DRC-2011-007077 - 0901a06880253ca3

State of Utah
GARY R. HERBERT
Govemor
GREG BELL
Lieutenant Govemor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
July 14,2011
David C. Frydenlund
Vice President and Counsel
Denison Mines (USA) Corp (DUSA)
1050 17^^ Street, Suite 950
Denver, CO 80265
Dear Mr. Frydenlund:
SUBJECT: Ground Water Discharge Permit UGW370004
Permit Amendment
The following are attached for your attention:
a. Executed subject Ground Water Discharge Permit UGW370004 (Permit) Amendment,
dated July 14,2011.
b. Statement of Basis Memorandum dated July 13, 2011, for the subject Permit Amendment.
c. Marked copy of the subject Permit Amendment indicating the changes from the previous
Permit.
This Permit change is a minor modification to the Permit. This Permit Amendment changes the
monitoring requirements for the slimes drain recovery elevation testing from monthly to quarterly.
The various changes to the permit are discussed in detail in item b. above.
If you have questions on this Permit Amendment, please contact David Rupp of my staff
UTAH WATER QUALITY BOARD
Rusty Lundberg, Co-Executive Secretary
DAR:dr
Attachments
F:\DUSA\GWDP\XmtlLtr 7-14-11 .doc
195 North 1950 West • Salt Lake City, UT
Mailing Address; RO. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 • T.D.D. [phone]
wyvw.deq.utalt.gov
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RE: 7/14/11; GWDP/permit amendment / UK
David C Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
1050 17th ST STE 950
Denver CO 80265
!psTForm 3800. August 2006 Seq Reverse for^liVstructibns.;
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RE: 7/14/11; GWDP/permit amendment / DR
David C Frydenlund
Vice President & General Counsel
Denison Mines (USA) Corp (DUSA)
1050 17th ST STE 950
Denver CO 80265
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j PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
Permit No. UGW370004
STATEOFUTAH
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 Quahty Act, Title 19, Chapter 5, Utah Code
Annotated 1953, as amended, the Act,
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 17'''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 Quahty 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 W > ^ ^ •
This Permit shall expire March 8, 2010 (Thi^Permit is in Timely Renewal)
Application for Permit Renewal was received September 1, 2009
Signed this l4^ayof ^^H. 2011
Co-Executi ve^ecretary
Utah Water Quality Board
Table of Contents
PART L SPECIFIC PERMIT CONDITIONS 1
A. GROUND WATER CLASSIHCATION 1
B. BACKGROUND WATER QUALITY 1
C. PERMIT LIMITS : J ...2
1. Ground Water Comphance Limits 2
2. Tai 1 i n gs Cel 1 Operati on s 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 Taihngs Cell Construction Authorized 8
3. Existing Facility DMT Performance Standards 8
4. Best Available Technology Requirements for New Constmction 11
5. BAT Design Standards for Tailings Cell 4A 11
6. BAT Performance Standards for Tailings Cell 4A 14
7. Definition of 1 le.(2) Waste 14
8. Closed Cell Performance Requirements 14
9. Facihty Reclamation Requirements 15
10. Stormwater Management and Spill Control Requirements 15
11. Requirements for Feedstock Material Stored Outside the Feedstock Storage Area... 15
12. BAT Design Standards for Tailings Cell 4B 16
13. BAT Performance Standards for Tailings Cell 4B 19
14. BAT Performance Standards for the New Decontamination Pad..... 19
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONTTORING 20
1. Routine Groundwater Comphance Monitoring 20
2. Groundwater Monitoring: General Monitoring Wells MW-20 and MW-22 21
3. Groundwater Head Monitoring 21
4. Groundwater Monitoring Well Design and Constmction Criteria 21
5. Monitoring Procedures for Wells - 22
6. White Mesa Seep and Spring Monitoring 22
7. DMT Performance Standard Monitoring 23
8. BAT Performance Standard Monitoring 24
9. On-site Chemicals Inventory 25
10. Tailings Cell Wastewater Quality Monitoring 25
11. Groundwater Monitoring Modifications 26
12. BAT Performance Standard Monitoring 26
F. REPORTING REQUIREMENTS 27
1. Routine Groundwater Monitoring Reports 27
2. Routine DMT Performance Standard Monitoring Report 28
3. Routine BAT Performance Standard Monitoring Reports 29
4. DMT and BAT Performance Upset Reports 29
5. Other Information 29
6. Groundwater Monitoring Well As-Built Reports 29
7. White Mesa Seeps and Springs Monitoring Reports 30
8. Chemicals Inventory Report 31
9. Tailings Cell Wastewater Quality Reports 31
10. Revised Hydrogeologic Report 31
11. Annual Slimes Drain Recoyery Head Report 31
12. Decontamination Pads Annual Inspection Report 32
G. OUT OF COMPLIANCE STATUS 32
i
1. Accelerated Monitoring Status : , 32
2. Violation of Permit Limits 32
3. Failure to Maintain DMT or BAT Required by Permit 32
4. Facihty Out of Compliance Status 33
H. COMPLIANCE SCHEDULE REQUIREMENTS 34
1. On-site Chemicals Inventory Report 34
2. Infiltration and Contaminant Transport Modeling Work Plan and Report 34
3. Plan for Evaluation of Deep Supply Well WW-2 35
4. Installation of New Groundwater Monitoring Wells 36
5. Background Groundwater Quality Report for New Monitoring Wells 36
6. Detailed Southwest Hydrogeologic Investigation 37
PART n. REPORTING REQUIREMENTS 39
A. REPRESENTATTVE SAMPLING 39
B. ANALYTICAL PROCEDURES 39
C. PENALTIES FOR TAMPERING 39
D. REPORTING OF MONITORING RESULTS 39
E. COMPLIANCE SCHEDULES 39
F. ADDITIONAL MONITORING BY THE PERMITTEE 39
G. RECORDS CONTENTS 39
H. RETENTION OF RECORDS 40
I. NOTICE OF NONCOMPLIANCE REPORTING 40
J. OTHER NONCOMPLL\NCE REPORTING 40
K. INSPECTION AND ENTRY 40
PART ffl. COMPLIANCE RESPONSIBILmES 41
A. DUTY TO COMPLY 41
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS 41
C. NEED TO HALT OR REDUCE ACTIYFIY NOT A DEEENSE 41
D. DUTYTOMmGATE.... 41
E. PROPER OPERATION AND MAINTENANCE 41
PART IV. GENERAL REQUIREMENTS 42
A. PLANNED CHANGES 42
B. ANTICIPATED NONCOMPLIANCE 42
C. PERMIT AcTTONS 42
D. DUTY TO REAPPLY 42
E. DUTY TO PROVIDE INFORMATION 42
F. OTHER INFORMATION 42
G. SIGNATORY REQUIREMENTS 42
H. PENALTIES FOR FALSIFICATION OF REPORTS 43
I. AvAiLABiLrrY OF REPORTS 43
J. PROPERTY RIGHTS 43
K. SEVERABILITY 43
L. TRANSFERS 43
M. STATE LAWS 44
N. REOPENER PROVISIONS 44
• • List of Tables
Table 1. Ground Water Classification ..: : 1
Table 2. Groundwater Compliance Limits 3
Table 3. DMT Engineering Design and Specifications ,. 6
Table 4. Feedstock Storage Area Coordinates 10
Table 5. Approved Tailings Cell 4A Engineering Design and Specifications 11
Table 6. Approved Tailings Cell 4B Engineering Design and Specifications 16
Table 7. Groundwater Monitoring Reporting Schedule 28
m
Part I.A & I.B
Permit No. UGW370o64
PART I. SPECMC 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
Average TDS (mg/L)
DUSA Data
Class III Groundwater
Average TDS (mg/L)
DUSA Data
Well
ID
Average
Concentration^^^
Standard
Deviation^^^ WelllD
Average
Concentration^^^
Standard
Deviation^^^
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^'^ 18 2,605 297
MW-19^'^ 22 2,457 900
MW-20^*^ 7 5,663 114
MW-22^^^ 8 7,537 365
MW-3A 9 5,547 129
MW-23 10 3,443 244
MW-24 10 4,116 117
MW-25^'^ 11 2,843 67
MW-26^''^ 12 3,155 65
MW-27^'^ 10 1,019 28
MW-28 11 3,677 87
MW-29 8 4,380 27
MW-31^'^ 10 1,265 50
MW-32^'^ 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 ng/L) and thalUum in MW-19 (2.1 jig/L) exceed the GWQS, 30 ng/L and 2.0
ng/L, respectively. Therefore these wells have been classified as Class 111 groundwater rather than Class II groundwater.
4) Wells MW-20 and MW-22 are not point of compliance monitoring wells, but instead are general 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, 2010. 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 ng/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 LE. 1).
7) Background concentrations of uranium in well MW-27 (34 ng/L) and selenium in MW-31 (71 ng/L) exceed the GWQS, therefore these wells
have been classified as Class III groundwater rather than Class II groundwater.
8) Well MW-32 was originally named TW4-17 and was installed as part of the chloroform contaminant investigation at the facility. Under this
Permit it is included as a POC well for the tailings cells in Part I.E. 1.
B. BACKGROUND WATER QUALITY - based on groundwater samples collected through June 2007 for
existing wells (MW-1, MW-2, MW-3, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-
18, MW-19, MW-26, and MW-32) and through December 2007 for new wells (MW-3A, MW-23,
MW 24, MW-25, MW-27, MW-28, MW-29, MW-30 and MW-31), the upper boundary of
Part I.B & I.C
Permit No. UGW370004
backgrpund 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 pWQS 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 1 le.(2) material is prohibited.
