365 182.5 365 75.21 182.5
Copper 1,300 650 650 650 650 650 650 650 325 650 650 325
Iron 11,000 (5) 5,500 5,500 4,162 5,500 2,675.83 299 1,869 2,750 5,500 14,060 2,750
Lead 15 7.5 7.5 7.5 7.5 7.5 7.5 7.5 3.75 7.5 7.5 3.75
Manganese 800 (4) 915.4 550 7,507 1,806 1,610 1,837 5,624 61 400 5,594.90 200
Mercury 2 1 1 1 1 1 1 1 0.5 1 1 0.5
Molybdenum 40 (2) 20 20 20 20 20 20 20 10 20 20 10
Nickel 100 (3) 50 50 50 50 50 50 50 25 50 94 25
Selenium 50 25 25 25 25 25 11.1 25 34 71 25 12.5
Silver 100 50 50 50 50 50 50 50 25 50 50 25
Thallium 2 1 1.5 1 1.1 1 1 1.2 0.5 1 1 0.5
Tin 17,000 (4) 8,500 8,500 8,500 8,500 8,500 8,500 8,500 4,250 8,500 8,500 4,250
Uranium 30 (3) 46.66 32 11.9 6.5 41.8 4.9 15 8.32 9.1 5.26 7.5
Vanadium 60 (4) 30 30 30 30 30 30 30 15 30 30 15
Zinc 5,000 2,500 74 2,500 2,500 2,500 83 30 1,250 2,500 230 1,250
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 3.75
Volatile Organic Compounds (ug/l)
Acetone 700 (4) 350 350 350 350 350 350 350 175 350 350 175
Benzene 5 2.5 2.5 2.5 2.5 2.5 2.5 2.5 1.25 2.5 2.5 1.25
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 1,000
Carbon Tetrachloride 5 2.5 2.5 2.5 2.5 5 2.5 2.5 1.25 2.5 2.5 1.25
Chloroform 70 (4) 35 35 35 35 70 35 35 17.5 35 35 17.5
Chloromethane 30 (2) 15 5.7 15 15 30 4.6 15 7.5 6.1 15 7.5
Dichloromethane 5 (3) 2.5 2.5 2.5 2.5 5 2.5 2.5 1.25 2.5 2.5 1.25
Naphthalene 100 (2) 50 50 50 50 50 50 50 25 50 50 25
Tetrahydrofuran 46 (4) 23 23 23 23 23 23 23 11.5 23 23 11.5
Toluene 1,000 500 500 500 500 500 500 500 250 500 500 250
Xylenes (total) 10,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 2,500 5,000 5,000 2,500
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 1
Chloride (mg/l) 46.8 10 71 35 58.31 105 41 128 143 35.39
Sulfate (mg/l) 2,860 2,524 2,903 1,933 2,082.06 2,533 2,946 972 532 2,556.70
TDS (mg/l) 5,085.42 3,670 4,450 2,976 3,284.19 3,852 4,400 1,918 1,320 3,960

5

Footnotes:
1) Utah Ground Water Quality Standards (GWQS) as defined in UAC R317-6, Table 2. Ad hoc GWQS also provided herein, as noted, and as allowed by UAC R317-6-2.2.
2) Ad hoc GWQS for ammonia (as N), molybdenum, 2-Butanone (MEK), chloromethane, and naphthalene based on EPA drinking water lifetime health advisories.
3) Ad hoc GWQS for nickel, uranium, and dichloromethane (methylene chloride, CAS No. 75-09-2) based on final EPA drinking water maximum concentration limits (MCL).
4) Ad hoc GWQS for manganese, tin, vanadium, acetone, chloroform (CAS No. 67-66-3), and tetrahydrofuran based on drinking water ad hoc lifetime health advisories prepared by or in collaboration with EPA Region 8 staff.
5) Ad hoc GWQS for cobalt and iron based on EPA Region 3 Risk Based Concentration limits for tap water.
6) 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.
9) Because background quality has not yet been determined at monitoring well MW-35, which was installed in September 2010 for Tailings Cell 4B, the Executive Secretary has set GWCLs equal to the fraction of the GWQS
(0.25) for Class II Groundwater. After submittal and approval of the Background Groundwater Quality Report, required by Part I.H.5 of this Permit, the Executive Secretary will re-open and modify the GWCLs to be equal to the
mean concentration plus two standard deviations (X+2σ) for each contaminant.