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Part LD
Permit No. UGW370004
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:
Table3. DMT Engineering Design and Specifications
Tailings
Cell
Report
Type Engineering Report Design Figures
Constrtiction
Specifications
Celll Design June, 1979 D'Appolonia
Consulting Engineers, Inc
Appendix A, Sheets 2,4, 8,
9, 12-15
Appendix B
Cell 2 Design June, 1979 D'Appolonia
Consulting Engineers, Inc
Appendix A, Sheets 2, 4, 7-
10, 12-15
Appendix B
As-Built February, 1982 D'Appolonia
Consulting Engineers, Inc ^'^^
Figures 1, 2, and 11 _ N/A
Cell 3 Design May, 1981 D'Appolonia
Consulting Engineers, Inc
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear, Inc. ^'^^
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) Taihngs Cell 1 - consisting of the following major design elements:
1) Cross-valley Dike and East Dike - constmcted 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 constmcted
on the east margin of the pond, which forms a continuous earthen stmcture 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)
constmcted 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 constmcted immediately over the FML with a
thickness of 12-inches on the cell floor and 18-inches on the interior sideslope:
3) Cmshed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of cmshed 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.
PartLD
Permit No. UGW370004
b) Tailings Cell 2 - which consists of the following major design elements:
1) Cross-valley Dike - constmcted 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 constmcted 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 constmcted 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 mn 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 - constmcted 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 constmcted 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) Cmshed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of cmshed sandstone was prepared and rolled smooth as a FML sub-base layer.
Beneath this underlay, native sandstone and other foundation materials were graded
PartLD
Permit No. UGW370004
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System - immediately above the FML, a nominal
12-inch (cell floor) to 18-inch (inside sideslope) soil protective blanket was
constructed of native sands from on-site excavated soils (70%) and dewatered and
cyclone separated tailings sands from the mill (30%). On top of this protective
blanket, a network of 3-inch PVC perforated pipe laterals was installed on
approximately 50-foot centers. This pipe network gravity drains to a 3-inch
perforated PVC collector pipe which also drains toward the south dike, where it is
accessed from the ground surface by a 12-inch diameter, inclined HDPE access pipe.
Each mn 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.
Existing Tailings Cell Constmction Authorized - tailings disposal in existing Taihngs Cells
1, 2, and 3 is authorized by this Permit as defined in Table 3 and Part I.D.I, 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 ofthis Permit, and issuance of
a constmction permit.
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) Quarteriy Slimes Drain Recovery Test - effective July 11,2011, the Permittee shall
conduct a quarterly 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
PartLD
Permit No. UGW370004
ii. Achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements, with no change in water
level, as measured to the nearest 0.01 foot.
3) Annual Slimes Drain Compliance - shall be achieved when the average annual
wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to the currently approved DMT Monitoring Plan, meets the conditions in Equation 1,
below:
Equation 1:
[YEy + IEy.l + YEy.2 ] / [Ny + Ny.J + Ny.2 ] < [ZEy., + ^Ey.Z + IEy.3 ] / [ Ny.) + Ny.2 + Ny.3 ]
Where:
XEy = Sum of all monthly and quarterly slimes drain tailings fluid elevation measurements that
meet the test performance standards found in the sub-paragraphs of 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 applicable frequency and method of the approved DMT
Monitoring Plan at the time of each SDRE test, these recovery tests are to be conducted and the SDRE
values reported in units of feet above mean sea level (amsl). However, when monthly and quarteriy
measurements are combined in the above equation, the quarterly values shall be multiplied by a
coefficient of three (3).
XEy.i = Sum of all SDRE measurements made in the year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
XEy.2 = Sum of all SDRE measurements made in the second year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
XEy.3 = Sum of all SDRE measurements made in the third year previous to the calendar year of
interest. However, when monthly and quarterly measurements are combined in the equation above,
each quarterly value shall be multiplied by a coefficient of three (3).
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. However, when monthly and quarterly
measurements are used in the equation above, each quarterly test shall be counted as three (3) separate
tests.
Ny.i = 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. However, when monthly
and quarterly measurements are used in the equation above, each quarterly test shall be counted as
three (3) separate tests. 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. However, when monthly and quarterly measurements are used in the equation above,
each quarterly test shall be counted as three (3) separate tests.
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. However, when
monthly and quarterly measurements are used in the equation above, each quarterly test shall be
counted as three (3) separate tests.
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.
Part I.D
Permit No. UGW370004
Report for
Calendar
Year
Source of Data By Calendar Year for Equation 1 Variables (right side) Report for
Calendar
Year Ey-l Ev-2 Ev.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
Pennittee shall ensure that the maximum elevation ofthe tailings waste solids does not
exceed the top of the FML liner.
d) DMT Monitoring Wells - at all times the Permittee shall operate and maintain Tailings
Cells 2 and 3 to prevent groundwater quality conditions in any nearby monitoring well
from exceeding any Ground Water Compliance Limit established in Table 2 of this
Permit.
e) Roberts Pond - the Permittee shall operate this wastewater pond so as to provide a
minimum 2-foot freeboard at all times. Underno 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 eastem 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 LD. 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.
Comer 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
10
Part LD
Permit No. UGW370004
Northwest 323,600 2,579,990
Footnote:
1) Approximate State Plane Coordinates beginning from the extreme northeast comer 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
constmction 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 Constmction - any construction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facihties 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 constmction 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 n
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 ^'^
Geosyntec Consultants
November 27, 2006 Cell Seismic Study ^"^ MFG Consulting Scientists
II
Part LD
Permit No. UGW370004
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 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 biterrogatory.
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, constmcted by the
Permittee between 1989 and1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these dikes have
slopes of 3H to IV. The west dike has an interior slope of 2H to IV. 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 comers.
c) Taihngs 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 ofthe Cell 4 A floor area. In other locations, the primary FML will
be in contact with the shmes 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 comer. 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 tum, 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.
12
Part I.D
Pennit No. UGW370004
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 pattem across the floor
of Cell 4A that drain to a "backbone" of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed immediately over the primary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection pipe. A
series of continuous sand bags, filled with filter sand cover the strip drains. The sand
bags are composed of a woven polyester fabric filled with well graded filter sand to
protect the drainage system from plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC) pipe
found at the downgradient end of the strip drain lines. This pipe is in tum overlain by
a berm of gravel that mns the entire diagonal length of the cell, sunounded by a
geotextile fabric cushion in immediate contact with the primary FML. In tum, 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 comer downhill to the far southwest comer 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 comer, 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 constmcted 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
13
PartLD
• Permit No. UGW370004
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 hned spillway will be constmcted near the
westem comer of the north dike to allow emergency mnoff 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
stmcture will be constructed at Cell 4A. All stormwater mnoff 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:
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 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 iess
then 3-feet in Cell 4A, as measured from the top of the upper FML.
7. Definition of 1 le.(2) Waste - for purposes of this Permit, 1 le.(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 1 le.(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 Perfonnance Requirements - before reclamation and closure of any tailings
disposal cell, the Permittee shall ensure that the final design, constmction, 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:
14
PartLD
Pemiit No. UGW370004
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 intemal 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
constmct a cover system over the tailings cells in compliance with all engineering design and
specifications in an approved Reclamation Plan. The Executive Secretary reserves the right
to require modifications of the Reclamation Plan for purposes of compliance with the Utah
Ground Water Quality Protection Regulations, including but not limited to containment and
control of contaminants, or discharges, or potential discharges to Waters of the State.
10. Stormwater Management and Spill Control Requirements - the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the cunentiy 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, constmction, 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 rV.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:
15
Part LD
Permit No. UGW370004
1) A storage area composed of a hardened engineered surface of asphalt or concrete, and
2) A storage area designed, constmcted, 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
mn-off, and
4) Stormwater drainage works approved in advance by the Executive Secretary, or
5) Other storage facilities and means approyed 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 constmcted 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
Engineerin g Drawings
Name Date Revision No. Titie
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 January 2009 Rev. 1 Lining System Details n
Sheet 7 Of 8 January 2009 Rev. 1 Lining System Details IE
Sheet 8 of 8 January 2009 Rev. 1 Lining System Details FV
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 Constmction Quality Assurance Plan for the
Constmction of Cell 4B Lining System
Geosyntec Consultants
September 2009 (Revised) Technical Specification Section 02200
(Earthwork)
Geosyntec Consultants
Blast Plan, KGL and Associates and Blast Plan KGL and Associates and
16
Part LD
Permit No. UGW370004
August 6, 2009 Review, Geosyntec Consultants letter dated
September 10, 2009
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 constmcted dikes on the south and west side ofthe 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 IV. The exterior
slopes of the southem and westem dikes will have typical slopes of 3H to IV. Limited
portions of the Cell 4B interior sideslopes in the northwest comer and southeast comer of
the cell, (where the slimes drain and leak detection sump will be located will also have a
slope of 3H to IV. The base width of the southem dikes varies from approximately 92
feet at the westem end to approximately 190 feet at the eastem 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 detennined by ASTM D-1557. The floor of Cell 4B
has an average slope of 1 % that grades from the northwest comer to the southeast comer.
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 comer. 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 tum, 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.
17
Part LD
Pennit No. UGW370004
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 pattem across the floor
of Cell 4B that drain to a "backbone" of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed immediately over the primary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection pipe. A
series of continuous sand bags, filled with filter sand cover the strip drains. The sand
bags are composed of a woven polyester fabric filled with well graded filter sand to
protect the drainage system from plugging.