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
to drain to a single low point near the upstream toe of the south cross-valley dike.
Part I.D
Permit No. UGW370004
8
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
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.
Part I.D
Permit No. UGW370004
9
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.
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.
Part I.D
Permit No. UGW370004
10
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
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
Part I.D
Permit No. UGW370004
11
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.

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
Part I.D
Permit No. UGW370004
12
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.
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
Part I.D
Permit No. UGW370004
13
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.
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. Performance standards for Tailings Cell 4A shall
include the following:
Part I.D
Permit No. UGW370004
14
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.
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.
Part I.D
Permit No. UGW370004
15
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,
3) A storage area that provides containment berms to control stormwater run-on and
run-off, and
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
Part I.D
Permit No. UGW370004
16
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

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.

1. Engineering drawing Sheet 6 of 8 is approved by the Exesutive Secretary on XX/XX/XX, subject to conditions
and requirements outlined in Part I.H.11 6 of this Permit. << Call Rupp, get date of DRC approval of Sheet 6 of 8.
Next Permit modification, revise line in table, and add the new approved 4B as-built / drawings also. >>
Part I.D
Permit No. UGW370004
17
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 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
Part I.D
Permit No. UGW370004
18
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
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 the currently 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
Part I.D
Permit No. UGW370004
19
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.
14. BAT Performance Standards for the New Decontamination Pad - the Permittee shall operate
and maintain the New Decontamination Pad (NDP) to prevent release of wastewater to
groundwater and the environment in accordance with the currently approved DMT
Monitoring 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. Performance standards for the NDP shall include,
but are not limited to, the following:
a) NDP LDS Access Pipes - the water level shall not exceed 0.10 foot above the concrete
floor in any LDS access pipe, at any time. Compliance will be defined as a depth to
standing water present in any of the LDS access pipes of more than or equal to 6.2 feet as
measured from the water measuring point (top of access pipe).
b) Soil and debris will be removed from the wash pad of the NDP, in accordance with the
currently approved DMT Monitoring Plan. Cracks in the wash pad greater than 1/8 inch
(width) will be repaired within five working days of discovery.
Part I.E
Permit No. UGW370004
20
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 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, and MW-35.
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-35MW-36, MW-37, or any other well required by Part I.H.46
of this Permit, and continue until otherwise determined by the Executive Secretary
pursuant to Part I.H.57.
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).
3) General Monitoring Wells: MW-20 and MW-22
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
Part I.E
Permit No. UGW370004
21
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
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: General Monitoring Wells MW-20 and MW-22 - the Permittee
shall monitor wells MW-20 and MW-22 on a semi-annual basisStarting 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) Groundwater head monitoring requirements of Part I.E.3
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.
c) 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
Part I.E
Permit No. UGW370004
22
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, and P-5.
b)
c) Head Monitoring Well - MW-34.
c)d) Existing General Monitoring Wells - MW-20 and MW-22.
d)e) Contaminant Investigation Wells - any well required by the Executive Secretary as a
part of a contaminant investigation or groundwater corrective action.
e)f) Any other wells or piezometers required by the Executive Secretary.
4. Groundwater Monitoring Well Design and Construction Criteria - all new groundwater
monitoring wells installed at the facility shall comply with the following design and
construction criteria:
a) Located as close as practical to the contamination source, tailings cell, or other potential
origin of groundwater pollution.
b) Screened and completed in the shallow aquifer.
c) Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including the EPA
RCRA Ground Water Monitoring Technical Enforcement Guidance Document, 1986,
OSWER-9950.1.
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
5. Monitoring Procedures for Wells - beginning with the date of Permit issuance, all monitoring
shall be conducted by the Permittee in conformance with the following procedures:
a) Sampling - grab samples shall be taken of the 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
Part I.E
Permit No. UGW370004
23
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.
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:
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.
Part I.E
Permit No. UGW370004
24
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
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: 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.
Part I.E
Permit No. UGW370004
25
g) Weekly New Decontamination Pad Inspection - the Permittee shall conduct weekly
inspections of the New Decontamination Pad as described in Part I.D.14 of this Permit
and the currently approved DMT Monitoring Plan.
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
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 the currently approved Cell 4A BAT,
Monitoring, Operations and Maintenance Planany 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.
Part I.E
Permit No. UGW370004
26
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, 4A, and 4B.
b) One slimes drain wastewater access pipe at each of Tailings Cells 2, 3, 4A, and 4B. For
Cells 3, 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.
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
Part I.E
Permit No. UGW370004
27
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:
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.
Part I.E & I.F
Permit No. UGW370004
28
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 the currently approved Cell 4B BAT,
Monitoring, Operations and Maintenance Planany 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
29