2) Horizontal Slimes Drain Collection Pipe System - includes a "backbone" piping
system of 4-inch ID Schedule 40 perforated PVC slimes drain collection (SDC) pipe
— found at the downgradient end of the strip drain lines. This pipe is in tum overlain by
a berm of gravel that mns the entire diagonal length of the cell, surrounded by a
geotextile fabric cushion in immediate contact with the primary FML. In tum, 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 mns from the far northwest comer downhill to the far southeast comer 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 comer, 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
constmcted 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 constmcted near the
southeastem comer 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
18
PartLD
Pemiit No. UGW370004
fabric installed within it at its midsection, set atop a cushion geotextile placed directiy
over the primary FML in a 4-foot deep trapezoidal channel. A lOO-foot wide, 60-mil
HDPE membrane splash pad will be installed beneath the emergency spillway. No other
spillway or overflow stmcture 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 cunentiy approved Cell 4B 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 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 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 ariy 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
cunently approved DMT Monitoring Plan. Cracks in the wash pad greater than 1/8 inch
(width) will be repaired within five working days of discovery.
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Partl.E
Pennit No. UGW370004
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) cunently 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 Executi ve 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 mohitoring
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 (fomieriyTW4-
15), MW-30, 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-36,
MW-37, or any other well required by Part LH.4 of this Permit, and continue until
otherwise determined by the Executive Secretary pursuant to Part I.H.5.
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 (formeriy 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
20
PartLE ,
Permit No. UGW370004
i. GWCL Parameters - all contaminants specifiedin 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
enor 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 basis. Said sampling shall comply
with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part LE. 1.
b) Groundwater head monitoring requirements of Part LE.3
c) Well monitoring procedure requirements of Part I.E.5.
3. Groundwater Head Monitoring - on a quarterly basis and at the same frequency as
groundwater monitoring required by Part I.E.I, 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 LE.l of this Permit.
b) Piezometers-P-l,P-2, P-3,P-4, andP-5.
c) Head Monitoring Well - MW-34.
d) General Monitoring Wells - MW-20 and MW-22.
e) Contaminant Investigation Wells - any well required by the Executive Secretary as a part
of a contaminant investigation or groundwater corrective action.
f) Any other wells or piezometers required by the Executive Secretary.
4. Groundwater Monitoring Well Design and Constmction Criteria - all new groundwater
monitoring wells installed at the facility shall comply with the following design and
constmction criteria:
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Partl.E
Pennit No. UGW370004
a) Located as close as practical to the contamination source, tailings cell, or other potential
origin of groundwater pollution.
b) Screened and completed in the shallow aquifer.
c) Designed and constructed in compliance with UAC R317-6-6.3(I)(6), including the EPA
RCRA Ground Water Monitoring Technical Enforcement Guidance Document, 1986,
OSWER-9950.1.
d) Aquifer tested to determine local hydraulic properties, including but not limited to
hydraulic conductivity.
5. Monitoring Procedures for Wells - beginning with the date of Permit issuance, all monitoring
shall be conducted by the Permittee in conformance with the following procedures:
a) Sampling - grab samples shall be taken of the groundwater, only after adequate removal
or purging of standing water within the well casing has been performed.
b) Sampling Plan - all sampling shall be conducted to ensure collection of representative
samples, and reliability and validity of groundwater monitoring data. ,
c) Laboratory Approval - all analyses shall be performed by a laboratory certified by the
State of Utah to perform the tests required.
d) Damage to Monitoring Wells - if any monitor well is damaged or is otherwise rendered
inadequate for its intended purpose, the Permittee shall notify the Executive Secretary in
writing within five calendar days of discovery.
e) Field Monitoring Equipment Calibration and Records - immediately prior to each
monitoring event, the Permittee shall calibrate all field monitoring equipment in
accordance with the respective manufacturer's procedures and guidelines. The Permittee
shall make and preserve on-site written records of such equipment calibration ih
accordance with Part E.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 hmited 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.I 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:
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Part I.E
Permit No. UGW370004
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 currentiy approved QAP; pursuant to Part LE.l 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 spht sample any or all seeps or springs.
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 LD.l and I.D.3 of this Permit, including, but not limited
to the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells 1 and 3 - the Permittee
shall monitor and record weekly the elevation of wastewater in Tailings Cells 1 and 3 to
ensure compliance with the maximum, wastewater elevation criteria mandated by
Condition 10.3 of the License. Said measurements shall be made from a wastewater level
gauge or elevation survey to the nearest 0.01 foot.
b) Quarteriy Slimes Drain Water Level Monitoring: Cells 2 and 3 - the Permittee shall
monitor and record quarterly the depth to wastewater in the slimes drain access pipes as
described in Part I.D.3 of this Permit and the currentiy 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 1 separate slimes drain recovery test at each disposal cell in each
quarterly period of each calendar year that meets 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
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Pemiit No. UGW3700b4
DMT operations standards in Part LD.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: l)Confirm the bulk feedstock materials are
maintained within the approved Feedstock Storage Area defined by Table 4, and 2)
Verify that all altemate feedstock materials located outside the Feedstock Area defined in
Table 4, are stored in accordance with the requirements found in Part LD.l 1.
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 constmcts 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 currentiy 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 currentiy approved Liner Maintenance Provisions, and 2) report all repairs made
pursuant to Part I.F.2.
g) Weekly New Decontamination Pad Inspection - the Permittee shall conduct weekly
inspections of the New Decontamination Pad as described in Part LD.14 of this Permit
and the currently approved DMT Monitoring Plan.
Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the
currently approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, 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
24
Part I.E
Pemiit No. UGW370004
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. Underno 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) Quarterly Slimes Drain Recovery Head Monitoring - immediately after the Permittee
initiates pumping conditions in the Tailings Cell 4A slimes drain system, quarterly
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 cunentiy approved Cell
4A BAT, Monitoring, Operations and Maintenance Plan.
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
Constmction 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 LG.3.
9. On-site Chemicals Inventory - the Permittee shall monitor and maintain a current inventory
of all chemicals used at the facility at rates equal to or greater than 100 kg/yr. Said inventory
shall be maintained on-site, and shall include, but is not limited to:
a) Identification of chemicals used in the milling process and the on-site laboratory, and
b) Determination of volume and mass of each raw chemical currently held in storage at the
facility.
10. Tailings Cell Wastewater Quality Monitoring - on an annual basis, the Permittee shall collect
wastewater quality samples from each wastewater source at each tailings cell at the facility,
including, but not limited to:
a) One surface impounded wastewater location at each of Tailings Cells 1, 3,4A, 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 currentiy 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.
• 25
Partl.E
Pemiit No. UGW370004
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 Pennit, 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) A.nalytical Methods - all laboratory analysis shall be conducted using analytical
methods listed in the currentiy approved QAP pursuant to Part LE. l 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 r
iii. Lower limits of quantitation for groundwater for semi-volatile organic
compounds listed in Table 2 of EPA Method 8270D, Revision 4, dated Febmary,
2007.
6) Quality Control Samples - the Permittee will conduct quality control (QC) sampling
and analysis as a part of aif tailings wastewater samphng, in accordance with the
requirements of Section 4.3 ofthe currently approved QAP; pursuant to Part LE.l of
this Permit. Said QC samples shall include, but are not hmited 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, shmes 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 cunently 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, 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:
26
Part I.E & I.F .
Permit No. UGW370004
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 rei ated moni toring 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. Underno 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
Taihngs Cell 4B. Said measurements shall be made to the nearest 0.1 foot.
b) Quarterly Slimes Drain Recovery Head Monitoring - immediately after the Permittee
initiates pumping conditions in the Tailings Cell 4B slimes drain system, quarterly
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, Mbnitoring, Operations and Maintenance Plan.
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
Constmction Quality Assurance Plan (CQA/QC Plan) as found in Table 6 of this Pemiit.
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
LE.l, LE.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:
27
Part LF
Permit No. UGW370004
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 thefollowing: 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 welis 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. I (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.
Routine DMT Performance Standards Monitoring Report - the Pennittee shall provide
quarterly monitoring reports of all DMT performance standards monitoring required by Parts
28
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Pemiit No. UGW370004
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 ofthis Permit. BAT Monitoring at Cells 4 A 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:
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
29
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Permit No. UGW370004
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 constmction,
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 3^^*^ 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.E. 1(a) of this Permit,
b) Laboratory Results - for each sample collected that comply with the requirements of Part
I.F.l(b) ofthis 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 3^*^ Quarter Routine Groundwater
Monitoring event of each year. The contour map shall be at a map scale, such that, all
seeps and springs listed in the approved Sampling Plan for Seeps and Springs in the
Vicinity of the White Mesa Uranium Mill and the monitoring wells on site may be seen
on one map,
d) Data Evaluation - and interpretation of all groundwater quality data collected,
e) Quality Assurance Evaluation and Data Validation - for the seeps and springs water
quality data that meets the requirements of Part I.F. 1 (d),
f) Electronic Data Files and Format - that meet the requirements of Part I.F. 1(e) of this
Permit, and
g) Survey data for the seeps and springs shall be based on an elevation survey, conducted
under the direction of and certified by a Utah licensed professional engineer or land
surveyor. The survey will include State Plan Coordinates (northings and eastings) and
30
PartLE
Pemiit No. UGW370004
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.I. 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 3^^^
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) ofthis 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 FV.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 mbnitoring wells for all
groundwater monitoring parameters required by this Pemiit, 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 H.G of this Permit, and:
a) Provide the individual slimes drain recovery head monitoring data for the previous
calendar year, including, but not limited to: date and time for the start and end of
recovery test, initial water level, final depth to stable water level and equivalent recovery
water level elevation.
b) Calculate the average slimes drain recovery head for the previous calendar year.
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Part I.F & I.G
Pemiit No. UGW370004
c) Include a time series chart to show trends of the 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 LE.7(b) ofthis
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 2"*^ Quarter DMT Monitoring
Report due September 1, of each calendar year.