Table 7. 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.
Part I.F
Permit No. UGW370004
30
2. Routine DMT Performance Standards Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT performance standards monitoring required by Parts
I.D.3 and I.E.7 of this Permit. DMT monitoring shall be conducted in compliance with this
Permit and the currently approved DMT Monitoring Plan. 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 7, 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 7 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:
Part I.F
Permit No. UGW370004
31
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs shall be prepared by a
Professional Geologist licensed by the State of Utah, or otherwise approved beforehand
by the Executive Secretary.
b) Well Completion Diagram - that detail all physical attributes of the well construction,
including:
1) Total depth and diameters of boring,
2) Depth, type, diameter, and physical properties of well casing and screen, including
well screen slot size,
3) Depth intervals, type and physical properties of annular filterpack and seal materials
used,
4) Design, type, diameter, and construction of protective surface casing, and
5) Survey coordinates prepared by a State of Utah licensed engineer or land surveyor,
including horizontal coordinates and elevation of water level measuring point, as
measured to the nearest 0.01 foot.
c) Aquifer Permeability Data - including field data, data analysis, and interpretation of slug
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
Part I.F
Permit No. UGW370004
32
surveyor. The survey will include State Plan Coordinates (northings and eastings) and
vertical elevations. The surveyed coordinates and elevations of the seeps and springs
shall be within 1 foot of the highest point of the saturated seepage face on the day of the
survey. This survey data must be obtained before any samples are collected.
8. Chemicals Inventory Report - at the time of Permit renewal the Permittee shall submit a
report to update the facilities chemical inventory report required by Part I.H.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.
Part I.F & I.G
Permit No. UGW370004
33
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.
12. Decontamination Pads Annual Inspection Report - the New Decontamination Pad and
Existing Decontamination Pad will be taken out of service and inspected annually during the
second quarter of each year, to ensure integrity of the concrete wash pad surfaces. If
physical defects in the wash pad as defined by Part I.D.14 of the Permit are identified during
the inspection, repairs shall be made prior to resuming the use of the facility. Said defects
include, but are not limited to concrete deterioration, cracking, subsidence, etc. The results
of the annual inspection and all repairs will be documented on inspection forms in
accordance with the currently approved DMT Monitoring Plan. The inspection forms and
documentation of all repairs completed shall be included in the 2nd Quarter DMT Monitoring
Report due September 1, of each calendar year.
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-
Part I.G
Permit No. UGW370004
34
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)(c).
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.