G. OUT OF COMPLL\NCE 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 Pemiit; 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 B AT Required by Permit
a) Permittee to Provide Information - in the event that the Permittee fai Is 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)(l). Notification shall be given orally within 24-
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PartLG
Pemiit No. UGW370004
hours of the Permittee's discovery of the failure of DMT or BAT, and shall be followed
up by written notification, including the ihformation 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 Pemiit 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.
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 l.G.l, 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 altemative DMT or BAT for approval by the Executive Secretary.
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Pemiit No. UGW370004
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
taihngs 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: goveming 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 cbnditions at the site. Said conceptual model will identify the
physical domain(s) and geometries simulated including the tailings cell design and
constmction, all boundary and initial conditions assigned in the model(s), and the
shallow aquifer locations where future potential contaminant concentrations have been
predicted.
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Part I.H
Pemiit No. UGW370004
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.
0 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 constmction, 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 constmction 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.
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,
35
Part I.H
Pennit No. UGW370004
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 constmction 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. Installation of New Groundwater Monitoring Wells - the Permittee shall install at least
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-36 and MW-37 - install at least two new
compliance monitoring wells (MW-36 and MW-37),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.
5) All new wells shall provide early detection of tailings cell contamination of
shallow groundwater from Tailings Cell 4B.
6) All new wells shall provide discrete groundwater monitoring for tailings Cell 4B.
b) On or before June 30, 2011 or as otherwise approved by the Executive Secretary, the
Permittee shall submit a monitoring well As-Built report for all new wells installed to
document said well constmction for Executive Secretary approval. Said report shall
comply with the requirements of Part LF.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.
c) 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. 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.
5. Background Groundwater Quality Report for Well MW-35 and New Monitoring Wells -
within 30 calendar days of Executive Secretary approval of the new monitoring well As-
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Part I.H
Pemiit No. UGW370004
built Report, required by Part I.H.4, above, 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 the new wells 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 intemal 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 iriformation, 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 LE.l(b) or (c), and establish
Groundwater Compliance Limits in Table 2 for well MW-35 and the each of the new
wells.
6. 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 westem 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 westem
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 stmctural high area of the upper Bmshy 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 Cbttonwood 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 Bmshy 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.
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PartLH
Permit No. UGW370004
b) Demonstrate the full geologic and physical extent of the apparent unsaturated
stmctural high between Tailings Cell 4B and the westem 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.
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
PartI.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 westem
margin of White Mesa.
3) A revised stmctural contour map for the upper Bmshy 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.
7. Modification to the DMT Monitoring and Cell 4A and Cell 4B BAT O&M Plans - on or
before August 1, 2011, the Permittee shall submit proposed modifications to the currentiy
approved DMT Monitoring and Cell 4A and Cell 4B BAT O&M Plans for Executive Secretary
approval. Said changes shall conform to the requirements of Parts I.D.3(b), LD.6(c), I.D. 13(c),
I.E.7(b), I.E.8(b), LE.l2( b), and LE.l 1 of this PemiiL
38
Partfl
Permit No. UGW370004
PART n. REPORTING REQUIREMENTS
A. REPRESENTATIVE SAMPLING. Samples taken in compliance with the mohitoring 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
StateofUlah
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. COMPLL\NCE SCHEDULES. Reports of compliance or noncompliance with, or any progress reports
on interim and final requirements contained in any Compliance Schedule ofthis 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
frequentiy than required by this Permit, using approved test procedures as specified in this
Pemiit, the results of this monitoring shall be included in the calculation and reporting ofthe 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.
39
PartH
Permit No. UGW370004
H. RETENTION OF RECORDS. The Permittee shall retain records of all monitoring informatioh,
including all calibration and maintenance records and copies of all reports required by this
Permit, and records of all data used to complete the application for this Permit, for a period of at
least five years from the date of the sample, measurement, report or application. This period may
be extended by request of the Executive Secretary at any time.
I. NOTICE OF NONCOMPLIANCE REPORTING.
1. The Permittee shall verbally report any noncompliance which may endanger public health or
the environment as soon as possible, but no later than 24-hours from the time the Permittee
first became aware of the circumstances. The report shall be made to the Utah Department of
Environmental Quality 24-hour number, [phone], or to the Division of Water Quality,
Ground Water Protection Section at [phone], during normal business hours (8:00 am
- 5:00 pm Mountain Time).
2. A written submission shall also be provided to the Executive Secretary within five calendar
days of the time that the Permittee becomes aware of the circumstances. The written
submission shall contain:
a) A description of the noncompliance and its cause;
b) The period of noncompliance, including exact dates and times;
c) The estimated time noncompliance is expected to continue if it has not been corrected;
and,
d) Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance.
3. Reports shall be submitted to the addresses in Part H.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 E.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.
40
Partm
Permit No. UGW370004
PART m. COMPLIANCE RESPONSIBILrTIES
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 constmed 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 MmGATE. 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 tb 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.
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Part IV
Pemiit No. UGW370004
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 significantiy change the nature ofthe 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 ariy
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 fumish 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 fumish to the Executive
Secretary, upon request, copies of records required to be kept by this Pennit
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 pennit 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,
42
Part IV
Pemiit No. UGW370004
b) The authorization specified either an individual or a position having responsibility forthe
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
responsibihty, 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, tme, 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 FALSMCATION 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 ifany provision ofthis Permit, or
the application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this Permit, shall not
be affected thereby.
L. TRANSFERS. This Permit may be automatically transferred to a new Permittee if:
1. The current Permittee notifies the Executive Secretary at least 30 calendar days in advance
of the proposed transfer date;
43
Part IV
Permit No. UGW370004
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 constmed 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 pemiit modification is necessary to protect human heahh
or the environment.
44
State of Utah
GARY R. HERBERT
Governor
GREG BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
Rusty Lundberg
Dave Rupp and Loren Morton
July 13,2011
Statement of Basis for Minor Modification to DUSA Ground Water Discharge
Permit (the Permit); Reduced Slimes Drain Recovery Elevation (SDRE) for Cell
2 Monitoring Frequency: Change of SDRE Testing to Quarterly Monitoring from
Monthly Monitoring
See attached markup of the current Permit, last modified on Febmary 15, 2011. This proposed
markup is a monitoring change for the subject SDRE from monthly to quarterly IPart I.D.3(b),
etc:].
This change was proposed by DUSA in three (3) submittals from DUSA dated Febmary 25, May
27, and June 17, 2011. After review of the requested change in monitoring frequency, the DRC
considers the proposed change to be a minor modification to the permit, and it is recommended
we proceed with the change, as this action has the potential to 1) increase the annual volume of
slimes drain wastewater pumped from Cell 2, and 2) reduce the volume of wastewater stored in
the Cell 2 tailings, that otherwise might have potential to leak to underlying soil and groundwater
without this change.
Additional collateral changes were also made to the Permit, including:
A. Parallel changes for Cells 3, 4A and 4B slimes drain SDRE monitoring, as shown
in various locations in the permit text. These are related to the following Permit
sections:
a. Consistent performance standards for Cells 4A and 4B [shown in Parts LD.6(c)
and I D. 13(c)].
b. Consistent monitoring requirements for Cells 2 and 3 [Part I.E.7(b)] and Cells
4A and 4B [Parts LE.8(b) and I.E.12(b)],
c. Consistent reporting requirements for Cells 2 and 3 [Part I.F. 11]. Reporting
requirements for Cells 4A and 4B will need to be added to the Permit at a
future date when dewatering begins there.
B. Change to the Cell 2 Slimes Drain Performance Standard - The mathematics of
195 North 1950 West • Salt Uke City, UT
Maihng Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utoh.gov
Printed on 100% recycled paper
Page 2
Equation 1 given in I.D.3(b)(3) are changed to accommodate the new quarterly
monitoring frequency. This formula is used to determine and compare the average
head of three earlier years (years 2, 3 and 4 years ago) in the slimes drain, to the
average annual head of the three most current years (years 1, 2, and 3 years ago).
The purpose of this formula change is to equally weight the entries for new
quarterly readings with the former monthly readings. Thus, the fewer quarterly
readings will not be diminished in weight relative to the former monthly readings
in calculation of annual average head.
C. New compliance schedule item at Part I.H.7 to require DUSA to update / revise the
DMT Monitoring and the Cell 4A and 4B BAT O&M plans to reflect this change.
D. The July 11, 2011 effective date for use of quarterly monitoring [Part I.D.3(b)(2)],
and the August 1, 2011 deadline for DUSA to submit the revised DMT and BAT
monitoring plans [Part I.H.7], were provided as a means of expediting
implementation of the new monitoring frequency, and to encourage DUSA
progress in de-watering the Cell 2 tailings.
Attachment: Changes to G.W.P. 07-14-11 SDRE Mos to Quarterly Monitoring.doc
Pennit No. UGW370004
STATE OF UTAH
DFVISION 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, Titie 19, Chapter 5, Utah Code
Aimotated 1953, as amended, the Act,
Denison Mines (USA) Corp.