Part I.H
Permit No. UGW370004
35
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. 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.8 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.
Part I.H
Permit No. UGW370004
36
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.8 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.
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,
Part I.H
Permit No. UGW370004
37
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.
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.
Part I.H
Permit No. UGW370004
38
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.
6.4.Installation of New Groundwater Monitoring Wells - the Permittee shall install at least
three two additional hydraulically downgradient wells adjacent to Tailings Cell 4B, to
replace existing wells MW-33 and MW-34. These replacement wells shall be installed,
in accordance with the following requirements:
a) New Compliance Monitoring Wells MW-363 and MW-374 - install at least two new
compliance monitoring wells (MW-363 and MW-374) 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:that will be located and completed as follows:
1) At least one well placed on the south side of Cell 4B between existing wells MW-
15 and MW-34.
2) At least one well located on the west side of Cell 4B, between MW-33 and MW-
35.
3) All new wells must be properly designed, installed, screened / completed, and
developed in accordance with Part I.E.4 of the Permit.
4) All new wells will demonstrate a saturated thickness of at least 5-feet, inside the
well screen, as measured from the upper geologic contact of the Brushy Basin
Member of the Morrison Formation, or as approved by the Executive Secretary.
4)5) All new wells shall Pprovide early detection of tailings cell contamination of
shallow groundwater from Tailings Cell 4B.
5)6) All new wells shall Pprovide discrete groundwater monitoring for tailings
Cell 4B.
6)Comply with the design, construction, and development requirements found in Part
I.E.4 of this Permit.
b) On or before May 15, 2011, Within 45 calendar days of completing well installation,
the Permittee shall On or before June 30June 30, 2011 or as otherwise approved by
the Executive Secretary, the Permittee shall submit a monitoring well As-Built report
for all new all new wells installed MW-33 and MW-34 installed 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
Part I.H
Permit No. UGW370004
39
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 14 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.
57. Background Groundwater Quality Report for Well MW-35 and New Monitoring Wells -
within 30 calendar days of receipt of written Executive Secretary approval of the new
monitoring well As-built Report, required by Part I.H.4, abovefor 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.
c) After completion of eight consecutive quarters of groundwater sampling and analysis of
well MW-35 and these new wells (MW-33, MW-34 and MW-35)required by Part I.H.4,
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 well MW-35 and the each of the new
wells.
Part I.H
Permit No. UGW370004
40
6. 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. < Reserved >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
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
Part I.H
Permit No. UGW370004
41
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 time frame 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
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.
Detailed Southwest Hydrogeologic Investigation and Report - the purpose of this
investigation is to define, demonstrate, and characterize: 1) hydraulic connection and local
groundwater flow directions between the area near Tailings Cell 4B, and the western margin
of White Mesa, including Westwater and Cottonwood Seeps, and Ruin Spring, and 2) the
full physical extent of unsaturated area between former well MW-16, MW-33 and the
western margin of White Mesa, as defined above. In preparation of this report, the Permittee
shall:
a) Install multiple borings and / or monitoring wells to completely enclose and define
both: 1) the subsurface structural high area of the upper Brushy Basin Shale Member
geologic contact and 2) the horizontal limits of saturation in the Burro Canyon
Formation. Said study shall include, but is not limited to a subsurface area between
Tailings Cell 4B, and the Westwater and Cottonwood Seeps, and Ruin Spring. At a
minimum the characterization / definition of said subsurface area shall be based on:
1) Dry wells or piezometers, completed down to a depth equal to or below the upper
geologic contact of the Brushy Basin Shale Member,
2) Piezometers or wells that intercept the shallow aquifer and encounter a saturation
thickness of 5-feet or more. Said wells and piezometers shall have a minimum
inside diameter of 3 inches. The Permittee shall complete hydraulic testing of all
such wells and piezometers in accordance with Part I.F.6(c) of this Permit.
b) Demonstrate the full geologic and physical extent of the apparent unsaturated
structural high between Tailings Cell 4B and the western margin of White Mesa,
including Westwater and Cottonwood Seeps and Ruin Spring.
c) Demonstrate the location and direction of all groundwater flow paths between
Tailings Cell 4B and nearby Westwater and Cottonwood Seeps and Ruin Spring.
Determine average linear groundwater velocity to said groundwater discharge
locations.
d) Perform geologic logging of all borings / wells, and submit geologic logs performed
and certified by a Utah licensed Professional Geologist.
Part I.H
Permit No. UGW370004
42
e) Submit the investigation report for Executive Secretary review and approval on or
before January 13, 2012. This report shall be certified by a Utah Licensed
Professional Engineer or Geologist and will include but is not limited to:
1) Geologic logs and well As-built diagrams that comply with the requirements of
Part I.F.6.
2) A revised equipotential map to describe both the physical extent of the dry zone
and all groundwater flow directions near Tailings Cell 4B and Westwater and
Cottonwood Seeps, and Ruin Spring. Said map shall demonstrate flowpaths
(steamtubes) to all respective groundwater discharge locations at the western
margin of White Mesa.
3) A revised structural contour map for the upper Brushy Basin Shale for the facility
and physical extent of White Mesa.
4) A revised saturation thickness map based on contemporaneous groundwater head
data for the Burro Canyon aquifer for the facility and physical extent of White
Mesa.
5) Appropriate geologic and hydrogeologic maps and cross-sections (to scale).
6) Results and interpretation of aquifer permeability testing as per Part I.F.6(c) of
this Permit.
g) The Permittee shall provide at least a 14 calendar day written notice to allow the
Executive Secretary to observe all drilling and well installation activities.
h) In the event the Executive Secretary determines that additional information is
required, this information will be submitted within a time frame approved by the
Executive Secretary.

Part II
Permit No. UGW370004
43
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.
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
Part II
Permit No. UGW370004
44
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
45
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
46
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
47
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:
Part IV
Permit No. UGW370004
48
1. The current Permittee notifies the Executive Secretary at least 30 calendar days in advance
of the proposed transfer date;
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.