Independence Plaza, Suite 950
1050 if ^ 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 Pennittee 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 Pemiit 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 ,2011
Co-Executive Secretary
Utah Water Quality Board
Table of Contents
PART I. SPECIFIC PERMIT CONDITIONS 1
A. GROUND WATER CLASSMCATION 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 STANDAJO^S 6
1. DMT Design Standards for Existing Tailings Cells 1, 2, and 3 6
2. Existing Tailings Cell Constmction Authorized ....8
3. Existing Facility DMT Performance Standards 8
4. Best Available Technology Requirements for New Constmction..... 1144-1^
5. BAT Design Standards for Tailings Cell 4A ll
6. BAT Performance Standards for Tailings Cell 4A 14444^
7. Definition of 1 le.(2) Waste 14
8. Closed Cell Performance Requirements i54|44
9. Facility Reclamation Requirements 1515H
10. Stormwater Management and Spill Control Requirements 15
11. Requirements for Feedstock Material Stored Outside the Feedstock Storage Area
164^
12. BAT Design Standards for Tailings Cell 4B : 16444^
13. BAT Performance Standards for Tailings Cell 4B I9m^
14. BAT Performance Standards for the New Decontamination Pad 19
E. GROUND WATER COMPLIANCE AND TECHNOLOGY PERFORMANCE MONITORING ..... 213430
1. Routine Groundwater Compliance Monitoring 212120
2. Groundwater Monitoring: General Monitoring Wells MW-20 and MW-22...... 222324
3. Groundwater Head Monitoring 223334
4. Groundwater Monitoring Well Design and Constmction Criteria 223334
5. Monitoring Procedures for Wells..... ......233133
6. White Mesa Seep and Spring Monitoring.. 233^33
7. DMT Performance Standard Monitoring 243433
8. BAT Performance Standard Monitoring 253534
9. On-site Chemicals Inventory 26262&
10. Tailings Cell Wastewater Quality Monitoring 26363^
11. Groundwater Monitoring Modifications 272726
12. BAT Performance Standard Monitoring 273236
F. REPORTING REQUIREMENTS 283^
1. Routine Groundwater Monitoring Reports 282827
2. Routine DMT Performance Standard Monitoring Report 29393^
3. Routine BAT Performance Standard Monitoring Reports 303029
4. DMT and BAT Performance Upset Reports 303039
5. Other hiformation 303039
6. Groundwater Monitoring Well As-Buih Reports 303039
7. White Mesa Seeps and Springs Monitoring Reports 313430
8. Chemicals Inventory Report , 323334
9. Tailings Cell Wastewater Quality Reports 323334
10. Revised Hydrogeologic Report 323334
11. Annual Slimes Drain Recovery Head Report ......323231
12. Decontamination Pads Annual Inspection Report 333332
i
G. OUT OF COMPLIANCE STATUS .....333333
1. Accelerated Monitoring Status 333333
2. Violation of Permit Limits 333332
3. Failure to Maintain DMT or BAT Required by Permit 333333
4. Facility Out of Compliance Status 3d3^33
H. COMPLIANCE SCHEDULE REQUIREMENTS. 353^34
1. On-site Chemicals Inventory Report 35353^
2. Infiltration and Contaminant Transport Modeling Work Plan and Report 35353^
3. Plan for Evaluation of Deep Supply Well WW-2 36363#
4. Installation of New Groundwater Monitoring Wells 373^36
5. Background Groundwater Quality Report for New Monitoring Wells 373736
6. Detailed Southwest Hydrogeologic Investigation 383837
PART IL REPORTING REQUIREMENTS 404039
A. REPRESENTATIVE SAMPLING. '. 404039
B. ANALYTICAL PROCEDURES. 404039
C. PENALUES FOR TAMPERING 404039
D. REPORTING OF MONITORING RESULTS 404039
E. COMPLIANCE SCHEDULES 404039
F. ADDITIONAL MONITORING BY THE PERMITTEE 404039
G. RECORDS CONTENTS 404039
H. RETENTION OF RECORDS 414439
I. NOTICE OF NONCOMPLIANCE REPORTING 414440
J. OTHER NONCOMPLIANCE REPORTING 414440
K. INSPECTION AND ENTRY 414440
PART m. C0MPLL\NCE RESPONSIBILITIES 424344
A. DUTY TO COMPLY 424344-
B. PENALTIES FOR VIOLATIONS OF PERMIT CONDITIONS 424344-
C. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE 424344
D. DUTY TO MITIGATE 424344
E. PROPER OPERATION AND MAINTENANCE 424344
PART rv. GENERAL REQUIREMENTS 434343
A. PLANNED CHANGES.... 434343
B. ANTICIPATED NONCOMPLIANCE 434343
C. PERMIT ACTIONS 434343
D. DUTY TO REAPPLY 434343
E. DUTY TO PROVIDE INFORMATION 434343
F. OTHER INFORMATION 434343
G. SIGNATORY REQUIREMENTS 434343
H. PENALTIES FOR FALSIFICATION OF REPORTS ; 4^1'1^-13
I. AVAILABILITY OF REPORTS 4^'11^3
J. PROPERTY RIGHTS 4^^1113
K. SEVERABILITY 444443
L. TRANSFERS 4^^^d3
M. STATE LAWS 454$44
N. REOPENER PROVISIONS 454M4
11
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 114440
Table 5. Approved Tailings Cell 4A Engineering Design and Specifications. 11
Table 6. Approved Tailings Cell 4B Engineering Design and Specifications 164644
Table 7. Groundwater Monitoring Reporting Schedule 29393^
111
Part I.A & I.B
Permit No. UGW370004
PART 1. 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
Average TDS (mg/L)
DUSA Data
Class in Groundwater
Average TDS (mg/L)
DUSA Data
Well
ID
Average
Concentration^^^
Standard
Deviation^^^ WelllD
Average
Concentration^^^
Standard
Deviation^^^
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^'^ 18 2,605 297
MW-19^^^ 22 2,457 900
MW-20^'*^ 7 5,663 114
MW-22^'^^ 8 7,537 365
MW-3A 9 5,547 129
MW-23 10 3,443 244
MW-24 10 4,116 117
MW-25^^^ 11 2,843 67
MW-26^^^ 12 ' ' 3,155 65
MW-27^'^ 10 1,019 28
MW-28 11 3,677 87
MW-29 8 4,380 27
MW-31 10 1,265 50
MW-32^'*^ 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 weU MW-18 (55.1 ng/L) and diallium in MW-19 (2.1 ^g/L) exceed the GWQS, 30 ^g/L and 2.0
Ug/L, respectively. Therefore these wells have been classified as Class in groundwater rather than Class 11 groundwater.
4) Wells MW-20 and MW-22 are not point of comphance monitoring wells, but instead are general 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, 2010. This data was obtained from the Permittee's Background Groimdwater Quality Report for wells MW-20 and MW-22 dated
June, 2010.
5) Background concentration of manganese in well MW-25 (1,806 ^g/L) exceeds the GWQS, therefore well MW-25 has been classified as Class
III groundwater rather than Class 11 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 CompUance (POC) well for the tailings cells (see Part I.E. 1).
7) Background concentrations of uranium in well MW-27 (34 ng/L) and selenium in MW-31 (71 (ig/L) exceed the GWQS, therefore these wells
have been classified as Class III groundwater rather than Class II groundwater.
8) Well MW-32 was originally named TW4-17 and was installed as part of the chloroform contaminant investigation at the facility. Under this
Permit it is included as a POC well for the tailings cells in Part I.E. 1.
B. BACKGROUND WATER QUALITY - based on groundwater samples collected through June 2007 for
existing wells (MW-1, MW-2, MW-3, MW-5, MW-11, MW-12, MW-14, MW-15, MW-17, MW-
18, MW-19, MW-26, and MW-32) and through December 2007 for new wells (MW-3A, MW-23,
MW 24, MW-25, MW-27, MW-28, MW-29, MW-30 and MW-31), the upper boundary of
1
Part I.B & LC
Pemiit No. UGW370004
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 bf other compounds such as paints, used oil, antifreeze,
pesticides, or any other contaminant not defined as 1 le.(2) material is prohibited.
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PartLD
Permit No. UGW370004
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
constmction as described by design and constmction 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
Constmction
Specifications
Celll Design June, 1979 D'Appolonia
Consulting Engineers, Inc
Appendix A, Sheets 2,4, 8,
9,12-15
Appendix B
Cell 2 Design June, 1979 D'Appolonia
Consulting Engineers, Inc
Appendix A, Sheets 2, 4, 7-
10,12-15
Appendix B
As-Built February, 1982 D'Appolonia
Consulting Engineers, Inc
Figures 1, 2, and 11 N/A
Cell 3 Design May, 1981 D'Appolonia
Consulting Engineers, Inc
Sheets 2-5 Appendix B
As-Built March, 1983 Energy Fuels
Nuclear, Inc. ^"^^
Figures 1-4 N/A
Footnotes:
1) D'Appolonia Consulting Engineers, inc., Jime, 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 hiitial Phase - Taihngs 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, hic. May, 1981, "Engineer's Report Second Phase Design - Cell 3 Taihngs IVIanagement System White
Mesa Uranium Project Blanding, Utah Energy Fuels Nuclear, bic. Denver, Colorado", unpubUshed 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.", unpubhshed 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 - constmcted 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 constmcted
on the east margin of the pond, which forms a continuous earthen stmcture 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)
constmcted of solvent welded seams on a prepared sub-base. Top elevation ofthe
FML liner was 5,618.5 ft amsl on both the south dike and the north cut-slope. A
protective soil cover layer was constmcted immediately over the FML with a
thickness of 12-inches on the cell floor and 18-inches on the interior sideslope.
3) Cmshed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of cmshed 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.
PartLD
Pennit No. UGW370004
b) Tailings Cell 2 - which consists of the following major design elements:
1) Cross-valley Dike - constmcted 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 constmcted 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 constmcted of native
sands fi'om on-site excavated soils.
3) Cmshed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of cmshed 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 constmcted 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 mn 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 - constmcted 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 constmcted 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 ofall
other disposal cell FML liners.
3) Cmshed Sandstone Underlay - immediately below the FML a nominal 6-inch thick
layer of cmshed sandstone was prepared and rolled smooth as a FML sub-base layer.
Beneath this underlay, native sandstone and other foundation materials were graded
Part LD
Pemiit No. UGW370004
to drain to a single low point near the upstream toe of the south cross-valley dike.
Inside this layer, an east-west oriented pipe was installed to gather fluids at the
upstream toe of the cross-valley dike.
4) Slimes Drain Collection Layer and System - immediately above the FML, a nominal
12-inch (cell floor) to 18-inch (inside sideslope) soil protective blanket was
constmcted 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 mn ofthe 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 Constmction Authorized - tailings disposal in existing Tailings Cells
1, 2, and 3 is authorized by this Permit as defined in Table 3 and Part LD.l, 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 constmction 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) Quarterly Monthly Slimes Drain Recovery Test Prior to the date of this permit
amendment, the permittee conducted monthly Slimes Drain Recovery^ Tests. After
the date of this amendmenteffective July 11; 201 L the Permittee shall conduct a
quarterly 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
8
Part I.D
Pemiit No. UGW370004
ii. Achieves a stable water level at the end of the test, as measured by three
consecutive hourly water level depth measurements, with no change in water
level, as measured to the nearest 0.01 foot.
3) Armual Slimes Drain Compliance - shall be achieved when the average annual
wastewater recovery elevation in the slimes drain access pipe, as determined pursuant
to the currentiy approved DMT Monitoring Plan, meets the conditions in Equation 1,
below:
Equation 1:
[ IBy + IBy-1 + EEy-2 ] / [Ny + Ny.l + Ny.2 ] < [ EEy-1 + lEy.2 + EEy.3 ] / [ Ny.l + Ny.2 + Ny.3 ]
Where:
EEy = Sum of all monthly and quarterlv slimes drain tailings fluid elevation measurements that
meet the test perfonnance standards foimd in the sub-paragraphs of 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 applicable frequency and method of the currently
approved DMT Monitoring Plan at the time of each SDRE test, these recovery tests are to be
conducted monthl>^ and the SDRE values reported in units of feet above mean sea level (amsl).
However, ^earterly samples^when tf-monthly and quarterlv measurements are combined ased-in the
above equation above with monthly samples, the quarterly values shall be multiplied by a coefficient
of three (3V4e-equivalently compare the quarterlv to the monthlv SDRE tests.
2^.1 = Sum of all SDRE measurements made in the year previous to the calendar year of
interest. However, when monthlv and quarterly measurements are combined samples, if used in the
equation above, each quarterlv value with monthlv samples, shall be multiplied by a coefTicient of
three (3) to equivalently compare the quarterlv to the monthlv SDRE teste.
rEy-2 = Sum of all SDRE measurements made in the second year previous to the calendar year of
interest. However, when monthly and quarterlv measurements are combinedsamples. if used in the
equation above, each quarterlv values -wilh-monthlv samples, shall be multiplied by a coefficient of
three (3)-to equivalontly compare the quarterlv to the monthlv SDRE tests.
rEy.3 = Sum of all SDRE measurements made , in the third year previous to the calendar year of
interest. However, when monthlv and quarterlv measurements are combinedsamples, if used in the
equation above, each quarterly value with monthly sampks^shall be multiplied by a coefficient of
three (3)-to equivalently compare the quarterly to the monthly SBRE-tests.
Ny = Total number of SDRE tests that meet the test performance standards foimd in Part
I.D.3(b)(2), conducted during the calendar year of interest. However, when monthlv and quarterlv
measurements are t6ster4f-used in the equation above, each quarterly test -with monthlv tests, shall be
counted as three (3) separate tests^rto equivalently compare the quarterly to the monthly number-ef
Ny.l = Total number of SDRE tests that meet the test performance standards foimd in Part
I.D.3(b)(2), conducted in the year previous to the calendar year of interest. However, when monthly
and quarterly measurements are tests, if used in the equation above, each quarterly with monthly tests,
shall be counted as three (3) separate tests, to oquivalently compare the quarterly to the monthlv
number of tests.
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. However, when
monthlv and quarterly measurements are tests, if used in the equation above, each quaiterly -with
monthlY-tests, shall be counted as three (3) separate tests, to equivalently compare the quarterly to the
monthlv number of-tests.
PartLD
Permit No. UGW370004
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. However, w^hen
monthlv and quarterly ,measurements are tests, ij^used in the equation above, each quarterly ^with
monthly tests, shall be counted as three (3) separate tests, to equivalently compare the quarterly to the
monthly number of tests.
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.
Report for
Calendar
Year
Source of Data By Calendar Year for Equation 1 Variables (right side) Report for
Calendar
Year By.] Ev-2 Ev-3 Nv., Nv.2 Nv.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 Elevatiori - upon closure of any tailings cell, the
Permittee shall ensure that the maximum elevation of the tailings waste solids does not
exceed the top of the FML liner.
d) DMT Monitoring Wells - at all times the Permittee shall operate and maintain Tailings
Cells 2 and 3 to prevent groundwater quality conditions in any nearby monitoring well
from exceeding any Ground Water Compliance Limit established in Table 2 of this
Permit.
e) Roberts Pond - the Permittee shall operate this wastewater pond so as to provide a
minimum 2-foot freeboard at all times. Under no circumstances shall the water level in
the pond exceed an elevation of 5,624 feet amsl. In the event that the wastewater
elevation exceeds this maximum level, the Permittee shall remove the excess wastewater
and place it into containment in Tailings Cell 1 within 72-hours of discovery. At the time
of mill site closure, the Permittee shall reclaim and decommission the Roberts Pond in
compliance with a final Reclamation Plan approved under the License (hereafto:
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 eastem 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 LD.l 1. 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.
10
PartLD
Pennit No. UGW370004
Table 4. Feedstock Storage Area Coordinates (1)
Comer 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 Irom the extreme northeast comer 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
constmction 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.
Best Available Technology Requirements for New Constmction - any constmction,
modification, or operation of new waste or wastewater disposal, treatment, or storage
facilities shall require submittal of engineering design plans and specifications, and prior
Executive Secretary review and approval. All engineering plans or specifications submitted
shall demonstrate compliance with all Best Available Technology (BAT) requirements
stipulated by the Utah Ground Water Quality Protection Regulations (UAC R317-6). Upon
Executive Secretary approval this Permit may be re-opened and modified to include any
necessary requirements.
BAT Design Standards for Tailings Cell 4A - the BAT design standard for Tailings Cell 4A
shall be defined by and constmction 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
Engineerins 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
Sheets of7 June 15, 2007 Rev. 1 Lining System Details I
Sheet 6 of 7 June 15, 2007 Rev. 1 Lining System Details n
Sheet 7 of 7 June 15, 2007 Rev. 1 Lining System Details IH
11
Part I.D
Pemiit No. UGW370004
Figure 1 August, 2008 -Spillway Splash Pad Anchor
Engineering Specifications
Date Document Title Prepared by
June, 2007 Revised Technical Specifications for the
Constmction of Cell 4A Lining System
Geosyntec Consultants
June, 2007 Revised Constmction Quality Assurance Plan for
the Constmction of Cell 4A Lining System
Geosyntec Consultants
March 27, 2007 Revised Geosynthetic Clay Liner Hydration
Demonstration Work Plan
Geosyntec Consultants
November 27, 2006 Cell Seismic SUidy 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 Geosyntec Consultants
August 22, 2006 Pipe Strength Calculations Geosyntec Consultants
September 27, 2007 DMC Cell 4A - GCL Hydration Geosyntec Consultants
Footnotes:
1) AsquaUfiedbyconditionsfoundinMay2,2007 Division of Radiation Control letter.
2) As clarified by February 8, 2007 Division of Radiation Control Round 6 Interrogatory.
Tailings Cell 4A Design and Constmction - approved by the Executive Secretary will consist
of the following major elements:
a) Dikes - consisting of existing earthen embankments of compacted soil, constmcted by the
Permittee between 1989 and 1990, and composed of four dikes, each including a 15-foot
wide road at the top (minimum). On the north, east, and south margins these dikes have
slopes of 3H to IV. The west dike has an interior slope of 2H to IV. Widtii 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 21 l-
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 comers.
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 4 A floor area. In other locations, tiie primary FML will
be in contact with the slimes drain collection system (discussed below).
12
PartLD
Pemiit No. UGW37O004
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 comer. 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 sunounded with a
gravel filter set in the leak detection sump, having dimensions of 10 feet by 10 feet by
2 feet deep. In tum, 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 pattem across the floor
of Cell 4A that drain to a "backbone" of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed inimediately 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 tum overlain by
a berm of gravel that mns the entire diagonal length of the cell, surrounded by a
geotextile fabric cushion in immediate contact with the primary FML. In tum, 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 mns from the far northeast comer downhill to the far southwest comer 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 comer, above the primary FML.
Said pipe then merges with another horizontal pipe of equivalent diameter and
13
PartLD
Peraiit No. UGW370004
material, where it is enveloped by gravel and wbven 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 constmcted 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 constmcted near the
westem comer of the north dike to allow emergency mnoff 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
stmcmre will be constmcted at Cell 4A. All stormwater mnoff 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 hiaintain
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:
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(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 1 le.(2) Waste - for purposes of this Permit, 1 le.(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 1 le.(2) of
14
PartLD
Pemiit No. UGW370004
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, constmction, 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 bf precipitation of 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 intemal 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.e. 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
constmct a cover system over the tailings cells in comphance 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 comphance 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 ofthe State.
10. Stormwater Management and Spill Control Requirements - the Permittee will manage all
contact and non-contact stormwater and control contaminant spills at the facility in
accordance with the currently approved Stormwater Best Management Practices Plan. Said
plan includes the following minimum provisions:
a) Protect groundwater quality or other waters ofthe state by design, constmction, 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(0),
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.
Reconstmction 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.
15
PartLD
Pennit No. UGW370004
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, constmcted, 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
LD.4,
3) A storage area that provides containment berms to control stormwater mn-on and
mn-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 Taihngs Cell 4B - the BAT design standard for Tailings Cell 4B
shall be defined by and constmcted 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
Engineerin g 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
Sheets of 8 December 2007 Rev. 0 Lining System Details I
Sheet 6 of 8 January 2009 Rev. 1 Lining System Details n
Sheet 7 of 8 January 2009 Rev. 1 Lining System Details HI
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
Geosyntec Consultants
16
PartLD
Pennit No. UGW370004
Calculation Package
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 Constmction - approved by the Executive Secretary will consist
of the following major elements:
a) Dikes - consisting of newly constmcted dikes on the south and west side ofthe 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 southem and westem dikes will have typical slopes of 3H to IV. Limited
portions of the Cell 4B interior sideslopes in the northwest comer and southeast comer of
the cell, (where the slimes drain and leak detection sump will be located will also have a
slope of 3H to IV. The base width of the southem dikes varies from approximately 92
feet at the westem end to approximately 190 feet at the eastem 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 comer to the southeast comer.
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 tiie
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).
17
Part I.D
Pemiit No. UGW370004
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 comer. 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 sunounded 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 tum, 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 ofat 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 pattem across the floor
of Cell 4B that drain to a "backbone" of perforated collection pipes. These strip
drains are made of a prefabricated two-part geo-composite drain material (solid
polymer drainage strip) core surrounded by an envelope of non-woven geotextile
filter fabric. The strip drains are placed immediately over the primary FML on 50-
foot centers, where they conduct fluids downgradient in a southwesterly direction to a
physical and hydraulic connection to the perforated slimes drain collection pipe. A
series of continuous sand bags, filled with filter sand cover the strip drains. The saiid
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 tum 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 tum, 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 mns from the far northwest comer downhill to the far southeast comer 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 comer, 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
18
Part I.D
Pemiit No. UGW370004
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
constmcted 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 ofthe 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 constmcted near the
southeastem comer of the east dike to allow emergency mnoff 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 cushibn 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 stmcture will be constmcted at Cell 4B. All stormwater mnoff 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 approved Cell 4B 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 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 - shafl 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 tiie 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
19
PartLD
Pennit No. UGW370004
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 constimte 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
currentiy approved DMT Monitoring Plan. Cracks in the wash pad greater than 1/8 inch
(width) will be repaired within five working days of discovery.
20
Part LE
Permit No. UGW370004
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 follov/ing wells:
1) Upgradient Wells: none
2) Lateral or Downgradient Wells: MW-11, MW-14, MW-25, MW-26 (formerly TW4-
15), MW-30, MW-31, and MW-35.
3) Fumre Cell 4B Downgradient Wells to be Installed - quarterly monitoring shall begin
within 30 calendar days of installation of new groundwater monitoring wells MW-36,
MW-37, or any other well required by Part LH.4 of this Permit, and continue until
otherwise determined by the Executive Secretary pursuant to Part I.H.5.
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 ofthis 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 Wefls: 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, temperamre, specific conductance, and
redox potential (Eh).
2) Laboratory Parameters
21
Partl.E
Pennit No. UGW370004
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
WaterComplianceXimit 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 ertor
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 basis. Said sampling shall comply
with the following Permit requirements:
a) Routine groundwater compliance monitoring requirements of Part LE.L
b) Groundwaterheadmonitoringrequirements of Part LE.3
c) Well monitoring procedure requirements of Part LE.5.
3. Groundwater Head Monitoring - on a quarterly basis and at the same frequency as
groundwater monitoring required by Part LE.l, 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 LE.l of this Permit.
b) Piezometers-P-1, P-2, P-3, P-4, and P-5.
c) Head Monitoring Wefl - MW-34.
d) General Monitoring WeUs - MW-20 and MW-22.
e) Contaminant Investigation Wells - any well required by the Executive Secretary as a part
of a contaminant investigation or groundwater corrective action.
f) Any other wells or piezometers required by the Executive Secretary.
4. Groundwater Monitoring Well Design and Constmction Criteria - all new groundwater
monitoring wells installed at the facility shall comply with the following design and
constmction criteria:
22
Part I.E ' •
Pennit No. UGW370004
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 constmcted in compliance with UAC R317-6-6.3(I)(6), including tiie 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 afler 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 manufacmrer's procedures and guidelines. The Permittee
shall make and preserve on-site written records of such equipment calibration in
accordance with Part II.G and H of this Permit. Said records shall identify the
manufacmrer'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 ofthis
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:
23
Partl.E
Pennit No. UGW370004
1) Ground Water Quality Standards concentrations defined in Table 2 ofthis Permit,
and
2) For TDS, Sulfate, and Chloride, the Minimum Detection Limit for those constiments
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 currentiy 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.
DMT Performance Standards Monitoring - the Permittee shall perform technology
performance monitoring in accordance with the cunently approved DMT Monitoring Plan
to determine if DMT is effective in minimizing and controlling the release of contaminants
pursuant to the provisions of Parts LD.l and I.D.3 of this Permit, including, but not limited
to the following activities:
a) Weekly Tailings Wastewater Pool Elevation Monitoring: Cells 1 and 3 - the Permittee
shall monitor and record weekly the elevation of wastewater in Tailings Cells 1 and 3 to
ensure compliance with the maximum wastewater elevation criteria mandated by
Condition 10.3 of the License. Said measurements shall be made from a wastewater level
gauge or elevation survey to the nearest 0.01 foot.
_b) Quarterly Monthly Slimes Drain Water Level Monitoring: Cells 2 and 3 - the Permittee
shall monitor and record quarterly monthlv 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
quarterly period of each calendar year that meets 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 hcensed engineer or land surveyor, r
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
24
Partl.E
Permit No. UGW370004
DMT operations standards in Part I.D.3. Said measurements shall be made in accordance
to the cunently approved DMT Monitoring Plan.
d) Weekly Feedstock Storage Area Inspection - the Permittee shall conduct weekly
inspections of aU 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 altemate feedstock materials located outside the Feedstock Area defined in
Table 4, are stored in accordance with the requirements found in Part LD.l 1.
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 constmcts a hardened
surface storage area for feed materials, pursuant to Part I.D.ll, 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 currentiy 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 LG.3 by implementation
of the currently approved Liner Maintenance Provisions, and 2) report all repairs made
pursuant to Part I.F.2.
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.
Cell 4A BAT Performance Standards Monitoring and Maintenance - in accordance with the
currentiy approved Cell 4A BAT, Monitoring, Operations and Maintenance Plan, 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 fiilly
operational within 24-hours of discovery shall constimte 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
25
Part LE
Pemiit No. UGW370004
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
Taihngs Cell 4A. Said measurements shall be made to the nearest 0.1 foot.
b) Quarterly Slimes Drain Recovery Head Monitoring - immediately after the Permittee
initiates pumping conditions in the Tailings Cell 4A slimes drain system, monthly
quarterly 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 Plan.
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 Cefl 4A
Constmction Quality Assurance Plan (CQA/QC Plan) as found in Table 5 of this Permit.
Repairs shall be performed by qualified liner repair personnel and shall be reported in a
Liner Repair Report, certified by a Utah licensed Professional Engineer. The Liner Repair
Report shall be submitted to for Executive Secretary approval in accordance with Part
I.F.3 of the Permit. Any leak, hole, or other damage to the liner will be reported to the
Executive Secretary pursuant to the requirements found in Part I.G.3.
9. On-site Chemicals Inventory - the Permittee shall monitor and maintain a cument 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 1,3,4 A, 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 inimediately 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.
26
Part I.E
Pennit No. UGW370004
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
constiments 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 Febmary,
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 ofthe currently approved QAP; pursuant to Part I.E. 1 of
this Permit. Said QC samples shall include, but are not limited to: trip blanks,
duplicate samples, and equipment rinse blanks.
7) Prior Notification - at least 30 calendar days before any water quality sample
collection, the Permittee shall provide vmtten 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 - inimediately following
Executive Secretary approval of the Cell 4B BAT, Monitoring, Operations and Maintenance
Plan, the Permittee shall inimediately implement all monitoring and recordkeeping
requirements therein. The Cell 4B BAT monitoring shall include the following:
a) Weekly Leak Detection System (LDS) Monitoring - including:
27
Part I.E & I.F
Pennit No. UGW370004
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 LD S pumping or related monitoring equipment not repaired and made
fiilly operational within 24-hours of discovery shall constimte 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 constimte failure of B AT, 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. Underno circumstances shall the average
daily LDS flow volume exceed 26,145 gaflons/day.
4) 3-foot Minimum Vertical Freeboard Criteria - the Permittee shalF operate and
maintain wastewater levels to provide a 3-foot Minimum of vertical freeboard in
Tailings Cell 4B. Said measurements shall be made to the nearest 0.1 foot.
b) Quarterly Slimes Drain Recovery Head Monitoring - inimediately after the Permittee
initiates pumping conditions in the Tailings Cell 4B slimes drain system, monthly
quarterly 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 Plan.
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
Constmction 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
LE.l, I.E.2, I.E.3, and LE.5 of this Permit for Executive Secretary review and approval.
Reports shall be submitted according to the following schedule:
28
Part I.F
Pemiit No. UGW370004
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 ofsample
containers and preservatives. /
b) Laboratory Results - or copies thereof that provide the following: date and time sampled,
date receiyed 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 yerify 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 constiments: chloride, fluoride, sulfate, and uranium.
Routine DMT Performance Standards Monitoring Report - the Permittee shall provide
quarterly monitoring reports of all DMT performance standards monitoring required by Parts
29
Part I.F
Pennit No. UGW370004
I.D.3 and I.E.7 of this Permit. DMT monitoring shall be conducted in compUance with this
Pennit 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 quarteriy 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 tiiis Permit. BAT Monitoring at CeUs 4A and 4B shaU
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 quarteriy 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 wiU include:
a) LDS Monitoring - including:
1) Report on the operational stams of the LDS pumping and monitoring equipment
during the quarter, including identification of any intervals of non-operational stams
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
l.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 LD in accordance with tiie 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 incortect infonnation 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 tiie following information:
a) Geologic Logs - that detail all soil and rock lithologies and physical properties of all
subsurface materials encountered during drilling. Said logs shall be prepared by a
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Part I.F
Permit No. UGW370604
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 constmction,
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 constmction 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 3'^'^ Quarter Routine
Groundwater Monitoring Report due on December 1, of each calendar year. S aid 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.l(b) ofthis 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 3'"'^ 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) ofthis
Permit, and
g) Survey data for the seeps and springs shall be based on an elevation survey, conducted
under the direction of and certified by a Utah licensed professional engineer or land
surveyor. The survey will include State Plan Coordinates (northings and eastings) and
31
PartLE
Peraiit No. UGW370004
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.I. 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 3"^
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 Pennittee 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 FV.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 Pemiit, 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 aimual 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 ofthis Peraiit, 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.
32
Partl.F&I.G'
Peraiit No. UGW370004
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 shaU provide written descriptions and fmdings 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) ofthis
Permit.
12. Decontamination Pads Annual Inspection Report - the New Decontamination Pad and
Existing Decontamination Pad will be taken out of service and inspected aimually during the
second quarter of each year, to ensure integrity of the coricrete wash pad surfaces. If physical
defects in the wash pad as defined by Part LD.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 2"^* Quarter DMT Momtoring
Report due September 1, of each calendar year.
G. OUT OF COMPLIANCE STATUS
1. Accelerated Monitoring Stams - 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 LE.l(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 stams of the facility can be determined by the Executive Secretary.
2. Violation of Permit Limits - out-of-compliance stams 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-
33
PartLG
Permit No. UGW370004
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.
Facility Out of Compliance Stams - if the facility is out of compliance, the following is
required:
a) The Permittee shall notify the Executive Secretary of the out of compliance stams within
24-hours after detection of that stams, followed by a written notice within 5 calendar days
of the detection.
b) The Permittee shall continue accelerated sampling pursuant to Part l.G.l, 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 ofthe 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 riot 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 altemative DMT or BAT for approval by the Executive Secretary.
34
PartLH
Peraiit No. UGW370004
H. COMPLL\NCE 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 ofthis
Permit. The Permittee shall submit an infiltration and contaminant modeling for Executive
Secretary approval, that:
a) Identifies all applicable and pertinent historic smdies 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. AU 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 concepmal model used and justifies why it is representative or
conservative of acmal field conditions at the site. Said concepmal model will identify the
physical domain(s) and geometries simulated including the tailings cell design and
constmction, all boundary and initial conditions assigned ih the model(s), and the
shallow aquifer locations where fumre potential contaminant concentrations have been
predicted.
35
PartLH
Permit No. UGW370004
e) Justifies how the infiltration and contaminant transport problem has been adequately
concepmalized, 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 Resiilts - 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 fumre
time to re-assess its ability to represent site characteristics and predict long-term
performance of tailings cell design and constmction, 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 constmction 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 ofthe final
infiltration and contaminant transport report, the Reclamation Plan may be modified to
accommodate necessary changes to protect public health and the environment.
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 shaU:
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,
36
PartLH
Pennit No. UGW370004
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 constmction 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. Installation of New Groundwater Monitoring Wells - the Permittee shall instaU at least
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-36 and MW-37 - install at least two new
compliance monitoring wells (MW-36 and MW-37),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 samrated thickness of at least 5-feet, inside the
well screen, as measured from the upper geologic contact ofthe Bmshy Basin
Member of the Morrison Formation, or as approved by the Executive Secretary.
5) All new wells shall provide early detection of tailings cell contamination of
shallow groundwater from Tailings Cell 4B.
6) All new wells shall provide discrete groundwater monitoring for tailings Cell 4B.
b) On or before June 30, 2011 or as otherwise approved by the Executive Secretary, the
Permittee shall submit a monitoring well As-Built report for all new wells installed to
document said well constmction 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.
c) 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. 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.
5. Background Groundwater Quality Report for Well MW-35 and New Monitoring Wells -
within 30 calendar days of Executive Secretary approval of the new monitoring well As-
37
PartLH
Permit No. UGW370004
built Report, required by Part I.H.4, above, 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 LE.l.
b) WeU monitoring procedure requirements of Part LE.5.
c) After completion of eight consecutive quarters of groundwater sampling and analysis of
well MW-35 and the new wells required by Part LH.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, includirig, but
not limited to, evaluation of data characteristics and intemal 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.
6. 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 westem margin
of White Mesa, including Westwater and Cottonwood Seeps, and Ruin Spring, and 2) the full
physical extent of unsamrated area between former well MW-16, MW-33 and the westem
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 stmcmral high area of the upper Bmshy Basin Shale Member
geologic contact and 2) the horizontal limits of samration in the Burro Canyon
Formation. Said smdy 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 Bmshy Basin Shale Member,
2) Piezometers or wells that intercept the shallow aquifer and encounter a samration
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) ofthis Permit.
38
Part I.H
Permit No. UGW370004
b) Demonstrate the full geologic and physical extent of the apparent unsamrated
stmctural high between Tailings Cell 4B and the westem 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.
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 LF.6.
2) A revised equipotential map to describe both the physical extent ofthe dry zone
and all groundwater flow directions near Tailings Cell 4B and Westwater and
Cottonwood Seeps, and Ruin Spring. Said map shall demonstrate flowpaths
(steammbes) to all respective groundwater discharge locations at the westem
margin of White Mesa.
3) A revised stmcmral contour map for the upper Bmshy Basin Shale for the facility
and physical extent of White Mesa.
4) A revised samration 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.
7. Modification to the DMT Monitoring and Cell 4A and Cell 4B BAT O&M Plans - on or
before August L 2011, Tthe Permittee shall submit proposed modifications, as needed, to
the currently approved DMT Monitoring and Cell 4A and Cell 4B BAT O&M Plans for
Executive Secretarv approval. Said changes shall T4e-conform to the quarterly
monitoring requirements of Parts I.D.3rb). LD.6(c). I.D.13rc). I.E.7(b), I.E.8(b). I.E. 12(b),
and I.F.I 1 of this Ppermit amendment, on or before ^5 davs after of the signed dat&-ef
this Permit AmendmeBi.
39
Part II
Peraiit No. UGW370004
PART IL 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
reportirig period:
Attention: Compliance and Monitoring Program
StateofUlah
Division of Water Quality
Department of Environmental Quality
Sah 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 witii, or any progress reports
on interim and final requirements contained in any Compliance Schedule ofthis 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
frequentiy than required by this Permit, using approved test procedures as specified in this
Permit, the results ofthis monitoring shall be iricluded in the calculation and reporting ofthe 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.
40
Part II
Peraiit No. UGW370004
H. RETENTION OF RECORDS. The Permittee shall retain records of all monitoring information,
including all calibration and maintenance records and copies of all reports required by this
Permit, and records of all data used to complete the application for this Permit, for a period ofat
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, (801) 53 8-6333, or to tiie 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 reoccurtence 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 facihty or activity is located or
conducted, or where records must be kept under the conditions ofthe 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.
41
Part III
Peraiit No. UGW370004
PART III. COMPLIANCE RESPONSIBILITIES
A. DUTY TO COMPLY. The Permittee must comply with all conditions of this Permit. Any Permit
noncompliance constimtes 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 tiie 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 VIOLAT[ONS 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 negligentiy 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 constmed 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 compUance with the conditions of this Permit.
D. DUTY TO MIHGATE. 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 aU 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 compUance with the conditions of the Permit.
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PART W. 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 namre 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 ofthis 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 fumish 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 fumish 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 promptiy 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.
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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 occup)dng 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, tme, 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 b>^ both.
I. AVAILABILITY OF REPORTS. Except for data determined to be confidential by the Permittee, all
reports prepared in accordance with the terms of this Permit shall be available for public
inspection at the offices of the Executive Secretary. As required by the Act, permit applications,
permits, effluent data, and groundwater quality data shall not be considered confidential.
J. PROPERTY RIGHTS. The issuance of this Permit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local laws or regulations.
K. SEVERABILITY. The provisions of this Permit are severable, and if any provision of this Permit, or
the application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this Permit, shall not
be affected thereby.
L. TRANSFERS. This Permit may be automatically transferred to a new Permittee if:
1. The current Permittee notifies the Executive Secretary at least 30 calendar days in advance
of the proposed transfer date;
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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 constmed to preclude the instimtion of any legal
action or relieve the Permittee from any responsibilities, liabilities, penalties estabhshed pursuant
to any applicable state law or regulation under authority preserved by Section 19-5-115 ofthe
Act.
N. REOPENER PROVISIONS. This Permit may be reopened and modified (following proper
administrative procedures) to include the appropriate limitations and compliance schedule, if
necessary, if one or more of the following events occurs:
1. If new ground water standards are adopted by the Board, the Permit may be reopened and
modified to extend the terms of the Permit or to include pollutants covered by new standards.
The Permittee may apply for a variance under the conditions outlined in R317-6-6.4(D).
2. Changes have been determined in background groundwater quality.
3. The Executive Secretary determines permit modification is necessary to protect human health
or the environment. ,
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